### MEMORANDUM

TO: Dan-Tam Nguyen, ERG

FROM: Casey MacQueen, ERG

DATE: June 18, 2009

SUBJECT: Meeting Summary – Discussion with CPA in Response to Comments Submitted to Formaldehyde ANPR Docket

On June 17, 2009, ERG participated in a meeting with the Composite Pa nel Association (CPA) at CPA headquarters in Leesburg, Virginia . The following ERG employees and CPA representatives were in attendance:

Attendee: Affiliation: Thomas Julia CPA, President 1
John Bradfield CPA, Director of Environmental Affairs Gary Heroux CPA, VP of Product Acceptance Anthony Gaglione ERG Casey MacQueen ERG

CPA described the organization’s purpose and me mbership, the composite panel “value chain,” composite panel manufacturing processes, and in dustry progress toward formaldehyde standards and compliance.

CPA and Its Members

 CPA represents 95% of North American producers of PB, MDF, and HB. CPA represents nearly all U.S. manufacturers (only a couple of companies are not CPA members).

 CPA provided ERG with copies of the 2009 Surface & Panel Buyers Guide, which addresses CPA membership, products, and standards.

 CPA recommended ERG contact the Business and Institutiona l Furniture Manufacturer’s Association (BIFMA).

 CPA recommended ERG contact the International Wood Pro ducts Association (IWPA), headquartered in Alexandria, Virginia.

 CPA recommended ERG contact the Recreational Vehicle Industry Association (RVIA), headquartered in Reston, Virginia.

 CPA estimated that every major distributor of composite panels is an associate member of CPA. Distributors of composite panels may handle unfinished panels, semi-finished goods, or finished goods.

1 Thomas Julia briefly spoke with the group during the beginning of the meeting and was not present during the remainder of the meeting.Memorandum June 18, 2009 Page 2

The Composite Panel “Value Chain”

 CPA stated that composite panel manuf acturers commonly sell both directly to distributors and directly to OEM facilit ies (if a bulk quantity is ordered).

 CPA stated that major end uses of domestica lly manufactured composite panels include cabinets, store fixtures, and business and in stitutional furniture. CPA estimated that 70-
80% of the Business and Institutional Furn iture Manufacturer’s Association (BIFMA)
and Kitchen Cabinet Manufact urer’s Association (KCMA) members use composite panels manufactured domestica lly (in North America).

 CPA estimated that the vast majority of the American Home Furnishings Alliance (AHFA) members use composite panels importe d from overseas. CPA claimed that in response to the CARB ATCM, home furnishi ng companies have drastically reduced Asian imports; additionally though, many mills in China have become CARB-certified.

 CPA stated that building constr uction-related end uses of part icleboard (PB) include floor underlayments, manufactured home decking, and stair treads; these end uses account for approximately 4% of domestically manufactur ed PB. The remaining 96% is used in industrial (non-struct ural) applications.

 CPA stated that there are no common building construction-related e nd uses for medium density fiberboard (MDF).

 CPA stated that the composite core of hardwood-plywood is more than likely PB.

Composite Panel Manufacturing

 CPA stated that composite panel products typi cally have decorative finishes/overlays. These overlays may be applied on a separate production line from the composite panel core, at a “sister” facility (e.g., down the road from the mill), or at an unaffiliated finishing site.

 CPA stated that common types of “value-a dded surfaces” include melamine lamination, veneer application, or painted surfaces.

 CPA stated that the point in the com posite panel manufacturing process where formaldehyde levels are highest is at the hot press; hot pre sses are typically enclosed, and the process is surrounded with controls util izing very high air exchange rates.

Formaldehyde Emissions Standards and Compliance

 CPA stated that the composite panel manu facturing industry, on the whole, voluntarily complied with the HUD 0.3 ppm formaldehyde standard. Over the following years, industry worked toward the CARB ATCM Phase I standard.

 CPA stated that the biggest technological advancement toward meeting formaldehyde emission standards has been hybrid adhesives. Melamine or other scavengers have commonly been added. Melamine-urea-form aldehyde (MUF) is a promising technology
to meet CARB ATCM Phase II standards.

 CPA stated that research and attempts to achieve CARB ATCM Phase II have been centered around researching new adhesives/ feedstocks. Plant modifications (e.g., pollution control) may be necessitated by th e presence of different chemicals. The industry, as a whole, is not pursuing proce ss modifications in an attempt to achieve compliance; rather, modifications are made in response to changed feedstock materials.Memorandum June 18, 2009 Page 3

Changing the length of time a composite panel is subjected to the hot press is not a reasonable method to achieve compliance, because it requires additional energy and would likely overdry the pa nel and lead to warping.

 CPA stated that they are aware of multiple mills that have already achieved CARB ATCM Phase II compliance.

 CPA stated that ANSI standards for form aldehyde were recently updated and approved, and currently allow facilities to choose between CARB ATCM Phase I and Phase II standards for certification; however, the next ANSI standard is expected to limit certification to achieving Phase II standards.