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Jim and Lynn … just wanted to let you know that the AHFA supports
the “Proposed Modifications” as detailed in the “15 Day” version
of the ATCM dated 01/31/08 … more specifically:

1.    We support the definition of “laminated products” in Section
93120.1(25)

2.    We support the additional label requirements added for
fabricators in Section 93120.7(d).

3.    We support the addition of a “secondary test method by third
party certifiers” in Section 93120.9. We strongly believe that the
addition of this test method for certification will help
facilitate and improve the ability of off-shore compliance to the
ATCM. We also support the use of the secondary test method for
compliance purposes as a “deconstructive test” to verify the
compliance of composite wood products used as component parts of
finished products.

4.    We support the modification to the definition of hardwood
plywood in Section 93120.1(19) not to include curved plywood.

5.    We support the modification in 93120.7(a)(2) not to require
third party certification for fabricators that are also “producers
of laminated products.”

6.    We support the modification in 93120.7(a)(3) that requires
the composite wood product of the “platform” of a laminated
product to meet the applicable emission requirement of the
composite wood product used.

7.    We support the modification in 93120.7(a)(4) that requires
fabricators to meet the requirements of 93210.3 if they are
manufacturing a composite wood product used exclusively by the
fabricator as component parts of finished products.

8.    We strongly support the 18 month sell through period as
prescribed in 93120.2 (a) and agree with the language “that does
not comply with Phase 1 and Phase 2 effective dates.” This will
allow for the adequate “turn of inventory” within the supply chain
and facilitate compliance.

 

Let me know if you have any questions.

 

Bill Perdue

VP ESH - Standards

AHFA

336-884-5000, x117

276-806-2014 m

bperdue@ahfa.us