1 

### 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

22 

### 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

3



### • 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

43 

## Proposed Amendments – Changes Since November 2013 Public Workshop Title 17, California Codeof 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 adj ust federal proposal where appropriate 

### • Propose ATCM amendments for ARB consideration after U.S. EPA regulation finalized

64 

### • Definitions • Hardboard • Hardwood Plywood • Labeling • NAF/ULEF • Third Party Certification • Laminated products
7



### • 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

85 

### • Additional criteria added tohardboard 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

9



### • Require 2-ply HWPW and HWPW made with lumber core, spec ial 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

106 

### • 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

11



### • QC testing requirement for mills that produce in infrequent intervals  If production < 7 days/month, requi re 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 co llected over a minimum period of one week



### • 

### For NAF HWPW, platform must also comply with NAF requirements

127 

### • 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 certificati on statement that the

resin formulation and additives will not change

13



# • 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

148 

# • 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? 15



# • 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 169 

# • 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)

1810 

### • Should all TPCs and contract l aboratories 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

19



# • 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

2011 

# LAMINATED PRODUCTS

• Applies to laminated products made by fabricators  Laminate consists of wood veneer or synthetic material


# • Requires use of certified platform material

2212 

# • 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 23

• Establish new formaldehyde emission performance standard of 0.13 ppm fo r 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
2413 

### 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

25



### • 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

2614 

### • Applicability - Who is subject to the 0.13 ppm laminated products standard?

 Fabricators of componentparts and finished goods  If wood veneered laminated product being sold to panel distributor or retaile r, then considered HWPW and must be third party certified

27

• Request for disclosure of panel producer’s verification data to fabricators

 Propose to rely on fabricators negotiating separate agreement wit h 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

2815 

### • 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)

29



# OPEN DISCUSSION16 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

31