Comment Log Display

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.