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United States Environmental Protection Agency

Pressed Wood Manufacturing Industry Survey:

Hardwood Plywood, Medium Density Fiberboard, and

Particleboard Manufacturers

General Information, Definitions, and Instructions

Thank you for participating in EPA’s pressed wood manufacturing industry survey.

Please return the completed response no later than Weekday, Month Day, Year.

Completing the survey is voluntary, but it is important that you respond. EPA needs

information from all companies (including those making products with low

formaldehyde emissions) to determine whether further action is needed, and to

understand the impact of potential actions on manufacturers. Your participation will

help EPA understand your company and the industry as a whole.

If you have any questions, please contact Ann Ferris at ferris.ann@epa.gov or (202)

564-3207; Peter Nagelhout at nagelhout.peter@epa.gov or (202) 566-2313; or

William Silagi at silagi.william@epa.gov, or at (202) 564-8788.
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GENERAL INFORMATION

Respond for Individuals Plants. This questionnaire was designed to gather data for individual

manufacturing plants, not all the plants operated by a parent company or company headquarters.

(However, you may need information from a parent company or company headquarters in order to

complete the questionnaire.) Please provide responses that are specific to your plant only, as identified

on page 1 of the questionnaire. If you are completing the questionnaire for multiple plants owned by

the same company, please use a separate questionnaire for each plant.

Plants Making Other Products. This questionnaire is designed to collect information on hardwood

plywood, medium density fiberboard, and particleboard products. If your plant also manufactures

other composite wood products (such as hardboard or structural composites), you should receive a

separate questionnaire. If you need a copy of the other questionnaire and did not receive one, please

contact EPA.

Skills Needed to Report. This questionnaire is intended to be completed by a person knowledgeable

about both the technical and financial aspects of the pressed wood products manufacturing operations

at your plant. In some cases, you may need to look up records or consult staff in other departments to

complete all the information requested.

Use Readily Obtainable Information. This questionnaire asks for readily obtainable information,

e.g., information known or easily accessed by technical, managerial, or supervisory employees of your

company who are responsible for manufacturing, processing, technical services, or marketing. If you

do not have the underlying information, you do not have to generate it to complete the questionnaire.

For example, the questionnaire asks for information on formaldehyde emission levels from your

products. If you have not already tested your products for formaldehyde emissions, you do not need to

test them in order to respond to this questionnaire. In this example, if you do not have any

formaldehyde testing data, you would report “UK” (for “Unknown”) on the questionnaire.

Generating Additional Copies. As shown in Figure 1, if you need to fill out more than one copy of a

section in the questionnaire, or need more space than a table provides, click the “Add Copy” button to

have the electronic version of the form automatically generate an additional copy of the section or

table. If you are using the paper version of the form, please use the extra copies provided and make

additional copies as necessary.

Suggested Recordkeeping. Participation in this questionnaire is currently voluntary, so that you are

not required to respond. If you do respond, you are not required to keep any records to document your

response. You may, however, wish to keep a copy of the completed questionnaire for your files to

refer to in case EPA contacts you with any follow-up questions to clarify your answers later in the

process.
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CONFIDENTIAL BUSINESS INFORMATION

You may designate information that you submit on this questionnaire as Confidential

Business Information (CBI). EPA takes stringent measures to protect CBI submitted in connection

with TSCA pursuant to part 2 of title 40 of the Code of Federal Regulations (known as 40 CFR part

2) and the TSCA CBI Protection Manual. These procedures include security clearance and training

for all staff permitted to access TSCA CBI, storage of TSCA CBI in secured areas, computer

security for TSCA CBI, secure methods for creating, transferring, and destroying TSCA CBI, and

advance notice of disclosure to contractors (usually via the Federal Register) where such disclosure

is authorized. Access to TSCA CBI is limited to persons who are TSCA CBI cleared.

EPA will disclose information that is covered by a claim of confidentiality only to the

extent permitted by, and in accordance with, the procedures in TSCA section 14 (to the extent they

may apply) and the regulation at 40 CFR part 2, which provides advance notice and an opportunity

to object prior to public disclosure. Otherwise, confidential data provided by individual companies

will not be identified in summary reports or released to unauthorized individuals, and public

dissemination of results based on TSCA CBI will be limited to aggregate statistics that do not

disclose confidential data.

The information collected by EPA may be disclosed to contractors of the Agency. This

access will only occur to enable the contractors to perform required tasks for the Agency. These

contractors, including staff, will comply with Agency procedures for contractor handling of

confidential information collected in connection with TSCA. By returning the survey to EPA, you

consent to this disclosure to EPA's contractors.

Please assert CBI claims only where there is a legitimate need to do so. In general,

voluntarily submitted information is entitled to confidential protection where the information would

not customarily be disclosed to the public, although authorities in TSCA Section 14 may apply.

To identify data as CBI, simply check the box in the left-hand margin on the

questionnaire form next to each question where you provide CBI. For example, as shown in

Figure 2, if the total volume of hardwood plywood manufactured by your plant is

confidential, then check the box at the left of Question #9(a). Please note that information not

specifically identified as CBI may be made available to the public without further notice.

If you claim any information in your response as CBI, see the enclosed instructions on how

to assemble your completed questionnaire and return it to EPA.

In order to ensure the protection of CBI, please do not e-mail any data or materials

that you designate as CBI.
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Figure 1. Example of How to Generate Additional Copies of a Questionnaire Section or Table

If you need to fill out more than one copy of a section in the questionnaire, or need more space

than a table provides, click the “Add Copy” button to have the electronic version of the form

automatically generate an additional copy of the section or table. If you are using the paper version of

the form, please use the extra copies provided and make additional copies as necessary.
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Figure 2. Example of CBI Checkbox Marked to Claim Data as Confidential

Mark the CBI checkbox in the left-hand margin of the questionnaire form (indicated by the red

arrow in the figure below) to claim information you provide as confidential.
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GENERAL DEFINITIONS

Additive. Additives to composite panel products include, but are not limited to, biocides, buffers, catalysts, fire

retardants, release agents, scavengers, tack agents, and wax emulsions.

Adhesive/emissions class. Adhesive/emissions class means a class of pressed wood products that differs from

others based on binder/resin technology, formaldehyde emission certification standard category, and/or

formaldehyde emission profile. You need not report separately for products that differ only based on physical

characteristics such as thickness, density, or strength, but have the same formaldehyde emission profile; these

products may be reported together within the same adhesive/emissions class.

Catalyst. An additive to a resin formulation that allows the resin to cure faster or harder than it otherwise

would.

Composite panel products. See “Pressed wood products” definition.

Energy costs. Costs of fuels or energy (e.g., natural gas, electricity) inputs used in manufacturing the primary

composite panel products.

Filled or coated products. Secondary composite panel products made typically by treating particleboard or

MDF on one or both surfaces with either a high solids filler to improve surface properties, or one or more layers

of liquid or decorative paint, or powder coating. Includes EB (electron beam) and ultraviolet (UV) cured

products and direct-ink printed products.

Finished board. Primary composite panel product, not secondary or value added products.

Formaldehyde emission certification standard category. The emission standard you meet (if any) that

requires the lowest product formaldehyde emissions. Examples include the CARB Phase 1, Phase 2, ULEF and

NAF standards; the CPA EPP Grademark Standard; the European E1/E2 standards; the Japanese F-star

standards; and the HUD standards.

Hardwood plywood (HWPW). A primary composite panel product usually made with a decorative face ply of

hardwood veneer and intermediate, core, and back plys of other veneers or materials. It is assembled with the

grains of adjacent layers perpendicular to each other. An adhesive system is applied to the veneer surfaces

during assembly, and then cured under heat and pressure. Adhesive systems rated only for interior service are

commonly used. Also included is plywood with a coniferous face if it is intended to be used for decorative

purposes. Solid wood, particleboard, or medium density fiberboard may be substituted for veneer in the core of

the panel. The requirements for hardwood plywood are specified in ANSI standard HP-1-2004.

High pressure laminates (HPL). A surfacing material composed of layers of resin-saturated papers fused

together under heat and pressure. May be either decorative or plain. HPL is often glued to primary composite

panels such as plywood and particleboard to form secondary composite panel products such as countertops or

other work surfaces.

Hot stamp foils. Decorative pigments or paint designed to be transferred from a disposable carrier film to the

surface or edge of a composite panel product substrate through use of a heated laminating roll.

Low basis weight papers. Low basis weight papers (lightweight papers) are commonly used as decorative

overlays on a variety of primary composite panel substrates. An adhesive is normally applied either to the paper

or to the substrate then cured by a heated laminating roll press.

Low pressure decorative laminates (LPDL). Resin-saturated decorative papers that are fused to the surfaces

of primary composite panel products with heat and pressure. Often referred to as “melamine laminates” or

“polyester laminates.” LPDLs do not require additional adhesive application. LPDLs do not include papers

saturated with phenolic resins, which are classified as medium and high density overlays (MDOs and HDOs).

Master panel. Term commonly used for some primary composite panel products after they emerge from the

press in rough form prior to sawing and sanding to finished dimensions.
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Medium and high density overlays (MDO and HDO). Papers impregnated with phenolic resins that are fused

to primary composite panel products with heat and pressure. MDO and HDO are often applied to softwood

plywood for exterior applications such as concrete form or signs.

Medium density fiberboard (MDF). A primary composite panel product composed primarily of cellulosic

fibers and a bonding system cured under heat and pressure. MDF density is typically between 500 kg/m3(31

lb/ft3) and 1,000 kg/m3(62 lb/ft3). The requirements for MDF for interior applications are specified in ANSI

standard A208.2-2009.

Modifications to existing equipment. Any upgrading, retro-fitting, or other modifications to exiting equipment

in order to reduce formaldehyde emissions.

New equipment costs. The amount paid for any new equipment that was purchased in order to reduce

formaldehyde emissions, including installation and structural support costs for this equipment.

Particleboard. A primary composite panel product composed of discrete cellulosic particles (as opposed to

individual fibers), usually wood, and a bonding system cured under heat and pressure. The density of

particleboard products ranges from 300 kg/m3(19lb/ft3) for low density door core products to over 800 kg/m3

(50lb/ft3) for demanding industrial applications. The requirements for particleboard are specified in ANSI

standard A208.1-2009.

Plant. Physical facility (consisting of one or more buildings, processes, and assemblies of equipment) where

composite panel products are manufactured.

Planned change. Changes that are likely to occur (you are confident that they will be undertaken) – as opposed

to future “possible” projects which may or may not ultimately be executed. Planned changes include expansions

or equipment upgrades/changes in the next three years.

Post-press treatment. An additional manufacturing step performed after pressing primary composite panel

products that is undertaken to reduce formaldehyde emissions (e.g., treat boards with anhydrous ammonia).

Pressed wood category. A type of primary composite panel product. In this questionnaire it includes only the

three following products: hardwood plywood, medium density fiberboard, and particleboard. There may be

multiple product grades or adhesive/emissions classes within a pressed wood category. (See definition of

“Adhesive/emissions class.”)

Pressed wood products. General term describing all types of primary and secondary pressed wood products

made from cellulosic material, usually wood, and an adhesive or resin bonding system that is cured under heat

and/or pressure.

Primary composite panel products. See “Primary pressed wood products” definition.

Primary pressed wood products. General term describing all types of primary products made from cellulosic

material, usually wood, and an adhesive or resin bonding system that is cured under heat and/or pressure.

Primary pressed wood products may be used in either industrial or construction applications in their “primary”

form, or converted into “secondary” pressed wood products through the application of a laminate, or coating, or

through shaping or assembly with other components.

Production technology. The production process and raw materials used to produce a composite panel product.

This includes the resin technology used (defined below).

Process controls. The system of motors, sensors, controllers, devices, operator interfaces, and sequencing logic

installed in a plant to control the primary composite panel product manufacturing process.

Recordkeeping costs. Costs associated with keeping records of inspections, tests, and any other procedures

whose records are normally kept under customary business practices.

Recurring costs. Costs incurred on an ongoing basis.

Research and development costs. Upfront costs necessary to test new production methods or refine the

manufacturing process prior to commercial production.
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Resin technology. The particular resin formulation (including scavengers and other additives) used and its

direct integration into the manufacturing process, including associated process controls and preparation,

application, and/or blending equipment.

Scavenger. An additive to a resin formulation that is intended to combine with free formaldehyde to convert it

to an inert reaction product.

Secondary composite panel products. See “Secondary products” definition.

Secondary pressed wood products. See “Secondary products” definition.

Secondary products. Products fabricated from or mainly composed of one or more primary pressed wood

products. Examples of secondary products include, but are not limited to, filled or coated products, low pressure

decorative laminates (LPDL), vinyl laminate, or the application of high pressure laminates (HPL), hot stamp

foils, low basis weight papers (LBWP), or medium or high density overlays (MDO or HDO) to a composite

wood panel substrate.

Start-up costs. Costs that are incurred initially after a production change, but that are not expected to be

incurred on a recurring basis.

Testing and certification costs. Cost of having primary composite panel products tested and of maintaining

certification.

Ultimate parent company. Highest level company, group of companies, or other legal entity that owns or

directly controls the reporting facility or plant, either within the U.S. or globally (if applicable). For example,

this may be the company that is quoted on a stock exchange.

Veneer. Thin sheets or strips of wood created by peeling or slicing logs. Normally used to make plywood.

Vinyl laminate. Thin vinyl films, usually two to six millimeters thick, commonly used as decorative overlays

on a variety of substrates. An adhesive is normally applied either to the vinyl or to the substrate and then cured

by a heated laminating roll press.

Figure 3 illustrates how some of the terms used in this survey relate to each other.
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Figure 3. Composite Panel Product Description

This figure illustrates how some of the terms used in this survey relate to each other.
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LIST OF ABBREVIATIONS

Abbreviation Description

CBI Confidential business information

N/A Not applicable

NAF No-added formaldehyde

ton Ton (2,000 pounds = 1 ton)

UA Unavailable

UF Urea formaldehyde

UK Unknown

ULEF Ultra-low emitting formaldehyde
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SURVEY OUTLINE

The questionnaire has eight sections:

I. General Manufacturer Identification Information;

II. Primary Pressed Wood Products Manufactured;

III. Changes to Achieve CARB Phase 1 Certification;

IV. Changes to Achieve CARB Phase 2 Certification;

V. Planned Changes to Achieve CARB Phase 2 Certification;

VI. Issues that May Affect Ability to Reduce Formaldehyde Emissions for Respondents Who

Do Not Intend to Become CARB Phase 2 Certified;

VII. Issues That May Affect Ability to Use a No-Added Formaldehyde (NAF) Resin; and

VIII. Secondary Products Manufactured.

The questions in each section are described in detail in the “Question-by-Question Instructions”.
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QUESTION-BY-QUESTION INSTRUCTIONS

Please answer all of the questions. Refer to the “General Definitions” section for further explanation

of certain key terms used throughout the questionnaire.

Section I: General Manufacturer Identification Information

Questions 1- 8.

The answers to the questions in this section have been pre-filled based on publicly available

information and the initial phone call to your plant. Please verify that the pre-filled information is

correct; if it is incorrect, or if there is any missing information, please provide corrections on the

line(s) following the question or check the appropriate boxes.

Before completing this portion of the questionnaire, see the General Definitions section of these

instructions for the explanation of the term “ultimate parent company”.



Why does EPA need this information? The information in Section I will be used

to ensure that your plant is properly identified and that the appropriate contacts are

available to answer any questions that EPA might have on the completed

questionnaire. Because of the complex relationships between and among

corporations, you are asked to distinguish between the parent company (legal

owner) of the plant and the company that operates the plant. Information about

the legal owner may be used by EPA in economic analyses that distinguish

between small and large businesses.

Section II: Primary Pressed Wood Products Manufactured

Before completing this portion of the questionnaire, see the General Definitions section of these

instructions for the explanation of the terms “primary pressed wood product”, “resin technology”,

“production technology”, and “planned change”.

Note that in this survey, “Adhesive/emissions class” means a class of pressed wood products that

differs from others based on binder/resin technology, formaldehyde emission certification standard

category, and/or formaldehyde emission profile. You need not report separately for products that

differ only based on physical characteristics such as thickness, density, or strength, but have the same

formaldehyde emission profile; these products may be reported together within the same

adhesive/emissions class.



For example: Your company currently makes two product lines. One,

RegularResinTM panel, is made with UF resin and is CARB Phase 1 certified. The

other, UltraGreenTM panel, is certified as CARB NAF. Both RegularResinTM and

UltraGreenTM are made in multiple thicknesses designed for different applications.

But within each product line, all of the products use the same resin and have the

same emissions profile. So for the purpose of reporting to this survey, report all of

the information for RegularResinTM as one adhesive/emissions class, and all of the

information for UltraGreenTM as another adhesive/emissions class.
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

For example: Your company currently makes two product lines. One,

NormalThickness®panel, is made with UF resin and is CARB Phase 1 certified.

The other, ExtraThin®panel, is also made with UF resin and is CARB Phase 1

certified. Although both products use the same resin and are Phase 1 certified,

they are very different in terms of thickness and as a result they have different

actual emissions levels. So for the purpose of reporting for this survey, report all of

the information for NormalThickness®as one adhesive/emissions class, and all of

the information for ExtraThin®as another adhesive/emissions class.

Question 9. Primary Composite Panel Products Manufactured and Production Volume.

Please complete the table. Note that in column 3 of Question 9 you need only to provide the

aggregate estimated average volume of primary composite panel products manufactured at your plant

(over the five year period between 2005 and 2009) for each of the pressed wood categories you make,

summed over all thicknesses or other physical properties produced.

Question 10. Regions Where Pressed Wood Products Manufactured at Your Plant are Sold. Please

check all applicable boxes to indicate the geographical regions where the pressed wood products that

were manufactured at your plant were sold and are expected to be sold.



Why does EPA need this information? The information in Question 9 helps

EPA understand what categories of primary pressed wood products you

manufacture. The volumes may be used in EPA economic analyses to determine

your plant’s share of national production in order to estimate the aggregate volume

meeting various emission levels and/or certification standards.

Question 10 will allow EPA to correlate responses with any existing current

regulations that are applicable to your plant’s products (such as regulations that

cover certain products sold in California or in foreign markets).

EPA is asking about the past five years to get a longer term perspective about any

changes that have occurred. EPA is asking about the next three years to get a

multi-year prediction that is within a reasonable planning horizon.

Question 11. Hardwood Plywood is Produced at this Plant. If hardwood plywood is produced at your

facility please check all applicable boxes and fill in the appropriate blanks.

Question 12. Medium Density Fiberboard is Produced at this Plant. If medium density fiberboard is

produced at your facility please check all applicable boxes and fill in the appropriate blanks. When

Question #12(f) asks about the importance of appearance to your customers, it is asking about the

appearance of the boards themselves, since this might be impacted by changes to resin composition or

other inputs in order to reduce formaldehyde emissions. The question is not asking about the

importance of decorative overlays and coatings, unless the ability to use these overlays and coatings

might be affected by changes to reduce formaldehyde emissions.

Question 13. Particleboard is Produced at this Plant. If particleboard is produced at your facility please

check all applicable boxes and fill in the appropriate blanks. When Question #13(f) asks about the

importance of appearance to your customers, it is asking about the appearance of the boards

themselves, since this might be impacted by changes to resin composition or other inputs in order to

reduce formaldehyde emissions. The question is not asking about the importance of decorative

overlays and coatings, unless the ability to use these overlays and coatings might be affected by

changes to reduce formaldehyde emissions.



Why does EPA need this information? Questions 11-13 provide information to

EPA about the characteristics of your plant that may influence your ability to use

various technology options for lowering formaldehyde emissions.
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Question 14. Resin Types and Certification Standards. Please aggregate the information by

adhesive/emissions class for each pressed wood category produced at your facility – that is, complete

one row for each group of products with similar formaldehyde emissions profiles. The sample

response in the table explains how to report for hybrid systems using different resins in the face and

core layers.

A list of binder/resin categories and certification standard categories is provided at the bottom of

the table.

NOTE: Please complete this table for each adhesive/emissions class of each pressed wood category

produced at your facility. If you need more space than the table provides, click the “Add Copy”

button to have the electronic version of this form automatically generate an additional copy of the

table. If you are using the paper version of the form, please use the extra copies provided and make

additional copies as necessary.

Column 1: Pressed Wood Category. Indicate the pressed wood category by selecting from the

dropdown menu on the electronic form or entering the appropriate pressed wood category

abbreviation listed below the table.

Column 2: Adhesive/Emissions Class. Indicate the adhesive/emissions class. The different

adhesive/emissions class can simply be numbered (as in the example) or labeled more

descriptively if desired.

Binder/Resin Categories: Columns 3, 4, and 5 ask about the binders and resins used to manufacture

your products.

Column 3: Previous Binder/Resin Category. If you changed resin technology categories since the

beginning of 2005, indicate the resin technology category that was previously used. If you

changed resins more than once since the beginning of 2005, indicate the resin technology

category that was most recently used before the one you currently use. If you have not

changed resin technology categories since the beginning of 2005, enter “not applicable” or

“N/A”.

Column 4: Current Binder/Resin Category. If you use more than one resin technology for a pressed

wood category, list all that are applicable in separate rows.



For example: If last year you produced an MDF panel using a urea-formaldehyde

resin, but you currently produce this product using a MUF resin for the face layers

and a UF resin for the core, and next year you plan to modify the resins you

currently use by adding scavengers, you should report this as shown in row one of

the example in the questionnaire.



For example: If you began production of a new grade of MDF two years ago

using a urea-formaldehyde resin with added scavengers that you have not

changed since you began production, but you intend to produce this product next

year using a MUF resin with added scavengers, you should report this as shown in

row two of the example in the questionnaire.



For example: If you switched last year from a urea-formaldehyde resin with

added scavengers to a methylene diisocyanate resin, enter “UF+s” in Column 3

(“Previous”) and “pMDI” in Column 4 (“Current”).
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

For example: If you switched last year from a urea-formaldehyde resin to a

mixture of a urea-formaldehyde resin and a soy resin, enter “UF” in Column 3

(“Previous”) and “UF+SBR” in Column 4 (“Current”). If you switched to a mixture of

a urea-formaldehyde resin, a soy resin, and an added scavenger, enter

“UF+SBR+s” in Column 4 (“Current”).

 For example: If last year you produced all your particleboard using a ureaformaldehyde resin with added scavengers, and you currently continue to produce

particleboard using the same resin formulation, but now you also produce a noadded formaldehyde class of particleboard using a methylene diisocyanate resin,

you should complete two rows in the particleboard category, one for products

made with UF resin and another for products made with pMDI.

Column 5: Planned Changes to Binder/Resin Category. If your plant has specific plans to change

resin technologies between now and the end of 2012, indicate the resin technology category that will

be used. If you do not plan to change resin technology categories, enter “not applicable” or “N/A”. If

plan to change resins but you are not sure which changes you will make because you are still

considering more than one possible resin technology (e.g., both enhanced UF resins and soy-based

resins), please report the resin you consider most likely and use this as the basis for your response.



For example: If you expect to switch next year from a urea-formaldehyde resin to

a melamine-urea-formaldehyde resin with added scavengers, enter “MUF+s” in

column 5 (“Planned Changes”).

Formaldehyde Emission Certification Standard Category: Columns 6, 7, and 8 ask about the

emission certification standards you meet for the products you manufacture. In this survey, the

“formaldehyde emission certification standard category” means the emission standard you meet

that requires the lowest product formaldehyde emissions. If your product does not meet an emissions

certification standard, enter “None”. If there is no emissions standard that applies to your product,

answer “N/A”.

Column 6: Previous Certification Category. If the formaldehyde emissions standard in Column 7

was met only as a result of resin technology or production technology changes made since

the beginning of 2005, indicate the formaldehyde emissions standard previously met by

the product, if any.

Column 7: Current Certification Category. Indicate the formaldehyde emissions standard that is

currently met.

Column 8: Planned Changes to Certification Category. If your plant has specific plans to meet a

formaldehyde emissions standard between now and the end of 2012 (that it does not

currently meet), indicate the emissions standard that will be met.

Question 15. Formaldehyde Emission Levels from Finished Boards. This question asks about emissions

from finished boards – do not report stack or fugitive emissions of formaldehyde. In this survey,

“finished boards” refers to primary pressed wood boards, not secondary or value-added products.

For average and maximum emissions, provide results from a standard test method for a large or small

chamber test. A standard test method means a standardized laboratory method or testing protocol,

such as those published by the American Society for Testing and Materials (ASTM) and/or those

approved for use under CARB, the Japanese F-star program, or the European E1 program. See Figure

4 at the end of these instructions for examples of common test measurement methods. Provide

emission levels as large chamber equivalent emissions if possible. If you can not report results as

large chamber equivalent emissions, please indicate this in the space provided above the table.
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If you have been making the adhesive/emissions class for a year or more, calculate the average and

maximum emissions over the past year. If you have not been making the product for a full year,

calculate the average and maximum over whatever time frame you manufactured the

adhesive/emissions class. If you have test data showing that the actual maximum emissions level from

your product is lower than the maximum allowed by the certification standard you meet, report the

actual maximum. In addition, the emissions levels reported should only include those from products

tested within typical certification timeframes (i.e., tests performed within 30 days of production).

These levels may exceed the emissions levels when the product is ultimately shipped. Please specify

the units for the emissions data, such as parts per million (ppm).

Please report a separate line in the table for each different adhesive/emissions class reported in

Question 14. If you are using the electronic version of the form, it will automatically fill Question 15

with the pressed wood categories and adhesive/emissions classes that you reported in Question 14. If

you selected the “Add Copy” button in Question 14, the electronic version of the form will

automatically generate an additional copy of the table for Question 15. If you are using the paper

version of the form, please use the extra copies provided and make additional copies as necessary, and

list the pressed wood categories and adhesive/emissions classes in the order that you reported them in

Column 1 and Column 2 of Question 14.

Column 1: Pressed Wood Category. If you are using the electronic version of the form this column

will be automatically filled based on your responses to question 14. If you are using the

paper version, indicate the pressed wood category by entering the appropriate pressed

wood category abbreviation listed below the table.

Column 2: Adhesive/Emissions Class. If you are using the electronic version of the form this column

will be automatically filled based on your responses to question 14. If you are using the

paper version, indicate the adhesive/emissions class. The different adhesive/emissions

class can simply be numbered (as in the example) or labeled more descriptively if desired.

Columns 3 and 4: Previous Emission Levels. If the current formaldehyde emissions levels listed in

Columns 5 and 6 has changed due to manufacturing changes implemented since the

beginning of 2005, indicate the average and maximum formaldehyde emission rate prior to

the current level.

Columns 5 and 6: Current Emission Levels. Indicate the average and maximum formaldehyde

emission levels for the emissions category that you currently meet.

Columns 7 and 8: Planned Emission Levels. If your plant has specific plans to achieve a

formaldehyde emission level for that pressed wood category between now and the end of

2012, enter the anticipated average and maximum emission levels.

Columns 9 and 10: Share of Production. Please provide the relative share of production volume for

each adhesive/emissions class. In column 9, provide the total annual production share

using the current binder/resin technology and production process, in percent. For

example, if four fifths of your production is for a given adhesive/emissions class within a

pressed wood category, enter “80%”. The sum of the shares reported within each pressed

wood category should equal 100 percent.

In column 10, report the estimated annual production shares that are anticipated after

planned changes to raw materials and production processes to reduce formaldehyde

emissions are completed, whenever the change is planned to occur. (For example, if you

have a change planned for 2011 that will reduce formaldehyde emissions, report the

production shares expected for 2011.) If you do not plan on making any changes to

reduce formaldehyde emissions, report the estimated annual production shares that are

anticipated in 2012. For example, if you plan for all of your production of the pressed

wood category to be the given adhesive/emissions class in the future, enter “100%”. If
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you cannot estimate the expected future shares of production will be, enter “UK.” The sum

of the shares reported within each pressed wood category should equal 100 percent.



Why does EPA need this information? Questions 14 and 15 provide information

on the type of resins and binders used in the industry and the formaldehyde

emission certification standards and emissions levels for products. The information

also helps EPA to understand the relative importance of the different classes of

products.

This information is important given the ongoing changes in the industry due to the

California Air Resources Board (CARB) Airborne Toxics Control Measure (ATCM)

for formaldehyde emissions from primary pressed wood products, the growing

demand for green building products, etc. This information will help EPA determine

whether any action is necessary regarding formaldehyde emissions from pressed

wood products.

Sections III and IV: Changes to Achieve CARB Phase 1 or Phase 2 Emission Requirements

Please complete questions 16 through 18 (Section III) if you have made changes to your production

process or raw materials for the purpose of achieving CARB Phase 1 certification. Please complete

questions 19 through 21 (Section IV) if you have made changes to your production process or raw

materials for the purpose of achieving CARB Phase 2 certification. If you bypassed CARB Phase 1

certification and your initial CARB certification was for Phase 2, you should skip Section III and

complete Section IV.

A separate copy of Section III needs to be completed for each adhesive/emissions class of each

pressed wood category where there were recent changes to achieve CARB Phase 1 certification.

Similarly, complete a separate copy of Section IV for each adhesive/emissions class of each pressed

wood category where there were recent changes to achieve CARB Phase 2 certification.

Click the “Add Copy” button on the survey to have the electronic version of this form automatically

generate an additional copy of Section III or IV. If you are using the paper version of the form, please

use the extra copies provided and make additional copies as necessary.

Before completing this portion of the questionnaire, see the General Definitions section of these

instructions for the explanation of the term “adhesive/emissions class”.

The categories in the cost questions (materials, labor, energy, recordkeeping, testing, reject rates,

productivity, downtime, etc.) are not meant to overlap. In order to avoid double-counting costs, do not

report the same cost under more than one category.

Do not repeat your Section III responses in Section IV unless there was another similar change to

achieve Phase 2 certification. For example, if you added a catalyst to your resin to achieve Phase 1

certification, indicate that in Question 16(b). If you then changed your again catalyst to meet Phase 2,

indicate that in Question 19(b). But if you continued to use the same catalyst to meet Phase 2, do not

check “Addition of catalysts to resin” in Question 19(b).
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Questions 16 & 19. Changes to production processes or raw materials. Please check all applicable boxes

and provide responses in the space provided. Questions 16(d) and 19(d) ask you to either provide an

estimate of the costs or choose an estimated range for the costs that you expect to incur for optimizing

your production process. Please enter either a single dollar value or a range, but not both. If you are

using the electronic version of the form and wish to report a range, you may use the drop down box to

select from the ranges provided. If you are using the paper version of the form and wish to report a

range, please choose one of the following ranges and write the letter that corresponds to that range in

the space provided (e.g., to indicate that costs are between $5,000 and $9,999, write “B” in the space

provided):

(A) < $5,000

(B) $5,000 to $9,999

(C) $10,000 to $24,999

(D) $25,000 to $49,999

(E) $50,000 to $99,999

(F) $100,000 to $249,999

(G) $250,000 to $499,999

(H) $500,000 to $999,999

(I) > $1 million



Why does EPA need this information? Questions 16 through 21 provide

information about the issues that might affect manufacturers’ ability to reduce

formaldehyde emissions, the types of changes to production processes or raw

materials that have been made to reduce formaldehyde emissions, and the costs

of addressing these issues. EPA will use this information to understand the

feasible options for reducing formaldehyde emissions, and to assess the extent to

which formaldehyde emissions are already being reduced

Questions 17 & 20. Issues your plant addressed in order to achieve CARB Phase 1 or 2 certification.

These questions ask about the issues that your plant addressed in order to implement recent changes to

the production processes or to the raw materials for the purpose of achieving CARB Phase 1 (Question

17) or Phase 2 (Question 20) certification for the products manufactured at your plant.

Questions 18 & 21. Estimated costs of changes to the production processes or raw materials. These

questions ask about the costs that were incurred in order to implement recent changes to the production

processes or to the raw materials to achieve CARB Phase 1 or Phase 2 certification for products

manufactured at your plant.

Questions 18(a) to 18(c), 18(f), 21(a) to 21(c), and 21(f) ask you to either provide an estimate of the

total costs or choose an estimated range for the total costs that you have incurred for making changes

to the production processes or to the raw materials to achieve CARB Phase 1 or Phase 2 certification.

Please enter either a single dollar value or a range, but not both. If you are using the electronic version

of the form and wish to report a range, you may use the drop down box to select from the ranges

provided. If you are using the paper version of the form and wish to report a range, please choose one

of the following ranges and write the letter that corresponds to that range in the space provided (e.g., to

indicate that costs are between $5,000 and $9,999, write “B” in the space provided):

(A) < $5,000

(B) $5,000 to $9,999

(C) $10,000 to $24,999

(D) $25,000 to $49,999

(E) $50,000 to $99,999

(F) $100,000 to $249,999

(G) $250,000 to $499,999

(H) $500,000 to $999,999

(I) > $1 million
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Questions 18(d), 18(e), 18(g), 18(i)-18(l), 21(d), 21(e), 21(g), and 21(i) to 21(l) ask you to either

provide an estimate of the costs per thousand square feet of production or provide an estimated range

for the costs per thousand square feet of production that you incurred for making changes to the

production processes or to the raw materials to achieve CARB Phase 1 or Phase 2 certification. Please

provide a single estimate if you are able to do so. If you are unable to provide a single estimate, please

provide an estimated range for the costs you incurred.

See the General Definitions section of these instructions if you need further explanation of the

terms “research and development”, “modifications to existing equipment”, “new equipment

costs”, “additive”, “post-press treatment”, “recordkeeping costs”, and “testing and

certification costs”.

Section V: Planned Changes to Achieve CARB Phase 2 Emission Requirements

Please complete questions 22 through 24 if you:

1. Anticipate making changes to your production process or raw materials for the purpose of

achieving CARB Phase 2 certification;

2. Have already achieved CARB Phase 2 certification but you anticipate making additional

changes to production processes or raw materials for the purpose of optimizing the production

processes for your CARB Phase 2 certified products; or

3. Have already achieved CARB Phase 2 certification but you anticipate making additional

changes to production processes or raw materials for the purpose of achieving CARB Phase 2

ULEF or NAF certification.

If you will need to address different issues to achieve CARB Phase 2 certification for different

products in a pressed wood category (for example, MDF and thin MDF, or products made with UF

resin and products made with MF resin), please complete a separate copy of Section V for each group

of products where similar issues will need to be addressed. You may choose to complete a separate

copy of Section V for each adhesive/emissions class, complete a separate copy of Section V for a

group of adhesive/emissions classes, or simply complete a separate copy of Section V for an entire

pressed wood category.

If you are not sure which changes you will make to achieve CARB Phase 2 certification because you

are still considering more than one possible approach (e.g., both enhanced UF resins and soy-based

resins), please use the approach you consider most likely as the basis for your responses in Section V.

Adhesive/emissions class means a class of pressed wood products that differs from others based on

binder/resin technology, formaldehyde emission certification standard category, and/or formaldehyde

emission profile.

Click the “Add Copy” button on the survey to have the electronic version of this form automatically

generate an additional copy of Section V. If you are using the paper version of the form, please use

the extra copies provided and make additional copies as necessary.

The categories in the cost questions (materials, labor, energy, recordkeeping, testing, reject rates,

productivity, downtime, etc.) are not meant to overlap. In order to avoid double-counting costs, do not

report the same cost under more than one category.

Do not repeat your Section III or IV responses in Section V unless you plan to make another similar

change. For example, if you indicated in Question 19(b) that you added a catalyst to your resin to

achieve Phase 2 certification, indicate that in Question 19(b), do not check “Addition of catalysts to

resin” in Question 22(b) unless you plan to change your catalyst to optimize production or achieve

ULEF or NAF certification.

Question 22. Planned changes to production processes or raw materials. In Question 22(a), specify the

pressed wood category manufactured at your plant: hardwood plywood, medium density fiberboard, or
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particleboard. Indicate the adhesive/emissions class(es) for the group of products if applicable. Please

answer the remaining sub-questions in Question 22 as related to this group of products.



Why does EPA need this information? Question 22 provides information about

the types of changes to production processes or raw materials that will be made

to reduce formaldehyde emissions. This information will help EPA to determine

the types of changes manufacturers plan to make to reduce formaldehyde

emissions, and whether any EPA action to reduce formaldehyde emissions from

pressed wood products is necessary.

Question 23. Issues your plant is expected to address in order to achieve CARB Phase 2 certification,

optimize your process, or become certified as ULEF or NAF. Please check all applicable boxes

and provide responses in the space provided.



Why does EPA need this information? EPA needs information about the

issues that might affect manufacturer’s ability to reduce formaldehyde emissions

in order to determine what options might be technically feasible.

Question 24. Estimated costs of planned changes to the production processes or raw materials. These

questions ask about the costs that are expected to be incurred in order to achieve CARB Phase 2

certification, to optimize your production process, or to achieve CARB ULEF or NAF certification.

Questions 24(a) to 24(c), and 24(f) ask you to either provide an estimate of the total costs or choose an

estimated range for the total costs that you expect to incur for making changes to the production

processes or to the raw materials to achieve CARB Phase 2 certification, optimize your process, or

achieve ULEF or NAF certification. Please enter either a single dollar value or a range, but not both.

If you are using the electronic version of the form and wish to report a range, you may use the drop

down box to select from the ranges provided. If you are using the paper version of the form and wish

to report a range, please choose one of the following ranges and write the letter that corresponds to that

range in the space provided (e.g., to indicate that costs are between $5,000 and $9,999, write “B” in

the space provided):

(A) < $5,000

(B) $5,000 to $9,999

(C) $10,000 to $24,999

(D) $25,000 to $49,999

(E) $50,000 to $99,999

(F) $100,000 to $249,999

(G) $250,000 to $499,999

(H) $500,000 to $999,999

(I) > $1 million

Questions 24(d), 24(e), 24(g), and 24(i) to 24(l) ask you to either provide an estimate of the costs per

thousand square feet of production or provide an estimated range for the costs per thousand square feet

of production that you expect to incur for making changes to the production processes or to the raw

materials to achieve CARB Phase 2 certification, optimize your process, or achieve ULEF or NAF

certification. Please provide a single estimate if you are able to do so. If you are unable to provide a

single estimate, please provide an estimated range for the costs you expect to incur.

See the General Definitions section of these instructions if you need further explanation of the terms

“research and development”, “modifications to existing equipment”, “new equipment costs”,

“additive”, “post-press treatment”, “recordkeeping costs”, and “testing and certification costs”.
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

Why does EPA need this information? EPA needs information about the

expected costs of reducing formaldehyde emissions in order to consider the costs

of potential actions to reduce formaldehyde emissions in the future.

Section VI: Issues That May Affect Ability to Reduce Formaldehyde Emissions for

Respondents Who Do Not Intend to Become CARB Phase 2 Certified

If you make products that you do not intend to have CARB Phase 2 certified because they do not meet

the definition of definitions of hardwood plywood, medium density fiberboard, or particleboard in the

CARB ATCM (e.g., curved plywood) or they are exempt from the CARB ATCM (e.g., you intend on

selling all of the production outside of California), please complete Question 25.

Please complete a separate copy of Question 25 for each pressed wood category that you do not intend

to have Phase 2 certified. If you would need to address different issues to achieve CARB Phase 2

certification for different products in a pressed wood category (for example, MDF and thin MDF, or

products made with UF resin and products made with MF resin), please complete a separate copy of

Question 25 for each group of products where similar issues would need to be addressed. You may

choose to complete a separate copy of Question 25 for each adhesive/emissions class, complete a

separate copy of Question 25 for a group of adhesive/emissions classes, or simply complete a separate

copy of Question 25 for an entire pressed wood category.

Click the “Add Copy” button on the survey to have the electronic version of this form automatically

generate an additional copy of Section VI. If you are using the paper version of the form, please use

the extra copies provided and make additional copies as necessary.

Question 25. Please indicate the issues your plant would need to address in order to adopt a lower

emission technology to meet CARB Phase 2 formaldehyde emission limits. These questions ask

about the issues that your plant would need to address in order to implement changes to the production

processes or to the raw materials for the purpose of reducing the formaldehyde emissions to achieve

CARB Phase 2 compliance.



Why does EPA need this information? EPA needs information about the

issues that might affect manufacturer’s ability to reduce formaldehyde emissions

in order to determine what options might be technically feasible.

Section VII: Issues That May Affect Ability to Use a No-Added Formaldehyde (NAF) Resin

Please complete a separate copy of Question 26 for each pressed wood category manufactured at your

plant, with the following exceptions:

1. The pressed wood category has no added formaldehyde; or

2. The pressed wood category will have no added formaldehyde after making the planned

changes to the production process or raw materials reported in Questions 22 through 24.

If you would need to address different issues to use a NAF resin for different products in a pressed

wood category (for example, MDF and thin MDF, or products made with UF resin and products made

with MF resin), please complete a separate copy of Question 26 for each group of products where

similar issues would need to be addressed. You may choose to complete a separate copy of Question

26 for each adhesive/emissions class, complete a separate copy of Question 26 for a group of
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adhesive/emissions classes, or simply complete a separate copy of Question 26 for an entire pressed

wood category.

Click the “Add Copy” button on the survey to have the electronic version of this form automatically

generate an additional copy of Section VII. If you are using the paper version of the form, please use

the extra copies provided and make additional copies as necessary.

Question 26. Please indicate the issues your plant would need to address in order to adopt a no-added

formaldehyde (NAF) resin technology. These questions ask about the issues that your plant would

need to address in order to implement changes to the production processes or to the raw materials for

the purpose of adopting an NAF resin technology.



Why does EPA need this information? This information will help EPA

determine in what circumstances NAF resin technology might be a feasible option

for reducing formaldehyde emissions.

Section VIII: Secondary Products Manufactured

Question 27. Resins and Binders for Secondary Pressed Wood Products Manufactured. If you

manufacture secondary wood products, please complete this table to provide information

about the categories of secondary products that your plant manufactures, the resins/binders

used in each, and the primary pressed wood products used as inputs. Use the codes at the

bottom of the table to indicate the binder/resin technology used in the secondary

manufacturing process and the primary pressed wood product(s) used in manufacturing this

secondary product. Please include resins in saturated papers when reporting the resin/binder

used. Refer to the table header for instructions on how to complete the table if you use more

than one resin for a single product, or if you use different resins to manufacture different

secondary products.

See the General Definitions section of these instructions for a description of the product

categories reportable as secondary pressed wood products.



Why does EPA need this information? The coatings and coverings used in

secondary products, and the resins used to adhere them, may affect formaldehyde

emissions from panel products. EPA needs this information to better understand

the materials being used to manufacture secondary products.
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Figure 4. Common Standard Test Methods for Formaldehyde Emissions

This table presents some examples of common standard test methods. Note that this list may not be

complete and additional test methods may have been approved by CARB since the publication of this

document.

Number Description CARB-Approved

ASTM E 1333-96 Standard Test Method for

Formaldehyde Concentrations in Air

and Emission Rates from Wood

Products Using a Large Chamber

CARB primary test method

ASTM D 5582-00 Standard Test Method for

Determining Formaldehyde Levels

from Wood Products Using a

Dessicator

CARB small-scale quality control

ASTM D 6007-02 Standard Test Method for

Determining Formaldehyde

Concentrations in Air and Emission

Rates from Wood Products Using a

Small Chamber

CARB small-scale quality control

EN 120 Wood based panels—determination

of formaldehyde content—extraction

method called perforator method,

European Standard

CARB alternate small-scale quality control

EN 717-2 Wood-based panels—determination

of formaldehyde release—Part 2:

formaldehyde release by the gas

analysis method, European Standard

CARB alternate small-scale quality control

JIS A 1460 Building boards. Determination of

formaldehyde emission—desiccator

method, Japanese Industrial Standard

CARB alternate small-scale quality control

EN 717-1 Wood-based panels—determination

of formaldehyde release—Part 1:

formaldehyde emission by the

chamber method. European Standard.

EN 717-3 Wood-based panels—determination

of formaldehyde release—Part 3:

formaldehyde release by the flask

method, European Standard

ISO/DIS 12460 Wood-based panels — Determination

of formaldehyde release — Part 4

JIS A 1901 Determination of the emission of

volatile organic compounds and

aldehydes for building products—

small chamber method, Japanese

Industrial Standard