### Personal Communication with KCMA. **Notes on phone conversation between Matthew LaPenta (Abt Associates) and Richard Titus**  **(Kitchen Cab inet Manufacturers Association). 10.28.2010. Questions were forwarded in advance.**  **Responses highlighted in green are from Matt LaPenta’s hand written notes of the conversation.**   Number of “Fabricators”  Roughly what percentage of all U.S. cabinet manufacturing firms are members of your association? 5% of firms, 70% of production. 60% of members have less than 10 million in sales. 200 cabinet manufacturers. There are about 5,000 manufacturers total. Are there any characteristics that may be typical of firms not represented by your organization? No, Diverse. For example, a specific area of the country, or a type of kitchen cabinet or cabinet construction.  What percentage of cabinet makers would you estimate use composite wood products (hardwood plywood, particleboard, or medium density fiberboard) in their products? 100%.  Of these manufacturers using composite wood products, what percentage would you estimate produce at least some product lines that are CARB compliant because they use CARB certified panels or component parts and follow the CARB recordkeeping and labeling requirements? These are ballpartk estimates. About 50% of members and 50% of total U.S. cabinet production is CARB compliant product lines. The KCMA Environmental Stewardship Program requires this. In 2011, ESP products will all be CARB 2 compliant.  Do the manufacturers that are 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 parts or do not follow the CARB recordkeeping and labeling requirements? No. Confident that cabinet manufacturers do not carry 2 product lines. It would be too hard to avoid mixing the many components for cabinets.  Impact of Labeling Requirement s  A national regulation of composite wood products could potentially require manufacturers that use composite wood materials to put a label on every separate item that gets produced and shipped out. Given this, could you estimate the average number of lab els that would be needed annually for each manufacturer that uses composite wood materials? Clarified that “item” means unit (e.g., cabinet) and not, for example, component. Could not say for sure. But possible to estimate assuming 15 - 17 cabinets per job in new housing and fact that new housing accounts for about 30% of sales. In neighborhood of several, 3? 5? 10? Million?  If labels were required for each shipment of products instead of each individual item, about how may items would be included in a ty pical shipment? Did not answer, but above says 15 - 17 cabinets per job.  Number of Wood Veneer “ Laminator Product” Manufacturers  The recent federal legislation uses the term laminat ed 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 themselves? Please do not include other types of laminates (such as high pressure laminates, thermally fused papers, vinyl films, decorative foils, or polypropylene films) in your answer. 11 members said they did this. 5% or less of manufacturers do this. It is not common. For those manufacturers that would be cla ssified as wood veneer laminators, how common is it for these

manufacturers to also fabricate products using purchased panels that were already finished with a wood veneer or other decorative finish? They would do both.  What percentage of the production of wood veneer laminated products are produced using formaldehyde based resins to affix wood veneers to purchased platforms? 6 -NAF, 5 -UF  If wood veneer laminators using UF resins were to switch to a lower emission resin, what would be the likely resin choice ? In order from most likely: PVA, MUF, Soy, PF  Of those wood veneer laminators that use no - added formaldehyde resins, what are the most common adhesives used? In order from most likely: PVA and Soy  If wood veneer laminators were subject to the same third p arty testing requirements as CARB, about how many different product types would need to be third party certified for a typical manufacturer? Don’t know, but there is a lot of variation because cabinets use a large number of components. Different price points, species, fashion changes, and durability requirements dictate this variation. General comments:  KCMA ESP program requires CARB compliance and verifies it.  Cabinet makers have historically not done the veneering themselves. KCMA is concerned that the suppliers of their members who are laminated product manufacturers under CARB would be adversely affected by the rule.  KCMA wants federal rule to be as close to CARB as possible  The HWPW manufacturers are trying to set up a trade barrier by pushing for a regulation on laminated product manufacturers, but this would hurt domestic cabinet manufacturers  Concerned about IRIS

– this will be a big deal.  Suggested contacting him to get input on third party testing requirements, especially finished product testi ng. Suggested that finished product testing may be a good tool to identify bad actors for further investigation.