Analysis of the new Voluntary Canadian Standard for
Formaldehyde Emissions from Composite Wood Products
Brian Sause, Director – HPVA Laboratories
June, 2016
The Canadian Standards Association (CSA Group), accredited by the Standards Council of Canada (SCC) as a
standard developer, recently published “CAN/CSA-0160-16, Formaldehyde emissions standard for composite
wood Products”. The CSA began the standard writing process with an exhaustive volatile organic chemical (VOC)
standard and ended up on just formaldehyde. Although their stated intent was to harmonize with the existing
California Air Resources Board’s (CARB) Airborne Toxic Control Measures (ATCM) 17 CCR §93120 on all sections
relating to responsibilities of manufacturers and third party certifiers, the CSA’s standard falls short on how it is to
be administered.
Most surprisingly, the standard allows users to label product with either “Complies with CAN/CSA-O160” or
“Certified to CAN/CSA O160” depending on the level of participation in accredited third party programs. This
essentially allows self-certification and labeling within this standard through the “Complies with” statement as an
alternative to third party certification. No guidance is given on how a “complies with” program would be
monitored other than use of an accredited testing laboratory and specimen chain of custody.
Relying on a “complies with” label would leave out the confidence established by the quality control items
required by CARB and the ANSI/HPVA HP-1 American National Standard for Hardwood and Decorative Plywood,
including third party oversight on determination of product types, test frequency, quality management system
requirements, and process controls to monitor potential increases in emissions.
Certifying to CAN/CSA O160 would include all of the requirements of the CARB ATCM, without the California
reporting process. Third party certifiers, like HPVA Laboratories, accredited to ISO/IEC 17065 would be
acceptable to meet this standard by the Standards Council of Canada (SCC) though mutual recognition
agreements. However, it is unclear how the process of achieving exemption by executive order from CARB for a
proven emission track record would be handled, or even if allowed, within this standard’s framework.
The CSA’s definition of Hardwood Plywood is inconsistent with the definition in the ANSI/HPVA HP-1 2016, an
approved consensus standard dating back to 1934. Although HP-1 is specifically referenced, the CSA failed to
include the current edition of the standard and quotes out of context from a 12 year old edition. Neither the
HPVA nor the Canadian Hardwood Plywood & Veneer Association (CHPVA) were consulted during the
development of this standard.
The CHPVA reported at the HPVA annual meeting in June that, “the CSA voluntary standards is basically CARB
without the fabricator exemption”. This is true in that there is no specific exemption language, but in section 3
there is a note accompanying the definition of hardwood plywood which excludes “laminated products (sic),
military specified plywood, and curved plywood”. There are no definitions provided for any of these materials.
For consumers and specifiers, I am afraid the standard’s inconsistency with the ANSI/HPVA HP-1 2016 standard,
option for labeling compliance by a single test versus 3rd party certification and on-going quality assurance, and
lack of clarity on laminated products will clearly create perplexities in the marketplace.