### Personal Communication with BIFMA. 2010. Br ad Miller's (BIFMA) Written Responses to Questions about FSCWPA Impacts on Members. November 23, 2011.

1) Number of Fabricators a) What percentage of office furniture manufa cturers would you estimate use composite wood products (hardwood plywood, particleboard, or medium density fiberboard) in their products? i) 100%

b) Of these manufacturers, what percentage would you estimate produce at least some product lines that are CARB compliant because they use CARB certifi ed panels or component parts and follow the CARB recordkeeping and labeling requirements? i) 100%

c) Do the manufacturers that ar e producing CARB compliant product lines also carry product lines

for sale outside of California that are not CARB compliant? If, so what percentage of production volume would you estimate are product lines that are not compliant with CARB because they do not use CARB certified panels or component part s or do not follow the CARB recordkeeping and labeling requirements? i) Yes, only if the manufacturer is outside of North America and not selling to US; Not likely within the US. ii) N/A or 0 (in the U.S., unknown internationally).

2) Impact of Labeling Requirements a) A national regulation of composite wood products could potentially require manufacturers that use composite wood materials to put a label on ever y separate item that gets produced and shipped out. Given this, could you estimate the averag e number of labels that would be needed annually for each manufacturer that uses composite wood materials? i) This could be huge, easily in the millions for large manufacturers, depending on the definition of “separate item”. Smaller ma nufacturers would also be significantly burdened if new labeling requirements, beyond what they are already doing for CARB, were instituted. Also, for some parts it is ju st not feasible to label every individual part because there is no space on the part.

b) If labels were required for each shipment of pr oducts instead of each individual item, about how may items would be included in a typical shipment? i) A single “shipment” could contain anywhere from one to hundreds (maybe thousands)

items

. If bulk packaging could be labeled, you could divide the “millions” by 15 (approximation based on 15 parts per bulk pack).

3) Number of Wood Veneer “Lam inator Product” Manufacturers a) The recent federal legislati on uses the term laminated product to mean a finished good (such as a custom panel, cabinet, window, door, or piece of furniture) that is produced by affixing a wood veneer to a purchased platform. How many of your members would you say produce such laminated products by affixing wood veneer themse lves? Please do not include other types of laminates (such as high pressure laminates, therma lly fused papers, vinyl f ilms, decorative foils, or polypropylene films) in your answer. i) Many, if not most, BIFMA manufacturers produce office desk and storage products with wood veneer. It is estimated 75% of those would laminate their own products. Those who do not manufacture their own buy veneered components from suppliers.

b) For those manufacturers that would be classi fied as wood veneer laminators, how common is it for these manufacturers to also fabricate pr oducts using purchased panel s that were already

finished with a wood veneer or other decorative finish? i) It ranges from zero to 100% between i ndividual companies. While the majority of companies apply their own veneer to products, we believe it is not uncommon for companies to also purchase veneered components.c) What percentage of the produ ction of wood veneer laminated products are produced using formaldehyde-based resins to affix wood veneers to purchased platforms? i) Very little, if any. d) If wood veneer laminators using UF resins were to switch to a lower emission resin, what would be the likely resin choice? i) PVA e) Of those wood veneer laminat ors that use no-added formaldehy de resins, what are the most

common adhesives used? i) PVA f) If wood veneer laminators were subject to the same third party testing requirements as CARB, about how many different product types would n eed to be third party certified for a typical

manufacturer?

i) This would impact veneer on MDF, veneer on PB, and veneer on plywood. These categories would represent materials that are pervasive within the industry and account for thousands if not tens of thousands of individual product types. Further, the ASTM E1333 testing method is designed for four-foot by eight-foot sheets of material while office furniture veneered parts vary widely in size and shape. Veneers may also be applied to steel, aluminum, and other substrates but these are outside of this legislation.