Frequently Asked Questions: Third-Party Certification
(HWPW = hardwood plywood; HWPW-VC = hardwood plywood veneer core; HWPW-CC = hardwood plywood composite core; PB = particleboard; MDF = medium density fiberboard)
1. Who has to be third-party certified? Only manufacturers of HWPW-VC, HWPW-CC, PB, MDF and thin MDF are required to be third-party certified.
2. What do Third-Party Certifiers (TPCs) "certify"? TPCs verify that manufacturers of composite wood products (panels) are capable of complying with the ATCM's emission standards. Manufacturers certify that their panels comply with the emission standards by labeling their panels as CARB Phase 2 compliant. TPCs also conduct quarterly inspections and testing, and review routine quality control testing conducted by each manufacturing mill. Verifications by TPCs apply to specific product types at each mill operated by a manufacturer. A list of certified manufacturing mills is maintained on CARB's composite wood products webpage.
It is important to note that just because a mill is listed on CARB's list of certified mills does not mean that everything made by that mill complies with CARB's emission standards. For many mills, most of their production is not intended for sale in California and is not CARB compliant.
3. Are Third-Party Certifiers (TPCs) required to test finished goods? No.
4. Will CARB supply manufacturers with a list of certified third-party certifier (TPC) testing facilities? We maintain a list of approved TPCs on our website. Currently, we have approved about 40 third-party certifiers. For more information, please visit our list of TPCs on our composite wood products webpage.
5. What plans are in place to have certified third-party testing facilities internationally? Most of the TPCs are providing international services. See the list of approved TPCs on our webpage.
6. What has CARB done to address international stakeholders with respect to third-party certification? CARB approached this issue in three steps. Initially, CARB conducted outreach to major international stakeholders and to the regulated community abroad. Staff traveled to China and Malaysia to conduct site visits to the Chinese consulate and participated in conferences to discuss and explain the CARB ATCM and the standards. CARB's outreach efforts also include translations of fact sheets, presently available in five language (Chinese, Spanish, Portuguese, Russian, and Indonesian). The translations of the ATCM text are available in the above listed languages at our composite wood products webpage. Second, CARB also put great emphasis on working with international third party certifiers to develop the certification program. Thirdly, important modifications were made to the rule in order to provide consistency compared to other international standards. CARB staff developed and changed the ATCM to allow the use of the secondary test method (small chamber method) to reduce the worldwide need for large chamber testing. In addition, we allowed alternative quality control test methods to provide consistency with existing test methods used for Japanese and European Union composite wood product regulations. CARB also worked closely with the International Wood Panel Association and made contacts with its member manufacturers.
7. My company is currently accredited to be a product certifier (e.g, ISO Guide 65), testing laboratory (e.g., ISO 17025), and inspection body (e.g., ISO 17020), and we have years of experience in inspecting composite wood products mills and testing formaldehyde emissions from panels. The scope of our ISO/IEC 17025 includes ASTM D 6007, but does not include ASTM E 1333. Do we have the qualifications to be a CARB-approved Third-Party Certifier? Your company can qualify as a TPC if your secondary method (ASTM D 6007) has been deemed equivalent to the primary method (ASTM E 1333), in accordance with title 17, California Code of Regulations, section 93120.9 and the data is included as part of the TPC application. Unless your ASTM D 6007 chamber is equivalent, it cannot be used to verify panel emission levels, for purposes of the ATCM. If you are in the process of establishing equivalence with an ASTM E 1333 chamber, your application may be submitted, but will be deemed "incomplete". Please note that the demonstration of equivalence will require you to perform the required comparison testing with an ASTM E 1333 chamber operated by a CARB-approved testing laboratory before an approved Executive Order can be granted. A demonstration of equivalence made with a testing laboratory that has not received CARB-approval will not be accepted as valid, for purposes of the ATCM.
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