Joint Industry Statement: 60 Minutes Report

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Good Morning,

Please see the joint industry statement related to a 60 Minutes story about Lumber Liquidators and specifically concerning the utilized test methodology to measure formaldehyde. As the second accredited laboratory engaged by 60 Minutes for small chamber analysis of deconstructed flooring samples the attached statement is reflective of our opinion of the ARB SOP.

Without preference to any party involved in the 60 Minutes report and from a purely technical aspect, there exist nearly limitless production and processing variables that will impact the original emission profile of a regulated composite wood product. In current conversations taking place throughout the market there exists an assignment of explicit compliance with the emission requirements of the Airborne Toxic Control Measure. In our opinion this is an improper way to view any test result utilizing the ASTM D6007 test method – either when measuring emissions from a ‘raw’ regulated panel and especially from a ‘deconstructed’ regulated panel. From the ASTM D6007-14 method alone:

13. Precision and Bias
  • 13.1 A study including seven laboratories and four test materials was conducted in accordance with Practice E691 and resulted in the following statements for precision and bias.
  • 13.1.1 Repeatability – Test results indicate a repeatability (within laboratory) precision standard deviation ranging from 0.01 to 0.02 for products emitting 0.06 to 0.24 ppm of formaldehyde.
  • 13.1.2 Reproducibility – Test results indicate a reproducibility (laboratory) precision standard deviation ranging from 0.02 to 0.05 for products emitting 0.06 to 0.24 ppm of formaldehyde, respectively.

We fully support the efforts of the California Air Resources Board to improve indoor air quality. Benchmark actively participates with the agency as changes are made to the CARB ATCM and we maintain an open door policy for members of the Air Resources Board to enter our laboratory at all times; the United States Environmental Protection Agency accepted the same offer and has spent time in our laboratory while promulgating the U.S. National Formaldehyde Regulation. Our concern for the quality of air in homes, offices, schools and commercial structures is now being extended into even more stringent regulatory schemes such as the California Department of Public Health Section 01350 which we cover through our VOC Green program. Indoor air quality is important and clean air benefits everyone.

The circumstances surrounding the current conversations and search for answers regarding the different test methods utilized by different entities has compelled us to provide this simple analysis – Precise, reproducible results from material tested using ASTM D6007 is difficult at best. The variability found in the 2013 CARB Interlaboratory Comparison (Benchmark ID: NN) demonstrates this.

We are not discounting the SOP as irrelevant, it can be used as a tool by technically competent and trained regulatory agencies to warrant further investigation into a product. We do not agree with the assignment of explicit ‘compliance’ or ‘non-compliance’ of a product when tested in this manner.

The opportunity to participate with a storied institution such as 60 Minutes was an honor for us. Each of us here can replay the voices of Safer, Cronkite, Rooney and many others which we heard so often growing up. Our decision to participate with this project came from a sense of responsibility that we needed to try our best to explain a highly complex environmental regulation and the test methods used – the ATCM has many nuances that are difficult to grasp. This statement too is born from a sense of responsibility – we are being bombarded with questions from every corner of the nation about this issue. Applying precise measurement techniques to an inhomogeneous product created in an imperfect manufacturing environment is impractical. The merits of the language of the ATCM can be argued by attorneys, politicians and regulators and is not a discussion we will enter. Opening a dialogue concerning the technical aspects of test methods used within the regulation is a discussion we have entered before and continue to participate in today.

Sincerely,

Travis R. Snapp
Managing Director, Benchmark International (BMI)
Chief Operating Officer, Benchmark Holdings (BMH)

CARB 2 Formaldehyde Testing and Compliance

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Recently, the CBS program 60 Minutes aired a piece on Chinese-made laminated flooring that was tested for formaldehyde emissions. Benchmark International was one of the labs hired to test products purchased and supplied by 60 Minutes. Benchmark International tested all products provided using CARB’s testing methodology and standard operating procedures.

Travis Snapp’s testimony to the Subcommittee on Fisheries, Wildlife, Oceans and Insular Affairs

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On May 16, 2013, Benchmark International COO Travis Snapp testified before the Subcommittee on Fisheries, Wildlife, Oceans and Insular Affairs during the Oversight Hearing on “The 2008 Lacey Act Amendments.”

The video below features excerpts of Travis’ testimony from that hearing.

EPA Releases US National Formaldehyde Proposals

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CARB Large Chamber TestingThe EPA recently released a new regulation to protect the public from exposure to formaldehyde. This new regulation includes additional products not covered by CARB and will impact multiple businesses throughout the wood products industry at both the primary and secondary points of manufacture.

We’re Here to Help

At Benchmark International, we’re here to support the industry and help you make sense of new laws. As we study this latest regulation, we will keep you updated with what you need to do. If you have any questions, please don’t hesitate to contact us at 1-541-484-9212 or email  info@benchmark-intl.com.

Join Us for a Free Webinar

In the near future, Benchmark, in conjunction with Oregon State University’s Wood Science Engineering Department, will hold a free webinar to address the implications of the formaldehyde regulation. Watch for an announcement and invitation to follow.

Read a Summary of the Regulation

We’ve included a summary of the new regulation below, straight from the EPA website. To view the full regulation, click here. We’ve also included two in-depth prepublication versions of the proposed EPA rules:

Formaldehyde Emissions Standards for Composite Wood Products;Proposed Rule [RIN 2070-AJ92; FRL-9342-3]

Formaldehyde; Third-Party Certification Framework for the Formaldehyde Standards for Composite Wood Products[RIN 2070-AJ44; FRL 9342-4]

Proposed Rules to Implement the Formaldehyde Standards for Composite Wood Products Act (TSCA Title VI)

CARB Small Chamber TestingThe EPA proposed two rules aimed at protecting the public from the risks associated with exposure to formaldehyde. The first proposal would implement formaldehyde emission standards under TSCA Title VI, and would apply to hardwood plywood, medium-density fiberboard, particleboard, and finished goods containing these products that are sold, supplied, offered for sale, or manufactured (including imported) in the United States.

The second proposal would establish a framework for a third-party certification program to ensure that composite wood panel producers comply with the formaldehyde emission limits established under TSCA Title VI.

These rules will protect people against the risks posed by formaldehyde emitted from composite wood products. These rules will also put in place one national set of standards for companies that manufacture or import these products and ensure the same protections for all Americans.

This rule also includes implementing provisions for:

First Proposed Rule: Formaldehyde Standards for Composite Wood Products Act Implementing Regulation

As required by the law, the first proposal sets limits on how much formaldehyde may be released from composite wood products, including hardwood plywood, medium-density fiberboard, particleboard and finished goods containing these products, that are sold, supplied, offered for sale, manufactured, or imported in the United States. It also includes protective yet common sense exemptions from some testing and recordkeeping requirements for products made with no-added formaldehyde resins. This proposal includes additional implementing provisions for:

  • Laminated products
  • Testing requirements
  • Product labeling
  • Chain of custody documentation, and other recordkeeping requirements
  • Enforcement
  • Product inventory sell-through provisions, including a product stockpiling prohibition

Second Proposed Rule: Third-Party Certification Framework

The law also requires the establishment of a third-party certification program to ensure that composite wood panel producers comply with the established emission limits. Under the proposed framework, third-party certifiers (TPCs) would be required to apply to EPA-recognized accreditation bodies who would verify the certifiers’ ability to ensure that panel producers comply with the formaldehyde emission standards. Under this rule, TPCs would audit composite wood panel producers and verify compliance with the formaldehyde emission standards.

  • TPCs would be responsible for activities such as:
  • Regularly auditing composite wood panel producers
  • Conducting and verifying formaldehyde emissions tests
  • Ensuring that panel producers’ quality assurance/quality control procedures and testing complies with the TSCA Title VI implementing regulations

Benchmark International holds the following accreditations, which are all proposed requirements of the EPA regulation:

ISO/IEC Guide 65 Accredited

ISO/IEC 17020 Inspection Agency Accredited

ISO/IEC 17025 Testing Laboratory Accredited

Welcome to the new BMH website.

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Dear Friends,

Welcome to the new Benchmark International website! We hope you like its easy-to-navigate, enhanced features. We’re always looking for ways to serve you better, and this site will help us achieve that goal.

Use our new site to learn more about our testing, engineering design, inspection and certification services. We offer the widest range of testing options for wood, flooring, concrete and steel products at the most competitive prices.

Be sure to check out the new Featured Clients section, which includes a detailed listing of some of our clients’ companies and products. We are proud to represent each one of them.

Here are a few reasons our clients choose us for all their testing and certification needs:

We work with you one-on-one. As a boutique service provider, we are able to develop personal relationships with each client. We’re with you every step of the way during the testing process.

We don’t sell you unnecessary services. We are proud of our reputation as one of the few testing agencies that won’t sell you services you don’t need. We strive for honesty and accuracy every day—and that’s exactly what we deliver.

We are experts in our field. Our team has years of experience in the forest, composite, concrete and steel products industries. With roots that date back 60 years, we are one of the oldest accredited testing labs anywhere in the world! Today we’re carrying on testing services that originally began in 1956—and we’re only getting better. If you have a product that needs to be tested, we can generate a solution for you.

Thank you for visiting our site. We hope you’ll put our services to the “test.”

Sincerely,

Travis R. Snapp
Managing Director and Chief Operation Officer, BMH