MEMORANDUM

DATE: August 3, 2011

SUBJECT: Updated Formaldehyde Emissions from Select Wood Furniture 

Manufacturers

FROM: Nicholas Swanson, EPA/OAQPS/SPPD/NRG 

TO: Docket No.: EPA-HQ-OAR-2010-0786

As an outgrowth of the public comments submitted on the proposed Wood Furniture 

Manufacturing RTR (subpart JJ) amendments, EPA made inquiries to a few facilities to inquire 

about their current emissions of formaldehyde associated with wood furniture manufacturing 

operations. This action was taken to get better insight on how emissions data for some of the 

highest formaldehyde emitting facilities has changed since 2005. If there had been a change, a

further discussion ensued about the cause. The facilities contacted and their corresponding 2010 

formaldehyde (HCHO) emissions are listed below in Table 1. The data obtained in Table 1 was 

supplied via telephone conversations with the facility or the facility’s environmental contractor. 

Because this data is unverified, it is treated as general and useful information, but corresponding 

values for facilities have not been updated in databases. There are two facilities for which 

updated emissions information was not provided: 1) Ellinger’s Agitized was deemed to not be a 

wood furniture facility and is not in this source category; they produce wooden bowls and other 

kitchen supplies and thus, updated emissions data is not relevant to this rule making; and 2)

Plywood Cabinet Plant is actually a part of the Republic Industries Inc. facility and any 

emissions are considered to be for Republic Industries. This still shows the trend that facilities 

have drastically reduced emissions of formaldehyde from 2005 to 2010. From the data provided 

by these facilities, it shows that most have reduced emissions to less than 400 pounds of 

formaldehyde/year. There are a few contributing factors to this reductions in emissions. First, 

many wood furniture manufacturers have reduced the concentration of formaldehyde in their 

coatings, effectively reducing formaldehyde emissions. Second, the economic climate has 

affected many of the facilities’ production levels. With a decrease in production, there will be 

less coating used and then less emitted. Specific responses are included in Attachment 1. 
Table 1

Facility Name 2005 NEI 

HCHO 

Emissions 

(tpy)

2010 

HCHO 

Emissions

(tpy)*

Type of Wood 

Furniture 

Manufacturer

Alabama Inter-Forest Corporation 1.35 0.1 Cabinetry

Bertch Cabinet Manufacturing Inc. Legacy Div 0.75 0.037 Cabinetry

Ellinger’s Agitized Wood Products 0.414 n/a Kitchen Supplies

Kitchen Kompact 1.008 0.8285 Cabinetry

Legacy Cabinets 1.1 0.0009 Cabinetry

Plywood Cabinet Plant 1.377 n/a Cabinetry

Republic Industries Inc 0.677 0.111 Cabinetry

Stanley Furniture Company 0.633 0.070395 Home furnishings

Thomasville Furniture - Lenoir Plant 0.48 0.023 Home furnishings

Tru-Wood Cabinets Inc 0.14 0.06 Cabinetry

*All updated emissions data is self reported through conversations via telephone 
Attachment 1

Alabama Inter-Forest Corporation

According to our data from the National Emission Inventory (NEI) in 2005, your emissions 

based on your coatings was 1.35 tpy. 

What is your actual amount of emissions of formaldehyde from the past year?

Facility representative did not have information in front of him, but said that it was just 

about 0.1 tons.

Bertch Cabinet Manufacturing 

According to our data from the National Emission Inventory (NEI) in 2005, your emissions 

based on your coatings was 0.75 tpy. 

What is your actual amount of emissions of formaldehyde from the past year?

72 lb per year

Do you use low- (<1%) or no- formaldehyde coatings?

Yes

How much coating (volume) is used in a year?

21.3 tons & 15.7 tons & 10.3 tons = 47.3 tons = 94,600 pounds ~ 12,613 gallons

Legacy Cabinets 

According to our data from the National Emission Inventory (NEI) in 2005, your emissions

based on your coatings was 1.1 tpy. 

What is your actual amount of emissions of formaldehyde from the past year?

ADEM reporting for last year – 0.0009 TPY

Do you use low- (<1%) or no- formaldehyde coatings?

Most coatings don’t have HCHO but was not given a number

How much coating (volume) is used in a year?

In December:

8,799 gallons coatings 89 gallons of adhesive 550 gallons cleaning solvent

Approx in a year:
105,600 gal coating 1,068 gal adhesive 6,600 gal of cleaning solvent

Total: 113268 gallons of applicable coatings

Republic Industries Inc. (includes Plywood Cabinet Plant)

According to our data from the National Emission Inventory (NEI) in 2005, your emissions 

based on your coatings was 0.677 tpy. 

What is your actual amount of emissions of formaldehyde from the past year?

222 lbs/year at 40% of capacity

Stanley Furniture Company 

According to our data from the National Emission Inventory (NEI) in 2005, your emissions 

based on your coatings was 0.633 tpy. 

What is your actual amount of emissions of formaldehyde from the past year?

140.79 pounds of HCHO last year

Do you use low- (<1%) or no- formaldehyde coatings?

No formaldehyde in finish coating; 0.1% & 0.5% in contact adhesives

Thomasville Furniture – Lenoir facility

What is your actual amount of emissions of formaldehyde from the past year?

331 pounds (46 lbs from gluing and rest from combustion sources)

Which coatings used contain formaldehyde?

Only contact adhesives amounting to 46 pounds last year

Tru-wood cabinets

What is your actual amount of emissions of formaldehyde from the past year?

120 pounds HCHO from 2010

Do you use low- (<1%) or no- formaldehyde coatings?

0.018 lb/gal HCHO max content in coating (assume a density of ~8lbs/gal for the coating 

 0.018lb HCHO/gal coating = 0.225% HCHO in coating

What types of coatings contain formaldehyde?

Found mostly in Topcoats and sealers