Ed Korczak

By Ed Korczak Executive Director, National Wood Flooring Association
When people talk about green flooring options, they often think about the flooring material itself — wood, stone, vinyl, carpet, etc. — but there are other major components used in any flooring installation that impact the environment as well. These can include things like adhesives, stains, sealers, paints and other similar products. These types of products emit VOCs, which are made up of a variety of organic chemicals that may be dangerous to both humans and our environment. Because these gases are potentially hazardous, recent regulations have been implemented that govern their production and use.

Products that are affected by VOC regulations are far-reaching for the wood flooring industry. They can include, but are not limited to, stains, sealers, finishes, paint and adhesives. In the United States, there are a variety of organizations that regulate VOC emissions. In California, the California Air Resources Board (CARB) was established to monitor air quality for the state of California, but in other areas of the U.S., such as the Northeast, regulations are governed by the Ozone Transport Commission (OTC). Generally speaking, these organizations have implemented regulations to reduce the overall VOC emissions from products in an effort to reduce both environmental impact and human exposure. And while this legislation is relative to the United States only, its significance is far-reaching because many manufacturers are altering their products to meet these strict regulations.

As an example, substances classified as varnishes, which includes both oil-modified and water-based finishes, currently have a U.S. national VOC limit set at 450 grams per liter. OTC states place more stringent standards, establishing a ratio of 350 grams per liter, while CARB standards are even more stringent at 275 grams per liter. Other products used in wood flooring, such as conversion varnishes, tongue oil, stain, sealer and lacquer, have different regulations and different compliance ratios.

The responsibility for compliance generally lands in the lap of the manufacturer. They are required by law to clearly label their products to include required compliance information on the container. However, ignorance of the regulations will not excuse a contractor from fines and repercussions, which can be severe.

During the 2009 National Wood Flooring Association convention, a panel of experts presented a startling example of how common products found in a typical contractor’s vehicle could result in severe fines. The example listed the following products:
• 6 quarts of stain (VOC 550 g/L)
• 2 gallons of stain (VOC 550 g/L)
• 10 gallons of sealer (VOC 550 g/L)
• 10 gallons of OMU poly (VOC 525 g/L)
• 5–10 gallons of waterborne (VOC <350 g/L)

For a contractor working in the state of New Jersey, potential fines for noncompliant products could add up as follows:

• 6 quarts of stain No fine since this falls under the quart exemption ruling
• 2 gallons of stain $1,200 for being over the 250 VOC limit
• 10 gallons of sealer $10,000 for being over the 200 VOC limit
• 10 gallons of OMU poly $6,000 for being over the 350 VOC limit
• 5–10 gallons of waterborne No fine since all waterborne is under the 350 VOC limit

In this one example, this typical contractor in New Jersey could be facing fines of up to $17,200 for having products in his vehicle that are not VOC compliant. However, the fines are not limited to just the contractor. The distributor selling the product could be fined $4,000 for incorrect documentation, as well as an additional $17,200 if the products in question are documented incorrectly. The manufacturer is equally liable and can be fined in the same fashion.

Industry insiders complain that most manufacturers are being forced, at considerable expense, to bring their products into compliance with these regulations. Manufacturers generally are working to meet the most stringent standards so the expense of product development will not need to take place again in a few years when more areas adopt similar programs. In addition, federal funding for schools and other public programs is lost when states do not comply with these regulations.

Stains, sealers and finishes are not the only products affected by VOC compliance, though. Engineered wood products are of special concern because of the adhesives used in the core construction process and formaldehyde emissions. These are subject to the same regulations as the products previously mentioned, and it is important to note that regulations are changing constantly. Also of importance is products must be in compliance for the area in which they are used, not for the area in which they are sold.

There is also a concern throughout the industry about products that have been manufactured prior to these new regulations. Generally speaking, manufacturers will have approximately 18 months from the regulation implementation dates to move their products, and contractors will be able to use them within this same time period.

Although many areas have not yet established VOC compliance legislation, implementation dates have been established through 2012 for many areas. A complete list of regulatory dates is available on the NWFA’s web site at www.nwfa.org.