California agency ponders formaldehyde rules: eight wood products industry associations form a coalition to voice their concerns over the regulatory process and its potential for economic harm. (Panel Extra).
The California Air Resources Board (CARB) initiated a draft rule-making process last fall that some wood products associations say could greatly restrict the manufacture and sale of furniture, cabinets and other wood products made with wood composites containing formaldehyde. In the worst imaginable case, the industry fears CARB could set the maximum allowable emission limits so low as to eliminate composite wood products made with urea-formaldehyde from the state.
Among the products that could be affected are particleboard, medium density fiberboard, hardwood plywood, softwood plywood, oriented strand board and laminated veneer lumber.
Robert Krieger, staff air pollution specialist for CARB, said he wanted to make it clear that CARB has no intention of banning wood composite products in California. "There is a process for everything. We are just beginning to evaluate composite wood products. We never said we were going to ban something."
Nevertheless, Chris Leffel, senior vice president for the Composite Products Assn., said industry has cause for concern. In addition to emission limits, some of the concerns shared by the coalition members include:
* The belief that the risk assessments upon which formaldehyde is being considered for regulation by CARB are outdated and greatly overstate the potential for formaldehyde-related health problems.
* The generally held misconception that there are alternative products readily available and applicable to replace those containing urea-formaldehyde, far and away the resin most used in particleboard, MDF and hardwood plywood.
* The potential of CARB to underestimate the economic impact on composite wood producers, secondary manufacturers, retailers, consumers and others.
CARB is required by statute to evaluate the need and scope of regulations for compounds the state has listed as a "toxic air contaminant." CARB identified formaldehyde as a toxic air contaminant in March 1992.
Whereas the U.S. EPA has classified formaldehyde as a "probable human carcinogen" under conditions of high or prolonged exposure, the California Office of Environmental Health Hazard Assessment (OEHHA) determined that no safe exposure threshold level exists for formaldehyde to preclude cancer risk.
Industry contends that OEHHA's 1992 risk assessment is not only based on old science but incorrectly concludes that even trace amounts of formaldehyde emissions can be harmful to humans. They point to the most recent studies of the Chemical Industry Institute of Toxicology (CIIT), the same research institution that first linked formaldehyde exposure to cancer in rats in the early 1980s. CIIT released a new risk assessment in September 1999 concluding that formaldehyde is up to 100,000 times less likely to cause cancer at the low levels found in composite panels than the 1992 OEHHA risk assessment.
While the CARB inventory shows that the lion's share of formaldehyde emissions in California is generated by motor vehicles, they disagree widely on the total amount of formaldehyde emitted by wood composite products. On its Web site, CARB says formaldehyde emissions from particleboard, MDF, hardwood plywood and other composite wood building materials could exceed 400 tons per year. Leffel said industry calculations show the total is a fraction of that.
Substitution No Solution
At a Nov. 14, 2001 meeting, CARB said it would review the feasibility of using alternatives to urea-formaldehyde resins in composite wood products. Potential substitutes include phenol formaldehyde and methyl di-isocyanate (MDI), popularly used in strawboard.
Meeting with CARB on Jan. 24, several industry representatives of a delegation of 25 people, contended that not only are their products containing urea-formaldehyde safe, but using an alternative resin would be cost prohibitive, weaken product performance or both.
Gary Gramp, technical director of the Hardwood Plywood & Veneer Assn., said, "Hardwood plywood manufacturers use urea-formaldehyde resins because they work best. Phenol formaldehyde is not an option because it bleeds through the thinner face veneers that are used today. MDI is also not an effective plywood resin" because it will not bridge gaps like UF or PF, Gramp said.
Gramp said he was encouraged that CARB members were "receptive at the meeting in terms of listening and understanding what we had to say. I was glad to hear one of the CARB representatives say that they may have to consider different standards for each product" as opposed to an across-the-board standard for all composite wood products made with urea-formaldehyde.
David Harmon, technical manager of western North America for Borden Chemical Inc., spoke on behalf of four manufacturers that when combined, produce most of the urea-formaldehyde used in North America. Harmon said the composite wood products industry has eliminated upwards of 90 percent of formaldehyde emissions since the 1980s. "The possibility of using lower-emitting urea-formaldehyde is there but at a great cost" in terms of the price of the resin itself, the lower efficiency of these resins to achieve performance properties and the potential of negatively impacting composite wood panel mill productivity.
Gramp and Leffel each said the industry hopes to persuade CARB to recognize the ANSI standards for formaldehyde emission limits. The ANSI standard for hardwood plywood formaldehyde emissions is 2 parts per million (ppm) for wall paneling and 0.3 ppm for hardwood plywood grades used in furniture and cabinets. ANSI standards for particleboard and MDF formaldehyde emissions also are 0.3 ppm.
"The formaldehyde emissions coming out of our products are so low," Leffel said, "that we're trying to show CARB that current standards exceed the necessary protection for public health." To help bolster industry's case, Leffel said CARB members are being invited to participate in a tour of composite wood product mills in April.
Krieger said CARB is sending out a survey to manufacturers of composite wood products to collect additional data and information.
"We appreciate the fact that industry is sharing information with us," Krieger said. "We're on a learning curve right now and we need to learn more about the industry. We're being kind of bombarded with all of the information. Ultimately we have to see how this affects the public."
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|Publication:||Wood & Wood Products|
|Date:||Mar 1, 2002|
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