kip howlett - chpva carb compliance workshop

8/14/2019 Kip Howlett - CHPVA CARB Compliance Workshop

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CARB COMPLIANCEWORKSHOP

What You Need toKnow

What You Need to DoPresented by: Kip Howlett

June 5, 2008

Huntsville, Ontario, Canada


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CARB COMPLIANCE WORKSHOP

What Everyone Needs to Do

Comply with emission standards

Recordkeeping

Labeling

Statements of compliance on bill of lading or

invoice


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IMPLEMENTATION DATES

Regulation Driven Phase 1 HWPW-VC

January 1, 2009

Phase 1 HWPW-CC

July 1, 2009

Phase 2 HWPW-VC

January 1, 2010

Phase 2 HWPW-CC

July 1, 2012

Customer Driven Will some clients want

compliant product

before the ATCM

regulation effective

dates?


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HARDWOOD PLYWOOD DEFINITION

Hardwood plywood includes Wall paneling Industrial panels

Hardwood plywood panels used to make

flooringHardwood Plywood Does Not Include

Laminated products

Military specified plywood

Curved plywood


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EXEMPTIONS TO ATCM

Composite wood products or finishedgoods containing CWP manufactured,

sold, offered for sale, or supplied for

shipment outside California

CWP used in manufactured homessubject to the HUD Manufactured

Housing Standard


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SELL-THROUGH PROVISIONS

Sector DependentControversial Statements Made by

CARB Enforcement at AHFA

Workshop


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Manufacturers of Hardwood Plywood 3-Month Sell-Through Period

Veneer Core manufactured before 1/1/09

that does not comply with Phase 1

May be sold, supplied or offered for saleby manufacturer until March 31,2009

Veneer core manufactured on or after 1/1/09

must comply with Phase 1

All veneer core used in California mustcomply with Phase 1 by 3/31/09


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Manufacturers of Hardwood Plywood

3-Month sell through applies to composite

core hardwood plywood for Phase 1 and

Phase 2 based on respective effective dates

Manufacturers of Particleboard andMDF

Same 3-month sell through periods for

Phase 1 and Phase 2 based on effective

dates


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Fabricator Sell-Through Provisions

Finished goods containing composite wood

products that does (sic) not comply with

the Phase 1and Phase 2 effective dates

specified in section 93120.2(a) may be used,

sold, supplied, offered for sale by fabricators

for up to eighteen months after each of the

specified effective dates.


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Controversy at AHFA Workshop CARB Enforcement Division speaker says Phase 1

sell-through provisions only apply to furniture

manufactured before January 1, 2009.

Hypothesis this interpretation mirrors requirement

for all composite wood products manufactured after

January 1, 2009 to meet Phase 1 emission limits

Reality if fabricators can purchase non-compliant

board 3-months after effective date, it should be

allowed for use in the manufacture of furniture

which then has an 18-month sell-through period

Need interpretation from CARB


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Retailers

Composite wood products: 12 months

Finished goods: 18 months


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SUMMARY

18 mos12 mosRetailers

18 mos3 mosFabricators

18 mos3 mosImporters

18 mos5 mosDistributors

N/A3 mosManufacturers

Finished GoodsCWP


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HARDWOOD PLYWOOD EXEMPTIONS

Military specified plywood

Curved plywood

Laminated products

Hardwood plywood manufactured by

fabricators Championed by kitchen cabinet and furniture

industries

Competitive disadvantage to hardwood

plywood manufacturers


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Laminated products Definition: Finished good or component part

of a finished good made by a fabricator inwhich a laminate or laminates are affixed toa platform. If the platform consists of a

composite wood product, the platform mustcomply with the applicable emissionstandards and must be third-party certified

Resulting laminated product does not haveto comply with the ATCM emission

standards or be third-party certified


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Laminated products

Fabricators manufacturing composite wood

products exclusively for use by the fabricator

in making finished goods must meet all

applicable requirements for a manufacturer

(e.g. comply with the ATCM emission limits

and be third-party certified) with the

exception of product labeling


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Laminated Products Laminated products replaced Architectural

Plywood exemption in previous versions ofATCM

HPVA Technical Committee opposed

exemption for AP and laminated products HPVA comments for almost two years

objected to the exemption

May be recognition from CARB that amistake was made change now wouldrequire a new rulemaking


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PRODUCT LABELING

Composite Wood Products Manufacturer Name Product complies with applicable Phase 1 or

Phase 2 emission standard or was madeusing NAF or ULEF resins

Product lot or batch number ARB assigned number of approved third-

party certifier (does not apply tomanufacturers using ARB approved NAF orULEF resins)

Statement of compliance on bill of lading orinvoice


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PRODUCT LABELING

Distributors, Importers

If composite wood products or finished

goods were not modified, no additional

labeling required

If composite wood products or finished

goods were modified, labeling is the same as

required for fabricators

Retailers

No labeling requirements


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PRODUCT LABELING

Fabricators

Must label all finished goods containing

hardwood plywood, PB, or MDF to be sold or

supplied to California

Label must be applied as a stamp, tag,

sticker, or bar code on every finished good

produced or on every box containing the

finished good


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PRODUCT LABELING

Fabricators Label must include

Fabricators name

Date finished good was produced

Marking to denote finished good

manufactured with composite wood productscompliant with Phase 1 or Phase 2, ormanufactured with CARB approved NAF orULEF resins

Statement of compliance to applicable

emission standards on bill of lading or invoice


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RECORDKEEPING

Composite Wood Products

Starting January 1, 2009, must keep records

of all quality assurance emissions test data

for each product

Manufacturers using CARB approved NAF

and ULEF resins must keep records

documenting ARB approval

Records must be kept in hard copy or

electronic form for two years


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RECORDKEEPING

Composite Wood Products

Records kept for two years must include:

Tracking information to allow a product to

be traced to a specific lot or batch

Product information Purchaser information

Transporter information

Identification of ARB approved TPC

Disposition of non-complying lots


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Small Scale Quality Control Tests in

Plant

Non-Complying Lots

Any lot with a test value that exceeds the

applicable standard

Must be isolated from other certified lots

May be re-certified by treating withscavenger or use of other means to reduce

formaldehyde and re-testing

If manufacturer does not re-certify, lot may

not be labeled for sale in California

If already labeled, label must be removed


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Plant

Non-Complying Lots

Small Scale Retesting

At least three panels from three separate

bundles

Each panel shall be tested using plantssmall scale quality control test

Average of three samples must test below

the quality control limit

If lot can not be recertified, certifier mustbe notified promptly in writing


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PlantPlant Reporting

Each manufacturer must maintain productdata reports for each plant, production line,and product type

Copies must be submitted to certifier at least

monthly Report must include

Quality control limit

Results of quality control tests

Retest values


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PlantRecordkeeping

Complete records must be kept documenting:

Small scale test results with testing frequency

Production sequence

Changes in resin percentage

Increases in u-f mole ratio Changes in press time more than 20%

Testing of QC employees

Disposition of non-conforming products

Records must be maintained at least 2 years


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Recommendations

GET A COPY OF THE REGULATIONhttp://www.arb.ca.gov/regact/2007/compwood07/compwood07.htm

For Further Information

Gary D. Gramp

[email protected]

703-435-2900, Ext. 115

THANK YOU!
http://www.arb.ca.gov/regact/2007/compwood07/compwood07.htmhttp://www.arb.ca.gov/regact/2007/compwood07/compwood07.htm

kip howlett - chpva carb compliance workshop

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