# Comments of the Hardwood Plywood

and Veneer Association (HPVA) submitted to the Environmental Protection Agency (EPA) on the Advanced Notice of Proposed Rulemaking (ANPR) for formaldehyde from certain wood products: EPA

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Submitted by: Kip H owlett

, President

- HPVA 3/19/2009HPVA Comments to EPA

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## Comments and Analysis of EPA ’s ANPR for National Product Emission Standards for Formaldehyde from Certain Wood Products

Background : EPA has published an Advance Notice of Proposed Rulemaking i n response to a petition filed by the Sierra Club and 25 other organizations to have the California Air Resources Board ( CARB ) formaldehyde emission limits on composite wood products become national standards. The authority that the Sierra Club petitions t he EPA to use is under the Toxic Substances Control Act (TSCA). HPVA submitted comments to EPA in response to that petition.

Discussion: EPA requests specific information as part of this notice, asks for views on the legal authority it should utilize, rais es questions about the health effects of formaldehyde and announces that the National Academy of Sciences will conduct a review, and sets out schedule for regional h e arings over the next two months. The following are the w ritten comments of the Hardwood Pl ywood and Veneer Association (HPVA) on this ANPR. HPVA also testif ied at the public hearing in Washington DC.

Introduction: HPVA represents manufacturers in the U.S. and Canada who produce hardwood plywood (HWPW), hardwo od veneer (V), and engineered hardw ood flooring (EWF)

. HPVA only represents companies who manufacture in North America. In the HWPW and EWF sectors, HPVA represents more than 90% of the North American production capacity. However, over the last 10 years, over 60% of U.S. HWPW domestic prod uction capacity has been permanently shut down. 1 Moreover, at the present time because of the recession, operating rates are at 50% of this current, reduced US capacity. Imports now account for an estimated 80% of the U.S. market and China now takes about a 55% market share of those imports. 2

HPVA is also a standards organization under the American National Standards Institute ( ANSI ) and has promulgated two national consensus sta n dards for products that a re subject to this rulemaking: hardwood plywood (ANS I/HPVA HP

- 1

- 2004) and engineered wood flooring (ANSI/HPVA EF

- 2002).

HPVA is a lso certified by the International Accreditation Service ( IAS ) for product certification (ISO 65), for our laboratory (ISO/IEC 17020) , and for spe c ific testing (ISO/IEC 17025) such as formaldehyde (ASTM E1333 and ASTM D 5582) and fire (ASTM E 84, ASTM E 662, ASTM E 648, ASTM E 162, and ASTM D 3675)

. HPVA is also a T hird P arty C ertification organization recognized by C alifornia (TPC

- 8) . HPVA has been a certifier of HWPW used in manufacturedHPVA Comments to EPA

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3 housing under the U.S. H ousing and U rban D evelopment (HUD) formaldehyde emissions program since its inception. HPVA has over 25 years of formaldehyde certification experience. HUD has the only national formaldehyde emission standard for these products but is mandatory only for manufactured housing. It is used voluntarily in other applications when the HWPW bears the ANSI/HPVA HP

- 1 st a mp which currently specifies HUD emission limits and is being revised now to incorporate CARB emission limits for HWP W.
HPVA supports the CARB emission limits for HWPW and EWF becoming national standards.

The CARB emission standards are basically de facto national standards now as currently 75% and soon over 90% of North American HWPW manufacturing production will be CA RB certified. The same is true for EWF as well. ANSI/HPVA HP

- 1 and ANSI/HPVA EF voluntary national consensus standards are being revised now to incorporate those limits and will go out for canvas shortly. These standards are common reference standards for significant segments of the market: home building (NAHB Green Building Standard) , kitchen cabinets ( KCMA’s Environmental Stewardship Program) , and other environmentally preferable programs in downstream market segments

. HWPW is a specialty product not a c ommodity product. HWPW is a very heterogeneous product

. HWPW is manufactured with different species of real wood veneer faces, primarily HW species but SW decorative species as well. These differences are measured by significant ranges of physical properti es as measured by specific gravity, weight, hardness, modulus of rupture, and modulus of elasticity. HWPW is made u sing a wide variety of cores, including veneer core ( VC ) with varying numbers of plies ( about 6 5 %), particleboard ( PB ) ( about 12%) , medium den sity fiberboard ( MDF ) (about 20%) , Combination Cores ( veneers and thin MDF for example ) , and lumber core (< 1 %). Prefinished HWPW has about 85% VC. HWPW comes in a wide variety of thicknesses and performance properties. The k ey point is that the HWPW emissio n standards are the same irrespective of this wide variability in cores and physical properties

. By contrast, more homogeneous wood products include raw PB, raw MDF, construction grade plywood (PW

- PS 1 &2) ) or oriented strand board (OSB), hardwood (HW) pulp, or softwood (SW) pulp.
HWPW and EWF are interior, decorative products used in the manufacture of cabinets, furniture, fixtures, floors and architectural products. As the attached Hardwood Plywood H a ndbook and Veneer Species Guide demonstrate, the co mbinations of product cores, dimensions, and species provide a remarkable variety of aesthetic and physical performanceHPVA Comments to EPA

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4 properties. Softwood plywood and OSB are not substitute materials. They are structural construction materials and not aesthetically att ractive, decorative interior panel products. (See pages 12

- 20 of the Handbook )
HWPW has the lowest emission standards of any of the regulated products. ( See Table 1 for Comparison s of the CARB Emission Values )

Table 1 CARB Regulation

– Limits (Ceiling) ppm
Phase 1 and 2 Emission Standards for Hardwood Plywood (HWPW), Particleboard (PB), and Medium Density Fiberboard (MDF) 1

Effective Date --- Phase 1 (P1) and 2 (P2) Emission Standards (ppm)

---

HWPW

- VC HWPW

- CC PB MDF Thin MDF

1

- 1

- 2009 P1: 0.08

---------- P1: 0.18 P1: 0.21 P1: 0.21

7

- 1

- 2009

---------- P1: 0.08

--------- ---------- ---------

1

- 1

- 2010 P2: 0.05

1

- 1

- 2011

----------- ----------- P2: 0.09 P2: 0.11

-----------

1

- 1

- 2012

----------- ----------- ----------- ------------ P2: 0.13

7

- 1

- 2012

----------- P2: 0.05

---------- ----------- ----------
ULEF Target 0.04 0.04 0.05 0.06 0.08

ULEF Cap 0.05 0.05 0.08 0.09 0.11

NAF Target 0.04 0.04 0.04 0.04 0.04

NAF Cap 0.05 0.05 0 .06 0.06 0.06

(1) Based on the large chamber test Method (ASTM E1333

- 96) in parts per million (ppm). HWPW

- VC = veneer core; HWPW

- CC = composite core, where the core material is PB or MDF

On Jan. 1, 2010, there will be two standards in effect for HWPW

- V C: 0.05 ppm for standard product and 0.04 ppm for exempt product. Exempt HWPW product cannot have a test result that exceeds 0.05pmm and 90% must be 0.04 ppm or lower. Exempt products use no addedHPVA Comments to EPA

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5 formaldehyde (NAF), no added urea formaldehyde (NAUF), or u ltra

- low emitting formaldehyde (ULEF) resin systems.
On July 1, 2010, there will two standards in effect for HWPW

- CC: 0.05 ppm for standard product and 0.04 ppm for exempt product. Exempt product cannot have a test value that exceeds 0.05 ppm and 90% mus t be 0.04 ppm or lower.
All HWPW irrespective of the core used, the thickness, and the wood species used in its construction will be required to meet on July 1, 2010, the 0.05 ppm limit for standard product and 0.04 ppm for exempt product. The difference in these values is the narrowest of any of the regulated products. As we will discuss in a later section of these comments, in the actual conditions of typical use, the ambient indoor measurements will be far lower than these compliance testing concentrati ons due to the higher loading rates in the tests used. Actual ambient levels will be predicted to be virtually background based on indoor air quality surveys conducted by EPA, HUD, CPSC, and CARB.
There is a wide variety of resin systems in use to meet th ese standards ranging from soy based, polyvinyl acetate ( PVA ) , and phenol formaldehyde ( PF ) to modified urea formaldehyde ( U LE F ) and other systems

.
Dried r esins are 2

. 0

- 3 .0 % of HWPW (VC) by weight compared to PB and MDF which will be 9

- 12% by weight. Costs and technic al application issues will vary by plant depending on the type and age of the equipment.
As a TPC we are observing success in achieving compliance with the CARB emission limits utilizing a range of different technologies. Another concern will be meeting o ther product physical performance requirements that are required to meet Building Code and other mandated performance properties. These requirements can include glue bond and fire performance.
Resin use can also impact the performance of environmental con trol equipment. In order to insure compliance with environmental operating permits, those operating parameters also have to be considered.
The key point is that changing resin systems varies by plant, equipment, product mix, markets served, and a variety o f other factors. Conversion of resin systems includes both capital and increased operating costs. Changing resin systems can also affect plant productivity if resin press time cycles are slowed which also results in increased costs with conversion. This ch ange is not a simple task.HPVA Comments to EPA

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6 Finally, wood wastes are typically used for fuel and energy generation in these plants, and resins systems can affect the operation of these boilers. With the national energy policy emphasis on increasing the use of renewable, bi o

- energy fuels, this industry has relied on these wood wastes as a backbone of their manufacturing processes for decades

. EPA requests information about specific properties of various resins, their costs, and impacts on the various resin systems on the wor kplace and the environment, we recommend that resin suppliers are in the best position to provide that type of information to EPA as some of it would be classified as confidential business information.
The CARB emission limits for HWPW should apply univer sally to all HWPW products.

The CARB standard has a very significant flaw in that it contains different definitions for the identical product (HWPW) in order to bifurcate the regulatory compliance solely on the basis of the kind of manufacturer who are bo th making HWPW but one is classified as a manufacturer and the other a “fabricator”. For one class of manufacturers the emission limits apply, but for the other class a giant loophole has been created. See Appendix A.
The emission standards must apply to any and all HWPW irrespective of who manufactures the HWPW. CARB arbitrarily differentiates between a primary HWPW manufacturer and a “fabricator” who also manufactures HWPW but is exempt from having to certify the HWPW they manufacture.

HWPW is manufactu red by laying up the veneers including the decorative face and back

veneers and pressing them to make the sheet of HWPW. A second method is pressing the face and back onto a VC , PB, MDF, or combination platform . Both methods are used in the production of HWPW and EWF. “Fabricators” can and do the very same thing. Both processes are indistinguishable between manufacturers and fabricators.
The application of a paper, foil, plastic, paint, finish or lacquer to a core , typically PB or MDF, is
not the manufactur e of HWPW or EWF. In the common nomenclature of commerce, this product is described as a laminated panel. These products are not covered by the CARB rule. Only the application of a wood or woody grass veneer to the face and back makes a panel HWPW.

Veneer cores are the most common cores used to manufacture HWPW

. A v eneer c ore is not hardwood plywood because it does not have ANSI/HPVA HP

- 1 decorative face and back grade

veneer s . Veneer core is a component (component) of HWPW but only b e comes HWPW afterHPVA Comments to EPA

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7 the face and back veneers are applied. CARB has no formaldehy de emission requirement for a stand alone “veneer (plywood) core” (VC) platforms.

Because there is no corresponding emission standard for a VC platform , if a “fabricator” uses a VC to apply a face veneer, the “fabricator” cannot produce a CARB certification for that pl atform. If a VC platform producer voluntarily agrees to meet a CARB certification limit and some domestic platform producers do provide that certification, what is the applicable limit

– HWPW, PB, or MDF?
A “fabricator” has no obligation to certify if the y apply face and back veneers to a VC core, certified PB or certified MDF core that the finished HWPW product meets the CARB HWPW emission standard.
Our experience as a TPC clearly demonstrates that HWPW products manufactured by participants in our program who use VC platforms need to utilize platforms that conform or closely conform to the HWPW emission standards to insure that the final HWPW product also conforms to those require me nts. The ANSI/HPVA HP

- 1 revision addresses th i s concern by

re commending tha t every imported lot of VC platforms be QC tested before it is used for production of HWPW. In HPVA’s TPC program, we require that imported platforms be identified and certified as a separate product line.
The resin systems used to apply the face and back decorative veneers and the veneers themselves must combine to reduce the emissions of CARB compliant PB and MDF by 45 to 67% in order to meet the emission standard for HWPW when a “manufacturer” produces the HWPW. This is not the requirement for a “fabrica tor” who makes the same end product. A manufacturer, whether they lay up all the veneers or apply a face and back to a purchased veneer core, PB or MDF core would have to meet the applicable HWPW emission standards. A fabricator applying a face veneer to a veneer core would have no standard to meet and a PB or MDF core product would not have to meet the substantial emission reduction requirements applicable if they were a HWPW

- VC manufacturer. In fact, the emissions could actually increase because CARB has in effect exempted the “glue line” that a fabricator uses to apply the face veneers which could have high emission characteristics.
If all the emission values were identical for all the products used to manufacture HWPW, then this would be less of an issue . As seen above in Table 1, emission requirements vary considerably. Even if the values were the same, exempting a type of manufacturer, i.e. fabricator, exempts the surface glue line from regulatory scrutiny. For a manufacturer, that glueHPVA Comments to EPA

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8 line is regulate d. This is a loophole. EPA needs to address and close this loophole in the federal rulemaking process.
The critical problem is the need to reduce CARB approved emissions for PB and MDF when they are used as a core in HWPW and for VC which has no mandatory emission limit to all meet the HWPW limits. 1 In all three (3) cases, a single emission value must be met at the end of any of these combination of processes to have a CARB certified HWPW product.
There is also a very significant enforcement issue here as well. A “fabricator” can have “certified” PB or MDF for their core panels, but the face and back veneers would have to be removed in the finished HWPW product to re

- test the cores for CARB compliance. The adhesives used and the process of removing the face and back can both change the emission characteristics of the core and make verification of compliance very difficult if not impossible to ascertain. The emission contributions of the adhesive lines used in the manufacture for the face and back veneers are exempt under the CARB rule. In effe ct, those adhesives can legally adulterate the core. CARB had committed but has yet to complete research to determine if this technical question could result in this aspect of their rule being practically unenforceable. HPVA is collaborating with Penn Stat e University to address this hypothesis.
Moreover, will the consumer be able to differentiate between HWPW that is manufactured and therefore fully certified and that which is laminated by the “ fabricator ” and not fully certified? Would that information affect consumer choice if they had full knowledge of the definitions of the products in Appendix A that helped them make that decision? Appendix A is not consumer friendly prose.
To summarize, this exemption creates a two tiered system: HWPW made by a “manufacturer” must be th ird party certified to meet the most stringent of the product emission standards and be certified to reduce otherwise CARB compliant core when they are used to the more stringent HWPW values. On the other hand, if you manufacture HWPW but are a “fabricato r”, CARB has for this group of HWPW “manufacturers” exempted the glue lines used to apply the face and backs to the core and exempted the significant emission reduction requirement in the final product from the HWPW standard.

The CARB rule has intended a nd clearly permits this dual product classification. CARB requires HWPW with certified low emissions but also allows other HWPW products with emissions that are both unknown and un

- certified

. T h is CARB rule flaw must not b e replicated or adopted in any federal emission standard for these products

.HPVA Comments to EPA

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9 This exemption is a giant loophole. It particularly advantage ou s for off

- shore producers who escape the higher operating costs associated with the new resin systems, certification and
t esting compliance costs, and record keeping that is difficult to audit and enforce. Given the dismal state of the domestic US economy, low price point products have a decided advantage. Without insuring a level playing field, non

- compliant, cheaper product s will likely further erode the domestic production share of the US market costing the US economy jobs and value added taxable profits of domestic producers. This is not a non

- tariff trade barrier but a consistent, equally applied science based standard fo r product performance and safety that conforms to World Trade Organization (WTO) requirements

. This is a product standard. Because it achieves specified safety and health performance characteristics, this standard must universally apply to all HWPW produc ts irrespective of who produces it, irrespective of where it is made, and irrespective of the type of core used to manufacture HWPW. The CARB emission standards for HWPW must be the same for anyone who makes HWPW. Moreover, the emission limits for HWPW are the lowest of any of the regulated composite wood products.
This exemption results in inconsistent product performance for otherwise identical products subject to a product safety standard. This exemption creates a huge economic advantage for “fabricator manufacturers” who avoid the costs of compliance and are located off shore Furniture imports and a growing share of kitchen cabinets for assembly comprise major segments of the U.S. market and represent direct imports of HWPW as components.
Imports of HWP W should meet US performance standards and only a federal rule can achieve this leveling of the playing field.

The U

. S . HWPW market has been witness to increasing market share taken by imports, primarily by Chinese manufacturers, on a volume basis (near 8 0%) and a value basis (over 65%). See attached Table 2 . U.S. capacity has been shut down permanently or idled as a result.
In a recent study by the ITC 332 Study (copy attached) , t he ITC identities many of the factors that give Chinese products their cost ad vantage and mentions the costs of meeting new more stringent formaldehyde standards but does not specifically quantify those factors.
Imported HWPW accounts for over 6 5 % of the US HWPW market which is estimated to be about $2.4 billion. Because imported panels are of lower unit value than domestically produced panels, the market share of imported products may actually be 70

- 75% of the North American market. Because the import codes which sometimes group non

- homogenous products under the same code, exact f igures for the products of interest in this ANPR are difficult to determine.HPVA Comments to EPA

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10 Imports are a major factor for US consumers who would be protected by this rule. An enforceable federal standard will help to insure both consumer protection and a level playing f ield for producers.

The recent report on these imports by the International Trade Commission

- USITC Publication 4032 (August, 2008), Wood Flooring and Hardwood Plywood: Competitive Conditions Affecting the U.S. Industries focuses on several factors that have favored Chinese manufacturers. A copy is provided for the record.
The ITC identities many of the factors that give Chinese product manufacturers their cost advantage and mentions the costs of meeting new, more stringent formaldehyde standards as one of these. The report does not specifically quantify the economic value of those advantages. The hardwood industry is working with Congress to continue this investigation as the recent economic downturn has resulted in reported backsliding recently of some of the key reforms to address these issues. 2 HWPW is an important component in furniture and with most of that capacity in China and Southeast Asia that supplies the US market, the “fabricator” exemption allows HWPW from those manufacturers to come in basically unregulated. Increasing market penetration by kitchen cabinet manufacturers off shore is also occurring. This is the second, most important end use for HWPW.
Imports are a major factor for US consumers who would be protected by this rule. An enforceable federal standard will help to insure both consumer protection and a level playing field for producers.

A rule under the Toxic Substances Control Act with its international enforcement provisions provides an assurance that all HWPW irrespective of country of origin, domestically or foreign produced, will have the same formaldehyde performance characteristics. Absent a federal rule, imports with cost advantages will have a marked pricing advantage and in these hard economic times increase their market share. Meanwhile the U.S. has a piecemeal, non

- federal, import unenforceable approach, while the technology exists and domestic industry has made the commitment to utilize this new generation of technologies. As a TPC, we can certify that it is rapi dly being employed in North America. As a TPC, we can also state that we observe higher failure rates from off shore producers with some foreign suppliers significantly higher than allowable U.S. limits whether CARB or even HUD and their own domestic emiss ion standards.HPVA Comments to EPA

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11 HPVA supports EPA using voluntary national consensus standards such as ANSI/HPVA HP

- 1 and ANSI/HPVA EF which incorporate the CARB emission requirement in those standards and their adoption under the authority of the National Technology Tran sfer Act (NTTA).

We do not believe as we have previously commented to EPA that a rule can be justified under section 6 (a) of TSCA. The CARB rule is essentially predicated as a technology based standard and for that reason we believe that authority under another section or a new statutory provision that would permit the incorporation by reference of the revised and updated ANSI/HPVA HP

- 1 and ANSI/HPVA EF national consensus standards would be a preferable approach. These standards which have been the operat ing norm in the industry and widely accepted and referenced by end users of these products address the other concerns that we have discussed in these comments.

The revised ANSI/HPVA HP

- 1 and EF standard s like CARB require independent third party certifica tion; use of certified laboratory testing facilities, ASTM approved test methods, inspections, audits, and labeling. EPA’s adoption of these national consensus standards achieves the same end emission performance results and would focus EPA on “checking t he checker.” With EPA’s testing and enforcement capacity, this gains significant efficiencies and tim e liness of compliance. A major weakness in the implementation of the CARB rule has been CARB’s failure to conduct a “round robin” validation test of all t he TPC’s that have been approved. We have voluntarily conducted our own mini

- round robins and have annual audits conducted by the International Accreditation Service (IAS) which include equipment calibration reviews. CARB has yet to determine if all the ap proved TPC’s are following common and consistent practices.

As EPA determined over a decade ago, formaldehyde measurements in home and workplaces then did not warrant a finding of an unreasonable risk of injury. The new CARB standards further reduce expos ures in effect adding additional margins of safety using new technologies to levels that were viewed as not posing unreasonable risks of injury or adverse health effects before

.
Because the HWPW products are tested at loading rates in a large scale tes t chamber that are far higher than actual, document usage rates, the test results are correspondingly higher than levels would be predicted if typical loading rates were used. Field measurements confirm these calculations. Field measurements conducted by E PA and NPA in the 1990’s study which found no reason for concern will be even lower today with the utilization of even lower or non

-HPVA Comments to EPA

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12 formaldehyde emitting HWPW products. 3 HWPW is tested using a loading rate of 0.13 ft2/ft3 for industrial use panels and 0.29 f t2/ft3 for wall panels, however actual use in conventional homes are 0.016

– 0.019 ft2/ft3

. A test chamber value of 0.04 ppm would predict to be 0.004 ppm or at virtually the limits of detection. Moreover, HWPW products in the presence of other products wi th higher formaldehyde emission characteristics would function as “sinks” for those emissions. 4

The recent FEMA trailer experience is not a testament that the earlier measures taken by HUD and evaluations by EPA were insufficient. Rather the performance re sponse to the natural disaster caused by Hurricane Katrina by the federal emergency response agency in charge was inadequate including the provision of emergency housing. Many of the housing units provided storm victims were recreational vehicles which are not subject to an y FEMA’s failings are not representative of America’s housing stock. The vast inventor y of American housing is best characterized by EPA’s earlier assessment and findings and not an emergency situation involving an infinitesimal number of housing units and a federal agency ’s generally recognized incompetent response by comparison.

In summa ry and for the r easons discussed , HPVA supports the timely promulgation of a federal standard for formaldehyde emissions fro m HWPW. The federal standard should apply universally to all HWPW products. The federal standard for HWPW emissions should apply to all manufacturers and producers who sell their HWPW in the U.S. Imports of HWPW should meet U.S. performance standards and only a federal rule can achieve this leveling of the playing field.HPVA Comments to EPA

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13 1 Manufacturers of VC platforms can and some suppliers do p roduce and certify the formaldehyde emission values of their products. This is voluntary but prudent because HWPW manufacturers who use these platforms can better assure that their final HWPW product will meet the stringent CARB emission values for HWPW. ( Source: HPVA Annual Industry Surveys)

2 Imported HWPW accounts for over 62% of the US HWPW market which is estimated to be about $2.4 billion. Because imported panels are of lower unit value than domestically produced panels, the market share of imported pr oducts may actually be 70

- 75% of the North American market. Because the import codes which sometimes group non

- homogenous products under the same code, exact figures for the products of interest in this ANPR are difficult to determine. (Source: ITC Report 332

- 487 USITC Publication 4032, August 2008 and HPVA Annual Industry Surveys)

3 ASTM E 1333, Appendix X 3.3 ; “ Formaldehyde

– Basic Information

– Indoor Air Quality (IAQ) , ” Environmental Protection A g ency , http : // www.epa.gov/iaq/formalde.html
, “ U pdate on Formaldehyde: 1997 Revision, ” Consumer Product S a fety C o mmission, CPSC Document #725, http:// www.cpsc.gov/CPSCPUB/PUBS/725.html
,

4 See Chang ,J. and Guo,Z.1992, Sorption and Reemission of Formaldehyde from Gypsum Wallboard, ASHRAE IAQ 1992, pp. 301

- 307; Godish , T. and Kanyer, B. 1985, Formaldehyde Source Interaction Studies , Forest Products Journal 35 (4): 13

- 17 ; Rouch, J. 1987, Formaldehyde Source Interaction Studies, Environ m e ntal Pollu tion 48, pp. 1

- 12; Garrison, S. and Walcott, R. 1985, Factors that Influence Formaldehyde Levels in Mobile H o mes , Forest Produc ts Journal 35, (2) 11

- 18.HPVA Comments to EPA

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14 APPENDIX A
Source: Airborne Toxic Control Measure to Reduce Formaldehyde Emissions from Composite Wood Products Section 93120.1 Definitions

CARB PRODUCT DE FINITIONS:
(19) “hardwood plywood (HWPW) means a panel composed of an assembly of (A) hardwood layers or plies of veneer or (B) veneers in combination with a platform consisting of lumber core, composite core, a special core or back material joined with a n adhesive. The face veneer may be composed of a hardwood or decorative softwood species (ANSI/HPVA HP

- 1

- 2004). “Hardwood plywood” includes wall paneling, industrial panels, and “hardwood plywood” panels used in making flooring. “Hardwood plywood” does not include laminated products, military specified plywood, or curved plywood. (20) “Hardwood plywood

- composite core” (HWPW

- CC) means hardwood plywood with a composite

core. (21) “Hardwood plywood

- veneer core” (HWPW

- VC) means hardwood plywood with a core of a sheet or sheets of veneer. (35) “Plywood” means a panel product consisting of layers of wood veneers in combination with a platform, pressed together with resin.....” (34) “Platform” means a veneer core, composite core, or combination core, lumber core, or special core material used in the manufacture of hardwood plywood or laminated products. (Emphasis added) (5) “Combination core” means a platform for making hardwood plywood that consists of a combination of layers of veneer and particleboard or medium de nsity fiberboard. (7) “Composite core” means a platform for making hardwood plywood or laminated products that consists of particleboard and/or medium density fiberboard, or combination core. (25) “Laminated product” means a finished good or component part of a finished good made by a fabricator in which a laminate or laminates are affixed to a platform. If the platform consists of a composite wood product, the platform must comply with the applicable emission standards. (24) “Laminate” means a veneer or ot her material affixed as a decorative surface to a platform. (8) “Composite wood products” means hardwood plywood, particleboard, and medium density fiberboard......”

CARB PRODUCER DEFINITIONS:
(26) “Manufacturer” means any person who manufactures or produces a composite wood product.
(12) “Fabricator” means any person that uses composite wood products to make finished goods. “Fabricator” includes producers of laminated products. (Emphasis added)HPVA Comments to EPA

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15 # # # # #
EPA requests information on the markets for HWP W and a copy of the 2007 HPVA Stock Panel Report is attached which is submitted under a claim of CONFIDENTIAL BUSINESS INFORMATION.