Comment Log Display

									February 15, 2008


Dear Ms Csondes

Subject: ARB Modified Compound ATCM

Thank you for the opportunity to provide comment on the modified
document.

I have a just few questions and comments regarding the document;
most are really more questions as point of clarification.   

A) On page 1-58 there is reference to testing method and frequency
for hardwood plywood which spells out a specified criteria based
upon weekly sq. ft of production.  There should be a level of
flexibility regarding reduced testing requirements if one can
demonstrate statistical compliance at a reduced level of testing
burden.  The test requirement is to condition for seven days
before testing, so obviously it is not being directly used to
monitor and adjust one’s process.  If testing is at zero
conditioning, then one is obligated to provide the correlation and
expected decay curve representing compliance at the seven day
conditioning timeframe.  I don’t believe as much of this data
exists for HWPW as ARB may be expect.  

In the same respect that a manufacturer can define product
categories or groupings, a manufacturer should be able to submit a
statistically sound sampling and testing scheme utilizing approved
methodology in order to demonstrate compliance.  It will
ultimately be supported by the quarterly primary or secondary
testing anyway.  We would simply request the additional statement
below the table under paragraph “C” on page 1-58 

“Or sufficient sampling frequency utilizing approved methodology
in order to demonstrate compliance”

B) Since the testing methods call for a seven day conditioning
time period, I assume even for field compliance verification
testing, it would be mandated to follow the same protocol of
sampling, appropriate conditioning then testing.  

C) To us it would seem appropriate that compliance testing should
be on a product or article as sold for point of use and tested in
a manner consistent with recommended use(i.e horizontal, finished
side up).  Reducing of that product to its component parts to test
would render the product non serviceable and would almost certainly
reduce the accuracy and applicability of the test results.

D) We believe we should be able to start the exemption application
in parallel to the generation of the data collection process, with
approval contingent upon satisfactory demonstration of the data.

Thank you for consideration of these comments

Respectfully 


Dennis H. Bradway
Mgr Technical Support
Mannington Mills