ICR Appendix E1: Instructions for Survey Instrument for Hardboard And Structural Composite Manufacturers

United States Environmental Protection Agency

Pressed Wood Manufacturing Industry Survey:
Hardboard and Structural Composite Manufacturers
General Information, Definitions, and Instructions

Thank you for participating in EPA’s pressed wood manufacturing industry survey.
Please return the completed response no later than Weekday, Month Day, Year.
Please contact William Silagi at [email protected] or (202) 564-8788 if you have
any questions about this survey.

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GENERAL INFORMATION

Respond for Individuals Plants. This questionnaire was designed to gather data for individual
manufacturing plants, not all the plants operated by a parent company or company headquarters.
(However, you may need information from a parent company or company headquarters in order to
complete the questionnaire.) Please provide responses that are specific to your plant only, as
identified on page 1 of the questionnaire. If you are completing the questionnaire for multiple plants
owned by the same company, please use a separate questionnaire for each plant.
Plants Making Other Products. This questionnaire is designed to collect information on hardboard
and structural composite products. If your plant also manufactures other composite wood products
(i.e., hardwood plywood, medium density fiberboard, or particleboard), you should receive a separate
questionnaire. If you need a copy of the other questionnaire and did not receive one, please contact
EPA.
Skills Needed to Report. This questionnaire is intended to be completed by a person knowledgeable
about both the technical and financial aspects of the pressed wood products manufacturing operations
at your plant. In some cases, you may need to look up records or consult staff in other departments to
complete all the information requested.
Use Readily Obtainable Information. This questionnaire asks for readily obtainable information,
e.g., information known or easily accessed by technical, managerial, or supervisory employees of
your company who are responsible for manufacturing, processing, technical services, or marketing. If
you do not have the underlying information, you do not have to generate it to complete the
questionnaire. For example, the questionnaire asks for information on formaldehyde emission levels
from your products. If you have not already tested your products for formaldehyde emissions, you do
not need to test them in order to respond to this questionnaire. In this example, if you do not have any
formaldehyde testing data, you would report “UK” (for “Unknown”) on the questionnaire.
Suggested Recordkeeping. Participation in this questionnaire is currently voluntary, so that you are
not required to respond. If you do respond, you are not required to keep any records to document
your response. You may, however, wish to keep a copy of the completed questionnaire for your files
to refer to in case EPA contacts you with any follow-up questions to clarify your answers later in the
process.

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CONFIDENTIAL BUSINESS INFORMATION
Under section 14 of the Toxic Substances Control Act (TSCA), you may designate
information that you submit on this questionnaire as Confidential Business Information (CBI).
EPA takes stringent measures to protect CBI submitted in connection with TSCA pursuant to part 2
of title 40 of the Code of Federal Regulations (known as 40 CFR part 2) and the TSCA CBI
Protection Manual. These procedures include security clearance and training for all staff permitted
to access TSCA CBI, storage of TSCA CBI in secured areas, computer security for TSCA CBI,
secure methods for creating, transferring, and destroying TSCA CBI, and advance notice of
disclosure to contractors (usually via the Federal Register) where such disclosure is authorized.
Access to TSCA CBI is limited to persons who are TSCA CBI cleared.
EPA will disclose information that is covered by a claim of confidentiality only to the
extent permitted by, and in accordance with, the procedures in TSCA section 14 and the regulation
at 40 CFR part 2, which provides advance notice and an opportunity to object prior to public
disclosure. Otherwise, confidential data provided by individual companies will not be identified in
summary reports or released to unauthorized individuals, and public dissemination of results based
on TSCA CBI will be limited to aggregate statistics that do not disclose confidential data.
Please assert CBI claims only where there is a legitimate need to do so. In general,
voluntarily submitted information is entitled to confidential protection where the information would
not customarily be disclosed to the public, although authorities in TSCA Section 14 may apply.
To identify data as CBI, simply check the box in the left-hand margin on the
questionnaire form next to each question where you provide CBI. For example, as shown in
Figure 1, if the total volume of glulam manufactured by your plant is confidential, then check
the box at the left of Question #9(a). Please note that information not specifically identified as
CBI may be made available to the public without further notice.
If you claim any information in your response as CBI, see the enclosed instructions on how
to assemble your completed questionnaire and return it to EPA.
In order to ensure the protection of CBI, please do not e-mail any data or materials
that you designate as CBI.

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Figure 1. Example of CBI Checkbox Marked to Claim Data as Confidential

Mark the CBI checkbox in the left-hand margin of the questionnaire form (indicated by the
red arrow in the figure below) to claim information you provide as confidential.

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Figure 2. Example of How to Generate Additional Copies of a Questionnaire Section or Table
If you need to fill out more than one copy of a section in the questionnaire, or need more
space than a table provides, click the “Add Copy” button to have the electronic version of the form
automatically generate an additional copy of the section or table. If you are using the paper version of
the form, please use the extra copies provided and make additional copies as necessary.

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GENERAL DEFINITIONS
Additive. Additives to composite panel products include, but are not limited to, biocides, buffers, catalysts, fire
retardants, release agents, scavengers, tack agents, and wax emulsions.
Adhesive/emissions class. Adhesive/emissions class means a class of pressed wood products that differs from
others based on binder/resin technology, formaldehyde emission certification standard category, and/or
formaldehyde emission profile.
Catalyst. An additive to a resin formulation that allows the resin to cure faster or harder than it otherwise
would.
Composite panel products. See “Pressed wood products” definition.
Finished board. Primary composite panel product, not secondary or value added products.
Formaldehyde emission certification standard category. The emission standard you meet (if any) that
requires the lowest product formaldehyde emissions. Examples include the European E1/E2 standards; the
Japanese F-star standards; and the HUD standards
Glulam. Glued laminated timber, also known as “glulam”, is an engineered column, beam or other structurallyrated product created by bonding together individual small pieces of lumber in long lengths and deep depths.
Considered a primary composite panel product for the purpose of this survey.
Hardboard. A primary composite panel product manufactured mainly from interfelted lignocellulosic fibers
(usually wood), consolidated under heat and pressure in a hot press to a density of 500 kg/m3 (31 pounds per
cubic foot) or greater to meet the performance requirements specified in ANSI A135.4. Some hardboard
products may exhibit a density of up to 1000 kg/m3 (62.5 lb/ft3).
I-joists. An assembly of primary composite panel products made for structural or construction applications.
The I-joists may be of any dimension but are normally composed of LVL or lumber flanges and OSB or
softwood plywood webs. An adhesive is used to join the flanges to the web.
Oriented Strandboard (OSB). A primary composite panel product manufactured of cellulosic wafers or
strands, usually wood, and a bonding system, purposefully arranged in layers oriented in specific directions, and
cured under heat and pressure.
Other Structural Composite. A composite panel product manufactured at your plant, other than glulam,
hardboard, I-joists, oriented strandboard, softwood plywood, or structural composite lumber.
Plant. Physical facility (consisting of one or more buildings, processes, and assemblies of equipment) where
composite panel products are manufactured.
Planned change. Changes that are likely to occur (you are confident that they will be undertaken) – as opposed
to future “possible” projects which may or may not ultimately be executed. Planned changes include expansions
or equipment upgrades/changes in the next three years.
Pressed wood products. General term describing all types of primary and secondary composite panel products
made from cellulosic material, usually wood, and an adhesive or resin bonding system that is cured under heat
and/or pressure.
Primary composite panel products. See “Primary pressed wood products” definition.

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Primary pressed wood category. A type of primary composite panel product. In this questionnaire this
includes the following products: glulam, hardboard, i-joists, oriented strandboard ,softwood plywood, laminated
veneer lumber, laminated strand lumber, parallel strand lumber, oriented strand lumber, ad other structural
composites. This questionnaire does not pertain to the following three products: hardwood plywood, medium
density fiberboard, and particleboard (These products are covered in a separate survey). There may be multiple
product grades or adhesive/emissions classes within a primary pressed wood category. (See definition of
“Adhesive/emissions class.”)
Primary pressed wood products. General term describing all types of primary products made from cellulosic
material, usually wood, and an adhesive or resin bonding system that is cured under heat and/or pressure.
Primary composite panel products may be used in either industrial or construction applications in their
“primary” form, or converted into “secondary” composite panel products through the application of a laminate,
or coating, or through shaping or assembly with other components.
Production technology. The production process and raw materials used to produce a composite panel product.
This includes the resin technology used (defined below).
Resin technology. The particular resin formulation (including scavengers and additives) used and its direct
integration into the manufacturing process, including associated process controls and preparation, application,
and/or blending equipment.
Scavenger. An additive to a resin formulation that is intended to combine with free formaldehyde to convert it
to an inert reaction product
Softwood Plywood. A primary composite panel product made up of relatively thin layers of veneer, usually
wood, glued together with the grain of adjacent layers at right angles, or a combination of veneers and other core
material such as particleboard, MDF, or lumber. Softwood plywood may be made with any wood species and a
durable adhesive system rated for structural or exterior exposure applications.
Structural composite lumber (SCL). A family of engineered wood products created by layering dried and
graded wood veneers or flakes with waterproof adhesive into blocks of material known as billets. Includes
laminated veneer lumber (LVL), laminated strand lumber (LSL), parallel strand lumber (PSL), and oriented
strand lumber (OSL).
Ultimate parent company. Highest level company, group of companies, or other legal entity that owns or
directly controls the reporting facility or plant, either within the U.S. or globally (if applicable). For example,
this may be the company that is quoted on a stock exchange.

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LIST OF ABBREVIATIONS
Abbreviation
CBI
N/A
NAF
ton
UA
UK

Description
Confidential business information
Not applicable
No-added formaldehyde
Ton (2,000 pounds = 1 ton)
Unavailable
Unknown

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SURVEY OUTLINE
The questionnaire has four sections:
1. General Manufacturer Identification Information;
2. Products Manufactured;
3. Recent or Planned Changes Resulting in Lower Formaldehyde Emissions; and
4. Issues That May Affect Ability to Reduce Formaldehyde Emissions or Switch to a NoAdded Formaldehyde (NAF) Resin.
The questions in each section are described in detail in the “Question-by-Question Instructions”.

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QUESTION-BY-QUESTION INSTRUCTIONS
Please answer all of the questions. Refer to the “General Definitions” section for further explanation
of certain key terms used throughout the questionnaire.

Section I: General Manufacturer Identification Information
Questions 1- 8.
The answers to the questions in this section have been pre-filled based on publicly available
information and the initial phone call to your plant. Please verify that the pre-filled information is
correct; if it is incorrect, or if there is any missing information, please provide corrections on the
line(s) following the question or check the appropriate boxes.
See the definition of “ultimate parent company” in the General Definitions section before answering
these questions.”

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Why does EPA need this information? The information in Section I will be used to
ensure that your plant is properly identified and that the appropriate contacts are
available to answer any questions that EPA might have on the completed
questionnaire. Because of the complex relationships between and among
corporations, you are asked to distinguish between the parent company (legal
owner) of the plant and the company that operates the plant. Information about the
legal owner may be used by EPA in economic analyses that distinguish between
small and large businesses.

Section II: Primary Pressed Wood Products Manufactured
In this questionnaire, “primary pressed wood product” refers to all “primary composite panel
products” except hardwood plywood, medium density fiberboard, and particleboard (which are
covered in a separate questionnaire). Primary composite panel products include all types of primary
products made from cellulosic material (usually wood) and an adhesive or resin bonding system that is
cured under heat and/or pressure. These products include, but are not limited to glulam, hardboard, Ijoists, oriented strandboard, softwood plywood, laminated veneer lumber, oriented strand lumber,
parallel strand lumber, and laminated strand lumber.
See the definitions of “adhesive/emissions class,” “resin technology,” “production technology,”
and “planned change” in the General Definitions section before answering these questions.”
Question 9. Primary Pressed Wood Products Manufactured and Production Volume.
Please complete the table. Note that in column 3 of Question 9 you need only to provide the
aggregate estimated average volume of primary pressed wood products manufactured at your plant
(over the five year period between 2005 and 2009) for each of the pressed wood categories you make,
summed over all thicknesses produced.
Question 10. Resin Types and Certification Standards.
Please aggregate the information by adhesive/emissions class for each pressed wood category
produced at your facility – that is, complete one row for each group of products with similar
formaldehyde emissions profiles. A list of binder/resin categories and certification standard
categories is provided at the bottom of the table.
NOTE: Please complete this table for each adhesive/emissions class of each pressed wood category
that has been produced at your facility in the last five years or that you plan to produce in the next
three years.

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If you need more space than the table provides, click the “Add Copy” button to have the electronic
version of this form automatically generate an additional copy of the table. If you are using the paper
version of the form, please use the extra copies provided and make additional copies as necessary.
Column 1: Pressed Wood Category. Indicate the pressed wood category by selecting from the
dropdown menu on the electronic form or entering the appropriate pressed wood category
abbreviation listed below the table. If selecting the “Other Structural Composite”
category, please specify the type of product for which you are reporting. Electronic form
users can click on the applicable cell after selecting the “OTR:” category from the
dropdown menu to enter a description of the product.
Column 2: Adhesive/Emissions Class. Indicate the adhesive/emissions class. The different
adhesive/emissions class can simply be numbered (as in the example) or labeled more
descriptively if desired (e.g., sheathing).
Column 3: Binder/Resin Category. If you use, have used, or will use more than one resin technology
or production technology for a pressed wood category, list all that are applicable in
separate rows.

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For example: If last year you produced all your OSB using a PF resin, and you
currently continue to produce OSB using the same resin formulation, but now you
also produce a no-added formaldehyde class of OSB using a pMDI resin, you should
complete two rows in the OSB category (one for each adhesive/emissions class of
OSB you produce).

Column 4: Emission Certification Standard Category. Indicate whether this pressed wood
adhesive/emissions class meets any formaldehyde emissions standards (European E1,
Japanese F-star, etc.). In this survey, the “formaldehyde emission certification
standard category” means the emission standard you meet that requires the lowest
product formaldehyde emissions. If your product does not meet an emissions certification
standard, enter “None”.
Column 5: Adhesive/Emissions Class Produced in last 5 years. Indicate whether the class of
products was produced in the last five years (“yes” or “no”).
Column 6: Adhesive/Emissions Class Produced this year. Indicate whether the class of products was
produced this year (“yes” or “no”).
Column 7: Adhesive/Emissions Class Produced 3 years from now. Indicate whether the class of
products is expected to be in production three years from now (“yes” or “no”).
Columns 8 and 9: Average and Maximum Formaldehyde Emission Levels from Finished Boards.
Indicate the average and maximum formaldehyde emission rates for finished boards. If
you have been making the adhesive/emissions class for a year or more, calculate the
average and maximum emissions over the past year. If you have not been making the
product for a full year, calculate the average and maximum over whatever time frame you
manufactured the adhesive/emissions class. If you do not regularly test formaldehyde
emissions rates, but have performed one-time or occasional formaldehyde emissions
testing, calculate the average and maximum formaldehyde emissions rates using available
test results.
For the maximum emission level, report the actual maximum level measured, not the
maximum allowed by a certification standard (if any). In addition, the emissions levels
reported should only include those from tests performed within 30 days of production.

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Column 10: Measurement Method. List the “measurement method” that is used to measure or test
the emission levels. This is usually a standardized laboratory method or testing protocol,
such as those published by the American Society for Testing and Materials (ASTM).
Provide the test standard number/abbreviation, or a descriptive title for the method that
you use. See Figure 4 at the end of these instructions for examples of common test
measurement methods.

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For example: If you use ASTM E1333 - 96(2002) Standard Test Method for
Determining Formaldehyde Concentrations in Air and Emission Rates from Wood
Products Using a Large Chamber to measure the formaldehyde emissions from
oriented strandboard, then in the “OSB” row(s), enter “Large Chamber Method,
ASTM E1333-96”. If you use the European perforator method to measure
formaldehyde emissions from glulam, in the “GL” row(s), enter “EN 120 European
Perforator Test.” See Figure 4 at the end of these instructions for more examples of
common test measurement methods.

Columns 11 and 12: Share of Production. Please provide the relative share of production volume for
each adhesive/emissions class. In column 11, provide the total annual production share
using the current binder/resin technology and production process, in percent. For
example, if four fifths of your production is for a given adhesive/emissions class, enter
“80%”. The sum of the shares reported within each pressed wood category should equal
100 percent.
In column 12, report the estimated annual production shares that are anticipated after any
planned changes to raw materials and production processes to reduce formaldehyde
emissions are completed, whenever the change is planned to occur. (For example, if you
have a change planned for 2011 that will reduce formaldehyde emissions, report the
production shares expected for 2011.)
If no planned changes to reduce formaldehyde emissions are anticipated, report the
estimated annual production shares that are anticipated in 2012. For example, if you plan
for all of your production of the pressed wood category to be the given adhesive/emissions
class in the future, enter “100%”. If you do not know what the future shares of production
will be, enter “UK.” The sum of the shares reported within each pressed wood category
should equal 100 percent.

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Why does EPA need this information? Question 10 provides information on the
formaldehyde emissions levels from hardboard and structural composites, trends,
and the relative importance of different classes of products. This information will
help EPA to determine whether or not to take any action regarding formaldehyde
emissions from these products.

Section III: Recent or Planned Changes Resulting in Lower Formaldehyde Emissions
Question 11. Have you made any recent changes (since 2005) to production processes or raw materials
that resulted in lower product formaldehyde emissions?
Please check all applicable boxes.
Question 12. Do you plan to make any changes in the next three years to production processes or raw
materials expected to result in lower product formaldehyde emissions?
Please check all applicable boxes.

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Why does EPA need this information? The information in Questions 11 and 12
will be used to assess the extent to which formaldehyde emissions are being
reduced in the absence of any EPA action and if so, why.

Section IV: Issues That May Affect Ability To Reduce Formaldehyde Emissions or Switch to a
No-Added Formaldehyde Production Technology
Question 13. Issues That May Affect Ability to Reduce Formaldehyde Emissions
Please complete a separate copy of Question 13 for each primary pressed wood category manufactured
at your plant that is manufactured with added formaldehyde.
If the issues you would need to address in order to reduce formaldehyde emissions vary within a
pressed wood category, a separate copy of Question 13 can be completed for each group of products
within a pressed wood category where similar issues would need to be addressed.
Click the “Add Copy” button on the survey to have the electronic version of this form automatically
generate an additional copy of Question 13. If you are using the paper version of the form, please use
the extra copies provided and make additional copies as necessary.
Question 14. Issues That May Affect Ability to Switch to NAF Production Technology
Please complete a separate copy of Question 14 for each primary pressed wood category manufactured
at your plant that is manufactured with added formaldehyde.
If the issues you would need to address in order to adopt a NAF resin technology vary within a pressed
wood category, a separate copy of Question 14 can be completed for each group of products within a
pressed wood category where similar issues would need to be addressed.
Click the “Add Copy” button on the survey to have the electronic version of this form automatically
generate an additional copy of Question 14. If you are using the paper version of the form, please use
the extra copies provided and make additional copies as necessary.

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Why does EPA need this information? If EPA determines that it should
address formaldehyde emissions from hardboard or structural composites, the
Agency will use the information from Questions 13 and 14 to determine the
technical and economic feasibility of potential actions.

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Figure 4. Common Standard Test Methods for Formaldehyde Emissions
Figure 4 presents some examples of common standard test methods. Note that this list may not be
complete.
Number
ASTM E 1333-96
ASTM D 5582-00
ASTM D 6007-02
EN 120
EN 717-2
JIS A 1460
DMC
EN 717-1
EN 717-3
ISO/DIS 12460
JIS A 1901

Description
Standard Test Method for Formaldehyde Concentrations in Air and Emission Rates
from Wood Products Using a Large Chamber
Standard Test Method for Determining Formaldehyde Levels from Wood Products
Using a Dessicator
Standard Test Method for Determining Formaldehyde Concentrations in Air and
Emission Rates from Wood Products Using a Small Chamber
Wood based panels—determination of formaldehyde content—extraction method
called perforator method, European Standard
Wood-based panels—determination of formaldehyde release—Part 2: formaldehyde
release by the gas analysis method, European Standard
Building boards. Determination of formaldehyde emission—desiccator method,
Japanese Industrial Standard
Dynamic Microchamber Test method by Results Technology Inc.
Wood-based panels—determination of formaldehyde release—Part 1: formaldehyde
emission by the chamber method. European Standard.
Wood-based panels—determination of formaldehyde release—Part 3: formaldehyde
release by the flask method, European Standard
Wood-based panels — Determination of formaldehyde release — Part 4
Determination of the emission of volatile organic compounds and aldehydes for
building products—small chamber method, Japanese Industrial Standard

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