More than 100 RV manufacturers and wood suppliers attended a half-day seminar Tuesday (Sept. 30) in South Bend, Ind., to learn about the formaldehyde emission standard for wood products that will take effect next year in California.
Lynn Baker, air pollution specialist with the California Air Resource Board (CARB), led the meeting sponsored by the Recreation Vehicle Industry Association (RVIA). The trade association has taken the lead in adopting the CARB air quality standard for wood products used by member manufacturers. It represents just one course of action taken by RVIA to address formaldehyde following allegations of health problems in occupants of emergency vehicles used for hurricanes Katrina and Rita in 2005.
As a condition of RVIA membership, RV manufacturers must build their units for sale in all 50 states using CARB compliant wood by Jan. 1, 2009, and CARB certified wood by July 1, 2010. “Compliant” wood meets CARB’s formaldehyde emission levels while “certified” wood not only meets these levels but also adheres to CARB’s certification requirements as documented by a CARB approved third-party agency.
RVIA is treating California’s new law as a national standard because California is the nation’s largest consumer of RVs, with 9% of all RVs sold in 2007, according to RVIA research.
California adopted this “airborne toxic control measure” (ATCM) to reduce public exposure to airborne formaldehyde. The measure stipulates new formaldehyde emission standards for hardwood plywood, particleboard and medium density fiberboard (MDF).
The first phase of the CARB wood products standard stipulates that veneer core and thin MDF meet an emission level of 0.08 parts per million by July 1, 2010. Beginning on that date, all new RVs offered for sale in California must contain only applicable CARB-certified wood products.
The law requires panel manufacturers to be third-party certified and perform in-plant quality control testing. The law applies to distributors, retailers, importers and fabricators.
The turnout at Tuesday’s meeting “demonstrates that the industry is taking this issue very, very seriously,” said Matt Wald, RVIA’s director of governmental affairs. About two-thirds of the people in the audience were manufacturers, Wald estimated, and most in attendance were from northern Indiana.
Darrell Hawkins, CARB enforcement staffer, took part by phone, and RVIA’s Bruce Hopkins, vice president of standards and education, also participated, explaining how RVIA is working the CARB standards into its standards process.
Tuesday’s meeting was closed to the press. In summarizing the meeting’s contents to RVBusiness, Wald said he senses the industry has two major questions about the CARB standards.
“First is the slowdown in the market and the fact that an RV that leaves a plant today (that is not CARB-certified) could still be sitting on a lot July 2010 when the first enforcement takes place. There is always concern about things you can’t control,” he said.
Wald said Baker, while not making a commitment, indicated that CARB might be able to make an accommodation for such units.
“A close second,” according to Wald, “is the availability in any reasonable time frame of certified luan, getting Asian mills certified and getting materials to the builders to where the woods needs to be. The clock is ticking, so to speak, and it’s a big problem with luan.”
Baker noted that approximately 70% to 80% of the lumber mills in North America are already providing particleboard and MDF that is CARB-certified. However, just two of the more than 40 mills in Indonesia, Malaysia, China and Vietnam that provide the vast majority of luan products are CARB-certified. And there is just one third-party certifier in all of Southeast Asia.
Baker said he understands manufacturers’ concerns but offered no resolution.
During his presentation Tuesday, Baker made these additional statements:
• Manufacturers will have to affix a label on their units certifying that they comply with CARB standards and that its contents, such as furniture and cabinets, also are compliant.
• Manufacturers must maintain documentation on all wood products they buy and sell for at least two years. This paper trail will be vital if CARB subsequently discovers any violation during its testing process, which begins at the retail level on dealers’ lots, he said. “We’re a little bit concerned about getting more California dealers involved in this standard and getting them to understand it,” Wald told RVBusiness. “We want to make sure the dealers understand their obligations under the standards.”
• CARB enforcers will enforce the standard by inspecting the product for compliance with labeling requirements. They will then check the chain of custody documentation (paper trail). They will then screen the product for emissions and further check in a laboratory if necessary. If the product exceeds the standard, this will initiate an enforcement action. CARB officials will begin to work backward in the chain, going to the unit’s manufacturer and asking the company to show they made every effort to make sure the product was CARB-certified.
• Fines will be assessed based on factors such as the extent of harm caused by the violation, the nature and persistence of the violation, the length of time over which the violation occurs, the frequency of past violations and the time of response of any mitigation of the violation.
On Monday, RVIA led Baker on tours of the Robert Weed Plywood facility in Bristol, Ind., and of a Jayco Inc. plant in nearby Middlebury.
“He came away with a great appreciation for the challenges our industry is facing: how are we supposed to keep track of where wood is coming from and where it’s ending up,” Wald said.
For more information on this issue, go to www.arb.ca.gov/toxics/compwood/compwood.htm.