WASHINGTON - The U.S. Environmental Protection Agency (EPA) is giving stakeholders an additional 16 days to comment on its proposed Formaldehyde Emissions Standards for Composite Wood Products, especially those who want a say on how the EPA will treat laminated wood products in its rule.
EPA will entertain public comments through May 24; the previous deadline had been May 8. EPA has expressed interest in CARB's potential modifications to its Airborne Toxics Control Measure to Reduce Formaldehyde Emissions from Composite Wood Products to address laminated products.
The Federal Wood Industries Coalition (FWIC), a group of more than a dozen industry trade associations led by the Composite Panel Association (CPA), has encouraged EPA to adopt the California's Air Resource Board's (CARB) rule for formaldehyde emissions from composite wood products as the national standard. FWIC also supports a proposal by CARB that would establish a 0.13 ppm formaldehyde emission performance standard for laminated products made with wood veneer. Among the criteria, the standard would apply to unfinished wood-veneered laminated products and enforcement testing would be performed on a product specimen, based on the flow-to-area ratio for MDF.
EPA said it has received a wide variety of public comments on the regulation as it pertains to laminated wood products. Comments include:
• Some have argued that laminated products should be exempted from the definition of hardwood plywood or otherwise be held to the same testing requirements as hardwood plywood.
• Several commenters suggest that EPA should consider self-certification for smaller companies. One of these commenters suggested excluding small companies that produce less than 100,000 square feet per year from the testing and certification requirements.
• Some other commenters suggested that it would be appropriate to limit the required testing to once a year and require laminated product producers to test only their highest emitting product.
• Another commenter said that, because hardwood plywood is indistinguishable from laminated products, the hardwood plywood emission standard is appropriate.
• Yet another commenter said, EPA's proposal “gives no credit or recognition to the significant reduction in emissions when a product is laminated and finished.”
In regard to laminated products, EPA said it is is considering one, or a combination of, the following: CARB's latest proposal; a reduced testing program for laminated products, a self-certification program for laminated products, an exemption of laminated products from the definition of “hardwood plywood”; or an exemption from testing and certification requirements for all laminated products or just those made by a low-volume producer.
EPA requests comment and information on what an appropriate production volume threshold for testing and certification might be. EPA is also considering whether third-party certification should be required for laminated products if emission testing for these products is required; what emission standard, if any, would be appropriate for laminated products; and whether laminated products should be grouped for testing purposes.
To learn more about the EPA's proposed wood composite panel formaldehyde rule or to comment, check out the Federal Register.
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