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OMB Control No. 2070-0177 

Approval Expires 03/31/2013

United States Environmental Protection Agency 

 

Pressed Wood Manufacturing Industry Survey: 

 

Hardwood Plywood, Medium Density 

Fiberboard, and Particleboard Manufacturers 

 

Questionnaire

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

 

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

information from all companies (including those making products with low formaldehyde 

emissions) to determine whether further action is needed, and to understand the impact of 

potential actions on manufacturers. Your participation will help EPA understand your 

company and the industry as a whole. 

Survey ID:

The information collected by EPA may be disclosed to contractors of the Agency. This access will only occur to enable the contractors to 

perform required tasks for the Agency. These contractors, including staff, will comply with Agency procedures for contractor handling of 

confidential information collected in connection with TSCA. By returning the survey to EPA, I consent to this disclosure to EPA's 

contractors.
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OMB Control No. 2070-0177 

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The public reporting and recordkeeping burden for this collection of information is 

estimated to average 20 hours per response. Send comments on the Agency's need for 

this information, the accuracy of the provided burden estimates, and any suggested 

methods for minimizing respondent burden, including through the use of automated 

collection techniques to the Director, Collection Strategies Division, U.S. Environmental 

Protection Agency (2822T), 1200 Pennsylvania Ave., NW, Washington, D.C. 20460. 

Include the OMB control number in any correspondence. Do not send the completed 

questionnaire to this address.

An Agency may not conduct or sponsor, and a person is not required to respond to, a collection of information, 

unless it displays a currently valid OMB control number.
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OMB Control No. 2070-0177 

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I. General Manufacturer Identification Information

Please verify that the information that we have for your company is accurate. Please correct any errors or 

complete any missing information on the lines following Questions 1 through 8 below. Please consult 

appropriate staff at your company as necessary to obtain the correct information.

Check red box if response is confidential business information (CBI) 

1. The name of your company:

2. The name of your plant:

3. The address of your plant (mailing address and physical address, if different):

Physical 

Address Line 1:

Address Line 2:

City: State: ZIP 

Mailing 

Address Line 1:

Address Line 2:

City: State: ZIP 

4. The name and address of the ultimate parent company that owns this plant:

Parent Company:

Address Line 1:

Address Line 2:

City: State: ZIP 

5. Your company’s website address:

6. Your contact information:

Name:

Title:

Telephone:

E-mail:
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OMB Control No. 2070-0177 

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7. Size of ultimate parent company:

a. The approximate number of employees (worldwide) of the ultimate parent company that owns this plant:

less than 50

50-99

100-249

250-499

500-999

1,000-1,499

1,500 or more

Number:

b. The approximate 2009 gross revenue (worldwide) of the ultimate parent company that owns this plant:

less than $1 million

$1-$49 million

$50-$99 million

$100-$499 million

$500 million or more

Gross Revenue ($):

8. Size of this plant:

a. The approximate total number of employees (full time and part time) in total at this plant:

less than 25

25-49

50-99

100-149

150-249

250-499

500 or more

Number:

b. The approximate 2009 gross revenue of this plant:

less than $1 million

$1-$49 million

$50-$99 million

$100-$499 million

$500 million or more

Gross Revenue ($):

Check red box if response is confidential business information (CBI) 
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OMB Control No. 2070-0177 

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II. Primary Pressed Wood Products Manufactured

* Check red box if response is confidential business information (CBI) 

CBI*

Pressed Wood 

Category 

 

 

 

 

(Column 1)

Check if 

manufactured at 

your plant 

 

 

 

(Column 2)

In the 5-year period from 2005 through 

2009, what was the average annual 

total production? 

(please specify basis) 

 

 

(Column 3)

Provide your plant's rated 

maximum capacity 

 

 

 

 

(Column 4)

Example: 

c. Particleboard

Avg. annual production:

1 million sq. ft

basis: 3/4"

Max capacity:

5 million sq. ft

basis: 3/4"

a. Hardwood Plywood Avg. annual production:

basis:

Max capacity:

basis:

b. Medium Density 

Fiberboard (MDF)

Avg. annual production:

basis:

Max capacity:

basis:

c. Particleboard Avg. annual production:

basis:

Max capacity:

basis:

9. Primary pressed wood products manufactured and production volume. 
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* Check red box if response is confidential business information (CBI) 

10. Regions where pressed wood products manufactured at your plant were sold and are 

expected to be sold. PLEASE CHECK ALL THAT APPLY (check N/A if not applicable).

CBI*

Pressed Wood 

Category 

 

 

 

(Column 1)

Regions where primary pressed 

wood products were sold during 

the five year period from 

2005 through 2009 

 

(Column 2)

Regions where primary pressed 

wood products are expected to 

be sold after the end of 2012 

 

 

(Column 3)

a. Hardwood Plywood California

U.S. (excluding CA)

European Union

Japan

Other Nations

N/A or I don't know

California

U.S. (excluding CA)

European Union

Japan

Other Nations

N/A or I don't know

b. Medium Density Fiberboard California

U.S. (excluding CA)

European Union

Japan

Other Nations

N/A or I don't know

California

U.S. (excluding CA)

European Union

Japan

Other Nations

N/A or I don't know

c. Particleboard California

U.S. (excluding CA)

European Union

Japan

Other Nations

N/A or I don't know

California

U.S. (excluding CA)

European Union

Japan

Other Nations

N/A or I don't know
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OMB Control No. 2070-0177 

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a. Please indicate the type(s) of hardwood plywood production process(es) used at your plant:

11. Hardwood plywood is produced at this plant. 

If hardwood plywood is NOT produced at this plant please skip to Question 12.

Check red box if response is confidential business information (CBI) 

Log-based mill (interior veneer plys generated on-site from logs, face veneers

Purchases all veneers and/or composite panel components (no log processing capability)

Purchases prepared platforms and face veneers (3-ply mill)

Engineered flooring

Flushed door

None of the above. Please specify the type:

and interior composite panels may be purchased)

b. Indicate which process you use for manufacturing hardwood plywood:

Please indicate the share of hardwood plywood production volume that is 

line-by-line:

All hardwood plywood is produced using a line-by-line process

All hardwood plywood is produced using a 2-step process

Hardwood plywood is produced using both line-by-line and 2-step processes. 

None of the above. Please specify the process:

%

c. Indicate the type(s) of platforms you use for manufacturing hardwood plywood:

Veneer core

Particleboard core

Medium density fiberboard core

Lumber core

Combination core

None of the above. Please specify the type:

No

Yes, military specified hardwood plywood

Yes, curved hardwood plywood

Yes, hardwood plywood defined as a laminated product under CARB

d. Indicate whether any hardwood plywood produced at this plant does not meet CARB's definition of 

hardwood plywood:
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Blowline blending exclusively 

Mechanical blending exclusively

Combination of blowline and mechanical blending

None of the above. Please specify the type:

d. Please specify the type of blending equipment your plant employs:

Check red box if response is confidential business information (CBI) 

e. Please indicate the type(s) of press(es) at your plant:

Multi-opening platen press(es)

Single opening platen press(es) 

Steam injection platen press(es) 

Continuous steel belt press(es)

Continuous drum (Mende) press(es)

None of the above. Please specify the type:

f. Please indicate how important your board's appearance is to your customers:

Appearance is very important 

Appearance is somewhat important

Appearance is not important

c. Does your plant manufacture layered medium density fiberboard?

Yes

No

a. Please indicate how much thin board (<3/8”) your plant produces as a share of all medium 

density fiberboard production volume at your plant: %

b. Please describe the typical pH levels of your raw wood material:

Raw wood material has relatively high pH levels (6.0 or greater)

Raw wood material has average pH levels (4.0 to 5.9)

Raw wood material has relatively low pH levels (3.9 or less)

12. Medium density fiberboard is produced at this plant. 

If medium density fiberboard is NOT produced at your plant please skip to Question 13.
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OMB Control No. 2070-0177 

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d. Please indicate the type(s) of press(es) at your plant:

Multi-opening platen press(es)

Single opening platen press(es) 

Steam injection platen press(es) 

Continuous steel belt press(es)

Continuous drum (Mende) press(es)

None of the above. Please specify the type:

Caul

Caul-less

e. Please describe the type(s) of forming line(s) your plant employs:

f. Please indicate how important your board's appearance is to your customers:

Appearance is very important 

Appearance is somewhat important

Appearance is not important

c. Please indicate the approximate percentages of your particleboard production by grade 

(see ANSI 208.1-2009 for grade definitions)

% Grade M-0 (Commercial)

% Grade M-1(Commercial)

% Grade M-S (Commercial)

% Grade M-2 (Industrial)

% Grade M-3 (Interior stair tread)

% Floor Underlayment (PBU)

% MFD Home Decking (D-2, D-3)

% Door Core (LD-1, LD-2)

% Grade H-1 (High density industrial)

% Grade H-2 (High density industrial)

% Grade H-3 (High density industrial)

% Grade M-3i (Industrial)

% Other

a. Please indicate how much thin board (<1/2”) your plant produces as a share of all particleboard 

production volume at your plant: %

b. Please describe the typical pH levels of your raw wood material:

Raw wood material has relatively high pH levels (6.0 or greater)

Raw wood material has average pH levels (4.0 to 5.9)

Raw wood material has relatively low pH levels (3.9 or less)

13. Particleboard is produced at this plant. 

If particleboard is NOT produced at your plant please skip to Question 14. 

Please specify:
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Copy #1 of Question 14 OMB Control No. 2070-0177 Approval Expires 03/31/2013

1. Pressed Wood Category 

Abbreviations:

2. Binder/Resin Categories: 3. Certification Standard Categories:

HWPW Hardwood PlywoodMDF Medium Density Fiberboard

PB Particleboard

CNSL Cashew Nut Shell Liquid MF Melamine-formaldehyde MUF Melamine-urea-formaldehyde

pMDI Polymeric Diphenylmethane 

Diisocyanate

PF Phenol-formaldehyde 

PF-MDI Phenol-formaldehyde-MDI PMUF-MDI Phenol-melamine-ureaformaldehyde-MDI

PUF-MDI Phenol-urea-formaldehyde-MDIPUFT Phenol-urea-formaldehyde Tannin

PVA Polyvinyl Acetate SBR Soy-based resins TBR Tannin-based resins UF Urea-formaldehyde O Other: Please Describe+s addition of scavenger to resin 

(for example, "MF+s")

+c addition of catalysts to resin 

+a addition of other additives to 

resin

CA-1 CARB Phase 1CA-2 CARB Phase 2 (not ULEF or NAF)CA-2(ULEF) CARB Phase 2 with ultra-low-emitting formaldehyde

CA-2(NAF) CARB Phase 2 with no added formaldehyde 

CPA CPA EPP GrademarkE1/E2 European Standard (specify level in table above)F Japanese Standard (specify “*” level in table above)HUD HUD Standard

O Other - please specifyNone No certification standard category was met/will be metN/A Not applicable/not required

Add Copy

Pressed Wood 

Category

Adhesive/

Emissions

Binder/ Resin Category (select from list below)2 Formaldehyde Emission Certification Standard Category (select from list below)3

CBI*

(select from 

list below)1

(Column 1)

Class 

(Column 2)

Previous 

(if changed in last 5 years) 

(Column 3)

 Current 

(Column 4)

Planned changes 

(over the next 3 years) 

(Column 5)

Previous 

(if changed in 

last 5 years) 

(Column 6)

 Current 

(Column 7)

Planned 

changes (over 

the next 3 years) 

(Column 8)

Example: MDF 1 Face: UF Core: UF Face: MUF Core: UF Face: MUF+s Core: UF+s None CA-1 CA-2Example: MDF 2 Not Applicable UF+s MUF+s None CA-1 CA-2

14. Resin Types and Certification Standards.* Check red box if response is confidential business information (CBI) 

 Please complete the following table for particleboard, medium density fiberboard, and hardwood plywood 

products produced at your plant. If you produce products in more than one adhesive/emissions class, list each class in a separate row. For the purpose of this survey, adhesive/emissions class means a class of pressed wood product that differs from others based on binder/resin technology, formaldehyde emission certification standard category, and/or formaldehyde emission profile. If you use more than one resin type for the same product, such as different resins for face and core layers, please indicate each resin in the table (see example below). If you need more rows than provided in the table below, click the button below to have the electronic version of this form automatically generate an additional copy of this question. If you are using the paper version of this form, please use the extra copies provided and make additional copies as necessary. 
Copy #1 of Question 15

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Formaldehyde emission levels from finished boards Share of Production 

Pressed Wood 

Category

Adhesive/

Emissions

Previous 

(if changed in last 5 years) Current

Planned 

(over the next 3 years)

Volume

CBI*

(select from 

list below)1

(Column 1)

Class 

(Column 2)

Average 

(specify units)

(Column 3)

Max 

(specify units) 

(Column 4)

Average 

(specify units)

(Column 5)

Max 

(specify units) 

(Column 6)

Average 

(specify units)

(Column 7)

Max 

(specify units) 

(Column 8)

Current 

(%) 

(Column 9)

Planned 

(%) 

(Column 10)

Example: MDF 1 unknown unknown 0.10 ppm 0.15 ppm 0.06 ppm 0.08 ppm 40% 20%Example: MDF 2 Not Applicable Not Applicable 0.15 ppm 0.18 ppm 0.06 ppm 0.09 ppm 60% 80%

1. Pressed Wood Category Abbreviations: HWPW Hardwood PlywoodMDF Medium Density Fiberboard

PB Particleboard

15. Formaldehyde Emission Levels from Finished Boards.* Check red box if response is confidential business information (CBI) 

 Please complete the following table for particleboard, medium density fiberboard, and hardwood 

plywood products produced at your plant. For the purpose of this survey, adhesive/emissions class means a class of pressed wood product that differs from others based on binder/resin technology, formaldehyde emission certification standard category, and/or formaldehyde emission profile. If you produce products in more than one adhesive/emissions class, list each class in a separate row. For average and maximum emissions, provide results from a standard test method for a large or small chamber test (see Figure 4 of instructions). Provide results as large chamber equivalent emissions if possible. If you have been making the current adhesive/emissions class for a year or more, calculate the average and maximum emissions over a one year period. If you have not been making the product for a full year, calculate the average and maximum over whatever time frame you manufactured the adhesive/emissions class. If you are using the paper version of the form, please use the extra copies provided and make additional copies as necessary, and list the pressed wood categories and adhesive/emissions classes in the order that you reported them in Column 1 and Column 2 of Question 14.

Yes No

If No, please specify which rows do not report large chamber equivalent emissions and indicate the measurement method used:

 Will you report all the formaldehyde emissions below as large chamber equivalent emissions?
Copy #1 of Section III

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Add Copy

III. Changes to Achieve CARB Phase 1 Certification

Please complete Questions 16 through 18 if you have made changes to your production process or raw materials for 

the purpose of achieving CARB Phase 1 certification. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

A separate copy of Section III needs to be completed for each pressed wood category where there were changes to 

achieve CARB Phase 1 certification. In addition, if you have made changes to more than one adhesive/emissions class 

within a pressed wood category, please complete a separate copy of Section III for each adhesive/emissions class. 

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

technology, formaldehyde emission certification standard category, and/or formaldehyde emission profile. 

 

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

Section III. If you are using the paper version of this form, please use the extra copies provided and make additional 

copies as necessary.

Check red box if response is confidential business information (CBI) 

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

Check all boxes that apply and fill in the applicable blanks.

Primary Pressed Wood Category:

a. Specify product for which there were changes to the production processes or raw materials 

used in order to achieve CARB Phase 1 certification:

Please consider only the most recent major reduction in formaldehyde emissions 

you have made specifically to comply with CARB Phase 1 in your responses to 

Questions 16-18. 

 

For example, if you are a particleboard manufacturer who: 

1. Made changes to your adhesive system to meet the CPA EPP Grademark 

formaldehyde emission limit of 0.30 ppm, 

2. Then made additional changes to meet the revised CPA EPP Grademark 

formaldehyde emission limit of 0.20 ppm, 

3. Then made additional changes to meet the CARB Phase 1 formaldehyde 

emission limit of 0.18 ppm, 

 

Your responses should only reflect the changes you made to reduce your 

formaldehyde emissions from the 0.20 ppm limit to the 0.18 ppm limit to achieve 

CARB Phase 1 certification. If you made multiple changes to reduce your 

formaldehyde emissions from the 0.20 ppm to 0.18 ppm, report the sum of all of 

those changes. 

Adhesive/Emissions Class:
Copy #1 of Section III

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b. What were the changes to the resin system or production process? Please check all that apply.

Lower ratio of formaldehyde to other resin component(s) (e.g., urea,

Please specify non-formaldehyde resin component:

Addition of or changes to catalysts in resins

Post-press treatment of panels

New resin system (for example, substituting melamine for urea)

Changes to application equipment

Changes to blending equipment

Changes to pressing or drying times

Changes to process controls

Changes to pressing or drying temperatures

Other Please specify:

melamine, phenol, etc.).

Addition of or changes to scavengers in resins

Addition of or changes to other additives in resins

16. (cont.) Changes to the production processes or raw materials to achieve CARB Phase 1 certification. 

Check all boxes that apply and fill in the applicable blanks.

Check red box if response is confidential business information (CBI) 

c. Please indicate the extent to which you have optimized your production process since making these 

changes:

Production Process Fully Optimized

Production Process Nearly Optimized

Production Process Partially Optimized

Production Process Not Optimized

e. OPTIONAL. Please use the space below to clarify or further explain any of your responses to Question 16.

d. Do you expect to incur additional costs associated with optimizing your process?

Yes: Please provide an estimate of the additional costs you expect to incur for process

No

17. Issues your plant addressed in order to achieve CARB Phase 1 certification.

a. Your plant needed to address issues associated with sticking or buildup on press platens.

b. Your plant needed to improve resin unloading, storage and handling system to deal with 

higher liquid viscosity, handle dry materials, and/or blend multiple components.

optimization: $ or choose a range:
Copy #1 of Section III

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Check red box if response is confidential business information (CBI) 

d. Your plant needed to address issues associated with resin tack, including:

Build-up in conveyers, bins, or mat formers

Mat integrity problems

Prepress tack

c. Your plant needed to upgrade blending or application equipment.

Please describe equipment change. For instance, “Installed two new metering pumps and flow 

meters to control ratios of resin components to a new inline mixer. Installed new programmable 

automation controllers on the blender and resin metering pumps and integrated into the mill’s 

visualization platform.”

e. Your plant needed to upgrade your press.

For the press that was upgraded, please describe what was done. For instance, “Converted 

the press from steam heat to thermal oil in order to achieve higher platen temperature and 

improve productivity with PF resin.” 

f. Your plant needed to resolve issues associated with not having enough cooling capacity to 

deal with master panels.

g. Your plant needed to resolve issues associated with out-of-press moisture content due to 

longer or hotter press times.

h. Industrial hygiene concerns (e.g., worker health) influenced your ability to use certain resin types.

i. Your plant needed to resolve issues associated with waste control.

Please explain:

17. (cont.) Issues your plant addressed in order to achieve CARB Phase 1 certification.

j. Your plant needed to address issues associated with limited excess drying capacity.

k. Your plant needed to modify your board coolers.

l. Your plant needed to add new wood burners to burn residuals that were previously recycled.
Copy #1 of Section III

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Check red box if response is confidential business information (CBI) 

18. Estimated costs of changes to the production processes or raw materials.

a. Did your plant incur research and development costs directly as a result of changes made to achieve 

CARB Phase 1 certification?

Yes:

No

b. Did your plant incur capital improvement costs directly as a result of changes made to achieve 

CARB Phase 1 certification (check all that apply)? 

Yes, capital expenditures for modifying existing equipment

Yes, capital expenditures for new equipment

No

c. Did your plant incur any other start-up or one-time costs directly as a result of changes made to 

achieve CARB Phase 1 certification? 

Yes:

No

Please describe the costs incurred:

17. (cont.) Issues your plant addressed in order to achieve CARB Phase 1 certification.

m. OPTIONAL. Please use the space below to describe other issues your plant addressed or to clarify or 

further explain any of your responses to Question 17.

Please provide cost estimate: $ or choose range:

Please provide a cost estimate for all capital improvements costs directly related to changes made to 

achieve CARB Phase 1 certification: 

 

Enter estimate: $ or choose a range:

Please provide cost estimate: $ or choose range:
Copy #1 of Section III

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Check red box if response is confidential business information (CBI) 

18. (cont.) Estimated costs of changes to the production processes or raw materials.

e. Did any of the following operating costs change directly as a result of changes made to achieve CARB 

Phase 1 certification (check appropriate boxes)?

Labor costs: increased decreased remained unchanged 

Energy costs: increased decreased remained unchanged 

Other operating costs: increased decreased remained unchanged 

please specify:

Overall, this was a cost: increase decrease

f. Did any of the following recordkeeping, testing, or certification costs change as a result of changes made 

to achieve CARB Phase 1 certification (check appropriate boxes)? 

Recordkeeping costs: increased decreased remained unchanged 

Testing and certification costs: increased decreased remained unchanged 

Overall, this was a cost: increase decrease

Resin prices: increased decreased remained unchanged 

Resin usage: increased decreased remained unchanged 

Additive costs: increased decreased remained unchanged 

Post-press treatment costs: increased decreased remained unchanged 

Other material costs: increased decreased remained unchanged 

please specify:

Overall, this was a cost: increase decrease

d. Did any of the following material costs change directly as a result of changes made to achieve 

CARB Phase 1 certification (check appropriate boxes)? 

Please provide an estimate of how much recordkeeping, testing, and certification costs changed as a result of 

changes made to achieve CARB Phase 1 certification: 

 

Enter estimate for initial costs: $ or choose a range: 

 

Enter estimate for annual recurring costs: $ or choose a range: 

Please provide an estimate of how much material costs changed directly as a result of changes made to 

achieve CARB Phase 1 certification per thousand square feet of production on a 

 

Enter estimate: $ or provide a range: 

basis:

Please provide an estimate of how much operating costs changed directly as a result of changes made to 

achieve CARB Phase 1 certification per thousand square feet of production on a 

 

Enter estimate: $ or provide a range:

basis:
Copy #1 of Section III

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Check red box if response is confidential business information (CBI) 

18. (cont.) Estimated costs of changes to the production processes or raw materials.

j. Did your plant’s productivity, in terms of production per hour, change directly as a result of 

changes made to achieve CARB Phase 1 certification (check all that apply)? 

Yes, productivity increased

Yes, productivity decreased

No, productivity did not change as a result of changes made to achieve CARB Phase 1 certification.

please specify approximate percentage change:

please specify approximate percentage change:

g. Did product reject rates change directly as a result of changes made to achieve CARB Phase 1 

certification? If so, how much did the reject rate increase or decrease? (Please indicate change in 

reject rate, not the overall rate)

Yes, higher - reject rate increased: 

Yes, lower - reject rate decreased: 

No, reject rates did not change as a result of changes made to achieve CARB Phase 1 certification.

less than 5% 5% to 10% more than 10%

less than 5% 5% to 10% more than 10%

Please provide an estimate of how much your costs changed directly as a result of the change in reject rate 

per thousand square feet of production on a 

 

Enter estimate: $ or provide a range:

basis:

h. Please indicate the percentage of production that is rejected for exceeding the Phase 1 

emission levels: %

Please indicate what is done with panels rejected for exceeding the Phase 1 emission levels:

% Sold for domestic use outside of California

% Exported

% Burned for energy generation

% Reused as raw material

% Used or disposed of in some other way. Please describe:

Please provide an estimate of how much your costs changed directly as a result of the change in 

productivity per thousand square feet of production on a 

 

Enter estimate: $ or provide a range: 

basis:

i. Did your plant experience an initial period of adjustment, where efficiency was low, as you made 

changes to achieve CARB Phase 1 certification? For example, this may include test production runs.

Yes, adjustment period was experienced

No, no significant adjustment period was experienced

please specify approximate duration:

basis:

Please provide an estimate of how much your costs changed directly as a result of the initial adjustment 

period per thousand square feet of production on a 

 

Enter estimate: $ or provide a range: 
Copy #2 of Section III

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l. Did your plant incur any other recurring costs directly as a result of changes made to achieve CARB 

Phase 1 certification (check all that apply)? 

Yes:

No

m. OPTIONAL. Please use the space below to clarify or further explain any of your responses to Question 18.

Please describe the costs incurred:

per thousand square feet of production on a basis.

Please provide cost estimate: $

Check red box if response is confidential business information (CBI) 

18. (cont.) Estimated costs of changes to the production processes or raw materials.

or provide range:

k. Did your plant’s amount of downtime (i.e., periods of time during which production was stopped) change 

directly as a result of achieving CARB Phase 1 certification?

Yes, downtime increased

Yes, downtime decreased

No, downtime did not change as a result of changes made to achieve CARB Phase 1 certification.

please specify how much downtime changed:

please specify how much downtime changed:

Please provide an estimate of how much your costs changed directly as a result of the change in downtime: 

per thousand square feet of production on a 

 

Enter estimate: $ or provide a range:

basis:
Copy #1 of Section IV

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Check red box if response is confidential business information (CBI) 

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

Check all boxes that apply and fill in the applicable blanks.

a. Specify product for which there were changes to the production processes or raw materials used in order 

to achieve CARB Phase 2 certification:

Adhesive/Emissions Class:

IV. Changes to Achieve CARB Phase 2 Certification

Add Copy

Please complete Questions 19 through 21 if you have made changes to your production process or raw materials for 

the purpose of achieving CARB Phase 2 certification. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

A separate copy of Section IV needs to be completed for each pressed wood category where there were changes to 

achieve CARB Phase 2 certification. In addition, if you have made changes to more than one adhesive/emissions class 

within a pressed wood category, please complete a separate copy of Section IV for each adhesive/emissions class. 

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

technology, formaldehyde emission certification standard category, and/or formaldehyde emission profile. 

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

Section IV. If you are using the paper version of this form, please use the extra copies provided and make additional 

copies as necessary.

Please consider only the most recent major reduction in formaldehyde emissions 

you have made specifically to comply with CARB Phase 2 in your responses to 

Questions 19-21. 

For example, if you are a particleboard manufacturer who: 

1. Made changes to your adhesive system to meet the CPA EPP Grademark 

formaldehyde emission limit of 0.30 ppm, 

2. Then made additional changes to meet the revised CPA EPP Grademark 

formaldehyde emission limit of 0.20 ppm, 

3. Then made additional changes to meet the CARB Phase 1 formaldehyde 

emission limit of 0.18 ppm, 

4. Then made additional changes to meet the CARB Phase 2 formaldehyde 

emission limit of 0.09 ppm, 

Your responses should only reflect the changes you made to reduce your 

formaldehyde emissions from the 0.18 ppm limit to the 0.09 ppm limit to achieve 

CARB Phase 2 certification. If you made multiple changes to reduce your 

formaldehyde emissions from the 0.18 ppm to 0.09 ppm, report the sum of all of 

those changes.

Primary Pressed Wood Category:
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b. What were the changes to the resin system or production process? Please check all that apply.

19. (cont.) Changes to the production processes or raw materials to achieve CARB Phase 2 certification. 

Check all boxes that apply and fill in the applicable blanks.

Check red box if response is confidential business information (CBI) 

c. Please indicate the extent to which you have optimized your production process since making 

these changes:

Production Process Fully Optimized

Production Process Nearly Optimized

Production Process Partially Optimized

Production Process Not Optimized

e. OPTIONAL. Please use the space below to clarify or further explain any of your responses to Question 19.

d. Do you expect to incur additional costs associated with optimizing your process?

Yes: Please provide an estimate of the additional costs you expect to incur for process

No

20. Issues your plant addressed in order to achieve CARB Phase 2 certification.

a. Your plant needed to address issues associated with sticking or buildup on press platens.

b. Your plant needed to improve resin unloading, storage and handling system to deal with 

higher liquid viscosity, handle dry materials, and/or blend multiple components.

Lower ratio of formaldehyde to other resin component(s) (e.g., urea,

Please specify non-formaldehyde resin component:

Addition of or changes to catalysts in resins

Post-press treatment of panels

New resin system (for example, substituting melamine for urea)

Changes to application equipment

Changes to blending equipment

Changes to pressing or drying times

Changes to process controls

Changes to pressing or drying temperatures

Other Please specify:

melamine, phenol, etc.).

Addition of or changes to scavengers in resins

Addition of or changes to other additives in resins

optimization: $ or choose a range:
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Check red box if response is confidential business information (CBI) 

d. Your plant needed to address issues associated with resin tack, including:

Build-up in conveyers, bins, or mat formers

Mat integrity problems

Prepress tack

c. Your plant needed to upgrade blending or application equipment.

Please describe equipment change. For instance, “Installed two new metering pumps and flow 

meters to control ratios of resin components to a new inline mixer. Installed new programmable 

automation controllers on the blender and resin metering pumps and integrated into the mill’s 

visualization platform.”

e. Your plant needed to upgrade your press.

For the press that was upgraded, please describe what was done. For instance, “Converted 

the press from steam heat to thermal oil in order to achieve higher platen temperature and 

improve productivity with PF resin.” 

f. Your plant needed to resolve issues associated with not having enough cooling capacity to 

deal with master panels.

g. Your plant needed to resolve issues associated with out-of-press moisture content due to 

longer or hotter press times.

h. Industrial hygiene concerns (e.g., worker health) influenced your ability to use certain resin types.

i. Your plant needed to resolve issues associated with waste control.

Please explain:

20. (cont.) Issues your plant addressed in order to achieve CARB Phase 2 certification.

j. Your plant needed to address issues associated with limited excess drying capacity.

k. Your plant needed to modify your board coolers.

l. Your plant needed to add new wood burners to burn residuals that were previously recycled.
Copy #1 of Section IV

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21. Estimated costs of changes to the production processes or raw materials.

a. Did your plant incur research and development costs directly as a result of changes made to achieve 

CARB Phase 2 certification?

Yes:

No

b. Did your plant incur capital improvement costs directly as a result of changes made to achieve 

CARB Phase 2 certification (check all that apply)? 

Yes, capital expenditures for modifying existing equipment

Yes, capital expenditures for new equipment

No

c. Did your plant incur any other start-up or one-time costs directly as a result of changes made to 

achieve CARB Phase 2 certification? 

Yes:

No

Please describe the costs incurred:

20. (cont.) Issues your plant addressed in order to achieve CARB Phase 2 certification.

m. OPTIONAL. Please use the space below to describe other issues your plant addressed or to clarify or 

further explain any of your responses to Question 20.

Please provide cost estimate: $ or choose range:

Please provide a cost estimate for all capital improvements costs directly related to changes made to 

achieve CARB Phase 2 certification: 

 

Enter estimate: $ or choose a range:

Please provide cost estimate: $ or choose range:
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Check red box if response is confidential business information (CBI) 

21. (cont.) Estimated costs of changes to the production processes or raw materials.

e. Did any of the following operating costs change directly as a result of changes made to achieve CARB 

Phase 2 certification (check appropriate boxes)?

Labor costs: increased decreased remained unchanged 

Energy costs: increased decreased remained unchanged 

Other operating costs: increased decreased remained unchanged 

please specify:

Overall, this was a cost: increase decrease

f. Did any of the following recordkeeping, testing, or certification costs change as a result of changes made to 

achieve CARB Phase 2 certification (check appropriate boxes)? 

Recordkeeping costs: increased decreased remained unchanged 

Testing and certification costs: increased decreased remained unchanged 

Overall, this was a cost: increase decrease

d. Did any of the following material costs change directly as a result of changes made to achieve 

CARB Phase 2 certification (check appropriate boxes)? 

Resin prices: increased decreased remained unchanged 

Resin usage: increased decreased remained unchanged 

Additive costs: increased decreased remained unchanged 

Post-press treatment costs: increased decreased remained unchanged 

Other material costs: increased decreased remained unchanged 

please specify:

Please provide an estimate of how much material costs changed directly as a result of changes made to 

achieve CARB Phase 2 certification per thousand square feet of production on a 

 

Enter estimate: $ or provide a range: 

basis:

Overall, this was a cost: increase decrease

Please provide an estimate of how much operating costs changed directly as a result of changes made to 

achieve CARB Phase 2 certification per thousand square feet of production on a 

 

Enter estimate: $ or provide a range:

basis:

Please provide an estimate of how much recordkeeping, testing, and certification costs changed as a result of 

changes made to achieve CARB Phase 2 certification: 

 

Enter estimate for initial costs: $ or choose a range: 

 

Enter estimate for annual recurring costs: $ or choose a range: 
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Check red box if response is confidential business information (CBI) 

21. (cont.) Estimated costs of changes to the production processes or raw materials.

j. Did your plant’s productivity, in terms of production per hour, change directly as a result of 

changes made to achieve CARB Phase 2 certification (check all that apply)? 

Yes, productivity increased

Yes, productivity decreased

No, productivity did not change as a result of changes made to achieve CARB Phase 2 certification.

please specify approximate percentage change:

please specify approximate percentage change:

g. Did product reject rates change directly as a result of changes made to achieve CARB Phase 2 

certification? If so, how much did the reject rate increase or decrease? (Please indicate change in 

reject rate, not the overall rate)

Yes, higher - reject rate increased: 

Yes, lower - reject rate decreased: 

No, reject rates did not change as a result of changes made to achieve CARB Phase 1 certification.

less than 5% 5% to 10% more than 10%

less than 5% 5% to 10% more than 10%

Please provide an estimate of how much your costs changed directly as a result of the change in reject rate 

per thousand square feet of production on a 

 

Enter estimate: $ or provide a range:

basis:

h. Please indicate the percentage of production that is rejected for exceeding the Phase 2 

emission levels: %

Please indicate what is done with panels rejected for exceeding the Phase 2 emission levels:

% Sold for domestic use

% Exported

% Burned for energy generation

% Reused as raw material

% Used or disposed of in some other way. Please describe:

i. Did your plant experience an initial period of adjustment, where efficiency was low, as you made 

changes to achieve CARB Phase 2 certification? For example, this may include test production runs.

Yes, adjustment period was experienced

No, no significant adjustment period was experienced

please specify approximate duration:

Please provide an estimate of how much your costs changed directly as a result of the change in 

productivity per thousand square feet of production on a 

 

Enter estimate: $ or provide a range: 

basis:

basis:

Please provide an estimate of how much your costs changed directly as a result of the initial adjustment 

period per thousand square feet of production on a 

 

Enter estimate: $ or provide a range: 
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l. Did your plant incur any other recurring costs directly as a result of changes made to achieve CARB 

Phase 2 certification (check all that apply)? 

Yes:

No

m. OPTIONAL. Please use the space below to clarify or further explain any of your responses to Question 18.

Please describe the costs incurred:

per thousand square feet of production on a basis.

Please provide cost estimate: $ or provide range:

Check red box if response is confidential business information (CBI) 

21. (cont.) Estimated costs of changes to the production processes or raw materials.

k. Did your plant’s amount of downtime (i.e., periods of time during which production was stopped) change 

directly as a result of achieving CARB Phase 2 certification?

Yes, downtime increased

Yes, downtime decreased

No, downtime did not change as a result of changes made to achieve CARB Phase 2 certification.

please specify how much downtime changed:

please specify how much downtime changed:

Please provide an estimate of how much your costs changed directly as a result of the change in downtime: 

per thousand square feet of production on a 

 

Enter estimate: $ or provide a range:

basis:
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Please complete Questions 22 through 24 if you: 

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

Phase 2 certification, or 

2. If you have already achieved Phase 2 certification but you anticipate making additional changes to 

production processes or raw materials for the purpose of optimizing the production processes for your CARB 

Phase 2 compliant products, or 

3. If you have already achieved CARB Phase 2 certification but you anticipate making additional changes to 

production processes or raw materials for the purpose of achieving CARB Phase 2 ULEF or NAF certification. 

If you will need to address different issues to achieve CARB Phase 2 certification for different products in a pressed 

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

resin), please complete a separate copy of Section V for each group of products where similar issues will need to be 

addressed. You may choose to complete a separate copy of Section V for each adhesive/emissions class, complete 

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

Section V for an entire pressed wood category. 

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

considering more than one possible approach (e.g., both enhanced UF resins and soy-based resins), please use the 

approach you consider most likely as the basis for your responses in Section V. 

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

technology, formaldehyde emission certification standard category, and/or formaldehyde emission profile. 

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

Section V. If you are using the paper version of this form, please use the extra copies provided and make additional 

copies as necessary.

Check red box if response is confidential business information (CBI) 

22. Planned changes (through 2012) to the production processes or raw materials. 

Check all boxes that apply and fill in the applicable blanks.

a. Specify product for which there are planned changes (through 2012) to the production processes or 

raw materials used in order to achieve CARB Phase 2 certification, optimize your process, or achieve 

ULEF or NAF certification, using the Pressed Wood Categories from Question 9:

Add Copy

V. Planned Changes to Achieve CARB Phase 2 Certification

Adhesive/Emissions Class (if applicable):

Primary Pressed Wood Category:
Copy #1 of Section V

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b. What are the planned changes and changes that may be considered to the resin system or production 

process? Please check all appropriate boxes. (check N/A if not applicable)

Lower ratio of formaldehyde to other resin 

component(s) (e.g., urea, melamine, phenol, etc.)

planned may consider will not change N/A

please specify non-formaldehyde resin component:

Addition of or changes to scavengers in resins planned may consider will not change N/A

Post-press treatment of panels planned may consider will not change N/A

New resin system planned may consider will not change N/A

Changes to application equipment planned may consider will not change N/A

Changes to blending equipment planned may consider will not change N/A

Changes to process controls planned may consider will not change N/A

Changes to pressing or drying times planned may consider will not change N/A

Changes to pressing or drying temperatures planned may consider will not change N/A

Other planned may consider will not change N/A

please specify what will change:

Addition of or changes to catalysts in resins planned may consider will not change N/A

Addition of or changes to other additives planned may consider will not change N/A

Check red box if response is confidential business information (CBI) 

22. (cont.) Planned changes (through 2012) to the production processes or raw materials.

c. How firm are the planned changes for this pressed wood category and adhesive/emissions class?

Very Likely Somewhat Likely Somewhat Uncertain Very Uncertain

d. OPTIONAL. Please use the space below to clarify or further explain any of your responses to Question 22.
Copy #1 of Section V

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

certification, or optimize your production process.

a. Your plant will need to address issues associated with sticking or buildup on press platens.

Your plant will need to improve resin unloading, storage and handling system to deal with 

higher liquid viscosity, handle dry materials, and/or blend multiple components.

b. 

d. Your plant will need to address issues associated with resin tack, including:

Build-up in conveyers, bins, or mat formers

Mat integrity problems

Prepress tack

e. Your plant will need to upgrade your press.

For the press that will be upgraded, please describe what will be done. For instance, “Convert 

the press from steam heat to thermal oil in order to achieve higher platen temperature and 

improve productivity with PF resin.” 

f. Your plant will need to address issues associated with not having enough cooling capacity 

to deal with master panels.

g. Your plant will need to address issues associated with out-of-press moisture content due to 

longer or hotter press times.

c. Your plant will need to upgrade blending or application equipment.

Check red box if response is confidential business information (CBI) 

h. Industrial hygiene concerns (e.g., worker health) will influence your ability to use certain 

resin types.

i. Your plant will need to resolve issues associated with waste control.

Please describe the expected equipment change. For instance, “Install two new metering 

pumps and flow meters to control ratios of resin components to a new inline mixer. Install new 

programmable automation controllers on the blender and resin metering pumps and integrated 

into the mill’s visualization platform.”

Please explain:
Copy #1 of Section V

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Check red box if response is confidential business information (CBI) 

23. (cont.) Issues your plant is expected to address in order to achieve CARB Phase 2 certification, ULEF or 

NAF certification, or optimize your production process.

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

If you are uncertain about what future costs are likely to be, please provide your best estimate if 

possible. You may use the space provided in Question 24.l to describe uncertainties.

a. Does your plant expect to incur research and development costs directly related to changes to achieve 

CARB Phase 2 certification, ULEF or NAF certification, or optimize your production process?

Yes:

No

m. OPTIONAL. Please use the space below to describe other issues your plant is expected to address or to 

clarify or further explain any of your responses to Question 23.

j. Your plant will need to address issues associated with limited excess drying capacity.

k. Your plant will need to modify your board coolers.

l. Your plant will need to add new wood burners to burn residuals that were previously recycled.

c. Does your plant expect to incur any other start-up or one-time costs directly related to changes to 

achieve CARB Phase 2 certification, ULEF or NAF certification, or optimize your production process? 

Yes:

No

Please describe the expected costs:

b. Does your plant expect to incur capital improvement costs directly related to changes to achieve CARB 

Phase 2 certification, ULEF or NAF certification, or optimize your production process? (check all that apply)

Yes, capital expenditures for modifying existing equipment

Yes, capital expenditures for new equipment

No

Please provide cost estimate: $ or choose range:

Please provide a cost estimate for all capital improvements costs directly related to changes made to 

achieve CARB Phase 2 certification, ULEF or NAF certification, or optimize your production process: 

 

Enter estimate: $ or choose a range:

Please provide cost estimate: $ or choose range:
Copy #1 of Section V

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Check red box if response is confidential business information (CBI) 

24. (cont.) Estimated costs of planned changes to the production processes or raw materials. 

d. Does your plant expect any of the following material costs to change directly as a result of changes to 

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

(check appropriate boxes)?

Resin prices expected to: increase decrease remain unchanged 

Resin usage expected to: increase decrease remain unchanged 

Additive costs expected to: increase decrease remain unchanged 

Post-press treatment costs expected to: increase decrease remain unchanged 

Other material costs expected to: increase decrease remain unchanged 

please specify:

Overall, this is an expected cost: increase decrease

e. Are any of the following operating costs expected to change directly as a result of changes to achieve 

CARB Phase 2 certification, ULEF or NAF certification, or optimize your production process 

(check appropriate boxes)? 

Labor costs expected to: increase decrease remain unchanged 

Energy costs expected to: increase decrease remain unchanged 

Other operating costs expected to: increase decrease remain unchanged 

please specify:

Overall, this is an expected cost: increase decrease

f. Are any of the following recordkeeping, testing, or certification costs expected to change as a result of 

changes to achieve CARB Phase 2 certification, ULEF or NAF certification, or optimize your production 

process (check appropriate boxes)?

Recordkeeping costs expected to: increase decrease remain unchanged 

Testing & certification costs expected to: increase decrease remain unchanged 

Overall, this is an expected cost: increase decrease

Please provide a cost estimate for all material costs directly related to changes made to achieve CARB Phase 

2 certification, ULEF or NAF certification, or optimize your production process per thousand square feet of 

production on a 

 

Enter estimate: $ or provide a range: 

basis:

Please provide a cost estimate for all operating costs directly related to changes made to achieve CARB 

Phase 2 certification, ULEF or NAF certification, or optimize your production process per thousand square 

feet of production on a 

 

Enter estimate: $ or provide a range:

basis:

Please provide a cost estimate of recordkeeping, testing, and certification costs directly related to changes made to 

achieve CARB Phase 2 certification, ULEF or NAF certification, or optimize your production process: 

 

Enter estimate for initial costs: $ or choose a range: 

 

Enter estimate for annual recurring costs: $ or choose a range: 
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24. (cont.) Estimated costs of planned changes to the production processes or raw materials. 

Check red box if response is confidential business information (CBI) 

h. Please indicate the percentage of production expected to be rejected for exceeding the Phase 2 

emission levels: %

Please indicate what you expect to do with panels rejected for exceeding the Phase 2 emission levels:

% Sell for domestic use outside of California

% Export

% Burn for energy generation

% Reuse as raw material

% Use or dispose of in some other way. Please describe:

g. Are product reject rates expected to change directly as a result of changes to achieve CARB Phase 2 

certification, ULEF or NAF certification, or optimize your production process? If so, how much are the 

reject rates expected to increase or decrease? 

(Please indicate change in reject rate, not the overall rate)

No, reject rates are not expected to change as a result of changes to achieve CARB Phase 2

Yes, lower - expected to decrease: 

Yes, higher - expected to increase: less than 5% 5% to 10% more than 10%

less than 5% 5% to 10% more than 10%

certification, ULEF or NAF certification, or optimize your production process.

j. Is your plant’s productivity, in terms of production per hour, expected to change directly as a result 

of changes to achieve CARB Phase 2 certification, ULEF or NAF certification, or optimize your 

production process? 

Yes, productivity is expected to increase.

Yes, productivity is expected to decrease.

No, productivity is not expected to change as a result of changes to achieve CARB Phase 2

Please specify approximate percentage change:

Please specify approximate percentage change:

certification, ULEF or NAF certification, or optimize your production process.

Please provide an estimate of how much your costs would change directly as a result of the change in reject 

rate per thousand square feet of production on a 

 

Enter estimate: $ or provide a range:

basis:

i. Does your plant expect to experience an initial period of adjustment, where efficiency will be low, 

as it makes changes to achieve CARB Phase 2 certification, ULEF or NAF certification, or optimize 

your production process? For example, this may include test production runs.

Yes, adjustment period is expected

No, no significant adjustment period is expected

please specify approximate duration:

basis:

Please provide an estimate of how much your costs would change directly as a result of the initial 

adjustment period per thousand square feet of production on a 

 

Enter estimate: $ or provide a range: 

Please provide an estimate of how much your costs would change directly as a result of the change in 

productivity per thousand square feet of production on a 

 

Enter estimate: $ or provide a range: 

basis:
Copy #1 of Section V

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24. (cont.) Estimated costs of planned changes to the production processes or raw materials. 

Check red box if response is confidential business information (CBI) 

m. OPTIONAL. Please use the space below to clarify or further explain any of your responses to Question 24.

k. Is your plant’s amount of downtime (i.e. periods of time during which production is stopped) expected 

to change directly as a result of changes to achieve CARB Phase 2 certification, ULEF or NAF 

certification, or optimize your production process?

Yes, downtime is expected to increase.

Yes, downtime is expected to decrease.

No, downtime is not expected to change as a result of changes to achieve CARB Phase 2

Please specify expected change: 

Please specify expected change:

l. Does your plant expect to incur any other recurring costs directly as a result of changes to achieve 

CARB Phase 2 certification, ULEF or NAF certification, or optimize your production process?

Yes:

No

Please describe the expected costs:

certification, ULEF or NAF certification, or optimize your production process.

Please provide an estimate of how much your costs would change directly as a result of the change in 

downtime per thousand square feet of production on a 

 

Enter estimate: $ or provide a range:

basis:

per thousand square feet of production on a basis.

Please provide cost estimate: $ or provide range:
Copy #1 of Section VI

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VI. Issues That May Affect Ability to Reduce Formaldehyde Emissions 

for Respondents Who Do Not Intend to Become CARB Phase 2 

Certified

If you manufacture a product that you do not have certified under CARB Phase 2, because your product qualifies for 

an exemption under the CARB ATCM (it will be sold and used outside of California, or used in manufactured homes 

subject to HUD regulations) or because it does not meet the CARB ATCM definitions of hardwood plywood, medium 

density fiberboard, or particleboard, please complete Question 25. 

If you would need to address different issues to achieve CARB Phase 2 certification for different products in a pressed 

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

please complete a separate copy of Question 25 for each group of products where similar issues would need to be 

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

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

Question 25 for an entire pressed wood category. 

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

Section VI. If you are using the paper version of this form, please use the extra copies provided and make additional 

copies as necessary. 

Add Copy

a. Please specify the Primary Pressed Wood Category, using the Pressed Wood Categories from Question 9:

25. Issues your plant would need to address in order to adopt a lower emission technology 

to meet CARB Phase 2 formaldehyde emission levels.

Check red box if response is confidential business information (CBI) 

b. Please explain why you do not intend to become CARB Phase 2 certified:

c. What is the most likely resin/binder you would use if you were to become CARB Phase 2 certified?

d. Your plant would need to address issues associated with sticking or buildup on press platens.

Your plant would need to improve resin unloading, storage and handling system to deal 

with higher liquid viscosity, handle dry materials, and/or blend multiple components.

e.

Your plant would need to upgrade blending or application equipment. f.

Please describe the equipment changes expected to be necessary. For instance, “Install 

two new metering pumps and flow meters to control ratios of resin components to a new inline 

mixer. Install new programmable automation controllers on the blender and resin metering 

pumps and integrated into the mill’s visualization platform.”
Copy #2 of Section VI

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25. (cont.) Issues your plant would need to address in order to adopt a lower emission 

technology to meet CARB Phase 2 formaldehyde emission levels.

Check red box if response is confidential business information (CBI) 

g. Your plant would need to address issues associated with resin tack, including:

Build-up in conveyers, bins, or mat formers

Mat integrity problems

Prepress tack

h. Your plant would need to upgrade your press.

For the press that would need to be upgraded, please describe what would be done. For 

instance, “Convert the press from steam heat to thermal oil in order to achieve higher platen 

temperature with PF resin.” 

Your plant’s press is a bottleneck (no excess press capacity), so you would have to address 

or accept lower productivity because of slower curing resins.

i.

j. Your plant would have to address or accept lower productivity because of other reasons.

Please explain:

Your plant would need to resolve issues associated with not having enough cooling 

capacity to deal with master panels.

k.

l. Your plant would need to resolve issues associated with out-of-press moisture content due 

to longer or hotter press times.

m. Industrial hygiene concerns (e.g., worker health) would influence your ability to use certain 

resin types.

n. Your plant would need to resolve issues associated with waste control.

Please explain:
Copy #2 of Section VI

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25. (cont.) Issues your plant would need to address in order to adopt a lower emission 

technology to meet CARB Phase 2 formaldehyde emission levels.

Check red box if response is confidential business information (CBI) 

r. OPTIONAL. Please use the space below to describe other issues your plant would need to address or to 

clarify or further explain any of your responses to Question 25.

o. Your plant would need to address issues associated with limited excess drying capacity.

p. Your plant would need to modify your board coolers.

q. Your plant would need to add new wood burners to burn residuals that were previously recycled.
Copy #1 of Section VII

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VII. Issues That May Affect Ability to Use a No-Added Formaldehyde 

(NAF) Resin

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

plant, with the following exceptions: 

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

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

production process or raw materials reported in Questions 22 - 24. 

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

(for example, MDF and thin MDF, or products made with UF resin and products made with MF resin), please 

complete a separate copy of Question 26 for each group of products where similar issues would need to be 

addressed. You may choose to complete a separate copy of Question 26 for each adhesive/emissions class, 

complete a separate copy of Question 26 for a group of adhesive/emissions classes, or simply complete a separate 

copy of Question 26 for an entire pressed wood category. 

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

Section VII. If you are using the paper version of this form, please use the extra copies provided and make additional 

copies as necessary.

Add Copy

26. Issues your plant would need to address in order to use a no-added formaldehyde (NAF) 

resin technology.

Check red box if response is confidential business information (CBI) 

b. Your plant would need to address issues associated with sticking or buildup on press platens.

Your plant would need to improve resin unloading, storage and handling system to deal 

with higher liquid viscosity, handle dry materials, and/or blend multiple components.

c. 

d. Your plant would need to upgrade blending or application equipment.

Please describe the equipment changes expected to be necessary. For instance, “Install 

two new metering pumps and flow meters to control ratios of resin components to a new inline 

mixer. Install new programmable automation controllers on the blender and resin metering 

pumps and integrated into the mill’s visualization platform.”

e. Your plant would need to resolve issues associated with resin tack, including:

Build-up in conveyers, bins, or mat formers

Mat integrity problems

Prepress tack

a. Please specify the Primary Pressed Wood Category, using the Pressed Wood Categories from Question 9:
Copy #1 of Section VII

Page 37 of 39

OMB Control No. 2070-0177 

Approval Expires 03/31/2013

26. (cont.) Issues your plant would need to address in order to adopt a no-added 

formaldehyde (NAF) resin technology.

Check red box if response is confidential business information (CBI) 

Your plant’s press is a bottleneck (no excess press capacity), so you would have to address 

or accept lower productivity because of slower curing resins.

g. 

h. Your plant would have to address or accept lower productivity because of other reasons.

Please explain:

Your plant would need to resolve issues associated with not having enough cooling 

capacity to deal with master panels.

i. 

j. Your plant would need to resolve issues associated with out-of-press moisture content due 

to longer or hotter press times.

k. Industrial hygiene concerns (e.g., worker health) would influence your ability to use certain 

resin types.

l. Your plant would need to resolve issues associated with waste control.

Please explain:

p. OPTIONAL. Please use the space below to describe other issues your plant would need to address or to 

clarify or further explain any of your responses to Question 26.

m. Your plant would need to address issues associated with limited excess drying capacity.

n. Your plant would need to modify your board coolers.

o. Your plant would need to add new wood burners to burn residuals that were previously recycled.

For the press that would need to be upgraded, please describe what would be done. 

f. Your plant would need to upgrade your press.
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OMB Control No. 2070-0177 

Approval Expires 03/31/2013

VIII. Secondary Products Manufactured

CBI*

Secondary 

Pressed Wood 

Product Category 

 

 

(Column 1)

Check if 

manufactured 

at your plant. 

 

 

(Column 2)

Please use the codes listed below to 

specify the resin/binder currently 

used in the secondary 

manufacturing process1

 (include resins in saturated paper) 

(Column 3) 

Please use the codes listed below 

to specify the primary pressed 

wood product(s) used in this 

production 2

 

(Column 4) 

Example: 

Vinyl Laminate 

Resin or Binder Used:

(1) UF, (2) PVA

Primary Pressed Wood Product(s) Used:

(1) PB, (2) MDF

Example: 

Low Pressure Decorative 

Laminates (LPDL) 

Resin or Binder Used:

UF, MF

Primary Pressed Wood Product(s) Used:

PB

a. Filled or Coated Products 

Resin or Binder Used: Primary Pressed Wood Product(s) Used:

b. High Pressure Laminates 

(HPL)

Resin or Binder Used: Primary Pressed Wood Product(s) Used:

c. Hot Stamp Foils

Resin or Binder Used: Primary Pressed Wood Product(s) Used:

d. Low Basis Weight Papers 

(LBWP)

Resin or Binder Used: Primary Pressed Wood Product(s) Used:

e. Low Pressure Decorative 

Laminates (LPDL)

Resin or Binder Used: Primary Pressed Wood Product(s) Used:

f. Medium and High Density 

Overlays (MDO and HDO) 

Resin or Binder Used: Primary Pressed Wood Product(s) Used:

g. Vinyl Laminate

Resin or Binder Used: Primary Pressed Wood Product(s) Used:

h. Other. Please specify: Resin or Binder Used: Primary Pressed Wood Product(s) Used:

* Check red box if response is confidential business information (CBI) 

27. Resins and Binders for Secondary Pressed Wood Products Manufactured. 

If you use different resins or binders for different products within a secondary pressed wood product category, 

number each product separately. If you use more than one resin or binder for a single product, separate each resin/

binder with a comma. For example, if you manufacture two types of vinyl laminates, one product with a UF resin and 

another product with a PVA resin, you should report “(1) UF, (2) PVA” in column 3. If you manufacture a low pressure 

decorative laminate that uses a blend of UF and MF resins you should report “UF,MF” in column 3. Similarly, if one 

product is made with particleboard and a second is made with medium density fiberboard, you should report: 

“(1) PB, (2) MDF” in column 4 (see examples below). 

1. Binder/Resin Categories: 2. Primary Pressed Wood Categories:

CNSL Cashew Nut Shell Liquid 

MF Melamine-formaldehyde 

MUF Melamine-urea-formaldehyde

MDI Methlylene Diisocyanate

pMDI Polymeric Diphenylmethane Diisocyanate

PF Phenol-formaldehyde 

PF-MDI Phenol-formaldehyde-MDI 

PMUF-MDI Phenol-melamine-urea-formaldehyde-MDI

PUF-MDI Phenol-urea-formaldehyde-MDI

PUFT Phenol-urea-formaldehyde-Tannin

PVA Polyvinyl Acetate 

SBR Soy-based resins 

TBR Tannin-based resins 

UF Urea-formaldehyde 

O Other: Please Describe

+s addition of scavenger to resin (for 

example, "MF+s")

+c addition of catalysts to resin 

+a addition of other additives to resin

GLB Glulam beams

HB Hardboard

HWPW Hardwood Plywood

LVL Laminated Veneer Lumber

MDF Medium Density Fiberboard 

OSL Oriented Strand Lumber

OSB Oriented Strandboard

PB Particleboard 

SWPW Softwood Plywood
Page 39 of 39

OMB Control No. 2070-0177 

Approval Expires 03/31/2013

THE END 

Thank you. Please see the sheet labeled Instructions for 

Returning the Completed Questionnaire to EPA for directions 

on how to return this questionnaire to EPA.