Easy Going Green

CARB Small Scale Test Approved

CA Air Resource Board approved an alternate small scale test method [Dynamic Microchamber DMC]
for conducting quality control testing of formaldehyde emissions from manufacturers of composite wood products despite complaints from certain furniture manufacturers (you know who you are) who have done nothing but whine about how the small scale could not possibly match the large and that they would have to test using the large (and expend all that money) to avoid liability.

A copy of the approval letter can be found at: http://www.arb.ca.gov/toxics/compwood/outreach/dmc.pdf.

CARB Sell-Through Extended

The California Air Resource Board has announced a four-month delay in the enforcement of the Phase 1
sell-through dates for distributors and retailers of composite wood product panels manufactured before January 1, 2009.  The Advisory is available at: http://www.arb.ca.gov/toxics/compwood/outreach/sell_thru_advisory.pdf

ULEF Resin Application Available Thru CARB

Application for the use of no added formaldehyde (NAF) base resins or ultra low emitting formaldehyde (ULEF) resins is now available through CARB or direct download here.

CARB Enforcement Update

CARB has just posted to its site the Enforcement Sell-Through Advisory for Composite Wood Products. It is meant to clarify any ambiguity on how long you can buy and sell non-complying product. It separates the compliance requirements into the guidelines for the board itself and then for the finished goods. The entire document can be downloaded here and...

CARB & your China Shipments

Just when you thought CARB only had to do with composite wood and the bread you have been avoiding, the California Air Resource Board is coming after your ships too. Don't worry, they aren't enforcing the composite wood regulations early or anything, they are simply putting in the world's strictest diesel  regulation off any coast. At least those of us on this coast will be breathing easier these Olympics!

IF Wal-Mart is the new FDA...

I am really not trying to pick on Wal-Mart this month...it is just that all the other retailers just seem to sitting around doing nothing (which you will see in my upcoming reviews.) Right now though, be sure to check the trackback to "How Wal-Mart has Become the New FDA" in the GreenBiz.com Buzz. With Wal-Mart's current behavior on the LACEY and CARB issues following this model, I think the more consumer and watchdog group pressure they receive, the more the furniture industry will change as a whole. It is already happening now - Wal-Mart requires its vendors to change packaging or wood type immediately and then once a vendor finds a way to make it cheap enough for Wal-Mart, they start making it for all the OSS and wholesale clubs. So why shouldn't the other buyers sit on their butts all day? As long as they make sure they have vendors that are selling to Wal-Mart - let them do all the work for them, it's great strategy - not a leadership strategy, but a very efficient, energy-conserving strategy. Green is about conserving energy too, isn't it?

As for Wal-Mart as the FDA, thought I would dust off one of my commentaries on BPA (Bisphenol A) too...

CARB Small Scale QC Test Approved

Just approved by CA ARB is a Japanese 24-hour dessicator test method - JIS A 1460 as an alternate method for conducting formaldehyde emissions testing to the ASTM large chamber method. This should make it more cost effective and quicker for manufacturers and fabricators to QC the board they make or receive.

Any questions regarding this should be directed to Jim Aguila, Manager of Substance Evaluation Section of CA ARB at 916-322-8283.

CARB Watching...

So what is CARB up to now? With limited budget, they are spending their time trying to educate over 200 interested parties via Webinar and getting 3rd party certifiers ready asap. Although they stated that they would like to attend tradeshows and events to continue to educate about CARB, they made no commitment to attend the Vegas Furniture Fair. Thanks to added confusion from the furniture press, most of the Webinar consisted of calming confused furniture manufacturers convinced that they had to be certified, but as I have said, and now CARB, and each and every certifier has also said - NO, they do not need to be certified, only board manufacturers do. The certifiers speaking went even further to describe how they are certifying the board manufacturers and offering everyone services...

EPA Pressed to Review Composite Wood

Gotta love the market spin... when the Furniture Today article reported that the "EPA Denies Formaldehyde Position" you've got to be thinking this is never going to happen. But just wait - according to both the details in the full document released by the EPA and even by comments made by Formaldehyde Campaign Director, Becky Gillette, the denial is actually "a good thing."

Anaylsis CARB Impact on RTA Industry

Potential Effects on the RTA Industry –
Technically this is a repost of CARB Count from May but for those of you confused by the Furniture Today Article, I thought you might want to read my analysis again after reading the previous post.

Material Shortages in Asia –
While there is not a short term need for every furniture manufacturer to switch each and every product over to fully certified board immediately in order to meet the 2009 regulation criteria, there could be two compelling pushes that could cause a supply shortage. First, a couple of key retailers, most likely in my estimation, Wal-Mart and Staples (due to being one of the Green leader in the OSS marketplace so far), will likely push back on the furniture manufacturers and accelerate the 2011 schedule or require more documentation than is required by the ARB standards as written, which can only be satisfied by a fully certified board supplier and perhaps even go so far as to incorporate the Lacey roles and require FSC-certified wood too. Therefore anyone wishing to sell to Staples will have to buy board from the few certified board suppliers available now. The second push could come if the remaining industry manufacturers continue to panic and any one of them tries to corner the market on the new board creating a “buying frenzy” and convincing everyone else by example that it is what it takes to comply or win business.

Significant Cost Increases & Lower RTA Furniture Quality –
MDF could be decreasing significantly in popularity with price discrepancy in the soon-to-be Asian certified version. While it is more cost equivalent in the U.S., the MDF that meets the ATCM standards in Asia is about 30% more right now according to ARB sources. They are hoping that it actually helps equalize the U.S. and Asian furniture markets but I am sure that the less reputable Asian manufacturers will just opt to use less durable wood substrates for paper, vinyl and veneer to be laminated on top creating RTA product that has even lower quality than most now. Both those RTA manufacturers and the retailers with direct imports that are not in their direct control are going to be very risky propositions in the future from a QA and audit perspective. While you may think you are saving money with a direct import model, you need to add to you model the costs of additional audits, QA and the risk if the factory is misleading you both from a legal perspective and from a consumer confidence loss.

Limited Supplier Base –
An even greater worry could be the limited supplier base. If few board manufacturers are approved for sales and use in California many large home building retailers will purchase only from those suppliers for their nationwide needs (as many have “Green” corporate initiatives that they will be using California as the model.) So if Home Depot and others are tapping the same suppliers that all the furniture manufacturers are, then there could begin to be allocation of material issues. That combined with little or no security and privacy protecting board source on what is purchased.