Our mission to build acceptance and demand in North America for globally sourced 

wood products from sustainably managed forests.

International Wood Products Association

4214 King Street Alexandria, VA 22302

Tel: 703-820-6696 info@iwpawood.org

Fax: 703-820-8550

www.iwpawood.org

September 25, 2023

Ms. Nathalie Rioux

Standards Coordination Office

National Institute of Standards and Technology (NIST)

100 Bureau Drive, Stop 2100

Gaithersburg, MD 20899-2100

Email : nrioux@nist.gov

Re: Proposed Voluntary Product Standard PS 1-22, Structural Plywood

Dear Ms. Rioux:

These comments are provided on behalf of the International Wood Products Association (IWPA). IWPA 

is a not-for-profit trade association representing North American importers of wood and wood products, 

the offshore and domestic manufacturers who utilize these products, and the service providers that 

facilitate trade. Our members include manufacturers, importers, distributors, and retailers of structural 

plywood and structural panel products that must conform to the requirements defined or referenced in 

U.S. Department of Commerce Voluntary Product Standards PS 1 and PS 2. IWPA is not a testing or 

certification organization and will not derive any revenue from the industry as a result of the proposed 

amendments defined in the draft PS 1-22 standard.

Importantly, IWPA has a number of members whose supply chains have been impacted by the outcome 

of litigation brought by the U.S. Structural Plywood Integrity Coalition (the “Coalition”) related to the 

activities of certain accreditation bodies and qualified inspection and test agencies who previously 

operated in Brazil. Our members want to produce, purchase, sell and/or utilize the highest quality panel 

possible—whether produced domestically or abroad—and want to have confidence in the standard and 

the system overseeing the standard. The IWPA membership needs a clear and comprehensible standard 

without loopholes that an unscrupulous manufacturer (or third party providing oversight) might utilize. Our 

members also need to clearly understand the PS 1 standard’s requirements themselves when conducting 

their own due diligence. 

Our members, and the public in general, therefore rely on the effectiveness, consistency, and integrity of 

the manufacturer quality control and third party verification systems prescribed in the PS 1 standard to 

assure the structural plywood products in their supply chain conform to both PS 1 and building code 

requirements. Regretfully, the outcome of the litigation in Brazil has significantly eroded both industry and 

consumer confidence in the reliability of the manufacturer quality control and the product certification, 

testing and inspection processes that are intended to achieve this objective. Therefore, it is imperative

that NIST and the PS 1 Standing Committee adopt comprehensive and meaningful changes to the PS 1 

standard. To the maximum extent practical, the standard must provide clear, unambiguous, and 

objectively verifiable manufacturer quality control and third party oversight requirements to be met by not 

just the structural plywood producers but even more importantly, the Accredited Certification Agencies, 

Accredited Test Laboratories and Accredited Inspection Agencies who are charged with validating 

manufacturer and product compliance thereto. We are grateful to NIST for the opportunity to provide 

comments regarding this important effort.

For our part, IWPA has evaluated the proposed changes defined in the draft PS 1-22 standard in light of 

the intended end use of structural plywood products, the allegations made by the Coalition in its litigation, 

and concerns raised by some of our members. IWPA notes that many of the proposed technical fixes
Our mission to build acceptance and demand in North America for globally sourced 

wood products from sustainably managed forests.

International Wood Products Association

4214 King Street Alexandria, VA 22302

Tel: 703-820-6696 info@iwpawood.org

Fax: 703-820-8550

www.iwpawood.org

support the goal of resolving the historically unclear or ambiguous product acceptance criteria and test 

method requirements defined in previous versions of the standard. We support these changes as a 

means to minimize potential misunderstanding by document users for the purposes of reliably evaluating 

a panel product’s conformity to PS 1 requirements. 

Conversely, IWPA advises that the proposed requirements for a Manufacturing Quality Program are not

adequately defined in a manner that ensures uniform understanding and effective implementation by both

foreign or domestic panel producers and other document users. In addition, IWPA is particularly 

concerned the proposed Marking and Certification, Sampling, and the Inspection and Test Program

requirements contain certain provisions that are either a) ripe for abuse or b) not substantively 

prescriptive to enable the fair, objective, and impartial verification of manufacturer and product conformity 

by third parties. Such proposed provisions do not support the goal of defining a revised set of 

requirements intended to minimize the risk of recurrence of the same or similar behavior alleged by the 

Coalition in its litigation or to restore public confidence in the certification, inspection and testing 

processes that are critical to product acceptance and use in North America.

IWPA is aware that IWPA member Benchmark Holdings, LLC has submitted comments to NIST and the 

PS 1 Standing Committee highlighting its concerns regarding the proposed PS 1-22 standard, all of which 

underscore the nature of IWPA’s concerns summarized above, echoed by other IWPA members. With 

this in mind, IWPA joins with Benchmark Holdings, LLC in proposing solutions to resolve these concerns. 

In particular, IWPA supports Benchmark’s comments regarding the following:

1) An alternative path to compliance for Concrete Formwork, Marine, and Structural I plywood 

panels types is critical to ensure the long term compliance and availability of these product types.

2) Alignment of PS 1 panel size tolerances to that of PS 2-18 and the moisture content test method 

requirements of PS 2-18, PRP 210-2019, or other related standards is needed to eliminate 

conflict and provide a uniform set of requirements for affected product types.

3) Proposed provisions in PS 1-22, section 7.1 and 8.2.3.2 which permit the use of manufacturergenerated test data by third parties for the purposes of determining initial product conformance to 

PS 1 acceptance criteria as described in PS 1-22 sections 5.8.6 and 5.8.7, or the verification 

sampling and testing provisions defined in sections 8.2 and 8.3, is not appropriate and must be 

avoided.

4) Proposed provisions for the determination of “Near Minimum Thickness” as described in PS 1-22, 

sections 5.8.6.1 and 5.8.7.1 should be reconsidered to account for the manufacturer’s proprietary 

panel construction and “as-produced” thickness.

5) Definition of minimum/maximum test speeds and other test parameters similar to that defined in 

ASTM D906 is needed to ensure accurate, repeatable and reproducible bond performance test 

results. The IWPA objects to the removal of any well-established and well-vetted testing standard 

from the document as the lack of properly defined testing requirements can easily lead to 

inconsistencies and confusion in both production and third party certification.

6) Additional specificity regarding the required components for a manufacturer’s written quality 

program is needed to promote understanding and equitable application by document users. We 

appreciate allowing for individual or unique corporate cultures or production situations in creating 

a manufacturer’s manual, but bare minimums must be established and standardized for both the 

market’s confidence in the program and for consistency in third party validation. 
Our mission to build acceptance and demand in North America for globally sourced 

wood products from sustainably managed forests.

International Wood Products Association

4214 King Street Alexandria, VA 22302

Tel: 703-820-6696 info@iwpawood.org

Fax: 703-820-8550

www.iwpawood.org

7) Clear and meaningful provisions for third party verification, sampling and inspection is needed to 

promote uniform and reliable validation of manufacturer and product conformity to PS 1 

requirements.

8) An Interlaboratory Comparison Program (ILC) is necessary to ensure the impartial and objective 

performance of Accredited Test Laboratories who offer PS 1 test services and to develop data for 

the industry’s future improvement.

9) Other miscellaneous technical fixes as described in the comments submitted by Benchmark 

Holdings, LLC are appropriate to further clarify relevant provisions and further eliminate ambiguity 

or conflict related to the stated requirements.

The goal of any Standard is to define criteria to be met, the testing methods and evidence required to 

demonstrate compliance to the criteria and to establish procedures to independently verify compliance. A 

Standard should be free from political bias. A Standard should assist in aiding commerce in compliant 

material while blocking non-compliant material from entering the supply chain. The quality of a standard 

is even more important for a document such as PS 1 because of the life safety issue. IWPA therefore 

fully supports the efforts of NIST and the PS 1 Standing Committee to create a revised PS 1 standard that 

defines clear and objective product acceptance criteria as well as manufacturer quality control and third 

party oversight requirements. However to meet that goal, we believe the additional technical fixes 

summarized in these comments and those submitted in detail by Benchmark Holdings, LLC are 

necessary. NIST and the PS 1 Standing Committee must ensure that document users and affected 

stakeholders – both domestically and abroad – understand their exact responsibilities and the Accredited 

Certification Agencies, Accredited Test Laboratories and Accredited Inspection Agencies responsible for

validating product and manufacturer compliance are able to do so reliably and objectively. 

Thank you for your consideration of these comments. Please contact Joe O’Donnell (joe@iwpawood.org; 

703-820-6696) of the International Wood Products Association if you have questions or need additional 

information. 

Respectfully Submitted,

Ashley Amidon

Executive Director

International Wood Products Association