A Primer for Understanding Formaldehyde Regulations

What is Formaldehyde?

Formaldehyde is a naturally occurring chemical found in homes and buildings (and in your body if you overindulge in alcohol). Fortunately, it breaks down in the environment and within our bodies quickly. It’s not all sunshine and rainbows, prolonged exposure to high levels of the compound can lead to respiratory issues and even cancer. Below is a list of common items that contain formaldehyde:


Examples of Common Environmental Emitters of Formaldehyde

Plywood, MDF, Particleboard Carpet Insulation Air Fresheners
Cigarettes/Tobacco Glues and Resins Gas Stoves/Ovens Household Cleaners
Architectural/LVL Lumber Fabric softeners Engineered/Laminate Floors Wood Stoves/Space Heaters
Wrinkle-Free Cloths Personal Care Products Furniture Coatings and Finishes
Cabinetry Latex Paint/Wallpaper Fabric Softeners Cosmetics


Forest Products and Formaldehyde

There are many forest products that emit formaldehyde into the environment. All of these products fall into what is classified as composite wood products. They are products that are made by combining multiple pieces of wood together using glue. The resin or glue that holds the products together are often the reason for the emission. For decades formaldehyde was utilized to control the speed that a resin hardened and cured, the more formaldehyde, the faster the resin cured. As regulations were put into place, the amount of formaldehyde was decreased and the conditions and methods used to create the composite wood products were more closely monitored.


Who Regulates this Stuff?

In 1984, HUD 24 CFR 3280.308 became the standard for manufactured homes in the U.S. and regulated the amount of allowable formaldehyde that could come from a product. Fast forward to 2008, and the California Air Resources Board created CARB ATCM 93120, that regulates products that can be imported and sold into the state of California. The CARB rule, regulated the allowable limits of formaldehyde and created a system of Third Party Certifiers (TPC) that certify the process a manufacturer utilizes to meet the standard. In 2016, the Environmental Protection Agency (EPA) created the Toxic Substance Control Act (TSCA) Title VI, which regulates emission standards for all U.S. states and territories. TSCA Title VI also sets who can be a TPC and what the requirements of manufacturers, laminators, importers, distributors, and retailers are regarding the rule. Each set of rules, has their own detailed testing procedures, reporting standards, and document retention policies.


What is a TPC?

A TPC is an accredited company that verifies the accuracy of emission test procedures and facilities processes, evaluates and monitors the manufacturer/laminated product producer quality control programs, and provides independent audits and inspections of manufacturer/laminated product producer facilities. The TPCs must meet strict standards and be accredited to perform the duties required by the rules. Benchmark Holdings is an example of an accredited TPC for both CARB and TSCA Title VI.


What Does a TPC Do?

As part of both the requirements for TSCA Title VI and CARB ATCM 93120, TPCs evaluate the processes and procedures of companies who produce materials that fall under the rules. The TPC must perform a series of document reviews, laboratory and mill inspections, and product testing to make sure that all requirements are met. A mill’s process can then be certified, but certification is dependent on periodic testing, sampling, and inspections. Any failure to meet part of the requirements can lead to loss of certification.

EPA Toxic Substance Control Act (TSCA) Title VI

With the Environmental Protection Agency’s new Toxic Substance Control Act (TSCA) Title VI going into effect 12 December 2017, there are a lot of questions still unanswered about the Act. Fortunately, there are published answers regarding some elements of the rule. Here are the answers to some of the most common questions:

Who are some of the accreditation bodies?


Examples of EPA-approved Accreditation Bodies

American Association for Laboratory Accreditation (A2LA) Product certification and laboratory
ANSI-ASQ National Accreditation Board (ANAB) Laboratory only
International Accreditation Service (IAS) Product certification and laboratory
American National Standards Institute (ANSI) Product certification only

Who are third-party certifiers (TPC)?

An AB-accredited entity that:

  • Verifies the accuracy of emission test procedures and facilities used by HWPW, MDF, and PB manufacturers and laminated product producers to conduct formaldehyde quality control tests
  • Evaluates and monitors manufacturer/laminated product producer quality control programs
  • Provides independent audits and inspections of manufacturer/laminated product producer facilities, processes, and records

What are the limits for formaldehyde?

EPA TSCA Title VI Formaldehyde Emission Limits:

Formaldehyde Emission Limits: ppm
HWPW-VC 0.05
HWPW-CC 0.05
Particleboard 0.09
MDF >8mm thick 0.11
Thin-MDF ≤8mm thick 0.13
Laminated Products (wood/woody grass veneer attached to TSCA-certified platform) 0.05

Even though the rule does not go into effect until later in the year, labeling of the products can begin as early as 25 August 2017. Benchmark International has already begun preparing our clients for the new regulation, including creating a comprehensive training program. For more information, visit our webpage on EPA Regulations or contact us and see what we can customize for you.

CARB 2 Formaldehyde Testing and Compliance

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.