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> May 12, 2008
>
> Document Control Office
>
> Office of Pollution Prevention and Toxics (OPPT)
>
> Environmental Protection Agency
>
> 1200 Pennsylvania Avenue NW
>
> Washington, D.C. 20406-0001
>
> Re: Docket ID Number: EPA-HQ-OPPT-2008-0267
>
> Federal Register Notice Page 22369-22372
>
> April 25, 2008 (Volume 73, Number 81)
>
> Mr. James B. Gulliford,
>
> Assistant Administrator, Office of Prevention, Pesticides and Toxic
> Substances.
>
> I am writing on behalf of the Window and Door Manufacturers
> Association in response to the request for comments on the Toxic
> Substances Control Act (TSCA) Section 21 petition that EPA recently
> received from the Sierra Club and numerous other organizations
> regarding "Formaldehyde Emissions from Composite Wood Products." This
> petition requests EPA to exercise its authority under TSCA Section
> 6(a) to adopt and apply nationally the formaldehyde emissions
> regulation for composite wood products recently enacted by the
> California Air Resources Board (CARB), and to extend the regulation to
> include composite wood products used in manufactured homes.
>
> We represent manufacturers of doors, windows and skylights. Many of
> our members are engaged in making and using hardwood plywood (HWPW),
> particleboard (PB) and medium-density fiberboard (MDF) for components
> in their products; therefore, our membership has a direct stake in
> this petition. We want to ensure that the CARB regulation achieves its
> goals for formaldehyde reduction within industry standards. However,
> the Agency may not be aware that the CARB Airborne Toxic Control
> Measure (ATCM) will have a far reaching impact on manufacturers,
> distributors, fabricators, retailers and third-party certifiers of
> HWPW, PB, and MDF that manufacture, sell or supply these products for
> use in California. In addition, the industry is asking for
> clarification from CARB on several parts of the regulation, including
> definitions, rule language, labeling requirements, and sell-through
> dates. It is important to note that the CARB regulation has just been
> finalized, and is not yet a proven system in California.
>
> More importantly, it is not technologically or economically feasible
> to apply the regulation on a national level. The costs to the consumer
> will be enormous, the industry would be required to change its
> processes in manufacturing to complying with the new requirements on
> recordkeeping and labeling. In addition, we believe it would be
> unworkable and enormously expensive to the consumer if EPA were to
> manage the third-party certification process nationwide, as well as
> handle the enforcement and inspection issues on a national basis.
>
> continued
>
> Page 2
>
> Finally, the current CARB regulation only requires three specific
> composite wood product types (HWPW, PB and MDF) to conform to a
> reduced formaldehyde emissions level. CARB acknowledges that
> formaldehyde is also emitted from carpet, paints, stains and many
> other products. Adopting the CARB ATCM nationwide will not
> significantly reduce the formaldehyde emissions that people will be
> exposed but will significantly increase the cost of home ownership.
> Rather than adopt the CARB ATCM for formaldehyde as a nationwide
> regulation, we recommend that the EPA develop a performance based
> standard that has the objective of reducing human exposure to
> formaldehyde, regardless of the source of formaldehyde emissions.
>
> **WDMA** is committed to the reduction of formaldehyde emissions from
> composite wood products; however, we are very concerned that the
> implementation of this regulation on a national level will raise many
> significant issues throughout the industry and be impossible to
> manage. Therefore, we urge EPA to deny this petition.
>
> We would be pleased to provide any additional information on this
> topic. Please contact me with any questions in this regard.
>
> Sincerely,
>
> ![](media/image2.jpeg){width="1.5in" height="0.5in"}
>
> Jeffrey F. Lowinski
>
> Vice President, Technical Service