Cal. Code Regs. Tit. 17, div. 3, ch. 1, subch. 7.5, Airborne Toxic Control Measure for Diesel Particulate Matter from Portable Engines Rated at 50 Horsepower and Greater app 2
(a) Purpose.
The purpose of Appendix 2 of section 93120.12 is to provide quality assurance requirements for manufacturers of composite wood products to ensure compliance with the applicable formaldehyde emission standards in section 93120.2(a). Manufacturers must demonstrate compliance with the emission standards by way of third party certification, and must comply with the quality assurance requirements contained in Appendix 2. The requirements of Appendix 2 do not apply to product types for manufacturers who have received ARB approval to use no-added formaldehyde based resins or ULEF resins that have been exempted from third party certification requirements for those product types, except for the purpose of applying for re-approval to continue to use no-added formaldehyde based resins as specified in section93120.3(c) or ULEF resins as specified in section 93120.3(d).
Requirements are specified for: preparation of a quality control manual, establishment of a quality control function at the manufacturing plant (including testing equipment and designated quality control personnel), routine quality control procedures conducted at the plant, participation in periodic inspections and product testing by the third party certifying organization, and recordkeeping. These requirements are designed to ensure that certified unfinished (including sanded) composite wood products meet the applicable emission standards. Note: All panels must be tested in an unfinished condition, prior to application of a finishing or topcoat.
(b) Responsibility for Product Performance.
The manufacturer is responsible for the performance of all certified products, including meeting the applicable standard(s) in section93120.2(a) against which its products are certified.
(c) Quality Control Manual.
Each manufacturing plant must have a written quality control manual, which shall, at a minimum, contain the following:
(1) organizational structure of the quality control department;
(2) sampling procedures;
(3) method of handling samples;
(4) frequency of small scale quality control testing;
(5) procedures to identify changes in formaldehyde emissions resulting from production changes (e.g., increase in percentage of resin, increase in formaldehyde/urea molar ratio in the resin, or decrease in press time);
(6) provisions for additional testing;
(7) recordkeeping requirements; and
(8) average percentage of resin and press time for each product type.
(d) Quality Control Facilities.
At each manufacturing plant or location designated by manufacturers with more than one manufacturing plant, laboratory facilities and equipment shall be provided and properly maintained as a quality control facility for conducting such tests as are required by Appendix 2. Alternatively, the quality control facility may be a contract laboratory or a laboratory operated by an approved third party certifier. Equipment shall be calibrated in accordance with the equipment manufacturer's instructions. The original and any subsequent equipment calibration records shall be maintained.
(e) Quality Control Personnel.
(1) Quality Control Manager
Each plant shall have a person with adequate experience and/or training to be responsible for formaldehyde emission quality control. This person shall report to the plant manager and shall be identified to the third party certifier. The third party certifier shall be informed in writing within ten days of any change in his or her identity. The quality control manager shall review and approve all reports of routine small scale testing conducted on the plant's production. If a manufacturer with one or more manufacturing plants uses a testing facility to test routine quality control production samples, the quality control manager shall be responsible for ensuring that the samples are collected, packaged, and shipped according to the procedures specified in the quality control manual. The plant quality control manager shall be responsible for working with the company's testing facility to monitor results, and shall immediately inform the third party certifier by telephone, email, or FAX and by letter of any changes in production that require re-inspections as set forth in section 93120.12, Appendix 3.
(2) Quality Control Employee
Quality control employees shall have adequate experience and/or training to conduct accurate chemical quantitative analytical tests. The Quality Control Manager shall identify each person conducting routine small scale tests to the third party certifier. All quality control employees must be certified annually by the third party certifier for operation of the quality control test method.
(3) Chemical Analysis Tests
(A) Duplicate Analysis
The manufacturer will contact the third party certifier to request certification of any quality control employee identified by the Quality Control Manager. The third party certifier or plant Quality Control Manager shall test one portion of a formaldehyde solution based on the manufacturer's range in expected formaldehyde emissions; the employee to be certified shall test another portion of the same solution. The results of each test must be within a range of concentrations established by the third party certifier, to verify the correlation of the quality control test method.
(B) Blind Samples
The employee to be certified must determine the formaldehyde content of four sample solutions submitted to them by the third party certifier or plant Quality Control Manager. The formaldehyde content of the four sample solutions must be determined to be within a range of concentrations established by the third party certifier, to verify the correlation of the quality control test method.
(f) Primary or Secondary Method Tests.
(1) Initial (Qualifying) Primary or Secondary Method Test
Each product type, from each production line of each plant must be tested in a primary or secondary method testing chamber. The laboratory operating the chamber must be accredited by an accreditation body that is a signatory to the International Laboratory Accreditation Cooperation Mutual Recognition Arrangement (ILAC, 2000). The formaldehyde test methods used by the laboratory must be stated in its scope of accreditation. For the purpose of a qualifying test and with approval of the third party certifier, a manufacturer may group two or more product types together if they have similar emission characteristics. If a plant elects to have all or multiple products represented by a single product type, an initial qualification test failure by that representative product will cause certification to lapse on all other products represented. The emissions from each product type from each production line must not exceed the applicable standard.
(2) Correlation of Primary or Secondary Method and Small Scale Test Values
In order to qualify for certification, the manufacturer must establish a statistical correlation between values obtained from the primary or secondary test method and the values from the small scale tests for each product type and production line. For purposes of establishing this correlation, data for products from the manufacturer's plant or data obtained by a third party certifier must be used. The correlation must be based on a minimum sample size of five data pairs.
(3) Subsequent (Verifying) Primary or Secondary Method Tests
(A) Quarterly Chamber Test
1. Particleboard (PB) and Medium Density Fiberboard (MDF)
At least quarterly, a primary or secondary method test shall be conducted on randomly selected samples of each product type, as determined by the third party certifier. Manufacturers that use ULEF resins and have received ARB approval under section 93120.3(d)(1) need only have primary or secondary method tests conducted every six months. For the purpose of a verifying primary or secondary method test, a manufacturer may group two or more product types together if they have similar emission characteristics. If a plant elects to have all or multiple products represented by a single product type, a quarterly qualification test failure by that representative product will cause certification to lapse on all other products represented. The emissions from each product type must not exceed the applicable standard.
2. Hardwood Plywood (HWPW)
At least quarterly, a primary or secondary method test shall be conducted on randomly selected samples of the HWPW product determined by the third party certifier, after review of routine weekly quality control data, to have the highest potential to emit formaldehyde. Manufacturers that use ULEF resins and have received ARB approval under section 93120.3(d)(1) need only have primary or secondary method tests conducted every six months. For the purpose of a verifying primary or secondary method test, a manufacturer may choose to group two or more product types together if they have similar emission characteristics. If a plant elects to have all or multiple products represented by a single product type, a quarterly qualification test failure by that representative product will cause certification to lapse on all other products represented. The emissions from each product type must not exceed the applicable standard.
(B) Failure of a Primary or Secondary Method Test
1. Exceedance of standards
If the emission value obtained during a subsequent (verifying) primary or secondary method test exceeds the applicable standard, the tested product will be in violation of section 93120.2(a) and certification of that product type will be suspended until re-qualification. In such an event, the third party certifier is required to notify the manufacturer and ARB. If primary or secondary method and small scale test results on the same product differ, the primary or secondary method result shall be considered the benchmark value.
Manufacturers must submit the last month of quality control testing data to the third party certifier, for verification that the quality control limit (QCL) or shipping QCL (if applicable) reflects an accurate correlation between the primary or secondary method and the plant's quality control tests.
2. Re-qualification
Should an exceedance occur, plant production of that product type may be reinstated only upon successful completion of another primary or secondary method test. The re-qualification primary or secondary method test must be conducted on the same product type as that which failed during the verifying test.
3. Disposition of Failed Lot
The manufacturer may obtain certification of a lot which has failed the primary or secondary method test if the manufacturer can demonstrate to the satisfaction of third party certifier that: (1) each panel is treated with a scavenger or handled by other means of reducing formaldehyde emissions (e.g., aging); and (2) panels randomly selected from the treated panels are tested under and pass the primary or secondary method test within six weeks of the initial determination of a failed lot.
(g) Small Scale Quality Control Tests at Plant.
Each manufacturing plant shall conduct small scale quality control tests for each product type and production line to ascertain that its certified panels do not exceed the applicable emission standard. Alternatively, the quality control tests may be a conducted by a contract laboratory or a laboratory operated by an approved third party certifier. Unless prior notice is given, all lots of each product type being certified for compliance at each plant will be tested, with each lot's small scale quality control tests reported to the certifier.
(1) Approved Small Scale Test Methods
The following small scale tests may be used as quality control test methods:
(A) ASTM D 5582-00 (desiccator);
(B) ASTM D 6007-02 (small chamber); and
(C) alternative small scale tests that can be shown to correlate to the primary or secondary method tests as specified in subsection (g)(2) and are approved by the Executive Officer.
(2) Correlation of Quality Control Tests with Primary or Secondary Method Tests
Each plant's quality control test results must be shown to correlate to primary or secondary method test results. The correlation must be based on a minimum sample size of five data pairs. If data shows variation from the previously used correlation, the manufacturer shall work with the certifier to evaluate the data to determine if a statistically significant change has occurred. If a change is noted, a new correlation curve will be established for the manufacturer by the certifier.
(3) Quality Control Limit
Manufacturers will work with their third party certifier to establish a Quality Control Limit (QCL) at each manufacturer's plant for each product type and production line. The QCL is the value for any approved small scale quality control test which is based on the correlative equivalent to the value in a primary or secondary method test permitted by the applicable standard. In addition to the QCL, an excursion limit shall be established to account for process and testing variation to keep the product's emissions from exceeding the applicable standard. In the event that a manufacturer produces product lots that consistently exceed the applicable QCL, based on exceedance criteria established by the third party certifier, the certifier shall be notified promptly.
(4) Basic Testing Frequency
(A) PB and MDF
Manufacturers of PB and MDF must conduct routine small scale quality control tests at least once per shift (8 or 12 hours, plus or minus one hour of production) for each production line for each product type. Manufacturers of PB and MDF that use ULEF resins and have received ARB approval under section 93120.3(d) must conduct routine quality control tests at least weekly for each production line for each product type. Quality control samples shall be analyzed within a period of time specified in the manufacturer's quality control manual to avoid distribution of non-complying lots. In addition, quality control tests must be performed whenever a product type production ends without reaching eight hours of production or whenever one of the following occurs:
1. the resin formulation is changed so that the formaldehyde to urea ratio is increased;
2. an increase by more than ten percent in the amount of formaldehyde resin used;
3. a decrease in the designated press time by more than 20 percent; or
4. when the Quality Control Manager or Quality Control Employee has reason to believe that the panel being produced may not meet the requirements of the applicable standards.
(B) Reduction in Testing Frequency for PB and MDF
Testing frequency may be reduced to no less frequently than one test per 48-hour production period when the plant or production line demonstrates consistent operations and low variability of test values to the satisfaction of the third party certifier, based on criteria established by the certifier. Manufacturers must obtain advance written approval from the third party certifier and keep this written approval as part of the manufacturer record keeping requirements.
(C) HWPW
Manufacturers of HWPW must conduct routine small scale quality control tests on each product type and product line based on production at the plant. Quality control samples shall be analyzed within a period of time specified in the manufacturer's quality control manual to avoid distribution of non-complying lots. Testing frequency shall be as follows:
Minimum Number of Routine | |
Weekly HWPW | Tests/Week Per Product Type |
Production (sq. ft.) | and Product Line |
_ | |
Less than 200,000 | 1 |
_ | |
200,000 - 400,000 | 2 |
_ | |
Greater than 400,000 | 4 |
_ | |
(5) Non-complying Lots
A "non-complying lot" is any lot that has a test value in excess of the applicable standard. Test results from all non-complying lots shall be maintained as required by the manufacturer's recordkeeping requirements. For a non-complying lot to be certified, it must meet the requirements of subsections (g)(6) and (g)(7) below.
(6) Disposition of Non-complying Lots
A non-complying lot must be isolated from certified lots and the third party certifier must be notified. The non-complying lot cannot be certified unless it is determined to be in compliance by treating pursuant to subsection (g)(7) below and retesting pursuant to subsection (g)(8). If the manufacturer chooses not to certify, or is not able to certify a non-complying lot, the lot must not be labeled for sale in California. If the lot had already been labeled for sale in California, the label must be removed or obliterated. The original test value of that lot shall be maintained in the certification calculations for standard deviation and consecutive lots. Such lots shall be identified in the quality control chart.
(7) Treatment of Non-complying Product
Production which has failed the small scale test may be retested for certification if each panel is treated with a scavenger or handled by other means of reducing formaldehyde emissions (e.g., aging).
(8) Small Scale Retesting
The manufacturer may choose to retest a non-complying lot. When retesting a non-complying lot, the following criteria apply:
(A) At least three test panels shall be selected from three separate bundles. They should be selected in such a manner that is representative of the entire lot. Each panel shall be tested by the plant's small scale quality control test.
(B) Test samples shall not be selected from the top or bottom panels of a bundle.
(C) The average of three representative samples must test at or below the QCL or shipping QCL.
(D) In the event that a non-complying lot cannot be certified, the certifier shall be informed promptly in writing.
(9) Shipping QCL
A manufacturer may choose to establish a Shipping QCL, defined the same way as is the QCL above in subsection (g)(3), but based on panels prior to shipment rather than immediately after manufacturing. If a manufacturer chooses to establish a Shipping QCL that is distinct from the QCL, the manufacturer shall work with their third party certifier to establish this limit. The procedures for handling lots that do not comply with the Shipping QCL, and the procedures for retesting of such lots, are identical to the procedures for lots that do not comply with the QCL, as described above in subsections (g)(5) through (g)(8).
(10) Plant Reporting
Each manufacturer shall maintain for a minimum of two years the product data reports for each plant, production line and product type, and shall submit copies to the certifier at least monthly. The reports shall include a data sheet for each specific product with test and production information, and a quality control graph containing:
(A) QCL;
(B) excursion limit;
(C) shipping QCL (if applicable);
(D) results of quality control tests; and
(E) retest values.
(h) Recordkeeping.
Manufacturers shall maintain complete records documenting the following:
(1) small scale test results, including testing frequency;
(2) production sequence;
(3) changes in the resin percentage for any product type, from levels set by the quality control manual, by more than ten percent (calculated on the basis of resin solids and oven dry wood weight of the face and core furnish, adjusted proportionately);
(4) increases in the formaldehyde/urea mole ratio of the resin;
(5) changes in press time by more than 20 percent for any product from the levels set in the plant quality control manual;
(6) testing of Quality Control Employees;
(7) disposition of non-conforming products;
(8) calibration of on-site primary or secondary test methods (if any); and
(9) other records requested by the certifier under its discretion relating to section 93120.12, Appendix 3.
These records shall be made readily available to the certifier. Records shall be retained for a minimum of 2 years in electronic or hard copy form. Records shall also be provided to ARB upon request.
Cal. Code Regs. Tit. 17, div. 3, ch. 1, subch. 7.5, Airborne Toxic Control Measure for Diesel Particulate Matter from Portable Engines Rated at 50 Horsepower and Greater app 2