The NWFA, along with other members of the Federal Wood Industries Coalition (FWIC), recently signed on to a letter to the EPA regarding EPA’s TSCA Title VI. FWIC is a coalition of industry trade associations representing the entire supply chain of composite wood products and finished goods incorporating these panels and supplier groups.
The letter addresses a concern with EPA’s interpretation of a section of TSCA Title VI referencing testing correlations between a mill and its TPC. Currently EPA staff construes the Regulation to require that routine quality control tests of mills’ panel production be correlated only through reference to a large chamber test methodology — ASTM E-1333. Over the past ten years and more, the industry and the California Air Resources Board have also used an equivalent method — ASTM D-6007 — to establish their correlations. The two methods are equally reliable.
There simply is not the capacity of large chambers in the world to re-correlate hundreds of mills’ quality control procedures. If the position is not corrected, there is a real danger of major disruption in the world-wide supply of composite wood panels, furniture, kitchen cabinets, fixtures, flooring and other finished goods using composite panels. Expeditious relief is sorely needed.
The coalition letter also references the technical arguments made in an earlier CPA letter, but focus predominantly on concerns regarding the potential negative impacts of EPA’s misinformed interpretation of the regulation. The ask in the letter is for immediate relief through a public interpretation (through guidance) of this provision of the regulation that is in line with CARB’s current approach. It was also noted that a formal amendment would be appropriate at a later date to ensure there is no confusion in the marketplace.