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EPA Toxic Substance Control Act (TSCA) Title VI

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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.

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