Tuesday, April 24, 2012
Got a Hot Panel?
Last week I talked about process vs. product certification. Both can provide a good product, however, even under the best of systems and the most stringent of checks, you can still find production outside the standards. This is just the way the real world is and we know this. Unfortunately it is not apparent that all governmental agencies understand that right now.
If the process is certified, and the manufacturer is following the process, it is still possible for a limited amount of production to fall out of standard. Actually, that can happen with a product-based certification as well—the certifying body cannot check every single piece of plywood that ships out. In either case, it’s not automatically their fault (neither the manufacturer’s nor the certifier’s)—as business people, we understand that in the real world, production is actually done within “established levels of tolerance.” We recognize that, and it is hoped that the new regulations will find a way to recognize that as well.
Currently, CARB doesn’t really recognize the real world production conditions. Remember that CARB was established based on a maximum standard. That is, the limits set are the maximum allowed emissions, where with most other international standards, the emissions are set as a range. As any panel manufacturer knows, it is impossible to guarantee that all panels within a production lot are going to be exactly equal in their emissions—a little extra glue in a void, a particularly absorbent patch of grain, a temporary clog in an injector—and any panel could run a little “hot” as a result.
CARB does not have any allowance for a single panel in an entire lot being out of spec—it is hoped that the EPA’s new rules will establish a de minis exclusion, meaning that if perhaps 3-5% of the lot reads “hot” but still under a specified limit, and all proper production procedures have been followed, the manufacturer is not going to be punished for a few boards that fall outside the standard.
One issue that will become more and more important as formaldehyde (and other certifications) become a greater factor in our industry is the question of due diligence and a degree of innocent owner protection. Already a major discussion point with Lacey, this is something that should be also discussed as CARB and the EPA establish their new rules. If a company has performed due diligence in making a purchase of a “certified” product, shouldn’t that be taken into consideration? Should all their downstream customers be punished as well? Regulations that protect the consumer are good, but we should also write them in ways so that companies who are trying to do the right thing and take the extra steps are also protected.
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Tuesday, April 17, 2012
Formaldehyde Certifications: Product vs. Process
In the next few months, formaldehyde is going to be back in the news. CARB has been reviewing their regulations and is expected to announce significant changes within the next month that may particularly impact on the flooring industry. On the national front, the EPA is still working on the details of their regulations—it is hoped that sometime this summer they will open their proposal up for public comments.
CARB uses (and the EPA will likely continue this policy) a system of “process certification,” rather than “product certification.” This is a very important distinction for flooring dealers to recognize.
A product certification means that the Third Party Certifier (TPC) is stating that each piece of product has actually been produced compliant with the required specification.
A process certification means that the TPC has verified that the factory is capable of producing product to the required specification.
In process certification, the certifying body has no liability if the product is outside the standard. They’ve only checked for capability—in the case of CARB, they will audit the facility (checking equipment, glue, procedures, etc.) and they will spot-check production at least quarterly for formaldehyde levels. But they do not have inspectors stationed in the facility or check production as it comes out on a regular basis. Any buyers purchasing process-certified material are doing so fully at their own risk. They are unable to go back to the certifier if the product fails to meet the standards. CARB regulations clearly state that “The manufacturer is responsible for the performance of all certified products.”
In product certification, however, the certifying body assumes at least partial financial liability, and they respond accordingly. They will have inspectors in the factory weekly, even daily, and they will spot check material constantly. Obviously this would be a significant expense for the TPC and, accordingly, costs for a certified product are significantly higher. Product certification is usually reserved for material that has the need for the higher standards. (Composite wood products that are certified can include structural plywood and OSB. Most folks would agree that the liability issues for a roof system might be a little higher than for a sofa.)
Now, a process based certification can be just fine. And the flooring industry cannot afford to see every plank independently certified as a product. It is going to be costly enough when we are forced to establish a national process certification for our material.
It is important, however, that as buyers and sellers, we recognize the limitations and liability of a process based certification and establish systems of due diligence that will help ensure that our products meet our specifications. Remember, the certifying bodies aren’t providing us with any guarantees…
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Wednesday, April 11, 2012
Global Carbon Emissions
Last week’s look at increased forest cover and a reduction in illegal logging was wonderfully hopeful. However, I recently reviewed a report that said we’re still polluting far too much. The report, "Long-Term Trend in Global CO2 Emissions" was prepared by the European Commission's Joint Research Centre and PBL Netherlands Environmental Assessment Agency.
Some highlights (as well as the lows) were:
- Global emissions of carbon dioxide, the main cause of global warming, jumped 45% between 1990 and 2010, and reached an all-time high of 33 billion tons last year, the European Commission reports.
- The 27 member nations of the European Union (EU-27) cut CO2 emissions 7% during the 1990-2010 period and Russia slashed them 28%.
- Japanese emissions remained fairly constant.
- In contrast to the others, U.S. emissions increased 5%.
- The U.S. emits 16.9 tons of CO2 per capita per year, more than twice that of the EU-27's 8.1 tons and China's 6.8 tons.
- Chinese per capita CO2 emissions of 6.8 tons are below the EU-27 average, equaling those of Italy.
When you look at where the U.S. stands internationally, clearly we have a long way to go toward reducing our own individual carbon outputs. It’s great to be an industry that has the potential to contribute positively to the overall carbon conditions, but as individuals, let’s think more about our actions.
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Tuesday, April 03, 2012
Good News about the World’s Forests
Last week, I noted that the recent news regarding world’s forest has been good. Here are some positive reports and figures:
 The Food and Agriculture Organization of the United Nations (FAO) has released a global satellite survey of forest cover noting that total forest loss is 32% lower than had been thought over the last 15 years. The Forest Resource Assessment (FRA) previously reported a loss of 107 million ha between 1990 and 2005, whereas the new survey reports a loss of 73 million ha for that same time with Asia showing net gains from 1995-2010. (The full report is available here, and other publications can be found here.)
According to the latest Chatham House report on the world’s forests, the “total global production of illegal timber has fallen by 22 percent since 2002. The report goes on to state that “illegal logging has dropped by 50 percent in Cameroon, by between 50 and 75 percent in the Brazilian Amazon, and by 75 percent in Indonesia in the last decade. This reduction, documented in three of the five tropical timber producers studied, has prevented the degradation of up to 17 million hectares of forest, an area larger than England and Wales combined.”
The ITTO reports significant increases in Sustainably Managed Forests (SFM) and certified forest volumes in permanent forest estates (PFE) around the world. Some key notes from their report :
- The area of certified natural-forest production PFE increased in each region between 2005 and 2010. In all three regions combined, the certified forest area grew from 10.5 million hectares to 17.0 million hectares, an increase of 63% (1.3 million hectares per year). In percentage terms the biggest growth was in Africa, where the certified forest area more than tripled, from 1.48 million hectares to 4.63 million hectares.
- The area of production PFE considered to be under SFM increased between the 2005 and 2010 surveys, from 25.2 million hectares to 30.6 million hectares, an increase of about 20%.
- The estimated area of protection PFE with forest management plans in 2010 (51.9 million hectares) is significantly higher than the estimate made for 2005 (17.8 million hectares). The largest regional increase in percentage terms was in Africa, and the largest in terms of gross area was in Latin America and the Caribbean. Part of the overall increase in 2010 may be due to better information … Nevertheless, there has also been a real expansion in the use of management plans for protected areas.
- The estimated area of sustainably managed protection PFE more than doubled over the period, from 11.2 million hectares in 2005 to 22.7 million hectares in 2010. This increase was due mostly to a near-tripling of the area in Africa and Latin America and the Caribbean.
And, of course, the U.S. hardwood industry is rightly proud to note that even with an increase in production and international demand, overall standing timber volumes have doubled in the last 50 years.
It is great to see positive news for the forests from all around the world!
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