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Public Workshop to Discuss Proposed 

Amendments to the Airborne Toxic Control 

Measure to Reduce Formaldehyde Emissions from 

Composite Wood Products 

March 18, 2014

Sierra Hearing Room

Cal/EPA Headquarters, Sacramento

California Environmental Protection Agency

Air Resources Board

• Status of U.S. EPA regulation and ARB 

amendments 

• Proposed amendments to the 

Composite Wood Products ATCM -

changes since November 2013 public 

workshop

• Laminated products discussion

• Next steps

• Open discussion

Workshop Overview

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U.S. EPA 

• Process of evaluating comments

• Public meeting: Spring 2014 

• Revised regulations to be submitted to Office of 

Management and Budget (OMB): Spring 2014

• Goal for final regulations release: Fall 2014

• Implementation begins: Fall 2015

ARB

• Continue dialogue with U.S. EPA to align the rules to 

the extent feasible

• Board consideration in late 2014 or early 2015

 Will occur after U.S. EPA regulations finalized

Status of U.S. EPA Regulation 

and ARB Amendments 

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• Ongoing, productive discussions 

between U.S. EPA and ARB staff

 Close collaboration on identifying path to 

harmonization

 Evaluating reciprocity mechanisms for third party 

certification and NAF/ULEF approvals 

 U.S. EPA participation in ARB workshops and 

discussion sessions

 Requesting approval for ARB staff to attend 

U.S. EPA public meeting

Efforts to Harmonize with 

U.S. EPA’s Proposed Regulations

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Proposed Amendments –

Changes Since November 2013 

Public Workshop

Title 17, California Code of Regulations, 

Section 93120 

• Clarify requirements and applicability

• Improve enforceability

• Align ATCM with proposed U.S. EPA 

regulations to extent practicable

 Encourage U.S. EPA to adjust federal proposal 

where appropriate

• Propose ATCM amendments for ARB 

consideration after U.S. EPA regulation 

finalized 

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• Definitions

• Hardboard

• Hardwood Plywood

• Labeling 

• NAF/ULEF 

• Third Party Certification 

• Laminated products

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• Modified format for definitions with references 

to ANSI standards: MDF, hardboard, HWPW, 

and PB

• Added definitions for accreditation body, 

coating, IAF, ILAC, ply, subcontractor, 

synthetic material

• Added clarification to the definitions for 

fabricator, finished goods, laminate, laminated 

product, and platform 

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• Additional criteria added to hardboard definition to 

reflect ANSI standard

 Consolidated under heat and pressure in a hot press by 

(A) a wet process; or (B) a dry process that uses:

(1) a phenolic resin, or

(2) a resin system in which there is no formaldehyde as part of 

the resin cross-linking structure; or 

(C) a wet-formed/dry pressed process

• Hardboard with formaldehyde emissions 

≤0.06 ppm is exempt. If >0.06 ppm, then subject 

to MDF requirements

• Added exemption to 93120(d) to reflect change

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• Require 2-ply HWPW and HWPW made 

with lumber core, special core to meet 

0.05 ppm standard 

 Aligns with proposed U.S. EPA regulation

• Require HWPW with bamboo or cork 

veneer to comply with the HWPW 

0.05 ppm standard

• Platform for HWPW required to 

comply

• Propose added products be subject to 

emissions limit beginning July 2016

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• No change in labeling requirements for 

panel manufacturers

• Requirements for panel distributors, 

importers, and retailers of panels and 

finished goods

 Copy of panel bundle labels must be available 

upon customer request for sale of partial bundles

 If not individually labeled, method of identifying 

supplier of panel (or finished good) required 

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• QC testing requirement for mills that produce in 

infrequent intervals

 If production < 7 days/month, require minimum of 7 QC tests and 

one primary or secondary method test. 

• For approved NAF/ULEF that have changes 

(i.e., resin system, addition of products)

 Require submittal of one primary or secondary method test and a 

minimum of 5 QC test results collected over a minimum period of 

one week 

• For NAF HWPW, platform must also comply with 

NAF requirements 

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• Eliminate requirement to provide detailed 

resin formulation as part of NAF/ULEF 

applications

Assurance needed that resins and additives 

are not changed over duration of approval

− Require resin supplier name and resin name 

− Signed and dated certification statement that the 

resin formulation and additives will not change

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• Efforts underway to develop reciprocity 

with U.S. EPA concerning the TPC 

program

• ARB staff conducted informal survey of 

TPCs (February 2014) to obtain input on 

TPC program

• Survey responses shared with U.S. EPA 

staff

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• TPC Survey Questions

How many TPCs have or plan to obtain ISO 17065? 

Should ARB ATCM be included in the scope of 

AB’s audits?

Should TPC’s accreditation scope include 

conformance with ISO 17020?

AB’s willingness to enter into a recognition 

agreement?

Acceptability of relying on the secondary method 

evaluation for interlaboratory comparisons?

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• How many TPCs have or plan to obtain 

ISO 17065? 

 Most TPCs intend to obtain ISO 17065 by the end of 2014,

 Cost is between $ 10,000 to 20,000

• Should ARB ATCM be included in the scope of 

AB’s audits?

 ATCM should be included in the scope of AB audits, but it 

may be difficult for ABs to audit specifics of ATCM

 $ 3,000 to 5,000/audit; many have partial audit annually

 Most TPCs accept concept of ATCM audit every two years

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• Should TPCs accreditation scope include 

conformance with ISO 17020?

 All but one TPC agree that ISO 17065 covers 17020, 

thus retaining ISO 17020 is not needed

 Proposing to only require ISO 17020 for TPCs that use 

subcontractors for inspections

• AB’s willingness to enter into a recognition 

agreement?

 TPCs questioned whether ABs would be willing to enter 

into agreement; being members of ILAC or IAF should 

be sufficient

 Most willing to share AB info with ARB & U.S. EPA 17

• Acceptability of relying on the secondary 

method evaluation for interlaboratory 

comparisons?

 Most TPCs find it an acceptable approach, but 

several suggest continuing to periodically include 

large chambers in ILC evaluations

 One TPC indicated the cost of obtaining a small 

chamber was too high for a small TPCs 

(establishing equivalence to primary method) 

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• Should all TPCs and contract laboratories 

be required to operate secondary method

 Most TPCs/labs possess small chambers

 After equivalency established, can be used 

for certification and verification tests

 Allows one panel to be sent for ILCs, 

eases cost, logistics and preparation

• Viable option as long as periodic large 

chamber testing is conducted in ILCs 

based on TPC survey

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• Adjustments to accreditation 

requirements: 

Require that accreditations for product 

certification, inspection procedures, and 

laboratory operations be issued by ABs that 

are signatories to IAF or ILAC

Approach is consistent with U.S. EPA 

proposal

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LAMINATED PRODUCTS

• Applies to laminated products 

made by fabricators

 Laminate consists of wood veneer or 

synthetic material

• Requires use of certified platform 

material

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• Opportunities for additional emission 

reductions beyond the current ATCM

• Laminated products proposal presented 

at November 2013 public workshop

• Proposal modified based on 

stakeholder input

 No change to current ATCM requirements for 

laminated products made with synthetics

 Proposal applies to laminated products with wood 

veneers

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• Establish new formaldehyde emission performance 

standard of 0.13 ppm for wood veneer laminated 

products

 Standard would apply to laminated products consisting of 

unfinished wood veneer (i.e., no coating) affixed to certified 

platform

• Other requirements would continue (i.e., labeling, 

use of certified platform)

• Routine quality control testing and third party 

certification not required 

 Fabricators determine best way to ensure compliance

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Laminated Products

Revised Approach

(continued)

• Requirements for synthetic laminated 

products unchanged

 Synthetic laminated products still need 

certified platform

 Synthetic material does not include coatings 

or finishes

• Added definition of synthetic material to clarify

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• Achieves additional emission reductions 

beyond ATCM requirements

• Performance-based

• Minimizes economic burden on small 

businesses

• Simplifies enforcement

 Minimal deconstruction needed to determine 

compliance with 0.13 ppm standard

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• Applicability - Who is subject to the 0.13 ppm 

laminated products standard?

 Fabricators of component parts and finished goods

 If wood veneered laminated product being sold to 

panel distributor or retailer, then considered HWPW 

and must be third party certified

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• Request for disclosure of panel producer’s 

verification data to fabricators

 Propose to rely on fabricators negotiating 

separate agreement with their suppliers

 Fabricators can pursue Public Records Act 

Request with CARB if supplier uncooperative

 CARB will monitor and if is issue, will consider 

proposing amendments to regulation 

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• Evaluate stakeholder input 

• Additional collaboration on key issues

• Participate in U.S. EPA public meeting 

• Evaluate U.S. EPA’s final regulation 

• Additional public workshops as needed

• ARB Board consideration (after release of 

final U.S. EPA federal regulation)

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OPEN DISCUSSION
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Angela Csondes, Air Pollution Specialist

916-445-4448 or acsondes@arb.ca.gov

Lynn Baker, Staff Air Pollution Specialist

916-324-6997 or lbaker@arb.ca.gov

Peggy Taricco, Manager

916-323-4882 or ptaricco@arb.ca.gov

Composite Wood Products ATCM Website: 

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

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