Final EPA Formaldehyde Rule Outlined by KCMA
RESTON, VA — The U.S. Environmental Protection Agency has issued its “Final Rule” regarding Formaldehyde Emission Standards for Composite Wood Products – a set of regulatory guidelines with which cabinet manufacturers and component suppliers will need to comply in order to conform to federal guidelines.
The long-awaited EPA ruling, issued in July, has since been the subject of ongoing efforts by the Kitchen Cabinet Manufacturers Association to assist members in understanding new guidelines and supporting members’ compliance efforts.
Among those efforts, KCMA officials conducted a conference call with members in August, and worked with the association’s legal counsel, the Washington, DC-based Keller and Heckman, LLP, to compile a bullet-point memo highlighting the EPA requirements most likely to impact KCMA members and their supply chains. Addressed in both the phone call and memo were compliance provisions regarding testing, timelines, record-keeping and related issues, according to the KCMA.
“Many of the Final Rule’s provisions are keyed to a particular type of entity (e.g. panel producer, fabricator of finished products, etc.),” said Betsy Natz, CEO of the Reston, VA-based KCMA.
“However, some of the relevant definitions create ambiguities, thus making it difficult to determine exactly which provisions apply to which entities,” Natz noted. “For example, there are instances when a laminated product could be considered both a component part and a finished good, therefore potentially subjecting it to differing obligations at the same time.”
The EPA ruling also contains “distinct, but intertwined provisions covering labeling and record-keeping, in addition to testing and certification,” the KCMA pointed out.
KCMA members were advised to consult both the rule itself and the association’s regulatory counsel regarding the full scope of company-specific regulatory obligations.