Third party certifiers: composite wood products containing formaldehyde
Guidance document: The role of third party certifiers in certifying composite wood products under the Formaldehyde Emissions from Composite Wood Products Regulations
July 7, 2021
This document does not in any way supersede or modify the Canadian Environmental Protection Act, 1999 (CEPA 1999), the Formaldehyde Emissions from Composite Wood Products Regulations or the Directive Concerning Testing for Formaldehyde Emissions or offer any legal interpretation of the Act or the Regulations. In the event of an inconsistency between this document and the Act and the Regulations, the Act and the Regulations take precedence.
On this page
- Activities of third party certifiers
- Third party certifier ceases activities
The purpose of this guidance document is to provide general information about the roles and responsibilities of the third party certifiers (TPCs) within the third party certification framework in the Formaldehyde Emissions from Composite Wood Products Regulations under CEPA 1999.
Under the Regulations, composite wood products (CWPs) must meet the prescribed formaldehyde emission limits and be certified by a qualified TPC in order to be imported into or sold in Canada. While the elements of certification and the qualifications that a TPC must have are set out in the Regulations, this document describes voluntary, best practices for TPCs. The Regulations and these voluntary best practices align to the degree possible with the United States rule on formaldehyde emissions from CWPs, Toxic Substances Control Act, Title VI (TSCA). The TPC framework in the Regulations provides an additional layer of oversight at the composite wood panel level and facilitates regulated parties' compliance with the Regulations' testing and emission requirements.
2. Third party certifiers activities
2.1 Site visits
In order to carry out its certification role, a TPC should visit the production facilities of each composite wood panel and laminated products manufacturer that it certifies. The site visit should include a review of the equipment and operation of the facility, as well as the facilities' records, including all of the quality control tests carried out since the last TPC site visit. Typically, the TPC should visit each facility at least on a quarterly basis and ensure that the facility's records and production are in conformance with ISO/IEC 17020, Conformity assessment - Requirements for the operation of various types of bodies performing inspection. In cases where composite wood panel and laminated products manufacturers have qualified for reduced-frequency testing through the use of ultra-low emitting formaldehyde or no-added formaldehyde resins, the site visits should be conducted every six months or two years, as the case may be.
As indicated in section 26(1)(i)(ii) of the Regulations, the date and details of the most recent verification that a TPC performed with respect to a manufacturer's composite wood panels and laminated products is a record to be kept by the manufacturer and provided to Environment and Climate Change Canada officials upon request. The Regulations also require importers of composite wood panels and laminated products to obtain this information from manufacturers if requested by the government.
In addition to the activities described above, the TPC should work with the manufacturing facilities they certify to train facility officials to assess CWPs in conformance with ISO/IEC 17020.
The TPC should select the composite wood panel or laminated product specimens for primary testingFootnote 1 on behalf of the manufacturer. Under the Regulations, the composite wood specimen must be representative of the entire lot of panels and must not be taken from the top or bottom panel in a bundle. The rate of formaldehyde emissions can be influenced by other factors as well, and the TPC should rely on their expertise to ensure that an unbiased sample is selected that is representative of the entire lot.
2.3 Non-compliant lots
When non-compliant lots have been identified and treated by the manufacturer, the TPC should be involved in verifying the re-test results and ensuring that the tests have been carried out properly. The Regulations require the manufacturer and importer of a composite wood panel or laminated product who is informed of the non-compliant lot to notify the government.
2.4 Reduced-frequency testing for particleboard and medium density fibreboard (MDF)
According to the Regulations, a manufacturer of particleboard, MDF or thin-MDF may reduce the frequency of quality control testing required from once every 8-12 hours to once every 24-48 hours if a certain performance standard is met, based on a running average of 30 panels. The TPC should review the quality control test results from these running averages to ensure that manufacturers have achieved the stated performance standard in order to qualify for the reduced-frequency quality control testing.
2.5 Quality control manual
The TPC should work together with the composite wood panel or laminated product manufacturer to develop a quality control manual. This manual should include descriptions of the following:
- organizational structure of the facilities' quality control department
- sampling procedures, method for handling specimens, including a specific maximum time period for analyzing quality control samples and average percentage of resin and press time for each product type
- frequency of quality control testing
- procedures used to identify changes in formaldehyde emissions resulting from product changes
- provisions for additional testing, record keeping, labelling and product types
- procedures for reduced-frequency quality control testing (if applicable) and for handling non-compliant lots
3. Third party certifier ceases activities
In the case where a TPC is no longer qualified to certify CWPs, such as the loss of accreditation, or where a TPC is no longer providing certification services to any composite wood panel and laminated product manufacturers, the TPC should contact the Government of Canada at firstname.lastname@example.org to inform them.
- Footnote 1
Note: “Primary testing” used in this document is equivalent to “Quarterly testing” as used in TSCA Title VI (United States rule).
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