California’s Proposed Reductions in Caprolactam, Formaldehyde Emissions

Environmental Laws That Affect Flooring – California’s Proposed Reductions in Caprolactam and Formaldehyde Emissions Explained

~ Carpet and Rug Institute’s Frank Hurd Explains the significance to manufacturers, retailers

In the second part of his presentation at the Surfaces 2011 Floor Covering Event and Trade Show held Jan 25-27 in Las Vegas, Nevada, Frank Hurd, Carpet and Rug Institute vice-president and Carpet America Recovery Effort (CARE) board chair, spoke on reductions in emissions in caprolactam and formaldehyde currently proposed in California.

Mr Hurd’s comments came during an education session, entitled, Environmental Laws That Impact Your Business, where he appeared as part of a panel discussion that included representatives from the hardwood and resilient flooring industries. (See Environmental Laws Affecting Flooring: Carpet & AB 2398 at Surfaces 2011 on part one of his presentation detailing California’s recently-passed AB 2398 Carpet Stewardship Program.)

According to Mr. Hurd, California’s Office of Health Hazard Assessment (OEHHA) is currently recommending reducing the emission levels for caprolactam to “unattainable levels”. In addition, OEHHA has reduced the acceptable emission level for formaldehyde to a level that will difficult to attain.

Caprolactam is used in the production of Nylon 6, the fiber that accounts for approximately 30% of U.S. carpets. Formaldehyde has not been used in the production of carpet for approximately 40 years, but it is a substance that occurs in nature and is found at background levels when carpet is tested, albeit at lower levels than many other building materials and flooring types.

OEHHA’s recommendations are significant to the carpet industry in that they establish the Chronic Reference Exposure Level, or CREL, for many Volatile Organic Compounds, including caprolactam and formaldehyde. A CREL is a number that represents the amount of exposure a normal person could expect to come in contact with every day throughout their lifespan without experiencing any adverse health effects. Once OEHHA sets a CREL for a certain VOC, California’s Department of Public Health uses one-half of that number to set emission limits in its 01350 Indoor Air Quality Standard Standard Method for the Testing and Evaluation of Volatile Organic Chemical Emissions from Indoor Sources Using Environmental Chambers, Version 1.1 (2010). In turn, the 01350 standard, as it is commonly known, is what the CRI uses as the basis for establishing the emission levels in its Green Label Plus (GLP) IAQ Standard.

California is currently proposing cutting the allowable emissions from caprolactam from 100 micrograms emitted per cubic meter of air down to 2µg/m³. While the state of California measures emissions after 14 days, the carpet industry’s GLP standard measures emissions after only 24 hours – a far more difficult goal to achieve.

Ironically, Mr. Hurd points out that, after reviewing the same data accessed by California, the European Indoor Air Quality Standard raised its CREL for Caprolactam from 50 to 240µg/m³. Mr. Hurd said, “this vastly different view of the science by OEHHA is very troubling and CRI is doing all it can to convince OEHHA they have the wrong numbers.”

As for formaldehyde, OEHHA has already set its CREL at an extremely low level of 9µg/m³ from a previous level of 37µg/m3. This is further complicated by the fact that, as mentioned earlier, CA 01350, the standard for measuring VOC emissions, set its limits at one-half the established CREL, which in this case would be 4.5µg/m³. This level, while problematic for carpet, will have far-ranging effects on multiple building product categories. For this reason, the CA Dept. of Public Health, which is responsible for CA 01350, is only gradually implementing the change, thus providing manufacturers time to adjust to the lower levels.

Mr. Hurd assured retailers in the audience that carpets that carry the Green Label Plus logo would, now and in the future, meet or exceed regulations for Indoor Air Quality.

Here is the 4.3 minute video clip of Frank explaining California's proposed reductions in Caprolactam and Formaldehyde emissions. [To access the clip directly from YouTube, click on FH Enviro Laws Affecting Flooring (Caprolactum).]


Thank you, Frank.

~Bethany