Grass and TSCA

We’re back to formaldehyde and TSCA. And when I am talking ‘grass,’ I’m not talking something you smoke or eat—I’m talking woody fiber like bamboo or rice.

There was a lot of confusion about CARB and its treatment of bamboo flooring in the early days. TSCA has tried to make that very clear by saying that a “veneer” is not just made of wood, but could also be made of a “woody-grass.” The new definition of “veneer” is:

Veneer means a sheet of wood or woody grass with a maximum thickness of 6.4 millimeters (1/4 inch) that is rotary cut, sliced, or sawed from a log, bolt, flitch, block, or culm; including engineered veneer.

EPA further defines “woody grass” as, “a plant of the family Poaceae (formerly Gramineae) with hard lignified tissues or woody parts.”

This removes any confusion regarding engineered bamboo flooring—if you are starting with a plywood, MDF or particleboard platform and add bamboo veneer to it, or if you produce plywood that is constructed of veneers of bamboo, then that product is regulated by TSCA Title VI and is subject to the third-party certification requirements for panel producers and/or laminated product producers, as applicable.

As a note, what the industry calls “Solid” bamboo (vertical, horizontal) and “Strand bamboo” are still out of scope of TSCA because these products are constructed using different means and do not meet the EPA or CARB definitions of hardwood plywood, MDF, or particleboard.

And finally, CARB is expected to modify its definitions of veneer in the next update to match the EPA.

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