Hardwood Floors August/September 2018

REGULATED Engineered Flooring with a Plywood Core

REGULATED Engineered Flooring with an MDF Core

EXEMPT Engineered Flooring with a Lumber Core

REGULATED Laminate Flooring (Paper face/back and MDF core)

All photos courtesy of Elizabeth Baldwin.

Now, you’ll note that we are talking emission levels here. You will o en have requests for “formaldehyde-free ooring,” and that simply doesn’t exist. Formaldehyde is naturally occurring everywhere, all around us, and even in us. And it was put into wood by Mother Nature. at’s our fourth discussion point: TSCA, like CARB and almost every Indoor Air Quality standard out there, is about emissions, not content. It doesn’t ma er if you added formaldehyde into the oor during production. What ma ers is if it is coming out. TSCA doesn’t outlaw formaldehyde glues; it is not set up to restrict what goes in. TSCA was established to help control howmuch is coming out. ose are probably your four key discussion points for TSCA. ere are others of course – it’s a complicated regulation. But for your customer, you can make it pre y simple. Not all oors are regulated, and the EPA is not directly certifying the oors. CARB=TSCA in terms of products covered as well as for the established emission levels and it’s the emissions that you want to focus on, not the content.  For more on your responsibilities under TSCA as a regulated stakeholder, monitor my blog: hardwoodfloorsmag.com/category/blogs/ beyond-green/.

one of the four regulated products. Engineered ooring produced with plywood or MDF (or particleboard for that ma er) and laminate ooring produced with an MDF core must be made utilizing certi ed rawmaterial with speci ed record-keeping requirements. at’s your second fact for a customer. Not all ooring is indirectly regulated by TSCA. Solid wood ooring isn’t. Lumber core engineered ooring is not. LV or any of the varied newWPC type ooring is not. So you are not going to nd a TSCA label on every oor, and that may confuse some people. You need to know what’s covered. ( is may be your most challenging point if you are selling them a non- regulated product.) And speaking of what’s covered, you may run into confusion regarding enforcement dates and old inventory. It’s simply not possible to have everything in the world produced under TSCA all at once, so TSCA is coming into play in stages. e rst stage is from June 1, 2018 to March 22, 2019. During this time all impacted products being manufactured in or imported into the U.S. must be either CARB- or TSCA-compliant. at’s your third and potentially most important point tomake to the end-user. CARB and TSCA have the same emissions standards, and the EPA has stated speci cally and clearly that from June 1, 2018 toMarch 22, 2019 that a CARB-compliant oor is a TSCA-compliant oor. If your customer comes in saying “I wanted TSCA and you gave me CARB,” you can respond with con dence that the established emission levels for both programs are the same and TSCA has provided CARB production made in that rst stage with reciprocal recognition. (And you can sell that CARB-compliant material a er March 22, 2019, as well, as long as it was produced/imported prior to that date.)

Elizabeth Baldwin is Environmental Compliance Officer for Metropolitan Hardwood Floors. This simplified summary of key consumer concepts is provided for general information purposes only. It is neither intended, nor should it be construed, as legal advice. TSCA Title VI, like all regulations, is incredibly complex and as this article was written, official agency guidance was

still being developed. Companies or persons seeking legal advice on compliance with CARB or TSCA should consult with the regulatory agency directly and/or a qualified legal professional.

the magazine of the national wood flooring association

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