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As the owner of a small cabinetshop (under $1 million/year
volume)I'm watching this issue with a some interest.

Despite your assurances, I see a larger than comfortable potential
for damage to small shops like mine in several possible ways:

1. The proposal will still allow the importation of non-compliant
panels for use in fabrication of products whose eventual
destination is outside the state. Just as there are unlicensed,
uninsured shops in operation despite the best efforts of the CSLB,
these same shops will likely find ways to procure and use these
non-compliant panels for in-state distribution. Not only does this
have the potential to undercut the small shops with whom these
noncompliant shops would be in competition, but we compliant shops
will be squeezed from the other side as well, sharing the costs of
inspection/compliance/enforcement. Further obfuscating the impact
of this issue is a statement on Page 212, subsection titled
"Cabinets", which seems to imply that compliance with this program
might be voluntary, an unlikely premise given the intent of the
proposal.



2. On page 215, under the subsection titled "Remodeling Project",
you suggest that the panel costs for a $25,000.00 kitchen are
$600.00. This subsection refers to Tables VIII-18 & 19, which
appear to have been omitted from the proposal. Using Table VIII-17
as a reference, one can extrapolate that a $25,000 kitchen, using
3/4" maple plywood pre-compliance pricing of $38, should only
require 15-3/4 sheets of plywood for the entire job, including
countertops. Both the price per sheet and the number of sheets are
understated here, likely by around 20-25% at a guess. This
obviously understates, then, the cost impact of the subsequent
implementation of Phase 2 standards.

I recently read an article in one of the trade journals (I will be
happy to hunt this up and send it along to you, although I suspect
you already have it) which contends that the average person emits
more formaldehyde from his body than do all the wood products
combined in his residence. I mention this, assuming it is true, as
a point of interest and reference.