925,000 companies.
That's a big number, isn't it? That is the number of firms that the EPA estimates will be impacted by the proposed regulations on formaldehyde emissions from composite wood products, including engineered wood flooring.
Welcome to the "new CARB."
(Which, by the way, is officially known as "TSCA Title VI Compliant." I'm probably going to be pronouncing that as "Tiska" in the future. "Are you Tiska Compliant?" or "We are Tiska-certified!" will be the next hot conversation topic.)
Now the current draft of the regs runs just about 300 pages. You'll find it and other info here: http://www.epa.gov/oppt/chemtest/formaldehyde/. Once the final draft version is posted in the Federal Registrar, the industry will have 60 days to make comments. The exact date as to when it will be formalized is still unknown.
In all seriousness, there is no question that this rule will dramatically impact our industry.
In all seriousness, there is no question that this rule will dramatically impact our industry.
I will be working with a task force on coordinating commentary for the NWFA on these regulations. If you wish to comment on the proposed regulations, you may write to me or even better, comment directly to the EPA (instructions are on the site). The more direct comments, the better. They need to hear what you like and don't like about this in your own words.
The rules are based heavily on the CARB regulations. However there are a number of differences. For example, bamboo flooring is included (as it may eventually be within CARB). Lumber-core flooring (sometimes called sandwich construction or 3-ply) is also included. The number of possible TPC's (Third Party Certifiers) to use has been reduced, as the EPA is requiring more accreditation from TPC's permitted to certify against this regulation.
Most importantly, the current draft suggests that most flooring "fabricators" will require independent certification. (A "fabricator" will be someone who adds a layer (or more) of wood to the core-engineered flooring, kitchen cabinetry, many furniture companies…) That means almost all manufacturers of engineered flooring will have to first buy certified cores (HDF or plywood) and then also be independently certified. Beyond the cost factor that will be added to overhead, I can't imagine there is anywhere near sufficient testing capacity to cover this. The draft notes: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. These laminated products are regulated as hardwood plywood under this proposal unless they are made using NAF resins to attach the veneer to compliant and certified platforms, in which case they are exempted from the definition of hardwood plywood.
In my first read, I spotted a number of other points that may be of concern to the industry, and I encourage all to become involved in commenting on this. This regulation is going to govern the engineered flooring industry for the foreseeable future. This is also going to impact any other products you may, as an individual, wish to purchase or sell: cabinetry, furniture, doors, windows, etc. It may even cover some forms of underlayment as well.
Actually, with nearly a million companies facing compliance issues, it's going to radically change all aspects of the wood production and building industries.
You need to know what is in store. You have a chance now to help shape the final form of regulation; please take it!
