HK Mailing Address: Michael E. Haglund 

Michael K. Kelley (In Memoriam) 2177 SW Broadway Michael G. Neff Portland, Oregon 97201 Julie A. Weis 

Christopher Lundberg 

T 503.225.0777 Matt Malmsheimer 

Joshua Stellman (Astoria) F 503.225.1257 HAGL UNO KELLEY Eric J. Brickenstein LLP www.hk-law.com Christopher T. Griffith 

Kaisa Johnson 

Shay S. Scott 

Heather Reynolds (Astoria) 

Of Counsel 

LeRoy W. Wilder 

Retired 

September 22, 2023 

VIA FEDEX and EMAIL 

Nathalie Rioux 

Standards Coordination Office 

National Institute of Standards and Technology 

100 Bureau Drive, Stop 2100 

Gaithersburg, MD 20899-2100 

Email: nrioux@nist.gov 

Re: Proposed Voluntary Product Standard PS 1-22 

Dear Ms. Rioux: 

We represent the U.S. Structural Plywood Integrity Coalition ("Coalition"), which includes the 

following eight companies: Scotch Plywood Co., Inc., Veneer Products Acquisitions, LLC, Southern 

Veneer Specialty Products, LLC, Hunt Forest Products, LLC, Freres Lumber Co., Inc., Murphy 

Company, SOS Lumber LLC and Swanson Group, Inc. These eight family-owned companies operate 

nine plywood plants in Oregon and Washington and four in Alabama, Georgia and Louisiana. 

Combined, these companies employ more than 4,000 workers. 

The Coalition filed a petition in December 2020 that initiated the process under which the PS 1 

Standing Committee appointed a Standard Review Committee to conduct a review of the PS 1 

Standard and develop its proposed Voluntary Product Standard PS 1-22, Structural Plywood, 

published in the Federal Register on August 24, 2023. As noted in that petition, several highly 

inappropriate practices by PS 1 certification, inspection and testing agencies licensing PS 1 structural 

plywood manufacturers in Brazil created an urgent need for the PS 1 Standing Committee "to address 

a major failure by two certification, inspection and testing agencies to perform their quality control 

functions as authorized licensors of PS 1 grade stamps to plywood manufacturers in southern Brazil." 

As explained below, following a thorough review of the proposed changes to the PS 1 

Standard, the Coalition supports the proposed changes and congratulates the Standard Review 

Committee and the PS 1 Standing Committee on the comprehensive character of its work, particularly 

the substantial rewriting of Section 7 governing "Marking and Certification" and the new Section 8 

entitled "Quality Assurance Requirements." 
September 22, 2023 

Page 2 

As proposed, the much more detailed Section 7 makes clear that a certification agency 

accredited to certify plywood manufacturers under the PS 1 Standard must perform the necessary 

testing, inspections, and data analysis to be confident that its licensees can and do produce on-grade 

PS l structural plywood using veneer resources that will consistently meet the standard. Section 7, in 

combination with other clarifying changes in Sections 5 and 6, now makes clear that PS I certification, 

testing and inspection agencies are prohibited from engaging in any form of biased qualification 

testing, granting interim certification approvals and stamping privileges without testing, utilizing 

biased subcontractors as inspectors or failing to regularly perform periodic inspections and testing. 

These are all important clarifications ofthe existing PS 1-19 Standard that bring the precise language 

ofthe standard into line with its longstanding spirit and goals. 

The Coalition also wishes to express its strong support for the proposed new Section 8, which 

requires that each PS l manufacturer's quality assurance program must be documented in an approved 

Quality Manual and be subject to minimum requirements for ongoing inspection and testing by each 

manufacturer's certification, inspection and testing agency. It is worth noting that the quality assurance 

requirements set out in the proposed Section 8 are clearly modeled after the gold standard practices of 

the APA-The Engineered Wood Association. Importantly, these include a Quality Manual for each 

certified PS l mill, an assessment at least annually that the mill specifications for each mill are 

appropriate for the products being certified, consistent programs of inspection and testing based upon 

unbiased random sampling that is "representative ofthe population being inspected or tested," and 

rigorous corrective action procedures. Clearly, this new quality assurance section requires a 

certification, inspection and testing agency to perform annual testing like the APA's annual bending 

stiffness tests to assess the licensed mill's ongoing capability to meet the PS 1 Standard as well as the 

regular inspections and testing throughout each year that are the foundation of the first-rate quality 

control program that the consuming public expects are a fundamental component of any product with 

important life and safety functions. 

In conclusion, the U.S. Structural Plywood Integrity Coalition strongly supports adoption of 

the proposed PS 1-22 Standard. While the Standard Review Committee elected not to add control of 

the accreditation process to the PS I Standard in a manner comparable to the American Lumber 

Standard Committee that controls accreditation of certification, inspection and testing agencies under 

the PS 20 product standard governing structural lumber, the Coalition is hopeful that the substantial 

proposed revisions to the PS 1 Standard and the lessons learned from the two federal court cases 

prosecuted by the Coalition will result in more comprehensive and appropriate accreditation 

procedures by existing accreditors in the U.S. such as International Accreditation Service, Inc. and the 

American Association for Laboratory Certification, Inc. 

HK 

HAGLUND KELLEY LL P 
September 22, 2023 

Page 3 

cc: 

Scotch Plywood Co., Inc. 

Veneer Products Acquisitions, LLC 

Southern Veneer Specialty Products, LLC 

Hunt Forest Products, LLC 

Freres Lumber Co., Inc. 

Murphy Company 

SOS Lumber LLC 

Swanson Group, Inc. 

HK, 

I !1\0I UNO Kf:1_1 f:Y LLP