Formaldehyde Emissions Regulations (CARB/EPA Rule)

The State of California Air Resources Board provides an extensive list of questions frequently asked about the implementation of this regulation. Some of these questions and answers are excerpted below. For the full set, visit: http://www.arb.ca.gov/toxics/compwood/implementation/faq.htm

What composite wood products fall under the airborne toxic control measure (ATCM)?

The ATCM applies to all hardwood plywood (HWPW), particleboard (PB), and medium-density fiberboard (MDF), including thin MDF (≤ 8 mm), and finished goods that contain these products, that are sold, offered for sale, supplied, used, or manufactured for sale in California.

What specific products are not covered by the ATCM?

Materials that are not covered by the ATCM include, but are not limited to hardboard, natural wood, certified structural plywood, certified structural panels, structural composite lumber, oriented strand board, glue-laminated timber, prefabricated wood I-joist, finger-jointed lumber, or "composite wood products" used inside of new vehicles, rail cars, boats, aerospace craft or aircraft (please also refer to question #23).

What are examples of finished goods?

Finished goods mean any good or product other than a panel, containing HWPW, PB, and MDF. Finished goods include, but are not limited to furniture, cabinets, shelving, countertops, flooring, moldings, caskets, baseboards, rosettes, corbels, etc.

Who does the ATCM apply to?

The ATCM applies to manufacturers, distributors, importers, fabricators, and retailers of the products described in question 1, as well as third-party certifiers of manufacturers.

Does the ATCM apply to blockboard?

No, blockboard is not covered by the ATCM since it is not included in the definition of HWPW.

Does the ATCM apply to molded pallet blocks?

Molded pallet blocks that are made in individual molds and made specifically as molded pallet components are exempt for the ATCM. If in a given manufacturing process no flat panels are made or used, and if the resulting molded pallet block products have a very specific purpose, then molded pallet block products would not be subject to the ATCM.

Does SCS provide certification support?

SCS provides ongoing program support, including ongoing staff assistance, marketing and promotional support, and information about new or revised requirements. Certified clients will receive information about creating batch-specific Lot Labels for on-product use.

1. Apply for Certification
   Complete and submit an SCS Application Form. SCS scopes the project based on information provided in the application and prepares a proposal for your approval with a suggested timeline and quote. Once you approve the proposal, you sign a Work Order.  An SCS account manager is assigned to guide you through the certification process.
2. Data Collection
   An SCS technical coordinator helps you assemble preliminary data that will be submitted to SCS. SCS reviews the product data, corporate documentation, manufacturing process, product formulation, testing, etc., and assesses your readiness for an audit. Once sufficient data is collected, an auditor is assigned.
3. On-site Audit
   The auditor conducts an on-site audit to evaluate your data. The auditor interacts with your technical staff to clarify and obtain any additional information that might prove essential to reaching an accurate supportable evaluation.
4. Draft Assessment Report
   The auditor writes a draft assessment report that details the findings of the audit, which includes data analysis, non-conformities, and opportunities for improvement.
5. Internal Peer Review
   A second qualified SCS representative reviews the report, making any necessary corrections or changes before the report is sent to the client.
6. Corrective Actions
   You respond to any non-conformities with a Corrective Action Plan. You may also make comments and responses to the information contained in the report and the conclusions drawn by the auditor.
7. Certification Decision
   SCS conducts a final technical review of the assessment report and makes the final certification decision. If certification is granted, SCS issues the certificate and final report to your facility or operation. Once certified, your company is listed in the Green Products Certificate Database on the SCS website.
8. Certification Maintenance and Renewal
   Depending on the certification, SCS requires annual audits to maintain your certification and support continual improvement.

Eligibility

This program applies to producers of medium-density fiberboard (MDF), particleboard (PB), and hardwood plywood (HWP), including veneer and composite core.

Program Criteria

Formaldehyde levels in certified products must fall within established limits set by the State of California and the US EPA for each type of product. For more information about the regulation, including updates and advisories, see:

http://www.arb.ca.gov/toxics/compwood/compwood.htm

https://www.epa.gov/formaldehyde/formaldehyde-emission-standards-composite-wood-products

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