DWM - June2006

Volume 7 Issue 6 June 2006

CodeConcerns

Formaldehyde Regulations in Development
by Michael Fischer

"The California ARB has been working with stakeholders from the wood composites industry to find a way to transform the composite wood product industry to the use of alternate resin products and manufacturing
technologies that will reduce formaldehyde emissions."

In 1992, the California Air Resources Board (CARB) identified formaldehyde as a toxic air contaminant. The California Office of Environmental Health Hazard Assessment (OEHHA) determined that there was no safe exposure threshold for formaldehyde that would preclude the development of cancers. These findings followed the U.S. Environmental Protection Agency (EPA) evaluation of formaldehyde that classified for-maldehyde as a “probable human carcinogen.”

The EPA determination was based upon conditions of high or prolonged exposure to formaldehyde, occurring typically through inhalation of formaldehyde from natural or man-made sources.

During its study of formaldehyde, the CARB determined that composite wood products containing urea-formaldehyde resins were a major source of formaldehyde emissions. CARB estimates that more than 2.5 billion square feet of composite wood products, including particleboard, medium density fiberboard, hardwood plywood and composite veneer, are sold in California each year. These products are used commonly in furniture, kitchen and bathroom cabinetry and other building products.

Door and Window Assemblies
The door and window industry also use composite products as components in some assemblies. The percentage of composite products used in a door or window varies, from none to a small amount in many window products, to other products including interior doors that have much greater amounts of composite wood products.

The CARB is charged by the state legislature with the development of regulations that will reduce the perhaps 400 tons of formaldehyde emissions emitted annually in California from composite wood products. CARB has been working with stakeholders from the wood composites industry to find a way to transform the composite wood product industry to the use of alternate resin products and manufacturing technologies that will reduce formaldehyde emissions.

While many wood products, including furniture and cabinetry, may be more likely candidates for alternate materials and methods, door and window products are also required to meet other performance criteria by virtue of their use as part of homes and other structures. Doors and windows must comply with structural and fire protection requirements, and exterior products are subject to exposure from weather including the deteriorating effect of rainfall. With more stringent code requirements in place and on the way in California, meeting the myriad regulations will become a greater challenge as we move forward.

Working with CARB staff on the details of the regulation, code committees of the Window and Door Manufacturers Association (WDMA), are evaluating the specific requirements contained in drafts of the California formaldehyde regulation to provide a comprehensive understanding of the true effects of the proposed rules. As unintended consequences are identified, WDMA will continue the dialogue to make sure that the regulation includes a common sense approach to improving the quality of indoor air.

As always, a balanced approach makes the most sense. Requiring substitute methods to manufacture products that might provide slight reductions in formaldehyde emissions, while requiring twice the energy to produce and releasing twice the amount of carbon dioxide into the atmosphere might not be in the best interests of California citizens.

Regulation Specifics
The proposed regulations govern particleboard, medium density fiberboard, and hardwood plywood. The rules contain two separate phases with more stringent test levels going into effect in phase two. The current plan calls for testing of the raw material to ASTM large chamber test protocols. Implementation of the proposed rule will begin in July 2008, with final adoption of the phase two requirements slated for July 2013.

For door and window manufacturers that purchase regulated materials, the easiest path of compliance might be to purchase only approved products for any California sales. While that may sound easy, current logistical and operational realities may require that manufacturers convert all of their products to California-approved materials.

For manufacturers who produce regulated products, such as medium density fiberboard door skins, the rule will require that they perform the testing on the raw panels. Some of the same operational obstacles will also affect the cost of complying with the regulation. Converting to other resins or manufacturing methods also brings the likelihood of unintended consequences.

WDMA will work with CARB staff to evaluate the true effect of the draft regulations, and determine the most realistic approach to solving the problem of formaldehyde emissions and the potential effect on air quality. By taking a look at how other products perform, and at other factors including the specific test parameters for doors and windows, WDMA will help ensure the final regulations provide a meaningful solution to the citizens of California. Invoking an arbitrary rule that potentially adds cost, while sacrificing other product performance features and wasting energy, may not be the best solution. The goal should be to provide the best value to the end customer—including the potential positive health effects. WDMA and its members continue to advocate the safe application of door and window products.

Michael Fischer, with the Kellen Company, serves as director of codes and regulatory compliance for the Window and Door Manufacturers Association.