California Wood Industry Coalition Action Results in CARB Rulemaking Delay

A broad industry coalition has deterred consideration of a California Air Resources Board (CARB) policy change that the Association of Woodworking and Furniture Suppliers (AWFS) executive vice president Dale Silverman says could have a "devastating impact on both the California state economy and the viability of many of our member companies." The targeted CARB policy is the recently proposed Composite Wood Air Toxic Control Measure and in particular, Phase II of that proposal. The proposal would mandate what AWFS calls unrealistically low levels of permissible formaldehyde emissions created during various stages of composite wood and MDF manufacturing.

According to AWFS, unless revised the proposal would lead to the loss of thousands of jobs in the state. The resulting adverse economic impact on the allied industry could reach $1.06 billion per year, according to some estimates.

AWFS says that the recalibration of permissible emissions, as described in Phase II, could threaten local manufacturing and related sales opportunities, resulting in layoffs, business closures and other downturns. AWFS and the coalition are concerned about the balancing of proposed recalibrated emissions ceilings for the manufacture of particleboard and MDF materials and the job impact this is likely to create. The regulation would affect manufacturers and retailers of finished products (no matter where they are produced) that contain any amount of these materials, as well as raw panels manufactured or sold within the state. California and other U.S. companies would be burdened by the proposed ruling, viewed by many experts as technically unreal and unenforceable when it comes to policing offshore products.

"A variety of economic models have been authored and, regardless of the low-to-high values these present, it is clear that passage of Phase II would seriously damage California's economy and the woodworking industry throughout North America," said Silverman. "The only people possibly benefiting from this rule are a few companies that have developed costly formaldehyde free niche products as well as offshore manufacturers that produce their goods in uncontrolled environments and then would sell them in California at lower manufactured cost because there is no viable offshore enforcement plan."

CARB officials listened to industry criticism and postponed final hearings originally scheduled for August and September. CARB's next public workshop and release of an updated fact sheet is now for scheduled September 15, 2006 and their public board hearing is now on January 25, 2007.

AWFS' immediate goal now is to garner member support against this rulemaking proposition. AWFS agrees that the industry can live with reasonable emissions regulations and it supports all efforts to determine what those appropriate emissions levels may be and to develop an implementation schedule that enables industry to accommodate change without losing market or business opportunities to lower priced and unregulated off-shore products. AWFS's message to members is to understand and communicate to legislators and others:

  • The ATCM Phase II recalibration is being pursued without any demonstration of health benefits, and technological and economic feasibility - above all - it is being considered without regard for potential harm to California manufacturing and jobs … and the likelihood of higher prices for consumers.
  • CARB has failed to demonstrate how it would police in a manner to prevent cheating by importers of products made with composite wood manufactured offshore and not in compliance with CARB policies.
  • Achieving dramatically lower emission levels as called for by Phase II will require the adoption of mass-production technologies not available or feasible today for the broad industry. It will also require the adoption of unproven adhesive systems - whose safety impact is yet to be evaluated
  • Hence - Phase II should be comprehensively understood by members and their elected officials. By burdening small to mid-size companies with a technological hurdle that cannot be met by even the largest manufacturers and specialty companies, CARB is making the composite wood and MDF playing field uneven at best.

AWFS will remain an active voice within the CWIC community. We are optimistic that reason will prevail and that CARB will come to understand the full economic and political dimensions of this mis-guided effort to redraw the emissions map when it comes to the production of composite wood and MDF products. AWFS and its members appreciate CARB's timeline extension to permit full discussion of this important issue," Silverman concluded.

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