Sector Notebook Project Wood Furniture and Fixtures 

This report is one in a series of volumes published by the U.S. Environmental 

Protection Agency (EPA) to provide information of general interest regarding 

environmental issues associated with specific industrial sectors. The documents 

were developed under contract by Abt Associates (Cambridge, MA), and BoozAllen & Hamilton, Inc. (McLean, VA). This publication may be purchased from the 

Superintendent of Documents, U.S. Government Printing Office. A listing of 

available Sector Notebooks and document numbers is included on the following 

page. 

All telephone orders should be directed to: 

Superintendent of Documents 

U.S. Government Printing Office 

Washington, DC 20402 

(202) 512-1800 

FAX (202) 512-2250 

8:00 a.m. to 4:30 p.m., EST, M-F 

Using the form provided at the end of this document, all mail orders should be 

directed to: 

U.S. Government Printing Office 

P.O. Box 371954 

Pittsburgh, PA 15250-7954 

Complimentary volumes are available to certain groups or subscribers, such as 

public and academic libraries, Federal, State, local, and foreign governments, and 

the media. For further information, and for answers to questions pertaining to these 

documents, please refer to the contact names and numbers provided within this 

volume. 

Electronic versions of all Sector Notebooks are available free of charge at the 

following web address: www.epa.gov/oeca/sector. Direct technical questions to the 

�Feedback� button at the bottom of the web page. 

September 1995 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

EPA/310-R-95-003

EPA Office of Compliance 

Sector Notebook Project 

Profile of the Wood Furniture and 

Fixtures Industry 

September 1995 

Office of Compliance 

Office of Enforcement and Compliance Assurance 

U.S. Environmental Protection Agency 

401 M St., SW (MC 2221-A) 

Washington, DC 20460 

SIC Code 25 ii September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

Sector Notebook Contacts 

The Sector Notebooks were developed by the EPA�s Office of Compliance. Questions 

relating to the Sector Notebook Project can be directed to: 

Seth Heminway, Coordinator, Sector Notebook Project

US EPA Office of Compliance

401 M St., SW (2223-A)

Washington, DC 20460

(202) 564-7017

Questions and comments regarding the individual documents can be directed to the 

appropriate specialists listed below. 

Document Number Industry 

(202) 

EPA/310-R-95-001. Dry Cleaning Industry

EPA/310-R-95-002. Electronics and Computer Industry*

EPA/310-R-95-003. Wood Furniture and Fixtures Industry

EPA/310-R-95-004. Inorganic Chemical Industry*

EPA/310-R-95-005. Iron and Steel Industry

EPA/310-R-95-006. Lumber and Wood Products Industry

EPA/310-R-95-007. Fabricated Metal Products Industry*

EPA/310-R-95-008. Metal Mining Industry

EPA/310-R-95-009. Motor Vehicle Assembly Industry

EPA/310-R-95-010. Nonferrous Metals Industry

EPA/310-R-95-011. Non-Fuel, Non-Metal Mining Industry

EPA/310-R-95-012. Organic Chemical Industry*

EPA/310-R-95-013. Petroleum Refining Industry

EPA/310-R-95-014. Printing Industry

EPA/310-R-95-015. Pulp and Paper Industry

EPA/310-R-95-016. Rubber and Plastic Industry

EPA/310-R-95-017. Stone, Clay, Glass, and Concrete Industry

EPA/310-R-95-018. Transportation Equipment Cleaning Ind.

EPA/310-R-97-001. Air Transportation Industry

EPA/310-R-97-002. Ground Transportation Industry

EPA/310-R-97-003. Water Transportation Industry

EPA/310-R-97-004. Metal Casting Industry

EPA/310-R-97-005. Pharmaceuticals Industry

EPA/310-R-97-006. Plastic Resin and Man-made Fiber Ind.

EPA/310-R-97-007. Fossil Fuel Electric Power Generation Ind.

EPA/310-R-97-008. Shipbuilding and Repair Industry

EPA/310-R-97-009. Textile Industry

EPA/310-R-97-010. Sector Notebook Data Refresh-1997

EPA/310-R-98-001. Aerospace Industry

EPA/310-R-98-002. Agricultural Chemical, Pesticide, and

Fertilizer Industry

EPA/310-R-98-003. Agricultural Crop Production Industry

EPA/310-R-98-004. Agricultural Livestock Production Ind.

EPA/310-R-98-005. Oil and Gas Exploration and Production

Industry 

Contact Phone 

Joyce Chandler 564-7073 

Steve Hoover 564-7007 

Bob Marshall 564-7021 

Walter DeRieux 564-7067 

Maria Malave 564-7027 

Seth Heminway 564-7017 

Scott Throwe 564-7013 

Jane Engert 564-5021 

Anthony Raia 564-6045 

Jane Engert 564-5021 

Rob Lischinsky 564-2628 

Walter DeRieux 564-7067 

Tom Ripp 564-7003 

Ginger Gotliffe 564-7072 

Seth Heminway 564-7017 

Maria Malave 564-7027 

Scott Throwe 564-7013 

Virginia Lathrop 564-7057 

Virginia Lathrop 564-7057 

Virginia Lathrop 564-7057 

Virginia Lathrop 564-7057 

Jane Engert 564-5021 

Emily Chow 564-7071 

Sally Sasnett 564-7074 

Rafael Sanchez 564-7028 

Anthony Raia 564-6045 

Belinda Breidenbach 564-7022 

Seth Heminway 564-7017 

Anthony Raia 564-6045 

Amy Porter 564-4149 

Ginah Mortensen (913)551-7864 

Ginah Mortensen (913)551-7864 

Dan Chadwick 564-7054 

September 1995 iii SIC Code 25
Wood Furniture and Fixtures Sector Notebook Project 

EPA/310-R-98-008. Local Government Operations John Dombrowski 564-7036

*Spanish translations available.

SIC Code 25 iv September 1995
Sector Notebook Project Wood Furniture and Fixtures 

WOOD FURNITURE AND FIXTURES

(SIC 25 )

TABLE OF CONTENTS

Page

LIST OF EXHIBITS....................................................................................................... vii, viii

LIST OF ACRONYMS ....................................................................................................... ix, x

I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT..........................................1

I.A. Summary of the Sector Notebook Project............................................1

I.B. Additional Information.........................................................................2

II. INTRODUCTION TO THE WOOD FURNITURE AND FIXTURES INDUSTRY ..............4

II.A. Introduction, Background, and Scope of the Notebook.....................4

II.B. Characterization of the Wood Furniture and Fixtures Industry .......6

II.B.1. Industry Size and Geographic Distribution.......................6

II.B.2. Product Characterization...................................................10

II.B.3. Economic Trends................................................................11

III. INDUSTRIAL PROCESS DESCRIPTION.....................................................................13

III.A. Industrial Processes in the Wood Furniture and Fixtures Industry13

III.A.1. Drying .................................................................................13

III.A.2. Machining ...........................................................................15

III.A.3. Assembly.............................................................................16

III.A.4. Pre-finishing .......................................................................17

III.A.5. Coating Application...........................................................17

III.A.6. Finishing..............................................................................19

III.B. Raw Material Inputs and Pollution Outputs.....................................24

III.B.1. Drying .................................................................................24

III.B.2. Machining ...........................................................................26

III.B.3. Assembly.............................................................................26

III.B.4. Pre-finishing .......................................................................26

III.B.5. Coating Application...........................................................27

September 1995 v SIC Code 25
Wood Furniture and Fixtures Sector Notebook Project 

WOOD FURNITURE AND FIXTURES

(SIC 25 )

TABLE OF CONTENTS (CONT'D)

Page 

III.B.6. Finishing .............................................................................28

III.B.7. Cleanup Operations ...........................................................30

III.C. Management of Chemicals in Wastestream......................................34

IV. CHEMICAL RELEASE AND TRANSFER PROFILE.....................................................36

IV.A. EPA Toxic Release Inventory for the Wood Furniture and Fixtures

Industry................................................................................................39

IV.B. Summary of the Selected Chemicals Released .................................44

IV.C. Other Data Sources..............................................................................49

IV.D. Comparison of Toxic Release Inventory Between Selected

Industries .............................................................................................50

V. POLLUTION PREVENTION OPPORTUNITIES ..........................................................53

V.A. Identification of Pollution Prevention Activities in Use and

Environmental and Economic Benefits of Each Pollution Prevention

Activity.................................................................................................54

V.B. Pollution Prevention Case Studies.....................................................60

VI. SUMMARY OF FEDERAL STATUTES AND REGULATIONS......................................64

VI.A. General Description of Major Statutes...............................................64

VI.B. Industry-specific Regulatory Requirements .....................................79

VI.C. Pending and Proposed Regulatory Requirements ...........................81

SIC Code 25 vi September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

WOOD FURNITURE AND FIXTURES

(SIC 25 )

TABLE OF CONTENTS (CONT'D)

Page 

VII. COMPLIANCE AND ENFORCEMENT HISTORY.......................................................86

VII.A. Furniture and Fixtures Industry Compliance History.....................90

VII.B. Comparison of Enforcement Activity Between Selected Industries92 

VII.C. Review of Major Legal Actions ..........................................................97

VII.C.1. Review of Major Cases.......................................................97

VII.C.2. Supplemental Environmental Projects .............................97

VIII. COMPLIANCE ACTIVITIES AND INITIATIVES.........................................................98

VIII.A. Sector-related Environmental Programs and Activities ..................98

VIII.B. EPA Voluntary Programs ...................................................................99

VIII.C. Trade Association/Industry Sponsored Activity ...........................104

VIII.C.1. Environmental Programs.................................................104

VIII.C.2. Summary of Trade Associations .....................................104

IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/

BIBLIOGRAPHY .....................................................................................................108

September 1995 vii SIC Code 25
Wood Furniture and Fixtures Sector Notebook Project 

WOOD FURNITURE AND FIXTURES

EXHIBITS INDEX

Page 

Exhibit 1 Facility Size Distribution of Household Furniture Manufacturers ...... 6

Exhibit 2 Facility Size Distribution of Wood Furniture Manufacturers............... 7

Exhibit 3 Geographic Distribution of the Furniture and Fixtures Industry......... 8

Exhibit 4 Geographic Distribution of the Wood Furniture and

Fixtures Industry....................................................................................... 9

Exhibit 5 Top Ten Wood Furniture Manufacturers - 1990 .................................. 10

Exhibit 6 Chemical Components of Pigments Found in Paint............................ 21

Exhibit 7 Flow Diagram for Wood Furniture Manufacturing............................. 23

Exhibit 8 Relative VOC Emissions......................................................................... 29

Exhibit 9 Inputs and Outputs of Wood Furniture Manufacturing

Facilities ..................................................................................31, 32, 33, 34

Exhibit 10 Source Reduction and Recycling Activity for (SIC 25) ........................ 35

Exhibit 11 Top 10 TRI Releasing Furniture Manufacturing

Facilities (SIC 25)..................................................................................... 40

Exhibit 12 Top 10 TRI Releasing Furniture and Fixtures Facilities ..................... 40

Exhibit 13 TRI Reporting Furniture Manufacturing Facilities

(SIC 25) by State ..................................................................................... 40

Exhibit 14 Releases for Furniture Manufacturing Facilities (SIC 25) in

TRI, by Number of Facilities ........................................................... 41, 42

Exhibit 15 Transfers for Furniture Manufacturing Facilities (SIC 25) in

TRI, by Number of Facilities .................................................................. 43

Exhibit 16 Pollutant Releases (Short Tons/Year) .................................................. 49

Exhibit 17 Summary of 1993 TRI Data .................................................................... 51

Exhibit 18 Toxic Release Inventory for Selected Industries .................................. 52

Exhibit 19 Pollution Prevention Matrix........................................................58, 59, 60

Exhibit 20 Ethan Allen Pollution Prevention Case Study Summary.................... 63

Exhibit 21 Impacts of Environmental Statutes on the Wood Furniture

Manufacturing Industry ........................................................76, 77, 78, 79

Exhibit 22 Summary of Proposed MACT Emission Limit..................................... 84

Exhibit 23 Summary of Work Practice Standards for the MACT and CTG......... 85

Exhibit 24 Five Year Enforcement and Compliance Summary for the

Furniture Industry .................................................................................. 91

Exhibit 25 Five Year Enforcement and Compliance Summary for

Selected Industries .................................................................................. 93

SIC Code 25 viii September 1995
Sector Notebook Project Wood Furniture and Fixtures 

WOOD FURNITURE AND FIXTURES 

EXHIBITS INDEX (CONT'D) 

Page 

Exhibit 26 One Year Enforcement and Compliance Summary for

Selected Industries .................................................................................. 94

Exhibit 27 Five Year Inspection and Enforcement Statute for

Selected Industries .................................................................................. 95

Exhibit 28 One Year Inspection and Enforcement Summary by Statute for

Selected Industries .................................................................................. 96

September 1995 ix SIC Code 25
Wood Furniture and Fixtures Sector Notebook Project 

WOOD FURNITURE AND FIXTURES

(SIC 25 )

LIST OF ACRONYMS

AFS - AIRS Facility Subsystem (CAA database)

AIRS - Aerometric Information Retrieval System (CAA database)

BIFs - Boilers and Industrial Furnaces (RCRA)

BOD - Biochemical Oxygen Demand

CAA - Clean Air Act

CAAA - Clean Air Act Amendments of 1990

CERCLA - Comprehensive Environmental Response, Compensation and

Liability Act 

CERCLIS - CERCLA Information System 

CFCs - Chlorofluorocarbons 

CO - Carbon Monoxide 

COD - Chemical Oxygen Demand 

CSI - Common Sense Initiative 

CWA - Clean Water Act 

D&B - Dun and Bradstreet Marketing Index 

ELP - Environmental Leadership Program 

EPA - United States Environmental Protection Agency 

EPCRA - Emergency Planning and Community Right-to-Know Act 

FIFRA - Federal Insecticide, Fungicide, and Rodenticide Act 

FINDS - Facility Indexing System 

HAPs - Hazardous Air Pollutants (CAA) 

HSDB - Hazardous Substances Data Bank 

IDEA - Integrated Data for Enforcement Analysis 

LDR - Land Disposal Restrictions (RCRA) 

LEPCs - Local Emergency Planning Committees 

MACT - Maximum Achievable Control Technology (CAA) 

MCLGs - Maximum Contaminant Level Goals 

MCLs - Maximum Contaminant Levels 

MEK - Methyl Ethyl Ketone 

MSDSs - Material Safety Data Sheets 

NAAQS - National Ambient Air Quality Standards (CAA) 

NAFTA - North American Free Trade Agreement 

NCDB - National Compliance Database (for TSCA, FIFRA, EPCRA) 

NCP - National Oil and Hazardous Substances Pollution Contingency Plan 

NEIC - National Enforcement Investigation Center 

NESHAP - National Emission Standards for Hazardous Air Pollutants 

NO - 2 Nitrogen Dioxide 

NOV - Notice of Violation 

SIC Code 25 x September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

WOOD FURNITURE AND FIXTURES

(SIC 25 )

LIST OF ACRONYMS (CONT'D)

NOX - Nitrogen Oxide

NPDES - National Pollution Discharge Elimination System (CWA)

NPL - National Priorities List

NRC - National Response Center

NSPS - New Source Performance Standards (CAA)

OAR - Office of Air and Radiation

OECA - Office of Enforcement and Compliance Assurance

OPA - Oil Pollution Act

OPPTS - Office of Prevention, Pesticides, and Toxic Substances

OSHA - Occupational Safety and Health Administration

OSW - Office of Solid Waste

OSWER - Office of Solid Waste and Emergency Response

OW - Office of Water

P2 - Pollution Prevention

PCS - Permit Compliance System (CWA Database)

POTW - Publicly Owned Treatments Works

RCRA - Resource Conservation and Recovery Act

RCRIS - RCRA Information System

SARA - Superfund Amendments and Reauthorization Act

SDWA - Safe Drinking Water Act

SEPs - Supplementary Environmental Projects

SERCs - State Emergency Response Commissions

SIC - Standard Industrial Classification

SO2 - Sulfur Dioxide

TOC - Total Organic Carbon

TRI - Toxic Release Inventory

TRIS - Toxic Release Inventory System

TCRIS - Toxic Chemical Release Inventory System

TSCA - Toxic Substances Control Act

TSS - Total Suspended Solids

UIC - Underground Injection Control (SDWA)

UST - Underground Storage Tanks (RCRA)

VOCs - Volatile Organic Compounds

September 1995 xi SIC Code 25 
Sector Notebook Project Wood Furniture and Fixtures 

WOOD FURNITURE AND FIXTURES 

(SIC 25) 

I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT 

I.A. Summary of the Sector Notebook Project 

Environmental policies based upon comprehensive analysis of air, 

water, and land pollution are an inevitable and logical supplement to 

traditional single-media approaches to environmental protection. 

Environmental regulatory agencies are beginning to embrace 

comprehensive, multi-statute solutions to facility permitting, 

enforcement and compliance assurance, education/outreach, research, 

and regulatory development issues. The central concepts driving the 

new policy direction are that pollutant releases to each environmental 

medium (air, water, and land) affect each other, and that 

environmental strategies must actively identify and address these 

inter-relationships by designing policies for the "whole" facility. One 

way to achieve a whole facility focus is to design environmental 

policies for similar industrial facilities. By doing so, environmental 

concerns that are common to the manufacturing of similar products 

can be addressed in a comprehensive manner. Recognition of the need 

to develop the industrial "sector-based” approach within the EPA 

Office of Compliance led to the creation of this document. 

The Sector Notebook Project was initiated by the Office of Compliance 

within the Office of Enforcement and Compliance Assurance (OECA) 

to provide its staff and managers with summary information for 

eighteen specific industrial sectors. As other EPA offices, States, the 

regulated community, environmental groups, and the public became 

interested in this project, the scope of the original project was 

expanded. The ability to design comprehensive, common sense 

environmental protection measures for specific industries is dependent 

on knowledge of several inter-related topics. For the purposes of this 

project, the key elements chosen for inclusion are: general industry 

information (economic and geographic); a description of industrial 

processes; pollution outputs; pollution prevention opportunities; 

Federal statutory and regulatory framework; compliance history; and 

a description of partnerships that have been formed between 

regulatory agencies, the regulated community, and the public. 

September 1995 1 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

For any given industry, each topic listed above could alone be the 

subject of a lengthy volume. However, in order to produce a 

manageable document, this project focuses on providing summary 

information for each topic. This format provides the reader with a 

synopsis of each issue, and references where more in-depth 

information is available. Text within each profile was researched from 

a variety of sources, and was usually condensed from more detailed 

sources pertaining to specific topics. This approach allows for a wide 

coverage of activities that can be further explored based upon the 

citations and references listed at the end of this profile. As a check on 

the information included, each notebook went through an external 

review process. The Office of Compliance appreciates the efforts of all 

those that participated in this process and enabled us to develop more 

complete, accurate, and up-to-date summaries. Many of those who 

reviewed this notebook are listed as contacts in Section IX and may be 

sources of additional information. The individuals and groups on this 

list do not necessarily concur with all statements within this notebook. 

I.B. Additional Information 

Providing Comments 

OECA's Office of Compliance plans to periodically review and update 

the notebooks and will make these updates available both in hard copy 

and electronically. If you have any comments on the existing 

notebook, or if you would like to provide additional information, 

please send a hard copy and computer disk to the EPA Office of 

Compliance, Sector Notebook Project, 401 M St., SW (2223-A), 

Washington, DC 20460. Comments can also be uploaded to the 

Enviro$en$e Bulletin Board or the Enviro$en$e World Wide Web for 

general access to all users of the system. Follow instructions in 

Appendix A for accessing these data systems. Once you have logged 

in, procedures for uploading text are available from the on-line 

Enviro$en$e Help System. 

Adapting Notebooks to Particular Needs 

The scope of the existing notebooks reflect an approximation of the 

relative national occurrence of facility types that occur within each 

sector. In many instances, industries within specific geographic 

regions or States may have unique characteristics that are not fully 

captured in these profiles. For this reason, the Office of Compliance 

encourages State and local environmental agencies and other groups to 

SIC Code 25 2 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

supplement or re-package the information included in this notebook to 

include more specific industrial and regulatory information that may 

be available. Additionally, interested States may want to supplement 

the "Summary of Applicable Federal Statutes and Regulations" section 

with State and local requirements. Compliance or technical assistance 

providers may also want to develop the "Pollution Prevention" section 

in more detail. Please contact the appropriate specialist listed on the 

opening page of this notebook if your office is interested in assisting us 

in the further development of the information or policies addressed 

within this volume. 

If you are interested in assisting in the development of new notebooks 

for sectors not covered in the original eighteen, please contact the 

Office of Compliance at 202-564-2395. 

September 1995 3 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

II. INTRODUCTION TO THE WOOD FURNITURE AND FIXTURES INDUSTRY 

This section provides background information on the size, geographic 

distribution, employment, production, sales, and economic condition 

of the Wood Furniture and Fixtures industry. The type of facilities 

described within the document are also described in terms of their 

Standard Industrial Classification (SIC) codes. Additionally, this 

section contains a list of the largest companies in terms of sales. 

II.A. Introduction, Background, and Scope of the Notebook 

The furniture and fixtures industry encompasses companies that 

manufacture household, office, store, public building, and restaurant 

furniture and fixtures. These practices correspond to the Standard 

Industrial Classification (SIC) code 25 created by the Bureau of the 

Census to track the movement of goods and services within the 

economy. Although it is difficult to determine the exact number of 

facilities that fall within SIC code 25, 1987 Census data indicate that 

there were approximately 11,000 furniture manufacturing facilities in 

operation (complete 1992 Census data were not available). 

SIC 25, Furniture and Fixtures, consists of the following five threedigit industry groups: 

SIC 251 - Household Furniture

SIC 252 - Office Furniture

SIC 253 - Public Building and Related Furniture

SIC 254 - Partitions, Shelving, Lockers, and Office and

Store Fixtures 

SIC 259 - Miscellaneous Furniture and Fixtures. 

The following discussion focuses on SIC 251 because a majority of the 

wood furniture manufacturing facilities fall into this SIC code and the 

facilities in this SIC code tend to be the most heavily regulated. The 

Bureau of the Census estimates that in 1992, 256,000 people were 

employed by the household furniture manufacturing sector (SIC 251) 

of the furniture industry, a decline of approximately 10 percent from 

1987. The 1993 value of shipments for these firms exceeded $22 

billion, representing an increase of approximately seven percent over 

the previous year. Sales from the household furniture manufacturing 

industry were expected to rise by four percent in 1994. 

SIC Code 25 4 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

The household furniture manufacturing industry (SIC 251) consists of 

producers of wood furniture (SIC 2511), accounting for 42 percent of 

household furniture industry shipments in 1993; upholstered furniture 

(SIC 2512), accounting for 30 percent of shipments; metal furniture 

(SIC 2514), accounting for ten percent of shipments; and miscellaneous 

furniture (SIC 2517 and 2519), accounting for four percent of 

shipments. 

This industry is comprised of the production of many different types 

of products including wood household furniture, metal household 

furniture, mattresses, machine cabinets, shelving, and lockers. Because 

the items produced vary greatly in design depending upon the type of 

material used, style, price, and final use, the different types of 

machinery used in the various phases of production can reach into the 

hundreds or even thousands. This diversity of products provides a 

challenge for most manufacturers. 

Production lines for assembling furniture are costly, and because of 

this most manufacturers do not supply an exceptionally large range of 

items. To combat this problem, many firms specialize their production 

processes, allowing facilities to fill a specific niche in the market while 

still retaining flexibility in their manufacturing area. Manufacturers 

may specialize depending on the product manufactured, the product 

group, or the production process. Specialization has also allowed 

manufacturers to focus on quality by more carefully monitoring the 

entire production process, from raw material to finished product. 

Because SIC 25 covers such a diverse group of products, much of this 

profile will concentrate on the wood furniture manufacturing industry 

as defined by the following SIC codes: 

SIC 2511 - Wood Household Furniture, Except Upholstered 

SIC 2512 - Wood Household Furniture, Upholstered 

SIC 2517 - Wood Television, Radio, Phonograph, and Sewing 

Machine Cabinets 

SIC 2521 - Wood Office Furniture 

SIC 2531 - Public Building and Related Furniture 

SIC 2541 - Wood Office and Store Fixtures, Partitions, 

Shelving, and Lockers. 

All discussions on production processes and applicable regulations 

will be limited to activities covered by these four-digit SIC codes. 

September 1995 5 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

II.B. Characterization of the Wood Furniture and Fixtures Industry 

The discussion of the characterization of the wood furniture and 

fixtures industry is divided into the following four topics: industry 

size and geographic distribution, profile of the top ten furniture 

manufacturers, characterization of products, and economic health and 

outlook. 

II.B.1. Industry Size and Geographic Distribution 

Variation in facility counts occur across data sources due to many 

factors, including reporting and definitional differences. This 

document does not attempt to reconcile these differences, but rather 

reports the data as they are maintained by each source. 

Size Distribution 

According to 1987 Census data, approximately 63 percent of 

household furniture manufacturing facilities (SIC 251) have fewer than 

20 employees. Approximately 53 percent of facilities within this SIC 

code produce wood household furniture, while approximately 20 

percent produce upholstered household furniture. Exhibit 1 provides 

a distribution by facility size for household furniture manufacturing 

facilities. 

Exhibit 1 

Facility Size Distribution of Household Furniture Manufacturers 

Type of Furniture Facility Facilities 

with 1 to 19 

employees 

Facilities with 

20 to 99 

employees 

Facilities with 

100 or more 

employees 

Total 

Wood Household 

SIC: 2511 

2,084 573 291 2,948 

Upholstered Household 

SIC: 2512 

574 358 218 1,150 

Metal Household 

SIC: 2514 

207 123 88 418 

Mattresses and Bedsprings 

SIC: 2515 

504 282 53 839 

Wood Television and Radio 

Cabinets 

SIC: 2517 

44 22 14 80 

Household Furniture (misc.) 

SIC: 2519 

126 38 13 177 

Total 3,539 1,396 677 5,612 

SIC Code 25 6 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

Source: 1987 Census of Manufacturers Industry Series. 

According to information contained in EPA's October 1991 draft 

guidelines for the Control of Volatile Organic Compound Emissions from 

Wood Furniture Coating Operations, approximately 86 percent of the 

wood furniture industry (SIC codes 2434, 2511, 2512, 2517, 2519, 2521, 

2531, and 2541) have fewer than 50 employees. Approximately 37 

percent of facilities in this listing are wood household furniture 

manufacturers, while approximately 34 percent are wood kitchen 

cabinet manufacturers. Exhibit 2 provides a breakdown by facility size 

for the wood furniture manufacturers. 

Exhibit 2 

Facility Size Distribution of Wood Furniture Manufacturers 

Type of Furniture Facility Facilities 

with 1 to 49 

employees 

Facilities 

with 50 to 249 

employees 

Facilities with 

250 or more 

employees 

Total 

Wood Kitchen Cabinets 

SIC: 2434 

3,460 218 35 3,713 

Wood Household Furniture, 

except upholstered 

SIC: 2511 

2,466 344 138 2,948 

Wood Household Furniture, 

upholstered 

SIC: 2512 

782 292 76 1,150 

Wood Television, Radios, 

Phonograph, and Sewing 

Machine Cabinets 

SIC: 2517 

61 11 8 80 

Household Furniture, not 

elsewhere classified 

SIC: 2519 

150 22 5 177 

Wood Office Furniture 

SIC: 2521 

505 113 31 649 

Public Building and Related 

Furniture 

SIC: 2531 

381 95 15 491 

Wood Office and Store Fixtures, 

Partitions, Shelving, and 

Lockers 

SIC: 2541 

1,672 184 10 1,866 

Total 9,477 1,279 318 11,074 

Source: EPA Draft Guidelines for the Control of Volatile Organic Compound Emissions from 

Wood Furniture Coating Operations. 

September 1995 7 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

Geographic Distribution 

According to 1987 Census data, of the estimated 11,000 furniture 

manufacturing facilities (SIC 251), approximately 17 percent are 

located in California. North Carolina is home to approximately seven 

percent of these facilities, even though four of the top ten facilities are 

located in this State. Exhibit 3 provides a geographic distribution of 

the number of furniture and fixtures manufacturers (State totals are 

based on the number of facilities per State with 150 or more employees 

in a given industry sector). 

Exhibit 3 

Geographic Distribution of the Furniture and Fixtures Industry 

220 

144 

1803 

0 

4 

0 

0 

57 

7 

0 

142 

11 

149 

0 

0 

167 

484 

35 

38 

127 

4 

218 

864 

214 

296 

318 

71 

175 

747 

86 

178 

179 

38 

226 

463 314 

365 

348 

11 

456 

969 

39 20

284 

35 

20 

136 

312 

161 

1 

0 

Source: 1987 Census of Manufacturers Industry Series. 

Information contained in EPA's draft guidelines for the Control of 

Volatile Organic Compound Emissions from Wood Furniture Coating 

Operations shows that of the estimated 10,757 wood furniture 

manufacturing facilities (SIC codes 2434, 2511, 2512, 2517, 2519, 2521, 

2531, and 2541) approximately 17 percent are located in California. 

Although more facilities are located in California, the largest furniture 

manufacturing facilities and those responsible for producing the 

highest volume of furniture are located in North Carolina. Exhibit 4 

provides a geographic distribution of the wood 

SIC Code 25 8 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

furniture manufacturing industry (information is not available for 

Alaska, Delaware, Hawaii, Montana, Washington D.C., and 

Wyoming). 

Exhibit 4 

Geographic Distribution of Wood Furniture Manufacturing Facilities 

259 

178 

1789 

28 

25 

91 

18 

10 

156 

28 

52 

190 

468 

72 

34 

117 

23 

167 

868 

203 

298 

318 

79 

166 

690 

98 

229 

219 

53 

232 

351 313 

283 

325 

10 

448 

748 

31 20

272 

52 

11 

147 

447 

141 

0 

0 

Source: EPA Draft Guidelines for the Control of Volatile Organic Compound Emissions from 

Wood Furniture Coating Operations. 

According to a 1990 ranking by total annual sales of the top 300 wood 

furniture manufacturing facilities in Furniture Design and 

Manufacturing Magazine, Masco Corporation is the largest residential 

wood furniture manufacturer, with annual sales of $1.2 billion. 

Steelcase, Inc. is the largest manufacturer of wood office/institutional 

furniture, with annual sales of $1.8 billion. Exhibit 5 provides a 

breakdown of the top ten manufacturers of residential wood furniture 

and wood office/institutional furniture (sales figures are based on 

1988 and 1989 data and are estimates in some instances). 

September 1995 9 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

Exhibit 5

Top Ten Wood Furniture Manufacturers - 1990

Rank Name of Manufacturer Annual Sales, 

$ million 

Residential Furniture 

1 Masco Corporation 1,200 

2 Interco 1,100 

3 Ohio Mattress Company 700 

4 La-Z-Boy Chair Company 553 

5 Bassett Furniture Industries, Inc. 466 

6 Ladd Furniture 450 

7 Simmons USA 425 

8 Thomasville Furniture Industries, Inc. 417 

9 Mohasco Corporation 400 

10 Klaussner Furniture Industries 250 

Office/Institutional Furniture 

1 Steelcase, Inc. 1,800 

2 Herman Miller, Inc. 793 

3 Hanworth, Inc. >500 

4 HON Industries, Inc. 500 

5 Kimball International, Inc. 475 

6 Knoll International 275 

7 Allsteel, Inc. 220 

8 Virco Manufacturing Corporation 183 

9 Westinghouse Furniture Systems 170 

10 Shelby William Industries, Inc. 169 

Source: Furniture Design and Manufacturing Magazine. 

II.B.2. Product Characterization 

The furniture and fixtures industry, as defined by SIC 25, 

manufactures a wide variety of products, including wood and 

metal furniture, mattresses, draperies, public seating (i.e. stadium 

seats and bleachers), lockers, and restaurant furniture. Because this 

profile focuses on the wood furniture portion of the industry (SIC 

codes 2511, 2512, 2517, 2521, 2531, and 2541), the product 

characterization of the profile is limited in scope. Products covered 

under the relevant four-digit SIC codes include wood household 

furniture, such as beds, tables, chairs, bookshelves; wood television 

and radio cabinets; wood office furniture such as cabinets, chairs, 

and desks; and wood office and store fixtures and partitions, such 

as bar fixtures, counters, lockers, and shelves. 

SIC Code 25 10 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

II.B.3. Economic Trends 

According to the American Furniture Manufacturers Association 

(AFMA), wood furniture comprises approximately 50 percent of all 

furniture shipments nationally. Following a steady decline beginning 

in 1989, the furniture industry experienced moderate increases in 1992 

and 1993. This is in part attributed to the fact that private housing 

starts increased for the second consecutive year and the value of new 

residential construction rose an estimated seven percent. This rise in 

home sales and residential construction figures translated into a five 

percent increase in furniture shipments in 1993. Employment in the 

furniture and fixtures industry increased by two percent in 1993 

following a five year decline. 

Wood furniture manufacturers’ profits did not rise by as much as the 

increased shipments would suggest. Major increases in lumber prices, 

over 30 percent for softwood in approximately one year, significantly 

gouged profits in 1993. A similar rise in hardwood prices occurred in 

early 1992. Although lumber prices may fluctuate mildly, they are not 

expected to fall to the reduced levels of 1991 or early 1992. 

In 1993, wood furniture accounted for 48 percent of total furniture 

exports, followed by upholstered furniture (19 percent), metal 

furniture (10 percent), plastic furniture (four percent), and mattresses 

and bedsprings (three percent). Although overall U.S. household 

furniture exports increased five percent to $1.2 billion in 1993, imports 

rose more than 14 percent in the same time period. The resulting $2.3 

billion furniture and fixtures industry trade deficit mimicked that of 

1989. However, U.S. exports increased almost 150 percent from 1989 

through 1993 while imports increased only 25 percent in the same time 

period. As foreign markets become increasingly important to U.S. 

manufacturers of household furniture, attention is being focused on 

international agreements to ease trade restrictions. For example, many 

furniture manufacturers favored the North American Free Trade 

Agreement (NAFTA). Under this agreement, Mexico, a major 

importer of American home furniture, will immediately eliminate 

taxes on 21 percent of all imports of U.S. household furniture, with 

additional reductions to follow. 

September 1995 11 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

The real value of U.S. shipments of household furniture is expected to 

increase by four percent to an estimated $23 billion in 1994 due to 

improvements in the economy and consumer confidence. Over the 

next five years, household furniture shipments are expected to increase 

three to five percent annually. This prediction relies primarily upon 

increases in product prices rather than overall furniture units 

produced. 

SIC Code 25 12 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

III. INDUSTRIAL PROCESS DESCRIPTION 

This section describes the major industrial processes within the Wood 

Furniture and Fixtures industry, including the materials and 

equipment used, and the processes employed. The section is designed 

for those interested in gaining a general understanding of the industry, 

and for those interested in the inter-relationship between the industrial 

process and the topics described in subsequent sections of this profile -

- pollutant outputs, pollution prevention opportunities, and Federal 

regulations. This section does not attempt to replicate published 

engineering information that is available for this industry. Refer to 

Section IX for a list of reference documents that are available. 

This section specifically contains a description of commonly used 

production processes, associated raw materials, the byproducts 

produced or released, and the materials either recycled or transferred 

off-site. This discussion, coupled with schematic drawings of the 

identified processes, provide a concise description of where wastes 

may be produced in the process. This section also describes the 

potential fate (air, water, land) of these waste products. 

III.A. Industrial Processes in the Wood Furniture and Fixtures Industry 

The following description of production processes focuses on the 

manufacturing of wood furniture. The primary input for wood 

furniture manufacturing is raw lumber, and the production processes 

include steps such as drying, sawing, planing, sanding, gluing, and 

finishing. Each of these activities is described below. 

III.A.1. Drying 

Some furniture manufacturing facilities may purchase dried lumber, 

but others perform drying on-site. Drying of raw lumber is 

accomplished by using a drying kiln or oven, fired by a boiler. 

According to EPA document AP-42, furniture manufacturing facilities 

generally burn wood waste (from later stages of the production 

process) in boilers to heat the drying kilns and to alleviate possible 

solid waste disposal problems. The following boiler firing 

configurations are used for burning wood waste: Dutch oven; fuel cell 

oven; spreader stoker; suspension-fired; and fluidized bed 

combustion. The primary outputs of burning wood waste in boilers 

are point-source emissions to the atmosphere. A more detailed 

September 1995 13 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

discussion of all material inputs and pollution outputs will be covered 

in the following section. 

Types of Boilers 

One common type of boiler used in smaller operations is the Dutch 

oven. This unit is widely used because it can burn fuels with very 

high moisture content. Wood waste is used as fuel and is fed into the 

oven through an opening in the top of a refractory-lined furnace. The 

fuel accumulates in a cone-shaped pile on a flat or sloping grate. 

Combustion is accomplished in two stages: 1) drying and gasification, 

and 2) combustion of gaseous products. The first stage takes place in 

the primary furnace, which is separated from the secondary furnace 

chamber by a bridge wall. Combustion is completed in the secondary 

chamber before gases enter the boiler section. 

In the fuel cell oven, fuel is dropped onto suspended fixed grates and 

is fired in a pile. Unlike the Dutch oven, the refractory-line fuel cell 

also uses combustion air preheating and positioning of secondary and 

tertiary air injection ports to improve boiler efficiency. Because of 

their overall design and operating similarities, fuel cell and Dutch 

oven boilers have comparable emission characteristics. 

The most common firing method employed for wood-fired boilers 

larger than 45,000 kg/hr steam generation rate is the spreader stoker. 

With this boiler, wood enters the furnace through a fuel chute and is 

spread either pneumatically or mechanically across the furnace, where 

small pieces of the fuel burn while in suspension. Simultaneously, 

larger pieces of fuel are spread in a thin, even bed on a stationary or 

moving grate. The burning is accomplished in three stages in a single 

chamber: 1) moisture evaporation; 2) distillation and burning of 

volatile matter; and 3) burning of fixed carbon. This type of operation 

has a fast response to load changes, has improved combustion control, 

and can be operated with multiple fuels. Natural gas or oil is often 

fired in spreader stoker boilers as auxiliary fuel. This is done to 

maintain constant steam when the wood waste supply fluctuates and 

to provide more steam than can be generated from the wood waste 

alone. 

The suspension-firing boiler can be used for wood combustion, and 

differs from a spreader stoker in that small-sized fuel (normally less 

than 2 mm) is blown into the boiler and combusted by supporting it in 

air rather than on fixed grates. Rapid changes in combustion rate, and 

SIC Code 25 14 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

therefore steam generation rate, are possible because the finely divided 

fuel particles burn very quickly. 

A recent development in wood firing is the fluidized bed combustion 

boiler. A fluidized bed consists of inert particles through which air is 

blown so that the bed behaves as a fluid. Wood waste enters in the 

space above the bed and burns both in suspension and in the bed. 

Because of the large thermal mass represented by hot inert bed 

particles, fluidized beds can handle dirty fuels (up to 30 percent inert 

material). Wood fuel is burned faster in a fluidized bed than on a 

grate due to its immediate contact with hot bed material. As a result, 

combustion is rapid and results in nearly complete combustion of the 

organic matter, minimizing unburned organic compound emissions. 

III.A.2. Machining 

Once the lumber is dried, it is sawed into a shape of the approximate 

dimensions of the final furniture part, such as a table leg or a chair 

rung. Sawing across the grain in called crosscutting, and sawing 

parallel with the grain is referred to as ripping. Types of power saws 

used in furniture manufacturing include circular saws, band saws, 

scroll saws, radial saws, and portable handsaws. 

After sawing, the surfaces of the wood which will be flat in the final 

product are planed. Planing involves shaving one surface of wood by 

using a wide edged blade or blades called a planer. The type of power 

planer usually used in this manufacturing process is the jointer or 

jointer planer, which consists of blades fastened to a rotating 

cutterhead. The primary outputs from the sawing and planing 

processes are wood chips. 

The design of some furniture pieces requires that certain wooden parts 

be bent. This production step follows the planing process and usually 

involves the application of pressure in conjunction with a softening 

agent and increased atmospheric pressure. While soaking wood in 

water alone does increase its plasticity, the combination of heat and 

steam does increase further the plasticity of wood. The actual bending 

is accomplished by compressing the wood into the desired shape and 

then drying it to remove excess moisture. Drying after bending is 

accomplished in much the same way as the drying of raw lumber, in 

drying kilns using boilers to generate heat. 

September 1995 15 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

III.A.3. Assembly 

Wood furniture can either be finished (coated) and then assembled, or 

assembled and then finished. Residential and office/institutional 

furniture manufactured in the U.S. is generally made up of irregularly 

shaped, curved components, and for ease of production is assembled 

and then finished. Cabinets manufactured in the U.S., however, are 

frequently finished before assembly. 

After the wood parts have been planed and, if necessary, bent, they are 

assembled to form one furniture part, such as a tabletop. The 

assembly process usually involves the use of adhesives (either 

synthetic or natural) in conjunction with other joining methods, such 

as nailing. The wood furniture manufacturing industry uses adhesive 

formulations containing solvents (typically used for upholstered wood 

furniture) and hot melts or polyvinyl acetate (typically used for nonupholstered wood furniture). According to a representative of Masco 

Corporation, the vast majority of adhesives used to assemble nonupholstered wood furniture are hot melts or polyvinyl acetate. The 

amount of adhesives used depends on the type of product. 

The next step in the production process is the application of veneer. 

Veneer is a thin piece of wood of uniform thickness which is usually 

rotary-cut from a bolt of wood using a lathe. Not all furniture 

manufacturing involves the application of veneer. The production of 

veneer falls under SIC code 24 (lumber and wood products). The 

veneer is applied to the furniture part using adhesives, some of which 

require the use of heat and/or pressure. While not a significant source 

of releases, gluing operations and the use of adhesives for assembly 

and veneer are a source of atmospheric solvent releases. 

After veneer application or furniture assembly, the furniture part is 

sanded to ensure that its surface is as smooth as possible for the 

finishing stages of the production process. Sanding is usually 

accomplished by a disk, belt, or roller sanding machine using either 

open- or closed-coated sand paper. For open-coated sand paper, 

approximately 50 to 70 percent of the paper surface is coated with 

abrasive. For closed-coated sand paper, the paper surface is 

completely covered with abrasive. Closed-coated sand paper is 

generally used in operations requiring higher removal rates. The 

sanding process can also be employed at other stages of the production 

process, such as prior to the application of veneer or between the 

application of several coats of varnish during the finishing process. 

The primary outputs from sanding are wood particulates. 

SIC Code 25 16 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

III.A.4. Pre-finishing 

After initial sanding, an even smoother surface is attained by spraying, 

sponging, or dipping the furniture part with water, which causes the 

fibers of the wood to swell and "raise." After the surface is dried, a 

solution of glue or resin is applied and allowed to dry, causing the 

raised fibers to become more brittle. The raised fibers are then sanded 

down to form a particularly smooth surface. The primary outputs 

from second sanding are wood and glue or resin particulates. 

Because certain types of wood contain rosin (a naturally occurring 

resin) which can interfere with the effectiveness of certain finishes, a 

process known as derosination may be employed. Derosination is 

accomplished by applying a mixture of acetone and ammonia to the 

surface of the wood. Spent acetone and ammonia are the primary 

outputs from derosination. 

Once the unwanted rosin is removed from the wood, a process known 

as bleaching is used to lighten the color of the wood when the natural 

color is darker than that of the stain or finish to be applied. The 

process entails spraying, sponging, or dipping the wood into a 

bleaching agent, such as hydrogen peroxide. Spent bleaching agents 

are the primary outputs of this step of the production process. 

III.A.5. Coating Application 

There are various coating application techniques used by the wood 

furniture manufacturing industry for applying finishing coatings. The 

two principal methods are flatline finishing and spray application. 

Flatline finishing is used only to coat truly flat furniture parts and 

cannot be used for curved pieces, preassembled pieces, or pieces with 

many recesses. Although, spray application is the most commonlyused method to finish these furniture parts, brushing and dipping can 

also be used. 

The two principal ways of performing flatline finishing are roll coating 

and curtain coating. Roll coating involves the transfer of coating 

material by a roller or series of rollers, while curtain coating involves 

passing the furniture part through a cascade, or curtain, of coating 

material. 

September 1995 17 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

The methods used to spray apply coatings include air, airless, airassisted airless, high-volume low-pressure (HVLP), electrostatic, and 

the UNICARB® spray system. The conventional air spray technique 

uses compressed air to atomize the coating materials as they are being 

sprayed, by forcing them through a small opening at high pressure. 

The liquid coating is not mixed with air before exiting the nozzle. Airassisted airless spray uses an airless spray unit with a compressed air 

jet to finalize the breakup of the coating material. 

HVLP spraying involves the use of a high volume of air delivered at 

low pressure to atomize the coating material into a pattern of lowspeed particles. The use of low pressure can result in decreased 

overspray, which translates into less coating usage and less volatile 

organic compound (VOC) emissions. 

Electrostatic spraying has long been used in the metalworking and 

automobile industries to coat metal products. In the wood furniture 

industry, electrostatic spraying has somewhat limited use, mostly by 

cabinet and chair manufacturers. This finishing process is performed 

by spraying negatively-charged coating particles onto positivelycharged wood products. If the wood piece has a sufficient moisture 

content, it can be electrostatically sprayed without pretreatment. 

However, some wood must be pretreated to allow the piece to hold a 

positive charge. The material used for pretreatment often contains 

VOCs. 

The UNICARB® system is a relatively new system for spray coating 

developed by Union Carbide. A coating normally contains both 

coalescing (slow-evaporating) and diluent (fast-evaporating) solvents. 

The UNICARB® technology replaces the diluent solvents with liquid 

carbon dioxide. The carbon dioxide/coalescing solvent coating 

mixture is used to coat the wood with an airless spray gun. When the 

coating leaves the spray nozzle, the carbon dioxide in the mixture 

immediately flashes, and the coating material, which still contains 

coalescing solvents, continues enroute to the piece and cures in the 

conventional way. As of June 1991, the UNICARB® system was being 

tested in several coatings applications, but was not yet being used 

commercially in any production coating operation. 

SIC Code 25 18 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

III.A.6. Finishing 

The finishing of wood furniture can be subdivided into two different 

categories, interior finishing (furniture for indoor use) and exterior 

finishing (furniture for outdoor use), although the actual production 

processes involved are fairly similar. The main difference between 

interior and exterior finishing is the type of coating material applied, 

not the application processes. The following discussion outlines the 

production processes involved in interior finishing; exterior finishing 

will be mentioned only when the process differs from that of interior 

finishing. 

Wood finishing processes include coating, drying, and sanding the 

furniture in a series of steps which are repeated until the desired final 

appearance is achieved. While in small facilities the assembled 

furniture is sometimes moved between finishing stations manually, in 

most facilities the furniture is moved along the finishing line 

mechanically by tow-lines, overhead chain conveyors, and other 

conveyors including belt, roller, and slat conveyors. Tow-lines, chains 

or cables mounted in or on the floor, move a pallet, on which the 

assembled piece of furniture rides along the finishing line. The pallets 

can rotate and can be automatically disengaged from and reengaged to 

the tow-line to allow for pauses, as needed. Some facilities move the 

furniture on pallets that are hung from overhead chain conveyors. 

Many facilities use a combination of these methods to transport the 

furniture along the finishing line. 

Many of the finishing application methods use relatively high 

concentrations of VOCs which volatilize when the coating is applied. 

For example, solvents are used in the stains, paints, and finishes as 

well as in the inks used to print simulated wood grain onto plywood 

and particleboard. In addition, solvents are used in cleanup 

operations (i.e., to remove overspray from spray booths and to rinse 

solvent-based finishes from spray lines and equipment between color 

changes). The primary outputs from the following finishing 

applications are point-source and fugitive air emissions, as well as 

wood and coating material particulates. 

Staining involves the application of a clear colorant which adds initial 

color, evens out color, and accents without hiding the natural wood 

grain. Stains usually consist of transparent or semitransparent color 

solids (typically less than five percent by volume) suspended in a 

volatile liquid solution with a certain amount of a nonvolatile binder, 

which facilitates spreading, penetration, and fixation of color. 

September 1995 19 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

Commonly-used stains, all of which are used in conjunction with 

organic solvents, include: nongrain-raising, dye-type, no-wipe, and 

toners. 

Nongrain raising stains are dye-type stains which are intended to give 

clarity and depth to the wood finish. Dye-type stains consist of dyes 

that are completely dissolved in methanol. No-wipe stains are 

pigmented stains, containing a small amount of oil, pigment, and 

solvent, that are sprayed on and not wiped off. No-wipe stains are 

used to accent the wood grain, provide color uniformity and color 

retention. Toners are stains that contain nitrocellulose or vinyl 

binders, dissolved in solvent. Toners are not wiped, and are often 

pigmented. 

After staining, a washcoat, consisting of 2 to 13 percent solids by 

volume, is applied to the furniture piece. Washcoating is used to aid 

in adhesion, assist in filling or color uniformity, and partially seal the 

wood from subsequent staining operations. Washcoat also prepares 

the wood surface for another sanding after stain application. Some 

facilities buy sealer in bulk, and dilute their sealer to make washcoat. 

There are three main types of washcoat materials: standard 

nitrocellulose; vinyl or modified vinyl; and vinylmodified/”conversion” types. Advantages of nitrocellulose washcoats 

include quick drying, easy sanding, and clarity. Vinyl and vinylmodified washcoats consist of nitrocellulose and vinyl and provide 

better toughness and adhesion than pure nitrocellulose washcoats; 

however, some clarity is sacrificed. The “conversion” or precatalyzedtype washcoats also provide good adhesion and toughness, and are 

good for open pore woods. Because they react in place, they are 

impervious to solvents contained in subsequently applied sealers and 

topcoats. 

Fillers are applied to the wood surface to produce a smooth, uniform 

surface for later stages in the finishing process. Fillers, which consist 

of colorless or covering pigments, can be combined with stains or other 

pigments and are usually dispersed in a vehicle of drying oils, 

synthetic resins, and thinners based on organic solvents. Fillers are 

usually supplied as heavily pigmented, high-solids, low-VOC 

materials, which are reduced on the job. As supplied, solids contents 

of fillers are in the 75 percent solids by volume range. Once reduced, 

the solids contents usually range from 10 percent to 45 percent by 

volume. Fillers are usually spray applied, then wiped into the wood. 

SIC Code 25 20 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

Sealing, which is completed after staining and either before or after 

filling, consists of applying one or many coats of sealer. Sealers are 

usually a nitrocellulose-based lacquer, although vinyl or vinylmodified sealers and catalyzed sealers are also available and provide 

advantages similar to those of the washcoat counterparts. The primary 

purposes of sealers are to provide adhesion, make sanding more 

effective, and to seal the wood and establish a foundation for further 

coating applications. Solids contents of sealers typically range from 

ten to 30 percent by volume. 

For outdoor furniture, instead of, or in addition to, the filling and 

sealing processes, the wood surface is treated through a process 

known as priming. Priming treatments commonly used for outdoor 

wooden furniture include the application of fungicide and waterrepellent. 

One alternative to staining is painting. The process for applying paints 

is similar to that of applying stains or other finishes, although the 

chemical composition of paints differs from the other finishes. Paint is 

a viscous fluid, usually consisting of a binder or vehicle, a pigment, a 

solvent or a thinner, and a drier. Pigments are insoluble in the coating 

material and are deposited onto the wood surface as the vehicle dries. 

The chemical composition of a pigment varies according to its color as 

illustrated in Exhibit 6. 

Exhibit 6 

Chemical Components of Pigments Found in Paint 

Pigment Color Chemical Components 

White Titanium dioxide, white lead, zinc oxide 

Red Iron oxides, calcium sulfate, cadmium 

selenide 

Orange Lead chromate-molybdate 

Brown Iron oxides 

Yellow Iron oxides, lead chromate, calcium sulfide 

Green Chromium oxide, copper, phosphotungstic 

acid, phosphomolybdic acid 

Blue Ferric ferrocyanide, copper 

Purple Manganese phosphate 

Black Black iron oxide 

Source: McGraw-Hill Encyclopedia of Science and Technology, 1987. 

After the furniture part has been stained or painted, a topcoat, such as 

varnish or shellac, is applied in one of the final stages of the finishing 

process. Topcoats provide a clear coat whose function is to protect the 

September 1995 21 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

color coats, enhance the beauty of the furniture, and provide a durable 

final finish. Typical solids contents range from 13 to 30 percent solids 

by volume. There are four categories of topcoats: standard 

nitrocellulose topcoats; acrylic topcoats; catalyzed topcoats; and 

conversion varnishes. 

Nitrocellulose lacquers provide the best clarity, pick up little dirt, dry 

quickly, and are easy to wipe off and repair. Acrylic lacquers are used 

over white or pastel finishes as protection from common household 

cleaning products. They can also be applied over nitrocellulose 

topcoats for color retention. The clarity of acrylic lacquers is not as 

good as the nitrocellulose lacquers. Catalyzed topcoats are available in 

one- and two-pack form. The one-pack coatings are precatalyzed, and 

contain nitrocellulose resins and a small amount of urea resin. Because 

only a small amount of catalyst is added, it can take up to three to four 

weeks after application until the coating is completely cured, although 

it dries to the touch much sooner. The shelf life of precatalyzed 

coatings is more than six months. Conversion varnishes do not dry as 

quickly as nitrocellulose topcoats, and are difficult to spot repair, with 

washoff also being difficult or impossible. Conversion varnishes, like 

two-pack coatings, have a limited pot life. 

The two-pack coatings consist of two packs, one containing urea or 

melamine-based resins, and the other containing the catalyst. The two 

components are mixed before use. More catalyst is added to two-pack 

catalyzed coatings, so cure time is short (on the order of minutes or 

hours). Two-pack catalyzed coatings have a limited pot life after 

mixing (from one day to more than a week). 

In the U.S., lacquers (mostly nitrocellulose-based) are used by 

approximately 75 percent of the wood furniture industry; mostly by 

residential furniture manufacturers. Nitrocellulose lacquers have been 

used in the residential wood furniture industry for many years; they 

are easy to use, quick drying, and easy to repair. 

Approximately 15 percent of the wood furniture industry, primarily 

the cabinet and office/institutional furniture manufacturers, use 

conversion coatings (mostly acid-catalyzed coatings). Cabinets and 

office/institutional furniture require the chemical and mechanical 

resistance offered by catalyzed finishes. As of October 1991, 

polyurethane and unsaturated polyester and unsaturated polyacrylate 

coatings have had limited use in the United States. 

SIC Code 25 22 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

Rubbing, polishing, and cleaning are the final steps of the production 

process. Rubbing consists of the application of an abrasive in 

conjunction with a lubricant to level or dull the luster. Polishing 

consists of the application of soft abrasives or possibly only waxy 

ingredients to increase the gloss. The furniture parts are then ready 

for shipment and sale after a final assembly stage, if appropriate (i.e., 

attaching table legs to a table top). Exhibit 7 illustrates the steps of the 

wood furniture manufacturing process. 

September 1995 23 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

Exhibit 7 

Flow Diagram for Wood Furniture Manufacturing 

Sawing 

Raw 

Lumber 

Planing Bending 

Heat 

Boiler Sawdust & 

Wood Chips Drying 

Sanding 

Gluing 

Veneer 

Application 

Dry Kilns 

Bleaching Sanding

Exterior 

Finishing 

Interior 

Finishing 

Primer 

Coating 

Finish 

Coating 

Filling Sealing 

Finish 

Coating 

Rubbing 

Polishing Cleaning

Shipment 

Finished 

Product 

Derosination 

Staining/ 

Painting 

Wood & 

Finishing Material 

particulates 

Spent 

Solvents 

Staining/ 

Painting 

Spent 

Bleach 

Spent 

Paints 

Natural 

Rosin 

Sawdust & Glue Washcoating Particulates

Boiler 

Source: Process Flow Diagram for Franklin Furniture of Greeneville, Tennessee found in Pollution Prevention 

Options in Wood Furniture Manufacturing, 1992. 

SIC Code 25 24 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

III.B. Raw Material Inputs and Pollution Outputs 

The following discussion of raw material inputs and pollution outputs 

is organized along the same lines as the production process 

description. While there are solid waste and process wastewater 

implications for the wood furniture manufacturing industry, the vast 

majority of outputs from this industry are air emissions resulting from 

the solvent-intensive finishing operations. 

III.B.1. Drying 

The major emissions of concern from drying the raw lumber using 

wood boilers is particulate matter (PM), although other pollutants, 

particularly carbon monoxide (CO) and organic compounds, may be 

emitted in significant quantities if the boiler is in poor operating 

condition. The type and amount of the emissions depend on a number 

of variables, including the composition of the waste fuel burned, the 

degree of fly ash reinjection employed, and furnace design and 

operating condition. 

The composition of wood waste depends largely on the industry from 

which it originates. Furniture manufacturing generates a clean, dry 

wood waste (e.g., 2 to 20 weight percent moisture) which produces 

relatively low particulate emission levels when properly burned. 

However, other operations, such as pulp manufacturing, produce 

great quantities of bark which may contain a much higher weight 

percent moisture, possibly causing bark boilers to emit considerable 

particulate matter to the atmosphere unless they are well controlled. 

Furnace design and operating conditions are particularly important 

when firing wood waste. Because of the high moisture content that 

may be present in wood waste, a larger than usual area of refractory 

surface is often necessary to dry the fuel before combustion. In 

addition, sufficient secondary air must be supplied over the fuel bed to 

burn the volatiles that account for most of the combustible material in 

the waste. When proper drying conditions do not exist, or when 

secondary combustion is incomplete, the combustion temperature is 

lowered, and increased PM, CO, and organic compound emissions 

may result. Short-term emissions can fluctuate with significant 

variations in fuel moisture content. 

Fly ash reinjection, which is commonly used with larger boilers to 

improve fuel efficiency, has a considerable effect on PM emissions. 

September 1995 25 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

Because a fraction of the collected fly ash is reinjected into the boiler, 

the dust loading from the furnace and, consequently, from the 

collection device increase significantly per unit of wood waste burned. 

More recent boiler installations typically separate the collected 

particulate into large and small fractions in sand classifiers. The 

smaller particles, mostly inorganic ash and sand, are sent to ash 

disposal. 

The four most common control devices used to reduce PM emissions 

from wood-fired boilers are mechanical collectors, wet scrubbers, 

electrostatic precipitators (ESPs), and fabric filters. 

Fabric filters (i.e., baghouses) and ESPs are employed when collection 

efficiencies above 95 percent are required. However, fabric filters have 

had limited applications to wood-fired boilers. The principle 

drawback to fabric filtration, as perceived by potential users, is a fire 

danger arising from the collection of combustible carbonaceous fly ash. 

Steps can be taken to reduce this hazard, including the installation of a 

mechanical collector upstream of the fabric filter to remove large 

burning particles of fly ash. 

Emissions of nitrogen oxides (NOx) from wood-fired boilers are lower 

than those from coal-fired boilers due to the lower nitrogen content of 

wood and the lower combustion temperatures which characterize 

wood-fired boilers. 

According to the AFMA document Integrated Waste Management 

Program Applicable to the On-site Management of Certain Non-hazardous 

Wood Product Finishing Wastes, dated May 1993, the operating 

temperatures of boilers used by this industry are sufficient to 

adequately combust the chemical constituents of wood product 

finishing waste (i.e., sawdust mixed with dust from the various 

coating materials used in furniture finishing operations such as dried 

lacquer chips). Based on its interpretation of hazardous waste as 

defined in 40 CFR 261.21(a)(2), the AFMA determined that wood 

product finishing waste was acceptable for combustion in a boiler. 

The State of North Carolina Department of Environment, Health, and 

Natural Resources initially disagreed with this interpretation. 

However, according to the AFMA, the Director of the Division of Solid 

Waste Management, in a March 9, 1994 meeting, approved the 

AFMA's interpretation. 

SIC Code 25 26 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

III.B.2. Machining 

The primary outputs from the sawing and planing processes are wood 

chips and sawdust, which are used as fuel in boilers for other furniture 

production processes. Wood chips may also be sold to manufacturers 

of other wood-based products, such as pulp and paper mills. Because 

no coating materials have been applied to the furniture prior to 

machining, the particles are almost completely composed of wood, 

unlike outputs from later sandings which contain particles of finishing 

material as well as wood particles. 

III.B.3. Assembly 

Adhesives can be either natural or synthetic in origin and typically 

contain solvents. Commonly used adhesive formulations contain 

solvents such as methyl isobutyl ketone, methyl ethyl ketone, xylene, 

toluene, and 1,1,1-trichloroethane. Solvents are also used to clean 

adhesive application equipment such as spray guns. Adhesives used 

to apply veneer can differ from adhesives used for assembly and 

usually include phenolics, ureas, melamines, polyvinyl resin 

emulsions, hot melts, contacts, and mastics. Application of some of the 

above-mentioned adhesives requires the use of heat and/or pressure. 

Solvent release from the use of adhesives during assembly and veneer 

application (either as a product carrier or cleaning agent) can be 

significant. 

According to a representative of Masco Corporation, the wood 

furniture industry primarily uses hot melts or polyvinyl acetate which 

do not contain volatile organic compounds and therefore have little or 

no emissions implications. Wood chips and sawdust are outputs of the 

sanding performed after the assembly and application of veneer. 

III.B.4. Pre-finishing 

Typical outputs of the pre-finishing steps of the manufacturing process 

are spent solvents from the derosination process and spent bleaching 

agents from the bleaching process. Derosination entails the 

application of ammonia and acetone to remove the natural resin in the 

wood. The outputs from this step are, therefore, spent ammonia and 

acetone, as well as any of the naturally-occurring resin removed by 

this process. Bleaching agents typically used by the wood furniture 

industry include hydrogen peroxide, sodium bisulfite, sodium 

September 1995 27 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

hyposulfite, sodium perborate, oxalic acid, potassium permanganate, 

and sodium or calcium hypochlorite. 

III.B.5. Coating Application 

In the wood furniture industry, coatings are usually applied in spray 

booths, using various types of spray application equipment. The 

booths generally do not have any temperature or humidity control, 

and are maintained at ambient conditions. Often, both manual and 

automatic spray booths are equipped with dry filters, typically a paper 

material, to control particulates. In the past, water curtains had been 

used to control particulates. However, since the spent water had to be 

disposed of as a hazardous waste, and as hazardous waste disposal 

costs increased, the cost effectiveness of water curtain filtration 

decreased. Therefore, most of the new and modified spray booths in 

the wood furniture industry that use filters are equipped with dry 

filters. Some water-wash spray booths are still in use. 

Recirculating a portion of the exhaust from the spray booth increases 

the concentration of VOCs in the exhaust air leaving the spray booth 

and discharged to an end-of-pipe control system. According to a 

document entitled Demonstration of Paint Spray Booth Air Recirculation 

and Flow Partitioning: Design Validation, the concept of recirculation 

was patented by John Deere Corporation in 1979, but a large segment 

of the coating industry mistakenly believed that this practice was 

prohibited by OSHA regulations. During approved recirculation 

practices, equal portions of fresh air and recirculated air are pumped 

back into the booth. One advantage of using recirculation is the 

decreased exhaust flow volume emitted to the atmosphere and 

decreased capitol and operating costs of the VOC control system. A 

joint EPA and U.S. Air Force research and development program 

developed these emissions control concepts for hazardous air 

pollutants (HAPs). 

There are two types of add-on control devices, technologies used to 

capture pollutants from point-source air emissions: combustion 

control devices and recovery devices. Combustion control devices are 

used to destroy contaminants, converting them primarily to carbon 

dioxide and water. Combustion control devices used by the furniture 

industry include thermal incineration, with recuperative and 

regenerative heat recovery, and catalytic incineration. 

SIC Code 25 28 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

Recovery devices are used to collect VOCs prior to their final 

disposition. One recovery device is carbon adsorption used in 

conjunction with regeneration of the carbon bed by steam or hot air. 

By using either steam or hot air, the VOCs may be recovered or 

disposed of following regeneration. 

Thermal incineration is a process by which waste gas is brought to 

adequate temperature, and held at that temperature for a sufficient 

time for the organic compounds in the waste gas to oxidize. 

Catalytic incineration is comparable to thermal incineration in that 

VOCs are heated to a temperature sufficient for oxidation to occur. 

However, with catalytic incineration, the temperature required for 

oxidation is considerably lower than that required for thermal 

incineration because a catalyst is used to promote oxidation of 

contaminants. Platinum is the most widely used catalyst; palladium is 

also commonly used. Because the metals used as catalysts are 

expensive, only a thin film is applied to the supporting substrate. A 

commonly used substrate is ceramic. 

III.B.6. Finishing 

The primary outputs of the finishing steps of the manufacturing 

process include solvent emissions to the atmosphere, as well as spent 

solvents, and particles of wood and coating materials applied to the 

furniture. Solvents or thinners typically used in paints include toluene 

or xylene. Rubbing and polishing, performed after finishing, require 

the use of materials containing lubricants, such as detergents and 

petroleum-based thin oils, and abrasives, such as pumice, tripoli, and 

diatomaceous earth. Because wood furniture finishing is a solventintensive process, the primary outputs are spent solvents and solvent 

emissions. 

Flashoff areas are areas that are either between spray booths, or 

between a spray booth and an oven, in which solvent is allowed to 

volatilize from the coated piece. While some flashoff areas have forced 

air circulation and are referred to as forced-flashoff areas, most flashoff 

areas do not have a separate exhaust. The length of flashoff areas 

varies significantly by facility, and even within a facility, depending 

on whether the coating will be cured in an oven. A flashoff area that is 

not followed by an oven is often longer than one that is located in 

between a booth and an oven. 

September 1995 29 SIC Code 25 
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--- ---

--- ---

--- ---

Wood Furniture and Fixtures Sector Notebook Project 

Ovens are used between some coating steps to cure the coating prior to 

the next step in the finishing sequence. Many types of ovens are used 

in the wood furniture industry. Most are steam-heated using either a 

wood- or coal-fired boiler; others are gas-fired. Infrared or ultraviolet 

ovens are also used, but their use in the wood furniture industry is 

limited at this time. Oven temperatures can range from less than 38 to 

121 degrees Celsius depending on the type of coating used, the piece 

being coated, and the oven residence time. The exhaust rate from 

ovens also varies, and can range between 21.2 and 425 cubic meters 

per minute. 

Exhibit 8 contains the relative VOC emissions for three different model 

plants: a residential furniture manufacturing facility using a long 

finishing sequence (consisting of a total of three or more stain 

applications; a single application of wash coat, filler, sealer, and 

highlight; and two or three topcoat applications); a residential 

furniture manufacturing facility using a short finishing sequence 

(consisting of two stain applications, one application of washcoat and 

sealer, and two topcoat applications); and an office/cabinet 

manufacturing facility using a short finishing sequence (consisting of 

one application of stain, sealer, and topcoat). The relative VOC 

emissions are presented as a percent of each coating applied for each 

model plant. 

Exhibit 8 

Relative VOC Emissions 

Type of plant Furniture long Furniture short Office/cabinet 

Stain 26 percent 28 percent 32 percent 

Washcoat 4 percent 4 percent 

Filler 3 percent 

Wiping stain/glaze 8 percent 

Sealer 18 percent 32 percent 32 percent 

Highlight 1 percent 

Topcoat 40 percent 36 percent 36 percent 

Total 100 percent 100 percent 100 percent 

Source: EPA Draft Guidelines for the Control of Volatile Organic Compound Emissions 

from Wood Furniture Coating Operations. 

SIC Code 25 30 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

III.B.7. Cleanup Operations 

Solvent-borne nitrocellulose lacquers are the predominant type of 

coatings used by the wood furniture industry today. The resins in 

such coatings are relatively “difficult” to dissolve, so a high-solvencyrated solvent must be used in their formulation. Similarly, thinning of 

these coatings requires the use of the same solvent or one with 

equivalent solvency. This solvent is generically referred to as “lacquer 

thinner.” The current practice is to use lacquer thinner for both 

incidental thinning of premixed coatings and for cleanup of the 

coatings. Advantages of the lacquer thinner include its compatibility 

with the finishing materials and the ease with which it removes cured 

nitrocellulose lacquers. 

In wood-coating operations, industrial solvents are used 

predominantly for cleaning application equipment. In addition, 

cleanup solvent can also be used to clean out piping, clean booths and 

rails, strip cured coatings from wood parts or machinery, and 

periodically clean centralized coating storage and distribution (pump 

room) equipment. 

Application equipment must be cleaned every time there is a color 

change, and usually before the equipment is to be idle for a period of 

time (e.g., at the end of the day). For spray coating application, 

equipment cleaned with solvents includes spray guns, feed lines, and 

coating reservoirs (where applicable). In the case of roll coating 

operations, the rollers and spray bar nozzles must be cleaned 

periodically to maintain application quality as well as prior to color 

changes. 

Spray guns have traditionally been cleaned by sending pure solvent 

from the coating reservoir through the gun, and atomizing the solvent 

into the booth ventilation system. Recognizing that this results in 

significant emissions of solvent, some operators cut off the atomizing 

air to the spray gun and pump the cleanup solvent through the gun 

into a container. This procedure can work if the gun is the type that 

does not depend on the flow of the atomizing air to pump the coating 

(or cleanup solvent) through the mechanism. Alternately, cleanup 

may involve soaking the entire gun in solvent. This guards against the 

possibility that small amounts of coating inadvertently missed during 

the cleaning will cure and clog the small orifices of the gun. Cleanup 

solvent is often reused within a facility, and eventually recycled inhouse or sent out for recycling/disposal. Exhibit 9 provides an 

September 1995 31 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

overview of the material inputs and pollution outputs for each step of 

the wood furniture manufacturing process. 

Exhibit 9

Inputs and Outputs of Wood Furniture Manufacturing Facilities

Process Material Input Air Emissions Process 

Wastes 

Other Wastes 

Drying 

Ovens/Drying Kilns 

(boilers covered 

below) 

Raw lumber Emissions, 

including water 

and possible 

chemicals used in 

pretreatment of 

raw lumber 

Machining 

Sawing/Planing/ 

Sanding 

Dried lumber Wood chips, 

sawdust 

Wood chips, 

sawdust 

Wood chips, 

sawdust 

Bending/Drying 

(boilers covered 

below) 

Lumber Emissions, 

including water 

and possible 

chemicals used in 

pretreatment of 

raw lumber 

Assembly 

Gluing/Veneer 

Application 

Hot melts, polyvinyl 

acetate, solvent-based 

adhesives (e.g., 

methyl isobutyl 

ketone, methyl ethyl 

ketone, xylene, 

toluene, 1,1,1-

trichloroethane) 

Solvent emissions 

(e.g., methyl 

isobutyl ketone, 

methyl ethyl 

ketone, xylene, 

toluene, 1,1,1-

trichloroethane) 

Spent solventbased adhesives 

(e.g., methyl 

isobutyl ketone, 

methyl ethyl 

ketone, xylene, 

toluene, 1,1,1-

trichloroethane) 

Sanding Assembled furniture Wood chips, 

sawdust 

Wood chips, 

sawdust 

Wood chips, 

sawdust 

Pre-finishing 

Watering/Sanding Assembled furniture, 

water, adhesives, 

resins 

Wood chips, 

sawdust, 

adhesive, and 

resin particles 

Wood chips, 

sawdust, 

adhesive, and 

resin particles 

Derosination Ammonia, acetone Solvent emissions 

(e.g., acetone) 

Spent acetone, 

ammonia, 

natural resin 

from wood 

Spent acetone, 

ammonia, 

natural resin 

from wood 

SIC Code 25 32 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

Exhibit 9 (cont'd)

Inputs and Outputs of Wood Furniture Manufacturing Facilities

Process Material Input Air 

Emissions 

Process Wastes Other Wastes 

Pre-finishing (continued) 

Bleaching Bleaching agents (e.g., 

hydrogen peroxide, 

sodium bisulfite, 

sodium hyposulfite, 

sodium perborate, 

oxalic acid, potassium 

permanganate, 

sodium or calcium 

hypochlorite) 

Spent bleaching 

agents (e.g., 

hydrogen 

peroxide, sodium 

bisulfite, sodium 

hyposulfite, 

sodium perborate, 

oxalic acid, 

potassium 

permanganate, 

sodium or 

calcium 

hypochlorite) 

Spent bleaching 

agents (e.g., 

hydrogen 

peroxide, sodium 

bisulfite, sodium 

hyposulfite, 

sodium perborate, 

oxalic acid, 

potassium 

permanganate, 

sodium or 

calcium 

hypochlorite) 

Finishing 

Staining Mineral spirits, 

alcohol, solvents, 

pigments (e.g., iron 

oxides, lead chromate, 

calcium sulfate, 

cadmium selenide) 

Solvent 

emissions 

Pigment wastes 

(e.g., iron oxides, 

lead chromate, 

calcium sulfate, 

cadmium 

selenide), solvent 

wastes 

Washcoating Nitrocellulose-based 

lacquers, acrylic 

lacquers, varnish, 

shellac, polyurethane, 

solvents 

Solvent 

emissions 

Spent solvents, 

nitrocellulosebased lacquers, 

acrylic lacquers, 

varnish, polyurethane, and 

shellac 

Filling Pigments (e.g., iron 

oxides, lead chromate, 

calcium sulfate, 

cadmium selenide), 

stains, drying oils, 

synthetic resins, 

solvent-based 

thinners 

Solvent 

emissions 

Spent solvents, 

stains, drying oils, 

synthetic resins, 

thinners, and 

pigments (e.g., 

iron oxides, lead 

chromate, calcium 

sulfate, cadmium 

selenide) 

September 1995 33 SIC Code 25
Wood Furniture and Fixtures Sector Notebook Project 

Exhibit 9 (cont'd)

Inputs and Outputs of Wood Furniture Manufacturing Facilities

Process Material Input Air Emissions Process Wastes Solid Wastes 

Finishing (continued) 

Sealing Nitrocellulose-based 

lacquers, acrylic 

lacquers, varnish, 

shellac, solvents, 

polyurethane 

Solvent 

emissions 

Spent solvents, 

nitrocellulosebased lacquers, 

acrylic lacquers, 

varnish, shellac, 

polyurethane 

Priming Fungicide, waterrepellent 

Painting Toluene, pigments 

(e.g., titanium 

dioxide, iron oxides, 

lead chromate), 

epoxy-ester resins, 

aromatic 

hydrocarbons, glycol 

ether, halogenated 

hydrocarbons, vinyl 

acetate, acrylic 

Solvent 

emissions (e.g., 

toluene) 

Spent solvents 

(e.g., toluene), 

pigments (e.g., 

titanium dioxide, 

iron oxides, lead 

chromate), epoxyester resins, 

aromatic 

hydrocarbons, 

glycol ether, 

halogenated 

hydrocarbons, 

vinyl acetate, 

acrylic 

Topcoat Application Denatured alcohols, 

resins, shellac, 

petroleum distillates, 

toluene, disocyanate 

Solvent 

emissions (e.g., 

toluene) 

Spent denatured 

alcohols, resins, 

shellac, petroleum 

distillates, 

toluene, 

disocyanate 

Sanding (occurs 

intermittently 

between each of the 

above ishing 

applications) 

Finished piece of 

furniture 

Particles that 

include wood, 

adhesive, 

resin, 

nitrocellulose 

lacquer, paint, 

stain, filler, 

and sealer 

Particles that 

include wood, 

adhesive, resin, 

nitrocellulose 

lacquer, paint, 

stain, filler, and 

sealer 

Particles that 

include wood, 

adhesive, resin, 

nitrocellulose 

lacquer, paint, 

stain, filler, and 

sealer 

Rubbing/Polishing Lubricants, 

detergents, 

petroleum-based thin 

oils, pumice, tripoli, 

diamaceous earth 

Spent lubricants, 

detergents, oils 

fin

SIC Code 25 34 September 1995
Sector Notebook Project Wood Furniture and Fixtures 

Exhibit 9 (cont'd)

Inputs and Outputs of Wood Furniture Manufacturing Facilities

Process Material Input Air Emissions Process Wastes Solid Wastes 

Cleanup Operations 

Brush Cleaning/ 

Spray Gun Cleaning 

Acetone, toluene, 

petroleum distillates, 

methanol, methylene 

chloride, isopropanol, 

mineral spirits, 

alcohols 

Solvent 

emissions (e.g., 

acetone, 

toluene, 

methanol, 

methylene 

chloride) 

Spent solvents 

(e.g., acetone, 

toluene, 

methanol, 

methylene 

chloride), 

mineral spirits, 

alcohols, 

petroleum 

distillates 

Spent solvents 

(e.g., acetone, 

toluene, 

methanol, 

methylene 

chloride), mineral 

spirits, alcohols, 

petroleum 

distillates 

Boilers 

Boilers Wood and coating 

material particulates 

from the finishing 

process 

Boiler ash 

particulates 

Boiler ash 

Source: Pollution Prevention Options in Wood Furniture Manufacturing, 1992. 

III.C. Management of Chemicals in Wastestream 

The Pollution Prevention Act of 1990 (EPA) requires facilities to report 

information about the management of TRI chemicals in waste and 

efforts made to eliminate or reduce those quantities. These data have 

been collected annually in Section 8 of the TRI reporting Form R 

beginning with the 1991 reporting year. The data summarized below 

cover the years 1992-1995 and is meant to provide a basic 

understanding of the quantities of waste handled by the industry, the 

methods typically used to manage this waste, and recent trends in 

these methods. TRI waste management data can be used to assess 

trends in source reduction within individual industries and facilities, 

and for specific TRI chemicals. This information could then be used as 

a tool in identifying opportunities for pollution prevention compliance 

assistance activities. 

While the quantities reported for 1992 and 1993 are estimates of 

quantities already managed, the quantities reported for 1994 and 1995 

are projections only. The EPA requires these projections to encourage 

facilities to consider future waste generation and source reduction of 

those quantities as well as movement up the waste management 

September 1995 35 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

hierarchy. Future-year estimates are not commitments that facilities 

reporting under TRI are required to meet. 

Exhibit 10 shows that the furniture and fixtures industry managed 

about 47 million pounds of production-related waste (total quantity of 

TRI chemicals in the waste from routine production operations) in 

1993 (column B). Column C reveals that of this production-related 

waste, 98 percent was either transferred off-site or released to the 

environment. Column C is calculated by dividing the total TRI 

transfers and releases by the total quantity of production-related 

waste. In other words, about one percent of the industry's TRI wastes 

were managed on-site through recycling, energy recovery, or 

treatment as shown in columns D, E and F, respectively. The majority 

of waste that is released or transferred off-site can be divided into 

portions that are recycled off-site, recovered for energy off-site, or 

treated off-site as shown in columns G, H, and I, respectively. The 

remaining portion of the production-related wastes (90.6 percent), 

shown in column J, is either released to the environment through 

direct discharges to air, land, water, and underground injection, or it is 

disposed off-site. 

From the yearly data presented below it is apparent that the portion of 

TRI wastes reported as recycled on-site has remained steady and the 

portions treated or managed through energy recovery on-site have 

decreased slightly between 1992 and 1995 (projected). 

Exhibit 10

Source Reduction and Recycling Activity for SIC 25

A C D E F G H I J 

Production 

Related 

Waste 

% Reported 

as Released On-Site Off-Site 

Remaining 

Releases 

Year 

Volume 

(106

lbs.) 

and 

Transferred 

% 

Recycled 

% Energy 

Recovery 

% Treated % 

Recycled 

% Energy 

Recovery 

% 

Treated 

and 

Disposal 

1992 44 100% 0.66% 0.00% 0.57% 2.32% 6.55% 0.90% 89.35% 

1993 47 98% 0.70% 0.02% 0.42% 2.38% 5.10% 0.80% 90.58% 

1994 44 — 0.76% 0.00% 0.46% 2.47% 4.60% 0.78% 90.93% 

1995 44 — 0.73% 0.00% 0.46% 2.60% 5.19% 0.72% 90.31% 

B 

SIC Code 25 36 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

IV. CHEMICAL RELEASE AND TRANSFER PROFILE 

This section is designed to provide background information on the 

pollutant releases that are reported by this industry. The best source 

of comparative pollutant release information is the Toxic Release 

Inventory System (TRI). Pursuant to the Emergency Planning and 

Community Right-to-Know Act, TRI includes self-reported facility 

release and transfer data for over 600 toxic chemicals. Facilities within 

SIC Codes 20-39 (manufacturing industries) that have more than 10 

employees, and that are above weight-based reporting thresholds are 

required to report TRI on-site releases and off-site transfers. The 

information presented within the sector notebooks is derived from the 

most recently available (1993) TRI reporting year (which then included 

316 chemicals), and focuses primarily on the on-site releases reported 

by each sector. Because TRI requires consistent reporting regardless of 

sector, it is an excellent tool for drawing comparisons across 

industries. 

Although this sector notebook does not present historical information 

regarding TRI chemical releases over time, please note that in general, 

toxic chemical releases have been declining. In fact, according to the 

1993 Toxic Release Inventory Data Book, reported releases dropped by 

42.7% between 1988 and 1993. Although on-site releases have 

decreased, the total amount of reported toxic waste has not declined 

because the amount of toxic chemicals transferred off-site has 

increased. Transfers have increased from 3.7 billion pounds in 1991 to 

4.7 billion pounds in 1993. Better management practices have led to 

increases in off-site transfers of toxic chemicals for recycling. More 

detailed information can be obtained from EPA's annual Toxics 

Release Inventory Public Data Release book (which is available 

through the EPCRA Hotline at 1-800-535-0202), or directly from the 

Toxic Release Inventory System database (for user support call 202-

260-1531). 

Wherever possible, the sector notebooks present TRI data as the 

primary indicator of chemical release within each industrial category. 

TRI data provide the type, amount, and media receptor of each 

chemical released or transferred. When other sources of pollutant 

release data have been obtained, these data have been included to 

augment the TRI information. 

September 1995 37 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

TRI Data Limitations 

The reader should keep in mind the following limitations regarding 

TRI data. Within some sectors, the majority of facilities are not subject 

to TRI reporting because they are not considered manufacturing 

industries, or because they are below TRI reporting thresholds. 

Examples are the mining, dry cleaning, printing, and transportation 

equipment cleaning sectors. For these sectors, release information 

from other sources has been included. 

The reader should also be aware that TRI "pounds released" data 

presented within the notebooks is not equivalent to a "risk" ranking for 

each industry. Weighting each pound of release equally does not 

factor in the relative toxicity of each chemical that is released. The 

Agency is in the process of developing an approach to assign 

toxicological weightings to each chemical released so that one can 

differentiate between pollutants with significant differences in toxicity. 

As a preliminary indicator of the environmental impact of the 

industry's most commonly released chemicals, the notebook briefly 

summarizes the toxicological properties of the top five chemicals (by 

weight) reported by each industry. 

Definitions Associated With Section IV Data Tables 

General Definitions 

SIC Code -- the Standard Industrial Classification (SIC) is a statistical 

classification standard used for all establishment-based Federal 

economic statistics. The SIC codes facilitate comparisons between 

facility and industry data. 

TRI Facilities -- are manufacturing facilities that have 10 or more fulltime employees and are above established chemical throughput 

thresholds. Manufacturing facilities are defined as facilities in 

Standard Industrial Classification primary codes 20-39. Facilities must 

submit estimates for all chemicals that are on the EPA's defined list 

and are above throughput thresholds. 

Data Table Column Heading Definitions 

The following definitions are based upon standard definitions 

developed by EPA’s Toxic Release Inventory Program. The categories 

below represent the possible pollutant destinations that can be 

reported. 

SIC Code 25 38 September 1995 
--

-- 

-- 

--

-- 

Sector Notebook Project Wood Furniture and Fixtures 

RELEASES are an on-site discharge of a toxic chemical to the 

environment. This includes emissions to the air, discharges to bodies 

of water, releases at the facility to land, as well as contained disposal 

into underground injection wells. 

Releases to Air (Point and Fugitive Air Emissions) -- Include all air 

emissions from industry activity. Point emissions occur through 

confined air streams as found in stacks, ducts, or pipes. Fugitive 

emissions include losses from equipment leaks, or evaporative losses 

from impoundments, spills, or leaks. 

Releases to Water (Surface Water Discharges) - encompass any 

releases going directly to streams, rivers, lakes, oceans, or other bodies 

of water. Any estimates for stormwater runoff and non-point losses 

must also be included. 

Releases to Land -- includes disposal of waste to on-site landfills, 

waste that is land treated or incorporated into soil, surface 

impoundments, spills, leaks, or waste piles. These activities must 

occur within the facility's boundaries for inclusion in this category. 

Underground Injection is a contained release of a fluid into a 

subsurface well for the purpose of waste disposal. 

TRANSFERS is a transfer of toxic chemicals in wastes to a facility 

that is geographically or physically separate from the facility reporting 

under TRI. The quantities reported represent a movement of the 

chemical away from the reporting facility. Except for off-site transfers 

for disposal, these quantities do not necessarily represent entry of the 

chemical into the environment. 

Transfers to POTWs are wastewaters transferred through pipes or 

sewers to a publicly owned treatments works (POTW). Treatment and 

chemical removal depend on the chemical's nature and treatment 

methods used. Chemicals not treated or destroyed by the POTW are 

generally released to surface waters or landfilled within the sludge. 

Transfers to Recycling are sent off-site for the purposes of 

regenerating or recovering still valuable materials. Once these 

chemicals have been recycled, they may be returned to the originating 

facility or sold commercially. 

September 1995 39 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

Transfers to Energy Recovery -- are wastes combusted off-site in 

industrial furnaces for energy recovery. Treatment of a chemical by 

incineration is not considered to be energy recovery. 

Transfers to Treatment -- are wastes moved off-site for either 

neutralization, incineration, biological destruction, or physical 

separation. In some cases, the chemicals are not destroyed but 

prepared for further waste management. 

Transfers to Disposal -- are wastes taken to another facility for 

disposal generally as a release to land or as an injection underground. 

IV.A. Toxic Release Inventory for the Wood Furniture and Fixtures 

Industry 

Exhibits 13-15 illustrate the TRI releases and transfers for the entire 

furniture and fixtures industry (SIC 25). For the industry as a whole, 

solvents (such as toluene, methanol, xylene, methyl ethyl ketone, and 

acetone) comprise the largest number of TRI releases. The large 

number of solvent releases, both fugitive and point source emissions, 

result from the solvent-intensive finishing processes employed by this 

industry. In addition to being used as vehicle carriers, solvents are 

also used to clean the coatings application equipment. 

The TRI database contains a detailed compilation of self-reported, 

facility-specific chemical releases. The top reporting facilities for this 

sector are listed below. Facilities that have reported only the SIC codes 

covered under this notebook appear in Exhibit 11. Exhibit 12 contains 

additional facilities that have reported the SIC code covered within 

this report, and one or more SIC codes that are not within the scope of 

this notebook. Therefore, Exhibit 12 includes facilities that conduct 

multiple operations — some that are under the scope of this notebook, 

and some that are not. Currently, the facility-level data do not allow 

pollutant releases to be broken apart by industrial process. 

SIC Code 25 40 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

Exhibit 11

Top 10 TRI Releasing Furniture Manufacturing Facilities (SIC 25)

Rank 

Total TRI 

Releases in 

Pounds 

Facility Name City State 

1 1,277,737 Broyhill Furniture Ind., Inc. Complex Lenoir NC 

2 831,751 Broyhill Furniture Ind., Inc., Lenoir 

Furn. & Occas. 

Lenoir NC 

3 723,669 Singer Furniture Co. Lenoir NC 

4 700,675 Korn Ind., Inc. Sumter SC 

5 688,907 Lane Co., Inc. Altavista VA 

6 662,695 Okla Homer Smith Furniture Co., Inc. Fort Smith AR 

7 661,059 Stanley Furniture Co. Stanleytown VA 

8 642,385 J. D. Bassett Mfg. Co. Bassett VA 

9 639,345 Peters-Revington Furniture Delphi IN 

10 502,582 Bassett Superior Lines Bassett VA 

Source: U.S. EPA, Toxics Release Inventory Database, 1993. 

Exhibit 12

Top 10 TRI Releasing Furniture and Fixtures Facilities

SIC Codes Total TRI 

Releases in 

Pounds 

Facility Name City State 

2522, 2542, 

2521 

1,321,283 Steelcase Inc. Grand Rapids MI 

2511 1,277,737 Broyhill Furniture Ind. 

Complex 

Lenoir NC 

2542, 2541 939,055 Hadix, Inc. Goodwater AL 

2511 831,751 Broyhill Furniture Ind., Inc. 

Lenoir Furn. & Occas. 

Lenoir NC 

2522, 2542, 

2521 

809,096 Steelcase Inc. Kentwood NI 

2511 723,669 Singer Furniture Co. Lenoir NC 

2511 700,675 Korn Ind., Inc. Sumter SC 

2511 688,907 Lane Co., Inc. Altavista VA 

2511 662,695 Okla Homer Smith Furniture 

Co., Inc. 

Fort Smith AR 

2511 661,059 Stanley Furniture Co. Stanleytown VA 

Source: U.S. EPA, Toxics Release Inventory Database, 1993. 

Note: Being included on this list does not mean that the release is associated with non-compliance with 

environmental laws. 

September 1995 41 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project

SIC Code 25 42 September 1995

Exhibit 13

TRI Reporting Furniture Manufacturing Facilities (SIC 25) by State

State

Number of

Facilities State

Number of

Facilities

AL 7 MS 3

AR 8 NC 92

AZ 2 NE 2

CA 23 NH 1

CO 2 NY 14

CT 1 OH 4

FL 3 OK 2

GA 5 OR 3

IA 3 PA 9

IL 2 SC 5

IN 27 TN 13

KS 3 UT 2

KY 4 VA 32

MA 6 VT 3

ME 2 WA 3

MI 6 WI 10

MN 5 WV 1

MO 5

Source: U.S. EPA, Toxics Release Inventory Database, 1993.

Exhibit 14

Releases for Furniture Manufacturing Facilities (SIC 25) in TRI, by Number of

Facilities (Releases reported in pounds/year)

Chemical Name

# Facilities

Reporting

Chemical

Fugitive Air

Point Air

Water

Discharges

Underground

Injection

Land

Disposal

Total

Releases

Average

Releases

per

Facility

Toluene 247 1456881 10541044 5 0 70819 12068749 48861

Methanol 178 908347 8166501 10 0 7347 9082205 51024

Xylene (Mixed Isomers) 174 742449 5085471 5 0 14064 5841989 33575

Methyl Ethyl Ketone 166 439743 4241878 5 0 21507 4703133 28332

Acetone 115 282555 3157999 5 0 28328 3468887 30164

N-Butyl Alcohol 99 151616 2208962 5 0 13531 2374114 23981

Methyl Isobutyl Ketone 55 206847 1293417 5 0 58491 1558760 28341

Glycol Ethers 26 68627 413901 0 0 0 482528 18559

1,1,1-Trichloroethane 25 262643 1334203 0 0 4900 1601746 64070

Ethylbenzene 21 120246 241345 0 0 0 361591 17219

Isopropyl Alcohol

(Manufacturing)

11 9747 278413 0 0 0 288160 26196

Dichloromethane 6 102811 43894 0 0 0 146705 24451

Formaldehyde 6 30226 1086 0 0 0 31312 5219

Styrene 6 2744 42252 0 0 0 44996 7499

Di(2-Ethylhexyl) Phthalate 4 255 12458 0 0 0 12713 3178
Sector Notebook Project Wood Furniture and Fixtures 

Exhibit 14 (cont'd)

Releases for Furniture Manufacturing Facilities (SIC 25) in TRI, by Number of

Facilities (Releases reported in pounds/year)

Chemical Name 

# Facilities 

Reporting 

Chemical 

Fugitive Air 

Point Air 

Water 

Discharges 

Underground 

Injection 

Land 

Disposal 

Total 

Releases 

Average 

Releases 

per 

Facility 

Ethylene Glycol 4 616 26576 0 0 0 27192 6798 

1,2,4-Trimethylbenzene 4 2159 39987 0 0 0 42146 10537 

Trichloroethylene 3 1600 41781 0 0 0 43381 14460 

Barium Compounds 2 0 518 518 259 

Manganese 2 251 3 0 0 0 254 127 

Methylenebis 

(Phenylisocyanate) 

2 0 0 0 0 10 5 

Naphthalene 2 6 113 0 0 0 119 60 

Aluminum Oxide (Fibrous 

Form) 

1 11 224 0 0 0 235 235 

Ammonia 1 250 17000 0 0 0 17250 17250 

Chromium 1 250 0 0 0 0 250 250 

Copper 1 250 0 0 0 0 250 250 

Cumene 1 6 114 0 0 0 120 120 

Dibutyl Phthalate 1 6 110 0 0 0 116 116 

Diethyl Sulfate 1 869 16516 0 0 0 17385 17385 

Lead 1 250 0 0 0 0 250 250 

Maleic Anhydride 1 0 0 0 0 

Nickel 1 250 0 0 0 0 250 250 

Phenol 1 1 19 0 0 0 20 20 

Sulfuric cid A 1 0 0 0 0 

Vinyl Acetate 1 1 1163 0 0 0 1164 1164 

Totals 313 4,792,523 37,206,430 40 0 219,505 42,218,498 134,883 

0 0 0 

1 0 

0 0 0 

0 0 0 

Source: U.S. EPA, Toxics Release Inventory Database, 1993. 

September 1995 43 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project

SIC Code 25 44 September 1995

Exhibit 15

Transfers for Furniture Manufacturing Facilities (SIC 25) in TRI, by Number of

Facilities (Transfers reported in pounds/year)

Chemical Name

# Facilities

Reporting

Chemical

POTW

Discharges Disposal Recycling Treatment

Energy

Recovery

Total

Transfers

Average

Transfers

per

Facility

Toluene 247 3737 48124 400040 117454 746458 1315821 5327

Methanol 178 2114 33630 162308 25295 387147 610494 3430

Xylene (Mixed

Isomers)

174 2869 43912 83315 43768 212406 386270 2220

Methyl Ethyl Ketone 166 1540 38830 176031 57181 530621 804953 4849

Acetone 115 1030 . 281800 33469 304307 620606 5397

N-Butyl Alcohol 99 531 250 40077 26163 81491 148762 1503

Methyl Isobutyl Ketone 55 260 1925 7812 67211 63094 140552 2555

Glycol Ethers 26 0 . 7455 1284 43794 52533 2021

1,1,1-Trichloroethane 25 0 5905 . . 5608 11513 461

Ethylbenzene 21 255 31500 17979 165 10363 60262 2870

Isopropyl Alcohol

(Manufacturing)

11 499 . . 330 28509 29338 2667

Dichloromethane 6 0 . . 10430 4000 14430 2405

Formaldehyde 6 250 . . . . 250 42

Styrene 6 0 . 8520 . 131 8651 1442

Di(2-Ethylhexyl)

Phthalate

4 0 . . . 1625 1625 406

Ethylene Glycol 4 0 . . . . 0 0

1,2,4-Trimethylbenzene 4 0 . . 0 3393 3393 848

Trichloroethylene 3 0 . 1331 . . 1331 444

Barium Compounds 2 0 750 . . . 750 375

Manganese 2 0 . . . . 0 0

Methylenebis

(Phenylisocyanate)

2 . . . . 0 0

Naphthalene 2 0 . . . . 0 0

Aluminum Oxide

(Fibrous Form)

1 . . . . 0 0

Ammonia 1 0 . . . . 0 0

Chromium 1 0 . . . . 0 0

Copper 1 0 . . . . 0 0

Cumene 1 0 . . . . 0 0

Dibutyl Phthalate 1 0 . . . . 0 0

Diethyl Sulfate 1 0 . . . . 0 0

Lead 1 0 . . . . 0 0

Maleic Anhydride 1 0 . . . . 0 0

Nickel 1 0 . . . . 0 0

Phenol 1 0 . . . . 0 0

Sulfuric Acid 1 0 . . . . 0 0

Vinyl Acetate 1 0 . . . . 0 0

Totals 313 13,085 204,826 1,186,668 382,750 2,422,947 4,211,534 13,455

Source: U.S. EPA, Toxics Release Inventory Database, 1993.

0

0
Sector Notebook Project Wood Furniture and Fixtures 

IV.B. Summary of the Selected Chemicals Released 

The following is a synopsis of current scientific toxicity and fate 

information for the top chemicals (by weight) that facilities within this 

sector self-reported as released to the environment based upon 1993 

TRI data. Because this section is based upon self-reported release data, 

it does not attempt to provide information on management practices 

employed by the sector to reduce the release of these chemicals. 

Information regarding pollutant release reductions over time may be 

available from EPA's TRI and 33/50 programs, or directly from the 

industrial trade associations that are listed in Section IX of this 

document. Since these descriptions are cursory, please consult the 

sources referenced below for a more detailed description of both the 

chemicals described in this section, and the chemicals that appear on 

the full list of TRI chemicals appearing in Section IV.A. 

The brief descriptions provided below were taken from the 1993 Toxics 

Release Inventory Public Data Release (U.S. EPA, 1994), the Hazardous 

Substances Data Bank (HSDB), and the Integrated Risk Information 

System (IRIS), both accessed via TOXNET1. The information contained 

below is based upon exposure assumptions that have been conducted 

using standard scientific procedures. The effects listed below must be 

taken in context of these exposure assumptions that are more fully 

explained within the full chemical profiles in HSDB. 

1 TOXNET is a computer system run by the National Library of Medicine that includes a number of 

toxicological databases managed by EPA, National Cancer Institute, and the National Institute for 

Occupational Safety and Health. For more information on TOXNET, contact the TOXNET help line 

at 1-800-231-3766. Databases included in TOXNET are: CCRIS (Chemical Carcinogenesis Research 

Information System), DART (Developmental and Reproductive Toxicity Database), DBIR (Directory 

of Biotechnology Information Resources), EMICBACK (Environmental Mutagen Information Center 

Backfile), GENE-TOX (Genetic Toxicology), HSDB (Hazardous Substances Data Bank), IRIS 

(Integrated Risk Information System), RTECS (Registry of Toxic Effects of Chemical Substances), and 

TRI (Toxic Chemical Release Inventory). HSDB contains chemical-specific information on 

manufacturing and use, chemical and physical properties, safety and handling, toxicity and 

biomedical effects, pharmacology, environmental fate and exposure potential, exposure standards 

and regulations, monitoring and analysis methods, and additional references. 

September 1995 45 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

The top TRI releases for the furniture and fixtures industry (SIC 25) as

a whole, include:

Toluene

Methanol

Xylene

Methyl ethyl ketone

Acetone

N-butyl alcohol

1 1,1-trichloroethane

Dichloromethane.

Summaries of some of these chemicals follow.

Toluene 

Toxicity. Inhalation or ingestion of toluene can cause headaches, 

confusion, weakness, and memory loss. Toluene may also affect the 

way the kidneys and liver function. 

Reactions of toluene (see environmental fate) in the atmosphere 

contribute to the formation of ozone in the lower atmosphere. Ozone 

can affect the respiratory system, especially in sensitive individuals 

such as asthma or allergy sufferers. 

Some studies have shown that unborn animals were harmed when 

high levels of toluene were inhaled by their mothers, although the 

same effects were not seen when the mothers were fed large quantities 

of toluene. Note that these results may reflect similar difficulties in 

humans. 

Carcinogenicity. There is currently no evidence to suggest that this 

chemical is carcinogenic. 

Environmental Fate. The majority of releases of toluene to land and 

water will evaporate. Toluene may also be degraded by 

microorganisms. Once volatized, toluene in the lower atmosphere will 

react with other atmospheric components contributing to the formation 

of ground-level ozone and other air pollutants. 

Physical Properties. Toluene is a volatile organic chemical. 

SIC Code 25 46 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

Methanol 

Toxicity. Methanol is readily absorbed from the gastrointestinal tract 

and the respiratory tract, and is toxic to humans in moderate to high 

doses. In the body, methanol is converted into formaldehyde and 

formic acid. Methanol is excreted as formic acid. Observed toxic 

effects at high dose levels generally include central nervous system 

damage and blindness. Long-term exposure to high levels of 

methanol via inhalation cause liver and blood damage in animals. 

Ecologically, methanol is expected to have low toxicity to aquatic 

organisms. Concentrations lethal to half the organisms of a test 

population are expected to exceed 1 mg methanol per liter water. 

Methanol is not likely to persist in water or to bioaccumulate in 

aquatic organisms. 

Carcinogenicity. There is currently no evidence to suggest that this 

chemical is carcinogenic. 

Environmental Fate. Liquid methanol is likely to evaporate when left 

exposed. Methanol reacts in air to produce formaldehyde which 

contributes to the formation of air pollutants. In the atmosphere it can 

react with other atmospheric chemicals or be washed out by rain. 

Methanol is readily degraded by microorganisms in soils and surface 

waters. 

Physical Properties. Methanol is highly flammable. 

Xylene (Mixed Isomers) 

Toxicity. Xylenes are rapidly absorbed into the body after inhalation, 

ingestion, or skin contact. Short-term exposure of humans to high 

levels of xylenes can cause irritation of the skin, eyes, nose, and throat, 

difficulty in breathing, impaired lung function, impaired memory, and 

possible changes in the liver and kidneys. Both short- and long-term 

exposure to high concentrations can cause effects such as headaches, 

dizziness, confusion, and lack of muscle coordination. Reactions of 

xylenes (see environmental fate) in the atmosphere contribute to the 

formation of ozone in the lower atmosphere. Ozone can affect the 

respiratory system, especially in sensitive individuals such as asthma 

or allergy sufferers. 

September 1995 47 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

Carcinogenicity. There is currently no evidence to suggest that this 

chemical is carcinogenic. 

Environmental Fate. The majority of releases to land and water will 

quickly evaporate, although some degradation by microorganisms will 

occur. 

Xylenes are moderately mobile in soils and may leach into 

groundwater, where they may persist for several years. 

Xylenes are volatile organic chemicals. As such, xylenes in the lower 

atmosphere will react with other atmospheric components, 

contributing to the formation of ground-level ozone and other air 

pollutants. 

Methyl Ethyl Ketone 

Toxicity. Breathing moderate amounts of methyl ethyl ketone (MEK) 

for short periods of time can cause adverse effects on the nervous 

system ranging from headaches, dizziness, nausea, and numbness in 

the fingers and toes to unconsciousness. Its vapors are irritating to the 

skin, eyes, nose, and throat and can damage the eyes. Repeated 

exposure to moderate to high amounts may cause liver and kidney 

effects. 

Carcinogenicity. No agreement exists over the carcinogenicity of 

MEK. One source believes MEK is a possible carcinogen in humans 

based on limited animal evidence. Other sources believe that there is 

insufficient evidence to make any statements about possible 

carcinogenicity. 

Environmental Fate. Most of the MEK released to the environment 

will end up in the atmosphere. MEK can contribute to the formation of 

air pollutants in the lower atmosphere. It can be degraded by 

microorganisms living in water and soil. 

Physical Properties. Methyl ethyl ketone is a flammable liquid. 

Acetone 

Toxicity. Acetone is irritating to the eyes, nose, and throat. Symptoms 

of exposure to large quantities of acetone may include headache, 

unsteadiness, confusion, lassitude, drowsiness, vomiting, and 

respiratory depression. 

SIC Code 25 48 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

Reactions of acetone (see environmental fate) in the lower atmosphere 

contribute to the formation of ground-level ozone. Ozone (a major 

component of urban smog) can affect the respiratory system, especially 

in sensitive individuals such as asthmatics or allergy sufferers. 

Carcinogenicity. There is currently no evidence to suggest that this 

chemical is carcinogenic. 

Environmental Fate. If released into water, acetone will be degraded 

by microorganisms or will evaporate into the atmosphere. 

Degradation by microorganisms will be the primary removal 

mechanism. 

Acetone is highly volatile, and once it reaches the troposphere (lower 

atmosphere), it will react with other gases, contributing to the 

formation of ground-level ozone and other air pollutants. EPA is 

reevaluating acetone's reactivity in the lower atmosphere to determine 

whether this contribution is significant. 

Physical Properties. Acetone is a volatile and flammable organic 

chemical. 

Note: Acetone was removed from the list of TRI chemicals on June 16, 1995 

(60 FR 31643) and will not be reported for 1994 or subsequent years. 

1,1,1-Trichloroethane 

Toxicity. Repeated contact of 1,1,1-trichloroethane (TCE) with skin 

may cause serious skin cracking and infection. Vapors cause a slight 

smarting of the eyes or respiratory system if present in high 

concentrations. 

Exposure to high concentrations of TCE causes reversible mild liver 

and kidney dysfunction, central nervous system depression, gait 

disturbances, stupor, coma, respiratory depression, and even death. 

Exposure to lower concentrations of TCE leads to light-headedness, 

throat irritation, headache, disequilibrium, impaired coordination, 

drowsiness, convulsions and mild changes in perception. 

Carcinogenicity. There is currently no evidence to suggest that this 

chemical is carcinogenic. 

September 1995 49 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

Environmental Fate. Releases of TCE to surface water or land will 

almost entirely volatilize. Releases to air may be transported long 

distances and may partially return to earth in rain. In the lower 

atmosphere, TCE degrades very slowly by photooxidation and slowly 

diffuses to the upper atmosphere where photodegradation is rapid. 

Any TCE that does not evaporate from soils leaches to groundwater. 

Degradation in soils and water is slow. TCE does not hydrolyze in 

water, nor does it significantly bioconcentrate in aquatic organisms. 

IV.C. Other Data Sources 

The Aerometric Information Retrieval System (AIRS) contains a wide 

range of information related to stationary sources of air pollution, 

including the emissions of a number of air pollutants which may be of 

concern within a particular industry. With the exception of volatile 

organic compounds (VOCs), there is little overlap with the TRI 

chemicals reported above. Exhibit 16 summarizes annual releases of 

carbon monoxide (CO), nitrogen dioxide (NO2), particulate matter of 

10 microns or less (PM10), total particulates (PT), sulfur dioxide (SO2), 

and volatile organic compounds (VOCs). 

Exhibit 16

Pollutant Releases (Short Tons/Year)

Industry CO NO2 PM10 PT SO2 VOC 

U.S. Total 97,208,000 23,402,000 45,489,000 7,836,000 21,888,000 23,312,000 

Metal Mining 5,391 28,583 39,359 140,052 84,222 1,283 

Nonmetal Mining 4,525 28,804 59,305 167,948 24,129 1,736 

Lumber and Wood 

Products 

123,756 42,658 14,135 63,761 9,149 41,423 

Wood Furniture and 

Fixtures 

2,069 2,981 2,165 3,178 1,606 59,426 

Pulp and Paper 624,291 394,448 35,579 113,571 341,002 96,875 

Printing 8,463 4,915 399 1,031 1,728 101,537 

Inorganic Chemicals 166,147 108,575 4,107 39,082 182,189 52,091 

Organic Chemicals 146,947 236,826 26,493 44,860 132,459 201,888 

Petroleum Refining 419,311 380,641 18,787 36,877 648,153 309,058 

Rubber and Misc. Plastic 

Products 

2,090 11,914 2,407 5,355 29,364 140,741 

Stone, Clay, Glass, and 

Concrete 

58,043 338,482 74,623 171,853 339,216 30,262 

Iron and Steel 1,518,642 138,985 42,368 83,017 238,268 82,292 

Nonferrous Metals 448,758 55,658 20,074 22,490 373,007 27,375 

Fabricated Metals 3,851 16,424 1,185 3,136 4,019 102,186 

Electronics 367 1,129 207 293 453 4,854 

SIC Code 25 50 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

Motor Vehicles, Bodies, 

Parts, and Accessories 

35,303 23,725 2,406 12,853 25,462 101,275 

Dry Cleaning 101 179 3 28 152 7,310 

Source U.S. EPA Office of Air and Radiation, AIRS Database, May 1995. 

September 1995 51 SIC Code 25
Wood Furniture and Fixtures Sector Notebook Project 

IV.D. Comparison of Toxic Release Inventory Between Selected Industries 

The following information is presented as a comparison of pollutant 

release and transfer data across industrial categories. It is provided to 

give a general sense as to the relative scale of releases and transfers 

within each sector profiled under this project. Please note that the 

following table does not contain releases and transfers for industrial 

categories that are not included in this project, and thus cannot be used 

to draw conclusions regarding the total release and transfer amounts 

that are reported to TRI. Similar information is available within the 

annual TRI Public Data Release book. 

Exhibit 17 is a graphical representation of a summary of the 1993 TRI 

data for the Wood Furniture and Fixtures Industry and the other 

sectors profiled in separate notebooks. The bar graph presents the 

total TRI releases and total transfers on the left axis and the triangle 

points show the average releases per facility on the right axis. 

Industry sectors are presented in the order of increasing total TRI 

releases. The graph is based on the data shown in Exhibit 18 and is 

meant to facilitate comparisons between the relative amounts of 

releases, transfers, and releases per facility both within and between 

these sectors. The reader should note, however, that differences in the 

proportion of facilities captured by TRI exist between industry sectors. 

This can be a factor of poor SIC matching and relative differences in 

the number of facilities reporting to TRI from the various sectors. In 

the case of the Wood Furniture and Fixtures Industry, the 1993 TRI 

data presented here covers 313 facilities. These facilities listed SIC 25, 

Wood as a primary SIC code. 

SIC Code 25 52 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

Exhibit 17

0 

100 

200 

300 

400 

500 

600 

700 

Total Pounds (millions) 

0 

200,000 

400,000 

600,000 

800,000 

1,000,000 

Average Releases per Facility (lbs.) 

36 

24 

32 

27 

25 

2911 

34 

371 

331 

30 

286 

26 

281 

333, 334 

Total Releases Total Transfers Avg. Releases/Facility 

SIC 

Range 

Industry Sector SIC 

Range 

Industry Sector SIC 

Range 

Industry Sector 

36 Electronic Equipment and 

Components 

2911 Petroleum Refining 286 Organic Chemical Mfg. 

24 Lumber and Wood 

Products 

34 Fabricated Metals 26 Pulp and Paper 

32 Stone, Clay, and Concrete 371 Motor Vehicles, Bodies, 

Parts, and Accessories 

281 Inorganic Chemical Mfg. 

27 Printing 331 Iron and Steel 333,334 Nonferrous Metals 

25 Wood Furniture and 

Fixtures 

30 Rubber and Misc. 

Plastics 

September 1995 53 SIC Code 25
Wood Furniture and Fixtures Sector Notebook Project 

Exhibit 18 

Toxic Release Inventory Data for Selected Industries 

Releases Transfers Total 

Industry Sector SIC 

Range 

# TRI 

Facilities 

Total Releases 

(106 pounds) 

Average Releases 

per Facility 

(pounds) 1993 Total (106 

pounds) 

Average Transfers 

per Facility 

(pounds) 

Releases + 

Transfers 

(106 pounds) 

Average 

Release+ 

Transfers per 

Facility 

(pounds) 

Stone, ay, and 

Concrete 

32 634 26.6 41,895 2.2 3,500 28.2 46,000 

Lumber and 

Products 

24 491 8.4 17,036 3.5 7,228 11.9 24,000 

Furniture and 

Fixtures 

25 313 42.2 134,883 4.2 13,455 46.4 148,000 

Printing 2711-

2789 

318 36.5 115,000 10.2 732,000 46.7 147,000 

Electronics/Computer 

s 

36 406 6.7 16,520 47.1 115,917 53.7 133,000 

Rubber and Misc. 

Plastics 

30 1,579 118.4 74,986 45.0 28,537 163.4 104,000 

Motor Vehicle, 

Bodies, Parts and 

Accessories 

371 609 79.3 130,158 145.5 238,938 224.8 369,000 

Pulp and paper 2611-

2631 

309 169.7 549,000 48.4 157,080 218.1 706,000 

Inorganic Chem. Mfg. 2812-

2819 

555 179.6 324,000 70.0 126,000 249.7 450,000 

Petroleum Refining 2911 156 64.3 412,000 417.5 2,676,000 481.9 3,088,000 

Fabricated Metals 34 2,363 72.0 30,476 195.7 82,802 267.7 123,000 

Iron and Steel 3312-

3313 

3321-

3325 

381 85.8 225,000 609.5 1,600,000 695.3 1,825,000 

Nonferrous Metals 333, 334 208 182.5 877,269 98.2 472,335 280.7 1,349,000 

Organic hemical 

Mfg. 

2861-

2869 

417 151.6 364,000 286.7 688,000 438.4 1,052,000 

Metal Mining 10 Industry sector not subject to TRI reporting 

Nonmetal Mining 14 Industry sector not subject to TRI reporting 

Dry Cleaning 7215, 

7216, 

7218 

Industry sector not subject to TRI reporting 

Cl

Wood 

C

Source: U.S. EPA, Toxics Release Inventory Database, 1993. 

SIC Code 25 54 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

V. POLLUTION PREVENTION OPPORTUNITIES 

The best way to reduce pollution is to prevent it in the first place. 

Some companies have creatively implemented pollution prevention 

techniques that improve efficiency and increase profits while at the 

same time minimizing environmental impacts. This can be done in 

many ways such as reducing material inputs, re-engineering processes 

to reuse by-products, improving management practices, and 

employing substitution of toxic chemicals. Some smaller facilities are 

able to actually get below regulatory thresholds just by reducing 

pollutant releases through aggressive pollution prevention policies. 

In order to encourage these approaches, this section provides both 

general and company-specific descriptions of some pollution 

prevention advances that have been implemented within the Wood 

Furniture and Fixtures industry. While the list is not exhaustive, it 

does provide core information that can be used as the starting point for 

facilities interested in beginning their own pollution prevention 

projects. When possible, this section provides information from real 

activities that can, or are being implemented by this sector -- including 

a discussion of associated costs, time frames, and expected rates of 

return. This section also provides the context (in terms of type of 

industry and/or type of process affected) in which the pollution 

prevention technique can effectively be used. 

The following discussion of pollution prevention initiatives is based 

mainly on the EPA document Pollution Prevention Options in Wood 

Furniture Manufacturing and identifies those steps in the 

manufacturing process for which pollution prevention initiatives can 

and have been implemented. Exhibit 19 provides examples of process 

modification, material substitution, waste reduction, and recycling 

options for finishing and gluing operations. The EPA document from 

which this exhibit was developed does not indicate the methods used 

to compute cost savings. 

September 1995 55 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

V.A. Identification of Pollution Prevention Activities in Use and 

Environmental and Economic Benefits of Each Pollution Prevention 

Activity 

Pollution prevention techniques and processes currently used by the 

wood furniture and fixtures industry can be grouped into the 

following general categories: 

• Production planning and sequencing 

• Process or equipment modification 

• Raw material substitution or elimination 

• Loss prevention and housekeeping 

• Waste segregation and separation 

• Solvent recycling 

• Training and supervision. 

Each of these categories is discussed below briefly. Refer to Exhibit 19 

for specific pollution prevention techniques and associated costs, 

savings, and other information. 

Production planning and sequencing is used to ensure that only necessary 

operations are performed and that no operation is needlessly "undone" 

by a following operation. One example is to sort out reject parts prior 

to painting or finishing. A second example is to reduce the frequency 

of cleaning equipment by staining or painting all products of the same 

color at the same time. A third example is to schedule batch 

processing of lighter shades of paint prior to darker shades of paint so 

that equipment need not be cleaned between batches. 

Process or equipment modification is used to reduce the amount of waste 

generated. Manufacturers can change to a paint application technique 

that is more efficient than spray gun systems, such as airless and airassisted airless systems, electrostatic spray systems, or flat line 

finishing. 

Several technologies currently in the development stage could 

potentially apply to the wood furniture industry. These technologies 

are in the areas of spray booth design and curing methods. The spray 

booth designs discussed in this section include the Classic System 

Campbell Spray Booth and the Mobile Zone. Both designs seek to 

reduce the volume of air exhausted. 

SIC Code 25 56 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

Classic Systems has developed the Campbell spray booth, which the 

company indicates can reduce the volume of exhaust air by 

approximately 80 percent. The basic design of the Campbell spray 

booth involves the use of air curtains; the worker stands outside of the 

booth and sprays through the air curtain. The air curtain provides a 

barrier between the worker and the solvent emissions inside the booth 

resulting from coating the piece. A pilot system has been built, and a 

full-scale system has been designed. 

Mobile Zones Associates has developed a device which, when 

installed on a spray booth, enables the worker(s) to spray coatings 

from a partially enclosed mobile work platform. The worker stands 

inside a “cab,” the movement of which is controlled from inside the 

cab by the worker. Within the Mobile Zone cab, fresh ventilating air 

passes across the painter from an open “moving window” at his rear. 

The remaining section of the mobile work platform is ventilated using 

recirculated air. The Mobile Zone design contrasts with a conventional 

spray booth, in which the entire length of the booth is supplied with 

fresh ventilating air. 

Ultraviolet (UV)-curable coatings are frequently used by flatline 

furniture coating operations. Since the pieces are flat, curing in a 

conventional UV-cure oven is straightforward. Although UV-curable 

coatings are also applied to case goods (nonflat pieces), the UV-curing 

process with such pieces is more difficult. In order for a UV-curable 

coating to cure, all coating must be exposed to the UV-light. The 

lamps in the UV-oven must be situated to ensure exposure to all areas 

of the case goods, including recessed areas, carvings, etc. The UVlamp locations would need to be set for each type of case good 

depending on its configuration. Because furniture manufacturers 

typically produce many different types of case goods on a single line at 

any time, realignment of the UV-lamps for each type of case good is 

not feasible. However, if a manufacturer produces a single piece 

continuously for a length of time, the lamps could be arranged for that 

configuration. Then, after the lamps are adjusted, another type of 

piece could be produced for a length of time. 

Biofiltration is a control technology which sends contaminated exhaust 

air through a biofilter for contaminant removal. The biofilter consists 

of organic matter, such as tree bark and compost, the pores of which 

are filled with water. Biologically active micro-organisms are present, 

partly free-floating in the water and partly attached to the organic 

matter. 

September 1995 57 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

Raw material substitution or elimination is the replacement of existing 

raw materials with other materials that produce less waste, or a nontoxic waste. Some examples include substituting water-based finishes 

for solvent-based finishes or replacing volatile liquid finishes with 

electrostatically-applied powder finishes. 

Volatile organic compound (VOC) emissions from wood furniture 

finishing operations (primarily the hazardous air described in Section 

IV.B.) can be reduced by reformulating coating materials so that they 

contain fewer VOCs. Currently, in wood furniture finishing 

operations, VOC emissions result from the application and subsequent 

evaporation of finishing materials. Efforts are being made to 

reformulate the finishing materials used in the wood furniture 

industry so that they contain fewer VOCs. 

Waterborne finishing materials are currently being used by some 

furniture manufacturers. The potential exists for waterborne coatings 

to be used by all segments of the wood finishing industry. However, 

the waterborne coatings currently available are better suited to certain 

applications than others. For example: 

• Open pore woods are considered easier to finish with 

waterborne coatings than filled pores 

• Darker woods sometimes appear cloudy when finished with 

waterborne coatings, though the clarity has improved over the 

last ten years 

• Waterborne finishes do not have the rubbability of 

nitrocellulose lacquers and the finish is therefore not as glossy 

where a glossy finish is required 

• Waterborne coatings may require a modified drying method 

(increased airflow and temperature). 

Ultraviolet (UV)-curable coatings are currently used in various 

segments of the wood finishing industry. UV-curable coatings can be 

applied using spray equipment, roll coaters, or curtain coaters. 

Therefore, the potential exists for UV-curable coatings to be used on 

case good as well as flat pieces, and progress in this direction has been 

made. However, as mentioned previously, curing of the threedimensional pieces remains difficult because all of the coating 

materials must be exposed to the UV radiation. Problems arise in 

curing of recessed surfaces that do not get direct exposure to the 

SIC Code 25 58 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

radiation. Many studies are being conducted so that UV-curable 

materials may experience more widespread use in the future. 

Polyurethane coatings are used in some segments of the wood 

finishing industry. Polyurethane materials can be spray applied, or 

applied by curtain or roll coat, and are cured in the conventional 

manner. Polyurethane coatings are characterized by a high-gloss look, 

which may not be desirable to certain segments of the wood furniture 

industry. Other limitations that prevent its widespread use include 

the need for a clean room environment, the short pot life (one to six 

hours), and the difficulty in repairing. 

Polyester coatings are similar to polyurethanes in their uses and their 

limitations. The film properties of the polyester coatings are good; 

they provide good build and good chemical, mechanical, and heat 

resistance. However, application requires a clean room environment 

which can be very expensive and difficult to maintain. 

Loss prevention and housekeeping is the performance of preventive 

maintenance and equipment and materials management so as to 

minimize opportunities for leaks, spills, evaporative losses, and other 

releases of potentially toxic chemicals. For example, spray guns can be 

cleaned by submerging only the front end of the gun in the cleaning 

solvent; or routine maintenance of spray gun equipment can prevent 

equipment from breaking down and leaking. 

Waste segregation and separation involves avoiding the mixture of 

different types of wastes and avoiding the mixture of hazardous 

wastes with non-hazardous wastes. This makes the recovery of 

hazardous wastes easier by minimizing the number of different 

hazardous constituents in a given waste stream. Also, it prevents the 

contamination of non-hazardous wastes. Specific examples include 

segregating spent solvents by solvent types, and segregating nonhazardous paint solids from hazardous paint solvents and thinners. 

Solvent recycling is the use or reuse of a waste as an ingredient or 

feedstock in the production process on-site. Recycling in which a 

waste is recovered and reused in the production process on-site as an 

input is a form of pollution prevention. One example is the use of a 

small on-site still to recycle xylene or lacquer thinner. 

Training and supervision provides employees with the information and 

the incentive to minimize waste generation in their daily duties. This 

might include ensuring that employees know and practice proper and 

September 1995 59 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

efficient use of tools and supplies, and that they are aware of, 

understand, and support the company's pollution prevention goals. 

SIC Code 25 60 September 1995
Sector Notebook Project Wood Furniture and Fixtures 

Exhibit 19

Pollution Prevention Matrix

Process Pollution Prevention Process 

Economic and 

Environment Savings and 

Benefits 

Payback 

Period 

Application 

of finish and 

pre-finish 

coatings 

Process Modification 

Implement alternatives to compressed 

air spray gun systems including: 

1. Airless and air assisted airless • Material consumption 

reduction: 15% 

• Annual cost savings: 

$55,000 

• Waste volume from 

spray booth cleanup 

reduction: 50% 

Payback 

period: 

year 

2. Electrostatic spray systems • Annual cost savings: 

$150,000 

• Waste savings/ 

reduction from wiping 

stain compared to 

conventional spray 

units: 25% 

Payback 

period: 

years 

3. Flat line finishing • Annual savings in 

total coating costs: 20-

30% 

• Waste savings/ 

reduction in VOCs: 

25% 

Payback 

period: 

years 

Material Substitution 

Substitution of solvent-based inks with 

water-based inks 

• Annual cost savings in 

raw materials: 

$75,000 

• Annual cost savings in 

disposal costs: 

$37,000 

Information 

not available 

Waste Reduction 

Replace water-based paint booth 

filters with dry filters. Dry filters will 

double paint booth life and allow 

more efficient treatment of 

wastewater. 

• Annual cost savings: 

$1,500 

• Waste savings/ 

reductions: 3,000 

gallons/year 

Information 

not available 

Process Modification 

Train spray gun operators in proper 

spray techniques to minimize coating 

waste generation 

• Annual cost savings: 

$50,000 to $70,000 

• Finishing material 

required reduction: 

8-10% 

Information 

not available 

1 

2 

2 

September 1995 61 SIC Code 25
Wood Furniture and Fixtures Sector Notebook Project 

Exhibit 19 (cont'd) 

Pollution Prevention Matrix 

Process Pollution Prevention Process 

Economic and 

Environment Savings and 

Benefits 

Payback 

Period 

Application 

of finish and 

pre-finish 

coatings 

(continued) 

Recycling 

Recycle spent solvents with recovery 

units including: 

1. Small on-site solvent recovery still 

to recycle spent lacquer thinner 

• Annual cost savings: 

$5,700 

Payback 

period: 

year 

2. Small in-house still to recycle 

methylene chloride 

• Incentive was to avoid 

RCRA liability related 

to disposal 

Payback 

period: 

years 

3. In-house still to recycle xylene Information not 

available 

Payback 

period: 3 

months 

4. Batch distillation unit to recover 

xylene from paint equipment 

cleaning 

• Annual savings: 

$5,000 

Payback 

period: 3 

months 

5. Batch distillation to recover 

isopropyl acetate generated 

during equipment cleaning 

Information not available Payback 

period: 

years 

6. Recovery system for solvents 

contained in air emissions 

• Annual savings: 

$1,000 

Information 

not available 

7. Small solvent recovery still to 

recover spent paint thinner from 

spray gun cleaning and excess 

paint batches 

• Capital investment for 

a 15-gallon capacity 

still: $6,000 

• Annual savings in 

new thinner: $3,600 

• Annual disposal 

savings: $5,400 

• Waste savings/ 

reduction: 75% (745 

gallons of thinner 

recovered from 1,003 

gallons) 

• Product/waste 

throughput 

information: 1,500 

gallons of spent 

thinner processed per 

year 

Payback 

period: ess 

than one year 

1 

2 

1

1

2 

l

SIC Code 25 62 September 1995
Sector Notebook Project Wood Furniture and Fixtures 

Exhibit 19 (cont'd) 

Pollution Prevention Matrix 

Process Pollution Prevention Process 

Economic and 

Environment Savings and 

Benefits 

Payback 

Period 

Application 

of finish and 

pre-finish 

coatings 

(continued) 

8. Solvent recovery system to 

recover and reuse spent methyl 

ethyl ketone. 

• Annual savings: 

$43,000 

• MEK recovery rate: 

20 gallons/day 

(reflecting a 90% 

reduction in waste) 

Information 

not available 

Equipment 

cleaning 

Process Modification 

Flush equipment first with dirty 

solvent before final cleaning with 

virgin solvent and use cleanup 

solvents in formulation of subsequent 

batches of paint 

• Waste savings/ 

reduction: 98% 

• Paint cleanup solvents 

reduction: from 

25,000 to 400 gallons 

Information 

not available 

Source: Pollution Prevention Options in Wood Furniture Manufacturing, 1992. 

V.B. Pollution Prevention Case Studies 

Henredon Furniture Industries, located in California, applies stains 

and other finishes to chairs, benches, and a variety of other furniture 

items. Because the conventional spray guns that Henredon had been 

using were not meeting current regulations for VOC emissions, the 

company researched the feasibility of high-volume low-pressure 

(HVLP) spray guns. 

Henredon tested guns by a variety of manufacturers to find those that 

best fit their needs. The HVLP guns ultimately selected operate on air 

pressures from 7 to 10 psi, which is within the definitions set by 

California's South Coast Air Quality Management District. The lower 

pressure results in less overspray and more efficient use of material. 

The new HVLPs increased efficiency such that average material usage 

was reduced by 13 to 15 percent. Employee training on application 

techniques was also conducted to improve efficiency. The new guns 

improved product quality without slowing production rates. 

Henredon is currently using the HVLP guns to apply lacquers, sealers, 

and stains at three plant locations. 

Henredon saves approximately 18,512 gallons of raw material 

annually by using the more efficient guns. These savings equate to a 

reduction in VOC emissions of 126,060 pounds per year. 

September 1995 63 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

Purchase and installation cost between $350 and $500 per gun. 

Henredon figures to save approximately $119,673 per year in raw 

material usage, for an average payback period of 3.5 months. 

Thomson Crown Wood Products, Inc., manufactures wood television 

cabinets. Parts of these cabinets were sprayed with finishing 

materials by an air-assisted airless spray gun, resulting in the 

production of VOCs and a large paint waste stream. To ameliorate 

this problem, Crown Wood proposed to test high-volume lowpressure (HVLP) spray guns and evaluate their success in reducing 

these waste streams. 

Through in-house, on-line production testing, Crown Wood reviewed 

four different HVLP spray guns using penetrating stain (no-wipe), 

glaze, sap stain, equalizer, toner, shade, and water-based black paint. 

An HVLP spray gun manufactured by one company gave excellent 

performance during the penetrating stain and regular glaze 

applications. This gun was also highly recommended by the sprayers 

for its size, weight, triggering, and cleaning ease. However, because 

the sprayer did not hold a specific spray pattern very well, it could not 

be used for heavier finishes. Instead, an HVLP spray gun 

manufactured by another manufacturer, which also received good 

ratings by the sprayers, gave much more consistent coverage and 

spray pattern for the water-based black, sap stain, equalizer, shade, 

and toner finishes. 

With the new HVLP spray guns, Crown Wood has experienced 

material reductions of 65 percent for equalizer, 65 percent for stain, 54 

percent for toner, 35 percent for glaze, 35 percent for no-wipe, and 53 

percent for water-based black finishes. These reductions total over 

13,300 gallons per year, which also results in reductions in VOCs and 

paint waste. 

A total of $137,448 per year is the estimated savings from purchasing 

the new spray guns. Costs associated with paint waste reduction have 

not been determined, but a reduction in the amount of clean-up waste 

was evident. The cost of the project was $21,350. 

In July 1992, Crown Wood altered its printing process room to 

incorporate the lay-down or roll-on finishing top and end panels of the 

outside cabinet. With this process modification, 60 percent of the 

spraying operation is now diverted to the printing room. Along with 

paint waste and VOC discharges, this new application procedure 

reduced finishing purchases by 50 percent. 

SIC Code 25 64 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

Ethan Allen, Inc., manufactures dining and bedroom furniture. 

Coating procedures in the finishing operations produced 

approximately 37,000 pounds of hazardous waste annually. To reduce 

the quantity and disposal cost of this waste, the company made the 

equipment substitutions and cleanup changes discussed below. 

Some of the modifications resulted directly from employee 

suggestions. The company implemented a cost reduction program to 

facilitate employee involvement in waste/cost reduction activities. 

Employees submit waste/cost reduction ideas, which are evaluated by 

a cost reduction committee, and valid suggestions are assigned for 

savings calculations. 

Three main components of the coating operation generate the 

hazardous waste: overspraying collection systems, material transport 

systems, and equipment cleanup procedures. 

Overspray Collection Systems 

• Metal filters replaced paper/cardboard filters for all the coating 

operations. The metal filters are cleaned in a tank in which 

solvent is circulated with a diaphragm pump. The waste 

solvent/coating mix is distilled, and only the overspray is 

drummed for disposal. The cleaning solvent is reused. The 

metal filters used for lacquer and sealer overspray are hand 

wiped, and the dust is sent-off site for recycling. 

• A fabricated, sloped polyethylene-lined trough replaced 

absorbent wood shavings used to catch overspray. In the 

wiping stain booths, the trough is squeezed into a pan, and only 

the liquid overspray is drummed for disposal. 

• High-volume, low-pressure (HVLP) spray guns replaced 

conventional air-assisted spray gun equipment. As a result, the 

quantity of overspray to be filtered is reduced, and spraying 

efficiency is increased. Also, each operator is required to attend 

an annual technical training session. Training is provided by a 

representative of the spray gun manufacturer. 

Material Transport Systems 

• Polyethylene covers replaced cardboard covers for pallets used 

to transport products through coating operations. The 

overspray is peeled off the polyethylene cover and drummed 

for disposal. 

September 1995 65 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

• The racks used to transport material on the conveyor system are 

cleaned periodically during the boiler watchman’s free time. 

Thus, the employee’s time is utilized, and the racks can be 

reused. This procedure lengthens the life of the racks, which 

must be cleaned or disposed of as a solid hazardous waste. 

Cleanup Operations 

• A solvent distillation unit was installed to recover usable 

solvents and reduce hazardous waste generation. A sevengallon batch still, which is run twice daily, recovers five gallons 

of reusable solvent for every seven gallons of cleanup waste. 

These equipment substitutions and changes in cleanup procedures 

resulted in the elimination of 25,900 pounds of hazardous waste 

annually, for an estimated cost savings of $129,465 per year. The 

following exhibit lists the process, cost of implementation, quantity of 

waste reduction, and annual cost savings. 

Exhibit 20 

Ethan Allen Pollution Prevention Case Study Summary 

Process 

Capitol 

Investment, $ 

Waste Reduction, 

lbs/year 

Savings, 

$/year 

Metal Filters 7,000 10,000 48,125 

Lacquer and 

Sealer Recycle 

1,500 2,300 6,150 

Polyethylene 

Trough 

400 6,100 38,430 

HVLP Spray 

Guns (12 guns @ 

$250) 

3,000 Material Use Reduction: 

Sap Stain 27% 

Sealer 20% 

Lacquer 11% 

Material Use Savings: 

15,000 to 20,000 

Polyethylene 

Pallet Covers 

2,050 3,700 7,450 

Rack Cleaning 200 1,900 8,250 

Solvent 

Distillation 

4,500 1,900 3,200 

Total $68,650 25,900 $129,465 

Source: North Carolina Department of Environment, Health, and Natural Resources 

Pollution Prevention Program. 

SIC Code 25 66 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

VI. SUMMARY OF FEDERAL STATUTES AND REGULATIONS 

This section discusses the Federal statutes and regulations that may 

apply to this sector. The purpose of this section is to highlight, and 

briefly describe the applicable Federal requirements, and to provide 

citations for more detailed information. The three following sections 

are included. 

• Section VI.A contains a general overview of major statutes 

• Section VI.B contains a list of regulations specific to this 

industry 

• Section VI.C contains a list of pending and proposed regulations 

The descriptions within Section IV are intended solely for general 

information. Depending upon the nature or scope of the activities at a 

particular facility, these summaries may or may not necessarily 

describe all applicable environmental requirements. Moreover, they 

do not constitute formal interpretations or clarifications of the statutes 

and regulations. For further information, readers should consult the 

Code of Federal Regulations and other state or local regulatory 

agencies. EPA Hotline contacts are also provided for each major 

statute. 

VI.A. General Description of Major Statutes 

Resource Conservation And Recovery Act 

The Resource Conservation And Recovery Act (RCRA) of 1976 which 

amended the Solid Waste Disposal Act, addresses solid (Subtitle D) 

and hazardous (Subtitle C) waste management activities. The 

Hazardous and Solid Waste Amendments (HSWA) of 1984 

strengthened RCRA’s waste management provisions and added 

Subtitle I, which governs underground storage tanks (USTs). 

Regulations promulgated pursuant to Subtitle C of RCRA (40 CFR 

Parts 260-299) establish a “cradle-to-grave” system governing 

hazardous waste from the point of generation to disposal. RCRA 

hazardous wastes include the specific materials listed in the 

regulations (commercial chemical products, designated with the code 

"P" or "U"; hazardous wastes from specific industries/sources, 

designated with the code "K"; or hazardous wastes from non-specific 

sources, designated with the code "F") or materials which exhibit a 

September 1995 67 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

hazardous waste characteristic (ignitibility, corrosivity, reactivity, or 

toxicity and designated with the code "D"). 

Regulated entities that generate hazardous waste are subject to waste 

accumulation, manifesting, and recordkeeping standards. Facilities 

that treat, store, or dispose of hazardous waste must obtain a permit, 

either from EPA or from a State agency which EPA has authorized to 

implement the permitting program. Subtitle C permits contain general 

facility standards such as contingency plans, emergency procedures, 

recordkeeping and reporting requirements, financial assurance 

mechanisms, and unit-specific standards. RCRA also contains 

provisions (40 CFR Part 264 Subpart S and §264.10) for conducting 

corrective actions which govern the cleanup of releases of hazardous 

waste or constituents from solid waste management units at RCRAregulated facilities. 

Although RCRA is a Federal statute, many States implement the RCRA 

program. Currently, EPA has delegated its authority to implement 

various provisions of RCRA to 46 of the 50 States. 

Most RCRA requirements are not industry specific but apply to any 

company that transports, treats, stores, or disposes of hazardous waste. 

Here are some important RCRA regulatory requirements: 

• Identification of Solid and Hazardous Wastes (40 CFR Part 

261) lays out the procedure every generator should follow to 

determine whether the material created is considered a 

hazardous waste, solid waste, or is exempted from regulation. 

• Standards for Generators of Hazardous Waste (40 CFR Part 

262) establishes the responsibilities of hazardous waste 

generators including obtaining an ID number, preparing a 

manifest, ensuring proper packaging and labeling, meeting 

standards for waste accumulation units, and recordkeeping and 

reporting requirements. Generators can accumulate hazardous 

waste for up to 90 days (or 180 days depending on the amount 

of waste generated) without obtaining a permit. 

• Land Disposal Restrictions (LDRs) are regulations prohibiting 

the disposal of hazardous waste on land without prior 

treatment. Under the LDRs (40 CFR 268), materials must meet 

land disposal restriction (LDR) treatment standards prior to 

placement in a RCRA land disposal unit (landfill, land 

treatment unit, waste pile, or surface impoundment). Wastes 

subject to the LDRs include solvents, electroplating wastes, 

SIC Code 25 68 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

heavy metals, and acids. Generators of waste subject to the 

LDRs must provide notification of such to the designated TSD 

facility to ensure proper treatment prior to disposal. 

• Used Oil Management Standards (40 CFR Part 279) impose 

management requirements affecting the storage, transportation, 

burning, processing, and re-refining of the used oil. For parties 

that merely generate used oil, regulations establish storage 

standards. For a party considered a used oil marketer (one who 

generates and sells off-specification used oil directly to a used 

oil burner), additional tracking and paperwork requirements 

must be satisfied. 

• Tanks and Containers used to store hazardous waste with a 

high volatile organic concentration must meet emission 

standards under RCRA. Regulations (40 CFR Part 264-265, 

Subpart CC) require generators to test the waste to determine 

the concentration of the waste, to satisfy tank and container 

emissions standards, and to inspect and monitor regulated 

units. These regulations apply to all facilities who store such 

waste, including generators operating under the 90-day 

accumulation rule. 

• Underground Storage Tanks (USTs) containing petroleum and 

hazardous substance are regulated under Subtitle I of RCRA. 

Subtitle I regulations (40 CFR Part 280) contain tank design and 

release detection requirements, as well as financial 

responsibility and corrective action standards for USTs. The 

UST program also establishes increasingly stringent standards, 

including upgrade requirements for existing tanks, that must be 

met by 1998. 

• Boilers and Industrial Furnaces (BIFs) that use or burn fuel 

containing hazardous waste must comply with strict design and 

operating standards. BIF regulations (40 CFR Part 266, Subpart 

H) address unit design, provide performance standards, require 

emissions monitoring, and restrict the type of waste that may be 

burned. 

EPA's RCRA/Superfund/UST Hotline, at (800) 424-9346, responds to 

questions and distributes guidance regarding all RCRA regulations. The 

RCRA Hotline operates weekdays from 8:30 a.m. to 7:30 p.m., EST, 

excluding Federal holidays. 

Comprehensive Environmental Response, Compensation, And Liability Act 

September 1995 69 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

The Comprehensive Environmental Response, Compensation, and 

Liability Act (CERCLA), a 1980 law commonly known as Superfund, 

authorizes EPA to respond to releases, or threatened releases, of 

hazardous substances that may endanger public health, welfare, or the 

environment. CERCLA also enables EPA to force parties responsible 

for environmental contamination to clean it up or to reimburse the 

Superfund for response costs incurred by EPA. The Superfund 

Amendments and Reauthorization Act (SARA) of 1986 revised various 

sections of CERCLA, extended the taxing authority for the Superfund, 

and created a free-standing law, SARA Title III, also known as the 

Emergency Planning and Community Right-to-Know Act (EPCRA). 

The CERCLA hazardous substance release reporting regulations (40 

CFR Part 302) direct the person in charge of a facility to report to the 

National Response Center (NRC) any environmental release of a 

hazardous substance which exceeds a reportable quantity. Reportable 

quantities are defined and listed in 40 CFR § 302.4. A release report 

may trigger a response by EPA, or by one or more Federal or State 

emergency response authorities. 

EPA implements hazardous substance responses according to 

procedures outlined in the National Oil and Hazardous Substances 

Pollution Contingency Plan (NCP) (40 CFR Part 300). The NCP 

includes provisions for permanent cleanups, known as remedial 

actions, and other cleanups referred to as "removals." EPA generally 

takes remedial actions only at sites on the National Priorities List 

(NPL), which currently includes approximately 1300 sites. Both EPA 

and states can act at other sites; however, EPA provides responsible 

parties the opportunity to conduct removal and remedial actions and 

encourages community involvement throughout the Superfund 

response process. 

EPA's RCRA/Superfund/UST Hotline, at (800) 424-9346, answers questions 

and references guidance pertaining to the Superfund program. The CERCLA 

Hotline operates weekdays from 8:30 a.m. to 7:30 p.m., EST, excluding 

Federal holidays. 

Emergency Planning And Community Right-To-Know Act 

The Superfund Amendments and Reauthorization Act (SARA) of 1986 

created the Emergency Planning and Community Right-to-Know Act 

(EPCRA, also known as SARA Title III), a statute designed to improve 

community access to information about chemical hazards and to 

facilitate the development of chemical emergency response plans by 

SIC Code 25 70 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

State and local governments. EPCRA required the establishment of 

State emergency response commissions (SERCs), responsible for 

coordinating certain emergency response activities and for appointing 

local emergency planning committees (LEPCs). 

EPCRA and the EPCRA regulations (40 CFR Parts 350-372) establish 

four types of reporting obligations for facilities which store or manage 

specified chemicals: 

• EPCRA §302 requires facilities to notify the SERC and LEPC of 

the presence of any "extremely hazardous substance" (the list of 

such substances is in 40 CFR Part 355, Appendices A and B) if it 

has such substance in excess of the substance's threshold 

planning quantity, and directs the facility to appoint an 

emergency response coordinator. 

• EPCRA §304 requires the facility to notify the SERC and the 

LEPC in the event of a release exceeding the reportable quantity 

of a CERCLA hazardous substance or an EPCRA extremely 

hazardous substance. 

• EPCRA §§311 and 312 require a facility at which a hazardous 

chemical, as defined by the Occupational Safety and Health Act, 

is present in an amount exceeding a specified threshold to 

submit to the SERC, LEPC, and local fire department material 

safety data sheets (MSDSs) or lists of MSDSs and hazardous 

chemical inventory forms (also known as Tier I and II forms). 

This information helps the local government respond in the 

event of a spill or release of the chemical. 

• EPCRA §313 requires manufacturing facilities included in SIC 

codes 20 through 39, which have ten or more employees, and 

which manufacture, process, or use specified chemicals in 

amounts greater than threshold quantities, to submit an annual 

toxic chemical release report. This report, commonly known as 

the Form R, covers releases and transfers of toxic chemicals to 

various facilities and environmental media, and allows EPA to 

compile the national Toxic Release Inventory (TRI) database. 

All information submitted pursuant to EPCRA regulations is publicly 

accessible, unless protected by a trade secret claim. 

EPA's EPCRA Hotline, at (800) 535-0202, answers questions and distributes 

guidance regarding the emergency planning and community right-to-know 

September 1995 71 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

regulations. The EPCRA Hotline operates weekdays from 8:30 a.m. to 7:30 

p.m., EST, excluding Federal holidays. 

Clean Water Act 

The primary objective of the Federal Water Pollution Control Act, 

commonly referred to as the Clean Water Act (CWA), is to restore and 

maintain the chemical, physical, and biological integrity of the nation's 

surface waters. Pollutants regulated under the CWA include "priority" 

pollutants, including various toxic pollutants; "conventional" 

pollutants, such as biochemical oxygen demand (BOD), total 

suspended solids (TSS), fecal coliform, oil and grease, and pH; and 

"non-conventional" pollutants, including any pollutant not identified 

as either conventional or priority. 

The CWA regulates both direct and indirect discharges. The National 

Pollutant Discharge Elimination System (NPDES) program (CWA 

§402) controls direct discharges into navigable waters. Direct 

discharges or "point source" discharges are from sources such as pipes 

and sewers. NPDES permits, issued by either EPA or an authorized 

State (EPA has presently authorized forty States to administer the 

NPDES program), contain industry-specific, technology-based and/or 

water quality-based limits, and establish pollutant monitoring and 

reporting requirements. A facility that intends to discharge into the 

nation's waters must obtain a permit prior to initiating its discharge. A 

permit applicant must provide quantitative analytical data identifying 

the types of pollutants present in the facility's effluent. The permit will 

then set forth the conditions and effluent limitations under which a 

facility may make a discharge. 

A NPDES permit may also include discharge limits based on Federal 

or State water quality criteria or standards, that were designed to 

protect designated uses of surface waters, such as supporting aquatic 

life or recreation. These standards, unlike the technological standards, 

generally do not take into account technological feasibility or costs. 

Water quality criteria and standards vary from State to State, and site 

to site, depending on the use classification of the receiving body of 

water. Most States follow EPA guidelines which propose aquatic life 

and human health criteria for many of the 126 priority pollutants. 

Storm Water Discharges 

In 1987 the CWA was amended to require EPA to establish a program 

to address storm water discharges. In response, EPA promulgated the 

SIC Code 25 72 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

NPDES storm water permit application regulations. Storm water 

discharge associated with industrial activity means the discharge from 

any conveyance which is used for collecting and conveying storm 

water and which is directly related to manufacturing, processing or 

raw materials storage areas at an industrial plant (40 CFR 

122.26(b)(14)). These regulations require that facilities with the 

following storm water discharges apply for a NPDES permit: (1) a 

discharge associated with industrial activity; (2) a discharge from a 

large or medium municipal storm sewer system; or (3) a discharge 

which EPA or the State determines to contribute to a violation of a 

water quality standard or is a significant contributor of pollutants to 

waters of the United States. 

The term "storm water discharge associated with industrial activity" 

means a storm water discharge from one of 11 categories of industrial 

activity defined at 40 CFR 122.26. Six of the categories are defined by 

SIC codes while the other five are identified through narrative 

descriptions of the regulated industrial activity. If the primary SIC 

code of the facility is one of those identified in the regulations, the 

facility is subject to the storm water permit application requirements. 

If any activity at a facility is covered by one of the five narrative 

categories, storm water discharges from those areas where the 

activities occur are subject to storm water discharge permit application 

requirements. 

Those facilities/activities that are subject to storm water discharge 

permit application requirements are identified below. To determine 

whether a particular facility falls within one of these categories, the 

regulation should be consulted. 

Category i: Facilities subject to storm water effluent guidelines, new 

source performance standards, or toxic pollutant effluent standards. 

Category ii: Facilities classified as SIC 24-lumber and wood products 

(except wood kitchen cabinets); SIC 26-paper and allied products 

(except paperboard containers and products); SIC 28-chemicals and 

allied products (except drugs and paints); SIC 29-petroleum refining; 

and SIC 311-leather tanning and finishing. 

Category iii: Facilities classified as SIC 10-metal mining; SIC 12-coal 

mining; SIC 13-oil and gas extraction; and SIC 14-nonmetallic mineral 

mining. 

September 1995 73 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

Category iv: Hazardous waste treatment, storage, or disposal 

facilities. 

Category v: Landfills, land application sites, and open dumps that 

receive or have received industrial wastes. 

Category vi: Facilities classified as SIC 5015-used motor vehicle parts; 

and SIC 5093-automotive scrap and waste material recycling facilities. 

Category vii: Steam electric power generating facilities. 

Category viii: Facilities classified as SIC 40-railroad transportation; 

SIC 41-local passenger transportation; SIC 42-trucking and 

warehousing (except public warehousing and storage); SIC 43-U.S. 

Postal Service; SIC 44-water transportation; SIC 45-transportation by 

air; and SIC 5171-petroleum bulk storage stations and terminals. 

Category ix: Sewage treatment works. 

Category x: Construction activities except operations that result in the 

disturbance of less than five acres of total land area. 

Category xi: Facilities classified as SIC 20-food and kindred products; 

SIC 21-tobacco products; SIC 22-textile mill products; SIC 23-apparel 

related products; SIC 2434-wood kitchen cabinets manufacturing; SIC 

25-furniture and fixtures; SIC 265-paperboard containers and boxes; 

SIC 267-converted paper and paperboard products; SIC 27-printing, 

publishing, and allied industries; SIC 283-drugs; SIC 285-paints, 

varnishes, lacquer, enamels, and allied products; SIC 30-rubber and 

plastics; SIC 31-leather and leather products (except leather and 

tanning and finishing); SIC 323-glass products; SIC 34-fabricated metal 

products (except fabricated structural metal); SIC 35-industrial and 

commercial machinery and computer equipment; SIC 36-electronic 

and other electrical equipment and components; SIC 37-transportation 

equipment (except ship and boat building and repairing); SIC 38-

measuring, analyzing, and controlling instruments; SIC 39-

miscellaneous manufacturing industries; and SIC 4221-4225-public 

warehousing and storage. 

Pretreatment Program 

Another type of discharge that is regulated by the CWA is one that 

goes to a publicly-owned treatment works (POTWs). The national 

pretreatment program (CWA §307(b)) controls the indirect discharge 

SIC Code 25 74 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

of pollutants to POTWs by "industrial users." Facilities regulated 

under §307(b) must meet certain pretreatment standards. The goal of 

the pretreatment program is to protect municipal wastewater 

treatment plants from damage that may occur when hazardous, toxic, 

or other wastes are discharged into a sewer system and to protect the 

quality of sludge generated by these plants. Discharges to a POTW are 

regulated primarily by the POTW itself, rather than the State or EPA. 

EPA has developed technology-based standards for industrial users of 

POTWs. Different standards apply to existing and new sources within 

each category. "Categorical" pretreatment standards applicable to an 

industry on a nationwide basis are developed by EPA. In addition, 

another kind of pretreatment standard, "local limits," are developed by 

the POTW in order to assist the POTW in achieving the effluent 

limitations in its NPDES permit. 

Regardless of whether a State is authorized to implement either the 

NPDES or the pretreatment program, if it develops its own program, it 

may enforce requirements more stringent than Federal standards. 

EPA’s Office of Water, at (202) 260-5700, will direct callers with questions 

about the CWA to the appropriate EPA office. EPA also maintains a 

bibliographic database of Office of Water publications which can be accessed 

through the Ground Water and Drinking Water resource center, at (202) 260-

7786. 

Safe Drinking Water Act 

The Safe Drinking Water Act (SDWA) mandates that EPA establish 

regulations to protect human health from contaminants in drinking 

water. The law authorizes EPA to develop national drinking water 

standards and to create a joint Federal-State system to ensure 

compliance with these standards. The SDWA also directs EPA to 

protect underground sources of drinking water through the control of 

underground injection of liquid wastes. 

EPA has developed primary and secondary drinking water standards 

under its SDWA authority. EPA and authorized States enforce the 

primary drinking water standards, which are, contaminant-specific 

concentration limits that apply to certain public drinking water 

supplies. Primary drinking water standards consist of maximum 

contaminant level goals (MCLGs), which are non-enforceable healthbased goals, and maximum contaminant levels (MCLs), which are 

September 1995 75 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

enforceable limits set as close to MCLGs as possible, considering cost 

and feasibility of attainment. 

The SDWA Underground Injection Control (UIC) program (40 CFR 

Parts 144-148) is a permit program which protects underground 

sources of drinking water by regulating five classes of injection wells. 

UIC permits include design, operating, inspection, and monitoring 

requirements. Wells used to inject hazardous wastes must also comply 

with RCRA corrective action standards in order to be granted a RCRA 

permit, and must meet applicable RCRA land disposal restrictions 

standards. The UIC permit program is primarily State-enforced, since 

EPA has authorized all but a few States to administer the program. 

The SDWA also provides for a Federally-implemented Sole Source 

Aquifer program, which prohibits Federal funds from being expended 

on projects that may contaminate the sole or principal source of 

drinking water for a given area, and for a State-implemented Wellhead 

Protection program, designed to protect drinking water wells and 

drinking water recharge areas. 

EPA’s Safe Drinking Water Hotline, at (800) 426-4791, answers questions 

and distributes guidance pertaining to SDWA standards. The Hotline 

operates from 9:00 a.m. through 5:30 p.m., EST, excluding Federal holidays. 

Toxic Substances Control Act 

The Toxic Substances Control Act (TSCA) granted EPA authority to 

create a regulatory framework to collect data on chemicals in order to 

evaluate, assess, mitigate, and control risks which may be posed by 

their manufacture, processing, and use. TSCA provides a variety of 

control methods to prevent chemicals from posing unreasonable risk. 

TSCA standards may apply at any point during a chemical’s life cycle. 

Under TSCA §5, EPA has established an inventory of chemical 

substances. If a chemical is not already on the inventory, and has not 

been excluded by TSCA, a premanufacture notice (PMN) must be 

submitted to EPA prior to manufacture or import. The PMN must 

identify the chemical and provide available information on health and 

environmental effects. If available data are not sufficient to evaluate 

the chemical's effects, EPA can impose restrictions pending the 

development of information on its health and environmental effects. 

EPA can also restrict significant new uses of chemicals based upon 

factors such as the projected volume and use of the chemical. 

SIC Code 25 76 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

Under TSCA §6, EPA can ban the manufacture or distribution in 

commerce, limit the use, require labeling, or place other restrictions on 

chemicals that pose unreasonable risks. Among the chemicals EPA 

regulates under §6 authority are asbestos, chlorofluorocarbons (CFCs), 

and polychlorinated biphenyls (PCBs). 

EPA’s TSCA Assistance Information Service, at (202) 554-1404, answers 

questions and distributes guidance pertaining to Toxic Substances Control 

Act standards. The Service operates from 8:30 a.m. through 4:30 p.m., EST, 

excluding Federal holidays. 

Clean Air Act 

The Clean Air Act (CAA) and its amendments, including the Clean Air 

Act Amendments (CAAA) of 1990, are designed to “protect and 

enhance the nation's air resources so as to promote the public health 

and welfare and the productive capacity of the population.” The CAA 

consists of six sections, known as Titles, which direct EPA to establish 

national standards for ambient air quality and for EPA and the States 

to implement, maintain, and enforce these standards through a variety 

of mechanisms. Under the CAAA, many facilities will be required to 

obtain permits for the first time. State and local governments oversee, 

manage, and enforce many of the requirements of the CAAA. CAA 

regulations appear at 40 CFR Parts 50-99. 

Pursuant to Title I of the CAA, EPA has established national ambient 

air quality standards (NAAQSs) to limit levels of "criteria pollutants," 

including carbon monoxide, lead, nitrogen dioxide, particulate matter, 

ozone, and sulfur dioxide. Geographic areas that meet NAAQSs for a 

given pollutant are classified as attainment areas; those that do not 

meet NAAQSs are classified as non-attainment areas. Under §110 of 

the CAA, each State must develop a State Implementation Plan (SIP) to 

identify sources of air pollution and to determine what reductions are 

required to meet Federal air quality standards. 

Title I also authorizes EPA to establish New Source Performance 

Standards (NSPSs), which are nationally uniform emission standards 

for new stationary sources falling within particular industrial 

categories. NSPSs are based on the pollution control technology 

available to that category of industrial source but allow the affected 

industries the flexibility to devise a cost-effective means of reducing 

emissions. 

September 1995 77 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

Under Title I, EPA establishes and enforces National Emission 

Standards for Hazardous Air Pollutants (NESHAPs), nationally 

uniform standards oriented towards controlling particular hazardous 

air pollutants (HAPs). Title III of the CAAA further directed EPA to 

develop a list of sources that emit any of 189 HAPs, and to develop 

regulations for these categories of sources. To date EPA has listed 174 

categories and developed a schedule for the establishment of emission 

standards. The emission standards will be developed for both new 

and existing sources based on "maximum achievable control 

technology" (MACT). The MACT is defined as the control technology 

achieving the maximum degree of reduction in the emission of the 

HAPs, taking into account cost and other factors. 

Title II of the CAA pertains to mobile sources, such as cars, trucks, 

buses, and planes. Reformulated gasoline, automobile pollution 

control devices, and vapor recovery nozzles on gas pumps are a few of 

the mechanisms EPA uses to regulate mobile air emission sources. 

Title IV establishes a sulfur dioxide emissions program designed to 

reduce the formation of acid rain. Reduction of sulfur dioxide releases 

will be obtained by granting to certain sources limited emissions 

allowances, which, beginning in 1995, will be set below previous levels 

of sulfur dioxide releases. 

Title V of the CAAA of 1990 created a permit program for all "major 

sources" (and certain other sources) regulated under the CAA. One 

purpose of the operating permit is to include in a single document all 

air emissions requirements that apply to a given facility. States are 

developing the permit programs in accordance with guidance and 

regulations from EPA. Once a State program is approved by EPA, 

permits will be issued and monitored by that State. 

Title VI is intended to protect stratospheric ozone by phasing out the 

manufacture of ozone-depleting chemicals and restrict their use and 

distribution. Production of Class I substances, including 15 kinds of 

chlorofluorocarbons (CFCs), will be phased out entirely by the year 

2000, while certain hydrochlorofluorocarbons (HCFCs) will be phased 

out by 2030. 

EPA's Control Technology Center, at (919) 541-0800, provides general 

assistance and information on CAA standards. The Stratospheric Ozone 

Information Hotline, at (800) 296-1996, provides general information about 

regulations promulgated under Title VI of the CAA, and EPA's EPCRA 

Hotline, at (800) 535-0202, answers questions about accidental release 

SIC Code 25 78 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

prevention under CAA §112(r). In addition, the Technology Transfer 

Network Bulletin Board System (modem access (919) 541-5742)) includes 

recent CAA rules, EPA guidance documents, and updates of EPA activities. 

Exhibit 21 provides an overview of the statues and certain regulations 

applicable to the wood furniture manufacturing industry. The 

information contained in this matrix is based on data from the 

American Furniture Manufacturers Association document, 

Environmental Guide for the Furniture Industry. 

Exhibit 21

Impacts of Environmental Statutes on the Wood Furniture Manufacturing

Industry

Statute & 

Section 

Drying 

(ovens, boilers) 

Machining 

(sawing, 

planing, 

sanding) 

Assembly 

(gluing, 

veneer 

application) 

Pre-finishing/ 

Finishing 

(all coating 

applications) 

Cleanup/ 

Shipping 

(cleanup, 

equipment 

maintenance, 

warehousing) 

Resource Conservation and Recovery Act 

Section 6921 

(3)(A) 

(Hazardous 

Waste) 

Boiler water 

treatment 

chemicals may 

be regulated 

N/A Unused 

commercial 

chemical 

products may 

be regulated 

Unused 

commercial 

chemical 

products and 

potentially 

ignitable nonliquid wastes 

are likely to be 

regulated 

Solvent cleanup 

solutions, 

burning of 

potentially 

ignitable 

wastes, and 

chemical 

storage and 

spills may be 

regulated 

Section 6941 

(Solid Waste) 

State/Local 

Regulations 

Non-hazardous 

boiler ash may 

be regulated 

Wood waste 

may be 

regulated 

Wood and 

adhesive 

waste may be 

regulated 

N/A Equipment 

maintenance 

materials may 

be regulated 

Section 6991 

(USTs) 

Underground 

fuel tanks may 

be regulated 

N/A Adhesive and 

solvent underground 

storage tanks 

may be 

regulated 

Solvent underground storage 

tanks are likely 

to be regulated 

N/A 

Comprehensive Environmental Response, Compensation, and Liability Act 

CERCLA N/A N/A N/A Potential spill 

and disposal 

problems are 

likely to occur 

Potential spill 

and disposal 

problems may 

occur 

Source: AFMA Environmental Guide for the Furniture Industry. 

September 1995 79 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

Exhibit 21 (cont'd)

Impacts of Environmental Statutes on the Wood Furniture Manufacturing

Industry

Statute & 

Section 

Drying 

(ovens, boilers) 

Machining 

(sawing, 

planing, 

sanding) 

Assembly 

(gluing, 

veneer 

application) 

Pre-finishing/ 

Finishing 

(all coating 

applications) 

Cleanup/ 

Shipping 

(cleanup, 

equipment 

maintenance, 

warehousing) 

Emergency Planning and Community Right-to-Know Act, SARA Title III 

Sections 

301-303 

N/A N/A Adhesives 

may be 

regulated 

Finishing 

materials are 

likely to be 

regulated 

Finishing and 

maintenance 

materials are 

likely to be 

regulated 

Section 304 N/A N/A Adhesives 

spills may be 

regulated 

Finishing 

materials spills 

are likely to be 

regulated 

Maintenance 

materials spills 

may be 

regulated 

Sections 

311-312 

N/A N/A Adhesives 

may be 

regulated 

Finishing 

materials are 

likely to be 

regulated 

Finishing and 

maintenance 

materials are 

likely to be 

regulated 

Section 313 N/A N/A Emissions 

from solventbased 

adhesives may 

be regulated 

Hazardous 

finishing 

materials are 

likely to be 

regulated 

Hazardous 

chemical 

emissions 

disposal may be 

regulated 

Clean Water Act 

Wastewater 

Discharge 

Permitting 

Program 

Wastewater 

discharge from 

boilers, 

compressors, 

cooling water, 

and drying kiln 

condensate may 

be regulated 

N/A Adhesive 

wash and 

water 

discharge may 

be regulated 

Wastewater 

discharge from 

water-wash 

spray booths 

and rag 

laundering are 

likely to be 

regulated 

N/A 

SPCC 

Planning 

N/A N/A Adhesive 

management 

may be 

regulated 

Finishing oil 

management is 

likely to be 

regulated 

Storage and use 

of fuels and 

lube oils may be 

regulated 

Source: AFMA Environmental Guide for the Furniture Industry. 

SIC Code 25 80 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

Exhibit 21 (cont'd)

Impacts of Environmental Statutes on the Wood Furniture Manufacturing

Industry

Statute & 

Section 

Drying 

(ovens, boilers) 

Machining 

(sawing, 

planing, 

sanding) 

Assembly 

(gluing, 

veneer 

application) 

Pre-finishing/ 

Finishing 

(all coating 

applications) 

Cleanup/ 

Shipping 

(cleanup, 

equipment 

maintenance, 

warehousing) 

Clean Water Act (continued) 

Storm Water 

Discharge 

Permitting 

Program 

Wood storage 

may be 

regulated 

Wood 

particulates in 

runoff are 

likely to be 

regulated 

Adhesive 

storage may 

be regulated 

Finishing 

materials 

management is 

likely to be 

regulated 

Fuel and 

maintenance 

chemical 

management 

and material 

storage may be 

regulated 

Clean Air Act 

Section 7411 

(NSPS) 

May apply to 

certain boilers 

N/A N/A N/A N/A 

Section 7411 

(New Source 

Review) 

Permit required 

before 

construction of 

new source 

Permit 

required 

before 

construction 

of new source 

Permit 

required 

before 

construction 

of new source 

Permit required 

before 

construction of 

new source 

Permit required 

before 

construction of 

new source 

Section 7411 

(Control 

Techniques 

Guidelines) 

N/A N/A N/A 

Draft form 

scheduled for 

release in 

August, 1995 

N/A 

Section 7501 

(Nonattainment Areas) 

Sources in CO, 

SO2 , NOX, O3 

(VOC), PM10, or 

Pb nonattainment areas may 

be subject to 

additional 

requirements 

Sources in 

PM10 

nonattainment 

areas may be 

subject to 

additional 

requirements 

N/A 

Sources in O3 

(VOC) and 

PM10 

nonattainment 

areas may be 

subject to 

additional 

requirements 

N/A 

Section 7412 

(Hazardous 

Air 

Pollutants) 

N/A N/A 

Currently 

being 

finalized; 

scheduled for 

release in 

November, 

1995 

Currently being 

finalized; 

scheduled for 

release in 

November, 

1995 

N/A 

Section 7410 

(a)(2) 

(Operating 

Permits 

Program) 

Permit required 

for all major 

and certain 

non-major 

sources 

Permit 

required for 

all major and 

certain nonmajor sources 

Permit 

required for 

all major and 

certain nonmajor sources 

Permit required 

for all major 

and certain 

non-major 

sources 

Permit required 

for all major 

and certain 

non-major 

sources 

September 1995 81 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

Exhibit 21 (cont'd)

Impacts of Environmental Statutes on the Wood Furniture Manufacturing

Industry

Statute & 

Section 

Drying 

(ovens, boilers) 

Machining 

(sawing, 

planing, 

sanding) 

Assembly 

(gluing, 

veneer 

application) 

Pre-finishing/ 

Finishing 

(all coating 

applications) 

Cleanup/ 

Shipping 

(cleanup, 

equipment 

maintenance, 

warehousing) 

Clean Air Act (continued) 

Section 7411 

(Enhanced 

Monitoring) 

Certain boilers 

may be subject 

to enhanced 

monitoring 

requirements 

depending on 

the magnitude 

of emissions 

Large 

operations 

may be 

subject to 

enhanced 

monitoring 

requirements 

Sources may 

be subject to 

enhanced 

monitoring 

requirements 

depending on 

the magnitude 

of emissions 

Sources may be 

subject to 

enhanced 

monitoring 

requirements 

depending on 

the magnitude 

of emissions 

N/A 

Spill Reporting 

Spill 

Reporting 

Boiler fuels may 

be regulated 

N/A Adhesives 

and solvents 

may be 

regulated 

Toxic finishing 

materials are 

likely to be 

regulated 

Maintenance 

chemicals and 

oils may be 

regulated 

Source: AFMA Environmental Guide for the Furniture Industry. 

VI.B. Industry-specific Regulatory Requirements 

Clean Air Act (CAA) 

The Clean Air Act as amended in 1990 established the basis for the 

EPA to set new requirements for hazardous air pollutants (HAPs) that 

apply to emissions of 189 toxic chemicals listed in the Clean Air Act. 

EPA recently proposed Maximum Available Control Technology 

(MACT) standards for the wood furniture manufacturing industry. 

In addition, the Agency is developing a control techniques guideline 

(CTG) for the industry to reduce the emissions of VOCs. While a CTG 

is not a rule, States generally follow the CTG guidance in developing 

rules for facilities located in ozone non-attainment areas and the ozone 

transport region. A preliminary draft model rule containing a preview 

of the reasonably available control technologies (RACT) that will be 

recommended in the draft CTG has been made publicly available for 

the wood furniture industry. A more detailed discussion of both the 

SIC Code 25 82 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

draft CTG and the MACT standards can be found in the following 

section pertaining to pending regulatory requirements. 

The Economic Incentive Program (EIP) rules, promulgated on April 7, 

1994 (59 FR 16690), provide general information on using innovative 

strategies to meet the Clean Air Act requirements, including RACT. 

(The RACT applicability threshold for this model rule is 10 tons for a 

wood furniture facility located in an extreme ozone nonattainment 

area and 25 tons per year for a wood furniture facility located in a 

marginal, moderate, serious, or severe ozone nonattainment area or in 

the ozone transport region; EPA Method 24 is used as the basis for 

evaluating VOC data on coatings). The EIP rule contains a range of 

options for States to use in incorporating economic incentives and/or 

innovative strategies into their State Implementation Plans (SIPs). 

Resource Conservation and Recovery Act (RCRA) 

The Resource Conservation and Recovery Act (RCRA) regulates the 

generation, transportation, treatment, storage, and disposal of 

hazardous waste. Although the furniture industry does not tend to 

generate listed hazardous wastes, it may produce characteristic 

hazardous wastes. The wood furniture manufacturing industry uses 

many solvents. Spent solvents and solvent still bottoms are often 

characterized as hazardous wastes. In addition, furniture 

manufacturing facilities may generate ignitable or toxic wastes. Many 

wastes generated from the use of paints, wood treatments, stains, 

varnishes, and adhesives may be ignitable or might fail the Toxicity 

Characteristic Leaching Procedure (TCLP) test. 

If a facility generates 100 kilograms or more of hazardous waste (or 

one kilogram of acutely hazardous waste) per month, it may be subject 

to accumulation time limits, storage restrictions, personnel training 

requirements, manifesting, and land disposal restrictions for these 

wastes. 

Emergency Planning and Community Right-to-Know Act (EPCRA) 

Furniture manufacturers may store extremely hazardous substances 

(EHS) and hazardous chemicals. If so, facilities would be subject to the 

emergency planning and hazardous chemical inventory provisions of 

EPCRA. If they release an EHS or a CERCLA hazardous substance 

such as toluene or acetone, they may need to report it under the 

emergency release reporting requirements of SARA Title III. The 

Toxic Chemical Release Inventory affects only relatively large 

September 1995 83 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

furniture companies that use toxic chemicals, such as toluene 

disocyanate or methylene chloride, above 10,000 pounds annually. 

Clean Water Act (CWA) 

The Clean Water Act (CWA) regulates discharges of various pollutants 

into the surface waters of the U.S. or to publicly owned treatment 

works (POTWs). The effluent provisions of 40 CFR Part 429, Subpart 

L, regulate facilities which conduct wood finishing activities such as 

staining and dipping, and require that sources not discharge untreated 

process wastewater into navigable waters. 

CWA regulations also regulate wood furniture manufacturers both 

with water wash spray booths (40 CFR Part 429, Subpart P) and 

without wash spray booths (40 CFR 429 Subpart O). Both Subparts 

require that sources not discharge process wastewater pollutants 

directly into navigable waters. Both effluent limitations greatly restrict 

the amount of effluent from process wastewaters which may be 

released into POTWs and require monitoring and recordkeeping 

activities. For sources discharging to POTWs, Subpart P requirements 

are similar to those in Subpart O with the exception that pH levels and 

levels of solids that settle are regulated for the best practicable 

technology requirements. 

VI.C. Pending and Proposed Regulatory Requirements 

Information contained in this section was obtained from the Fact Sheet 

on the Proposed MACT and CTG for the Wood Furniture Finishing Industry 

developed and distributed by the Small Business Ombudsman of 

North Carolina. The Clean Air Act as amended in 1990 established the 

basis for the EPA to set new requirements for HAPs and to develop 

control techniques guidance (CTG) to reduce VOC emissions. The 

EPA recently proposed a MACT standard for the wood furniture 

manufacturing industry, which applies to 189 toxic chemicals listed in 

the Clean Air Act as HAPs. To help States meet the ambient air 

quality standard for ozone, the Agency is also developing a CTG for 

the industry to reduce emissions of VOCs. 

The MACT and CTG are concerned with two different types of 

emissions. The MACT will regulate emissions of HAPs from all wood 

furniture surface coating operations nationwide. The CTG will 

address emissions of VOCs from wood furniture finishing, cleaning, 

SIC Code 25 84 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

and washoff operations at facilities located in ozone non-attainment 

areas or in the ozone transport region. 

The MACT standard will apply to "major sources" in the wood 

furniture manufacturing industry. A major source is one that emits or 

has the potential to emit 10 tons per year (tpy) of an individual HAP or 

25 tpy of a combination of HAPs per year. The recommended 

application of the CTG is for sources that emit or have the potential to 

emit 10 tpy of VOCs in an extreme non-attainment area and 25 tpy per 

year of VOCs in any other ozone non-attainment area and in the ozone 

transport region. 

Sources using or agreeing to use no more that 250 total gallons per 

month, or 3,000 gallons per rolling 12-month period, of finishing, 

contact adhesives, and cleaning materials are not major sources and 

are exempted from the MACT standard. 

The MACT standard proposes numerical emission limits for surface 

coating operations including finishing, gluing, and peelable spray 

booth coating. Finishes include stains, washcoats, basecoats, fillers, 

sealers, glazes, highlighters, enamels, and topcoats. The CTG 

preliminary draft proposes numeric emissions limits for finishing and 

cleaning operations and for strippable booth coatings. 

In addition to numeric emissions limits, the MACT standard and CTG 

propose work practice standards that include inspection and 

maintenance of equipment, good housekeeping practices such as 

closed tops on solvent and mixing containers, procedures to account 

for solvent use, and some limitations on the use of conventional air 

spray guns, promoting the use of more efficient spray guns. 

A source may be affected by both the MACT and CTG. For example, if 

a wood furniture manufacturer is located in an ozone non-attainment 

area, uses VOCs and potentially emits greater than 25 tons per year of 

total VOC emissions, and is a major source for HAPs, the facility 

would be subject to both requirements. 

The following implementation/compliance schedule is proposed with 

respect to the MACT and CTG: 

A preliminary draft model rule to reduce VOCs was distributed 

to State and local air agencies in June 1994. This preliminary 

rule contains emission limits based on RACT for reducing 

VOCs. RACT requirements may vary among states and local 

September 1995 85 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

governments as some will set more stringent requirements to 

accommodate their specific air quality problems. 

Under a court-ordered deadline, the MACT standard was 

proposed November 21, 1994. November 1995 is the scheduled 

date for final adoption. 

Sources emitting more than 50 tpy of HAPs will have until 

November 21, 1997 to comply with the final rule. 

Sources emitting less than 50 tpy of HAPs will have 

approximately three years to comply with the final rule. This 

date will probably be November 1998. 

Compliance with the MACT standard can be achieved with compliant 

coatings; that is, either non-HAP coatings or those meeting the limits, 

such as 1.0 lb of HAP per pound of solid. High-solids coatings and 

water-based coatings have fewer VOCs and HAPs, and are becoming 

more readily available. Although add-on control may also be used to 

meet the standards, the use of less solvent and fewer toxics in coatings 

and finishes is likely to be the route most manufacturers take towards 

compliance (and may be more economical). 

The basis for the recommended standards for finishing operations is 

the use of low-HAP materials or control devices such as incinerators. 

For cleaning operations, the standards are based on use of low-VOC 

strippable coatings for spray booths. 

In addition to numeric standards, the proposed rules minimize 

evaporative emissions through work practices covering storage, 

transfer, and applications in finishing, contact adhesive, cleaning, and 

washoff operations. These practices include employee training, 

inspection and maintenance, and housekeeping measures (such as 

"containers should be closed when not in use"). 

Exhibits 22 and 23 provide an overview of the proposed MACT 

emissions limits and work practice standards for the MACT and CTG. 

This information was obtained from the Fact Sheet on the Proposed 

MACT and CTG for the Wood Furniture Finishing Industry. 

SIC Code 25 86 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

Exhibit 22 Summary of Proposed MACT Emission Limit 

Emission Point Existing 

Source 

New Source 

Finishing Operations 

(1) Achieve a weighted average HAP content across all 

coatings (maximum lb VHAP/lb solids) 

1.0a 0.8a 

(2) Use compliant finishing materials (maximum lb 

VHAP/lb solids) 

- stains 1.0a 1.0a 

- washcoats 1.0a,b 0.8a,b 

- sealers 1.0a 0.8a 

- topcoats 1.0a 0.8a 

- basecoats 1.0a,b 0.8a,b 

- enamels 1.0a,b 0.8a,b 

- thinners (maximum percent HAP allowable) 10.0 10.0 

(3) As an alternative, use add-on control device 1.0c 0.8c 

(4) Use a combination of (2) and (3) 1.0 0.8 

Cleaning Operations 

Strippable spray booth material (max VHAP content = lb 

VOC/lb solids) 

0.8 0.8 

Contact Adhesive Operations 

(1) Use compliant contact adhesives (max VHAP content, as 

applied (lb VHAP/lb solids) 

(i) For foam adhesives used in products that meet 

flammability requirements 

1.8 0.2 

(ii) For all other adhesives (including foam adhesives 

used in products not meeting flammability 

requirements); or 

1.0 0.2 

(2) Use a control device 1.0d 0.2d 

Source: Fact Sheet on the Proposed MACT and CTG for the Wood Furniture Finishing Industry. 

a The limits refer to the HAP content of the coating as applied. 

b Compliant washcoats, basecoats, and enamels must be used if they are purchased premade; that is, they are 

not formulated on-site by thinning other finishing materials. If they are formulated on-site, they must be 

formulated with compliant finishing materials and thinners containing no more than three percent HAP by 

weight. 

c The control device must operate at an efficiency equivalent to no greater than 1.0 lbs. (or 0.8 lbs.) of HAP 

being emitted from the affected emission <N> source per pound of solids used. 

d The control device must operate at an efficiency that is equivalent to no more than 1.0 lbs. Volatile HAP 

(VHAP) emitted from the affected emission point per pound of solids used. 

September 1995 87 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

Exhibit 23

Summary of Work Practice Standards for the Proposed MACT and CTG

Emission Source Work Practice 

Finishing Operations 

Transfer Equipment Leaks Develop written inspection and maintenance plan to address and 

repair leaks. The plan must identify a minimum inspection 

frequency of one per month and procedures for addressing 

malfunctions. 

Storage containers 

including mixing 

equipment 

When such containers are used for VOC- or HAP-containing 

materials, keep covered when not in use. 

Application equipment Limit use of conventional air spray guns and encourage use of 

more efficient technology. 

Finishing materials Demonstrate usage of HAPs of potential concern have not 

increased except as allowed by the standards; document in the 

formulation assessment (MACT only). 

Cleaning Operations 

Gun/line cleaning Collect cleaning solvent into a closed container. 

Cover all containers associated with cleaning when not in use. 

Spray booth cleaning Do not use solvents unless cleaning conveyors or metal filters. 

Wash-off tanks/general 

cleaning 

Do not use chemicals that are known, probable, or possible 

carcinogens, as identified in section 112(g), in concentrations 

subject to MSDS reporting, as required by OSHA (MACT only). 

Keep wash tank covered when not in use. 

Minimize dragout by tilting and/or rotating part to drain as 

much solvent as possible and allowing sufficient time to dry. 

Maintain log of the quantity and type of solvent used for washoff 

cleaning as well as the quantity of waste shipped off site and the 

fate of this waste (recycling or disposal). 

Maintain a log of the number of pieces washed off and the reason 

for washoff. 

Miscellaneous 

Operator training All operators shall be trained on proper application, cleanup, and 

equipment use. 

The training program shall be written and retained on site. 

Implementation plan Develop a plan to implement work practice standards. 

Maintain plan on site. 

Source: Fact Sheet on the Proposed MACT and CTG for the Wood Furniture Finishing Industry. 

The work practice standards apply to both existing and new major sources. Air guns will be allowed only in 

the following instances: 

- when used in conjunction with coatings less than 1.0 lb. VOC/lb. of solids 

- for touch up and repair under limited conditions 

- when spray is automated 

- when add-on controls are used 

SIC Code 25 88 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

- if the cumulative application is less than 5 percent of total gallons of coating applied 

- if the permitting agency determines other application technology is economically or technically 

infeasible. 

September 1995 89 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

VII. COMPLIANCE AND ENFORCEMENT HISTORY 

Background 

To date, EPA has focused much of its attention on measuring 

compliance with specific environmental statutes. This approach 

allows the Agency to track compliance with the Clean Air Act, the 

Resource Conservation and Recovery Act, the Clean Water Act, and 

other environmental statutes. Within the last several years, the 

Agency has begun to supplement single-media compliance indicators 

with facility-specific, multimedia indicators of compliance. In doing 

so, EPA is in a better position to track compliance with all statutes at 

the facility level, and within specific industrial sectors. 

A major step in building the capacity to compile multimedia data for 

industrial sectors was the creation of EPA's Integrated Data for 

Enforcement Analysis (IDEA) system. IDEA has the capacity to "read 

into" the Agency's single-media databases, extract compliance records, 

and match the records to individual facilities. The IDEA system can 

match Air, Water, Waste, Toxics/Pesticides/EPCRA, TRI, and 

Enforcement Docket records for a given facility, and generate a list of 

historical permit, inspection, and enforcement activity. IDEA also has 

the capability to analyze data by geographic area and corporate 

holder. As the capacity to generate multimedia compliance data 

improves, EPA will make available more in-depth compliance and 

enforcement information. Additionally, sector-specific measures of 

success for compliance assistance efforts are under development. 

Compliance and Enforcement Profile Description 

Using inspection, violation, and enforcement data from the IDEA 

system, this section provides information regarding the historical 

compliance and enforcement activity of this sector. In order to mirror 

the facility universe reported in the Toxic Chemical Profile, the data 

reported within this section consists of records only from the TRI 

reporting universe. With this decision, the selection criteria are 

consistent across sectors with certain exceptions. For the sectors that 

do not normally report to the TRI program, data have been provided 

from EPA's Facility Indexing System (FINDS) which tracks facilities in 

all media databases. Please note, in this section, EPA does not attempt 

to define the actual number of facilities that fall within each sector. 

Instead, the section portrays the records of a subset of facilities within 

the sector that are well defined within EPA databases. 

SIC Code 25 90 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

As a check on the relative size of the full sector universe, most 

notebooks contain an estimated number of facilities within the sector 

according to the Bureau of Census (See Section II). With sectors 

dominated by small businesses, such as metal finishers and printers, 

the reporting universe within the EPA databases may be small in 

comparison to Census data. However, the group selected for inclusion 

in this data analysis section should be consistent with this sector's 

general make-up. 

Following this introduction is a list defining each data column 

presented within this section. These values represent a retrospective 

summary of inspections and enforcement actions, and solely reflect 

EPA, State, and local compliance assurance activities that have been 

entered into EPA databases. To identify any changes in trends, the 

EPA ran two data queries, one for the past five calendar years (August 

10, 1990 to August 9, 1995) and the other for the most recent twelvemonth period (August 10, 1994 to August 9, 1995). The five-year 

analysis gives an average level of activity for that period for 

comparison to the more recent activity. 

Because most inspections focus on single-media requirements, the data 

queries presented in this section are taken from single media 

databases. These databases do not provide data on whether 

inspections are State/local or EPA-led. However, the table breaking 

down the universe of violations does give the reader a crude 

measurement of the EPA's and States' efforts within each media 

program. The presented data illustrate the variations across regions 

for certain sectors.2 This variation may be attributable to State/local 

data entry variations, specific geographic concentrations, proximity to 

population centers, sensitive ecosystems, highly toxic chemicals used 

in production, or historical noncompliance. Hence, the exhibited data 

do not rank regional performance or necessarily reflect which regions 

may have the most compliance problems. 

2 EPA Regions include the following States: 1 (CT, MA, ME, RI, NH, VT); 2 (NJ, NY, PR, 

VI); 3 (DC, DE, MD, PA, VA, WV); 4 (AL, FL, GA, KY, MS, NC, SC, TN); 5 (IL, IN, MI, MN, 

OH, WI); 6 (AR, LA, NM, OK, TX); 7 (IA, KS, MO, NE); 8 (CO, MT, ND, SD, UT, WY); 9 

(AZ, CA, HI, NV, Pacific Trust Territories); 10 (AK, ID, OR, WA). 

September 1995 91 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

Compliance and Enforcement Data Definitions 

General Definitions 

Facility Indexing System (FINDS) -- this system assigns a common 

facility number to EPA single-media permit records. The FINDS 

identification number allows EPA to compile and review all permit, 

compliance, enforcement, and pollutant release data for any given 

regulated facility. 

Integrated Data for Enforcement Analysis (IDEA) -- is a data 

integration system that can retrieve information from the major EPA 

program office databases. IDEA uses the FINDS identification number 

to "glue together” separate data records from EPA’s databases. This is 

done to create a "master list” of data records for any given facility. 

Some of the data systems accessible through IDEA are: AIRS (Air 

Facility Indexing and Retrieval System, Office of Air and Radiation), 

PCS (Permit Compliance System, Office of Water), RCRIS (Resource 

Conservation and Recovery Information System, Office of Solid 

Waste), NCDB (National Compliance Data Base, Office of Prevention, 

Pesticides, and Toxic Substances), CERCLIS (Comprehensive 

Environmental and Liability Information System, Superfund), and 

TRIS (Toxic Release Inventory System). IDEA also contains 

information from outside sources such as Dun and Bradstreet and the 

Occupational Safety and Health Administration (OSHA). Most data 

queries displayed in notebook Sections IV and VII were conducted 

using IDEA. 

Data Table Column Heading Definitions 

Facilities in Search -- are based on the universe of TRI reporters 

within the listed SIC code range. For industries not covered under TRI 

reporting requirements, the notebook uses the FINDS universe for 

executing data queries. The SIC code range selected for each search is 

defined by each notebook's selected SIC code coverage described in 

Section II. 

Facilities Inspected --- indicates the level of EPA and State agency 

facility inspections for the facilities in this data search. These values 

show what percentage of the facility universe is inspected in a 12 or 60 

month period. This column does not count non-inspectional 

compliance activities such as the review of facility-reported discharge 

reports. 

SIC Code 25 92 September 1995 
--

--

--

Sector Notebook Project Wood Furniture and Fixtures 

Number of Inspections -- measures the total number of inspections 

conducted in this sector. An inspection event is counted each time it is 

entered into a single media database. 

Average Time Between Inspections provides an average length of 

time, expressed in months, that a compliance inspection occurs at a 

facility within the defined universe. 

Facilities with One or More Enforcement Actions -- expresses the 

number of facilities that were party to at least one enforcement action 

within the defined time period. This category is broken down further 

into Federal and State actions. Data are obtained for administrative, 

civil/judicial, and criminal enforcement actions. Administrative 

actions include Notices of Violation (NOVs). A facility with multiple 

enforcement actions is only counted once in this column (facility with 3 

enforcement actions counts as 1). All percentages that appear are 

referenced to the number of facilities inspected. 

Total Enforcement Actions describes the total number of 

enforcement actions identified for an industrial sector across all 

environmental statutes. A facility with multiple enforcement actions is 

counted multiple times (a facility with 3 enforcement actions counts as 

3). 

State Lead Actions -- shows what percentage of the total enforcement 

actions are taken by State and local environmental agencies. Varying 

levels of use by States of EPA data systems may limit the volume of 

actions accorded State enforcement activity. Some States extensively 

report enforcement activities into EPA data systems, while other States 

may use their own data systems. 

Federal Lead Actions -- shows what percentage of the total 

enforcement actions are taken by the U.S. EPA. This value includes 

referrals from State agencies. Many of these actions result from 

coordinated or joint State/Federal efforts. 

Enforcement to Inspection Rate expresses how often enforcement 

actions result from inspections. This value is a ratio of enforcement 

actions to inspections, and is presented for comparative purposes only. 

This measure is a rough indicator of the relationship between 

inspections and enforcement. This measure simply indicates 

historically how many enforcement actions can be attributed to 

inspection activity. Related inspections and enforcement actions under 

the Clean Water Act (PCS), the Clean Air Act (AFS) and the Resource 

September 1995 93 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

Conservation and Recovery Act (RCRA) are included in this ratio. 

Inspections and actions from the TSCA/FIFRA/EPCRA database are 

not factored into this ratio because most of the actions taken under 

these programs are not the result of facility inspections. This ratio 

does not account for enforcement actions arising from non-inspection 

compliance monitoring activities (e.g., self-reported water discharges) 

that can result in enforcement action within the CAA, CWA and 

RCRA. 

Facilities with One or More Violations Identified -- indicates the 

number and percentage of inspected facilities having a violation 

identified in one of the following data categories: In Violation or 

Significant Violation Status (CAA); Reportable Noncompliance, 

Current Year Noncompliance, Significant Noncompliance (CWA); 

Noncompliance and Significant Noncompliance (FIFRA, TSCA, and 

EPCRA); Unresolved Violation and Unresolved High Priority 

Violation (RCRA). The values presented for this column reflect the 

extent of noncompliance within the measured time frame, but do not 

distinguish between the severity of the noncompliance. Percentages 

within this column can exceed 100 percent because facilities can be in 

violation status without being inspected. Violation status may be a 

precursor to an enforcement action, but does not necessarily indicate 

that an enforcement action will occur. 

Media Breakdown of Enforcement Actions and Inspections -- four 

columns identify the proportion of total inspections and enforcement 

actions within EPA Air, Water, Waste, and TSCA/FIFRA/EPCRA 

databases. Each column is a percentage of either the "Total 

Inspections,” or the "Total Actions” column. 

VII.A. Furniture and Fixtures Industry Compliance History 

Exhibit 24 provides a Regional breakdown of the five year 

enforcement and compliance activities for the furniture and fixtures 

industry. Region IV conducted approximately 68 percent of the 

inspections of furniture manufacturing facilities performed in the 

United States. This large percentage is due to the concentration of 

furniture manufacturers in the Southeastern U.S., specifically in North 

Carolina. 

SIC Code 25 94 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

Exhibit 24

Five Year Enforcement and Compliance Summary for the Wood Furniture and

Fixtures Industry

A B C D E F G H I J 

Furniture and 

Fixtures 

SIC 25 

Facilities in 

Search 

Facilities 

Inspected 

Number of 

Inspections 

Average 

Number of 

Months 

Between 

Inspections 

Facilities 

w/one or 

more 

Enforcement 

Actions 

Total 

Enforcement 

Actions 

State Lead 

Actions 

Federal Lead 

Actions 

Enforcement 

to Inspection 

Rate 

Region I 13 10 52 15 0 0 0% 0% — 

Region II 14 10 33 25 3 3 0% 100% 0.09 

Region III 39 33 211 11 7 15 100% 0% 0.07 

Region IV 121 103 1,045 7 10 40 94% 6% 0.04 

Region V 50 36 144 21 10 25 96% 4% 0.17 

Region VI 10 8 20 30 1 1 0% 100% 0.05 

Region VII 13 4 12 65 1 1 100% 0% 0.08 

Region VIII 3 3 6 30 1 5 100% 0% 0.83 

Region IX 24 3 7 206 1 1 0% 100% 0.14 

Region X 6 3 4 90 0 0 0% 0% — 

Total/Average 293 213 1,534 11 34 91 91% 9% 0.06 

September 1995 95 SIC Code 25
Wood Furniture and Fixtures Sector Notebook Project 

VII.B. Comparison of Enforcement Activity Between Selected 

Industries 

Exhibits 25-28 contain summaries of the one and five year enforcement 

and compliance activities for the furniture and fixtures industry, as 

well as for other selected industries. As indicated in Exhibits 25 and 

26, the furniture and fixtures industry has a low enforcement to 

inspection rate compared to other industries. Exhibits 27 and 28 

provide a breakdown of inspection and enforcement activities by 

statute. Of all the furniture and fixtures industry inspections, 

approximately 52 percent were performed under the Clean Air Act, 

while approximately 45 percent were conduced under RCRA. The 

large percentages of CAA and RCRA inspections for this industry are 

due to the VOC emissions and spent finishing materials resulting from 

the solvent intensive processes used by this industry. 

SIC Code 25 96 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

Exhibit 25

Five Year Enforcement and Compliance Summary for Selected Industries

A B C D E F G H I J 

Industry Sector 

Facilities in 

Search 

Facilities 

Inspected 

Number 

of 

Inspections 

Average Number 

of Months 

Between 

Inspections 

Facilities 

w/One or More 

Enforcement 

Actions 

Total 

Enforcement 

Actions 

State Lead 

Actions 

Federal 

Lead 

Actions 

Enforcement to 

Inspection Rate 

Metal Mining 873 339 1,519 34 67 155 47% 53% 0.10 

Non-metallic Mineral 

Mining 

1,143 631 3,422 20 84 192 76% 24% 0.06 

Lumber and Wood 464 301 1,891 15 78 232 79% 21% 0.12 

Furniture 293 213 1,534 11 34 91 91% 9% 0.06 

Rubber and Plastic 1,665 739 3,386 30 146 391 78% 22% 0.12 

Stone, Clay, and Glass 468 268 2,475 11 73 301 70% 30% 0.12 

Nonferrous Metals 844 474 3,097 16 145 470 76% 24% 0.15 

Fabricated Metal 2,346 1,340 5,509 26 280 840 80% 20% 0.15 

Electronics/Computers 405 222 777 31 68 212 79% 21% 0.27 

Motor Vehicle 

Assembly 

598 390 2,216 16 81 240 80% 20% 0.11 

Pulp and Paper 306 265 3,766 5 115 502 78% 22% 0.13 

Printing 4,106 1,035 4,723 52 176 514 85% 15% 0.11 

Inorganic Chemicals 548 298 3,034 11 99 402 76% 24% 0.13 

Organic Chemicals 412 316 3,864 6 152 726 66% 34% 0.19 

Petroleum Refining 156 145 3,257 3 110 797 66% 34% 0.25 

Iron and Steel 374 275 3,555 6 115 499 72% 28% 0.14 

Dry Cleaning 933 245 633 88 29 103 99% 1% 0.16 

September 1995 97 SIC Code 25
Wood Furniture and Fixtures Sector Notebook Project 

Exhibit 26

One Year Enforcement and Compliance Summary for Selected Industries

A C D E F G H 

Industry Sector Facilities in 

Search 

Facilities 

Inspected 

Number of 

Inspections 

Facilities w/One or More 

Violations 

Facilities w/One or More 

Enforcement Actions 

Total 

Enforcement 

Actions 

Enforcement 

to Inspection 

Rate 

Number Percent* Number Percent* 

Metal Mining 873 114 194 82 72% 16 14% 24 0.13 

Non-metallic Mineral 

Mining 

1,143 253 425 75 30% 28 11% 54 0.13 

Lumber and Wood 464 142 268 109 77% 18 13% 42 0.15 

Furniture 293 160 113 66 41% 3 2% 5 0.04 

Rubber and Plastic 1,665 271 435 289 107% 19 7% 59 0.14 

Stone, Clay, and Glass 468 146 330 116 79% 20 14% 66 0.20 

Nonferrous Metals 844 202 402 282 140% 22 11% 72 0.18 

Fabricated Metal 2,346 477 746 525 110% 46 10% 114 0.15 

Electronics/Computers 405 60 87 80 133% 8 13% 21 0.24 

Motor Vehicle Assembly 598 169 284 162 96% 14 8% 28 0.10 

Pulp and Paper 306 189 576 162 86% 28 15% 88 0.15 

Printing 4,106 397 676 251 63% 25 6% 72 0.11 

Inorganic Chemicals 548 158 427 167 106% 19 12% 49 0.12 

Organic Chemicals 412 195 545 197 101% 39 20% 118 0.22 

Petroleum Refining 156 109 437 109 100% 39 36% 114 0.26 

Iron and Steel 374 167 488 165 99% 20 12% 46 0.09 

Dry Cleaning 933 80 111 21 26% 5 6% 11 0.10 

*Percentages in Columns E and F are based on the number of facilities inspected (Column C). Percentages can exceed 100% because violations and actions can occur 

without a facility inspection. 

B 

SIC Code 25 98 September 1995
Sector Notebook Project Wood Furniture and Fixtures

September 1995 99 SIC Code 25

Exhibit 27

Five Year Inspection and Enforcement Summary by Statute for Selected

Industries

Industry Sector Number of

Facilities

Inspected

Total

Inspections

Enforcement

Actions

Clean Air Act Clean Water Act Resource Conservation

and Recovery Act

FIFRA/TSCA/

EPCRA/Other

*

% of Total

Inspections

% of Total

Actions

% of Total

Inspections

% of Total

Actions

% of Total

Inspections

% of Total

Actions

% of Total

Inspections

% of Total

Actions

Metal Mining 339 1,519 155 35% 17% 57% 60% 6% 14% 1% 9%

Non-metallic

Mineral Mining

631 3,422 192 65% 46% 31% 24% 3% 27% <1% 4%

Lumber and Wood 301 1,891 232 31% 21% 8% 7% 59% 67% 2% 5%

Furniture 293 1,534 91 52% 27% 1% 1% 45% 64% 1% 8%

Rubber and Plastic 739 3,386 391 39% 15% 13% 7% 44% 68% 3% 10%

Stone, Clay and

Glass

268 2,475 301 45% 39% 15% 5% 39% 51% 2% 5%

Nonferrous

Metals

474 3,097 470 36% 22% 22% 13% 38% 54% 4% 10%

Fabricated Metal 1,340 5,509 840 25% 11% 15% 6% 56% 76% 4% 7%

Electronics/

Computers

222 777 212 16% 2% 14% 3% 66% 90% 3% 5%

Motor Vehicle

Assembly

390 2,216 240 35% 15% 9% 4% 54% 75% 2% 6%

Pulp and Paper 265 3,766 502 51% 48% 38% 30% 9% 18% 2% 3%

Printing 1,035 4,723 514 49% 31% 6% 3% 43% 62% 2% 4%

Inorganic

Chemicals

302 3,034 402 29% 26% 29% 17% 39% 53% 3% 4%

Organic

Chemicals

316 3,864 726 33% 30% 16% 21% 46% 44% 5% 5%

Petroleum

Refining

145 3,237 797 44% 32% 19% 12% 35% 52% 2% 5%

Iron and Steel 275 3,555 499 32% 20% 30% 18% 37% 58% 2% 5%

Dry Cleaning 245 633 103 15% 1% 3% 4% 83% 93% <1% 1%

* Actions taken to enforce the Federal Insecticide, Fungicide, and Rodenticide Act;

the Toxic Substances and Control Act, and the Emergency Planning and

Community Right-to-Know Act as well as other Federal environmental laws.
Wood Furniture and Fixtures Sector Notebook Project

SIC Code 25 100 September 1995

Exhibit 28

One Year Inspection and Enforcement Summary by Statute for

Selected Industries

Industry Sector Number of

Facilities

Inspected

Total

Inspections

Enforcement

Actions

Clean Air Act Clean Water Act Resource Conservation

and Recovery Act

FIFRA/TSCA/

EPCRA/Other

% of Total

Inspections

% of

Total

Actions

% of Total

Inspections

% of

Total

Actions

% of Total

Inspections

% of

Total

Actions

% of Total

Inspections

% of

Total

Actions

Metal Mining 114 194 24 47% 42% 43% 34% 10% 6% <1% 19%

Non-metallic

Mineral Mining

253 425 54 69% 58% 26% 16% 5% 16% <1% 11%

Lumber and

Wood

142 268 42 29% 20% 8% 13% 63% 61% <1% 6%

Furniture 293 160 5 58% 67% 1% 10% 41% 10% <1% 13%

Rubber and

Plastic

271 435 59 39% 14% 14% 4% 46% 71% 1% 11%

Stone, Clay, and

Glass

146 330 66 45% 52% 18% 8% 38% 37% <1% 3%

Nonferrous

Metals

202 402 72 33% 24% 21% 3% 44% 69% 1% 4%

Fabricated Metal 477 746 114 25% 14% 14% 8% 61% 77% <1% 2%

Electronics/

Computers

60 87 21 17% 2% 14% 7% 69% 87% <1% 4%

Motor Vehicle

Assembly

169 284 28 34% 16% 10% 9% 56% 69% 1% 6%

Pulp and Paper 189 576 88 56% 69% 35% 21% 10% 7% <1% 3%

Printing 397 676 72 50% 27% 5% 3% 44% 66% <1% 4%

Inorganic

Chemicals

158 427 49 26% 38% 29% 21% 45% 36% <1% 6%

Organic

Chemicals

195 545 118 36% 34% 13% 16% 50% 49% 1% 1%

Petroleum

Refining

109 439 114 50% 31% 19% 16% 30% 47% 1% 6%

Iron and Steel 167 488 46 29% 18% 35% 26% 36% 50% <1% 6%

Dry Cleaning 80 111 11 21% 4% 1% 22% 78% 67% <1% 7%

* Actions taken to enforce the Federal Insecticide, Fungicide, and Rodenticide Act; the

Toxic Substances and Control Act, and the Emergency Planning and Community

Right-to-Know Act as well as other Federal environmental laws.
Sector Notebook Project Wood Furniture and Fixtures 

VII.C. Review of Major Legal Actions 

This section provides summary information about major cases and 

supplemental enforcement projects that pertain to the Wood Furniture 

and Fixtures Industry. Information in this section is provided by the 

Office of Enforcement and Compliance Assurance and EPA's 

Enforcement Accomplishments Report. 

VII.C.1. Review of Major Cases 

As indicated in EPA's Enforcement Accomplishments Report, FY1991, 

FY1992, FY1993 publications, two significant enforcement actions were 

resolved between 1991 and 1993 for the furniture and fixtures 

industry, involving RCRA violations. One of the RCRA enforcement 

cases also included CWA violations. The companies against which the 

cases were brought include a school furniture manufacturer and a 

furniture refinisher. 

Of the two actions involving RCRA violations, one was a civil action 

for penalties and injunctive relief against the school furniture 

manufacturer. The action was based on 29 RCRA and significant 

CWA violations discovered by EPA inspectors. The violations resulted 

primarily from the use of two unlined surface impoundments as part 

of a waste water treatment facility. The second case involving RCRA 

violations was against a furniture refinisher and resulted in a 

conviction on four counts of illegal disposal of hazardous waste and 

imposition of a jail sentence. The hazardous waste consisted primarily 

of furniture stripping solvents. 

VII.C.2. Supplemental Environmental Projects 

SEPs are compliance agreements that reduce a facility's stipulated 

penalty in return for an environmental project that exceeds the value 

of the reduction. Often, these projects fund pollution prevention 

activities that can significantly reduce the future pollutant loadings of 

a facility. The yearly Regional updates and the Enforcement 

Accomplishments Reports, FY1991, FY1992, and FY1993 did not provide 

information on any SEPs entered into by furniture or fixture 

manufacturing facilities. 

September 1995 101 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

VIII. COMPLIANCE ACTIVITIES AND INITIATIVES 

This section highlights the activities undertaken by this industry sector 

and public agencies to voluntarily improve the sector's environmental 

performance. These activities include those independently initiated by 

industrial trade associations. In this section, the notebook also 

contains a listing and description of national and regional trade 

associations. 

VIII.A. Sector-related Environmental Programs and Activities 

One major sector-related environmental research project has been 

undertaken at the Furniture and Manufacturing and Management 

(FMM) Center at North Carolina State University (NCSU), organized 

in 1991 as an outgrowth the Furniture Manufacturing and 

Management curriculum, which began in 1948. The mission of the 

FMM Center is three-fold: 

• To conduct applied research on manufacturing and engineering 

issues for the benefit of the furniture industry; 

• To carry out an extension program providing ongoing technical 

assistance and technology transfer in support of the furniture 

industry. Extension services focus on the areas of upholstery 

furniture manufacturing, case goods manufacturing, and 

environmental management; 

• To educate engineers with specific knowledge of furniture 

manufacturing. 

The Environmental Program of the FMM Center is divided into 

applied research activities and extension services. Research activities 

are related to the industry in general rather than a particular company. 

Currently, the FMM Center has two ongoing research projects related 

to environmental issues: 

• Development of environmental recordkeeping software and a 

computerized tracking system for chemical usage and emission 

reporting; 

• Exploration of a biofiltration project, a method for destruction 

of VOC and HAP emissions from finishing operations. 

SIC Code 25 102 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

The following project, requested by the U.S. EPA, may be undertaken 

in the near future: 

• Use of very low VOC/HAP coatings for wood finishing 

processes as a pollution prevention option for complying with 

the MACT and CTG. 

The purpose of the environmental extension program is to promote 

cooperation between the furniture industry and the FMM Center. 

Activities include providing technical assistance and advisory 

guidance, conducting literature searches, acting as liaison, and 

providing training, and other requested services, including: 

• Quarterly environmental forum for environmental managers 

and engineers in the furniture industry 

• Information dissemination, including free computerized 

literature searches 

• Technical assistance on an individual company basis, including 

short-term consultations 

• Workshops and training. 

In addition to the FMM initiatives, the North Carolina Small Business 

Ombudsman has been active in increasing awareness about the 

proposed MACT and CTG for the wood furniture finishing industry 

by issuing a fact sheet. The Small Business Ombudsman and some of 

the larger trade associations have also been involved in other 

compliance-related initiatives (see Section VIII.C.1.). 

VIII.B. EPA Voluntary Programs 

33/50 Program 

The "33/50 Program" is EPA's voluntary program to reduce toxic 

chemical releases and transfers of 17 chemicals from manufacturing 

facilities. Participating companies pledge to reduce their toxic 

chemical releases and transfers by 33 percent as of 1992 and by 50 

percent as of 1995 from the 1988 baseline year. Certificates of 

Appreciation have been given to participants who met their 1992 goals. 

The list of chemicals includes 17 high-use chemicals reported in the 

Toxics Release Inventory. 

September 1995 103 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

Of the 17 chemicals covered by the 33/50 Program, 11 are used by and 

are outputs of the wood furniture manufacutring industry. All but 

three of these eleven chemicals are solvents which are sued throughout 

furniture production, particularly in the finishing stages of the process. 

Exhibit 28 lists those companies participating in the 33/50 program 

that reported under SIC code 25 to TRI. Many of the participating 

companies listed multiple SIC codes (in no particular order), and are 

therefore likely to conduct operations in addition to Wood Furniture 

and Fixtures Industry. The table shows the number of facilities within 

each company that are participating in the 33/50 program; each 

company's total 1993 releases and transfers of 33/50 chemicals; and the 

percent reduction in these chemicals since 1988. 

According to EPA, 359 furniture manufacturing companies comprise 

the potential 33/50 universe. Of those companies, 31 or 8.64 percent 

are participating in the program, which is less than the average for all 

industries of 14 percent participation. 

Exhibit 28

Wood Furniture and Fixtures Facilities Participating in the 33/50 Program

Parent Facility name Parent City ST SIC Codes # of 

Participating 

Facilities 

1993 Releases 

and Transfers 

(lbs.) 

% Reduction 

1988 to 1993 

Armstrong World Industries Lancaster PA 2511 11 1,109,350 * 

Bassett Superior Lines Bassett VA 2511 12 2,063,109 50 

Best Chairs Inc. Ferdinand IN 2511 1 51,700 *** 

Geiger Group Inc Atlanta GA 2521 1 45,078 81 

Hamilton Industries Inc Two Rivers WI 2521 1 31,875 7 

Haworth Inc Holland MI 2522, 2521 2 194,050 50 

Heidelberg Cement Inc Allentown PA 2511 1 119,957 * 

Itr Industries Inc Deer Park NY 2511 1 34,882 * 

Joyce International Inc (De) New York NY 2541 2 118,847 25 

Klipsch & Associates Inc Indianapolis IN 2517, 2519, 

3651 

1 11,521 * 

La-Z-Boy Chair Company Monroe MI 2511 7 572,153 ** 

Lozier Corporation Omaha NE 2542, 2541 2 186,715 85 

Madix Inc Terrell TX 2542, 2541 1 623,805 55 

Marmon Group, Inc Chicago IL 2541 1 1,092,218 1 

Mascotech Taylor MI 2511 17 3,163,830 35 

North American Philips Corp New York NY 2517 1 1,281,928 50 

Oklahoma Fixture Co. Tulsa OK 2541 2 236,975 *** 

Seely Pine Furniture Inc. Berkeley 

Springs 

WV 2511 1 22,996 *** 

Shuford Industries Inc Hickory NC 2511 3 1,613,303 58 

Silver Furniture Co Inc Knoxville TN 2511 1 73,705 45 

SIC Code 25 104 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

Exhibit 28

Wood Furniture and Fixtures Facilities Participating in the 33/50 Program (cont'd)

Parent Facility name Parent City ST SIC Codes # of 

Participating 

Facilities 

1993 Releases 

and Transfers 

(lbs.) 

% Reduction 

1988 to 1993 

Steelcase Inc Grand Rapids MI 2522, 2542, 

2521 

5 2,042,735 20 

Suba Mfg. Inc Benicia CA 2541 1 5,949 25 

Thomson Consumer Electronics Indianapolis IN 2517 1 2,110,314 43 

W. J. Roscoe Co. Akron OH 2851, 2891, 

2517 

1 40,051 50 

White Consolidated Industries Cleveland OH 3585, 2542, 

2541 

1 808,298 81 

* = not quantifiable against 1988 data. 

** = use reduction goal only. 

*** = no numerical goal. 

Environmental Leadership Program 

The Environmental Leadership Program (ELP) is a national initiative 

piloted by EPA and State agencies in which facilities have volunteered 

to demonstrate innovative approaches to environmental management 

and compliance. EPA has selected 12 pilot projects at industrial 

facilities and Federal installations which will demonstrate the 

principles of the ELP program. These principles include: 

environmental management systems, multimedia compliance 

assurance, third-party verification of compliance, public measures of 

accountability, community involvement, and mentoring programs. In 

return for participating, pilot participants receive public recognition 

and are given a period of time to correct any violations discovered 

during these experimental projects. (Contact: Tai-ming Chang, ELP 

Director, 202-564-5081 or Robert Fentress, 202-564-7023) 

Project XL 

Project XL was initiated in March 1995 as a part of President Clinton's 

Reinventing Environmental Regulation initiative. The projects seek to 

achieve cost effective environmental benefits by allowing participants 

to replace or modify existing regulatory requirements on the condition 

that they produce greater environmental benefits. EPA and program 

participants will negotiate and sign a Final Project Agreement, 

detailing specific objectives that the regulated entity shall satisfy. In 

exchange, EPA will allow the participant a certain degree of regulatory 

flexibility and may seek changes in underlying regulations or statutes. 

Participants are encouraged to seek stakeholder support from local 

September 1995 105 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

governments, businesses, and environmental groups. EPA hopes to 

implement fifty pilot projects in four categories including facilities, 

sectors, communities, and government agencies regulated by EPA. 

Applications will be accepted on a rolling basis and projects will move 

to implementation within six months of their selection. For additional 

information regarding XL Projects, including application procedures 

and criteria, see the May 23, 1995 Federal Register Notice, or contact 

Jon Kessler at EPA's Office of Policy Analysis (202) 260-4034. 

Green Lights Program 

EPA's Green Lights program was initiated in 1991 and has the goal of 

preventing pollution by encouraging U.S. institutions to use energyefficient lighting technologies. The program has over 1,500 

participants which include major corporations; small and medium 

sized businesses; Federal, State and local governments; non-profit 

groups; schools; universities; and health care facilities. Each 

participant is required to survey their facilities and upgrade lighting 

wherever it is profitable. EPA provides technical assistance to the 

participants through a decision support software package, workshops 

and manuals, and a financing registry. EPA's Office of Air and 

Radiation is responsible for operating the Green Lights Program. 

(Contact: Susan Bullard at 202-233-9065 or the Green Light/Energy 

Star Hotline at 202-775-6650) 

WasteWi$e Program 

The WasteWi$e Program was started in 1994 by EPA's Office of Solid 

Waste and Emergency Response. The program is aimed at reducing 

municipal solid wastes by promoting waste minimization, recycling 

collection, and the manufacturing and purchase of recycled products. 

As of 1994, the program had about 300 companies as members, 

including a number of major corporations. Members agree to identify 

and implement actions to reduce their solid wastes and must provide 

EPA with their waste reduction goals along with yearly progress 

reports. EPA in turn provides technical assistance to member 

companies and allows the use of the WasteWi$e logo for promotional 

purposes. (Contact: Lynda Wynn, 202-260-0700 or the WasteWi$e 

Hotline at 1-800-372-9473). 

According to a representative from the Business and Institutional 

Furniture Manufacturers Association (BIFMA), BIFMA has recently 

joined the EPA's Waste Wi$e Program. 

SIC Code 25 106 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

Climate Wise Recognition Program 

The Climate Change Action Plan was initiated in response to the U.S. 

commitment to reduce greenhouse gas emissions in accordance with 

the Climate Change Convention of the 1990 Earth Summit. As part of 

the Climate Change Action Plan, the Climate Wise Recognition 

Program is a partnership initiative run jointly by EPA and the 

Department of Energy. The program is designed to reduce 

greenhouse gas emissions by encouraging reductions across all sectors 

of the economy, encouraging participation in the full range of Climate 

Change Action Plan initiatives, and fostering innovation. Participants 

in the program are required to identify and commit to actions that 

reduce greenhouse gas emissions. The program, in turn, gives 

organizations early recognition for their reduction commitments; 

provides technical assistance through consulting services, workshops, 

and guides; and provides access to the program's centralized 

information system. At EPA, the program is operated by the Air and 

Energy Policy Division within the Office of Policy Planning and 

Evaluation. (Contact: Pamela Herman, 202-260-4407) 

NICE3 

The U.S. Department of Energy and EPA's Office of Pollution 

Prevention are jointly administering a grant program called The 

National Industrial Competitiveness through Energy, Environment, 

and Economics (NICE3). By providing grants of up to 50 percent of 

the total project cost, the program encourages industry to reduce 

industrial waste at its source and become more energy-efficient and 

cost-competitive through waste minimization efforts. Grants are used 

by industry to design, test, demonstrate, and assess the feasibility of 

new processes and/or equipment with the potential to reduce 

pollution and increase energy efficiency. The program is open to all 

industries; however, priority is given to proposals from participants in 

the pulp and paper, chemicals, primary metals, and petroleum and 

coal products sectors. (Contact: DOE's Golden Field Office, 303-275-

4729) 

September 1995 107 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

VIII.C. Trade Association/Industry Sponsored Activity 

The following discussion will provide an overview of the larger 

trade associations representing the wood furniture manufacturing 

industry, with contact names, addresses, and summaries of 

activities undertaken by the associations to heighten their member 

companies' awareness of environmental regulations and 

compliance issues. 

VIII.C.1.Environmental Programs 

The larger trade associations with member companies from the wood 

furniture manufacturing industry have undertaken campaigns to 

educate further their membership on environmental regulations and 

compliance issues. The American Furniture Manufacturers 

Association (AFMA), in conjunction with 3M Environmental 

Engineering, Akzo Nobel, and Radian Corporation, has developed an 

industry compliance notebook and training course to inform facility 

managers of environmental regulations which could apply to their 

manufacturing operations. Similarly, Business and Institutional 

Furniture Manufacturers Association (BIFMA), AFMA, and the 

Kitchen Cabinet Manufacturers Association (KCMA) have already 

conducted four training seminars on the draft CTG and MACT 

standards for the wood furniture industry and how to comply with the 

new requirements. In addition, AFMA, BIFMA, KCMA, and the 

National Paint and Coatings Association were the primary industry 

trade association representatives in the lengthy regulatory negotiation 

process with EPA and other interested parties on the CTG and MACT 

standards. 

VIII.C.2. Summary of Trade Associations 

American Furniture Manufacturers 

Association (AFMA) 

P.O. Box HP-7 

High Point, NC 27261 

Phone: (910) 884-5000 

Fax: (910) 884-5303 

Members: 336 

Staff: 14 

Founded in 1984, this trade association includes manufacturers 

seeking to provide a unified voice for the furniture industry and to aid 

in the development of personnel. The group provides market research 

SIC Code 25 108 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

data, industrial relations services, costs and operating statistics, and 

general management and information services. The AFMA has annual 

meetings and publishes a membership directory once a year. 

Business and Institutional Furniture 

Manufacturers Association (BIFMA) 

2680 Horizon Drive S.E., Suite A-1 

Grand Rapids, MI 49546 

Fax: (616) 285-3765 

Members: 221 

Staff: 6 

Budget: $700,000 

Contact: Russell Coyner, Exec. Dir. 

Phone: (616) 285-3963 

This trade association consists of firms that manufacture furniture 

intended for use in offices, public spaces, and non-live-in institutions 

(including seating and space divider manufacturers). BIFMA is 

involved in industry relations, government relations, and maintains 

and provides industry information and statistics. The group conducts 

annual management conferences and publishes an annual membership 

directory, a bimonthly newsletter, and various statistical reports for its 

membership. 

Futon Association International (FAI) 

P.O. Box 6548 

Chico, CA 95927-6548 

Phone: (916) 534-7833 

Toll free: (800) 327-3262 

Fax: (916) 534-7875 

Members: 450 

Staff: 2 

Contact: Timothy Jacobs, 

Executive Director 

The FAI includes manufacturers, suppliers, wholesalers, and retailers 

of futons. This trade association facilitates contact and communication 

within the futon industry and keeps members informed of changes in 

the bedding industries codes, laws, and regulations. The FAI annually 

hosts a Futon EXPO and publishes periodic bulletins, membership 

directories, and a quarterly document entitled Updates. 

September 1995 109 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

Grand Rapids Area Furniture Manufacturers 

Association (GRAFMA) 

4362 Cascade Road, S.E., Suite 113 

Grand Rapids, MI 49506 

Phone: (616) 942-6225 

Fax: (616) 942-1730 

Members: 56 

Staff: 2 

Budget: $97,000 

Contact: Carol Kooistra, 

Executive Director 

This association consists of furniture manufacturers located in western 

Michigan. The organization conducts wage surveys, compiles 

statistics, sponsors periodic seminars on furniture technology, and 

publishes brochures, newsletters, and the document entitled Roster. 

International Home Furnishings Marketing 

Association (IHFMA) 

P.O. Box 5687 

High Point, NC 27262 

Phone: (910) 889-0203 

Fax: (910) 889-7460 

Members: 55 

Staff: 2 

Contact: Richard Barentine, 

Executive Director 

Founded in 1955, this furniture manufacturers’ group works to create a 

cooperative business environment. The IHFMA holds semiannual 

meetings in North Carolina and publishes various brochures and 

pamphlets. 

International Wholesale Furniture 

Association (IWFA) 

P.O. Box 2482 

164 S. Main Street, Suite 404 

High Point, NC 27261 

Phone: (910) 884-1566 

Members: 127 

Staff: 2 

Contact: Sonny Berry, 

Executive Director 

The IWFA consists mainly of wholesalers of home furniture but also 

includes some supplier firms that manufacture products offered for 

sale by wholesale-distributor members. This trade association hosts 

semiannual banquets and publishes a monthly newsletter entitled 

National Wholesale Furniture Association and an annual publication 

Who’s Who in Furniture Distribution. 

SIC Code 25 110 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/BIBLIOGRAPHY 

For further information on selected topics within the furniture and fixtures 

industry, a list of publications is provided below: 

General Profile 

Encyclopedia of Associations, 27th ed., Deborah M. Burek, ed., Gale Research Inc., 

Detroit, Michigan, 1992. 

Enforcement Accomplishments Report, FY 1991, U.S. EPA, Office of Enforcement 

(EPA/300-R92-008), April 1992. 

Enforcement Accomplishments Report, FY 1992, U.S. EPA, Office of Enforcement 

(EPA/230-R93-001), April 1993. 

Enforcement Accomplishments Report, FY 1993, U.S. EPA, Office of Enforcement 

(EPA/300-R94-003), April 1994. 

Standard Industrial Classification Manual, Office of Management and Budget, 1987. 

1992 Toxic Release Inventory (TRI) Public Data Release, U.S. EPA, Office of Pollution 

Prevention and Toxics, April 1994. (EPA/745-R94-001) 

U.S. Industrial Outlook 1994 - Household Consumer Durables, Department of 

Commerce. 

1987 Census of Manufacturers, Industry Series: Household Furniture, Bureau of the 

Census. (MC87-I-25A) 

1992 Census of Manufacturers, Preliminary Report Industry Series: Household Furniture, 

Bureau of the Census, May 1994. (MC92-I-25A(P)) 

Process Descriptions 

Draft Guidelines for the Control of Volatile Organic Compound Emissions from Wood 

Furniture Coating Operations, U.S. EPA, Office of Air and Radiation, October 1991. 

EPA Document AP-42 - Compilation of Air Pollutant Emission Factors 

McGraw-Hill Encyclopedia of Science & Technology, 6th ed., vols. 5, 6, 11, 13, 14, 16, 18, 

19, McGraw-Hill Book Company, New York, New York, 1987. 

September 1995 111 SIC Code 25 
Wood Furniture and Fixtures Sector Notebook Project 

Regulatory Profiles 

Draft Control Techniques Guidelines (CTGs) - Appendix B: Preliminary Draft Model Rule 

for Wood Furniture Finishing and Cleaning Operations, U.S. EPA. 

Environmental Guide for the Furniture Industry, AFMA, 3M Environmental 

Engineering, Akzo Nobel, Radian Corporation, Research Triangle Park, North 

Carolina, 1994. 

Furniture/Wood Manufacturing and Refinishing, U.S. EPA, RCRA Fact Sheet. 

(EPA/530-SW-90-027c) 

Pollution Prevention 

Pollution Prevention Options in Wood Furniture Manufacturing, A Bibliographic Report, 

U.S. EPA, Office of Pollution Prevention and Toxics, February 1992. (EPA/560/8-

92/001C) 

Contacts * 

Name Organization Telephone

Rosalyn Hughes U.S. EPA, Region IV (inspector)

David Stout Broyhill Corporation

Gary Bell La-Z-Boy Chair Company

Stan Payne Bassett Furniture

Ronald Pridgeon NC Department of Environment,

Health, and Natural Resources 

John Cullen Masco Corporation 

Larry Runyan American Furniture Manufacturers 

Association 

Bob Naboicheck Futon Association International 

Sholeh Azar NC State University 

Bob McCrillis U.S. EPA, Office of Research and 

Development 

404-347-2904 

704-758-3111 

313-242-1444 

703-629-6000 

919-571-4000 

313-274-7400 

910-884-5000 

203-549-2000 

919-515-6400 

919-541-2733 

* Many of the contacts listed above have provided valuable background 

information and comments during the development of this document. EPA 

appreciates this support and acknowledges that the individuals listed do not 

necessarily endorse all statements made within this notebook. 

SIC Code 25 112 September 1995 
Sector Notebook Project Wood Furniture and Fixtures 

Bob Marshall U.S. EPA, OECA 202-564-7021 

Madeliene Strum U.S. EPA, RTP 919-541-2383 

Paul Eisele Masco Corporation 313-274-7400 

Name Organization Telephone 

Edyth McKinney Small Business Ombudsman, 

North Carolina 800-829-4841 

John Lank U.S. EPA, Region IV (inspector) 404-347-7603 

September 1995 113 SIC Code 25