First Name | Michael |
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Last Name | Zimmerman |
Email Address | mzimmerman@sauder.com |
Affiliation | Sauder Woodworking Co. |
Subject | Comments on Feb 1st Draft of ATCM Composite Wood |
Comment | To the Board of California Air Resources Board (CARB) Again, thank you for the opportunity to share some of our comments regarding the CARB regulation 93120. We feel there are several issues in your regulation that need to be addressed. 1. Changes in the language for sell-through for the Fabricator section page 45 may be more confusing. The original wording was (Page 38 of the Dec 21st Draft): a. Finished goods containing HWPW-VC, HWPW-CC, PB, MDF, or thin MDF produced before the Phase 1 and Phase 2 effective dates specified in section 93120.2 (a) may be sold, supplied offered for sale by fabricators for up to eighteen months after each of the specified effective dates. It is now worded as (page 45 of Feb 1st draft): b. Finished goods containing HWPW-VC, HWPW-CC, PB, MDF, or thin MDF that does not comply with Phase 1 and Phase 2 effective dates specified in section 93120.2 (a) may be used, sold, supplied, offered for sale by fabricators for up to eighteen months after each of the specified effective dates. This wording change seems to allow a Fabricator to continue using non-complying composite panels in their manufacturing processes till June 30th 2010 and sell into California. Do we as a Fabricator have till June 30th 2010 to comply? 2. The proposed finished product enforcement testing still lacks validation scientifically. The lack of data or evidence for the finished products testing is concerning. The regulation will be implemented without sound scientific data correlating raw panel large chamber testing to a finished product enforcement test. There are several hundred different board mills in the world and a thousand different methods to finish a panel. What impact will each variable have on the finished product testing? Will each mill have a different emission factor when sanded? Do finishes when removed impact the emission of the sanded composite panel? Combine both unknowns and an already large error associated with finished product emissions testing it may be impossible to know whether or not a finished composite panel was or was not compliant to the Regulation. 3. The regulation does not promote the use of lower emitting composite products use by the Fabricators. The regulation gives the manufacturers incentives to use lower emitting resins for making composite panels. However, there is no incentive for the Fabricators to buy and use those panels. In a cost-sensitive market, price is still more powerful than environmentally friendly. Studies continue to show that the majority of consumers will not pay even 1% more for an environmentally friendly product. The lower emitting panels will probably have some added cost associated with them. If the Fabricator cannot off-set that cost, Fabricators will not use the lower emitting products that CARB would like to promote. Is there not an off-set possible by reducing the paper work or tracing requirements or recognition?? 4. Will there be more specific labeling requirements, such as font and size and specific wording for the CARB Phase I Compliant? 5. Will there be specific wording for Bill of Lading and Invoices? Sincerely, Michael Zimmerman Senior R&D Chemist Sauder Woodworking Co. mzimmerman@sauder.com |
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Original File Name | |
Date and Time Comment Was Submitted | 2008-02-15 09:05:43 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.