RVIA Clarifies Its Position on CARB Enforcement
The Recreation Vehicle Industry Association’s (RVIA) Standards Department has issued the following clarification of the association’s position on the use of California Air Resource Board (CARB) certified wood in response to recent questions about whether the association plans to alter its enforcement position, according to RVIA Today Express.
The increased production of RVs over the past 60 days has spurred a concern among some RVIA members that there could be a shortage of CARB-certified luan in the near future, impacting some manufacturers’ production.
It appears that the temporary shortage of CARB-certified luan is a supply-chain issue rather than an RVIA enforcement issue. RVIA has no influence over the actions of CARB, which requires that, as of July 1, 2010, every RV sold in the state of California must contain CARB-certified wood. Any manufacturer or dealer who sells an RV containing non-certified wood in the state of California after this date would be subject to monetary penalties as established by CARB.
RVIA’s requirements use the same effective date for the other 49 states, but it will apply to RVs built on or after July 1, 2010, not to those RVs sold on or after that date. While RVIA has petitioned CARB for relief on the July 1, 2010, date of sale, there has been no response from CARB, leaving the association to assume that July 1, 2010, remains the effective date for mandatory inclusion of CARB compliant wood (non-certified, but meets the CARB emission levels) in RV products sold at retail in California.
RVIA will continue to allow wood products that meet CARB emission levels but are not CARB certified until July 1, 2010, after which, CARB certified wood products will be required. If an RVIA member does not comply, a deviation will continue to be cited. For this type of deviation under the RVIA Standards program, a member would have to be cited a total of four times (the initial deviation and three repeats) before enforcement action will be taken.
Changing the program requirements in the face of a temporary shortage caused by supply chain issues does not appear to be in the best interest of RVIA or its members. Accordingly, RVIA will continue to enforce the program requirements as directed by the RVIA board of directors.