A close look at the formaldehyde issue: Wood Cuts - Apr 2016
By Brett Miller
Anyone working in the flooring industry these days is likely familiar with the recent media coverage regarding formaldehyde emission levels from flooring. Although the product in question was really just one specific category type—laminate—the media frenzy seemed to paint the entire flooring industry with one broad brush stroke. The result is that many consumers were left feeling both confused and frightened.
It is not just consumers, either. Many people working in the industry are confused about how to reassure their customers that the products they are purchasing are safe. Some probably didn’t even consider what a CARB label really meant. Now more than ever, it is important to understand exactly what the issues are, and to address them in a confident and knowledgeable manner to alleviate fear and misunderstandings.
The media has reported that the flooring in question was noncompliant with CARB. It makes sense, then, to first gain a thorough understanding of exactly what CARB is.
WHAT IS CARB?
CARB is an acronym for the California Air Resources Board, an agency established in 1967 by then-governor Ronald Reagan to regulate air quality in the state of California. In a nutshell, the mission of CARB is to protect the public from harmful exposure to airborne contaminants, which can include high levels of formaldehyde.
In 2009, CARB established the world’s toughest standard for limiting formaldehyde emissions from composite wood products. The standards themselves are only legally enforceable in California; however, most producers sell CARB compliant flooring in all regions. More importantly, the U.S. federal government is now finalizing regulations that will largely duplicate CARB on a national level. Although the exact release date for these new regulations is not known, the Environmental Protection Agency (EPA) has stated it would like to begin the roll out this summer. Canada is working on standards duplicating aspects of CARB as well.
It may come as a surprise to many, including those of us in the flooring industry, that CARB does not directly regulate flooring, as the media coverage implied. There is no such thing as a CARB certified floor. CARB does, however, regulate composite wood components—plywood, particleboard, medium-density fiberboard (MDF) and thin MDF—that are found in many types of flooring. In fact, what we in the flooring industry call CARB is actually just one small part of the entire California agency’s program, specifically the Airborne Toxic Control Measure (ATCM) number 93120. This is the state order that governs the allowed formaldehyde emission level, certification procedures, and chain of custody requirements for composite wood panel products produced or sold in California.
The CARB program provides certification of these four specific panel types and considers a flooring to be compliant if it uses a properly certified product and meets certain administrative requirements. These requirements include undertaking “reasonable prudent precautions” to ensure the product in question meets CARB standards. Independent testing by buyers is not required, as the media reports implied, but can serve to provide additional assurance.
CONTENT VERSUS EMISSIONS
When you look at formaldehyde in terms of composite wood products (like the plywood used in engineered wood flooring or the MDF used in laminate flooring, for example), you have two ways to consider the issue: content vs. emissions.
As stated in the final CARB rule, Airborne Toxic Control Measure to Reduce Formaldehyde Emissions from Composite Wood Products, CARB is not about what formaldehyde goes into the product; CARB is about what formaldehyde emissions come out of a product. This is an important distinction because, while it might seem logical that higher formaldehyde content would lead to higher emissions, this is not always the case.
There are a host of other production process variables that ultimately determine the emission properties of a product. These can include things like the addition of so-called “catchers” or the glue blend (phenol vs. melamine, for example), the press conditions, etc. Time can be a factor, too, as can be the type of material being processed. In fact, two companies can have the same formaldehyde content in their glue, but their finished products might have very different emission profiles based on these other issues. Sales staff should be fully educated so that they can explain these distinctions to customers who are concerned about indoor air quality.
HOW CARB WORKS
Current CARB regulations require that certified composite wood panels meet specified emissions performance standards, regardless of what resins are used in their production process. All mills producing such panels are required to have third-party certification that their production procedures will lead to the required results. CARB therefore focuses on two primary issues: emission levels and documentation.
CARB formaldehyde emission limits are set at 0.05 ppm (parts per million) for hardwood plywood, at 0.11 ppm for MDF more than 8mm thick, and at 0.13 ppm for thin MDF of 8mm or less. CARB also regulates particleboard at 0.09 ppm. That’s a fraction of a part per million, but remember, it is the world’s strictest standard. Remember, too, that these standards are for flooring cores—emissions from floors are often even less because the top veneers block what might come out of the core.
As for documentation, all downstream buyers, including value-added manufacturers, importers, distributors and retailers, must follow certain documentary procedures to ensure a chain of custody that would allow the State of California to trace a product retailed in California back to the original panel manufacturer. When completing purchase orders, buyers should indicate that they want CARB certified (such as plywood or MDF) or CARB compliant (such as flooring or kitchen cabinets) material on the order, and they should ensure that their suppliers are doing the same. No matter where a company is on the distribution chain, it should be sure to maintain documentation showing that it requested and received CARB compliant material. CARB regulations state that records should be kept for a minimum of two years.
Typical labels on floor packaging say, “California 93120 Phase 2 Compliant for Formaldehyde Emissions.” Note that CARB had two phases as it was introduced to the industry. Phase 1 has long since passed, so everything should now say “Phase 2” or “P2” for short. Labels might also include phrases like “no added formaldehyde” (NAF) or “ultra-low emitting formaldehyde” (ULEF), which are special categories under CARB.
CARB AND FLOORING
How does all of this relate to flooring? First, let’s consider where CARB might impact real wood flooring products. Wood flooring comes in two primary forms: solid and engineered. While you can certainly test for emissions from a solid floor, CARB would only apply to engineered flooring that was manufactured with either a plywood or an MDF core, both of which are CARB-regulated composite wood products. The third structure common to engineered flooring, often called a lumber core, would not be regulated by CARB since it is produced using strips of solid timber sandwiched between pieces of veneer.
The product under the media scrutiny is laminate flooring, which is MDF covered on the face and back with a paper overlay. The top paper has a visual on it that looks like wood or stone or tile or leather or anything at all—it’s just a picture. When the laminate in question was tested, the floor itself wasn’t actually tested. Remember, the floor isn’t directly regulated by CARB, the MDF component is. So to test the product, the laboratories had to carefully sand off the paper face to expose the MDF underneath. This is called a “deconstruction” test.
This fact brings us back to the recent negative media attention around this issue. The media reports have created a firestorm, with consumers believing that any flooring product in their homes could lead to negative health consequences. However, while it is true that many of the laminate MDF cores tested were found to have higher than permitted emission levels, it does not necessarily mean that the majority of the laminate flooring itself was unsafe after installation. Among other factors, the paper on the face will block a lot of emissions.
At the time of printing, the U.S. government is still working on its final report, but the early indicators are that for most people, any excessive emissions from laminate flooring will not be a significant health risk. In fact, the government’s investigation into the flooring noted that, in some cases, ripping out the laminate could cause more health hazards than leaving it in place. It is also important to note that emissions do reduce over time.
More important, the industry should understand that the primary lawsuits are not about potential health hazards resulting from high emission levels. The lawsuits are based on charges of false advertising, breach of warranty, negligence or fraud—questioning whether or not the laminate was CARB compliant as advertised and labeled.
WHAT OF FORMALDEHYDE?
Formaldehyde, despite all the bad publicity, is not considered toxic in normal conditions. It is a naturally occurring substance, and it’s everywhere. Think of it as being similar to sunlight. It occurs naturally and we cannot live without it, but just like sunlight, at higher exposures it becomes an irritant. And just like sunlight, different people have different sensitivity levels, so some will react more severely or more quickly than others.
We are all exposed to naturally occurring formaldehyde daily. In fact, the average person processes about 1.5 ounces of formaldehyde each day as part of normal human metabolism. Formaldehyde is normally present in human blood at a low, steady-state concentration of about one to two parts per million. The World Health Organization and Health Canada have estimated that the average adult ingests nine times more formaldehyde each day from food than they inhale from all airborne sources combined. Formaldehyde is used in the production of clothing, vaccines, detergent and many other products.
Consider this as well: if the average person were to inhale secondhand smoke from five cigarettes within 30m2, they would breathe in formaldehyde levels of 0.23 ppm—that’s over four times what is allowed to be emitted by your engineered floor’s plywood core. Even more alarming, however, is that directly smoking just one cigarette will put 40.0 ppm in your lungs. This equates to roughly 400 times the formaldehyde emitted from CARB certified MDF.
The bottom line is that formaldehyde, like all naturally occurring substances, is generally not a problem under normal conditions, but can become an irritant or even a health hazard at higher levels of exposure. So we have regulations for a reason, and they should be followed to protect consumers and the workforce that manufacture the products in question.
You can do your part to serve your installation crews and your customers by insisting on compliant products that limit unnecessary exposure, and by providing customers with the accurate information they need to make informed purchasing decisions.
The current CARB emission limits are lower than other established standards for formaldehyde emissions. The World Health Organization limit is 0.10 ppm, the European E1 Standard limit is 0.10 ppm, the US Department of Labor (OSHA) permissible exposure level in the workplace for an eight-hour time-weighted average is 0.75 ppm, while the OSHA Hazard Communication Standard requires labels on any manufactured product that may emit 0.10 ppm or higher.
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