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Environmental Initiatives of North America, INC.
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Lumber Liquidators (LL) has been under intense scrutiny by the media and public lately for the formaldehyde content of Chinese-made laminate flooring they sell. By now you’ve seen the video of a distraught individual having to tear out all of his beautiful, brand new floor finish. Are such extraordinary measures justified? 60 Minutes commissioned laboratory tests which found that the composite core of the laminate flooring released levels of formaldehyde well above the California Air Resource Board’s (CARB) emission standards. Lumber Liquidators has said that 60 Minutes used an improper test method to evaluate the flooring and that their own test results show that their product’s formaldehyde emissions are actually below CARB standards.
 
So who’s right and, perhaps more importantly, what could be the impact to the health of occupants living in houses with this flooring?
 
The crux of the testing method debate is deconstruction of the material, which is the sanding or peeling off the laminate or veneer from the top of the flooring to test the core (“platform”) of the product. The big questions are the following:
 
Do CARB regulations require deconstruction as part of the testing process?
Is deconstruction as part of the testing process a fair way of evaluating exposure?
Are the results of deconstructive testing relevant to occupant exposure?
 
The CARB promulgated 17 CCR 93120 in April of 2008 as a way of regulating the amount of formaldehyde emissions from certain composite wood materials including resilient finishes and cabinetry. Formaldehyde exposure can cause immune symptom responses, irritation, and of course is a well-known carcinogen. Formaldehyde is often included in the resins which bind the wood substrate together. The regulation provides emission standards as well as testing methodology. Primary and secondary testing methods are provided and use ASTM E 1333 and ASTM D 6007[P1]  methods, respectively. Nowhere in the regulations or ASTM methods does it require deconstruction prior to testing; however, a finished product is found to not be in compliance if it contains any composite wood product which does not comply with the standard so testing the individual components of a product is part and parcel with achieving compliance with the CARB rules. The CARB also released a Standard Operating Procedure for preparing samples of finished wood products in September of 2013. This document states deconstruction is part of preparing a sample to be submitted to a laboratory but it is unclear if this is in use and for what circumstance.
 
Interestingly, in a joint project performed by the CARB and the American Home Furnishing Alliance it appeared that laminate floor products tested prior to deconstruction actually emitted more formaldehyde than those deconstructed. This difference was likely due to the urea-formaldehyde (UF) glue used to affix the veneer to the core having been removed by the deconstruction process. If we assume the only difference between the 60 Minutes and Lumber Liquidator’s’ testing is deconstruction, we might come to the conclusion that while the UF glue and laminate layers are in compliance, the core is not.
 
The biggest question is what does this mean for consumers? Especially for those who have already installed the allegedly out-of-compliance flooring. First let’s look at what the Feds say about formaldehyde: OSHA’s Permissible Exposure Limit (PEL) is 750 ppb (parts-per-billion). 60 Minutes’ own testing results were far lower, with formaldehyde emissions in the range of ~49 ppb to ~163 ppb. This is less than what the laboratory estimates concentrations in a new single-family residence would be. OSHA laws, however, were meant to be protective of generally healthy individuals in the work force with a 40-hour weekly exposure.
 
The Center for Disease Control (CDC) states in their document, “What You Should Know about Formaldehyde”, the following regarding exposures to various concentrations of formaldehyde:
 
CDC Table on Formaldehyde Exposures
 
Formaldehyde Concentration
 
Comment
10 ppb
Low
If your reading falls into the lower range, these levels are found on the streets of many cities and in many buildings. The risk of health problems at these levels is low.
10-100 ppb
Medium
If your reading falls into the intermediate range your risk of irritation from formaldehyde exposure is lower, but it is still important to take steps to reduce your formaldehyde exposure. This is especially important if family members are elderly, young children, or have health conditions such as asthma
100-1,000 ppb
High
If your reading falls into the higher range, you need to place a high priority on lowering your exposure to formaldehyde. This is especially important if family members are elderly, young children, or have health conditions such as asthma
 
 
It would seem then, that occupants with the Chinese flooring are unlikely to be exposed to acutely dangerous levels of formaldehyde. Although, technically any exposure is undesirable due to the carcinogenic effect. Additionally, the CARB estimates that a laminate flooring product will emit half of the initial level of formaldehyde in about three years due to off-gassing. If someone’s already had the flooring for more than three years they’re unlikely to be exposed to appreciable levels of formaldehyde. Of course, everyone is different and individuals sensitive to formaldehyde might react.
 
Here’s the takeaway:
The core of the Chinese flooring appears to be out of compliance with CARB formaldehyde standards.
Both Lumber Liquidators’ and 60 Minutes’ testing methods are valid for determining CARB compliance.
Lumber Liquidators’ testing method is closer to reality concerning occupant exposure.
Most occupants are unlikely to be exposed to appreciable levels of formaldehyde emitted by the flooring.
The CARB released a fact sheet addressing laminate flooring. CARB does not recommend removing flooring product unless occupants are experiencing noticeable health symptoms associated with formaldehyde exposure.
 
Environmental Initiatives does conduct testing of residences and commercial buildings. Our pricing depends on the size and location of the building. For additional questions and to inquire about testing, contact Paul Gosh at pg@eimidwest.com or call our office at (877) 653-6847.
 
Refs:
ATCM to Reduce Formaldehyde Emissions  from Composite Wood Products
Flooring Made with Composite Wood Products
SOP for Finished Good Test Specimen Preparation
Laminated Products Testing
60 Minutes Test Results
Estimation of Formaldehyde Emissions from Composite Wood Products
What You Should Know about Formaldehyde
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Tracey and Cassidy both presented at the 2015 Better Buildings Better Business conferences. Their presentations both focused on construction and renovation practice that promote good indoor air quality. For copies of the presentations, email ck@eimidwest.com
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3/13/15
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Winter in the northern regions is brutal on our attics. Mold growth on the roof decking is the result of humid air entering the attic and condensing on the decking. This condensation is usually not stopped by adding more attic ventilation. Instead, humidity sources in the residence must be controlled and the locations of air movement into the attic from the living space must be identified and corrected. Our company specializes in identifying the root causes of condensation and determine the impact on the residence.
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