Uniform Enforcement of New California Formaldehyde Emissions Limits Remains a Concern

May 1, 2007

The president of APA – The Engineered Wood Association said today his organization remains concerned over the ability of California state regulators to enforce stringent new formaldehyde emissions rules equally among domestic and foreign manufacturers of certain composite wood products.
 
The new emissions limits, which are scheduled to be phased in starting in 2009 and fully implemented in 2012, were adopted last week by the California Air Resources Board (CARB), a department of the state's Environmental Protection Agency.
 
"Enforcement remains an issue," Hardman said, "because substantial volumes of the wood products in question in California are imported. And we know there is product coming into the country that is sub-standard in other respects."
 
Products targeted by the measure include particleboard, medium density fiberboard and hardwood plywood, products typically made with urea formaldehyde adhesives. It will also affect manufacturers of furniture, cabinets and other consumer products that use those composite wood panels.
 
The regulations, called the "Airborne Toxic Control Measure to Reduce Formaldehyde from Composite Wood Products," exempt structural engineered wood products such as softwood plywood, oriented strand board, glulam timber, wood I-joists and laminated veneer lumber since formaldehyde emissions from those products are negligible.
 
The new regulations will establish the most stringent formaldehyde emissions limits on wood products in the United States and, when fully implemented, the strictest limits in the world, according to CARB. The Composite Panel Association, which represents manufacturers of particleboard and medium density fiberboard, predicts the measure will impose an annual cost of $2.5 billion on the domestic economy "while returning negligible health benefits to the citizens of California."
 
The measure requires that all domestic and foreign manufacturers certify their products by a "third party" laboratory approved by CARB and then label the items as meeting California's emissions requirements. Panel manufacturers, importers, distributors, fabricators and installers can all be held responsible for assuring that their products comply.
 
APA, Hardman said, is concerned about certification loopholes that could permit non-complying imported products, especially material from China, to enter the California market. Chinese hardwood plywood competes with domestic softwood plywood in some markets.

The International Trade Commission (ITC) began an investigation of Chinese hardwood plywood imports April 18 that, among other things, is exploring fraudulent stamping of panels. The results of that investigation are due in June 2008.
 
APA has cautioned the marketplace to beware of Chinese and other panel imports that are improperly and in many cases even fraudulently labeled. Hardman cited recent APA sampling tests of non-trademarked imported concrete form panels in which the average glue bond performance of the sample did not meet the minimum standard of U.S. Product Standard PS 1. Test results also indicated that the samples had an average load capacity of approximately 40 percent below the level of APA PS 1 Plyform® plywood and had formaldehyde emissions levels up to 500 times higher than those of domestic production.

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