First Name | Michael |
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Last Name | Anderson |
Email Address | michael.anderson@kodak.com |
Affiliation | Eastman Kodak Company |
Subject | CWP Rulemaking - Request for exemption for pallets, crates and other packaging materials |
Comment | Eastman Kodak Company appreciates the opportunity to provide comment(s) on the aforementioned CARB proposed rulemaking. We respectfully request that the Board give careful consideration towards the applicability of packaging mterials and grant an exemption for pallets, crates and other shipping/packaging media. Engineered wood products (i.e., plywood) have become more readily available in the shipping industry today to provide the necessary protection for the product during shipment, hold up to the physical demands during transport, and to avoid treatment costs associated with international phytosanitary measures (ISPM-15). While crate and dunnage materials have historically been constructed using composite wood products, pallets have recently migrated towards the use of these materials. We are concerned that the recent rulemaking and impending regulation for composite wood products in California did not adequately address the concerns and real world implementation aspects of the shipping industry and specifically on shipping/packaging materials. For starters, pallets, crates and packaging products do not pose the same risks or exposure pathways as fabricated products. Pallets are transient materials that are often stored in warehouses or transported in vehicles that pose little or no risk of exposure to humans. Crating and dunnage, likewise pose little harm by being disposable/recyclable by the end user. Unlike most fabricated goods, pallets, crates and packaging have very different use and applications which result in very different exposure scenarios. Manufacturers have little or no control over third-party warehouses or distribution facilities activities that result in repacking functions (ie., re-palletize). This is a very common practice in the retail market channel. It would be unfair to any OEM or producer in such situations. In order to avoid the possibility of an noncompliant, reusable pallet or crate would be shipped into California, we may be forced to discard the existing inventory and replace with new packaging. This will result in a premature disposition of packaging materials that had many more years of useful life. In addition to generating waste it would increase shipping costs, as new crates and pallets would have to be purchased to replace the existing inventory. We respectfully request that you and members of the composite wood product implementation team give careful consideration to packaging materials and pallets. We believe that the most logical approach is to exempt these materials from the ARB requirements. Thank you - Mike |
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Date and Time Comment Was Submitted | 2008-02-12 12:39:46 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.