**Personal Communication with NALFA. 2010. Conversation between Dennis Bradway (Mannington**

**Floors and North American Laminate Floor Association) and Abt Associates Inc. regarding written questions about FSCWPA Impacts. November 22, 2010.**  1. Number of “Fabricat ors”

a. What percentage of laminate flooring manufacturers would you estimate use composite wood products (hardwood plywood, particleboard, or medium density fiberboard) in their products? 95% or greater i. 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? 95% or greater are fully compliant. 100% have some compliant product lines. ii. 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 p roduct 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? Very few if any would not comply with CARB

– less than 5% of domestic. 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 every separate item that gets produced and shipped out. Given this, could you estimate the average number of labels that would be needed annually for each manufacturer that uses composite wood materials? Not sure. b. If labels were required for each shipment of products instead of each individual item, about how may items would be included in a typical shipment? Not sure. 3. Number of Wood Veneer “Laminator Product” Manufacturers

a. 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 prod uced 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. Did not have a good answer about number of mills that are laminated product manufacturers. Did say that EWF manufacturers typically lay up the cores themselves, which is not really consistent with what we heard during our survey screenings and other sources, such as evergreen. b. For those manufacturers that would be classified 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? Laminators are all fabricators.c. What percentage of the production of wood veneer laminated products are produced using formaldehyde

-based resins to affix wood ven eers to purchased platforms? d. If wood veneer laminators using UF resins were to switch to a lower emission resin, what would be the likely resin choice?

e. Of those wood veneer laminators that use no

- added formaldehyde resins, what are the most common adhesiv es used? PVAC and soy are used. f. If wood veneer laminators were subject to the same third party testing requirements as CARB, about how many different product types would need to be third party certified for a typical manufacturer?

 Imports are 40% to 50% o f domestic consumption.  Rule should require NAF or ULEF glue for laminated product manufacturers without the same testing requirements  EWF is 18

- 25% of ALL flooring  10% of product is laminated product  Says that product imported under laminated product exem ption is often made using UF resins. Says this displaces CARB compliant product. Says 15% of high emitting imports would turn into domestic production if they had to use low emitting glues.  EWF standard includes a formaldehyde emissions test on finish ed product  Want level playing field from an emissions standpoint  Does not think frequent testing of laminated products is necessary Thinks infrequent testing of finished product, for example, once a year, is sufficient