From: Ping Cheng <pcheng@icc-es.org> 

Sent: Wednesday, September 20, 2023 4:48 PM 

To: Rioux, Nathalie M. (Fed) <nathalie.rioux@nist.gov> 

Cc: Ping Cheng <pcheng@icc-es.org> 

Subject: Comments on the Proposed Revisions to PS 1-22 

Dear Ms. Rioux, 

We have been informed on the following proposed revisions to PS 1-22: 

1. Updated definitions to address Critical Section in Section 2.14. 

2. For species classified by testing, Section 5.2.4 clarified that species listed in Table 1 but 

grown in a different geographic region shall be qualified for use by performance testing. 

3. Clarified the adhesive bond requirements under Section 5.7.1 Exposure 1 and 5.7.2 

Exterior.

4. Added calculations for planar shear strength in Section 6.2.4 and shear-through-thethickness strength in Section 6.2.5. 

5. Added Categories 5/16 and 11/16 to Table 10, Table D1, and Table D2. 

6. Updated Section 7 Marking and Certification. The updates include: 1) Revised Section 

7.1 completely, 2) Added a new Section 7.2 for Accredited Certification Agency; 3) 

Revised the existing Section 7.2 by introducing two new sections for Accredited 

Inspection Agency (7.3) and Accredited Testing Laboratory (7.4). 

7. Added new Section 8 on Quality Assurance Requirements which included adding the 

following subsections: Manufacturing Quality Program (8.1), Inspection and Test 

Program (8.2), Sampling (8.3) and Corrective Action (8.4). 

We have reviewed the proposed revisions and have no comments on above listed Items 1, 2, 4 

through 6. The following comments on Item 3 and Item 7 are provided for your consideration: 

1. Comment on Item 3. This comment is related to the pass/failed requirements given in 

Section 5.7.1 and Section 5.7.2. According to Requirement 1 under Exposure 1 in Section 

5.7.1: “When at least 20 panels are tested, at least 95% of the individual panels 

represented by the test pieces shall have 30% wood failure or better, and at least 90% of 

the individual panels represented by the test pieces shall have 60% wood failure or 

better. In addition, the average wood failure of all test specimens taken from all 

individual panels shall be not less than 80%.” It is not sure as to how the three pass/fail 

requirements can be met at the same time. For an example, if each of 19 out of 20 test 

specimens has a wood failure from 31 % to 59%, then the tested panels have met the 

requirement of “When at least 20 panels are tested, at least 95% of the individual panels 

represented by the test pieces shall have 30% wood failure or better.” However, the 

tested panels have failed to meet the other two requirements. It would be our 

recommendation to use one pass/fail requirement, such as “the average wood failure of 

all test specimens taken from all individual panels shall be not less than 80%”, for 

adhesive bond evaluation. 

2. Comment on Item 7. This comment is related to the specified frequencies of inspections 

in new Section 8.2. According to ISO/IEC 17007, specific conformity assessment 
schemes, such as frequency of inspection, should not be included in a normative 

document. Also, ISO/IEC 17065 makes this statement: “When continuing use of a 

certification mark is authorized for placement on a product (or its packaging, or 

information accompanying it) (for process or service, see 7.9.4) of a type which has been 

certified, surveillance shall be established and shall include periodic surveillance of 

marked products to ensure ongoing validity of the demonstration of fulfilment of product 

requirements.” As an ISO/IEC 17065 Accredited Certification Agency, ICC-ES suggests 

the following modifications to Section 8.2: 

8.2 Inspection and Test Program 

The Accredited Certification Agency shall establish and implement an Inspection and 

Test Program to verify ongoing manufacturer and product conformity to the mill 

specification and the requirements of this Standard. At a minimum, the Inspection and 

Test Program shall include the following: 

8.2.1 At least annually (approximately every 12 calendar months): 

8.2.1.1 8.2.1 Assessment that the mill specifications for each mill are appropriate for 

the product being certified. 

8.2.1.2 8.2.2 A review of manufacturer’s Quality Manual. Updates to the Quality 

Manual shall be prepared by the manufacturer and submitted to the Accredited 

Certification Agency for review and approval. If the manufacturer made no updates to 

the Quality Manual in that year the manufacturer needs to notify the Accredited 

Certification Agency that no updates were done. 

8.2.2 At least semiannually (approximately every 6 calendar months):

8.2.2.1 8.2.3 Inspection of species, construction, panel grade, and thickness 

conformity with this Standard. 

8.2.3 At least quarterly (approximately every 3 calendar months): 

8.2.3.1 8.2.4 The production and quality system of each production facility producing 

plywood in accordance with this Standard shall undergo on-site audits by the 

Accredited Inspection Agency. The audits shall include, at a minimum: 

8.2.3.1.1 8.2.4.1 Verification of the appropriate use and legibility of panel marks 

to include, if applicable, the appropriate use of panel voiding marks as specified 

in Section 7.6. 

8.2.3.1.2 8.2.4.2 Review of the manufacturer’s in-plant quality inspection and test 

data to verify on-going product conformity to the mill specification and the 

requirements of this Standard. 

8.2.3.2 8.2.5 Verification sampling and inspection shall be conducted by the 

Accredited Inspection Agency at least (4) times per year, either in conjunction with or 

independent from the quarterly audits specified in Section 8.2.3.1. The sampling 

requirements in Section 8.3 shall apply. Verification testing of the sampling identified 

above shall be performed by the Accredited Testing Laboratory or by the 

manufacturer’s testing laboratory if it has been approved by the Accredited 

Certification Agency.
We appreciate the opportunity to provide our comments on the proposed revisions to PS 1-22. 

Sincerely,

Ping Cheng, P.E. 

Senior Staff Engineer 

ICC Evaluation Service, LLC 

Western Regional Office

3060 Saturn Street, Suite 100 

Brea, CA 92821 

Tel: 562.699.0543, x3535 | Fax: 562.695.4694 

Email: pcheng@icc-es.org | Web: www.icc-es.org