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Formaldehyde Part 3: CARB's Approach

Continuing our series on formaldehyde...

What people in the wood industry call "CARB" is actually "Airborne Toxic Control Measure (ATCM) number 93120." This is the regulation that governs the allowed formaldehyde emission levels, certification procedures and chain of custody requirements for composite wood panels in the state of California.

The California regulation is currently the world's toughest production standard for formaldehyde emissions from composite wood products, and the U.S. federal government is now planning to match them on a national level. The exact details of the federal law's enforcement structure will be hammered out over the next few years.

Current CARB regulations require that composite wood panels meet specified emissions performance standards, regardless of what resins are used in their manufacture. All mills producing such panels are required to have third-party certification that their production procedures will lead to these results. All downstream buyers (value-added manufacturers, importers, distributors, retailers) must follow certain documentary procedures to ensure a chain of custody that would allow the State of California to trace a product retailed in California back to the original panel manufacturer.

As noted above, CARB certification is based on the factory's production system and procedures, and the actual emission ratings from the resulting product. However, CARB also allows manufacturers to advertise their product's certification on a content-based condition. Therefore you will see on labels what appears to be an emission based standard of "CARB Certified Phase 1" (the product meets their first level for actual emissions) as well as what appears to be a content standard of "no added formaldehyde" and "ultra-low emitting formaldehyde." No wonder it's confusing, yes?

The ultimate emission limits in the California regulations are lower than either the European E1 or the Japanese F**** (referred to as "Four Star") ratings. However, they are unusual in the fact that the allowable levels vary by product category (particleboard formaldehyde emissions can be higher than plywood, for example) and are based on maximum limits, whereas other worldwide standards are used consistently for any type of composite wood products and are based on average levels.

Next time, we'll look at the wood flooring industry's responsibilities under CARB.

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