Phone Conversation with Dave Grulke, Cabinet Makers Association on
11/2/10.

Number of “Fabricators”

Roughly what percentage of all U.S. custom cabinet manufacturing firms
are members of your association?  Are there any characteristics that may
be typical of firms not represented by your organization? For example, a
specific area of the country, or a type of kitchen cabinet or cabinet
construction. About 1% of all cabinet makers. Mainly 10 person or less
shops.

Of manufacturers of wood kitchen cabinets, what percentage would you
estimate use composite wood products (hardwood plywood, particleboard,
or medium density fiberboard) in their cabinets? 100%

Of these manufacturers using composite wood products, what percentage
would you estimate produce at least some product lines that are CARB
compliant because they use CARB certified panels or component parts and
follow the CARB recordkeeping and labeling requirements? Markets are
mainly within 100 miles of home base.  Guess between 50% to 70% of
established professional cabinet shops would be compliant.  These
account for 2/3’s to 3/4’s of the custom cabinet market. Shops
in/near California would be compliant.

Do the manufacturers that are producing CARB compliant product lines
also carry product lines for sale outside of California that are not
CARB compliant?  If, so what percentage of production volume would you
estimate are product lines that are not compliant with CARB because they
do not use CARB certified panels or component parts or do not follow the
CARB recordkeeping and labeling requirements? Don’t know.

Impact of Labeling Requirements

A national regulation of composite wood products could potentially
require manufacturers that use composite wood materials to put a label
on every separate item that gets produced and shipped out.  Given this,
could you estimate the average number of labels that would be needed
annually for each manufacturer that uses composite wood materials? Not
sure.  Raised issue that 50% of the work involves assembling components
on site. How would labeling requirements handle that?

If labels were required for each shipment of products instead of each
individual item, about how may items would be included in a typical
shipment? Don’t know.

Number of Wood Veneer “Laminator Product”  Manufacturers

The recent federal legislation uses the term laminated product to mean a
finished good (such as a custom panel, cabinet, window, door, or piece
of furniture) that is produced by affixing a wood veneer to a purchased
platform.  How many of your members would you say produce such laminated
products by affixing wood veneer themselves?  Please do not include
other types of laminates (such as high pressure laminates, thermally
fused papers, vinyl films, decorative foils, or polypropylene films) in
your answer. Very, very few would do this. This is outsourced. If
someone did this, it might be a very small custom piece that they did.

For those manufacturers that would be classified as wood veneer
laminators, how common is it for these manufacturers to also fabricate
products using purchased panels that were already finished with a wood
veneer or other decorative finish?

What percentage of the production of wood veneer laminated products are
produced using formaldehyde-based resins to affix wood veneers to
purchased platforms?

If wood veneer laminators using UF resins were to switch to a lower
emission resin, what would be the likely resin choice?

Of those wood veneer laminators that use no-added formaldehyde resins,
what are the most common adhesives used? 

If wood veneer laminators were subject to the same third party testing
requirements as CARB, about how many different product types would need
to be third party certified for a typical manufacturer?

General Comments:

CMA recommends delaying rule until economic conditions improve. 

