First Name | Dick |
---|---|
Last Name | Titus |
Email Address | dtitus@kcma.org |
Affiliation | Kitchen Cabinet Manufacturers Associatio |
Subject | Comments on January 31, 2008 Revised ATCM for Compwood |
Comment | The Kitchen Cabinet Manufacturers Association (KCMA) appreciates this opportunity to comment on the January 31, 2008, version of the ATCM for composite wood products made available for a 15-day comment period. KCMA is the principal U.S. trade association for manufacturers of kitchen cabinets, bath vanities, and storage cabinets for other rooms. The compwood ATCM will directly impact all KCMA members manufacturing or selling cabinets in California. Wood and wood products, including particleboard, hardwood plywood, and medium density fiberboard, are essential materials used in the manufacture of the overwhelming majority of industry products. Cabinet manufacturers are subject to provisions of the ATCM regulating fabricators. We support the revised definition of “fabricator” -- Section 93120.1(a)(12) -- that has been expanded to include the production of laminated products. The revised definition of “laminated product” -- Section 93120.1 (a) (25) -- also is supported. The revised language in Section 93120.7 (2)-(4) regarding the treatment of laminated products clarifies how such products will be regulated. The revised language is consistent with the scope and purpose of the ATCM. KCMA supports the revised language. Currently, the regulation lacks a clear summary page of the effective dates fabricators must satisfy in order to be in compliance such as was developed for compwood manufacturers. We request that such a chart be developed and added to the regulation or made available as soon as possible to assist companies in developing their compliance strategy. It is suggested that the clarification provided in Section 93120.7(b)(3) regarding the responsibilities of local government agencies and school districts clearly be made applicable to all state government agencies. KCMA generally supports the 18-month sell-through provisions of the regulation. CARB staff deserves recognition for the openness and fairness with which this long and difficult process has been conducted. We anticipate many challenges when the actual enforcement phase begins. Hopefully, the same approach will continue. |
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Date and Time Comment Was Submitted | 2008-02-14 17:38:11 |
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