Question

We are looking for a hardwood flooring product that is low VOC. Can I rely on CARB compliance?

Asked by Eppie
Marina, CA

I am looking at an engineered hardwood floor (Gemwoods Pacific Treasures collection) that says: CARB Compliant Product complies with the US Lacey Act and the California formaldehyde emissions standards (Cal Code 93120.2(a)) Scientific Certification System: TPC-9 Not sure what this means! We have a cement subfloor.

Answer

Polly Osborne, FAIA, LEED AP

Answered by Polly Osborne, FAIA, LEED AP

Los Angeles, CA

Polly Osborne Architects

August 14, 2013

Dear Eppie,

The California Air Resources Board was started in 1967 by combining the Air Sanitation and Motor Vehicle Pollution Boards.  It outpaces most of the nation in clean air policy.

  • It enacted legislation in 2007 to reduce formaldehyde emissions in composite woods through The Air Toxic Control Measure.
  • The federal government is adopting measures based on the California regulations.  (The EPA released two proposed regulations for public comment in the federal register in June 2013). 
  • The Hardwood Plywood and Veneer Association has followed suit, developing testing criteria for the American National Standards Institute through their trade organization.

The CARB standards are quickly becoming the national standards.

CARB 93120.2

CARB compliant composite wood products have greatly reduced formaldehyde in their composition.  Formaldehyde is a known human carcinogen with no known safety level. 

There were two phases to the CARB 93120.2 measure that reduces formaldehyde.

  • Phase 1 measures went into effect in 2009, and the more stringent Phase 2 measures went into effect in 2012. 
  • All composite wood products now made or sold in California, with the exception of some manufactured housing, must comply with these measures, with a limit of 0.05 ppm for hardwood plywood.
  • Current warehouse stores of Phase 1 products must be sold or removed by December 2013, so only the more stringently complying materials remain.
  • From now until the end of the year, asking for phase 2 compliant material saves you from getting these old stores.

CARB compliant products 

Formaldehyde is added to binders and resins, and used in all areas of composite wood making.

The rules restrict its use and require third party testing to verify its off-gassing. Third party testing is by the “Scientific Certification System: TPC-9.  (TPC stands for transmission control protocol.)”   

The measure also encourages manufacturers to have “no added formaldehyde” (NAF) and “Ultra low emitting” products by giving these products special routes for compliance.  However, the product might still only say “CARB Compliant Product” so you really have to ask the manufacturer if you want a no added formaldehyde product. 

The CARB website has a list of approved NAF and Ultra low emitting products (here) but I didn’t see the Gemwoods product among them.  However, I do not know how often that list is updated or how complete it is.

Also, the label can be on the box or on the product, so if something isn’t labeled, check with the place you bought it.

Finishes will offgas too

Note that urea-based Formaldehyde resins are not the only components of wood composites that may off-gas.  Varnishes, finishes, etc may also contribute, so just because it is CARB 93120.2 compliant doesn’t mean it won’t smell or have VOCs. 

The Air Resources Board also regulates these, but it is done specifically by district and each district has its own set of rules based on its specific situation.  For Marina it would be the Monterey Bay Unified Pollution Control District which you can contact at (831) 647-9411.

ANSI/HPVA HP-1

While the CARB standard is testing the unfinished material, the ANSI/HPVA HP-1 is testing the finished material and includes other performance properties as well.

The American National Standards Institute accredited the Hardwood Plywood and Veneer Association to develop this standard. It is a voluntary industry developed standard with similar limits to CARB’s, as it supports the CARB standards.

So this is another stamp to look for when viewing a finished material, such as a prefinished floor.

Lacey Act

The Lacey Act is the oldest wildlife protection act in the country, enacted in1900 to combat the impact of hunting for the commercial trade, interstate commerce in illegal game, introduction of exotic species and bird killing for the feather trade.

It has had significant ammendments in 1981, 1988, and 2008. 

The 2008 ammendments broadened the range of plant species protected and now encompasses products made from those species.  Global trafficking in illegal and endangered hardwoods are prevented from entering the United States through this law.  Europe has enacted similar protection for endangered plants species.

When you think about it, we usually don’t have a clue where the wood from our axe or paint brush handle comes from.  So many things we use have wood parts, and now all those wood parts, from umbrella handles to pianos, are vetted for compliance with the Lacey Act.

Both these regulations have had profound effects on wood importing, composite wood manufacturing and especially the hardwood floor industry.  

A good step forward

At the rate we consume, these regulations can only be a good thing. 

We are the highest emitter of greenhouse gases in the world and between ourselves and Western Europe we manage to represent 60% of the world’s private consumption while being only 12% of its population. That 12% spends 87% of its time indoors, breathing whatever is off-gassing from our walls, floors and ceilings.

In terms of green building, these regulations are a good step forward in the areas of air quality and environmental protection.

 

Thanks to Lida Mahabadi for her research of these issues.

 

For more information:

http://www.fas.org/sgp/crs/misc/R42119.pdf

https://ic.fsc.org/documents.311.htm

https://ic.fsc.org/controlled-wood-standards.174.htm

http://www.arb.ca.gov/toxics/compwood/compwood.htm

https://m360.iwpawood.org/admin/forms/ViewForm.aspx?id=6066

http://www.arb.ca.gov/toxics/compwood/naf_ulef/listofnaf_ulef.htm

http://www.hpva.org/hpva-national-consensus-standards

http://www.worldwatch.org/node/810

http://www.arb.ca.gov/toxics/compwood/discussion.pdf

http://www.arb.ca.gov/coatings/arch/arch.htm

http://www.arb.ca.gov/capcoa/roster.htm

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