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 GOVERNMENT OF

 THE UNITED STATES OF AMERICA

 + + + + +

 ENVIRONMENTAL PROTECTION AGENCY

 + + + + +

 FORMALDEHYDE STANDARDS FOR

 COMPOSITE WOOD PRODUCTS ACT

 PUBLIC MEETING

 + + + + +

 MONDAY

 APRIL 28, 2014

 + + + + +

 The Formaldehyde Standards for

Composite Wood Products Act Public Meeting met

in the Room 1153, 1201 Constitution Avenue,

N.W., Washington, DC, at 1:00 p.m., Cindy

Wheeler, Chair, presiding.

PRESENT

LYNN VENDINELLO, Chief, Fibers and Organics

 Branch, National Program Chemicals

 Division

CINDY WHEELER, Formaldehyde Rulemaking

 Workgroup Chair

LOUISE WISE, Deputy Assistant Administrator,

 Office of Chemical Safety and Pollution

 Prevention
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ALSO PRESENT

LYNN BAKER, California Air Resources Board

ROBERT CRINER, National Association of Home

 Builders

KIP HOWLETT, Hardwood Plywood and Veneer

 Association

TOM JULIA, Composite Panel Association

BROCK LANDRY, Federal Wood Industries

 Council

JACKSON MORRILL, American Chemistry Council

TOM NELTNER, National Resources Defense

 Council

BILL PERDUE, American Home Furnishings

 Alliance

KELLY SHOTBOLT, Flakeboard

CINDY SQUIRES, International Wood Products

 Association

RICHARD TITUS, Kitchen Cabinet Manufacturers

 Association
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 T-A-B-L-E O-F C-O-N-T-E-N-T-S

Opening Remarks. . . . . . . . . . . . . . . . 4

 Louise Wise, Deputy Asst Administrator

 Office of Chemical Safety

 and Pollution Prevention

Review of Recommendations on the

Treatment of Laminated Products. . . . . . . . 7

 Cindy Wheeler, Formaldehyde

 Rulemaking Workgroup Chair

 Lead, Heavy Metals & Inorganics

 Branch, National Program

 Chemicals Division

Stakeholder Presentations. . . . . . . . . . .15

Rulemaking Next Steps. . . . . . . . . . . . 112

 Lynn Vendinello, Chief

 Fibers and Organics Branch,

 National Program Chemicals Division

Adjournment. . . . . . . . . . . . . . . . . 113
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1 P-R-O-C-E-E-D-I-N-G-S

2 (1:00 p.m.)

3 MS. WISE: So welcome everybody,

4 and thanks for coming. And also for those of

5 you who are on the phone, appreciate you being

6 here. I'm Louise Wise. I'm the deputy

7 assistant administrator for the Office of

8 Chemical Safety and Pollution Prevention, and

9 we're here obviously to talk about our

10 proposed rule on the formaldehyde emission

11 standards for composite wood products.

12 And as you know, EPA has already

13 proposed two rules in June of 2013 to assure

14 that the composite wood products produced

15 domestically and imported into the United

16 States meet formaldehyde emission standards

17 that were established by Congress way back in

18 2010.

19 The emission standards contained

20 in the EPA's proposed rule are identical to

21 the emission standards currently in place

22 under the California Air Resource Board's,
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1 that's CARB's, airborne toxics control measure

2 as you probably already know. But other

3 provisions in EPA's proposed rule align to the

4 extent possible and practical with those

5 regulations, but as you also know EPA's

6 proposed rule covers laminated products,

7 certain laminated products, while California's

8 current regulations exempt them.

9 But as you'll hear shortly about,

10 California has proposed some changes to that

11 rule. We differed because of the statutory

12 requirements that we had which required us to

13 meet certain emission standards even for

14 laminated products. So the reason for

15 extending the comment period and inviting you

16 to talk to us has a lot to do with our

17 questions around those issues.

18 So we've reopened the public

19 comment period to provide you the opportunity

20 to comment on three things -- how the proposed

21 rule would address laminated products; comment

22 on CARB's potential modifications that would
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1 affect laminated products; and the public

2 comments we've already received on laminated

3 products.

4 So since it's our goal to

5 harmonize with California's regulations, EPA

6 is especially interested in your comments on

7 CARB's potential modifications to its

8 regulations.

9 That proposal, CARB's proposal,

10 was referenced in our Federal Register notice

11 announcing this meeting and included in the

12 public document, but we'll have staff

13 immediately following me talk briefly about

14 the CARB proposal.

15 In addition to the comments

16 received in today's meeting, you can still

17 submit comments to the public document on or

18 before May 8th, and the EPA will consider the

19 comments made today at this public meeting as

20 well as those submitted to the docket in

21 developing our final regulation.

22 So once again I just want to
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1 welcome you. We really appreciate you coming

2 here. This is an issue that we're really

3 concerned about and want to hear from you, so

4 thank you.

5 MS. WHEELER: I'll get what I'm

6 going to say out in front of me and put the

7 rest of this out of the way so I don't break

8 the microphone or something else horrible

9 happen, you know, I fall off the little

10 platform here and break something.

11 I'm Cindy Wheeler. I work in the

12 National Program Chemicals Division of the

13 Office of Pollution Prevention and Toxics, and

14 I'm one of the team of rule writers and other

15 professionals that we have working on this

16 issue. There's quite a large team. We have

17 economists. We have toxicologists. We have

18 a wide variety of people working on this.

19 So as Louise just said, laminated

20 products is quite possibly the biggest issue

21 that we're dealing with in this rulemaking,

22 and we understand that our proposal brought in
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1 a lot of people that are not currently covered

2 under the California regulations.

3 So it's a new sector of the

4 industry that would be covered, and so we want

5 to make sure that we do it in an appropriate

6 way while still taking into account the

7 protection of human health and the

8 environment.

9 So that's why we're having a

10 reopening of the comment period on this. We

11 got a variety of comments on this issue during

12 our public comment period last year, and in

13 fact California's also looking at making some

14 changes to their treatment.

15 I'm sorry, I should have said go

16 to the next slide.

17 So again just to reiterate, we've

18 got a court reporter taking down the comments

19 we're getting today and we will also be

20 entertaining any public comments submitted to

21 our docket on or before May 8th, 2014.

22 Well, I'm just going to keep
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1 talking. I'm not saying anything any of you

2 don't already know. So California's proposal,

3 California is actually here and they're going

4 to make a presentation at some point after I

5 finish speaking so I'm not going to go into a

6 lot of detail on their proposal, just that

7 they are considering establishing a

8 formaldehyde emission performance standard for

9 laminated products.

10 It would apply to unfinished

11 laminated products and would not affect any of

12 the other requirements already applicable to

13 fabricators under the California regulations.

14 Testing and certification would

15 not be required. It would be up to the

16 laminated products producer, the fabricator,

17 to determine how best to ensure that their

18 products meet the performance standard. And

19 they believe that making it applicable to

20 unfinished laminated products would make it

21 somewhat easier to perform testing in an

22 enforcement context.
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1 So like I said, California is

2 here. They're going to speak about this

3 shortly. We also got a variety of comments

4 and other suggestions from other interested

5 parties during our open comment period.

6 Many commenters thought that

7 laminated products should be exempt from the

8 definition of hardwood plywood, or if not they

9 should not be held to the same testing

10 requirements as hardwood plywood.

11 Another commenter suggested a

12 possibility of a self-certification option for

13 laminated products. We also had some comments

14 that we should consider excluding small

15 producers, custom shops and that sort of thing

16 from the testing and certification

17 requirements. One suggestion was companies

18 that produce less than 100,000 square feet of

19 product in a year.

20 We had some commenters suggest a

21 reduced testing frequency while still

22 maintaining third party oversight for
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1 laminated product producers. And we also had

2 some comments saying maybe a reduced testing

3 and limited or no third party certification

4 option for laminated products.

5 We got a variety of suggestions on

6 what standard would be appropriate for

7 laminated products. One commenter suggested

8 that because hardwood plywood is often

9 indistinguishable from laminated products the

10 hardwood plywood emission standard is

11 appropriate.

12 One commenter thought that the

13 particle board emission standard would be the

14 most appropriate standard. And one commenter,

15 while not offering a specific emission

16 standard, noted that in many cases laminated

17 products are not offered for sale.

18 They are intermediates. They are

19 then incorporated into finished goods, and

20 that our proposal did not provide any

21 recognition or credit for the reduction in

22 emissions that often happens when a product is
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1 laminated and finished.

2 So we are considering -- we

3 haven't made up our minds on this, that's why

4 we've reopened the comment period. So we're

5 considering a combination or any and all of

6 these such as California's latest proposal, a

7 reduced testing program, a self-certification

8 program, an exemption, or an exemption for low

9 volume producers. So we are, as I say,

10 considering any and all of those ideas.

11 So we would be particularly

12 interested in any comments you might have to

13 offer today or in writing to our docket on

14 what an appropriate production volume

15 threshold for testing and certification might

16 be.

17 Whether or not third party

18 certification is important or should be

19 required, what emission standard laminated

20 products ought to be held to, whether they can

21 and/or should be grouped for testing purposes,

22 and whether there are any associated
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1 definitional changes that might be needed

2 including potential changes to the definition

3 of laminated product such as expanding the

4 eligible platforms to cover the cores

5 identified in the definition for hardwood

6 plywood.

7 So we are interested in any and

8 all comments along those lines. Any other

9 thoughts you may have on laminated products we

10 would certainly appreciate it.

11 And I really appreciate again all

12 of you being here. As Louise said, it's very

13 important that we hear from as many people as

14 we can on this particular subject. So thank

15 you again. And I will turn it over to Robert,

16 also on the team, for just some logistics and

17 to go over the agenda. Thank you.

18 MR. COURTNAGE: Hello everyone.

19 As Cindy mentioned, I'm also on the team

20 working on this rulemaking. And I just wanted

21 to go over some of the logistics from this

22 point forward with the meeting. We're going
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1 to have the stakeholder presentations.

2 Just to let you know where the

3 restrooms are, because it's somewhat

4 complicated on the first floor, if you go out

5 to the left and then to the right there's a

6 women's restroom. If you go out to the right

7 and then all the way to the left there's a

8 men's restroom.

9 For the presentations we ask that

10 you keep it to ten minutes so everyone has

11 enough time to speak. We'll remind you. When

12 you're getting close to the end of your

13 presentation we'll hold up a little one minute

14 left sign.

15 We plan to have some time after

16 everyone has spoke to have a Q&A session for

17 questions for either the presenters or for

18 EPA. After that Lynn Vendinello will give

19 some closing remarks and some next steps.

20 I wanted to note that because we

21 have an open comment period we're going to be

22 limited in what we can talk about. We can
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1 answer clarifying questions regarding the

2 rulemaking, but we're not going to be able to

3 discuss options that we're preferring at this

4 point based on information that we have to

5 date.

6 So our first speaker is Lynn Baker

7 of CARB.

8 MR. BAKER: Well, it's a great

9 opportunity to be here and speak with you on

10 your coast. We've seen all of you so many

11 times in our offices in Sacramento, so we

12 appreciate the opportunity to participate in

13 this meeting and see familiar faces closer to

14 your home front instead of out in the

15 provinces of California.

16 So I wanted to make a few remarks

17 just for the purposes of the record in terms

18 of the background of what got us to here and

19 then comment on our proposal, and then some

20 comments that we have on some of the other

21 proposals that have been put forth with regard

22 to laminated products.
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1 So when Sarah's ready I'm ready

2 for the second slide. There we go. Thanks.

3 And actually you can just go ahead to the next

4 slide, Sarah. And you can go on. Next one.

5 Okay. Well, no, not that far. There. There

6 we go, thank you.

7 So just for the purposes of

8 catching everyone up to how we got here, we

9 developed an airborne toxic control measure in

10 2007 that was adopted in 2008 into

11 California's code of regulations.

12 And actually I beg to differ with

13 Ms. Wise. Actually we do not exempt laminated

14 products. We do regulate laminated products.

15 They're required to have compliant cores or

16 compliant platforms. So any fabricator that's

17 making laminated products, they're required to

18 use a compliant core regardless of whether

19 it's a wood veneer or synthetic laminate.

20 Now, next slide. Okay. So our

21 reasons for proposing amendments to our

22 current approach to laminated products, we had
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1 committed when we developed our regulation to

2 look at laminated products. It was something

3 that we came up with actually after we went to

4 our board.

5 It was a way of addressing the

6 product. We had talked with a lot of industry

7 folks, and we came up with this option for

8 dealing with laminated products really without

9 any testing data.

10 So over the course of since 2008

11 we have conducted a number of studies of

12 laminated products. We've worked as many of

13 you know with American Home Furnishings

14 Alliance. Several furniture manufacturers

15 provided laminated products to us and we

16 tested a lot of these products.

17 And the data told us that there

18 were opportunities to have additional

19 formaldehyde reductions if we approached this

20 in a different way. Because we found some of

21 these wood veneered laminated products to be

22 quite high emitting, not all but some.
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1 So our amendment, or our proposed

2 amendment is part of a broader approach to

3 amending our regulation. We wanted to clean

4 up some inconsistencies, tighten up a few

5 requirements, and the laminated products is

6 one of those.

7 We proposed something last year,

8 we workshopped it and then we heard from many

9 of you. And so we've adjusted our proposal

10 and that was released at a workshop we had

11 back last month. So that's what I'm going to

12 talk about today. So next slide.

13 So as Cindy mentioned, I'll just

14 kind of reiterate. Our proposed amendment is

15 to establish a new formaldehyde emissions

16 standard for wood veneered laminated products.

17 Now the standard is 0.13 ppm which would be

18 for unfinished, so no coating, no varnish.

19 Unfinished laminated products that consist of

20 a wood veneer affixed to a compliant platform.

21 All the other requirements for

22 wood veneered laminated products would be the
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1 same as they currently are, same labeling

2 requirements, same requirement to use a

3 compliant platform.

4 Now we are not proposing any

5 routine quality control testing or third party

6 certification requirements. The fabricators

7 would determine the best way to ensure

8 compliance. This is patterned after our very

9 successful consumer products program.

10 In California we have a regulation

11 that's been in effect for many years to reduce

12 VOC or volatile organic compound emissions

13 from consumer products to reduce precursors to

14 photochemical smog.

15 The producers of all these

16 consumer products whether they be aerosol

17 hairsprays, deodorants, consumer pesticides,

18 do not have to do any testing, but there is a

19 standard VOC limit that those consumer

20 products have to meet.

21 And if they don't meet it, if we

22 test them and we find that they're exceeding
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1 that limit they will get a violation. But

2 they are not required to test their products.

3 And so we patterned our proposed amendment

4 after that.

5 Again a fabricator then would have

6 to determine their best way to ensure that

7 they are compliant. So if that's using a very

8 low emitting platform and they know they're

9 using a low emitting glue to adhere the wood

10 veneer, they can be confident that they're

11 going to be below the 0.13, they don't need to

12 do any testing.

13 If they're wanting to cut it a

14 little closer, they may want to do some

15 testing but no testing is required. And ARB's

16 compliance would be the check on that. Our

17 field staff that go out, pick up samples,

18 bring them back to our lab would help to

19 ensure compliance. Next slide.

20 The requirements for synthetic

21 laminated products do not change. They still

22 would need to have compliant platforms, still
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1 need labeling. We've also, just to try to

2 alleviate any confusion we've added

3 definitions of coatings and finishes, coatings

4 and synthetic material to our amendments to

5 help everybody understand what those are. So

6 in terms of -- sorry. Next slide, please.

7 So the basis for our proposed

8 amendment is the highest Phase 2 emissions

9 standard that we have which is for thin MDF.

10 That standard, the Phase 2 standard is 0.13

11 parts per million, so that's the basis for

12 this laminated products standard.

13 So that we're trying to ensure

14 that no wood veneered laminated product would

15 emit more than that platform material, which

16 in the worst case would be the thin MDF.

17 This approach treats laminated

18 products differently than hardwood plywood.

19 The big difference of course being that

20 there's no third party certification.

21 If there was a way to require

22 third party certification universally that
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1 might be something that we could consider.

2 But we have thought about this, talked to

3 industry folks, and we just do not believe

4 that there is sufficient third party certifier

5 or laboratory capacity for the tens of

6 thousands of fabricators worldwide that would

7 be affected by this. So that's why we're not

8 requiring or proposing to require third party

9 certification. Next slide please.

10 Benefits. The benefits of the

11 proposed amendment are that it establishes a

12 ceiling and achieves additional emission

13 reductions beyond our current regulatory

14 approach, where there's no limit to what some

15 of these wood veneered laminated products can

16 emit.

17 It's performance based. We are

18 not dictating what resins must be used to

19 affix the wood veneer. Someone can still use

20 a urea-formaldehyde resin if they can tweak it

21 so that they don't exceed the 0.13 level. And

22 the proposed amendment minimizes economic
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1 burdens on small businesses.

2 Applicability. Who's subject to

3 this standard? So any fabricator of a

4 component part, whether that may be a door

5 face or a cabinet door or a whole finished

6 good, would have to comply with this if

7 they're making a laminated product.

8 If we find in commerce a laminated

9 product that's been made by a fabricator and

10 it's being sold in bundles at a distributor or

11 retailer, we would view that as a piece of

12 hardwood plywood and we would say no, this is

13 not appropriate, this has to be third party

14 certified.

15 So this has to be made by a

16 fabricator that's making a finished good. If

17 it's mass panels being sold we would say, no,

18 that's got to be third party certified. Next

19 slide.

20 This is the brunt of what I wanted

21 to say, and this is the limitations of some of

22 the other approaches that have been shared.
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1 Again third party certification of all

2 fabricators has been proposed. We don't think

3 it's feasible. We just don't believe there

4 are enough global laboratories or testing

5 facilities to conduct all of this testing if

6 third party certification were to be required.

7 In addition, third party

8 certification would be very costly for small

9 businesses. Some have put out the idea, well,

10 maybe you have a minimum cutoff. And if

11 producers produce below 100,000 square feet

12 per year or per month that they wouldn't have

13 to comply, but only people above that would

14 have to comply.

15 That's very difficult to enforce

16 especially for international products. We

17 encounter a product in the market, we don't

18 know. Our enforcement staff don't know if

19 that company had produced more or less than

20 100,000 square feet. So we don't see that as

21 workable.

22 Requiring limited amounts of
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1 testing such as one test per year, we think,

2 has very little value. In fact, we think it

3 could be misleading. On the one hand a

4 regulatory agency, I think, could look at

5 this, whether it's us or U.S. EPA, and think,

6 well, they've conducted one test.

7 They've shown that they can

8 achieve the 0.13 level, but that doesn't say

9 anything about what they do the rest of the

10 year. They could change their resin

11 formulation the rest of the year.

12 We think the onus is on the

13 fabricator to make sure they are consistently

14 achieving this level, and achieving it once

15 for a test we think has very little value.

16 It's also misleading for the

17 company. The company might be misled to

18 think, well, I passed the 0.13, I'm good for

19 the rest of the year, and slow up on making

20 sure that they're really attaining it.

21 If we were to enforce something

22 and they showed us a piece of paper that had
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1 a test result of less than 0.13 thinking that

2 oh, we're good for the whole year, no. It

3 would still be a violation if it's above 0.13.

4 So we think a one test would be misleading.

5 Specifying resins, I already

6 mentioned, we think is not performance based.

7 We think it's better to allow the flexibility.

8 And finally, status quo, doing nothing doesn't

9 achieve any additional emission reduction

10 benefits.

11 So in closing, final slide. We

12 would suggest to EPA that they adopt our

13 suggested requirements for these wood veneered

14 laminated products. We would suggest to EPA

15 that they adopt the requirements for laminated

16 products that we've proposed, but we know a

17 lot of you have other perspectives and we

18 along with EPA will be interested to hear your

19 thoughts. So thank you for your attention.

20 MR. COURTNAGE: Thanks Lynn. Our

21 next speaker is Kip, and Kip do you want to

22 just sit right there or do you want to turn
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1 around or -- okay.

2 MR. HOWLETT: I'm Kip Howlett,

3 president of the Hardwood Plywood and Veneer

4 Association, and let the record show that I'll

5 go to any extreme to gain sympathy and

6 attention. Next slide. There you go, the

7 next one. The next one. Okay.

8 Hardwood plywood is veneer on a

9 platform and that platform can be veneer core,

10 particle board, MDF. Over 90 percent of

11 whether a paneling or fabricator manufacturer

12 are basically constructing hardwood plywood on

13 one of those three cores.

14 They can be lumber core,

15 combination cores, or other special cores, but

16 they're a small minority of overall

17 production. ANSI/HPVA HP-1 has defined

18 hardwood plywood as a national consensus

19 standard since 1932.

20 TSCA establishes one emission

21 standard for hardwood plywood, 0.05 part per

22 million. TSCA also established a ruling
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1 mechanism for a different compliance framework

2 for fabricators who manufacture hardwood

3 plywood. Next slide.

4 We support a compliance framework

5 for fabricators that is cost effective,

6 efficient, admittedly burdensome, but ensures

7 evidence of emission performance test data in

8 a compliance statement which can be enforced

9 under TSCA.

10 The identity of a manufacturer

11 must be known for enforceability. Because

12 CARB's rule is based on Clean Air Act

13 authority, the EPA regulation has to be

14 consistent with TSCA's legal framework. The

15 product itself is paramount and its possible

16 emissions to the outdoor ambient air. Next

17 slide.

18 Despite those distortions of

19 compliance costs, we suggested a minimum

20 testing requirement using tests to verify

21 emission performance, which is consistent with

22 the proposed rule and statutory framework.
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1 And a three-year phase-in period addresses the

2 capacity issue.

3 A signed compliance statement

4 provides an enforceable, legally binding

5 commitment for a fabricator manufacturer of

6 hardwood plywood to maintain compliance. Next

7 slide.

8 The statute has only one emission

9 level for hardwood plywood. To allow a

10 different emission level opens a host of

11 equity and, more importantly, enforcement

12 issues.

13 A two-level standard for the same

14 product is not consistent with TSCA. To allow

15 a different emission standard means a consumer

16 can be exposed to the lowest emission level

17 from the product, 0.05 part per million, and

18 the highest emission level, 0.13 part per

19 million, but both of those would be identified

20 under the CARB proposal as, if EPA were to

21 adopt it, EPA/TSCA compliant. That outcome is

22 not TSCA consistent and consumers should
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1 beware.

2 Also, with a 0.13 part per million

3 emission standard for hardwood plywood it

4 would be virtually impossible to enforce the

5 use of compliant cores of veneer core, 0.05

6 part per million, particle board or MDF, 0.08

7 part per million, because a fabricated

8 product, furniture or a kitchen cabinet, would

9 have a 0.13 part per million limit and simply

10 claim that all of the company's compliance

11 were internally manufactured.

12 Now on what basis would an

13 enforcement agency have reasonable cause to

14 pursue a fabricator to ensure that purchased

15 platforms were TSCA compliant when that

16 standard would be 0.13 part per million?

17 This approach eviscerates the

18 whole basis of fabricators using compliant

19 cores. Congress did not intend the regulation

20 of fabricators that had no specific testing or

21 proof of performance requirements.

22 Different emission levels at the
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1 highest emission rate indicate enforcement

2 action could be brought. This is exactly the

3 CARB proposal and that approach is legally

4 inconsistent with TSCA. It's an enforcement

5 charade and consumers are put at higher risk

6 with no means to differentiate exposure

7 emission rates. Thank you.

8 MR. COURTNAGE: Okay, the next

9 speaker is Bill Purdue, with the American Home

10 Furnishings Alliance.

11 MR. PERDUE: Good afternoon. I'm

12 Bill Perdue, vice president of regulatory

13 affairs for the American Home Furnishings

14 Alliance. The AHFA is the world's largest and

15 most influential trade association serving the

16 home furnishings industry.

17 AHFA's more than 400 member

18 companies operate numerous domestic wood

19 furniture manufacturing facilities, and

20 comprise an extensive global supply chain that

21 provides a wide variety of home furnishings to

22 the American consumer.
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1 Our member companies are part of

2 an industry sector that provides approximately

3 100,000 manufacturing jobs throughout the U.S.

4 and represents a $35 billion segment of the

5 nation's economy.

6 If the proposed rule is finalized

7 without changes, we estimate over a million

8 manufacturing jobs in the home furnishings and

9 related industries will be impacted.

10 The AHFA was pleased to learn that

11 EPA is considering a modification to the

12 proposed treatment of laminated products and

13 welcomes the opportunity to provide comment on

14 the issue before the agency during today's

15 public meeting.

16 As proposed, this rule

17 fundamentally changes the established

18 formaldehyde emissions certification model

19 created in California and now practiced by the

20 entire home furnishings industry.

21 Moreover, the end result of the

22 EPA's proposal was never envisioned or
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1 intended by the congressional sponsors of the

2 legislation. The extension of certification

3 beyond a raw panel and encompassing an

4 additional recertification requirement on

5 fabricators of laminated products is the

6 single most costly and burdensome aspect of

7 the proposed rule.

8 This also represents the single

9 most significant departure from the approach

10 taken by the CARB ATCM. Congress defined the

11 term "laminated products" by statute, but

12 expressly provided EPA authority to amend this

13 definition and exempt laminated products from

14 the definition of hardwood plywood.

15 We believe that there is

16 sufficient industry and technical data to

17 warrant such an exemption. As drafted, this

18 rule would impose substantial, unwarranted new

19 cost on the supply chain with little or no

20 corresponding benefit.

21 Fabricators of laminated products

22 will face dramatically increased costs
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1 associated with certification testing,

2 effectively turning them into panel producers.

3 This additional point of certification

4 requires fabricators to recertify intermediate

5 laminated products already produced using CARB

6 Phase 2 compliant cores as if those

7 fabricators were the original manufacturer of

8 the composite wood panels.

9 Further, this recertification

10 occurs before the component parts are

11 finished, an evaluated process that further

12 improves the emission characteristics of an

13 already certified core. This finishing

14 process has proven to vastly reduce

15 formaldehyde emissions.

16 AHFA submitted to the docket three

17 definitive studies that clearly demonstrate

18 that the value added process of finishing

19 further reduces the emission characteristics

20 of an already certified composite wood product

21 by at a minimum 80 percent.

22 In fact, the AHFA deconstructed
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1 study demonstrated a significant mean shift in

2 certified composite wood panels that are

3 finished in comparison to those same panels in

4 their raw, unfinished state.

5 This new certification requirement

6 for intermediate laminated products notably

7 alters the compliance obligation for

8 fabricators, globally, forcing them into

9 unrealistic component level certification

10 scheme that will require costly new equipment,

11 testing, and personnel.

12 The impact of this component level

13 certification will dramatically affect

14 manufacturing and provide no environmental

15 health benefit. This definitional change

16 ignores the evidence that costs incurred by

17 the furniture industry to prove and defend

18 compliance does not represent an increased

19 reduction in emission nor an increased health

20 benefit to the consumer.

21 The furniture industry will

22 shoulder the burden of an estimated $210
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1 million in new compliance cost. The rule as

2 drafted disregards the legislative mandate to

3 evaluate laminated products by ignoring

4 available and published data demonstrating

5 that finished products dramatically reduce the

6 emission profile of laminated products used as

7 component parts of finished goods.

8 As proposed, the rule offers no

9 improvement in emission performance for

10 finished goods, but requires fabricators to

11 absorb significant testing and certification

12 costs for a product that by itself is not

13 offered for sale. Once finished and assembled

14 into a final product there is no benefit to be

15 gained with further testing or regulation.

16 As a member of the Federal Wood

17 Industry Coalition, or FWIC, AHFA is on record

18 in support of the latest CARB proposal as an

19 appropriate alternative to the approach

20 currently proposed by EPA, and we reiterate

21 that support today.

22 However, this approach fails to
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1 completely recognize that the regulation of an

2 intermediate product is incongruent and not

3 representative of the finished product. We

4 respectfully request that EPA exercise its

5 authority and exclude laminated products from

6 the definition of hardwood plywood.

7 The application of a wood-faced

8 veneer over a certified and compliant

9 composite wood product platform or core should

10 not be subject to additional testing.

11 This is a reasonable approach to

12 regulating the industry that relies on

13 engineered wood products and satisfies the

14 intent of Congress while maintaining the

15 integrity of the rule.

16 We thank you for the opportunity

17 to participate in this public meeting and we

18 look forward to continued participation in the

19 process. Thank you.

20 MR. COURTNAGE: Thanks, Bill. Our

21 next speaker is Tom Julia, the Composite Panel

22 Association.
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1 MR. JULIA: Thank you. My name is

2 Tom Julia, president of the Composite Panel

3 Association, CPA, the trade association that

4 represents about 95 percent of the production

5 of particle board, MDF, and hardboard in North

6 America.

7 As such, we represent two of the

8 three major regulated products in this

9 rulemaking. We also represent most of the

10 laminators and surface coating manufacturers

11 that put things on our products. Most

12 adhesive suppliers, a good number of other

13 suppliers, as well as major customers. So we

14 have a lot at stake in this rulemaking and we

15 have a lot of experience in this rulemaking.

16 We also operate, separately funded

17 and managed, the International Testing and

18 Certification Center and the Grademark

19 Certification Programs, which are the largest

20 and most stringent such programs administered

21 in North America for industry products.

22 We've been at this for decades,
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1 and indeed much of the CARB model for quality

2 assurance and certification is based on the

3 CPA approach. CPA's been deeply involved in

4 the CARB rulemaking and the EPA rulemaking

5 from the inception.

6 While such matters are by nature

7 adversarial, and we appreciate that, I think

8 our efforts, I hope our efforts have been

9 characterized by an effort to be collaborative

10 and cooperative and constructive at all times.

11 And so it's why I'm particularly

12 pleased to be here with all of you and with

13 the staff of EPA and CARB to once again

14 discuss these rulemakings and in particular

15 laminated products issue.

16 I'm also pleased because most of

17 the industry is of a like mind not only on a

18 laminated products issue but on most of the

19 issues that remain in this rulemaking, both

20 with ARB and CARB.

21 And that's no simple task. It

22 didn't come accidentally, it came by design.
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1 It came by design because from its inception

2 industry formulated a group first called the

3 California Wood Industries Coalition, and

4 later when the EPA rulemaking was initiated,

5 the Federal Wood Industries Coalition, where

6 some 15 or more trade associations, in fact,

7 almost all the major trade groups with an

8 interest in this regulation come together to

9 address the issues of common concern and

10 hopefully bring forward a credible voice to

11 the EPA and to ARB.

12 I also want to note, and

13 particularly with a colleague here in the room

14 who will speak later, Tom Neltner, that I

15 still remember just a handful of years ago

16 when Tom and I sat down and actually

17 contemplated the possibility of getting a bill

18 through Congress whereby we could establish a

19 national standard for formaldehyde emissions.

20 A lot of people thought that was

21 far-fetched at the time, but a lot of people

22 couldn't understand how a coalition like that
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1 could be put together to get a bill through

2 Congress. But thanks to Tom, your hard work,

3 the hard work of your allies and the hard work

4 for which I'm also appreciative of, of many,

5 many colleagues in this room including the

6 HPVA and others, we did get that national

7 standard through Congress and it is the reason

8 we're all here today.

9 I think that's important, because

10 when we think about why we're here narrowly

11 today on laminated products, never, ever, was

12 it contemplated that this was a standard on

13 finished products, only raw products.

14 Indeed, any discussion of

15 laminated products and how to best promote

16 their compliance with the letter and spirit of

17 the CARB and EPA regulations should consider

18 why we worked on these regulations for so many

19 years.

20 Might there be shared objectives

21 that even those who see laminated products

22 issues differently can agree upon? I think
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1 so. And it is these overarching objectives

2 that should matter most to the EPA as it

3 decides the issues around laminated products

4 and completes its rulemaking. And indeed as

5 CARB completes its rulemaking amendments as

6 well.

7 Simply put, a national standard is

8 good for public health, it's good for the

9 American consumer, it's good for responsible

10 manufacturers who want to expand the markets

11 for composite panel products and for whom

12 consumer confidence in these products matters.

13 It's also a way to mitigate the

14 production and sale in the United States of

15 products that operate outside the bounds of

16 accepted industry practice and regulatory

17 requirements. It says to the bad actors, you

18 are not welcome here, and I think that's a

19 very good thing.

20 CARB is implementing a rule that

21 is working. Yes, it needs refinements, and

22 yes, CARB has taken the initiative to propose
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1 amendments. But let's remember, the CARB rule

2 is the toughest production standard of its

3 kind in the world for composite panel

4 products, and in just a few years it has

5 become the de facto global standard, even

6 though it only applies in California.

7 Composite panel emission levels

8 are down. Innovative low emitting adhesive

9 systems abound. CARB approved third party

10 testing and certification is now available

11 almost everywhere in the world, and

12 responsible companies all over the world have

13 made major investments in technology and

14 choices in sourcing to abide by the CARB rule

15 and showcase the compliance of their products.

16 What EPA can do now is make things

17 even more uniform, better, and enforceable,

18 especially if the directives of Congress are

19 followed and the final EPA and CARB rules read

20 exactly the same, are implemented on exactly

21 the same date, and are enforced fairly and

22 rigorously.
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1 What EPA should not do today is

2 seek a major expansion of the CARB rule that

3 will not result in appreciably more compliant

4 products in the marketplace, and that instead

5 will cause massive economic hardship to

6 industries already doing the right thing.

7 EPA should not take what is a

8 standard for raw product emissions and morph

9 it into one that also addresses coatings and

10 finished products.

11 That is not the standard that

12 Congress contemplated. That is not the

13 standard that a coalition proposed. And that

14 is not the standard that CARB is implementing

15 today.

16 To do anything more than what CARB

17 has proposed in its amendments to the

18 laminated products provisions of this rule

19 will result in a Don Quixote-like illusory

20 gain.

21 What will not be illusory however

22 is the loss of thousands more American
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1 manufacturing jobs in the furniture and other

2 industries and a further shift to offshore

3 sourcing.

4 What is not illusory is that

5 neither CARB nor EPA nor any other agency is

6 prepared to monitor and manage the compliance

7 of tens of thousands of companies around the

8 world that make products encompassed in the

9 laminated products provision. Most of these

10 are very small businesses even here in the

11 United States.

12 And what is not illusory is that

13 the third party testing and certification

14 system in existence today around the world

15 would have to expand exponentially to manage

16 the products that would be swallowed up in

17 this regulatory approach proposed by EPA a

18 year ago, or even one that goes substantially

19 beyond what CARB has proposed now.

20 In "A Tale of Two Cities" Dickens

21 wrote, "It was the best of times. It was the

22 worst of times. It was the age of wisdom. It
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1 was the age of foolishness." Then you've

2 heard me say this before.

3 Today, EPA has the opportunity to

4 complete a rule that will advance the public

5 interest and do something highly constructive

6 for American consumers, and one that industry,

7 the environmental community, organized labor,

8 the health care community and others can all

9 get behind.

10 You can act with wisdom to

11 promulgate well-considered rules to implement

12 the national standard on formaldehyde

13 emissions, rules that incorporate what CPA and

14 FWIC and others have recommended to you on a

15 variety of topics and which we now recommend

16 to you on laminated products.

17 By doing so you will make this a

18 better, fairer, more pragmatic and more

19 enforceable rule. I urge you to focus on

20 enforcing what is already in this rule with

21 the changes recommended by CWIC, CPA, FWIC and

22 CARB.
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1 You do not need to expand the

2 regulation of laminated products to have a

3 rule that already meets your threshold

4 objectives. You're already there. Thank you.

5 MR. COURTNAGE: The next speaker

6 is Kelly Shotbolt of Flakeboard.

7 MR. SHOTBOLT: Good afternoon. My

8 name is Kelly Shotbolt. I'm the president of

9 Flakeboard. We're the oldest surviving

10 composite panel manufacturer in North America,

11 having started in 1960, and today we're the

12 largest producer of these products in North

13 America.

14 We have eight such facilities, six

15 of which are here in the United States. We're

16 owned by a Chilean company called Arauco, and

17 Arauco has a similar sized footprint in South

18 America producing these products in Chile,

19 Brazil, and in Argentina.

20 And together with our South

21 American group we are now the second largest

22 producer of composite panels worldwide. So we
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1 have also a stake in what's going on here

2 because it certainly, it doesn't just affect

3 us in the West, but in our global activities.

4 In these global activities we

5 produce fin-MDF, HDF, MDF, particle board,

6 softwood plywood. We finish those panels with

7 paint and print. We laminate with papers and

8 foils and melamine and other materials.

9 We sell to retailers,

10 distributors, cabinet shops, furniture

11 manufacturers, store fixture manufacturers.

12 We sell to the molding companies, and of

13 course to the laminators of all kinds

14 including those that affix veneer.

15 This year I have the pleasure of

16 serving as the CPA chairman and I've been part

17 of that CPA leadership now for over 17 years.

18 So together with Tom Julia, who you just heard

19 from, I also represent the broad industry, 95

20 percent of the producers, as Tom already

21 commented on.

22 I'd like to first just make some
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1 comments on the state of the industry. And I

2 realize that EPA's primary consideration is

3 not economic, but I think some context in this

4 regard is helpful.

5 When I first started in this

6 business some 35 years ago, most of the

7 furniture that was consumed here was made in

8 North America. Actually, most of it was made

9 in the U.S. in the furniture belt of Virginia

10 and North and South Carolina.

11 About year 2000, 50 percent of the

12 furniture that's consumed here was being

13 produced offshore. Today, 72 percent of all

14 the wood furniture that's consumed in this

15 country is produced offshore.

16 Now as furniture manufacturing

17 started to shift, some shifted their model.

18 We have people in the audience here that have

19 a very, you know, a very strong model of

20 manufacturing and importing, but the vast

21 majority of the furniture industry just shut

22 down. And they closed up their doors and the
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1 statistics will bear that out.

2 So in our industry, and I'll take

3 one of our products, particle board, our

4 shipments today are about 50 percent of what

5 they were in their heyday. And so in sympathy

6 to our customers who have closed their doors,

7 we have been shutting mills down too. Some 20

8 industry mills have shut down in the last ten

9 or 15 years, affecting dozens of communities,

10 thousands of workers.

11 So with these pressures how have

12 we interacted with you the regulators or with

13 the environmental community? I think it's

14 fair to say that we've worked as cooperatively

15 as we possibly could even under the pressures.

16 And we've tried to be super17 constructive and work with CARB to develop, as

18 Tom said, the de facto global standard for

19 these kind of products, you know, and

20 something that our company was behind,

21 continues to support, and embraced right from

22 the very outset.
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1 We didn't engage in the typical

2 adversarial approach with the regulators and

3 the environmental community. We thought we

4 would take a different approach. We felt that

5 we could improve and we wanted to improve, but

6 we wanted to do it in an open and

7 collaborative spirit.

8 Personally, this is my second time

9 testifying here. I did earlier when we were

10 first approached EPA with the idea of

11 federalizing this particular rule.

12 It's a standard, however, that

13 while it's technically feasible to achieve, as

14 evidence by those of us that achieve it, it's

15 more expensive. Our productivity levels have

16 gone down. We need to use more expensive

17 resins. The compliance testing is expensive.

18 And it is just flat out miserable to achieve

19 each and every day.

20 And we found that out this winter

21 when, you know, we have to have extremely

22 tight operating conditions to meet these
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1 standards, and here we were faced with

2 unprecedented climatic conditions, and we were

3 running stock and inventory all the time in

4 quarantine because we weren't sure, our world

5 had shifted just that little bit and we lost

6 control and we found ourselves in a bind.

7 Just to let you know, this is

8 tough. Now we're a large company. We're one

9 that's made substantial investments in

10 laboratories and equipment and in people,

11 laboratory technicians.

12 We've configured our information

13 systems so that we can locate all the product

14 that's been made. We've got a traceability

15 system so that in the extreme case that

16 product gets into the field we can find it and

17 we can recall it back.

18 Now I just want you to think for a

19 minute what that will be like for our

20 customers, some of which are quite small.

21 Could they even begin to replicate that the

22 rigor of such a, it's such a tough rule that
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1 we've been dealing with.

2 The reality is that that 20

3 percent or 28 percent of that wood-based

4 furniture that's still produced in this

5 country, a big piece of that's going to leave.

6 It will have to.

7 Understand that the wage rates

8 here that are necessarily high to support, you

9 know, our workers' lives are a multiple higher

10 than they are in the other furniture producing

11 jurisdictions, in China and Cambodia and

12 Vietnam.

13 And so as this rule goes in effect

14 globally and to the extent that people embrace

15 it, it will be much less expensive to follow

16 and to adhere to in other parts of the world.

17 You know, industry produces about

18 six billion feet of product. All of it's

19 finished. Nobody buys a piece of particle

20 board for a piece of particle board. They buy

21 it because it is engineered to be finished,

22 painted or laminated or having veneer fixed on
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1 it.

2 So that's really the business

3 we're in. The difference is we're panel

4 producers. We can take the cost and the rigor

5 of this rule. Our customers cannot. They

6 can't handle the burden that this will put on

7 them.

8 And I do understand that there's

9 improvements that can be made by the EPA to

10 this rule and that makes great sense. And I

11 certainly applaud the work that's been done by

12 the EPA in an effort to tighten up those rules

13 and particularly in the area of the

14 reliability and credibility of third party

15 testing. I think these are advances that will

16 serve us well.

17 But I really do want to bring

18 focus on the importance of the EPA getting

19 this rule right. I want you to know that

20 Flakeboard supports the approach to laminated

21 panels that CARB has proposed.

22 It truly has deeply considered as
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1 we've heard today the affected and interested

2 parties including those at EPA. It's fair and

3 balanced. It's enforceable. It recognizes

4 those companies that are true panel producers,

5 like we are, and those companies that aren't.

6 So for all these reasons, I

7 respectfully request that the EPA reconsider

8 its original position and that you adopt the

9 approach to laminated panels that's endorsed

10 by CARB, by our association at the CPA, by the

11 American Home Furnishings Association and so

12 many others. Thank you.

13 MR. COURTNAGE: Thank you, Kelly.

14 The next speaker is Dick Titus with the

15 Kitchen Cabinet Manufacturers Association.

16 MR. TITUS: Thank you. I

17 appreciate the opportunity to come before you

18 and address the proposed regulation. I think

19 we have been working together for a long time,

20 particularly CARB and at EPA. I think we know

21 many of the folks in the audience.

22 Just as a real quick snapshot,
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1 KCMA is the major national trade association

2 for manufacturers of kitchen cabinets and bath

3 vanities. Our members probably account for

4 approximately 70 percent of the market in the

5 U.S. of those products.

6 I think it is interesting to note

7 that about 60 -- well, probably about 60

8 percent of our members report sales of under

9 $10 million. So we have some larger members,

10 we have small members, and then beneath that

11 number there are thousands of small custom, we

12 call them custom shops, most of whom employ

13 fewer than 20 employees.

14 They're very local and regional in

15 their sales and distribution, and we have a

16 few of those in our membership. The Cabinet

17 Manufacturers have about 170 in number.

18 But the potential impact of the

19 regulation on these small businesses could be

20 literally horrific, and I am pleased to see

21 the consideration that both CARB and EPA are

22 giving to that segment.
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1 And I would also compliment both

2 CARB and EPA for their very serious efforts to

3 harmonize the two standards. And I know that

4 is a rigorous endeavor. It's been kind of

5 interesting for us to observe and be part of

6 that whole process.

7 But the openness and the

8 willingness to consider our concerns and the

9 interest that we have has really been very

10 rewarding and very encouraging. So I would

11 compliment very much.

12 I think I told Lynn Baker at their

13 last open meeting they had that they may have

14 come up with, they might have cut the Gordian

15 knot in this very, very difficult laminated

16 products discussion.

17 And as you know, many other

18 organizations and interests have weighed in on

19 this. The Small Business Administration

20 advocacy has been a lead for the small, a

21 voice for the small business side, and most of

22 what they've done support very much what FWIC,
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1 which you will hear more about from our

2 attorney a little later. But again we support

3 what CARB has proposed and is considering, and

4 we encourage EPA to very much adopt that

5 approach.

6 Actually we have been looking for,

7 have requested in our comments, which also

8 it's apparent have been closely reviewed and

9 even in this announcement we could see many of

10 our concerns being reflected and seeking

11 further information, and we do appreciate

12 that.

13 We're still of the opinion that

14 there should be an exemption for laminated

15 products regulation of some sort, particularly

16 in our case, raised panel doors which are not

17 making plywood, use a totally different

18 technology. We submitted some technical data

19 on that which we hope will be listened to and

20 adhered to by EPA.

21 But we do think that that is

22 something that still needs to be brought to
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1 your attention. We think that, well, it's

2 interesting we've had this discussion about

3 trying to find a production cap, and we

4 understand the concerns that EPA has in

5 enforceability.

6 I might add that not only our

7 concern that there's not enough labs to do the

8 kind of testing that was required in the

9 original, and I think there's some general

10 understanding of that that's becoming

11 apparent, but that we think that having a

12 level of 100,000 square feet a year, and that

13 we originally suggested 125,000 a week, and

14 that's a pretty broad difference.

15 I would tell you that we think

16 125,000 is too high. We also think 100,000

17 per year is probably too low. We still maybe

18 could have some fruitful discussion of some

19 other level. But we think it is something

20 that is worthy to be found in the final

21 regulation.

22 I think an important one for us
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1 again is to encourage EPA to support

2 performance based formaldehyde emission

3 requirements for composite wood panel products

4 without bias toward any resin or manufacturing

5 technology employed to meet those

6 requirements, and that gets us into the ULEF

7 and NAF issue. And again, most of my comments

8 are reflected in the original comments that we

9 submitted.

10 Well, again, I don't want to be

11 too redundant, save some time. We do not

12 think additional testing should be required

13 for the reasons that were very well presented

14 earlier. We think that that is true.

15 I would also tell you that for the

16 last four years we've had an ongoing

17 environmental stewardship program and for the

18 last three years we've required that all

19 composite wood used by any of those attaining

20 such certification has to be CARB 2 compliant.

21 So I think, and we check the

22 records on sales or purchases and it has to
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1 match up. We have a rigorous requirements and

2 standards that are in place. It is working

3 and it reflects the CARB requirements.

4 We would suggest to EPA that we

5 could provide further information on that, but

6 we think it's been working, is working, and is

7 something again worthy of strong consideration

8 by EPA.

9 Again, we support the comments and

10 the efforts of FWIC to achieve an industry

11 consensus position and we appreciate again the

12 opportunity to present. Thank you.

13 MR. COURTNAGE: The next speaker

14 is Cindy Squires and/or Joe O'Donnell of

15 International Wood Products Association.

16 MS. SQUIRES: Thank you. I'm

17 Cindy Squires. I'm the executive director for

18 the International Wood Products Association,

19 and I represent the importers of wood and wood

20 products as well as the domestic and foreign

21 manufacturers of those products and the trade

22 facilitators for that system.
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1 IWPA is not a testing organization

2 so we will derive no revenue from additional

3 testing that may be required by the EPA or the

4 CARB proposal, and as a result of that we do

5 have a little bit of a different viewpoint.

6 However, we do want to make sure

7 that any program that is put forward is

8 workable regardless of what tests or process

9 may be done.

10 We are very happy to have been a

11 participant in the FWIC coalition, and we have

12 three major items that we thought would be

13 helpful to bring forward to this group from

14 the importer perspective.

15 First of all, from our perspective

16 we think that no matter what happens between

17 EPA and CARB there should definitely be an

18 effort to minimize the economic impact on the

19 affected industries, and that is a global set

20 of industries.

21 And the critical part of that

22 effort is to make sure that these programs are
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1 substantially the same. The second that we

2 have any changes between the two different

3 programs it becomes that much more complex to

4 be able to comply with it. And that gets, I

5 think, often when you look at a global

6 environment it makes it even more difficult

7 for people to comply.

8 Second, we want to make sure that,

9 you know, we're really recognizing that the

10 CARB and the EPA proposals are expanding the

11 scope pretty significantly. And we've talked

12 a bit about that with the laminated products.

13 But there are also new cores that are being

14 brought into the products that have not been

15 regulated previously.

16 And third, the rollout must

17 certainly provide for adequate time for

18 implementation, particularly when you're

19 talking about these new product classes.

20 First of all, the talk about the

21 minimizing of the economic impact. I

22 mentioned about the need to have the programs
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1 be substantially sustained, and that's

2 absolutely critical. I mean even minor

3 differences can cause so much confusion in the

4 workplace.

5 And I can tell you that just

6 trying to explain that to a global audience is

7 going to be very complicated. And for that

8 reason we're very pleased to see that EPA has

9 reopened the comment period and that they're

10 looking carefully at the CARB proposal.

11 We're encouraged that this is a

12 deliberative approach. We give great credit

13 to EPA for this work. And we're especially

14 pleased to see that EPA and CARB have been

15 having, as what I understand, weekly to

16 biweekly meetings to try to get the point of

17 having some parity between these two roles.

18 That should be encouraged, and it's not an

19 easy thing to do and we recognize that it's

20 been a difficult process.

21 We do support the objectives of

22 the formaldehyde emission standards to protect
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1 the health of the public. However, we want to

2 make it clear that that harmonization and the

3 narrow tailoring of those regulations are also

4 important objectives of the rule, and in fact

5 TSCA itself mandates that EPA must put forward

6 the least burdensome option that adequately

7 protects against health risk. And that least

8 burdensome option is, in my view, one that is

9 going to be consistent between the two

10 programs.

11 And I think it's particularly

12 important to put it out that any unnecessary

13 cost that has been imposed by the rules and

14 especially by having a difference between the

15 two, will be immediately felt by U.S.

16 consumers.

17 It's going to be felt in terms of

18 reduced competitiveness for U.S. produced

19 goods, and in those goods in the global

20 marketplace. Because don't forget, we should

21 be exporting our goods as well.

22 We talk a lot about imports, but
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1 the trade moves both ways. And if we make our

2 regime so complicated for those domestic

3 producers they are not going to be able to

4 look forward to those export markets.

5 And one of those ways that you can

6 minimize that cost is to look at a de minimis

7 type of exemption, and I know that KCMA has

8 put forward an exemption.

9 But I would also say you need to

10 make sure that you look at an exemption that

11 talks about just a small amount of wood in

12 another product. Because wood will begin to

13 be engineered out of products if you make the

14 compliance regime to include them so difficult

15 to do so, so having a de minimis that includes

16 both sides, I think, is important.

17 Now I think the big issue, and the

18 one reason we're here in this room, is the

19 second point that I wanted to talk about and

20 that is the expansion to such new product

21 classes.

22 Now we talked about the fact that
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1 we have this new laminated product expansion

2 and that will have a profound impact on a

3 number of small businesses and simply should

4 be minimized. But there are also other

5 product classes that are being expanded to,

6 and I think it's important to recognize that

7 that is occurring.

8 Now specific to laminated

9 products, and I think we all agree that it

10 isn't a significant expansion, and IWPA's

11 position has been previously to EPA that we

12 absolutely oppose the expansion to laminated

13 products.

14 We felt it was an overreaching and

15 unnecessary thing to do. And particularly

16 because of the unfamiliarity of those

17 businesses to those rules, the capacity of the

18 TPC system, and in our view the chilling

19 effect that that expansion would have on wood

20 products, it simply would make wood products

21 more expensive and for not any real good

22 reason.
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1 That being said, and while our

2 preferred approach would be not to regulate

3 laminated products, if a regulation were to go

4 forward on that sector we believe EPA and CARB

5 should be very harmonized on that approach and

6 that the CARB approach merits a very serious

7 look by EPA and has definitely been much more

8 narrowly tailored than the one that EPA has

9 put forward.

10 We do, however, continue to have

11 some concerns with how that may be actually

12 put forward, and in particular we are

13 concerned that we still are hearing about

14 deconstructive testing which as we understand

15 it is just simply, it's not a proven

16 technology and it makes much more sense to

17 just start with one level of a performance

18 based standard of 0.13.

19 Now specific to other products

20 that are being included in here, I think it's

21 important to note that lumber core, two-ply,

22 as well as special core is also being included
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1 into this rulemaking. And those are

2 significant changes for those manufacturers

3 who have never been involved in this program

4 before.

5 And I do want to raise the issue

6 of special core partly because in my view the

7 definitions I've seen so far pretty much

8 include everything that you could ever think

9 of and may have a chilling effect on

10 innovation.

11 We're trying to figure out what

12 exactly is envisioned in that and so we would

13 welcome additional discussion with the agency

14 about what they envision with that. But

15 mainly because I think it's going to be hard

16 to really translate that out into the field

17 when it is such a broad definition.

18 My third major point I wanted to

19 say was that there really does need to be

20 adequate time for the rollout of whatever

21 regulatory scheme goes forward, particularly

22 since we are talking about potential expansion
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1 into whole new product areas.

2 You know, I think you've got to

3 think about it, not just in terms of trying to

4 get something into compliance, getting the

5 education out there, but also think about a

6 warranty. When you put a warranty on a

7 product you're doing it based on exactly what

8 you know that product is.

9 And perhaps you may find that you

10 want to reformulate a product in order to

11 comply with the new rules. Well, you're going

12 to need to have time in order to know whether

13 or not that product is durable enough, if it

14 stands up to the new testing. That's going to

15 take time.

16 And even just a simple 12-month

17 warranty for a product, you would want to have

18 testing for that for 18 months. So you need

19 to recognize that there is going to be some

20 important impact.

21 In terms of foreign producer

22 impact, the proposed rule would require a
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1 foreign company that would have to, via the

2 importer, do some certification. That means

3 there's going to need to be a lot of look

4 through a very complex supply chain.

5 We would like to make sure that

6 EPA and CARB is aware of that and recognize

7 that it is a severe challenge and it is going

8 to take time to get that complex supply chain

9 educated and in compliance.

10 And so that is why we're so

11 interested in making sure that whatever

12 rollout occurs that it is sensitive to this

13 very complex web of supply chains and it

14 allows for time backing all the way up.

15 And also shipping time amongst the

16 different players. Things are going to be

17 produced in one country, sent to another

18 country and then maybe coming to the United

19 States and we need to be recognizing of that.

20 So with that, you know, I thank

21 you again for the outreach. I appreciate that

22 EPA has taken the time to reopen the comment
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1 period, and we look forward to working very

2 closely with CARB and EPA in the future.

3 Thank you.

4 MR. COURTNAGE: Thank you. Our

5 next speaker is Jackson Morrill of the

6 American Chemistry Council.

7 MR. MORRILL: Okay, good

8 afternoon. My name is Jackson Morrill and I'm

9 the director of the American Chemistry

10 Council's Formaldehyde Panel. And on behalf

11 of our members I would like to thank EPA, as

12 I think many of my colleagues have already

13 done today, for opening up the comment period

14 and providing us this opportunity to share our

15 views on, in particular, the laminated

16 products issue.

17 The ACC's Formaldehyde Panel

18 membership is made up of resin producers that

19 over the course of the past several decades

20 made tremendous strides in developing product

21 offerings to meet performance requirements set

22 by customers and by CARB's ATCM.
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1 These efforts have led to the

2 development of resin technologies including

3 ultra-low emitting formaldehyde resins that

4 encompass primarily advanced urea-formaldehyde

5 chemistry.

6 These resin systems meet or exceed

7 technical performance levels for a wide range

8 of composite wood products while also ensuring

9 compliance with current CARB ATCM technology

10 based emissions requirements.

11 And I think Tom said it very well

12 today. It must be noted that these really are

13 the most stringent emission standards in the

14 world today.

15 The ACC Formaldehyde Panel is also

16 a member of the Federal Wood Industries

17 Coalition, or FWIC, and we certainly through

18 the course of that effort have fully supported

19 the positions taken by that coalition and we

20 look forward to Brock's thoughts as he shares

21 them with you today on behalf of that

22 coalition later this afternoon.
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1 Regarding the issue of laminated

2 products, ACC commented to EPA in early

3 October of last year that it should exclude

4 laminated products from the definition of

5 hardwood plywood and not require additional

6 testing as was proposed.

7 We provided our comments to

8 extending the scope of the proposed rule to

9 include laminated products exceeded what

10 Congress had initially intended in the

11 Formaldehyde Standards for Composite Wood

12 Products Act, and in particular that Congress

13 made clear that EPA seek to promulgate a rule

14 that is the "equivalent to compliance with the

15 CARB ATCM."

16 With CARB's decision to also

17 regulate laminated products, however, the

18 dynamic has changed. And over the course of

19 two CARB-sponsored public workshops, the ACC

20 Formaldehyde Panel has come to the position

21 that the current CARB proposal that EPA is

22 considering provides a realistic compromise
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1 given the varied interests at stake.

2 We believe that the proposal is

3 implementable both for the regulator and the

4 regulated community. And we would

5 particularly like to highlight two features of

6 CARB's proposed approach that are particularly

7 important to our members, and I think these

8 are probably familiar to all of you from our

9 comments that we've made in the past.

10 First, CARB's proposal maintains a

11 performance based approach to resin

12 technologies. This is fully consistent with

13 CARB's Phase 2, and the proposed limits in

14 CARB's laminated products proposal are based

15 on the highest Phase 2 emission standard for

16 products used as platforms for laminated

17 products, thin, medium density fiberboard.

18 The performance based approach has

19 been proven through experience to allow board

20 manufacturers to effectively meet or exceed

21 current CARB Phase 2 emission standards. In

22 fact, CARB's Phase 2 has unequivocally shown
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1 that existing and developing technology for

2 both resins and panel manufacturing are

3 capable of delivering composite panel products

4 that emit at or very near the emission levels

5 for natural wood.

6 By taking a performance based

7 approach, the CARB Phase 2 program has had the

8 effect of encouraging advancement in all

9 technologies, and provides the widest array of

10 options for panel manufacturers in the

11 downstream chain of commerce.

12 Now providing this flexibility to

13 the marketplace to choose the resin system

14 that works best for the specific application

15 is critical. There are a number of factors

16 that laminators need to take into account when

17 choosing a resin technology, including ability

18 to comply with emission limits, technical

19 performance, readily available supply, and

20 price.

21 Certain resin technologies simply

22 do not perform in certain applications, and
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1 therefore there could be real technological

2 limitations. As we noted extensively in our

3 comments on the EPA's previously published

4 proposed rule, there's really no basis to

5 support an approach to regulating laminated

6 products that would promote the use of one

7 resin type over formaldehyde based resin

8 technologies, NAF resins over ULEF resin

9 technologies.

10 CARB's data on other regulated

11 categories makes clear that manufacturers

12 continue to rely on UF based resin

13 technologies to meet or exceed CARB Phase 2

14 emission standards, which is a real testimony

15 to the effectiveness and capability of UF

16 based resins to comply with emission standards

17 such as those in CARB's proposed laminated

18 products regulation, which again is the

19 world's most stringent emission, we're talking

20 about the world's most stringent emissions

21 controls for composite wood products.

22 Moreover, the test methodology for
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1 assessing performance under temperature and

2 humidity conditions, the ASTM E1333 test

3 method is mandated by federal statute, thus

4 already setting in place a performance based

5 framework for all types of resin systems.

6 The bottom line is that the

7 experience in the CARB and the scientific

8 underpinnings of testing and certification

9 processes demonstrate that a performance based

10 approach that does not discriminate against

11 ULEF technologies can assure compliance with

12 the statutorily mandated emission limits while

13 meeting diverse market needs and minimizing

14 economic impact.

15 It is however important to note

16 that economic impact is still a critical

17 issue, and I think some have noted that today,

18 one that EPA must continue to consider. As we

19 also provided extensively in our comments, the

20 proposed rules cost exceed its benefits, and

21 in addition, the benefits analysis does not

22 meet EPA on these protocols and is not
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1 supported by the best available science.

2 So even though our comments today

3 are focused on providing input on CARB's

4 proposed approach to laminated products, we

5 would certainly urge that EPA take a much

6 closer look at the benefits analysis going

7 forward and we still consider that a concern.

8 Second, we would like to highlight

9 within the CARB approach what they've done

10 with CBI. We believe that CARB has artfully

11 addressed the issue of confidential business

12 information, or CBI, in its proposal to

13 laminated products by restricting the need for

14 and communication of sensitive CBI.

15 CARB's proposal addressed its

16 concerns regarding noncompliant lots by

17 incorporating a 72-hour notification

18 requirement, alleviating the need to express

19 a mandate that panel producers provide test

20 results to downstream users.

21 Under this approach, downstream

22 users can still contract with their suppliers
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1 for access to test data, but it preserves the

2 ability for those suppliers to protect

3 confidential business information.

4 We also applaud, although not

5 directly related to laminated products, CARB's

6 proposed amendments to not require formulation

7 information for any of the existing exemptions

8 as is reflected in the most recent amendments,

9 relying instead on supplier name and name of

10 product. We think that's the right way to go.

11 This approach provides CARB with

12 enough information to regulate without

13 necessitating the transfer of CBI. So we

14 would strongly advocate that EPA seek to

15 synchronize with CARB in its proposed

16 approaches to addressing this issue.

17 I think you've heard this from a

18 number of folks and we want to reiterate the

19 importance of this issue as well that we would

20 certainly consider -- I'm sorry -- encourage

21 EPA to consider adopting the CARB proposal for

22 regulating laminated products to ensure
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1 regulatory consistency across the United

2 States. As I'm sure many stakeholders would

3 agree, regulation across the United States

4 poses numerous challenges that can have real

5 economic and legal implications.

6 As I noted above, we believe that

7 alignment with CARB is also consistent with

8 congressional intent. We do want to make

9 clear that we've certainly, as I think Cindy

10 said it well too, we really appreciate all

11 that EPA and CARB have done to coordinate on

12 this issue, and we certainly hope that this

13 level of coordination will continue going

14 forward so that unnecessary regulatory

15 inconsistency can be avoided.

16 We believe that CARB's proposed

17 approach provides a workable compromise. As

18 CARB has highlighted in their publicly

19 available summary, the approach to regulating

20 laminated products establishes a performance

21 based emission ceiling and achieves additional

22 emission reductions beyond the current
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1 regulation by ensuring that a laminated

2 product does not result in emissions any

3 greater than the certified platform.

4 Again we thank EPA for this

5 session, and we hope that EPA continues its

6 close dialogue with CARB and all stakeholders,

7 and ultimately that it adopt CARB's approach

8 to regulating laminated products. Thank you.

9 MR. COURTNAGE: Our next speaker

10 is Robert Criner of the National Association

11 of Home Builders.

12 MR. CRINER: Good afternoon.

13 Pleased to be here today. I represent the

14 National Association of Home Builders and I

15 wanted to share our concerns. Again, my name

16 is Robert Criner. I am not an employee of

17 theirs, but I am a remodeler from Virginia,

18 and I'm chairman of the NAHB Remodelers

19 Council.

20 NAHB is a Washington, D.C. based

21 trade association representing over 140,000

22 members who design and construct the single-
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1 family homes and we also remodel existing

2 homes. Collectively, NAHB members will

3 construct 80 percent of the new home units for

4 this year.

5 In addition, 57 percent of NAHB

6 remodeler members and many of its associates

7 are involved in the remodeling industry. NAHB

8 membership includes builders, remodelers,

9 suppliers, and others who serve the

10 residential, light commercial, and industrial.

11 Furthermore, more than 95 percent

12 of NAHB members meet the federal definition of

13 a small entity defined by the Small Business

14 Administration. NAHB members regularly work

15 with thousands of composite wood products that

16 may be covered by the proposed rule.

17 The uncertainty of the regulation

18 for home builders combined with the

19 duplicative recordkeeping requirements in the

20 proposed rule impose significant, unnecessary

21 burdens for the NAHB members.

22 On October 8th, NAHB submitted
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1 comments on the proposal to express concerns

2 for the uncertainty and of the applicability

3 of the regulation and recordkeeping and burden

4 for our members. We appreciate this

5 opportunity to provide further comments on the

6 treatment for laminated products under the

7 proposed regulations.

8 The proposed requirements for

9 fabricators should be harmonized with the

10 California Air Resource Board's regulations to

11 avoid differing regulatory requirements. More

12 specifically, EPA should include a limited

13 applicability to fabricators in regulating

14 laminated products.

15 Currently CARB's regulations do

16 not require third party certification in

17 testing requirements for a fabricator.

18 Instead, a fabricator's requirements are

19 limited to recordkeeping and labeling.

20 EPA's proposal, however, will

21 impose third party certification in testing

22 requirements for fabricators. The limited
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1 applicability to fabricators provided in

2 CARB's regulations must be reflected in EPA's

3 regulations to prevent regulatory confusion

4 and an increased burden on the regulated

5 community, many of which are small businesses

6 like myself.

7 More importantly, if EPA's

8 regulations do not include a limited

9 applicability to fabricators on laminated

10 products, the problem for home builders and

11 remodelers will be further exacerbated due to

12 the contradicting and vague qualifications for

13 a fabricator and a retailer.

14 For example, within the preamble

15 of the proposed rule EPA explains that a home

16 builder or presumably a remodeler or any other

17 type of contractor who purchases a product

18 such as a kitchen cabinet could be considered

19 a retailer or a fabricator under the proposed

20 rule and therefore will have to comply with

21 the proposed rule's recordkeeping

22 requirements.
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1 More specifically, EPA indicated

2 that a home builder who purchases finished

3 cabinets from another entity, installs them in

4 a home, and then sells the home to a customer

5 would be considered a retailer as long as no

6 major modifications are made to the cabinetry

7 in the process of installing them.

8 To me this means that if I perform

9 a major modification, whatever that might be,

10 on a kitchen cabinet, then I may be regulated

11 as a fabricator. The issue here is that it's

12 not clear what EPA means by a major

13 modification because no such definition or

14 even an explanation has been provided.

15 Without explaining what

16 constitutes a major modification, EPA is

17 leaving the door open to speculation that will

18 result in confusion. In addition, EPA must

19 also address the existing rules of certain

20 entities as an installer in the same way as

21 CARB has.

22 According to CARB, an installer
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1 simply puts finished goods into service. EPA

2 should also clarify whether such an entity

3 would be regulated for making modifications to

4 a product. For example, will EPA regulate me

5 as a fabricator if I purchase a pre-made

6 finished cabinet, if I get the kitchen

7 cabinets and I resize one of those cabinets to

8 be able to install them?

9 For example, if I shorten a

10 cabinet to make room for a refrigerator, or if

11 my plumber cuts the back of a cabinet out to

12 make room for the piping? In this role we are

13 only product users much like other customers

14 who reside at the end of the supply chain.

15 EPA should provide an explicit

16 exemption to an entity that functions in this

17 role as an installer as I have just described,

18 exempting such entities from the burdensome

19 recordkeeping and labeling requirements.

20 The regulatory burden on

21 fabricators is further increased by another

22 requirement in the proposed rule which is also
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1 inconsistent with CARB's requirements. EPA's

2 proposal includes a recordkeeping requirement

3 which includes a three-year record retention.

4 California on the other hand only requires two

5 years for its record retention.

6 EPA's authority to compel record

7 retention is restrained to only those that are

8 necessary for the effective enforcement. EPA

9 has failed to show a compelling reason to

10 justify the necessity of increasing the

11 recordkeeping burden to three years.

12 From an enforcement perspective

13 under TSCA, similar to other recordkeeping

14 requirements that I must comply with such as

15 the Lead RRP rule, penalties can be assessed

16 up to $37,500 per day per violation.

17 The difference between a record

18 retention violation for three years versus two

19 years is substantial. Aligning EPA's record

20 retention requirements with CARB's will

21 decrease recordkeeping burden on regulated

22 entities like my company and it will ensure a
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1 smooth transition of the regulation on a

2 national level.

3 Robert, you mentioned earlier that

4 you would clarify something for me. Could you

5 tell me what a major modification is? Would

6 that be a no? You're working on that one.

7 I'd be glad to help.

8 Well, the problem is if I go into

9 a closet and I buy a board which is already

10 certified by one of these people, and I pick

11 it up at Lowe's next to a customer of mine

12 who's picking one up for his closet as well,

13 is it a major modification if I cut the board?

14 How about if I take this same

15 board and cut it up into five pieces and make

16 a shoebox for it? Where's the major

17 modification? It's the same board my

18 customer's buying next door to me. It's not,

19 in my opinion, shouldn't throw me into the

20 recordkeeping burden that we talk about.

21 The other concern is that we talk

22 about these records and this cabinet or a
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1 small toilet topper for a bathroom or

2 something that may have a label on it. The

3 person I send to Lowe's to buy that is my

4 lowest employee, the runner.

5 Is he going to code the invoice

6 right to get it in the right job to where it's

7 a $37,500 mistake? He doesn't make that much

8 in a year.

9 I appreciate the time you've given

10 me today and would like to close with that

11 NAHB supports the development of cost

12 effective and justifiably reasonable

13 regulations.

14 NAHB continues to advocate against

15 unnecessary regulations to entities that are

16 not directly responsible for the targeted

17 issue such as the case here. The EPA's

18 proposed rule should be harmonized with CARB's

19 regulation, and thank you for the time.

20 MR. COURTNAGE: Okay. The next

21 speaker is Tom Neltner of the Natural

22 Resources Defense Council.
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1 MR. NELTNER: Thanks for the

2 wonderful and thoughtful comments I've been

3 getting today in hearing how the industry has

4 moved on this issue and CARB's continuing work

5 on it.

6 Today I'm speaking as an

7 individual. The public interest community is

8 going to submit comments, but we wanted to

9 hear what was going to be said today to be

10 able to prepare those comments. So they'll be

11 submitted by the deadline, Cindy.

12 When EPA finalizes the rule later

13 this year hopefully it closes a chapter for

14 the people who struggled with their health

15 after living in FEMA trailers after Hurricanes

16 Katrina and Rita disrupted their lives.

17 The high levels of formaldehyde

18 they struggled with appear to have largely

19 stemmed from poorly made composite wood panels

20 imported from overseas. By nationalizing the

21 California Air Resource Board's standards for

22 composite wood products, EPA protects those
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1 residents by setting high standards and, more

2 importantly, establishing a means to ensure

3 domestic and overseas manufacturers meet those

4 standards.

5 I applaud EPA for staying true to

6 the science when it raised concerns about

7 potential formaldehyde emissions from

8 manufacturers who glued a thin layer of veneer

9 to CARB-compliant wood.

10 To be honest, until this year I

11 didn't realize that a thin layer of veneer

12 could be only 1,000th of an inch thick.

13 That's essentially just a piece of paper, a

14 paper-thin coating on resin that could be

15 easily saturated with glue and off-gas

16 formaldehyde.

17 So applaud EPA for staying true to

18 the science. If that operation is done

19 poorly, whether in the United States or in

20 China, there is sufficient evidence that

21 laminators could undermine some of the

22 benefits that CARB, Congress, EPA, the
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1 industry, and the public thought they were

2 getting from the rule.

3 And so they thought they were

4 getting it from a rule whether it's furniture,

5 cabinets, or other wood products, the goal was

6 to make sure they consistently achieve the

7 stringent standards for formaldehyde off8 gassing.

9 However, EPA proposed solution in

10 the June 23rd proposal was simply a bridge too

11 far. From a purely public health perspective

12 I get it. I see the value with third party

13 certification for all products and I believe

14 that the health benefits would offset the

15 costs.

16 While true to the science, EPA's

17 proposal needed more creativity to craft a

18 pragmatic solution that ensured that

19 laminators did not undermine the objectives of

20 the rule and did it in a reasonable, cost

21 effective manner.

22 So I'm pleased to see EPA's,
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1 CARB's, and industry's ongoing and sustained

2 efforts to find the best solution and for EPA

3 to seek additional comment on CARB's March 4,

4 2014 proposal.

5 I support CARB's approach of

6 setting an emission standard of 0.13 for

7 laminated products and creating a category for

8 composite wood products for these things that

9 seem distinct from hardwood plywood.

10 Unfortunately I do not think CARB's approach

11 is far enough to ensure that the products will

12 actually achieve the standard.

13 It's not a problem with the 0.13.

14 I think it needs a little bit more on the

15 verification side. CARB was up here and, I

16 think, appropriately talked about the fact

17 that they can test the products, like the

18 paint for it.

19 Unfortunately I think wood

20 products are different because that test would

21 involve deconstructive testing, and

22 deconstructive testing in my years of work,
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1 and it's now been six years of work with

2 industry, is not a popular concept. It's not

3 a concept I think they think is validated or

4 enforceable.

5 So as long as it's going to be

6 enforced, the 0.13 is enforced with the

7 deconstructive testing, until there's

8 widespread support I don't see that as an

9 enforceable way to do it. I think there needs

10 to be some middle bridge, and I am not asking

11 for third party certification.

12 I think Bill, in particular,

13 you've talked to me and helped me understand

14 the challenges of that. What I think is

15 needed is, I think a performance standard

16 alone without means to verify compliance such

17 as a third party certification is

18 insufficient.

19 So I'm trying to find a middle

20 ground. Kip hit to some of that middle ground

21 when he talked on behalf of HPVA earlier. I

22 think a laminator should be responsible for
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1 self-certifying. I'm okay with self2 certifying for those laminators that the final

3 product not only used a core that complied

4 with the standards, but that the product as a

5 whole after lamination meets the 0.13

6 standard.

7 At a minimum, the self8 certification must be included in the

9 documentation that travels with the final

10 product so downstream users can see it, so

11 when that certification is there, they're not

12 just certifying that they used a compliant

13 core but that the wood also meets the 0.13

14 standard.

15 In addition, I think the

16 laminators should register with EPA when it

17 makes that self-certification. Because as a

18 practical matter I'm struggling with how EPA

19 can enforce a rule when it doesn't know who's

20 all out there.

21 I understand that that may be a

22 significant burden, so I think that's an issue
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1 that needs to be discussed. I do clearly

2 understand the risk that some companies,

3 especially those that are out of touch with

4 their customers' best interests, may not be

5 truthful when they self-certify.

6 We are relying on the veracity of

7 people ultimately. And also they may not have

8 any idea what they're doing. So I do see the

9 value in some testing to make sure that they

10 are capable of doing it. That they can

11 produce compliant wood, and yes, they can

12 cherry-pick the materials.

13 But I think it's important because

14 not only does EPA or CARB do verification, but

15 in my working with this industry and the KCMA

16 and AHFA, your members do a supply chain

17 verification. So if there is a means of

18 checking the paperwork to ask what kinds of

19 resins did you use, that kind of verification

20 is important, and that's why I think there

21 needs to be more than just 0.13.

22 So I do recognize, and I read this
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1 in AHFA's comments that a single piece of

2 furniture could come from many sources that

3 could use different glues and different

4 systems. I think that we should have an

5 option to check one or more of three options.

6 I do not quite agree that this

7 performance standard alone without any

8 verification is sufficient. I do think EPA

9 was correct in saying that if you self-certify

10 that you're using no added formaldehyde glue,

11 I think that's alone is enough.

12 I think one option of those three

13 is a no added formaldehyde resin. I think EPA

14 was correct to exempt laminators who use these

15 resins. Not just because the formaldehyde

16 off-gassing would be minimal, but because it

17 could be easily verified by checking the

18 records.

19 If the firm only purchased NAF

20 resins, the investigator whether at EPA or

21 CARB, or the buyer, should be satisfied. I

22 also think that there needs to be more than
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1 just NAF resins. I think the ULEF resin needs

2 to be considered as an option.

3 And in my mind, the way ULEF

4 resins are done in the CARB rule, which

5 involves extensive testing at a facility,

6 isn't going to work, because that's no more

7 than, they still have to do third party

8 certification, in essence.

9 So what I'd like to see is EPA

10 create an option for ULEF where a ULEF

11 manufacturer who shows that when you use this

12 product in a certain way that it gives EPA or

13 CARB confidence that they can consistently

14 meet the 0.13.

15 We should encourage the technology

16 innovation that's out there and allow that

17 resin to be certified. Effectively, one of

18 those creative companies that are making these

19 resins would make a showing to EPA or CARB,

20 convince them that you follow these

21 instructions, these laminators will stay in

22 the limit, they'll be fine. And I think
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1 that's the best way to create an option that

2 it spurs innovation.

3 For all those who don't want to

4 use a NAF or ULEF resin, I think they need to

5 be able to pull some of their product. Send

6 it to, probably annual, send it off for a

7 small chamber testing. What is it? Drop it

8 into a FedEx package, send it to the lab and

9 get it tested annually or whenever the

10 certification needs to be renewed.

11 But I think there needs to be some

12 way, not that they're showing that they every

13 day meet the standards, but that they're

14 capable of meeting the standards. And there

15 needs to be some of that verification.

16 And the supply chain could check.

17 Did you do the testing? Let me see the

18 results. So it engages the supply chain

19 without having to involve the deconstructive

20 testing that I know is so controversial.

21 The bottom line on this is that

22 self-certification is a pragmatic solution
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1 that will provide the reasonable means of

2 verification. By allowing those three options

3 to be explored we're giving people choices.

4 They don't have to do testing if they want to

5 go to the different resins.

6 Overall, I have to say I admire

7 CARB for sticking with this but also for the

8 way you've had workshops to discuss it and

9 actually had that engagement. I know that

10 isn't EPA's typical, its rulemaking process,

11 so I think the interplay between EPA and CARB

12 has been wonderful, and industry's ongoing

13 commitment to finding the right way has been

14 really impressive.

15 Overall, I've heard the comments.

16 I see your point. I think if we look at self17 certification with a little bit of

18 verification on it in giving people options,

19 I think we can reach the conclusion. We're

20 almost there. I'd like to see EPA get this

21 rule out this year. Thank you.

22 MR. COURTNAGE: Our next speaker
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1 is Brock Landry of the Federal Wood Industries

2 Coalition.

3 MR. LANDRY: Good afternoon. I'm

4 Brock Landry. I'm a partner with Venable,

5 here in town, and today have the honor of

6 appearing as counsel to the Federal Wood

7 Industries Coalition.

8 As Tom Julia mentioned, this is

9 really a remarkable group. It has not only

10 panel producers, resin producers,

11 international interests, downstream users in

12 the furniture, cabinet, molding, flooring

13 industries.

14 What we've tried to do is bring

15 together the different interested parties to

16 the maximum extent possible to give a united

17 voice to the regulators to try to streamline

18 the process and work for the best possible

19 regulation.

20 And again we commend both CARB and

21 EPA for their openness in talking to us about

22 these things and the interaction, and today's
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1 session is just one instance of that which we

2 appreciate.

3 I thought it might be useful just

4 to review the bidding a little bit about how

5 we got to this place about talking about

6 laminated products, now six years after it was

7 first introduced at CARB.

8 The 2008 regulation at CARB did

9 have a very broad exemption from the hardwood

10 plywood definition for laminated products. As

11 Lynn mentioned, the only real requirement was

12 that you use a composite core. Extremely

13 broad, split out a species of hardwood plywood

14 into a non-regulated environment with the

15 exception of the core.

16 When the EPA proposal came out it

17 had a very much more limited restriction. And

18 the central feature of that is to qualify as

19 a laminated product the laminate had to be

20 attached with an NAF resin. This is

21 impossible in many situations just because of

22 the features of the product and the
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1 performance of the product, so it by

2 definition added a whole new group of entities

3 to the regulated community, a huge expansion.

4 The FWIC, looking at this, thought

5 let's go back to the statutory definition in

6 the act. You know, this was a feature that

7 came about again between discussions of the

8 various industry parties and the folks who

9 were sponsoring this.

10 And our real purpose in the

11 legislation itself and in the laminated

12 products exemption was to equalize the

13 provisions to nationalize, if you will, the

14 California provisions.

15 When Senators Crapo and Klobuchar,

16 and Representatives Matsui and Burgess put

17 this legislation in, if you go back to their

18 introductory statements they all reference the

19 absolute need to unify the regulation of

20 formaldehyde between California and on a

21 national level and to expand it so it would

22 cover all of the products that are used
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1 nationally.

2 So FWIC initially looked at this

3 and said look, we think we ought to adopt

4 something like the statutory definition. But

5 we all know that the statute had one of the

6 most unusual provisions for statutory

7 definition that I've seen in my years

8 practicing law in this town.

9 It said, well, here's the

10 definition, but we're going to grant EPA the

11 authority to change it if they think it's

12 necessary. Why did that happen? During the

13 deliberation on the bill we had wide

14 acceptance of the statutory definition, and

15 near the end of the process that consensus was

16 not maintained.

17 And so rather than take the

18 possibility that the bill would be held up on

19 the floor by a single senator opposing it,

20 putting a hold on the bill, the sponsor said

21 look, we're going to put the agreed upon

22 definition in and we're going to put this
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1 unusual provision into the legislation that

2 allows EPA to change it. So those who are

3 unhappy with that decision can make their

4 arguments to EPA and see how it comes out.

5 And that's where we are today. So

6 again, FWIC supported the statutory approach.

7 It eliminated the idea of only having NAF as

8 the adhesive in laminates, and we thought it

9 was an acceptable approach.

10 CARB now came up with an approach

11 that said, okay, put an emission limitation on

12 there as well. Put the 0.13 ppm on as a

13 requirement in order to get the exemption.

14 And the industries looked at this and said,

15 could be a restriction, but we think this is

16 a reasonable, commendable approach to this

17 problem that we've been wrestling with for

18 four or five years.

19 So the FWIC group is here today to

20 say that we do support the CARB approach. We

21 think it's a creative way of resolving this

22 issue, and we would ask that EPA consider this
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1 for implementation in the federal regulation.

2 I'd like to talk just a little bit

3 about legal authority to do that. There's

4 been some questions about that. My friend Mr.

5 Howlett said that there's only one species or

6 one number for hardwood plywood. I would take

7 exception with him.

8 The laminated product category has

9 always been an exemption from hardwood

10 plywood. In other words it's a subset. And

11 we think it's totally within the discretion of

12 EPA to define that subset in a variety of

13 different ways, including an emission

14 limitation, and including those sectors of the

15 industries that are affected.

16 So we think it's perfectly

17 consistent. There's also been some suggestion

18 that this can't be consistent with the

19 legislation because the number 0.13 is higher

20 than the numbers, for instance, of 0.05 that's

21 there for hardwood plywood. But I think the

22 single fact that belies that most clearly is
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1 the fact that the statutory definition had no

2 emission limitation. None whatsoever.

3 So the CARB approach is actually a

4 step in between, and again I think completely

5 consistent with the legislation. You know,

6 when we started this journey back in 2009 or

7 2010 with Mr. Neltner and others, again the

8 real role was coordination of the two

9 regulatory regimes.

10 It's still the same goal today and

11 we're pleased that both the regulatory bodies

12 have accepted this principle, and now it's a

13 question of how do we get there on this

14 particular one and a few others which we've

15 commented on.

16 But I look back over this whole

17 history and it's one of the most interesting

18 that I've been involved in in my years in

19 Washington. When you go into a congressional

20 office to try to solve a problem and you say

21 I'm here for the wood products industry and

22 I'm espousing the position of the Natural
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1 Resources Defense Council, United Steel

2 Workers, the pediatricians, and Healthy Homes,

3 I think I've never had so many strange

4 reactions in my life from congressional

5 staffers and members.

6 But the point, I think, is

7 important because this is one of the real

8 success stories of industry, the public

9 interest community, the labor unions, the

10 health industry, coming together for a

11 reasonable solution to a situation with

12 products.

13 And again I would urge both CARB

14 and EPA to adopt the CARB proposal. I think

15 it's reasonable and it's consistent with

16 statute and it will promote the underlying

17 features of the statute. Thank you.

18 MR. COURTNAGE: So we're at the

19 end of our list of the folks who have signed

20 up to speak. If there's any others, we have

21 some time, would like to come up and speak for

22 a few minutes, otherwise we can have a Q&A
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1 session for either EPA or for those who have

2 spoken today.

3 You could just come up to the mic

4 and ask your question. Also for folks on the

5 phone or online as well, if you're online you

6 can type your question into the Q&A pod.

7 MR. BAKER: Thanks, Robert. Lynn

8 Baker with the Air Resources Board. I wasn't

9 going to come up. I figured there would be

10 other commenters that I would give them the

11 time.

12 But since no one came, I just

13 wanted to make one little comment with regard

14 to something that Cindy Squires mentioned

15 about the lumber core, special core, and two16 ply, which does add to what we're currently

17 regulating and certainly would add to what

18 EPA's regulating.

19 And Cindy, just for your

20 background for this, the background for

21 others, ARB's regulation has a definition of

22 hardwood plywood which includes everything
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1 under the sun. Two-ply, lumber core, special

2 core, combination core, composite core, and

3 veneer core.

4 But we only have two standards,

5 veneer core and composite core, so all those

6 other products we have not been regulating.

7 We've only been regulating veneer core and

8 composite core under our regulation.

9 And in fact we've directed all the

10 third party certifiers around the world to

11 only certify those two types of products,

12 veneer or composite core products. The

13 federal act defines hardwood plywood in the

14 way our regulation defines hardwood plywood as

15 including special core and lumber core.

16 And so I believe EPA is locked

17 into that definition of hardwood plywood which

18 is not the way we have been regulating it.

19 This definition's consistent with HPVA's HP-1

20 ANSI standard for hardwood plywood, so we

21 didn't dream this up. It's out of the HP-1.

22 But we think EPA, in talking with EPA staff,
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1 is locked into that definition of hardwood

2 plywood, and hence that's why we, ARB, have

3 proposed to expand our regulation to include

4 special core and lumber core and two-ply

5 products.

6 We would not have done that other

7 than again our efforts to harmonize with EPA,

8 and we feel if we don't do that then we would

9 be out of sync with EPA. So anyway I just

10 wanted to offer that.

11 MS. VENDINELLO: I would like to

12 thank everyone for coming and for

13 participating on the phone. And I'm Lynn

14 Vendinello. I'm one of the managers on this

15 rule in OPPT, and I promised to talk about

16 next steps.

17 We will look forward to

18 assimilating everything that was said today as

19 well as what's going to be submitted hopefully

20 by May 8th. We are very far behind in this

21 rulemaking, so staff has an extremely

22 ambitious schedule to get it done, probably
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1 now not by the end of this fiscal year but

2 hopefully by the end of this calendar year.

3 Just by virtue of opening up the

4 public comment period to hear more from you

5 today, we have to forego some of the schedule.

6 As you know we have been working to harmonize

7 as much as possible with California, but I

8 also want everyone to realize the sort of the

9 way in which EPA operates and some of the

10 themes of our administration including next

11 generation compliance, we're a little bit

12 different than California.

13 So we're trying to write a rule

14 that's consistent with the administrators'

15 priorities as well, and that's very

16 challenging. And I welcomed Tom's comments on

17 some ideas in that area. So thanks again and

18 we look forward again to getting your comments

19 by May 8th.

20 (Whereupon, the foregoing matter

21 went off the record at 2:56 p.m.)

22
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A

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