Continuing our series on formaldehyde ... So you are in the flooring industry and are wondering what your CARB related responsibilities are.
Right now, if you do not do any business in the state of California, not a thing. However, if you want to sell flooring in California, you need to make sure you are producing or purchasing CARB-certified products.
I'll assume manufacturers already know their responsibilities, so let's look at it from a buying prospective. CARB has two issues they want to check-the emissions and the documentation. Let's look first at the documentation.
Anyone (importer, wholesaler/distributor, or retailer) buying an engineered floor with either a plywood or HDF core needs to maintain chain of custody records. You need to put on your purchase order that you want CARB-Certified material and you will want to make sure that invoice and the packaged material both indicate that the floor is CARB-certified. If all you are doing is buying and re-selling the flooring and don't change the label, you're good to go.
If CARB decides to select your product for review, they'll purchase a box and ask to see your documents. The review goes up the chain-from the retailer to the distributor to the flooring manufacturer (or to the importer and then the manufacturer of the flooring) and then, if that company bought the core elsewhere, finally back to the manufacturer of the core material-the original particleboard or plywood panel. (Any extra companies that had even temporary ownership of the product in that chain can also get checked for documentary compliance.) The goal is to trace the product back to a specific manufacturing mill and even to a lot number and production date. As a retailer, you don't need to know the lot number-but you need to show that you asked for CARB material and it was invoiced to you as CARB material and that you can support tracking it back up the supply chain to the original production.
California will be happy to fine companies for failure to keep clean documentation records, so make sure you are on record as requiring CARB certified material and make sure that your suppliers are confirming that purchase on both their invoices and packages. As long as the state can trace backwards from your stock to someone else, you have met your documentary responsibilities.
See more info on CARB in the next post.