Odds are that many document destruction firms have not given much thought to the consoles they purchase to place at customer locations beyond their appearance, durability and price. But recent regulation in California has caused document destruction firms in that state to look more closely at consoles. It’s also required console manufacturers to adjust their product lines in some cases to address the topic of concern: formaldehyde emissions from composite wood products.
And now that California’s regulations have been adopted at the federal level, destruction firms may be more aware of the changes in console manufacturing that have been going on behind the scenes.
CLEARING THE AIR
The California Environmental Protection Agency’s Air Resources Board approved an airborne toxic control measure (ATCM) designed to reduce formaldehyde emissions from composite wood product panels and from finished goods containing composite wood products in April of 2007. The ATCM established formaldehyde emissions standards for hardwood plywood, particleboard and medium density fiberboard, requiring finished goods made from these materials to use composite wood products that comply with these new standards.
The emissions standards were designed to be phased in over time, with the first standards becoming effective Jan. 1, 2009. This initial phase set a cap for formaldehyde emissions of 0.08 parts per million (ppm) for hardwood plywood with a veneer core, of 0.18 ppm for particleboard, of 0.21 ppm for medium density fiberboard and of 0.21 ppm for thin medium density fiberboard. The standard for hardwood plywood with a composite core was phased in July 1, 2009, and required emission at or below 0.08 ppm.
The Phase 2 emission standards for hardwood plywood with a veneer core of 0.05 ppm became effective Jan. 1, 2010, while the standard of .09 ppm for particleboard and 0.11 ppm for medium density fiberboard became effective Jan. 1, 2011. Thin medium density fiberboard must meet a standard of 0.13 ppm by Jan. 1, 2012, while hardwood plywood with a composite core must meet a standard of 0.05 ppm by July 1, 2012.
The standards apply to domestic and imported products as well as to panel manufacturers, distributors, importers, fabricators and retailers of these composite wood products and finished goods containing those materials that are sold or supplied in California.
The new ATCM required console manufacturers to take a closer look at their supply chains.
COMPLIANCE READY
“Well in advance of the new Jan. 1, 2011, requirement from the California Air Resources Board (CARB) regarding the Air Toxic Control Measure 93120 reducing formaldehyde emissions from wood-based panels and from composite wood products, Jake, Connor & Crew worked closely with our North American board suppliers and ensured that we were fully compliant throughout our entire melamine product line,” says Shannon Park of Jake, Connor & Crew, Kitchener, Ontario. “We ensured that the board used in our consoles was more than fully compliant with these new regulations and we felt it was in the best interest of our customers to produce our entire line with this CARB-compliant board.”
Nancy Kilch of Kilch Enterprises, Marietta, Ga., says her company’s Regal cabinets complied with the E-1 European formaldehyde emission standards in advance of CARB legislation. “The European E-1 standard is roughly comparable to California’s CARB 1 requirements, although it uses different testing procedure,” she says. “To meet California’s ATCM, we had to begin using wood panels that met their specific emission levels and testing requirements.”
She adds that the company’s panels have been tested by SGS Group, a worldwide control and inspection company that is ISO 17025 certified for laboratory testing.
Pete Pancel, president and COO of All Source Security Container USA, based out of Barrie, Ontario, says his company has offered console products meeting the Phase 2 emissions standards for the last two years. “We have been providing shredders in the document destruction industry those containers as a competitive advantage for the last couple of years,” he says.
All Source’s entire console line uses the Phase 2-compliant particleboard, Pancel adds.
“Currently, the ATCM requires that fabricators take reasonable prudent precautions to ensure that composite wood products they procure for producing finished goods comply with applicable emission standards,” Park says. “This means that fabricators must employ supply chain management by asking for compliant products from their suppliers and by receiving written verification that they were supplied with compliant materials.”
She adds, “The ATCM also asks that fabricators ask their composite wood product mill suppliers to identify their third-party certifier and ask for copies of the mill’s formaldehyde testing results to verify compliance with the formaldehyde emissions standards. We ensure we comply with this requirement by conducting reviews on a regular basis to ensure that our board suppliers maintain their CARB approval as a third-party-certified manufacturer and that they and their documentation are fully compliant.”
Pancel says a mill in Oregon supplies the particleboard used in All Source consoles and the consoles are made in San Diego. The board is certified as compliant with the California standards by the Composite Panel Association, he adds. All Source labels its consoles with a point-of-origin sticker that identifies where the product was made and its compliance rating.
Kilch adds that the regulation stipulates that either the product itself or its outer packaging must be labeled with the manufacturer’s name, production date, batch or lot number and CARB compliance details.
PROVISIONS PROVIDED
The California regulation includes a “sell-through” provision designed to allow for reasonable clearing of inventories following the effective dates of the Phase 1 and Phase 2 standards, Park notes.
According to a regulatory guidance document issued in January 2011 by the California Air Resources Board, “Under the sell-through provisions, composite wood products and finished goods manufactured before each applicable effective date may be legally sold, supplied or offered for sale in California for specified periods of time after the effective date. Such products and finished goods do not need to comply with labeling requirements specified in the ATCM unless these products comply with the emission standards in the ATCM.”
Fabricators using composite wood products to make finished goods “may sell, supply or offer for sale finished goods made with Phase 1-compliant composite wood products for up to 18 months after the applicable effective date of the Phase 2 emission standards,” according to CARB.
Distributors of finished goods made with composite wood product panels, “may sell, supply or offer for sale finished goods containing pre-Phase 1-noncomplying composite wood products through Dec. 31, 2011; and finished goods containing Phase 1-compliant composite wood products for up to 18 months after the applicable Phase 2 emission standards,” according to the provisions.
“As a manufacturer, Jake, Connor & Crew was well aware of the pending changes to the regulations that were being proposed by the California Air Resources Board regarding formaldehyde emissions, both in January 2009 and the most recent changes effective January 2011,” Park says. She adds that the company worked proactively with its North American certified board suppliers to ensure that Jake, Connor & Crew’s entire product line was in full compliance with the regulations. “As a result, our full inventories in place on Jan. 1, 2009, and Jan. 1, 2011, were fully complaint.”
Kilch says her company has carefully monitored its inventory to ensure it is used in advance of the effective sell-through dates. “For example, we began stocking CARB 1 inventory in California after Jan. 1, 2009, in order to meet the original May 31, 2009, distribution compliance date (which was subsequently extended to Dec.31, 2010).” She adds, “Beginning Jan. 1, 2011, all new inventory sent to California is CARB 2 compliant, even though sell-through provisions would allow distribution of CARB 1 inventory until June.”
GREEN THINKING
In the case of All Source, Pancel says, offering environmentally friendly product options has always been a priority. “All Source has always and will continue to have green products available as choices for our customers. It’s a corporate direction driven not because of CARB compliance,” Pancel says.
He adds that the company’s customers often opt for the green choice when the alternative is provided, noting that All Source’s green container sales are actually higher outside of California.
While the company’s DuraFlex Green shredding console originally sold at a slightly higher price than its standard DuraFlex console, Pancel says that as industry demand grew for board that complies with the formaldehyde emissions standards, the mills started producing larger quantities more efficiently, resulting in a decline in price for that material. “The CARB 2 board is now at the same level as our regular board used to be at,” he says.
Jake, Connor & Crew’s Park says regulations have not had a negative effect on console quality or price. “We worked closely with our board suppliers to ensure that durability, appearance and strength would not be affected by the ATCM measure,” she says. “Due to our purchasing volumes and as an example of our continued commitment to corporate social responsibility, we showed our support of this environmental initiative and are proud that we have been able to offer this superior product at no additional cost to our customers.”
Kilch says she has found the panels the company uses to be somewhat more expensive than traditional panels, but Kilch Enterprises is not passing the cost on to its clients. She adds, “Product durability is not affected or compromised.”
While manufacturers and distributors of consoles must comply with the CARB 2 standards and the federal standards to be introduced in 2013, document destruction firms will not be directly affected by the regulations and will not need to upgrade to compliant consoles.
“The regulation has always been targeted at the sale and distribution of new products only,” says Kilch. “All existing console inventory is grandfathered in, as are all other wood products, including furniture, built-in cabinets, flooring, etc., already in place in homes and buildings throughout California.”
However, she cautions destruction firms to confirm adherence to CARB regulations with their suppliers when purchasing new consoles.
| Pictured from left: the Jake, Connor & Crew line of consoles, Kilch Enterprises’ Royal console and All Source Security Containers’ DuraFlex Green console. |  |