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-HQOPPT-2008-0627; FRL – 8386-3

Submitted by:

Kip Howlett,

President - HPVA

3/19/2009
HPVA Comments to EPA – HQ-OPPT-2008-0627 2

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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 in 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 the 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, raises 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 hearings over the next two months. The following are the written comments of the 

Hardwood Plywood and Veneer Association (HPVA) on this ANPR. HPVA also testified at the 

public hearing in Washington DC. 

Introduction: HPVA represents manufacturers in the U.S. and Canada who produce hardwood 

plywood (HWPW), hardwood veneer (V), and engineered hardwood 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 production 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 standards for products that are subject to this 

rulemaking: hardwood plywood (ANSI/HPVA HP-1 - 2004) and engineered wood flooring 

(ANSI/HPVA EF- 2002).

HPVA is also certified by the International Accreditation Service (IAS) for product certification 

(ISO 65), for our laboratory (ISO/IEC 17020), and for specific 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 Third Party Certification organization

recognized by California (TPC-8). HPVA has been a certifier of HWPW used in manufactured 
HPVA Comments to EPA – HQ-OPPT-2008-0627 3

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housing under the U.S. Housing and Urban Development (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 stamp which currently specifies HUD emission limits and is 

being revised now to incorporate CARB emission limits for HWPW. 

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 CARB 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 commodity 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 properties as measured by specific gravity, weight, hardness, modulus of 

rupture, and modulus of elasticity. HWPW is made using a wide variety of cores, including

veneer core (VC) with varying numbers of plies (about 65%), particleboard (PB)( about 

12%),medium density 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 key point is that the HWPW 

emission 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 

Handbook and Veneer Species Guide demonstrate, the combinations of product cores, 

dimensions, and species provide a remarkable variety of aesthetic and physical performance 
HPVA Comments to EPA – HQ-OPPT-2008-0627 4

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properties. Softwood plywood and OSB are not substitute materials. They are structural 

construction materials and not aesthetically attractive, 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 

Comparisons 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-VC: 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 added 
HPVA Comments to EPA – HQ-OPPT-2008-0627 5

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formaldehyde (NAF), no added urea formaldehyde (NAUF), or ultra-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% must 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 concentrations 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 these standards ranging from soy 

based, polyvinyl acetate (PVA), and phenol formaldehyde (PF) to modified urea formaldehyde 

(ULEF) and other systems. 

Dried resins are 2.0-3.0% of HWPW (VC) by weight compared to PB and MDF which will be 9-

12% by weight. Costs and technical 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 other 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 control 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 of 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 change 

is not a simple task.
HPVA Comments to EPA – HQ-OPPT-2008-0627 6

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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, bio-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 workplace 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 universally 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 both 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 manufactured 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 manufacture 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 veneer core is not 

hardwood plywood because it does not have ANSI/HPVA HP-1 decorative face and back grade

veneers. Veneer core is a component (component) of HWPW but only becomes HWPW after 
HPVA Comments to EPA – HQ-OPPT-2008-0627 7

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the face and back veneers are applied. CARB has no formaldehyde 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 

platform. 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 they 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 requirements. The ANSI/HPVA HP-1 revision addresses this concern by 

recommending that 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 “fabricator” 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 glue 
HPVA Comments to EPA – HQ-OPPT-2008-0627 8

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line is regulated. 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 effect, 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 State 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 third 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 “fabricator”, 

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 and 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. This CARB rule flaw must not be replicated or 

adopted in any federal emission standard for these products.
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This exemption is a giant loophole. It particularly advantageous for off-shore producers who 

escape the higher operating costs associated with the new resin systems, certification and 

testing 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 products 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 for 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 products 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 HWPW 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 80%) 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), the ITC identities many of the factors 

that give Chinese products their cost advantage and mentions the costs of meeting new more 

stringent formaldehyde standards but does not specifically quantify those factors. 

Imported HWPW accounts for over 65% 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 figures for the products of interest in this ANPR are difficult to determine.
HPVA Comments to EPA – HQ-OPPT-2008-0627 10

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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.

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 

rapidly 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 emission standards.
HPVA Comments to EPA – HQ-OPPT-2008-0627 11

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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 Transfer 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 operating 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 standards like CARB require independent third party 

certification; 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 the 

checker.” With EPA’s testing and enforcement capacity, this gains significant efficiencies and 

timeliness 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 the 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 approved 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 exposures 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 test 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 EPA 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 – HQ-OPPT-2008-0627 12

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formaldehyde emitting HWPW products.3 HWPW is tested using a loading rate of 0.13ft2/ft3 for 

industrial use panels and 0.29ft2/ft3 for wall panels, however actual use in conventional homes 

are 0.016 – 0.019ft2/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 

with 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 response 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 any FEMA’s failings are not 

representative of America’s housing stock. The vast inventory 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 summary and for the reasons discussed, HPVA supports the timely promulgation of a 

federal standard for formaldehyde emissions from 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 – HQ-OPPT-2008-0627 13

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1 Manufacturers of VC platforms can and some suppliers do produce 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 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 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 

Agency, http://www.epa.gov/iaq/formalde.html, “Update on Formaldehyde: 1997 Revision,” Consumer Product Safety 

Commission, 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, Environmental Pollution 48, pp. 1-12; Garrison, S. and Walcott, R. 1985, Factors 

that Influence Formaldehyde Levels in Mobile Homes, Forest Products Journal 35, (2) 11-18.
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APPENDIX A

Source: Airborne Toxic Control Measure to Reduce Formaldehyde Emissions from Composite 

Wood Products Section 93120.1 Definitions

CARB PRODUCT DEFINITIONS: 

(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 an 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 density 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 other 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 – HQ-OPPT-2008-0627 15

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# # # # #

EPA requests information on the markets for HWPW and a copy of the 2007 HPVA Stock Panel Report 

is attached which is submitted under a claim of CONFIDENTIAL BUSINESS INFORMATION.