Frequently Asked Questions: Emission Testing
(HWPW = hardwood plywood; HWPW-VC = hardwood plywood veneer core; HWPW-CC = hardwood plywood composite core; PB = particleboard; MDF = medium density fiberboard)
1. Who is required to emission test their products? Manufacturers of HWPW-VC, HWPW-CC, PB, MDF, and thin MDF are required to conduct emission testing of their products. The objective of the emission testing is to verify that the composite wood products produced comply with the emission standards on an on-going basis, to ensure the accuracy of production control and to ensure that low-emitting products are sold in California. Fabricators of finished goods are not subject to third-party certification requirements and do not have to emission test their finished goods or laminated products to verify compliance with the ATCM.
2. Why does CARB test composite wood products in finished goods? The ATCM requires that composite wood products (e.g., hardwood plywood, particleboard, and medium density fiberboard) contained in finished goods (e.g., flooring, furniture, and cabinets) comply with the formaldehyde emission standards. To verify compliance, CARB tests emissions of composite wood products as well as the emissions of such products contained in finished goods.
3. How does CARB test emissions of composite wood products in finished goods? CARB uses ASTM D 6007-02 - Standard Test Method for Determining Formaldehyde Concentration in Air from Wood Products Using a Small Scale Chamber, specified in section 93120.9(c) of the ATCM, to verify that composite wood products contained in finished goods comply with the emission standards. Pieces of composite wood products contained in finished goods (e.g., laminate flooring that consists of a laminate affixed to a medium density fiberboard core material, or a cabinet door that consists of particleboard with melamine laminate affixed to the face and back of the door) are prepared to expose the composite wood product for emissions testing. CARB's sample preparation procedures are documented in: Standard Operating Procedure for Finished Good Test Specimen Preparation Prior to Analysis of Formaldehyde Emissions from Composite Wood Products. There is some variability and uncertainty associated with sample preparation and emissions testing. This is not unique to testing of composite wood products. CARB staff accounts for this when considering whether or not enforcement action should be taken.
4. Can entities other than CARB determine whether finished goods comply with CARB’s Composite Wood Products Regulation? No. CARB is the only entity that has the authority to determine compliance of finished goods. Currently, CARB has approved 40 organizations (third-party certifiers or TPCs) to independently verify that producers of composite wood products (panels) have manufacturing systems that produce panels with formaldehyde emissions at or below the levels required by the ATCM. The TPC verifications include quarterly inspections and testing, and review of a producer’s quality control testing results (For additional information refer to question #2 of TPC FAQs). CARB’s approval of TPCs does not include finished goods (e.g., furniture, cabinets, flooring) because the ATCM does not require third-party certification of finished goods. Other entities may choose to use CARB’s sample preparation and emissions testing procedures for panels and/or finished goods to perform informational analyses for customers, but only CARB staff can determine whether finished goods comply with the regulation.
5. Are fabricators or retailers of finished goods required to conduct testing? No. Some companies have chosen to periodically test composite wood products from their suppliers. The ATCM requires fabricators of finished goods to use compliant composite wood material in their finished goods; to label their finished goods or boxes containing finished goods; and to provide documentation (i.e., invoices or bills of lading) with a statement of compliance to their customers. The ATCM also requires fabricators and retailers to keep records to document the steps they have taken to ensure that the goods that they make or sell comply with the ATCM. Fabricators and retailers are in violation of the regulation if they sell products that violate the emission standards.
6. What defines a reasonable correlation between a manufacturer's quality control data and a third-party certifier's compliance testing data? Third-party certifiers are required to establish a correlation (i.e., linear regression equation) between a manufacturers' routine quality control testing data and their third-party certifier's primary or secondary test method data. All correlations must be based on a minimum of five data pairs. CARB relies on third-party certifiers to establish reliable correlations to ensure on-going compliance of composite wood products offered for sale and supply to California.
7. Will CARB supply correlations for small-chamber-to-large-chamber and desiccator-to-large-chamber? No. The correlations will be calculated for manufacturers of composite wood products based on the primary or secondary test method data received from their third-party certifier (For additional information refer to TPC FAQs), under the requirements established by CARB.
8. The Dynamic Microchamber (DMC) is used extensively in the composite wood industry. Will it be CARB approved using the InterScan sensor? The dynamic Microchamber (DMC) and the new GP™ DMC are both approved for use as alternate small scale test methods for conducting formaldehyde emission testing for composite wood products.
9. What would constitute an acceptable demonstration of compliance for a manufacturer of a very low emitting product? The ATCM contains special provisions for CARB-certified manufacturers that produce composite wood products with very low formaldehyde emissions. The special provisions are provided for composite wood products made with no-added formaldehyde (NAF) or ultra-low emitting formaldehyde (ULEF) resins. To receive CARB approval as a NAF or ULEF product manufacturer, applicants are required to submit three months of quality control test data for NAF products and six months for ULEF products, along with primary or secondary method test data provided by their third-party certifier. Upon CARB approval, NAF and some ULEF products are exempt from on-going testing for two years; other ULEF products may be granted a reduction in frequency for on-going quality control testing for two years. Please refer to the NAF/ULEF requirements (Attachment A) of the application.
10. Can testing of finished furniture products conducted for non-CARB formaldehyde emission standards be considered reasonable prudent precautions under the rule? No. Testing of furniture products for compliance with non-CARB emission standards (e.g., European formaldehyde standards) would not constitute reasonable prudent precautions. A finished good could be made with non-complying composite wood, but due to the application of a laminate or a coating, may be able to pass the non-CARB emission standard. Under the rule, only actions taken to ensure that compliant composite wood products were used to make the furniture being offered for sale or supply to California would be considered to be reasonable prudent precaution.
11. Can a manufacturer use a small emissions chamber (ASTM D 6007) as a routine quality control test method? Yes, but a small chamber test data needs to be correlated to paired primary or secondary test method collected by their third-party certifier. Manufacturers may deem a small emissions chamber as equivalent to a primary method (section 93120.9), but their data cannot be used as a demonstration of product compliance in their quarterly tests for certification purposes. Quarterly tests for purposes of certification must be conducted by their third-party certifier.
12. What is the difference between primary testing, secondary testing, and the quality control testing conducted by a manufacturer? Manufacturers of composite wood products are required to conduct small scale quality control testing of their products at the manufacturing plant to ensure that their panels do not exceed applicable emission standards. Appendix 2 of the ATCM states that manufacturers have three options for conducting quality control testing: a desiccator (ASTM D 5582-00), a small chamber (ASTM D 6007-02), or an alternative small scale test that can be shown to correlate to the primary or secondary test methods. The primary and secondary test methods are used by third-party certifiers to verify compliance of manufacturers with applicable emission standards. Certifiers work with manufacturers to establish correlations between the manufacturer's small scale quality control tests and the primary or secondary method tests. Certifiers have the option of using either the primary or the secondary method. The primary method is defined as the large chamber test method (ASTM E-1333-96(2002)). The secondary test method consists of operating a small emissions chamber (ASTM D 6007-02) that has been deemed equivalent to a large chamber following the procedures specified in the ATCM.
13. For hardwood plywood with a composite core (HWPW-CC), does the core need to be tested and certified as complying with the applicable emission standard? Unless the core is being offered for sale separately, it does not need to be tested. Only the HWPW-CC needs to be tested and certified as complying. However, if the HWPW-CC is being sold as having been made with no-added formaldehyde (NAF) resins, the NAF designation applies to the entire composite wood product (the core and the resins used to affix the veneers) and in that case the core would need to be tested as part of the NAF product demonstration.
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