KCMA ESP Webinar October 27, 2009
List of Questions & Answers
Note correction on Slide #51. It should read:
Panel Products, proof of compliance
Statements on Invoices (preferred)
CARB ATCM Paper Trail (NOT-CARB MACT Paper Trail)
1. Does being ESP compliant qualify for LEED points?
2. How does ESP compare with FSC?
3. I get a lot of "can you provide LEEDS points" questions from my customers.
Some ESP certified cabinets may meet LEED requirements, but ESP certification itself
does not automatically contribute to LEED points. Cabinets can contribute to LEED
points only if they are manufactured with Forest Stewardship Council (FSC) certified
wood and have no added formaldehyde. The LEED specifications raise serious issues
concerning materials availability, extra cost, questionable performance and durability,
and possible substitution of adhesives with their own safety or health issues. LEED
certified cabinets are generally much more costly than more readily available ESP
The KCMA ESP differs from LEED in that it recognizes other than just FSC for
sustainable forest management points. It has been well-documented by independent
auditors that FSC is not the only credible and proven sustainable forest management
system. In addition, KCMA’s ESP takes a more holistic approach to environmentally
responsible cabinetry, examining the impact of the manufacturing process, the company’s
involvement in the community and the product.
4. I am seeing LEED referenced on specifications from architects, but not ESP very
often. Is there an effort underway to introduce ESP to architects or to have the
USGBC recognize or reference ESP?
USGBC/LEED has been approached and requested to reference ESP as the NAHB Green
Standard does. USGB has declined to reference ESP and still references only “no added
formaldehyde” cabinets. There have been efforts to educate architects re ESP.
5. When you state two invoices per product, are you referring per product category
such as composite, particle board or MDF?
Two invoices are required for each particleboard manufacturer, each MDF manufacturer,
each hardwood plywood veneer core manufacturer, each hardwood plywood composite
6. Is that 2 tags per inventory item or just 2 tags for plywood, particleboard, MDF?
Currently CARB requires you keep records for two years. Would you rather keep two
years of unit tags or two years of invoices (which your accounting department already has
to keep for more than two years)? As for volume of support, please see the answer to
7. MDF core material that has a laminate 1 side and a veneer 1 side, should it be
counted under HWPW Composite panel or MDF panel?
The Hardwood Plywood Veneer Association would consider this hardwood plywood –
8. Does KCMA require Third Party Certifications?
From the very beginning of the KCMA ESP Program, third party certification of panel
products was required and continues to be required. The ESP program is certified by an
independent ANSI-approved third-party auditing organization.
9. Bamboo is a renewable resource. Is there a way to get points for the use of
Trees also are a renewal resource. There is no current provision in the standard to
address bamboo. The ANSI/HPVA HP-1 Hardwood Plywood revision that is currently
in the review process addresses “woody grass” as a category of hardwood plywood.
It might be of interest to you that there is a growing effort within the LEEDS community
to remove the bamboo credit due to the transportation carbon footprint (6,000 miles by
ship when cabinet manufacturers are penalized for shipping cabinets over 500 miles).
10. Are you considering credit for solar panel installations?
That would be an item claimed under an energy conservation program (III.D.)
11. Import plywood is cheaper than domestic for interior panel products. What
domestic manufacturers have comparable products?
Contact the Hardwood & Plywood Veneer Manufacturers Association www.hpva.org and
request their “buyers guide.”
12. Who is the CPA MDF approved manufacturer?
The list of particleboard, MDF and hardboard manufacturers certified by CPA can be
13. What is your definition of hardboard?
The ANSI A135.4 definition of Basic Hardboard is “a panel manufactured primarily from
inter-felted lignocellulosic fibers which are consolidated under heat and pressure in a hot-
press to a density of 31 pounds per cubic foot or greater. Other materials may be added
to improve certain properties, such as stiffness, hardness, finishing properties, resistance
to absorption and moisture, as well as to increase strength, durability, and utility.”
14. What is the definition of recycled/recovered fiber?
Pre-Consumer Recycled includes fiber generated as a waste from manufacturing and
converting processes such as scrap, trimmings and cuttings that have been diverted from
the solid waste stream following the manufacturing and converting process. This material
must have undergone processing before becoming a waste to be included in this category.
Examples of this category include planer shavings, plytrim, sawdust, fines, chips and
Post-Consumer Recycled includes fiber from products that have completed their life as a
consumer item and have been diverted or recovered from the solid waste stream after
having been used and/or disposed of by the consumer following their intended use.
Examples of this category include used pallets, recycled furniture and cabinet waste,
construction waste and demolition waste.
Fiber in this category has been recovered as a by-product of an agricultural crop or
public/private tree maintenance program where the fiber generated is used on a secondary
basis not related to the original agricultural or ornamental function. For definitional
purposes, this fiber has been sub-categorized as wood and non-wood.
15. One of the “New” items was Hardboard. I am somewhat confused as to why this
is included. For Hardboard, the majority of the bond between the wood fibers is it
own lignin, and what resin that is used is phenol formaldehyde, the same glue to make
exterior plywood. As we know, phenol formaldehyde has no emission of
Some manufacturers claim they were using this hardboard product as cabinet backs
instead of thin MDF and requested that the KCMA ESP Committee add this product for
points. Since it is difficult to identify and distinguish this product from thin MDF after
installation in the cabinet, and the knowledge that at one time some manufacturers made
thin MDF and called it hardboard to avoid HUD Manufactured Home Regulations, the
ESP committee decided to also require it to be third party certified.
In the ten months this hardboard provision has been in the standard, no participant has
claimed it. The ESP Committee discussed this and decided to let it ride for another year.
If at that time there are no claims for using it, they will remove it from the specifications.
16. Can by-products be used for heating?
Yes, and claimed under III.C.
17. What about formaldehyde free as related to Indoor Air Quality?
Wood emits small amounts of formaldehyde. If it is wood, it is not “formaldehyde free.”
CARB defines “no added formaldehyde products” and “ultra low formaldehyde”
composite wood products which still need to be third-party tested and certified. KCMA
ESP 03-10 will award points for their use as well as points for other CARB complying
18. Points are awarded for using forestry certified material. However, the market
demand may not supply at least a 10% production of this type of product offering.
Has there been any consideration to awarding points to a manufacturer who offers
a product line that offers a foresty certification?
This ESP program operates on a plant or brand basis. If you have a specific “brand” that
utilizes a high percentage of chain-of-custody certified sustainable forestry material, you
can bring this brand in individually and claim those points. However, this brand must
still earn the required 80 points.
19. Regarding New Applicants, you noted that the Panel worksheet needs only show 4
months worth of data. Does the 4 month requirement also apply to recycling,
community service, etc?
Yes. While you are reporting on the four month spreadsheet, you should also be
collecting at least four months of other proof also.
20. Do purchased assemblies (waste basket kits) that contain plywood/particleboard
parts count towards the Air Quality / Resource Management points?
CARB requires compliance for ALL particleboard, MDF and hardwood plywood sold in
California. Those parts should also be included to generate the 80% compliance for
KCMA ESP 03-10.
21. Concerning ESP and plywood manufacturers, is there any way that cabinet
manufacturers benefit from purchasing materials from a supplier who has the esp
Since suppliers only have to prove 80% production or consumption, cabinet
manufacturers would still be required to keep their own proof of compliance paper trail
because: 1) CARB requires it, and 2) they need to prove they did not get the other 20% of
the supplier’s product.
22. Can we just have one line of product be ESP certified as opposed to our entire
Yes, come in as a brand.
23. Are January 2010 Carb Levels Carb 1 or Carb 2
24. Can you elaborate how is ESP related to CARB timeline of PHASE 1 and PHASE
As of July 1, 2009 all panel producers must be making Phase 1 material.
Phase 2 implementation dates for panel manufacturers are:
January 1, 2010 – Hardwood plywood veneer core (0.05 ppm)
January 1, 2011 – Particleboard (0.09 ppm), MDF (0.11 ppm)
January 1, 2012 – Thin MDF (0.13 ppm)
July 1, 2012 – Hardwood plywood composite core – (0.05 ppm)
KCMA will follow the CARB timeline for fabricators. If the cabinet manufacturers
(fabricators) change over earlier than the CARB deadline, KCMA has provisions to
25. Do you have a forecast for the cost increase for continued ESP Certification?
As you probably know, more than 80% of the ESP revenue goes directly to marketing
efforts. It also requires the allocation of considerable staff time and other support
activities which are heavily subsidized by other KCMA programs. Both the Board of
Directors and ESP Committee recognize that at some point in time, the ESP program will
have to be self supporting just as the ANSI/KCMA A161.1 Performance Certification
Program has been for forty years. That “time” has not been determined by the Board
and very likely will not be determined until the industry recovers from the current
26. Why produce a spreadsheet for documentation when I could submit you invoices
that confirms and validates compliance?
The manufacturers will need a spreadsheet or some other method to determine that the
required percentage of panel products is met. KCMA is just trying to build on that.
Some large manufacturers could send a 50 page spreadsheet with 30 invoice entries per
sheet – representing 1,500 invoices. KCMA does not have the staff capability to
calculate percentages from such a volume of invoices. The purpose of the spreadsheet is
the permit a quick review of consumption with sample invoices (that can be found on the
spreadsheet) to verify the data.
27. Why can't we e-mail you all the requested documentation?
The supporting data is seldom submitted in chronological order. Many claims can refer
back to a single document such as a policy statement or an EMS program. KCMA has
yet to review an application without going backwards to verify an item. This would
create inefficient utilization of time trying to scan back several pages on a computer
screen that shows only ½ a page. Such a provision would also increase the time it would
take the independent auditor to review a file during their annual inspection.
28. Are larger companies required to submit a spreadsheet of the thousands of
invoices they receive each year?
Yes, the same provisions and requirements apply to all participants regardless of size.