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Last week I noted that the EPA has released draft versions of proposed regulations for controlling formaldehyde emissions in composite wood products. That draft proposes to include most fabricators in the certification process. So any company that attaches a wood veneer to a core (which of course must be certified itself) will have to become independently certified … but wait! There's an option to certification!

You won't have to become certified if you use both a certified core and an NAF glue for all your production process. (And of course document your production process with a minimum three-year record-keeping obligation that should be made available to your customers or the government, upon request. Be sure to read the proposal for the fine print details.)

But anyway, back to the NAF: No Added Formaldehyde. Maybe you'll pick a soy glue or some type of water-based glue; that's up to you, but anything with a drop of formaldehyde in it is out. (No phenol, melamine or urea-the use of any form of formaldehyde glue means you get independently certified as a fabricator.)

Pulling from the draft:

Approximately 7,000 to 14,000 laminated product producers in the U.S. make products (such as custom hardwood plywood and architectural panels, windows, doors, kitchen cabinets, furniture, architectural woodwork and millwork, engineered wood flooring, and other goods) by affixing veneer to purchased platforms as part of the production process.

… Nationally, 2,700 to 4,000 of these laminated product producers are assumed to be using formaldehyde-based resins. It is generally less expensive for these firms to switch to a NAF resin than to pay for the certification and product testing required for panel producers under this proposal. EPA believes that nearly all laminated product producers using formaldehyde-based resins to attach wood or woody grass veneer to compliant and certified platforms will switch to NAF resins, in order to qualify for the exemption from the definition of hardwood plywood in this proposal. EPA assumes that only about 150 to 300 U.S. laminated product producers will continue using formaldehyde-based resins, and thus will need to certify and test their products as a result of this proposal.

… In addition, laminated product producers whose products are exempt from the definition of hardwood plywood would have to maintain records demonstrating use of a NAF resin, including the resin trade name, resin manufacturer contact information, and resin supplier contact information, or, if the resin is made in-house, records sufficient to demonstrate that the resin is a NAF resin.

Are you a manufacturer of flooring? If so, do you want to change your glue? Will your production be the same? The quality? The costs? Will you need to invest in new equipment? Consider these issues please and let the EPA know how you feel about their proposal.

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