How the New Formaldehyde Regulation Will Affect Door and Window Manufacturers
by Samantha Carpenter
The State of California, through its Air Resources Board, is in the final stage of developing an Air Toxic Control Measure (ATCM) for particleboard, medium-density fiberboard (MDF) and hardwood plywood—collectively known as composite wood.
In 1983, the California Legislature established a two-step process (AB 1807) of risk identification and risk management to address the potential health effects from airborne toxic substances and to reduce their risks. During the first step, the California Air Resources Board (CARB) and the California Office of Environmental Health Hazard Assessment (COEHHA) determine if a substance meets the definition of a toxic air contaminant, and to what extent. If a substance is determined to be a toxic air contaminant, the CARB begins the process of risk management. In this step, CARB evaluates the need, feasibility and cost of reducing emissions of a particular substance.
A Bit of History
Formaldehyde was identified as a toxic air contaminant by CARB more than 14 years ago. The COEHHA has determined that no safe exposure threshold level existed for formaldehyde to preclude cancer. The U.S. Environmental Protection Agency has classified formaldehyde as a “probable human carcinogen” under conditions of high or prolonged exposure. The International Agency for Research on Cancer (IARC) also concluded that formaldehyde is a probable human carcinogen.
During the identification of formaldehyde in 1992, CARB evaluated formaldehyde exposure in California and found that one of the major sources of exposure is from inhalation of formaldehyde emitted from formaldehyde resin-containing composite-wood products. An estimated 2.5 billion square feet of composite wood products (such as particleboard, MDF, hardwood, plywood and composite veneer) are sold in California annually. While CARB recognizes that other formaldehyde emission sources exist, emissions from composite wood products also contribute to an individual’s daily exposure to formaldehyde.
The Composite Panel Association (CPA) has spearheaded a coalition called the California Wood Industry Coalition to work aggressively with CARB to come up with an ATCM acceptable to the composite-wood industry. The coalition is comprised of a number of associations, including the CPA, American Home Furnishings Alliance, Kitchen Cabinet Manufacturers Association, American Forest and Paper Association, Hardwood Plywood and Veneer Association, Association of Woodworking and Furnishings Suppliers, Window and Door Manufacturers Association and Wood Moulding and Millwork Producers Association.
Tom Julia, president of the CPA, spoke with DWM magazine about how the ATCM on formaldehyde emissions originated. He said the regulation has been in the works for almost 15 years. But only in the past four years has CARB been actively pursing the regulation.
Effects on Manufacturers
Julia spoke further on behalf of the CPA, which he says represents about 95 percent of companies that produce composite wood products in North America. The CPA feels that mitigating formaldehyde emission is a laudable goal, and it has been supportive of reducing those emissions.
According to Julia, the CPA operates the largest third-party certification program of its kind in North America. It certifies, tests and audits products from companies that make [composite-wood products] in the U.S. and Canada, and the association just started to do it in Mexico. He says the critique the CPA and the wood coalition has is something he calls “the law of unintended consequences.”
“We think we are a very green—one of the greenest industries in the world,” Julia says. “The worst thing that could happen here—in our view from a public-policy standpoint or a consumer standpoint—is if the result of this rule causes manufacturers of cabinets, wood, etc., to shift away from composites and move to virgin materials—either harvested here in the United States or coming from offshore. Our stance would be that’s not a good environmental story—if you are going to move from an engineered component (something that’s recycled) and move to a solid wood. I think that CARB understands [this concern].”
Door and Window Manufacturer (DWM) magazine contacted a number of manufacturers of doors and windows as well as related building products, but many didn’t want to comment on what effect this would have on their companies. There were also many that didn’t know enough about the subject to comment or they do not use formaldehyde in their manufacturing process.
There were a few manufacturers who did comment on what impact this regulation would have on their businesses.
Chris Leffel, vice president of sales and marketing for SierraPine Ltd. of Roseville, Calif., (a manufacturer of composite panel products) has been involved in this rulemaking since its inception in 2001. This involvement has included presenting product and manufacturing process information to help the state understand the implications of their proposed regulation.
“This rule could have serious impacts for SierraPine, depending on the final emission levels CARB adopts and on how they plan to enforce this regulation,” Leffel says. “We don’t think we can meet their Phase II levels on either the particleboard or MDF products we produce using standard resin technology. Being forced to go to an alternative resin technology will significantly raise our costs, not to mention the other negative tradeoffs with these alternative resins.”
Peter McKibbin, senior vice president of Contact Lumber, a manufacturer of door components, door frames and other millwork products, says his company is really interested in this proposed ATCM.
“As a result, our director of quality, David Shayegi, in our Prineville operation is heavily involved with the Window and Door Manufacturers Association (WDMA) and we are going to react accordingly.”
No Significant Impact
Some manufacturers aren’t as concerned about the ATCM.
“In talking to our production staff, this has no bearing on us at this time since we are not involved in the manufacture of any of these products,” says Dean Stewart, director of sales and marketing for Heritage Veneered Products of Shawano, Wis., manufacturer of WOODPORT® interior hardwood stile and rail doors. “The only long-term effect we are concerned about is the increased cost or limited availability of these products from manufacturers who need to be in compliance. We have seen no impact yet other than some increased particleboard costs.”
“In today’s environment it is essential that manufacturers hold themselves accountable to insure their products’ quality and materials are produced with standards that serve to protect this world we live in,” says Noel E. King, technical director for Royal Mouldings of Marion, Va. “Based on information from our data sheets and paint supplier, our products contain no formaldehyde (other than the possibility of trace amounts which would not be required to be reportable).”
Some companies won’t be affected negatively, but positively.
John McIsaac, public relations manager for Columbia Forest Products of Portland, Ore., says that his company has been represented at every CARB stakeholder meeting and public workshop since April of this year.
“It certainly won’t have a negative effect. Last year, we began converting all our hardwood plywood plants to a formaldehyde-free manufacturing process and introduced to the market PureBond, a cost-neutral, formaldehyde-free, hardwood plywood panel …” McIsaac explains.
“We support the ATCM because our plywood achieves Phase II levels now. It’s funny: a lot of our competition is griping about the ATCM out of one side of its mouth, claiming it will cost Californians jobs and countless millions of dollars,” McIsaac says. “On the other side, several of our competitors are launching formaldehyde-free products of their own.”
SierraPine was one company that recently launched a formaldehyde-free product.
“The development of ARREIS was in no way linked to the California regulation. However, because it is a no-added formaldehyde (NAF) product, it will meet the proposed CARB regulation and all other worldwide standards for formaldehyde emissions easily,” says Leffel, who adds that SierraPine has been producing no-added formaldehyde products for nearly 18 years.
Enforcing the Formaldehyde Regulation on Imports
The CPA and wood coalition’s second concern has to do with imports.
According to CARB, California imports about 55 percent of its furniture products.
“We expect that through increased enforcement due to the proposed ATCM, these numbers will decrease to some extent. On the slide presentation
(http://www.arb.ca.gov/toxics/compwood/arbpresentation062006.pdf), you will find preliminary cost estimates,” says Gennet Paauwe, CARB office of communications.
Many in the CPA and the wood coalition fear that imports won’t decline with the formaldehyde ATCM, but that they will increase.
According to Julia, the United States is increasingly consuming wood products from abroad, specifically the Asian countries of China, Vietnam and Malaysia.
“What we have emphasized to CARB is that if they put a rule in place and they [can only enforce it against the U.S. manufacturer], then they are going to significantly drive up the cost to the consumer. What’s going to happen? You are going to further open the door to offshore products that don’t comply. How are you going to test these products from China or Vietnam? How are you going to know that it is really meeting the grade—that it’s really coming in at a low emission level,” poses Julia.
SierraPine agrees that there needs to be enforcement.
“If CARB is unable to come up with an enforcement approach that truly creates a level playing field, our customers will find themselves in an even worse situation as they compete with suppliers of finished and semi-finished products produced outside of California – especially offshore imports,” Leffel adds.
The ATCM on formaldehyde emissions for composite wood is expected to be phased in starting in 2008 and a second phase in 2010. For more information, view CARB’s presentations at:
Samantha Carpenter is a contributing editor for DWM magazine.
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No reproduction of any type without expressed written permission.