Comment Log Display

To the Board of California Air Resources Board (CARB)
Again, thank you for the opportunity to share some of our comments
regarding the CARB regulation 93120.  We feel there are several
issues in your regulation that need to be addressed. 
1. Changes in the language for sell-through for the Fabricator
section page 45 may be more confusing. The original wording was
(Page 38 of the Dec 21st Draft):
a.	Finished goods containing HWPW-VC, HWPW-CC, PB, MDF, or thin
MDF produced before the Phase 1 and Phase 2 effective dates
specified in section 93120.2 (a) may be sold, supplied offered for
sale by fabricators for up to eighteen months after each of the
specified effective dates. 

It is now worded as (page 45 of Feb 1st draft):
b.	Finished goods containing HWPW-VC, HWPW-CC, PB, MDF, or thin
MDF that does not comply with Phase 1 and Phase 2 effective dates
specified in section 93120.2 (a) may be used, sold, supplied,
offered for sale by fabricators for up to eighteen months after
each of the specified effective dates. 

This wording change seems to allow a Fabricator to continue using
non-complying composite panels in their manufacturing processes
till June 30th 2010 and sell into California. Do we as a
Fabricator have till June 30th 2010 to comply?

2. The proposed finished product enforcement testing still lacks
validation scientifically.  The lack of data or evidence for the
finished products testing is concerning.  The regulation will be
implemented without sound scientific data correlating raw panel
large chamber testing to a finished product enforcement test.
There are several hundred different board mills in the world and a
thousand different methods to finish a panel. What impact will each
variable have on the finished product testing?  Will each mill have
a different emission factor when sanded?  Do finishes when removed
impact the emission of the sanded composite panel?  Combine both
unknowns and an already large error associated with finished
product emissions testing it may be impossible to know whether or
not a finished composite panel was or was not compliant to the
Regulation.   
3. The regulation does not promote the use of lower emitting
composite products use by the Fabricators.  The regulation gives
the manufacturers incentives to use lower emitting resins for
making composite panels.  However, there is no incentive for the
Fabricators to buy and use those panels.  In a cost-sensitive
market, price is still more powerful than environmentally
friendly.  Studies continue to show that the majority of consumers
will not pay even 1% more for an environmentally friendly product. 
The lower emitting panels will probably have some added cost
associated with them.  If the Fabricator cannot off-set that cost,
Fabricators will not use the lower emitting  products that CARB
would like to promote.   Is there not an off-set possible by
reducing the paper work or tracing requirements or recognition??
4. Will there be more specific labeling requirements, such as font
and size and specific wording for the CARB Phase I Compliant?  
5. Will there be specific wording for Bill of Lading and
Invoices?


Sincerely,

Michael Zimmerman
Senior R&D Chemist
Sauder Woodworking Co.
mzimmerman@sauder.com