President Obama recently signed into law a bill (S. 1660) to reduce chemical emissions from certain wood products and materials that are used in commercial office buildings and other structures.
The new law amends the Toxic Substance Control Act to establish the first national emissions standard for formaldehyde in new composite wood products and is considered the most rigorous production standard worldwide. The measure requires the U.S. Environmental Protection Agency (EPA) to develop a new federal regulation by January 2013 to implement its provisions, which will become effective in July of that year.
When asked by what extent indoor air quality could be improved through implementation of this law, Air Quality Sciences President Tony Worthan told GBI, "Considering typical use in flooring, cabinetry, and furniture, these lowered amounts of allowable formaldehyde from manufactured wood boards could result in up to a 50 percent reduction in formaldehyde emissions relative to what is found in residential environments today."
For many years, formaldehyde has been a key ingredient in most adhesives used to make composite wood products. Its reactive nature allows formaldehyde to cross-link with other ingredients to form a strong, cost-effective bond. Results from scientific studies, however, have demonstrated that inhalation of formaldehyde from composite wood products containing urea formaldehyde resins is one the primary sources of human formaldehyde exposure. The Centers for Disease Control and Prevention believes that acute and chronic health effects from exposure to formaldehyde vary depending on individual sensitivity. Upper respiratory tract irritation can exacerbate asthma symptoms and other respiratory illnesses, but there is no evidence that exposure to formaldehyde causes asthma, nor is it considered to have reproductive or developmental effects on humans. Whether or not formaldehyde causes cancer has been studied and debated over the past 30 years and continues to be controversial. In 1992, the California Air Resources Board (CARB) formally listed formaldehyde as a toxic air contaminant in California with no safe levels of exposure.
Based on last year's CARB regulation, which is still in effect and will be fully implemented in 2012, the federal standards were developed with broad support from the entire composite wood products supply chain and other stakeholders. The law establishes a transparent chain of custody and manufacturer quality assurance requirements. The measure also requires third-party testing and certification and directs EPA to work with U.S. Customs and Border Protection and other relevant federal agencies to enforce the standards on imports.
The new federal standards apply to the following products:
- All finished products containing composite wood products for sale in the U.S., including hardwood plywood (HWPW), particle board (PB), and medium density fiberboard (MDF).
- Hardwood plywood made with a veneer core (HWPW-VC).
- Hardwood plywood made with a composite core (particle board or MDF) (HWPW-CC).
- Composite wood products made with ultra-low-emission formaldehyde (ULEF) or no added formaldehyde (NAF) resins.
The following table lists the federal formaldehyde emissions standards for composite wood products based on the primary test method, ASTM E 1333-96 (2002), and quality control test methods ASTM D-6007-02 or ASTM D-5582.
In its rulemaking, EPA may exempt some products made with ULEF resins from third-party certification if emissions do not exceed 0.04 ppm for 90 percent of the six months routine quality control testing data and no test results surpass 0.05 ppm for HWPW and 0.06 ppm for PB, MDF, and thin-MDF.
Used products, such as second-hand furniture and antiques, are exempt as research has indicated that formaldehyde emissions diminish significantly as products age and it is therefore considered unlikely that these products would have emission levels exceeding the new federal standard. In addition, the new law does not apply to components or assemblies that are part of composite wood products, presumably because the entire product itself is covered by the law.
Other exemptions include hardboard; structural plywood, panels and composite lumber; oriented strand board; glued laminated lumber; prefabricated wood I-joists; finger-jointed lumber; wood packaging; and composite wood products inside of new motor vehicles, rail cars, boats and aircraft (aeronautical and space). In addition, the law does not apply to windows or exterior doors and garage doors that contain composite wood products if the doors are made from composite wood products manufactured with NAF or ULEF resins or the doors contain less than 3 percent by volume of hardwood plywood, particleboard, or medium-density fiberboard combined. It also does not apply to other products that may contain formaldehyde such as fabrics and insulation.
It is uncertain what the penalties will be for non-compliance, Worthan said. "Final regulations have not been written although the [law] requires that EPA develop a new federal regulation by January 2013."
"The law will place further emphasis on the importance of clean indoor air relative to human health as the majority of our time is spent indoors versus outdoors," Worthan said. "Many incentive-based 'green' programs push offsets for pollutants in outdoor air, which does very little to impact energy use and even less to promote healthy indoor environments. With the release of this law, the hope is that all of these elements may work cooperatively for improved building, living, and energy efficiency. Likewise, use of low-formaldehyde wood materials will help decrease formaldehyde levels within newly constructed homes and buildings and assist in reaching the formaldehyde building clearance levels of LEED [Leadership in Energy and Environmental Design] and other green building requirements."
Steve Rizer, Editor
Green Building Insider