Volume 45, Issue 7 - September  2006

Unintended Consequences
Composite-Wood Industry Faces New Formaldehyde Regulation
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 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 ARB 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, medium-density fiberboard, 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 SHELTER magazine over the phone 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 it been actively in the works. 

“Really it’s a desire, and a commendable one, on the part of California to mitigate the impact of any chemical compound that would be perceived as a toxic chemical,” Julia explains. 

“Formaldehyde is one of the most common and studied compounds in the world. The body produces some of it everyday. It shows up in many consumer products; it is also used as the most common adhesive in composite-wood products. Because this is the type of chemical they would like to mitigate, California has decided to regulate it specifically in composite-wood products … I think it’s important to note to the consumer that about 98 percent of the emissions of formaldehyde, as they record them in California, is coming from someplace other than composite-wood products. Two-thirds of them are from automobiles, according to CARB’s own study,” Julia says.

Effects on Manufacturers

Manufacturers that use composite-wood products in their manufacturing processes aren’t too happy about the regulation.

“This has been pretty quiet for quite a few years. Now here they are, at it again. [They want formaldehyde levels] below the levels found in the natural environment. This seems more than a little bit ridiculous,” says Gary Bertch of Bertch Cabinet Mfg. of Waterloo, Iowa. “This will drive costs higher for U.S. manufacturers by imposing additional regulatory burdens with questionable benefits, at best, which makes no sense at all.”

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].”

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. 

“Those product by in large (some people may dispute this) do not comply with the environmental requirements that any products made in the United States or Canada comply with,” Julia says. “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.

Julia says the CPA tests products from all over the world. 

“Some of it we do on our own, some we do at the request of individual manufacturers. We know (and some things I can’t share because they are proprietary) that a lot of this product is not intending to meet even the current rules. Who is to believe that they would meet the future rules?” Julia asks. 

“In other words, the unintended consequence here is that [CARB] doesn’t have an enforcement scheme that can find a way to test the product coming in from offshore. What this is going to do is, unfortunately and potentially, open the door to more of this product coming in. And actually you can have higher emissions on products being sold to consumers. This runs the gamut from finished product, like cabinets and furniture to kitchen and bath cabinets, assembled furniture, ready-to-assemble furniture, but also could include flooring products, architectural mouldings, doors and windows—pretty much anything that could be made of a composite material. The scope is really massive on what it could affect,” Julia concludes.

This ATCM, like all other regulations in the making, are publicly discussed with all stakeholders prior to the board hearing date, which CARB expects to be sometime in the fall/winter timeframe, according to Paauwe.

CARB also holds meetings with stakeholders who want to discuss proposals, whether they are in-person or phone-in conference calls. 

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: http://www.arb.ca.gov/toxics/compwood/reg062006.pdf and http://www.arb.ca.gov/toxics/compwood/arbpresentation062006.pdf.

SHELTER
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