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Are You Ready? TSCA Title VI, Formaldehyde Standards for Composite Wood Products Takes Effect December 2017.

March 9, 2017

Formaldehyde is a colorless gas found in numerous products, including composite woods (plywood, particleboard and medium-density fiberboard, or MDF) and products containing these materials. As exposure to formaldehyde may cause adverse health effects, regulations exist to limit this substance in the market. Currently, any composite wood products or products containing these materials are already required to meet the California Air Resource Board’s Airborne Toxic Control Measure (referred to as CARB ATCM, or CARB) Phase 2 regulation if sold in California. However, national regulations consistent with CARB under the EPA’s Toxic Substances Control Act (TSCA) Title VI, Formaldehyde Standards for Composite Wood Products, will expand these requirement to the broader United States.

Though TSCA, which takes effect in December 2017, offers needed protection to consumers in the U.S. market, it also means fabricators, distributors, retailers and importers of composite wood products will become liable for their vendors and that represents a significant risk. While enforcement of CARB Phase 2 was limited, the EPA has port authority and will be conducting customs/border patrol, examining shipments and potentially requiring proof of compliance (i.e. traceability). Rather than being unable to present the required documentation within the allowed 30-day window or, worse, being found in violation of the regulation, it is recommended that companies take a proactive approach to monitoring supply chain integrity.

With a proven history of testing and product evaluations, UL can help companies evaluate, monitor and improve their composite wood supply chain partners. By working with UL to take ‘reasonable prudent precautions,’ as recommended by the EPA, companies can better understand the quality of the vendors they rely on. UL’s global experts and fully equipped testing facilities can assist companies by providing a complete evaluation of all vendors. This includes:

  1. Documentation Review - A questionnaire will be submitted to every vendor. In addition, traceability documentation is requested and reviewed for compliance.
  2. Factory Visit - After completing a review of all documentation and questionnaire responses, UL field experts will conduct an on-site factory inspection at every applicable vendor facility. This inspection will look at manufacturing and labeling practices.
  3. Risk Rating - Based on our findings, UL will assign a risk rating (low, medium, or high risk) to every vendor.
  4. Regular Inspections - Based on the rating, UL will recommend snap inspections at a given annual frequency (0-100) for every facility. These inspections involve UL field experts visiting manufacturing sites to randomly pull production samples for testing at a UL facility.

At the end of the day, you are only as strong as your supply chain partners. Rather than counting on this large list of vendors to keep you compliant, trust UL to minimize your risks and keep product moving as planned from port to port.

Click here to learn more about TSCA compliance.