According to the California Department of Public Health, formaldehyde can irritate the skin, eyes, nose, and throat. High levels of exposure have been linked to numerous health problems, including cancer and asthma. Consumers are exposed to formaldehyde via adhesives that are used to bind together fibers, particles, and wood veneers commonly seen in particleboard, medium-density fiberboard, and other hardwood plywood that is ultimately used in finished products such as flooring, furniture, and cabinetry. In 2008, the California Air Resources Board (CARB) set stringent standards for complying with the code for formaldehyde emissions, referred to as the Airborne Toxic Control Measure (ATCM 93120). Manufacturers of composite wood products destined for the California market were required to prove code compliance for low formaldehyde emissions under CARB’s ATCM 93120.
On December 12, 2016, the EPA took direct action by mirroring California’s standards and amended a final rule that was published in it’s Federal Register outlining new national standards concerning formaldehyde emissions for composite wood products. The act, known as the Toxic Substance Control Act (TSCA) Title VI, requires any company who imports, manufactures, sells, supplies, or offers for sale hardwood plywood, medium-density fiberboard, particleboard, and/or products containing composite wood materials destined for sale in the US to be labeled TSCA Title VI-compliant. Prior to March 22, 2019, products certified as CARB-approved were also considered certified under TSCA Title VI; however, after that date, wood products must be certified by an EPA TSCA Title VI-certified TPC and labeled as such. Further, fabricators using composite wood products to create finished items (e.g. furniture) need traceability; they must be able to provide records that they have purchased TSCA Title VI-certified composite wood.
What are the requirements?
The EPA requires that testing MUST be completed by a certified and approved Third Party Certifier (TPC).
The regulation outlines detailed requirements for quality control testing, frequency of the testing, and testing when changes in resin formulation are made. Initial and quarterly compliance chamber testing must use one of the following ASTM tests or equivalent:
- ASTM E1333: Standard Test Method for Determining Formaldehyde Concentrations in Air and Emission Rates from Wood Products Using a Large Chamber. See ASTM E1333 Video Demonstration here.
- ASTM D5582: Standard Test Method for Determining Formaldehyde Levels from Wood Products Using a Desiccator.
- ASTM D6007: Standard Test Method for Determining Formaldehyde Concentrations in Air from Wood Products Using a Small-Scale Chamber. See ASTM D6007 Video Demonstration here.
Once products are certified as TSCA Title VI-compliant, the EPA has outlined specific requirements for product labeling to include certification number from the TPC, a statement that product is TSCA Title VI-compliant, manufacturer lot number, and name of manufacturer or fabricator. Ongoing factory inspections must occur in order to assure continued quality, compliance, and safety.
Detailed recordkeeping is another important aspect of TSCA Title VI. Records demonstrating compliance, as well as continued and ongoing quality control, must be maintained and produced when necessary. If requested by the EPA, the records must be produced within 30 days. For importers, manufacturers, fabricators, distributors, and retailers, it is important that records be kept for a period of three (3) years. The recordkeeping aspect can become complicated, especially for fabricators who may use multiple types of wood products in a single piece of furniture.
ICC NTA, LLC is an industry expert in formaldehyde and formaldehyde testing. Approved by CARB and the EPA as a third-party certifier and testing lab, ICC NTA offers a single-source solution for all formaldehyde testing, inspection, certification, evaluation, and follow-up services. ICC NTA is qualified and certified to provide the following range of services for manufacturers who require TSCA Title VI and/or CARB compliance:
- CARB/TSCA Title VI certification and labeling
- Product testing for formaldehyde emissions in composite wood products manufactured for US consumers
- Factory inspections and/or factory audits
- Quality control review and assurance
- Quality control manuals
Manufacturers find value in using a TPC that also offers follow-up services such as testing, labeling, and factory inspection. Having all required services performed by a single vendor saves a significant amount of time and money, helping manufacturers get their products to market as quickly as possible. ICC NTA is accredited under ISO/IEC 17025 to test, ISO/IEC 17020 to inspect, and ISO/IEC 17065 to certify.
If you need assistance understanding the specific requirements for CARB/TSCA Title VI compliance as it relates to your product, you may review the frequently asked questions on the California Air Resources Board website or better yet, speak to an expert by calling ICC NTA at 574-773-7975.