First Name | Jim |
---|---|
Last Name | Rabe |
Email Address | jrabe@masonite.com |
Affiliation | Masonite Corporation |
Subject | Public Comments on the Proposed ATC Measure 93120 |
Comment | I am Vice President of Environmental Health and Safety for Masonite Corporation. The following comments are submitted by me on behalf of Masonite. The following comments and recommendations were complied through an extensive evaluation by Masonite technical, EHS, production and engineering personnel. Masonite believes them to be valid and reasonable for consideration by the Air Resource Board to improve the effectiveness and efficiency of the regulation. Jim Rabe 1. Masonite proposes the qualification period for the "Exempt ULEF" status (6 months of QC testing) be made consistent with that required for "no added-formaldehyde" status (3 months of QC tests). Suggested language: "If, after three months of routine QC testing and one primary or secondary method test, 90% of the emissions results are within the target value of 0.04 ppm, and no emissions results exceed the cap value of 0.06 ppm, the manufacturer may immediately petition the Executive Officer for approval of exempt ULEF status." 2. Masonite plant personnel are concerned that testing one sample per shift (up to 540 tests per production line in six months) will be too burdensome on production if required to perform this many tests. Three months of daily testing would provide 90 data points for production, which would be more than adequate to give a reliable estimate of the mean and variability of the emissions from the product. Standard practice in statistical methods accepts a minimum of 30 data points to validate the sample population. Masonite proposes a reduction in QC test frequency from one per shift to one per day. 3. For the same reason stated above the test frequency for standard production for components that do not meet the ULEF standard should be reduced from once per shift to one per day. 4. QC test frequency should be reduced for products that attain the ULEF, but not "exempt ULEF", designation to once per week, rather than once every 48 hours. Once per week will yield 52 data points over a year, sufficient data for estimating the mean and variability of the emissions. 5. Exterior doors can be made with laminated veneer lumber stiles and rails made with hardwood or softwood and capped with finger jointed softwood. Masonite proposes this type of material does not fall under the definition of HWPW and is exempt from the regulations. 6.Masonite proposes that a 2-ply HWPW-CC panel have the same emissions level as thin MDF. The basis for this is there are 2-ply door skins, comprised of a thin hardwood veneer which makes up 10% of the skin by weight, laminated to an MDF substrate that makes up 90% of the skin by weight. When testing this skin in a large chamber the MDF will contribute the majority of the emissions. 7.CARB's definition of a "window" includes jambs. The definition of a "door" is not specific as to its components. The definition should be revised to include framing members for pre-hung doors. 8.Section 93120.7.b.2: Exterior doors and garage doors that contain composite wood products are exempt if the doors are made for exterior use. What is the definition of exterior use? 9.Section 93120.7.b.2: Exterior doors and garage doors that contain composite wood products are exempt if the doors contain less then 3% by volume of HWPW, PB or MDF. Masonite requests that exterior doors be exempt if the HWPW, PB or MDF components make up 15% or less by volume of the finished door, if the component is sealed entirely inside the door or has only one exposed edge. The basis for this is that the smallest components of a door such as composite wood lock blocks are totally encased inside a door and rails which are only exposed on one edge can make up to 15% by volume of the door. |
Attachment | www.arb.ca.gov/lists/compwood07/120-masonite_comments__93120.doc |
Original File Name | Masonite Comments 93120.doc |
Date and Time Comment Was Submitted | 2008-02-15 13:50:16 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.