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 Panel Association (CPA) 

at CPA headquarters in Leesburg, Virginia. The following ERG employees and CPA 

representatives were in attendance: 

Attendee: Affiliation: 

Thomas Julia CPA, President1

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 membership, the composite panel “value chain,” 

composite panel manufacturing processes, and industry 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 Institutional Furniture Manufacturer’s 

Association (BIFMA). 

 CPA recommended ERG contact the International Wood Products 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 manufacturers commonly sell both directly to 

distributors and directly to OEM facilities (if a bulk quantity is ordered). 

 CPA stated that major end uses of domestically manufactured composite panels include 

cabinets, store fixtures, and business and institutional furniture. CPA estimated that 70-

80% of the Business and Institutional Furniture Manufacturer’s Association (BIFMA) 

and Kitchen Cabinet Manufacturer’s Association (KCMA) members use composite 

panels manufactured domestically (in North America). 

 CPA estimated that the vast majority of the American Home Furnishings Alliance 

(AHFA) members use composite panels imported from overseas. CPA claimed that in 

response to the CARB ATCM, home furnishing companies have drastically reduced 

Asian imports; additionally though, many mills in China have become CARB-certified. 

 CPA stated that building construction-related end uses of particleboard (PB) include floor 

underlayments, manufactured home decking, and stair treads; these end uses account for 

approximately 4% of domestically manufactured PB. The remaining 96% is used in 

industrial (non-structural) applications. 

 CPA stated that there are no common building construction-related end 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 typically 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-added surfaces” include melamine lamination, 

veneer application, or painted surfaces. 

 CPA stated that the point in the composite panel manufacturing process where 

formaldehyde levels are highest is at the hot press; hot presses are typically enclosed, and 

the process is surrounded with controls utilizing very high air exchange rates. 

Formaldehyde Emissions Standards and Compliance

 CPA stated that the composite panel manufacturing 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-formaldehyde (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 the presence of different chemicals. The 

industry, as a whole, is not pursuing process 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 panel 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 formaldehyde 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.