No one wants risk – particularly risk that can be harmful to people or the environment. That’s why Benchmark has developed a thorough formaldehyde emissions certification program that conforms to EPA and CARB regulations. The best part? It’s flexible and allows you to choose an approach that meets your production and sales objectives – at an affordable cost. Here’s what you need to know.
About EPA and CARB Regulations
Eligibility & Process
About EPA/CARB Regulations
Formaldehyde emissions of composite wood products took center stage in 2008 when the California Air Resources Board (CARB) enacted its Airborne Toxic Control Measure (ATCM) to Reduce Formaldehyde Emissions from Composite Wood Products Section 93120 – 93120.12 (commonly referred to as “CARB ATCM 93120”). Then, in 2016, the U.S. EPA published its Formaldehyde Standards for Composite Wood Products (40 CFR Part 770) regulation, which added Title VI to the U.S. Toxic Substances Control Act (TSCA Title VI).
Both TSCA Title VI and CARB ATCM 93120 regulations set forth formaldehyde emission standards and certification requirements for composite wood products including hardwood plywood (HWPW), medium density fiberboard (MDF), and particleboard (PB). EPA and CARB regulations also require that component parts and finished goods must be made using only certified composite wood products. Compliance to CARB Phase 2 formaldehyde emission standards and requirements is currently mandatory for all composite wood panels and finished goods containing composite wood products that are manufactured, imported, distributed, or sold in the state of California. EPA TSCA Title VI regulations took effect on June 1, 2018, and compliance is currently required for all composite wood panels, laminated products, component parts and finished goods manufactured or imported into the United States.
For a hardwood plywood, MDF, or particleboard panel to be certified as conforming to CARB ATCM 93120 or EPA TSCA Title VI regulations, the panels must have been produced by either 1) a manufacturer who is independently certified by an EPA/CARB-approved Third Party Certifier (TPC), or 2) a manufacturer who has obtained exemption from third party certification on the basis of the use of Ultra-Low Emitting Formaldehyde (ULEF) or No-Added Formaldehyde (NAF) resins. The manufacturer must perform routine quality control testing of the composite wood products it produces to verify the products meet EPA and CARB formaldehyde emission standards and is labeled accordingly. Additional documentation, record-keeping, and TPC oversight and independent testing requirements also apply.
In addition, EPA TSCA Title VI regulations also require that laminated products consisting of a wood or woody-grass (e.g., bamboo) veneer adhered to a TSCA Title VI-certified HWPW, MDF, or PB platform using a formaldehyde-containing resin must also be third-party certified. Laminated product producers must achieve TSCA Title VI certification by a qualified third-party certifier on or before March 22, 2024 unless such entities are exempt on the basis of the use of No-Added Formaldehyde (NAF) or phenol resins. Exempted laminated product producers are required to comply with additional record-keeping requirements as specified in the TSCA Title VI regulation.
Benchmark’s certification approach is designed to rigorously evaluate a manufacturer’s production operation and products in light of EPA and CARB requirements, while also providing an affordable and flexible program structure that can be tailored to meet your specific production and sales objectives.
Because each manufacturing operation is different, the time needed to achieve certification varies due to a number of factors including the complexity of the certification effort and the client’s current state of readiness. Whatever the situation, our certification process is straight forward, and we work hard to ensure you are supported throughout the process. From helping you to understand your obligations to providing you with practical testing solutions, we’ll be with you every step of the way.
Eligibility and Process
Determining eligibility is a critical step in ensuring that certification is the right path for you. While we aren’t bound to geographical location, it is important to know who is required to pursue EPA/CARB formaldehyde certification.
Producers of plywood, MDF, or particleboard panels.
Producers of laminated products (defined as a wood or bamboo veneer adhered to an underlying EPA-certified plywood, MDF or particleboard panel using a formaldehyde-containing resin).
What’s the general certification process?
As mentioned, the methodical process Benchmark applies ensures a thorough approach to deliver you the peace of mind you need.
- Client submits completed application for EPA/CARB certification
- Benchmark reviews application, confirms initial eligibility, and defines the tentative scope of certification
- Benchmark and client sign certification agreement
- Client selects method for conducting routine formaldehyde quality control testing
- Client prepares a Quality Control Manual and submits to Benchmark for approval
- Benchmark conducts initial site audit to validate compliance
- Benchmark completes initial qualification testing and quality control test method correlations as required by EPA and CARB regulations
- Certification review
- Certification decision making and document preparation
The bottom line:
Certification to EPA/CARB formaldehyde regulations isn’t something that should be taken lightly, and we understand how overwhelming the process may seem. Don’t sweat it. Give us a call. We’ve got your back.