First Name | Dennis |
---|---|
Last Name | Bradway |
Email Address | dennisb@mannington.com |
Affiliation | |
Subject | Modified Compwood ATCM |
Comment | February 15, 2008 Dear Ms Csondes Subject: ARB Modified Compound ATCM Thank you for the opportunity to provide comment on the modified document. I have a just few questions and comments regarding the document; most are really more questions as point of clarification. A) On page 1-58 there is reference to testing method and frequency for hardwood plywood which spells out a specified criteria based upon weekly sq. ft of production. There should be a level of flexibility regarding reduced testing requirements if one can demonstrate statistical compliance at a reduced level of testing burden. The test requirement is to condition for seven days before testing, so obviously it is not being directly used to monitor and adjust one’s process. If testing is at zero conditioning, then one is obligated to provide the correlation and expected decay curve representing compliance at the seven day conditioning timeframe. I don’t believe as much of this data exists for HWPW as ARB may be expect. In the same respect that a manufacturer can define product categories or groupings, a manufacturer should be able to submit a statistically sound sampling and testing scheme utilizing approved methodology in order to demonstrate compliance. It will ultimately be supported by the quarterly primary or secondary testing anyway. We would simply request the additional statement below the table under paragraph “C” on page 1-58 “Or sufficient sampling frequency utilizing approved methodology in order to demonstrate compliance” B) Since the testing methods call for a seven day conditioning time period, I assume even for field compliance verification testing, it would be mandated to follow the same protocol of sampling, appropriate conditioning then testing. C) To us it would seem appropriate that compliance testing should be on a product or article as sold for point of use and tested in a manner consistent with recommended use(i.e horizontal, finished side up). Reducing of that product to its component parts to test would render the product non serviceable and would almost certainly reduce the accuracy and applicability of the test results. D) We believe we should be able to start the exemption application in parallel to the generation of the data collection process, with approval contingent upon satisfactory demonstration of the data. Thank you for consideration of these comments Respectfully Dennis H. Bradway Mgr Technical Support Mannington Mills |
Attachment | www.arb.ca.gov/lists/compwood07/123-arb_modified_atcm.doc |
Original File Name | ARB modified ATCM.doc |
Date and Time Comment Was Submitted | 2008-02-15 14:30:42 |
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