Draft for Discussion Purp oses Only



### 3 / 1 3 /201 4 California Air Resources Board

Staff P roposal Alternate Regulatory Approach for Laminated Products Made with Wood Veneer *

Definition of Laminated Products California’s regulation to reduce formaldehyde emissions from composite wood products defines “laminated products” as “a finished good or component part of a finished good made by a fabricator in which a laminate or laminates are affixed to a platform.” I f the platform consists of a composite wood product, that product must comply with the applicable emission standards.

Proposal Establish 0.13 ppm formaldehyde emission performance standard for laminated products made with wood

veneer

.

 The standard would apply to unfinished (i.e., no coating or topcoat) wood

- veneered laminated products.

 O ther requirements for all laminated products (i.e., labeling, use of certified platform material) would continue (i.e., for laminated products made wi th synthetic laminate and wood veneer)

.

 R outine quality control testing and third party certification of laminated products are not required. Fabricators would determine the best way to ensure laminated products meet the standard.

 Enforcement testing w ould consist of testing a specimen of a wood

- veneered laminated product based on the flow

- to

- area ratio for medium density fiberboard (as specified in ASTM D 6007 , the small chamber test method ).

Basis

 Performance standard is based on the highest Phase 2 emission standard for products used as platforms for laminated products, that of thin medium density fiberboard.

 Approach treats laminated products as distinct from hardwood plywood

. U nlike HWPW

- CC
, laminated products are not sold as hardwood plywood panels and are not labeled as complying with the ANSI/HPVA HP

- 1 standard for hardwood plywood

.

 HWPC

- CC panels are produced by several hundred mills worldwide ; laminated products are produced by fabrica tors that number in the tens of thousands . There is not sufficient TPC/testing capacity to require fabricators to be subject to similar testing requirements as panel producers

.

Benefits

 E stablishes an emission ceiling and achieve s additional emission re ductions beyond the current regulation by ensuring that a laminated product do es not result in emissions any greater than a certified platform.

 Performance based

.

 Minimizes economic burden on small businesses

.

 Simplifies enforcement

- minimal deconstruction of laminated products will be needed to remove coating , if present ; no need to determine the type of platform material , unless verifying that platform was made of compliant material . Laminated products sold as finished goods or incorporated as component parts of finished goods will be enforced to laminated product standard

.

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### * Air Resources Board staff is developing proposed amendments to California’s regulation of formaldehyde emissions from composi te wood products. This one
- page summary provides staff’s current proposed changes to the requirements for laminated products that will be discussed at a public workshop on March 18, 2014

. No changes are being proposed for laminated products made with synthetic laminate. More information on the workshop can be found at www.arb.ca.gov/toxics/compwood/compwood.htm

.