Think the new EPA proposed formaldehyde regulations are only for manufacturers?
The EPA estimates that around 712,000 wholesalers and retailers will now have additional record-keeping responsibilities under the new EPA regulations.
(Note: They are discounting the estimated 133,000 companies that they say are already maintaining CARB records and therefore should not face a significant new burden because of these new regulations. Of course, since CARB and the EPA currently do not overlap their certifications, those 133,000 will have double tracking to do.)
"For distributors and retailers that are not manufacturers under TSCA, EPA is proposing that the only records they be required to keep are invoices and bills of lading."
That's not too bad-it's easier then CARB, actually. (With CARB, you're required to help track the production records, too.)
However, "Most records would have to be kept for a period of 3 years from the date that they are generated. In addition, all records that would be required by this proposal would also have to be provided to EPA upon request to facilitate EPA's compliance monitoring activities."
The EPA acknowledges that all of these companies "would incur costs to comply with the chain of custody requirements in this proposal, as well as rule familiarization costs."
Elsewhere, the proposed regulations note that:
Distributors and retailers must retain invoices and bills of lading and copies of labels used. These records must be maintained for a minimum of 3 years from the date that they are produced.
Distributors and wholesalers who receive labeled bundles of regulated composite wood products and then divide and repackage them, whether in bundles or separately, must label each separate bundle or item with the same information as required on the original label. Labels on bundles that are not so repackaged must be kept intact by distributors, wholesalers, and retailers.
Consider these issues please and review the details, and then let the EPA know how you feel about their proposal. Is your system set up to track certified products properly?
