First Name | Bill |
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Last Name | Perdue |
Email Address | BillPerdue@ahfa.us |
Affiliation | |
Subject | 15-Day Commwnt on Composite Wood ATCM |
Comment | 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 |
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Date and Time Comment Was Submitted | 2008-02-14 13:56:28 |
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