No, this is not another one of my alphabet soup series, and I certainly hope that JIW never becomes a mainstream acronym. But it could become one if the proposed EPA regulations are adapted as-is.
See one of the many other "devil in the detail" aspects about the new proposed formaldehyde regulations that include engineered wood flooring is the one where the EPA is proposing that no shipments be permitted until QC testing is done. Depending on the testing method, availability of qualified testing, and which test (routine/quarterly/annual) is being done, the regulations could require manufacturers to hold onto shipments for anywhere from three to 30 days. Maybe even more. Yes, that's right. You could make something and then be required to hold it for a month until the tests come back showing it meets emission levels.
Set aside the impact this will have on your marketing and on your cash flow. (And remember those impacts are going to be felt all the way down the chain.) Let's just look at the practical physical reality of that: If you are a manufacturer, do you have the storage space? Can you hold a week's production in storage an extra week? A month's production in storage an extra month? Do you have the physical space to sit on that much material?
This is one of the many areas where TSCA 6 is not "just like CARB." (CARB does not require manufacturers to hold shipments pending test results.)
Have you looked to see where else the regs differ? For example, they differ enough that we're talking about the potential loss of up to 75% of the current TPC's available to the market place … even as we see an exponential expansion of the number of companies requiring certification … Hmmm, now what's that going to do to our wait time for testing before shipment? I can hear the salesmen now, "Don't worry, we'll ship soon. It's ABT!" (All But Tested.)
Read the regs and participate in the process by going here.