What is CARB?
The California Air Resources Board (CARB) is the clean air agency within the California Environmental Protection Agency (CalEPA). CARB established and implemented the Airborne Toxic Control Measure (ATCM) to Reduce Formaldehyde Emissions from Composite Wood Products (commonly referred to as “CARB 93120”).
In 1992, the state of California designated formaldehyde as a toxic air contaminant with no safe level of exposure. California state law requires CARB to take action to reduce human exposure to all substances designated as toxic air contaminants. CARB subsequently evaluated formaldehyde exposure in California and found that one of the major sources of exposure was from inhalation of formaldehyde emitted from composite wood products containing urea-formaldehyde resins. As a result, CARB developed the CARB 93120 regulation to limit the formaldehyde emissions of composite wood products and support its obligation to protect the health of California citizens.
What is CARB 93120?
The Airborne Toxic Control Measure (ATCM) to Reduce Formaldehyde Emissions of Composite Wood Products (commonly referred to as CARB 93120) is a set of regulations developed by CARB that establishes formaldehyde emission standards applicable to composite wood products and specifies requirements applicable to the manufacture, fabrication, import, distribution, and sale of these products in the state of California. The regulation also established a framework to define the requirements of Third Party Certifiers (TPCs) authorized to provide third party certification services to composite wood product manufacturers.
What types of products are subject to CARB 93120 regulations?
CARB 93120 applies to composite wood products including:
- Hardwood Plywood-Veneer Core (HWPW-VC)
- Hardwood Plywood Composite Core (HWPW-CC)
- Medium Density Fiberboard (MDF)
- Thin-MDF (medium density fiberboard £8mm thick)
In addition, finished goods such as cabinetry, furniture, and flooring constructed of or containing composite wood components are also subject to CARB 93120 requirements.
Who must comply with CARB 93120 regulations?
The following types of organizations are subject to CARB 93120 requirements:
- Manufacturers who produce composite wood products (hardwood plywood, medium density fiberboard, and particleboard) intended for import, distribution, or sale in the state of California
- Fabricators who use composite wood products to produce finished goods intended for import, distribution, or sale in the state of California
- Importers who import composite wood products (or finished goods containing composite wood products) into the state of California
- Distributors who distribute composite wood products (or finished goods containing composite wood products) within the state of California
- Retailers who sell composite wood products (or finished goods containing composite wood products) to consumers within the state of California
Who should get certified to CARB 93120?
Primary manufacturers of composite wood products who have established the required quality control systems and who wish to import, distribute, or sell their products in the state of California are eligible for third party certification. Alternately, manufacturers who use No-Added Formaldehyde (NAF) or Ultra-Low Emitting Formaldehyde (ULEF)-based resins may be eligible for exemption from CARB 93120 third party certification requirements. BMH will help you decide which method is best suited for your situation and will tailor a program to meet your specific certification needs.
Fabricators, importers, distributors, and retailers are not eligible for third party certification under CARB 93120 regulations. However, BMH has established programs to assist these entities who wish to verify their suppliers and the composite wood products they deliver conform to CARB 93120 requirements prior to secondary fabrication or distribution.
Are CARB 93120 standards only recognized in California?
Currently, CARB 93120 only addresses formaldehyde emissions and compliance of composite wood products manufactured, imported, distributed, or sold in the state of California.
When the United States (US) Senate Bill 1660 was signed into law in 2010, it established the Formaldehyde Standards for Composite Wood Products Act. This US federal law directs the U.S. Environmental Protection Agency (US EPA) to establish formaldehyde emission standards similar to that of CARB 93120 for composite wood products (and finished goods containing composite wood components) imported, distributed, or sold throughout the United States. The US EPA is currently working to craft the final regulation which is expected to be approved by early 2016. More information regarding pending EPA regulations for composite wood products can be found by visiting our website.
What is a TPC?
A Third Party Certifier (TPC) is an independent agency approved by CARB to issue certifications to manufacturers who have implemented the required quality control systems and demonstrated the ability to consistently produce composite wood products that meet CARB 93120 formaldehyde emission standards. TPC’s such as Benchmark International (TPC 2) are contracted by the manufacturer to independently audit their quality system and perform periodic formaldehyde emission tests to verify the manufacturer is consistently producing compliant products.
What are CARB-approved formaldehyde test methods?
CARB recognizes several methods for measuring formaldehyde emissions including, but not limited to.
Chamber Test Methods:
- ASTM E1333 Large chamber – primary method
- ASTM D6007 Small chamber – secondary method
Small-Scale Quality Control Test Methods:
- ASTM D5582 Desiccator – Small scale method
- JIS A 1460 Desiccator – small scale method
- EN 717-2 Gas analysis – small scale method
- EN 120 Perforator – small scale method
- DMC Dynamic micro chamber – small scale method
A complete list of CARB approved test methods can be obtained at http://www.arb.ca.gov/toxics/compwood/outreach/testmethods.htm
How can my company become CARB certified?
Composite wood product manufacturers who wish to become certified should contact BMH at 1.541.484.9212 for an initial consultation to help determine the best certification approach. Once an application and agreement are signed, BMH will work with you to:
- Establish a baseline of compliance
- Develop and refine a Quality Control (QC) manual
- Create a checklist of action items necessary to achieve CARB compliance
- Conduct an initial compliance audit
- Independently test product samples to verify conformance to CARB emission standards
Once you have successfully passed the initial certification audit and testing, BMH will issue the certification. We will then establish a schedule to conduct routine quarterly audits and collect samples for compliance testing to monitor ongoing conformance to CARB requirements.