CARB-ATCM
California Air Resources Board (CARB) approved in 2007 a new standard of formaldehyde emissions controls named the Airborne Toxics Control Measure (ATCM). The measurement implements standard formaldehyde emissions ratings for all wood and manufactured wood products (including particleboard, hardwood, plywood, medium-density fiberboard, and also finished products manufactured with wood parts). The plan consists of two phases and requires manufacturers to comply with rigid standards for items that includes a wood product for manufacturing, sale, use, or supply within the state of California. The CARB study informs that substandard composite wood products currently induce household formaldehyde emissions up to 5%.
New Standards
The ATCM is determined to bring California standards up to meet existing formaldehyde emissions standards of Japan and Europe. The Japanese JIS/JAS Formaldehyde Adhesive Emission Standards was defined by the Japanese Industrial Standards (JIS) in conjunction with the Japanese Agricultural Standards (JAS) department. Using the Desiccator Test Method, emissions released from the wood are measured and rated. Ratings are assigned as, F*, F**, F***, and F****. F**** has the least measure of formaldehyde emissions, below 0.005 mg/m2h.
In 2000, the European standards established by the European Panel Industry included E1, 9mg/100g and below, E2, greater than 9mg/100g to below 30mg/100g, and E3, greater than 30mg/100g. A new level classification that correlates to Japan’s higher standard has been recently developed, E0, based on emissions measuring 0.5mg and less per liter. Europeans use a different test method named the Perforator Test Method.
A Phased-In Approach
Phase 1 began on January 1, 2009. The first step exceeds previous levels set by OSHA already in effect. The new ATCM formaldehyde emission standards of equal to or less than 0.08 ppm (parts per million) took effect for hardwood, plywood, particleboard, and medium density fiberboard.
Phase 2 emission levels are reserved for a staggered release beginning in January of 2010 through 2012. This phase defines even higher standards for formaldehyde emissions in wood products, 0.05 ppm. This is a higher standard than even the European E0 rating.
Because of the economic circumstances the USA are experiencing, CARB declared an impediment in the enforcement of sell through dates on flooring materials made before January 1, 2009. While created to support distributors, importers, fabricators, and retailers of composite wood products affected by those regulations, it is not supported to order more products.
CARB officials enforced the sell through dates, after December 31, 2010, imposing penalty for those who do not follow the law. As plenty of Phase 1 compliant materials are being produced alongside materials working toward Phase 2 compliance. There is no need to extend beyond current inventory. Remaining pre-Phase 1 inventory cannot be sold within the state of California.
The prolonged deadline benefits businesses troubled by the slowing economy to recoup some of the potential damage caused by the original sell through date. Because the economic conditions remained steady, the benefits these regulations set forth will not be diminished by the extended sales deadline. All other compliance dates stated in the legislation remain the same.
Phase 1 standards should not call for retooling of factory equipment. The standards can be achieved using existing resin technologies already in production. Phase 2 will mean adjustments to new adhesive procedures using resin of two types: NAF (no-added formaldehyde) or ULEF (ultra-low-emitting formaldehyde).
How It Works
Manufacturers are demanded to be accredited by a “third party certifier,” an independent watchdog accepted by the ARB and expected to authenticate products turned out by manufacturers to be in compliance with applicable standards. Manufacturers are also required to label composite wood products to identify their Phase 1 or Phase 2 standards.
Post-manufacturing importers, distributors, fabricators, and retailers are required to purchase and sell only manufacturing products or finished goods that comply with the new ATCM formaldehyde emission standards. They are expected to communicate with suppliers and document that the manufacturing process used in any products meets the established applicable standards and keep a written record of purchase date and supplier, along with what procedures were undertaken to verify that purchased products meet the new standards.
Fabricators are required to provide similar labeling and documentation in order to ensure the steps from raw products to finished flooring , wallboard, or furniture.
The ATCM is California law and does not apply to goods manufactured or sold for shipment outside of California. The ATCM also exempts hardwood plywood and particleboard used for manufactured homes that are subject to regulations established and enforced by the U.S. Department of Housing and Urban Development (HUD).
Industry Concerns
Industry concerns include the cost of retooling to manufacture to the new standards, man-hour cost in terms of compliance testing and documentation, plus testing and certification issues. This measure puts small businesses at risk, making it difficult for them to compete using the more expensive manufacturing cost incurred.
Another concern is that of testing and enforcement. The question of just how to regulate such a large industry remains, and standardized testing procedures for Phase 2 compliance could prove an insurmountable challenge. CARB has instituted a reporting requirement within the regulatory board to track progress and suggest solutions during the first year Phase 1 rollout.
Beyond California
The ATCM currently affects California, but the impact is expected to go globally. Current U.S. law regarding formaldehyde emissions are inadequate, and the CARB study is an important health concern. Growing environmental concerns are providing the pressure and impetus necessary to influence lawmakers to make environmentally sound agreements. Environmentalists anticipate that this measure will be adopted across the board to reduce the formaldehyde emissions.