What do CARB and ATCM Mean?
In 2007, the California Air Resources Board (CARB) approved a new standard of formaldehyde emissions controls called the Airborne Toxics Control Measure (ATCM). The measure provides standard formaldehyde emissions ratings for all composite wood and manufactured wood products, including particleboard, hardwood, plywood, medium-density fiberboard, and also from finished products manufactured with composite wood parts. The two-phase plan requires manufacturers to comply with strict standards for any product that includes a composite wood product for manufacturing, sale, use, or supply within the state of California. The CARB study suggests that substandard composite wood products currently generate up to 5% of household formaldehyde emissions.
The ATCM is intended to bring California standards up to meet existing Japanese and European formaldehyde emissions standards. Currently in force in Japan is the Japanese JIS/JAS Formaldehyde Adhesive Emission Standards, which was defined by the Japanese Industrial Standards (JIS) in conjunction with the Japanese Agricultural Standards (JAS) department. Using a testing methodology called the Desiccator Test Method, emissions released from the wood are measured and rated. Ratings are assigned as, F*, F**, F***, and F****. F**** has the least measure of formaldehyde emissions, below 0.005 mg/m2h and was previously the most stringent of worldwide standards.
European standards established in 2000 by the European Panel Industry included E1, 9mg/100g and below, E2, greater than 9mg/100g to below 30mg/100g, and E3, greater than 30mg/100g. A new ratings classification that compares to Japan’s higher standard has been more recently developed, E0, based on emissions measuring 0.5mg and less per liter. Europeans use a different test method that Japan, based on the Perforator Test Method, which is used to determine formaldehyde levels within the wood product from the inside.
A Phased-In Approach
Phase 1 began on January 1, 2009. The new ATCM formaldehyde emission standards of equal to or less than 0.08 ppm (parts per million) took effect for hardwood, plywood, particleboard, and medium density fiberboard. This first step exceeds previous standards set by OSHA already in effect.
Phase 2 emission standards are slated for a staggered release beginning in January of 2010 through 2012. Phase 2 specifies even higher standards for formaldehyde emissions in wood products, 0.05 ppm, a higher standard than even the European E0 rating.
Due to the economic conditions the state is experiencing, CARB recently announced a delay in the enforcement of sell through dates on flooring materials made before January 1, 2009. This is aimed to address the surplus in those materials as well as the inventory concerns during the transition between Phase 1 and Phase 2 is made in January 2010. While designed to assist distributors, importers, fabricators, and retailers of composite wood products affected by these new regulations, it is not recommended to order more product, as only current inventories should be sold.
After December 31, 2010, CARB officials will enforce the sell through dates, penalizing those who do not follow the regulation. As plenty of Phase 1 compliant materials are being produced alongside materials working toward Phase 2 compliance, there is no need to extend beyond current inventory. Remaining pre-Phase 1 inventory cannot be sold within the state of California without penalty after this date.
The extended deadline helps businesses affected by the slowing economy to recoup some of the potential loss caused by the original sell through date, and is intended for no other purpose. The benefits these regulations set forth will not be diminished by the extended sales deadline, because had the economic conditions remained steady, the materials would have already sold. All other compliance dates stated in the legislation remain the same and must be adhered to accordingly.
Phase 1 standards should not call for retooling of factory equipment. The standards can be achieved using existing resin technologies already in production. Phase 2 will mean adjustments to new adhesive procedures using NAF (no-added formaldehyde) or ULEF (ultra-low-emitting formaldehyde) resin.
How It Works
Under ATCM law, manufacturers are required to be certified by a “third party certifier,” an independent watchdog approved by the ARB and expected to verify product turned out by manufacturers to be in compliance with applicable standards. Manufacturers are also required to label composite wood products to identify their Phase 1 or Phase 2 standards and specify resins used in production (either NAF or ULEF).
Post-manufacturing importers, distributors, fabricators, and retailers are required to purchase and sell only manufacturing products or finished goods that comply with the new ATCM formaldehyde emission standards. They are expected to communicate with suppliers and document that the manufacturing process used in any products meets the established applicable standards and keep a written record of purchase date and supplier, along with what procedures were undertaken to verify that purchased products meet the new standards.
Fabricators are required to provide similar labeling and documentation in order to ensure that every step of the way from raw product to finished flooring , wallboard, or furniture, compliance is adhered to and the integrity of the product is protected.
The ATCM is California law and does not apply to goods manufactured or sold for shipment outside of California. The ATCM also exempts hardwood plywood and particleboard used for manufactured homes that are subject to regulations established and enforced by the U.S. Department of Housing and Urban Development (HUD).
Industry concerns include the cost of retooling to manufacture to the new standards, man-hour cost in terms of compliance testing and documentation, plus testing and certification issues. This measure puts California’s small businesses at risk, making it difficult for them to compete using the more expensive manufacturing cost incurred from purchasing compliant materials.
Another concern is that of testing and enforcement. The question of just how to regulate such a large industry remains, and standardized testing procedures for Phase 2 compliance could prove an insurmountable challenge. CARB has instituted a reporting requirement within the regulatory board to track progress and suggest solutions during the first year Phase 1 rollout.
Although the ATCM currently affects only California, the impact is expected to reach far beyond to resonate eventually with all U.S. states. Current U.S. law regarding formaldehyde emissions are inadequate, and the CARB study is both impactful and an important health concern for taxpayers, whose growing environmental concerns are providing the pressure and impetus necessary to influence lawmakers to make environmentally sound decisions. Environmentalists hope that this measure will be adopted across the board to reduce the formaldehyde emissions in every American home and produce cleaner air for the generations to come.
Regulations regarding formaldehyde emission standards continued to evolve. In 2010, the Formaldehyde Standards for Composite Wood Products Act was signed into law. This established a national emission standard for formaldehyde, which was finalized by the EPA in December 2016. It also established a third-party testing and certification program for manufactured and/or imported composite wood products.
On May 22, 2017, the EPA’s TSCA Title VI compliance went into effect to ensure full compliance with the Formaldehyde Standards for Composite Wood Products Act. By June 1, 2018, all composite wood products sold in the US were to be TSCA Title VI compliant. Since March 22, 2019, rather than using CARB ATCM Phase 2 emissions standards, all composite wood products must be certified and labeled as TSCA Title VI compliant by the EPA.