Comment Log Display

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