The proposed rules, released for public comment in May, are intended to implement the Formaldehyde Standards for Composite Wood Products Act, signed by President Obama in 2010.
"EPA’s proposals will be a jobs killer for American manufacturing due to the agency’s departure from what was intended by Congress, and that must change," said Tom Julia, CPA president.
CPA argues that EPA’s rules must strengthen the global Third Party Certifier (TPC) system that was established by CARB in 2008.
EPA has also proposed a complete stoppage of commerce where there has been an indication of a non-complying event at the initial source of panel production, but CPA proposes that EPA require extensive formal notice.
EPA has further proposed a dramatic expansion of CARB’s regulation of businesses using hardwood plywood in their production. CPA’s counter-proposal would require them to demonstrate the chain-of-custody use of compliant composite panel cores that already adhere to emission limits.
Notwithstanding a Congressional directive EPA chose not to write a de minimis exemption into its proposals. CPA has proposed a specific formula for addressing components, intermediary and finished products that contain a very small amount of composite wood by weight or volume.
