Tuesday, May 21, 2013
Proposed Lacey ANSI Standard
Folks, I’m going to interrupt our review of recycling in the United States to stick in a post on a timely topic—in fact, a time-sensitive topic.
The Hardwood Plywood and Veneer Association (HPVA) has created a proposed ANSI standard for legality due diligence. Prompted originally by the Lacey Act legislation, they are now hoping it will serve to assist companies selling into the EU, Australia, Japan and other countries with active or pending legality requirements. They introduce the standard as follows:
This standard is intended to assist companies in establishing a quality controlled system to significantly reduce the risk of illegal timber and wood products entering their supply chain and to demonstrate the level of due diligence in controlling associated risk. This Standard covers importing, exporting, and interstate commerce of timber and wood products with a North American focus and could have international implications for timber in international commerce. This Standard is not a chain-of-custody scheme, a legal verification system or sustainability certification, and does not constitute legal advice for due diligence compliance or guarantee legality of wood products.
The standard is currently in its public comment phase, and the National Wood Flooring Association is one of many organizations providing feedback. Individuals and independent companies may also offer their comments on the guidelines. If any NWFA member wants to receive a copy to review, email me here and I’ll send it out to them. Comments are to be emailed before June 24 to both psa@ansi.org and khowlett@hpva.org with the Standard’s reference number in the subject: BSR/HPVA LTDD 1.0-201x.
Note that an ANSI standard is a “Big Deal” issue. It is something that often is put into government contracts or architectural specifications for big projects. It might become terms of a contract. Even though this is voluntary, this could be a standard that you’ll be expected to follow if you want certain business.
In my personal opinion, this standard is very confusing and would be nearly impossible for most companies (particularly small- and medium-sized companies) to follow. I appreciate the efforts that the HPVA and other members of the development group have made to try to provide the industry with a guide, but I have a number of very specific concerns about it. So I would encourage you to read it for yourselves. See if it something that would help your business and see if it something you could put into action at your own company. If you like it, let them know. If you don’t, tell them why so they can make it better. This is going to potentially impact on your business’s future—how you buy and how you sell, so please, get a copy and take a look!
(And back to fun facts about recycling next week…)
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Tuesday, May 14, 2013
Images of Recycling (and Not), Part One
Sorry, Kim, I need to acknowledge that the original idea behind this post came from a competitor’s post on recycling.
The article started noting that “Americans toss away enough aluminum in a three-month period to rebuild all of the country’s commercial airplanes” and that “recycling one ton of paper saves one acre of trees.” As regular readers have seen in the past, I love comparison stats like this (how many CARB P2 panels did you eat today?), so this led to me do some of my own research. I found a report by the EPA that told me, among other things:
- On average, we recycled and composted 1.51 pounds out of our individual waste generation of 4.43 pounds per person per day.
- Over 33 percent of glass containers were recycled
- About 23 percent of wood packaging, mostly wood pallets, was recovered
- Over 13 percent of plastic containers and packaging was recycled.
Interesting, but that didn’t have quite the imagery punch I wanted. I was definitely pleased to see wood packaging up at the top of recycled percentages but thought we should try to do better than just 23%!
After going through that report, I then found an interesting Washington Post article looking at the food we waste in the United States each year, which told me that about 40% of all food in the United States goes uneaten, at an estimated value of $165 billion. The article outlines where in the chain the food is lost and why and notes that “Americans today waste 50 percent more food than they did in the 1970s” and that “about 23 percent of U.S. methane emissions comes from landfill food. Composting or even technologies to capture methane could reduce that.”
That was very interesting, and recommits me to using my leftovers. But I want imagery in my numbers and I found finally fun stats provided by the State of Mississippi, which included:
- The United States produces approximately 220 million tons of garbage each year, according to the Environmental Protection Agency. This is equivalent to burying over 82,000 football fields 6 feet deep in compacted garbage.
- Recycling aluminum takes 95% less energy than making aluminum from raw materials, and each aluminum can recycled saves enough electricity to light a 100-watt bulb for 3.5 hours.
- The energy saved from recycling one glass bottle is enough to light a 100-watt bulb for 4 hours.
- Around 4.5 million tons of office paper is thrown away each year in the United States. This is enough paper to build a 12-foot-high wall of paper from Los Angeles to New York City.
- Annually each person in the United States use paper equivalent to two pine trees.
- Approximately 88% of the energy is saved by producing plastic from plastic as opposed to plastic from the raw materials of oil and gas.
- Enough plastic bottles are thrown away each year in the United States to circle the earth four times.
- The United States throws away enough iron and steel to continuously supply all the nations automakers.
- The average household throws away two pounds of steel per week, which, if recycled, would save enough energy to keep a 60-watt bulb burning for two days.
- Steel recycling results in 74% savings in energy, 90% savings in virgin materials, 86% reduction in air pollution, 40% reduction in water use, 76% reduction in water pollution and 97% reduction in mining wastes.
Those are some impressive stats. Rethink your next toss of a plastic bottle into the general trash pile. Next week we’ll look at a few more.
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Tuesday, May 07, 2013
More State Legislation to Watch
A few weeks ago, I talked about pending legislation regarding the use of formaldehyde in products used by children. I’d now like to draw attention to proposed legislation in Massachusetts.
It’s a short law, and it is designed to ban the use of tropical material in state-funded projects. It has an allowance for the use of FSC-certified material, but recognizes no other certification systems.
First, all analysis, by organizations from the World Wildlife Fund to the United Nations to the U.S. Forest Service state that the best way to preserve forests is to have a healthy forest industry. Forests have value as standing forests—the moment you decrease demand for tropical wood products, that forest ceases to be valuable to the community around it. That forest is much more likely to be cleared and replaced by farmland or ranching. The bottom line is that boycotts lead to deforestation.
This is a controversy raging in several other states that are now looking to repair ocean boardwalks that were either damaged in Hurricane Sandy or just need updating. We all know that wood is the best environmental choice when you consider both the energy required to produce it and the product’s carbon footprint, but even so, New York City is considering specifying concrete and recycled plastic lumber over wood. Do we really want to spend a summer day strolling on a concrete boardwalk?
We all know that a longer use cycle is more green, right? This article quotes Atlantic City engineer John Feairheller, who said that ipé “lasts longer than it takes the trees to grow." He compared it to Southern yellow pine, which, depending on its grade, lasts five to eight years. Still, he’s being forced to look at non-tropical alternatives in wood, as well as non-wood products entirely because of political pressure.
Who is promoting this law and similar protests? Well, there are a few environmental groups that support it, but if you want to know the real force behind this, the clue may be in this key paragraph:
“Where state monies are being used, recycled plastic lumber shall be considered as an alternate material in all bids for outdoor and marine projects where hazardous material treated woods (HMTW) and tropical hardwoods are typically used…”
Wood as a material is always under a great deal of pressure from substitutes. What’s ridiculous is when an “environmental” reason is given to attack wood, given that it is so incredibly environmentally friendly by its very nature and that, again, only by giving forests economic value do you encourage increasing the number of trees in the world.
There are projects where LVT is the simply the better choice over hardwoods, and I am sure there are times when a WPC (Wood Plastic Composite) is better than wood. However this is something that should be determined by the specific project and by the desired performance and appearance. It is not something that should be legislated, and true environmental issues should be discussed, not used to “greenwash” the desire for a competitive advantage by another industry.
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Tuesday, April 30, 2013
Smokers Have More Chemicals
Last week I looked at the ingredient list of a Big Mac bun and a chocolate bar and how “scary” they all seemed. This week I want to look at an ingredient list that really should scare you.
What does formaldehyde have in common with the radioactive heavy metals lead-210 and polonium-210, as well as with hydrogen cyanide (also known as Zyklon B), vinyl chloride, arsenic, benzene and a host of other delights? They all are present in cigarette smoke.
“Cigarette smoke is a toxic cocktail of over 7,000 chemicals, including 250 poisonous and 70 carcinogenic compounds.”
The link above will lead you to a series of articles about the various chemicals that appear in tobacco smoke. I’ve pulled various quotes from those articles. What follows is a list of quotes and statistics directly from those various pages:
Lead-210 (Pb-210) and polonium-210 (Po-210) are poisonous, radioactive heavy metals that research has shown to be present in tobacco smoke … Inhaling lead-210 and polonium-210 increases the risk for lung cancer. In fact, because the buildup of radiation a person receives over many years of smoking can be huge, researchers feel that lead-210 and polonium-210 in cigarette smoke are significant factors for lung cancer in smokers.
Hydrogen cyanide, a colorless, poisonous gas, is one of the toxic byproducts present in cigarette smoke….Under the name of Zyklon B, hydrogen cyanide was used as a genocidal agent during World War II. While no one would willingly breathe hydrogen cyanide into their lungs, smokers do it multiple times with every cigarette they inhale. And because hydrogen cyanide is present in secondhand smoke, nonsmokers are also at risk of breathing in this poison when they are exposed to cigarette smoke.
Benzene is present in cigarette smoke and accounts for half of all human exposure to this health hazard.
Arsenic-containing pesticides used in tobacco farming persist in small quantities in cigarette smoke.
Cigarette smoke is laden with formaldehyde as well.
Tobacco companies discovered that adding ammonia to the cigarette manufacturing process helps convert bound nicotine molecules in tobacco smoke into free nicotine molecules. This process is known as "freebasing." Similar to the chemical process of freebasing cocaine, the end result is an enhanced effect of the drug on the user.
Researchers at the Colorado School of Mines in Golden, Colo., have recently identified three previously undetected pesticides in cigarette smoke. The pesticides are:
- Flumetralin: This chemical is known to be toxic to humans, and is carcinogenic. It's an endocrine disruptor, and its use on tobacco plants has been banned in Europe.
- Pendimethalin: This is another endocrine disrupter that targets the thyroid specifically. Pendimethalin is carcinogenic and toxic to humans.
- Trifluralin: Like the other two pesticides mentioned, trifluralin is an endocrine disrupter, is toxic to humans and is carcinogenic.
Tobacco-specific N-nitrosamines (TSNAs) are known to be some of the most potent carcinogens present in smokeless tobacco, snuff and tobacco smoke. Two of these chemical compounds, NNN and NNK, have been classified as Group 1 carcinogens.
Also known as chloroethylene, ethylene monochloride, or monochloroethylene, vinyl chloride is a flammable clear gas or a liquid with a mildly sweet odor. Vinyl chloride is a man-made product. It does not occur naturally in the environment. Today, vinyl chloride is most commonly used to make a polymer called polyvinyl chloride (PVC). PVC is found in various plastic products, including wire insulation and packaging materials.
Nicotine is a colorless, poisonous chemical, derived from the tobacco plant. Nicotine is highly addictive. When a person inhales cigarette smoke, the nicotine in the smoke is rapidly absorbed into the bloodstream and starts affecting the brain within 10 seconds. This results in a number of chemical reactions that involve hormones and neurotransmitters such as adrenaline, dopamine and insulin. Within minutes, the nicotine level in the blood drops, and the smoker begins to experience feelings of nicotine withdrawal, prompting the urge to light up again. Smoking "pleasure" in reality is simply the relief felt when the nicotine level in the bloodstream is replenished. The nicotine content in tobacco products varies widely. One drop of pure nicotine is enough to kill a person.
This list is only a fraction of what information is available off this one site alone. Those who know me know that I’m violently antismoking, so this choice of topics will be no surprise. However why am I putting it on a green blog on wood flooring? Well, beyond arming non-smokers with some info to help encourage folks to quit, I thought it could help salesmen put VOC fears into perspective. I don’t want anyone who chooses to smoke to ever complain about formaldehyde emissions from wood flooring, or really any emissions out there. Their complaints don’t have a puff to stand on.
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Tuesday, April 23, 2013
We’re All Chemicals
I have a friend just who loves to eat a mix of the following: calcium sulfate, calcium carbonate, calcium silicate, diacetyl tartaric acid esters of fatty acids, ethanol, sorbitol, polysorbate 20, potassium propionate, sodium stearoyl lactylate, ammonium chloride, ammonium sulfate, calcium peroxide, ascorbic acid, azodicarbonamide, calcium propionate and BOTH mono- and diglycerides among other things… Doesn’t that just make your mouth water?
I bet if you saw it as part of an MSDS for a flooring glue, you’d freak out, wondering what type of VOCs it would lead to, or if you need to wear gloves or mask in handling it. It sounds terrible; it sounds scary. A lot of bi, di and tri versions of “ides,” “ates” and “iums” never feels good. It sure doesn’t sound healthy and it doesn’t sound safe.
Well, I don’t know about healthy, since they’re all mixed up with some other things like flour and partially hydrogenated soybean oil as part of a Big Mac’s bun. But they are safe enough for the majority of our population. There may be the one in a 100,000 who has a sensitivity to “polysorbate 20” in even the smallest amounts, but for the most part, a Big Mac bun is going to do more harm to our waistline then anything else in our body.
I talk a lot about a lot of green claims coming from fear, and I think this is a good example. You may or may not like a Big Mac, and you may or may not think it’s the healthiest lunch around, but for the most part, you don’t look at that sesame seed bun as a chemical cesspool.
But isn’t that the bottom line? After all, we are all chemicals. Chemicals are not inherently evil, they just are. Many of them can hurt us in large amounts. Some can even hurt us in small amounts. Some people will be more sensitive to one over another. But a “chemical” itself? That’s not a bad word. We shouldn’t treat it as such.
Oh, and by the way, so you don’t think I’m picking on McDonald’s, you can take a quick look at some of Subway’s chemicals, oops, I mean ingredients, or what is in everyday brand name breads. Do a little Googling of your favorite treats. You may never look at that yummy chocolate bar the same way again.
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Tuesday, April 16, 2013
Let's Stop Scaring People About Formaldehyde
I recently ranted about proposed anti-formaldehyde legislation. I noted that formaldehyde is a natural part of life. This put me in mind of when I was living and working in Japan, a country that went on the anti-formaldehyde bandwagon years before the U.S. hopped aboard. I was talking with some customers about a product, translating between them and the supplier of the material. They asked if it had formaldehyde in it and were told it did not. They insisted that surely it did, that all foreign products had to contain formaldehyde, it was just known to be true. I asked them if they knew what formaldehyde was. They did not. I asked them if they knew that it was present in apples and spinach and smoked salmon. They did not. I asked them if they would stop eating apples and spinach and smoked salmon and they said no. Why not? Because that was “natural” formaldehyde.
Let’s compare the structure of natural and artificial formaldehyde:
Personally, I don’t see the difference.
That makes me think of one my other favorite stories. A year or so ago, I was talking to an American woman about formaldehyde issues. I quoted a few statistics to show that it wasn’t quite as harmful as she just KNEW it was. She got quite angry and nearly shouted, “Stop trying to confuse me with science!”
Sigh.
Ok, for those of you who want some nice comparisons to tell YOUR customers:
- The standard human body, through natural metabolic processes, generates and disposes of about 45,000 mg every day. This means that a person would have to breath air from CARB 2 particleboard for over 61 YEARS just to equal the amount that a body naturally generates and consumes in 24 hours. (Please pause and reread that figure: 61 years of CARB P2 emissions equals what you, as an average adult, naturally produces every 24 hours. Forget what you eat or breathe—this is what your own body is doing.)
- The average American “eats” at least 10 CARB 2 particleboards a day.
- Every time a baby exhales, they emit approximately 500 times the proposed level of formaldehyde that is acceptable according to the EPA.
Let’s take that one a bit further. The EPA’s proposed "safe level" for exposure to formaldehyde is 8 parts per trillion. (Personally I think the EPA may be right—at that level, I don’t think even the most sensitive of us could possibly be harmed.) Now let’s apply the "safe level" to automobiles, since a lot more people are harmed (and killed) by automobiles than by formaldehyde. That would work out to just over 0.05 of a car for the entire population of Earth. Yes, that’s about a steering wheel and perhaps part of a tire for all of us to share. Certainly we could all cross the street a lot more safely….
Come on, folks! Let’s stop trying to scare people and put some common sense back into our regulatory system.
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Tuesday, April 09, 2013
Response to Avi's Bamboo/Engineered Post
Avi, thanks for the chance to comment on your post about bamboo and engineered flooring, and sorry for the late reply.
Well, as you can imagine, I don't fully agree with your position. I think that the issue for much of what you listed in your blog post is not a factor of a specific product category itself, but the production quality of an individual item. I think these most of the items you listed can be just as green, and by some standards, even more green than solid is.
You've certainly seen a lot of solid flooring that was badly dried (either too wet or too dry), that was badly machined, that failed on the job site or required excessive sanding to make flat or whatever. You’ve cut your share of material in half to get out a twist. You’ve seen the failure of good flooring that was installed on wet subfloors. You’ve heard the squeaks and felt the bounce caused by insufficient nailing. You’ve winced to see dust damage on a finish. I’m sure there’s been cases where poor sanding left marks that just made you cry when the sunlight hit them…
For all categories of products, be it solid or engineered, bamboo or oak, prefinished or site-finished, I think the first question is the quality of production and then the quality of the install. After that, it's up to debate as to which item is more "green" than another depending on your definition or focus of being green.
A strand floor product or an HDF core both will use a lot of glue and processing power to make, but it can use a lot of scrap material that otherwise would be wasted—one negative, one positive. Plus strand goes beyond just bamboo these days to utilize a lot of different species that otherwise would just be wasted. For all of these and other engineered flooring, both general recovery and maximizing quality recovery is a big factor. A high-quality tree can be used to make many more square feet of floor than it could do in solid applications. And a 4- or 5-mm wear layer on engineered has pretty much the same refinishing life as a solid floor, while we’d all look at a 0.6-mm face as wearing out about the same as laminate. But yes, engineered flooring can also take a bit more processing power and glue to make.
What else? Job site finishing might be easier to sand down in a few years, but factory finishing puts a lot less VOC and sawdust in the air and allows more recycling of finish material. Trucking red oak from Pennsylvania to California generally means a greater carbon impact than container shipping Chinese oak across the Pacific. And I've long argued that we have to think how we use the limited amount of dirt we have on this planet—we can choose to put natural forests, plantations, farms, or shopping malls on that dirt, and each one has a different benefit and cost to consider. The bottom line is that these are complicated issues.
Is ash “greener” then oak because it dries faster? Is a rustic “greener” than a clear-color matched floor? Is a 2-inch recovery width better for the environment than a 6”-inch, or should we go wide to use less nails and glue? Should we never use a vertical-grain product because it requires a lot more waste to saw? Walnut is still, I believe, the one U.S. hardwood with a negative growth rate (we cut more volume than is being grown)—do we stop using it? Or is it more green than others because we get to use the nuts for years before we harvest for timber? Nothing’s simple…
Some people buy bamboo because they like the look and couldn’t care less if it is “green” or not by whatever definition you are using. Some people will buy an American wood just because it’s American and not want to even look at a tropical product, even if it’s FSC-certified—the “Made in USA” is their defining purchase point. Some folks get solid just because its SOLID and they don’t even think that maybe in the 8-inch width they want, engineered might be a bit more stable and perhaps a better use of a resource… (I once saw an architect in Japan use 6/4 x 10” FAS red oak for his flooring. It didn’t strike me as the greenest floor out there, but it was definitely SOLID.)
I agree completely that pulling up a floor shortly after install is a complete waste. So again I think to start with green, you start with a quality product. After that, the question becomes where your priority is—resins or carbon sinks or transportation or recyclability or whatever it is... There are so many different approaches to consider. I think you know my position, that there are shades of grey in being green, that nothing is black and white.
I’d like to see you look at pros and cons of each item from your unique contractor’s point of view. If you have tips to help avoid failure, that would be a green thing to offer up—people are going to keep using composites and engineered and bamboo for some time to come, so what can we do to educate them to pick the right product and to use it the right way? Is there a better nail type or nailing pattern to use? Got a recommended glue for one product over another? Suggestions on subfloors? What do you look for in an engineered floor construction?
Solid is a great product with a lot to cheer about. The U.S. hardwood resource is a terrific one—it’s well-managed and growing. If you are buying from a mill next door, that’s also great news, not just for reduced transport issues, but because you’re helping your neighbor. I don’t think we have to say the other products are bad to say that one is good. There are plusses and minuses in all of these, and I, for one, am delighted we have so many choices within our industry so we can pick the look and the product and the specific “green nature” that is matches our own sensibilities.
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Tuesday, April 02, 2013
Look For Me (and My T-Shirt) In Dallas
I wasn’t able to attend Domotex last week in Shanghai, but I think they had a record year. All reports have been positive. As the saying goes, a rising tide lifts all ships, and I hope we can see the entire industry prosper more this year.
Today is the first day of the NWFA Expo here in Dallas. Look for me tomorrow on the show floor in my “hugged it first shirt,” worn again at the request of some of the NWFA staff who weren’t able to attend Surfaces. Perhaps we’ll get some updated pictures to post this week.
Next week, I’ll be responding to my fellow HF blogger Avi's post about bamboo and engineered flooring, and then I'll be back talking chemicals, giving you some wonderful formaldehyde stats … anyone want to guess roughly how many CARB P2 particleboards you “ate” today?
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Tuesday, March 26, 2013
Formaldehyde-Filled Children?
The Minnesota state Legislature has introduced a bill to ban the use of formaldehyde in children’s products. The legislation is less than a page long and says that “no manufacturer may sell or offer for initial sale at retail in this state a children's product that contains: (1) formaldehyde, including formaldehyde contained in a solution; or (2) ingredients that chemically degrade under normal conditions of temperature and pressure to release formaldehyde.”
However it allows formaldehyde to be present in “a food, beverage, dietary supplement, or a medical device.” So formaldehyde in things that we eat and drink and take for our health are OK, but in other forms it will kill us? Not sure of the logic there, but, well, as you are probably already sensing, I don’t see much logic in this legislation at all.
But wait—they offer acceptable alternatives to formaldehyde, right? Well, the bill notes that “a manufacturer shall not replace a chemical whose use is prohibited in section 325F.175 with a chemical that has been designated by the Department of Health as a chemical of high concern under section 116.9402.” That list is only 255 pages long, so I’m sure it’s not overly restrictive.
The legislation is probably focused on banning the use of formaldehyde in personal care/cosmetic products such as lotions, shampoos, etc.; however, with a little creative work from a lawyer, it suddenly covers children’s toys, blankets, clothing, many off-the-shelf clothing detergents, and even flooring in a school or a home. More importantly, a bill like this continues to reinforce the stereotype that formaldehyde in and of itself—in any quantity, in any use—is evil. Where do you stop if you’re not using science to really evaluate risk?
I assume the lawmakers who signed onto this bill did so without real thought—the idea sounded good. “Protect the children”—we can’t disagree with that! “Formaldehyde? Oh wait, I’ve heard of that stuff, isn’t it what was in those FEMA things that made kids sick? Yeah, we should keep THAT away from the children!”
Well, I hate to tell you guys, but it’s too late. Formaldehyde is already inside our children. They make it themselves as part of a healthy normal metabolism. Drink a yogurt smoothie? Eat an orange? Your body breaks those products down into a variety of things, including formaldehyde. As well as helping process foods, our bodies use formaldehyde to assist in creating DNA and amino acids. Want to live without those?
Worse still, those children are emitting formaldehyde themselves! (We’re not even going to touch the issue of the methane they produce…) Human beings naturally exhale it with every outward breath. (We may not know if Clinton inhaled, but we do know that he was a formaldehyde emitter.)
In fact…hey you, yes, YOU there. You’re a formaldehyde emitter! Bet you didn’t know that average emission levels from humans can be higher than what’s allowed from a composite wood product.
We have formaldehyde all around us. You are probably breathing some right now, and it isn’t necessarily coming from your engineered flooring. It’s coming from the secondhand (or primary!) cigarette smoke, from car exhaust, from your fireplace. Take a deep whiff of smoke from that nice wood fire—ah, you just enjoyed a fresh hit of formaldehyde.
We eat formaldehyde. Apples and pears, smoked salmon and milk, peas and carrots … the average daily American diet contains about 10-20 mg of formaldehyde.
My point is that we need to be reasonable about our regulations. Let’s look at the science. We want to avoid excessive emissions, because, yes, too much of it is not healthy for any of us and certainly some folks have a hyper sensitivity. But just saying “go to ZERO” is silly.
Take this to the extreme of the logic tree: If you want to keep formaldehyde away from children, you have to acknowledge it is in them now and they are breathing it on each other at daycare. Do the lawmakers in Minnesota want to ban children?
Final note: Because our bodies process through formaldehyde so easily and quickly, almost all common formaldehyde reactions are related to being exposed to an immediate and localized high concentration rather than an accumulated long-term dosage. Most every symptom or problem will disappear after you are no longer exposed. Also, "formaldehyde in air is readily broken down by sunlight, with a half-life of approximately 30-50 minutes," so you’ll need to breathe quickly or you’ll miss it!
Many of the useful facts on formaldehyde were pulled from this article. Other good reading can be found here and here.
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Tuesday, March 19, 2013
Alphabet Soup Series, Part 8 of Many: SRA
Earlier I talked about Green Lanes and SRAs. SRA is a “Spatial Risk Assessment” and within our industry, it is normally defined generally as the assignment of risk based only on geographic location. Most people would agree that a U.S. hardwood would be considered “low risk” using an SRA.
A strict SRA does not consider anything other than the source location—it doesn’t look at the company supplying the product or their certifications or anything else. Just “they are based in X location and X has a higher or lower risk analysis based on ABC factors.”
One of the problems with SRAs within our industry is that we don’t have any official ones based on governmental analysis. ENGO’s have created many types of SRAs, many of which are quite well thought out, but none of which are officially recognized as absolute.
Personally I don’t believe that an SRA is the only valid way to look at risk. It’s one of many tools, and I think in many cases it can be overemphasized, with very good companies being blacklisted only because they are located in what is considered a high-risk region. In fact, it is possible that too much emphasis on geographic risk assessment can be a huge negative to the local forests, since it can hurt those companies trying to do it right.
That said, it is certainly one of many valid tools to assess risk, and if the U.S. government can provide the analysis to aid importers—and domestic producers—it would be great. As discussed last week, I think having some form of green lanes under Lacey could be a real help to the industry at large. However, for both SRAs and green lanes, I would like to see work done on the governmental level.
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Tuesday, March 12, 2013
Green Lane Legality
Two weeks ago, I wrote about Indonesia’s new Timber Legality Assurance System, SVLK, and last week I discussed the EUTR system for the European Union. Time to combine them and look at again at the “green lane” concept in the world of timber trade.
The SVLK is the foundation of Indonesia’s work on developing a VPA (Voluntary Partnership Agreement) with the EU that will give certified Indonesian products the right to use the “green lane” when entering the EU. This means that properly certified material will be considered compliant with the EUTR and allowed to enter the EU without hassle.
As noted in my earlier blog on the EUTR, U.S. products currently do not have the right to use the green lane into Europe.
Nor does Lacey have any form of a green lane for either imported material or domestic production. Under Lacey, a red oak floor from trees harvested in New York is considered as equally at risk as merbau flooring that has been certified legal in Indonesia. In fact, under many proposed systems of Lacey due care, the Indonesian product is defined as having lower risk since most groups give priority to a certified product.
Some groups look at the green lane concept as affirming “Spatial Risk Assessment” (SRA: the assignment of risk based only on geographic location) as the best method by which to base your level of due diligence or by which to select your suppliers. But I see green lanes as a very different concept from SRA—they are based on a government-to-government agreement as to what the local government says defines legality within their own country. Furthermore, the local government has defined a system by which companies can show compliance. It is not regionally based, but a true system of legality assurance, monitored by the government with certification available to those companies that follow it, not just to those that happen to be based in that region. One of the challenges with Lacey is that there is no true definition of compliance recognized by the U.S. government—a green lane system would help provide that.
That’s why many people feel that Lacey should offer some form of green lanes—that countries with national certification programs should have easier entry into the American market, just as they will have into the EU. The U.S. government could even do a state-by-state assessment within the U.S. to improve conditions here.
By the way, I was discussing this issue with Joe Buckhaults of Robinson Lumber, and he said to me that he could “see where the green lane option that the EUTR provides could make sense. If the exporting and importing countries can work out a system, government-to-government, then complying with due diligence would become more clear-cut, no pun intended.”
He may not have intended the pun, but I liked it enough to share here. And I agree with the idea behind it.
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Tuesday, March 05, 2013
EUTR Enforcement Starts This Week
So this week the EUTR regulations governing imports into Europe goes into effect. It will take some time before we see how this impacts on imports. The European Timber Trade Federation has made available the summary of the rules. More information is also available here.
I asked my go-to expert on the EU timber market, André de Boer of the ETTF: “What do importers have to do this week?” He replied:
Boer: It’s a misunderstanding to think that EUTR asks for controls at the point of entry (customs). That is not the case. The EUTR has two pillars:
- A prohibition to import illegally produced timber. No proof of legality has to be shown at customs, but if there is substantiated evidence that timber is illegal, then of course authorities such as customs can seize the timber—not only at customs but at any place the timber is found.
- Operators, which includes all importers, have to exercise due diligence. This is not controlled by customs but by either a national competent authority (on a risk-based approach) or by a monitoring organization (on a regular interval). These controls are aimed at checking whether due diligence has been exercised when buying timber. It’s basically a check on the correct purchasing policy and procedures of the importer. It’s at the importer’s office that the checks are done.
Question: Are checks scheduled regularly or are they random?
Boer: You have to make a distinction between a Competent Authority (CA) and Monitoring Organizations (MO).
A CA is a governmental organization. CA's have to check according to the EUTR on the basis of a risk-based approach. How they are going to do it is not clear and dependant on interpretation of the respective national CA's. It is likely that checks are done when risk is expected and that can be on the basis of the reputation of the company or the origin of the timber imported by the company.
A MO is an industry association like the ETTF or a private organization like FSC. MO's have to check compliance to the due diligence procedures determined by the membership system on a regular basis. In principal every member of the MO will therefore be checked at regular intervals. In the Netherlands, we consider regular checks once or twice per year, depending on the capacity that comes available. And of course checks can be done whenever this is felt necessary, e.g., on the basis of substantiated claims.
A CA might check someone that has already been checked by an MO, but participation in an MO like the ETTF will be considered part of good due diligence and means a CA would consider that operator “low risk” and not feel the need to check often.
Question: What is the burden on domestic manufacturers? How are they checked?
Boer: Domestic manufacturers are operators under the EUTR and are checked, in principle, in the same way as importers are checked.
Bear in mind that importers buying from domestic producers are not considered to be operators and do not have to follow the same due care practices outlined in the regulations.
Question: Do the checking procedures and groups differ per country or is there a Union-wide program?
Boer: It can be foreseen that there will be national differences, but the EU is going to play a harmonizing role. And the same goes for a group like the ETTF making one due diligence system available for all the member federations in all countries and the various wood industries.
Question: Do you expect some checks to start immediately as the regulations go officially into force?
Boer: Checks will start immediately if only under pressure of NGO's. But also, as said, it should be based first on the presumed level of risk.
It is likely that—apart from clear cases of illegality—that the checking authorities will be lenient in the first one or two years. Lots of questions—also for the CA's—are still unanswered. It is considered to be work in progress.
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Tuesday, February 26, 2013
New Indonesian Legality Regulations
There is another new acronym out there to learn: SVLK. It is part of a whole family of acronyms: TLAS, VPA, FLEGT. We’ve talked about VPA and FLEGT before.
SVLK is short for the “Sistem Verifikasi Legalitas Kayu,” or in English, the Indonesian Timber Legality Assurance System, also known as the Timber Legality Assurance System (TLAS). The new Indonesian legality regulation currently covers 26 products defined by their HS Codes with a further 14 products to be included in January 2014. This means that when you’re asking a company for their legality certification, be sure to get a copy of their Appendix details as well, which will help define products and species covered.
Exporters are required to have SVLK certification, and the governments of Europe and Japan are generally recognizing that certification as evidence of legality. This certification is likely to be recognized by Australia, too, as they work on their new legality regulations, and it will definitely be a factor for showing Lacey due diligence as well. Going beyond legality, SVLK is also designed to promote the country’s commitment to practice Sustainable Forest Management (SFM).
The new system is mandatory for all producers. It creates a chain of custody process designed to ensure the processing mills only use timber from legal sources, and that all products exported from the country are traceable to verifiable points of origin. It goes right to the point of harvest. For the long term, the Indonesian government has stated that it is trying to create a system of government controlled warehousing of logs and timber that will provide a resource for the secondary producers.
Certification is provided by auditing agencies accredited by the National Accreditation Committee (KAN) and independently monitored by the Forestry Independent Monitoring Network, which consists of civil society and forestry industry experts.
For more information, here are some links:
If you can get past the talking tree trunk (advance to around the 7th minute), there is some useful information in this YouTube video.
Some concerns are here.
Reviewing the actual details of the new Indonesian regulations did give me one of my favorite sentences I’ve read in a while. "Assessment of performance and timber legality verification on the holder of IUPHHK, IPK, IUIPHHK, and Advanced IUI is to be carried out by the LP&VI."
Wow.
But hey, if you can get past all the acronyms, the bottom line is that this is good news for the Indonesian forest and for all importers of such products.
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Tuesday, February 19, 2013
Federal Construction & Mandating LEED
Last week I was talking about the upcoming EPA regulations on formaldehyde and noted that we need to “let the government know what is practical.”
Well, here is another opportunity. The U.S. government is now reviewing its policy on having LEED be the only recognized green building program for federal construction. I think it would be great if they were to open up the system to other programs.
The the full posting of the announcement is here and many more details on the process and the systems under review can be found here. To save you time hunting for the contact info, comments may be submitted by one of the following methods:
- Visit www.regulations.gov and search for "Notice-MG-2012-04"
- Fax your comments to (202) 501-4067
- Email your comments to bryan.steverson@gsa.gov
- Mail them to: General Services Administration, Regulatory Secretariat (MVCB), Attn: Hada Flowers, 1275 First St. N.E., 7th Floor, Washington, DC 20417
The federal government is the single largest user of the LEED rating system, so this is an important issue. I’d encourage you to read this short article about some of the general concerns of this LEED-only policy, and this longer article in USA Today which explores the close connection between LEED and the government. Among other things, it notes that:
- More than 200 states, cities and federal agencies now require LEED certification for new public buildings
- About 26% of LEED-certified buildings are government-owned.
- Roughly 170 cities give LEED builders tax breaks, grants, expedited permitting or waivers allowing them to construct larger buildings than local law allows.
- Roughly 2,000 developments, buildings and homes have received $500 million in tax breaks nationwide.
I am not anti-LEED, but I do find it largely unfriendly to the wood industry. Not only does it restrict offering resource credit opportunities to only FSC-certified wood, but small changes in the latest version have resulted in heavily restricting the use of non-certified engineered flooring within the “indoor air quality” category (something I’ll be getting into more this year). And for me, having options is a very important, and I would encourage everyone to encourage the government to open up the system to more program options.
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Tuesday, February 12, 2013
Surfaces Review & Upcoming Formaldehyde Fun
Sorry folks, missed a week on the blog!
In any case, a couple of quick thoughts for this week as I finish playing catch-up.
First, as I was leaving Surfaces, someone asked me how many label/advertising issues I had caught. In the past, I’ve found quite a few—misuse of the FSC logo, “Lacey Compliance” labels, inaccuracies related to CARB, etc. This time I spotted very few obvious ones. However that may well be in part because I didn’t see that much logo proliferation. In the last few years, many companies seemed eager to stamp little “green stars” all over the products. This year, the logos and certificates all took a back seat to the product. And well they should.
We should all be good stewards at this point. It should be a given within our industry that we are green by definition. We should all be working hard to make our products out of well-sourced material using healthy chemical components. We don’t need a lot of logos and certificates to sell our flooring—at least not to each other. Let’s focus on the colors, textures, sizes, construction method and the overall quality. Let the product speak, not the certificates.
That said, we have another regulation that we will soon have to deal with: the upcoming EPA regulations on formaldehyde. This is the national expansion of the California regulation we call CARB. The legislation was passed several years ago, and the EPA and other federal agencies have been trying to figure out the enforcement procedures. The proposed regulations are to be announced shortly, and there will be a short period during which industry and others can provide commentary.
During the show I asked the NWFA and they agreed to form a “formaldehyde task force” to respond to this (and other VOC regulatory issues the industry is facing.) If folks are interested in participating, drop me a note.
Of course you don’t have to be a formal member of the task force to give me your two cents. I’ll be posting information on the regulation here and soliciting comments on the proposed regs. We’re all going to have to live with these new regulations for decades to come, so we need to understand them and let the government know what is practical and what is impossible for us to handle.
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Tuesday, January 29, 2013
I'm Going Green at Surfaces 2013
Hello, all! I was at the Surfaces show today wearing my very “green” T-shirt. I got the full support of the NWFA behind being green (that's me with NWFA CEO Michael Martin). Stop by their booth (the NWFA Pavilion along with Hardwood Floors at B3552) to say hello and look for me on the floor.
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Tuesday, January 22, 2013
Where’s the Green in Surfaces?
So it’s Surfaces next week—I’ll be there, so stop and say hi if you see me wandering around the show.
I should be mostly on the show floor because there are very few green-related seminars this year. It seems every year there are less and less. I don’t know if it’s because issues have been covered or if it’s because folks are not seeing the value in marketing green. Certainly it’s rare to get much of an upcharge for something specifically green. But more likely, I think it’s because (as I’ve said in a previous post) green’s become the default.
I remember working with some of our sales force last year on challenges they faced in the market. They talked about a range of things, but none were specifically green-related. I asked them about that and they said that green is more assumed, that you had to just meet certain conditions on air quality or certification or whatever it was and that no one made a big deal of it. It used to be that “being green” (or at least marketing yourself specifically as such) set you apart a bit more. Now it’s considered more of the default position. They said that they touched on it in presentations, and they were certainly prepared to go into details on any aspect if asked, but that it was more of an assumption by the customers. However, if they were asked and we didn’t meet the general expectation that we’d be green, then there would be problems.
I think that’s mostly a good thing. Wood is green. Our industry is green. We should be celebrated for it and it should be the standard that we meet. I think it’s great that we’re being recognized as such and no longer need to hammer home the point.
So I’ll be curious to see how people are marketing themselves as green at the show, to see if it’s getting much play on the banners or in the brochures. I’m curious if Lacey or CARB will get any play. Is there going to be more FSC (or more misuse of the FSC logo)? Will VOC’s be in the air?! (Of course they will be, but will anyone care?)
Where’s the green going to be at Surfaces?
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Tuesday, January 15, 2013
Mark Your Calendars
Tuesday, January 08, 2013
Master Index, Part II
So last year, I personally found the single most useful post I made was my Master Index of past posts. So let’s start the year with another one. As before, there are a few posts duplicated under different topics.
The Formaldehyde Series:
09/14/10 Alphabet Soup Series, Part 1 of Many: VOC
09/21/10 Formaldehyde, Part 1: The “CARBonization” of America
09/28/10 Formaldehyde, Part 2: Emissions vs. Content
10/05/10 Formaldehyde, Part 3: CARB’s Approach to Formaldehyde in Composite Wood Products
10/12/10 Formaldehyde, Part 4a: The Flooring Industry’s Responsibilities Under CARB (Part 1: Documentation)
10/19/10 Formaldehyde, Part 4b: The Flooring Industry’s Responsibilities Under CARB (Part 2: Emissions)
10/26/10 Formaldehyde, Part 5: LEED and the Air Quality Standard
11/02/10 Formaldehyde, Part 6: Fun Formaldehyde Facts
4/17/12 Formaldehyde Certifications: Product vs. Process
4/24/12 Got a Hot Panel?
5/1/12 Is Double Certification in our Future?
LEED and Other Green Building Programs
08/31/10 LEED and Certified Wood: Let's Acknowledge 'Wood is Good'
11/30/10 Alphabet Soup Series, Part 2: LEED
05/17/11 Let’s Look at LEED, Part 1: Basic Vocab
05/24/11 Let’s Look at LEED, Part 2: Specific Credits for Flooring
6/19/12 Alphabet Soup Series, Part 2 of Many: LEED
11/27/12 Eco-Friendly Offices ... But Where's the Wood?
12/4/12 Express Your Views on LEED
Legality Issues, Lacey
03/01/11 Gohowood in Japan
03/08/11 Resources for the Lacey Act and Legality
04/12/11 The Lacey Act: What it Says
04/19/11 Lacey’s Documentary Burden for Importers
04/26/11 Lacey’s Legality Burden
05/03/11 Lacey and Marketing U.S. Woods
11/15/11 Lacey in the U.S., Part 1
11/22/11 Lacey in the U.S., Part 2
11/29/11 The Lacey Act and Gibson Guitar
12/06/11 Lacey's Broad Scope
12/13/11 The Proposed Lacey RELIEF Act
8/28/12 The European Lacey?
9/4/12 FLEGT! (Gesundheit!?!)
3/27/12 If Prison Labor Shipments Were Lacey Violations
10/2/12 Useful Report: Legality
10/9/12 Useful Report: Certification
10/16/12 Do you feel guilty?
10/23/12 Ok, last one on legality for a while, I promise
Greenwashing & Green Marketing
01/25/11 Alphabet Soup Series, Part 4: Greenwashing
02/01/11 Greenwashing with Logos
02/08/11 Sins of Greenwashing, Part 1
02/15/11 Sins of Greenwashing, Part 2
02/22/11 Misuse of the FSC Logo
05/10/11 Green as the Default at the NWFA Convention
05/31/11 Language Choices
10/11/11 Alphabet Soup Series, Part 5: CSR
12/11/12 Green Labels: What's Really in my Pie?
Green Stats, Facts and Figures
6/26/12 Wood vs. Cement (and other building products)
7/3/12 Let’s Look at Some Life Cycle Analyses of Wood
4/3/12 Good News about the World’s Forests
4/10/12 Global Carbon Emissions
Alphabet Soup Series
09/14/10 Alphabet Soup Series, Part 1 of Many: VOC
11/30/10 Alphabet Soup Series, Part 2: LEED
12/28/10 Alphabet Soup Series, Part 3: MSDS
01/25/11 Alphabet Soup Series, Part 4: Greenwashing
10/11/11 Alphabet Soup Series, Part 5: CSR
5/29/12 Alphabet Soup Series, Part 6 of Many: Seeing REDD
11/6/12 Alphabet Soup Series, Part 7 of Many: APHIS
Tropical Timber Issues
08/17/10 Banning Tropical Timber = Burning Tropical Timber
08/24/10 Ask Your Suppliers for LKS
11/09/10 Visit to FRIM, Part 1
11/16/10 Visit to FRIM, Part 2 (pictures)
01/11/11 Carbon Credit Confusion
01/18/11 Options for Funding Certification
Plantations and Species Information
12/07/10 A Green Grass?
06/21/11 Dead Trees Standing
07/05/11 Plantations Pros and Cons, Part 1: the Cons
07/12/11 Plantations Pros and Cons, Part 2: the Pros
07/19/11 What's Hot in Plantations
07/26/11 Confucius or Confusion? What Acacia is This?
08/02/11 The Lowdown on Cork
06/07/11 What Mother Nature puts in Wood May Not Always Be Good for You, Either
06/14/11 Gifts from Old Ma Nature
Recycled & Reclaimed Wood
6/21/11 Dead Trees Standing
7/10/12 Being Green with Salvaged & Reclaimed Wood, pt. 1
7/17/12 Being Green with Salvaged & Reclaimed Wood, pt. 2: New life for old logs
7/24/12 Being Green with Salvaged & Reclaimed Wood, pt. 3: Swim or Sink
7/31/12 Being Green with Salvaged & Reclaimed Wood, pt. 4: Economic Factors
8/7/12 Being Green with Salvaged & Reclaimed Wood, pt. 5: Selecting the Salvage
8/14/12 Being Green with Salvaged & Reclaimed Wood, pt. 6: Working the Wood
Interviews with Organizations on the Ground
03/15/11 Snakes and the GFTN (GFTN Interview, Part 1)
03/22/11 The GFTN Goes Flat (Temporarily) (GFTN Interview, Part 2)
03/29/11 I Have a Suggestion About the Chicken (GFTN Interview, Part 3)
10/18/11 Sustainable Harvest International (SHI), Part 1 (Almost 3 million trees planted!)
10/25/11 Sustainable Harvest International (SHI), Part 2
11/01/11 Tropical Forest Foundation (TFF), Part 1
11/08/11 Tropical Forest Foundation, Part 2
9/11/12 An interview with Andre de Boer, pt 1
9/18/12 An interview with Andre de Boer, pt 2
9/25/12 An interview with Andre de Boer, pt 3
6/5/12 Rainforest Alliance Turns 25, Pt. 1
6/12/12 Rainforest Alliance Turns 25, Pt. 2
Industry Features
11/20/12 Tradition at Tremont Nails
8/21/12 The Green Nature of Factory Finishing
Political Issues
10/30/12 Plywood Dumping Case: What Will the Effects Be?
3/27/12 If Prison Labor Shipments were Lacey Violations
12/13/11 The Proposed Lacey RELIEF Act
9/13/11 China & Being Green
9/20/11 A Strong International Market Helps Green China
Industry Associations and Standards
09/07/10 Should We Have Green Standards? (Grades vs. Standards)
12/14/10 Association Resources, Part 1: In the Industry
12/21/10 Association Resources, Part 2: Green Building
09/06/11 IWPA & AHEC: An Expanded Focus
10/04/11 Hardwood Federation Fly-In
12/18/12 Goodbye to the MSDS
Malaysian Production
11/09/10 Visit to FRIM, Part 1
11/16/10 Visit to FRIM, Part 2 (pictures)
11/23/10 Malaysian Timber Programs
04/05/11 Malaysian Mission to the U.S.
5/8/12 5.9 Million Hectares and Growing: Malaysian Minister Interview Pt. 1
5/15/12 Malaysian Plantations—Rubberwood & More, Malaysian Minster Interview, Pt. 2
5/22/12 100 Years of Green, Minister Interview, Pt. 3
Chinese Production
09/13/11 China and Being Green
09/20/11 A Strong International Market Helps Green China
09/27/11 Evaluating Production Sources
Miscellaneous
08/10/10 Introduction: The World of 'Green'
01/04/11 Green Install Tips and Tricks
08/09/11 Spacecraft Earth
08/16/11 A Year of Blogging
08/23/11 My Green Summer Reading List
08/30/11 Enjoying the Woods
11/13/12 You Say Jatoba, I Say... Clarifying Wood Floor Marketing Names
10/30/12 Plywood Dumping Case
12/18/12 Goodbye to the MSDS
Wow, that’s a decent number of posts? You folks tired of me
yet?
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Tuesday, January 01, 2013
Happy New Year’s!
And once again, a Tuesday blog falls on a holiday and I think no one wants to read about business today (even if the hangovers some folks surely sport would allow them to focus.) So I’m going to take more time off … we’ll see if Kim is even up to posting this!
Happy New Year all! May you be healthy, happy and prosper well in 2013.
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