So last week I made a reference to a TSCA label that might read as:
This engineered flooring was manufactured with
plywood (HWPW-VC) compliant with EPA TSCA
Title VI and CARB ATCM 93120 Phase 2
And I realized that the acronyms nearly outnumbered the actual full words. So let’s look at them:
You should know all of these already:
EPA: United States Environmental Protection Agency
TSCA: Toxic Substances Control Act
CARB: California Air Resources Board
ATCM: Airborne Toxic Control Measure
The product, HWPW-VC (and its companion reference, HWPW-CC) may not be as familiar.
HWPW: HardWood PlyWood
-VC: Veneer Core (this is what you think of when you think “plywood,” lots of thin veneer piled up.)
-CC: Composite Core (this is MDF or particleboard sandwiched between wood veneer layers)
And while we’re at it, other CWP (Composite Wood Products) are:
PB: Particle Board
MDF: Medium Density Fiberboard (actually, ALL densities of fiberboard)
tMDF: (thin MDF which is ≤ 8 mm thick, often marked as HDF, even though HDF doesn’t really exist…)
And these products might be:
ULEF: Ultra Low Emitting Formaldehyde
NAF: No Added Formaldehyde
This is important because you might look at the list of CARB certified panel producers and see:
You need to know that the mill you’re buying from is making what you want to buy. If they aren’t listed as tMDF and that’s what you want, investigate! Sometimes (often) it’s a simple mistake in the data. If you write to your mill, they can tell their TPC to change it. (I once had a mill go through three corrections before their data in the database matched their actual certification status.) But if it’s not a mistake, don’t buy what they aren’t cleared to make.
Oh, and what’s a FER? That’s mine. I got tired of typing things like “TSCA and CARB” in my various SOPs or worse, “TSCA and CARB and the upcoming Canadian regulation.” So I started using “FER,” “Formaldehyde Emission Regulations.” It covers the two we have now and any that come up later. If you are selling something in Japan, it could cover JAS (Japanese Agriculture Standard) regulations as well. It’s all encompassing and saves me a lot of typing. “Follow the FER,” “Comply with the FER,” “This is covered by FER.” No, I won’t be labeling that way, but you may see me write more about our FERry Future.
Reminder: Don’t forget to attend the all-star panel of experts at the NWFA Wood Flooring Expo Think Tank Session, Regulations & Compliance – Formaldehyde/VOCs on Friday, April 13, 2018 at 9:30 AM.
Elizabeth Baldwin is Environmental Compliance Officer for Metropolitan Hardwood Floors. In her 25 plus year career in the wood industry has visited over 70 countries and hundreds of facilities of all sizes and types. She describes herself as a “jack of all wood trades.” Familiar with jungles of all sorts–having camped out along the Amazon and walked the halls of Congress–she blogs for the NWFA on both environmental and regulatory issues for educational and informational purposes only. Her blog is not intended and should not be construed as legal advice. Persons seeking legal advice on compliance with CARB, TSCA, the U.S. Lacey Act or any other law, regulation, or compliance requirement/claim should consult with the regulatory agency directly and/or a qualified legal professional.