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What you need to know about CARB

The California Air Resources Board (CARB) enacted legislation in 2007 to reduce formaldehyde emissions in composite wood products. The Air Toxic Control Measure (ATCM) includes hardwood plywood (HWPW), particleboard (PB), and medium density fibreboard (MDF), including thin MDF less than or equal to 8 mm. It also applies to finished goods that contain these products, and are sold, offered for sale, supplied, used, or manufactured for sale in California.

The ATCM, in part, contains Phase I and Phase 2 compliance dates for each category of composite wood products as displayed below:

*Phase 1 (P1) and 2 (P2) Emission Standards (ppm)*

 

Effective DateHWPW-VCHWPW-CC PBMDFThin MDF
1-1-2009 P1: 0.08 -------- P1: 0.18 P1: 0.21 P1: 0.21
7-1-2009 -------- P1: 0.08 -------- -------- --------
1-1-2010 P2: 0.05 -------- -------- -------- --------
1-1-2011 -------- -------- P2: 0.09 P2: 0.11 --------
1-1-2012 -------- -------- -------- -------- P2: 0.13
7-1-2012 -------- P2: 0.05 -------- -------- --------

What is important to note, is that these products will be readily available. The American National Standard for Hardwood and Decorative Plywood (ANSI/HPVA HP-1-2009) has adopted CARB emission limits and the majority of composite panel manufactures are producing as per the CARB standard, regardless.· Further, as signed into law, July 2010, by President Obama, a similar standard will become national legislation. The legislation, “Title VI—Formaldehyde Standards for Composite Wood Products”, is an amendment to the “Toxic Substances Control Act (15 U.S.C. 2601 et seq.) and will be enacted by January 2013.

**Metro Hardwoods CARB Compliance Documents** (add documents note)

Sell-Through Provisions

For up-to-date CARB information, visit:

http://www.arb.ca.gov/toxics/compwood/compwood.htm


Labeling Shipments & Documentation
When purchasing compliant panels or finished goods, fabricators must take “reasonable prudent precautions” to ensure the products they are buying comply with the rule and are labeled appropriately. The label must include:
Fabricator’s name
Date the finished good was produced
Language that clearly indicates the product complies with the applicable Phase 1 or Phase 2 emission limit.

In addition, all invoices or bills of lading must also include a statement of compliance indicating the product meets the Phase 1 and Phase 2 emission limit.

For example, CARB has indicated the following language would be acceptable for the required product label and statement of compliance:

“Contains (particleboard, MDF, hardwood plywood) that complies with CARB (Phase 1, Phase 2) formaldehyde emission standards in CCR 93120.2(a).”

If you’re using no-added formaldehyde or ultra-low emitting formaldehyde resins, you can replace the Phase 1/Phase 2 statement on your label and statement of compliance on your invoice with “Contains (particleboard, MDF, hardwood plywood) made with (NAF, ULEF) resins that comply with CARB formaldehyde emission standards in CCR 93120.2(a).”

While CARB does not have a specified standardized label format, the necessary information must be readily identifiable on the box or finished product. The information can appear in separate labels, if they all are clearly visible.

Beyond that, fabricators are required to keep records showing the date of purchases as well as the name of the supplier, and documenting the precautions they have taken to ensure the materials comply with the rule. These records must be kept in electronic or hard copy form for a minimum of two years.