Comments for Formaldehyde Proposal Due May 8May 5th, 2014 by DWM Magazine
The Environmental Protection Agency (EPA) extended the public comment period for its formaldehyde proposal, and a reminder to those who want to submit comments that they are due this week—May 8, 2014. The agency also hosted a public meeting in late April in Washington, D.C., to gain additional input on its June 2013 proposal, Formaldehyde Emissions Standards for Composite Wood Products rule, as it pertains to laminated products.
The 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.
“It also includes protective yet common sense exemptions from some testing and recordkeeping requirements for products made with no-added formaldehyde resins,” according to the EPA website. This proposal includes additional implementing provisions for:
· Laminated products;
· Testing requirements;
· Product labeling;
· Chain of custody documentation, and other recordkeeping requirements;
· Enforcement; and
· Product inventory sell-through provisions, including a product stockpiling prohibition.
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.
TPCs would be responsible for activities such as:
· Regularly auditing composite wood panel producers;
· Conducting and verifying formaldehyde emissions tests; and
· Ensuring that panel producers’ quality assurance/quality control procedures and testing complies with the TSCA Title VI implementing regulations.
“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,” according to the EPA website.
The California Air Resources Board’s (CARB) Alternate Regulatory Approach for Laminated Products Made with Wood Veneer is an approach supported by the Federal Wood Industries Coalition (FWIC), including the Composite Panel Association (CPA), the American Chemistry Council, The Engineered Wood Association and the Moulding and Millwork Producers Association.
“FWIC proposed a laminated products definition that would ease the significant, additional burden that would be imposed on countless fabricators by the EPA proposal. CARB’s recommendation, which would add an emission limitation to these products of 0.13 ppm where none had been present before, is a welcome and creative approach that FWIC supports. We also support the conclusion that products complying with the emission limit should not be subject to the testing and certification mandated by regulation. Although not referenced in the ATCM, CARB staff has frequently alluded to ‘deconstructive testing,’ a procedure that FWIC opposes. The imposition of an emission limitation for laminated products should moot the need for any deconstructive testing,” according to the FWIC.
At the April EPA meeting, CPA president Tom Julia and Chairman Kelly Shotbolt of Flakeboard gave presentations highlighting their support for CARB’s Alternate Regulatory Approach for Laminated Products Made with Wood Veneer. CPA Counsel Brock Landry also spoke in favor of CARB’s proposal on behalf of the FWIC.
“While EPA provided no reaction to the public testimony, the agency did state that they anticipate finalizing the regulation by year’s end,” according to the CPA website.
CPA and FWIC plan to submit additional written comments to EPA before the public comment period closes on May 8.