In August, the US EPA extended the public comment period for two regulations that will implement the Formaldehyde Standards for Composite Wood Products Act, or Title VI of the Toxic Substances Control Act. Both proposed rules initially were published in June 2013. Once the final rules are promulgated, manufacturers will have one year to comply. By including laminated products, the national regulation significantly expands the scope beyond the requirements of the California Air Resources Board (CARB) ATCM to control formaldehyde emissions from composite wood products. The Act defines a laminated product as a product made by affixing a wood veneer to a particleboard, MDF, or veneer-core platform. For the purpose of regulation, laminated products are considered a subset of hardwood plywood (HWPW). Such laminated products are included unless specifically exempted by the Act. At this time, the sole exemption proposed by the EPA is for laminated products in which a wood veneer is attached to a compliant, certified platform using a no-added formaldehyde (NAF) resin.
All environmental laws regulating chemicals require robust standards that are equitable and ensure that test results are accurate, precise and repeatable. The CARB ATCM program relies upon ASTM E1333, along with the small-chamber companion standard D6007, as the technical standard. The EPA proposes to base the national regulation on the same standards. ASTM E1333 fulfills its role for the ATCM because the products being tested and certified are panelized products, i.e., hardwood plywood, industrial particleboard and MDF mostly made with UF resins, that are very similar to the products considered when the standard was developed.
Scope of ASTM Standard Method E1333 is limited to testing large composite wood panels
ASTM Standard Method E1333 was first published in 1990. It was written to support the US HUD regulation on formaldehyde emissions from urea formaldehyde (UF) panel products used in manufactured housing. The approach is to test panelized products in a large chamber using an air change rate (0.5 air changes per hour) and product loading ratios that approximate panel usage (i.e., cabinetry, subflooring, wall paneling, etc.) in a typical manufactured house. For example, the loading ratio for MDF is substantially lower than for wall paneling and industrial particleboard to reflect the different product loading ratios of these products in a typical manufactured house. The test result is expressed as a chamber concentration at these conditions. The intent is to be able to directly compare the chamber concentration result to an exposure guideline for formaldehyde (the HUD formaldehyde guideline was 300 ppm).
Itâ€™s my opinion that ASTM E1333 cannot be applied beyond its current role for testing and certifying hardwood plywood, industrial particleboard and MDF panels because it has significant scope limitations and built-in biases. These include:
- Intended to support HUD regulations for manufactured housing (Section 1.5)
- Conducted at product loading rates & ventilation rates for manufactured houses (Section 1.1)
- Designed for testing 4 ft by 8 ft sheets of panel products (Sections 1.4 & 4.1.1)
- Sample shipping procedures designed for products in sheet form (Section 9.1)
- Analytical method intended for products with high formaldehyde emissions (Section 1.4)
- Temperature & humidity correction factors for concentration only relevant to UF resin products (Section 11.3)
New test standards are required to include laminated products in national formaldehyde emission regulation
Modern, much more detailed standards are needed to meet the laminated products requirements in the proposed national regulation. Laminated products span large ranges of forms, sizes and shapes and all must be accommodated. For each of the categories to be included, the standard needs to provide detailed instructions for sample collection, sample handling, sample shipping, specimen preparation, test parameters, and data analysis. ASTM E1333 and its small-chamber implementation, ASTM D6007, are bound by their limited scope and do not provide guidance on these fundamental issues.
In fact, more appropriate standards exist and are routinely used to measure the emissions of volatile organic compounds (VOCs) including formaldehyde from interior building products and commercial furniture. These are:
- CDPH/EHLB/Standard Method V1.1, 2010, Standard Method for the Testing and Evaluation of Volatile Organic Chemical Emissions from Indoor Sources using Environmental Chambers, Version 1.1; and
- ANSI/BIFMA M7.1-2011, Standard Test Method for Determining VOC Emissions from Office Furniture Systems, Components and Seating combined with ANSI/BIFMA X7.1-2011, Standard for Formaldehyde and TVOC Emissions of Low-emitting Office Furniture and Seating.
In the next post, Iâ€™ll discuss how the formaldehyde emission requirements in these finished product standards compare to the Phase 2 compliance requirements of the CARB ATCM.
Al Hodgson, November 19, 2013