Frequently Asked Questions: No-added formaldehyde and ultra-low emitting formaldehyde
(HWPW = hardwood plywood; HWPW-VC = hardwood plywood veneer core; HWPW-CC = hardwood plywood composite core; PB = particleboard; MDF = medium density fiberboard)
1. I make a veneered raised panel door. If the MDF core meets the NAF/ULEF (no-added formaldehyde/ultra-low emitting formaldehyde) standard, but the splices in the veneer are glued with UF, will it still meet the NAF/ULEF standard? The "NAF" and "ULEF" designation applies only to manufactured HWPW-VC, HWPW-CC, PB, or MDF panels and not to finished goods, such as doors.
2. The CARB regulation will drive an increase in use of NAF adhesives. Some of these adhesives emit substances that are irritating, harmful, and/or hazardous to the human body. An example is free MDI radicals - what is being done to address concerns like this? The ATCM is based on emissions performance standards, which does not dictate resins to be used. We cannot predict whether the use of NAF adhesives will increase as a result of the regulation, given the technological advancements with low-emitting urea formaldehyde resins (ULEF). When a manufacturer applies to CARB for certification, we will review the chemical composition of the NAF resin to determine if it qualifies for a NAF designation, we may also seek additional information from the applicant to clarify our assessment of the candidate NAF composite wood product. Furthermore, manufacturing facilities may also be regulated as stationary sources of emissions. The use of a particular resin, such as MDI, may be regulated by the local or state agencies that issue permits to stationary sources or regulate occupational exposure to chemicals.
3. Would a phenolic-formaldehyde (PF) platform (for example PB or MDF core) overlaid with hardwood veneer with PVA glue be considered a NAF product? No. The NAF designation refers to HWPW-VC, HWPW-CC, PB, and MDF panels made entirely with a NAF adhesive (products made with PF resin are not qualified as NAF). However, such composite core plywood could be tested and would probably meet the emissions requirements to be considered a ULEF product.
4. Is there concern that manufactured products using NAF/ULEF adhesives will act as sponges for formaldehyde when stored next to manufactured products using UF adhesives (e.g., Big Box retail storage)? No. We will be able to determine if the NAF/ULEF products were made with the proper resins, and if the retailer has the proper documentation on-site for both the NAF and ULEF products they offer for sale. In addition, the sample preparation conditioning requirements of ASTM D 6007-02 (small chamber) and ASTM E 1333-96(2002) (large chamber) are designed to address contamination by other products, by achieving a steady state emission rate prior to measuring the formaldehyde from the NAF/ULEF product.
5. Will CARB randomly test product from manufacturers that are using NAF/ULEF adhesives that have exemptions from the Executive Officer? Yes. The integrity of the program depends on consumers having certainty that the products meet the low emission standards and there is an effective compliance program.
6. Can a mill that's been approved to produce NAF/ULEF panels for sale in California also manufacture non-NAF/ULEF panels for non-California use? Mills can choose to produce products not subject to the California standards for non-California customers, but could not label those products as legal for sale or use in California. Moreover, they should inform their customers that if they intend to sell their products to California, they should purchase California compliant composite wood products to make those goods.
7. What are the third-party certification requirements for panel manufacturers that produce NAF/ULEF products? Manufacturers of "no-added formaldehyde" (NAF) products have to apply to CARB to be approved as a NAF manufacturer. Emissions data must be included in the application. If the application is approved by CARB, the product manufacturer would be exempt from the TPC requirements for two years, but still subject to field inspection and audits to verify their use of NAF resins. Manufacturers of ultra-low emitting formaldehyde resin (ULEF) products would also have to apply to CARB to be approved as ULEF manufacturer along with providing emissions data with their application. Once the application is approved by CARB, the ULEF manufacturer may be exempt from the TPC requirements for two years or allowed to test their products less frequently; however, they would be subject to field inspection and audits to verify their use of ULEF resins. NAF and ULEF approvals are granted for two-year periods and must be renewed accordingly.
8. A CARB-approved manufacturer (a panel producer) of ULEF composite wood products later discovers that their products exceed the ULEF target or cap values. Can the manufacturer label their products as TSCA Title VI compliant? The products shall only be labeled and sold as TSCA Title VI compliant if the products do not exceed the applicable CARB Phase 2 formaldehyde emission standards (identical to TSCA Title VI). Additionally, the panel producer must work with a CARB-approved/EPA recognized TPC to certify that the panels produced by the manufacturer on a lot-by-lot basis as being Phase 2 compliant. The panel producer would follow the non-complying lot testing requirements contained in the ATCM [Appendix 2, subsection (g)(8)].
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