Comment Log Display

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.