August 17, 2010 Mr. Michael O`Reardon ICC Evaluation - ICC-ES

August 17, 2010
Mr. Michael O’Reardon
ICC Evaluation Service, Inc
900 Montclair Road, Suite A
Birmingham, AL 35213
RE: Comments to AC 326 Proposed Changes to Section 5.2
Dear Mr. O’Reardon:
In response to proposed language changes to AC 326, Section 5.2, I would like to offer the
following comments.
Wood is not a manufactured product, it is a naturally grown product and with that comes inherent
variabilities that cause fluctuations in penetration and retention levels. Third party inspection
methods used under AWPA (American Wood Protection Association) have worked well to identify
these variabilities and judge the performance fairly among treating plants. In understanding that
wood has variability then what is the probability that we can meet a 95% conformance rate to
retention levels continuously in a reasonable manner? The proposed language does not
address probability, but enforces with a time delayed process that has the potential to place much
substandard product in the market. Furthermore, any adopted system needs to be clearly
defined and tested to prove its effectiveness.
The assumption can be made based on the revised language that there have been in service
failures of pressure treated forest products but none has been disclosed to my knowledge. The
emphasis on the revised language focuses on short falls of required retention levels of
preservative. This can be construed that current retention standards are such that there is an
insufficient safety factor built in for probability that there will be variabilities in treatment.
Maintaining a high quality standard for our industry is important and if we can improve our current
system then we should but I don’t agree instituting any untested system is a rational course of
action (measure twice, cut once).
Quality assurance seems comes under scrutiny due to the variability in wood. Two possible
alternatives to create an improved method might be:
1. Increase ESR retention levels to accommodate variability under the current evaluation
method.
2. Incorporate the LCL method proposed by AWPA T7 Task group that will evaluate overall
plant performance with a delineated process for corrective measures.
I think it is important to note that the latter addresses most all other concerns presented, however
it does present some challenges for small and even mid-size production facilities with low
production volumes, I think some well spelled out measures could be put in place to easily over
come this. Also, keeping in mind that this is a voluntary program helps to keep in perspective that
not all material produced by a treating plant is destined for code approved purposes and therefore
in the spirit and logic of the program it would seem that proprietary labeling remain outside of this
program. In saying this, the proven method finally chosen in this regard will have a direct impact
on how much material that is destined for code approved use is tagged as such. An effective
program will reduce, not increase this. If a 95% retention conformance rate ends up being
unreasonably achievable, is it likely to assume that even more generically labeled product will
reach the marketplace? If this is the case, and the objective is to maintain a standard of quality
knowing there will always be variability in wood, then the practical method of choice might be
option one. Another point to mention is the ICC and AWPA should have congruency and
connection along with a monitoring agency like the ALSC that would further the cause of quality
assurance.
Sincerely,
Richard J. Hales
Richard J. Hales
Director of Treating Operations
John A. Biewer Co. of Illinois
Biewer of Lansing, LLC
6111 W. Mt. Hope Hwy.
Lansing, MI 48917
517-322-3835
Fax: 517-322-3840
www.biewerlumber.com
September 3, 2010
Mr. Michael O’Reardon
ICC Evaluation Service, Inc
900 Montclair Road, Suite A
Birmingham, AL 35213
RE: Comments to AC 326 Proposed Changes to Section 5.2
Dear Mr. O’Reardon:
There are several points in the current proposed method I feel need to be addressed;
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Variability and Probability – they should not be separated.
Accountability – 3rd party overseer needed in the field and further attention in
the laboratory.
Clarity – much clarity is lacking in the currently proposed method.
Untested method – Haste to an untested methodology may be unwise.
Congruency – ICC and AWPA need to use the same methodology.
Variability and Probability
As we are all aware, wood is a natural grown material that has many variables prior to
treatment that help create the issue of variability. From sub-species within specie groups,
to forestry practices, climate and soil differences of where the trees are grown, to sawmill
practices,…wood is variable. If there is no argument with this, then how is it we could
measure the success of wood treatment, that has to overcome these variables, with a
system that measures on absolutes versus using a system based on probability? It could
be said that it could be managed through sample size, and although I believe this would
help, in the end, wood is still variable. It may be more reasonable to measure the
probability of wood treatment success or failure. The currently proposed system does not
address this properly.
Accountability
The current proposed system shows no field accountability system for the 3rd party
agencies. This is recognized in the AWPA with the presence of the ALSC. This is an area
of great importance. It solidifies the completeness of a program by holding accountable
the 3rd party agencies and their inspectors. The success and the reasons the ALSC
program were instituted stand as a very important example of the need for this.
Furthermore, the inspection process at the laboratory level should include actual
confirmation of tested samples with cross sampling being done in unannounced visits just
as wood treatment facilities experience. What is the point of auditing just a laboratory’s
practices/methods without also verifying that their results are accurate? That would seem
like a 3rd party agency visiting a treating plant and merely viewing records, practices, and
said results versus actually drilling wood to verify it is properly treated. If this were not
needed for the ICC program, why would the AWPA have adopted this? It would simply
seem short sighted on the ICC’s part to not have something in place in this regard.
Clarity
The proposed changes are spelled out in a very simplistic form. Although I appreciate
that fact, I feel it has been oversimplified to the point of incompleteness. The method
adopted needs to have a well thought out measuring system that takes into account all
size production facilities, accountability system, consequence system, and resolution
system. The current lack of detail within these areas shows the untested nature of it…
Untested method
The current system has been in place for over twenty years and was developed and
adjusted by a governing body of many individuals. The current method is completely
untested and would cause mayhem in the marketplace if adopted as is. To hastily adopt a
system, as presented, in a short period of time with a lack of industry involvement would
be simply unwise. There is an AWPA task group specifically working on this very issue,
a field of many individuals from the industry with the goal of meaningful method that is
progressing. If the ICC has accepted the many methods and criteria from the AWPA in
the past, what is causing it to strike out on its own in this endeavor? Is the motive healthy
for the industry?
Congruency
If the ICC’s goal is to take on creating a new “book of standards”, then striking out on
its own to develop this method makes sense. If it is not, the challenges created by the
absence of congruency may become ongoing. Methodology in the industry needs to
remain congruent.
If change is truly needed, my suggestion on what to adopt, that covers most of the above
concerns, is to adopt the LCL method being explored by the T7 task group of the AWPA.
Also, the adoption of 3rd party accountability, as was identified as a need in the AWPA, is
a very important part that needs to be in place, both for field testing and laboratory
testing, (not just lab auditing of practices).
Respectfully submitted,
Andy Hehl
Biewer of Lansing, LLC.
Arch Wood Protection, Inc.
5660 New Northside Dr., Ste. 1100
Atlanta, GA 30328
Tel 678.627.2000
Fax 678.627.2095
September 3, 2010
Subject: Comments on Proposed Changes to AC 326
As most in the industry I welcome changes that will uniformly and equitably help to ensure improved
conformance of treated wood products to accepted standards or requirements.
While AC 326 is specific to products produced under ICC ES evaluation reports, there are numerous
treated wood products produced (including nearly all production in the western U.S.) in conformance
with AWPA standards under the ALSC overview system. I believe that industry and the consumer will
be best served to take the time to develop a uniform system of assessing conformance that can be
applied to products produced under both systems.
The AWPA T7 task group has focused on a methodology that would ensure all inspection agencies
evaluate the performance of treating plants using a uniform, well defined method. While this will not
guarantee 95% conformance, evaluation of data from plants using the current system indicate that
plants in good standing should be in the 90-95% conformance range. There will be a task group meeting
to discuss the proposed method on Sunday September 26 prior to the AWPA fall meetings and the
possibility of the modified standard being voted on later that week. If such a proposal successfully
negotiates the AWPA consensus process it could become an approved standard in January 2011.
The proposal for AC326, while being specific in the required 95% conformance rate, lacks the ability to
ensure that treatment quality problems will be quickly discovered and corrected (once per quarter
assessment) and then fails to ensure prompt disqualification if the problem is not corrected (up to 3
months probation prior to disqualification).
The 95% retention conformance rate, while desirable in many respects, is problematical. Agencies
rarely have a full charge available to sample in the same manner as the plant QC (2 or 3 units versus a
full charge) and may not adequately consider variability, either in the wood in a charge or in the
analytical methods used to determine retention results. Final approval of any system would best be
done after a trial period that would ensure the system is reasonable and appropriate.
I believe that unless a treated product at a plant has a label that clearly indicates it does not meet any
standard or ES report, it should be subject to inspection as if it were labeled. This would be similar to
the “non-complying” label required by Georgia state law which ensures that purchasers have the
opportunity to know that material does not meet a standard. An agency or inspector has no way to
prevent application of labels after their visit.
Overview of the inspection agencies should also be addressed. While under the ICC ES program
agencies are accredited by IAS, there is no physical oversight of the field inspectors. Under the ALSC
program, which is currently limited to AWPA listed products, field inspectors check penetration and
retention of product at treating plants to assess the adequacy agency inspection. When discrepancies
Comments on Proposed Changes to AC 326
Page 2
arise between the agency and ALSC assessment of a plant’s quality, the agency must take corrective
action. In an ideal world inspectors would assess products in the same manner whether or not they are
being checked, however, the lack of oversight in the ICC ES program more easily enables encroachment
of the human factor and relationships with plant personnel to enter the equation. Product quality and
agency assessment of treated wood produced under ICC ES reports would be improved by oversight.
However, this would require the ALSC to modify their current program as well as inclusion of a
requirement in AC 326 for oversight.
Many of the same people are involved in the efforts to update QC procedures at AWPA and ICC ES. I
would encourage all to attend the AWPA task group and the fall T7 meeting as well as the scheduled ICC
ES industry meeting in Birmingham. With a concerted effort, I hope that the AWPA proposal can be
modified to be generally acceptable, approved as an AWPA standard and then be referenced within
AC326. Failing that we should at least make an effort to coordinate the QC requirements so that all
plants producing residential treated wood products are evaluated and assessed by third-party agencies
in a uniform manner. This will provide a level playing field for all producers and agencies as well as a
higher quality treated wood product for consumers regardless of whether products are in conformance
with AWPA standards or ICC ES report requirements.
Steve Shields
Director, Product Development
Email:
[email protected]
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Rosalind Fazel
AC326 Comments
Friday, September 03, 2010 2:36:39 PM
Comments on Criteria AC326.
Mike Jacques
BB&S Treated Lumber
401-641-2738
[email protected]
Comments:
We would agree that the entire testing process and analysis methods
used need to be reviewed. Historically, after testing virtually
thousands of wood treating samples, we have seen that the natural
variabilities in the wood, as well as how individual pieces of wood
absorb and retain chemical and solids, make the testing process
virtually useless as a product quality judgement tool. BB&S
addressed this point a number of years ago when salmples were
taken from three treating charges, one from above ground .25 ACQ,
one from abrove ground with water repellant .25 ACQ, and one from
ground contact .40 ACQ. Sufficient boring were taken such that a
master sample could be dried, ground, and then split into three sub
samples. These samples were then analyzed at BB&S, TPI and
Chemical Specialties Inc. Variances in the test results of these similar
samples were large, indicating that test machine and chemical
extraction methods created wide variances. On a month to month
basis, while we feel that we are treating properly, there are times
when we are informed that we have undertreated and get failing
marks, while at other times we are informed that we have
overtreated. For each of these, the results of tests at our facility
would indicated that we have treated the wood to appropriate levels.
We have also seen that borings can be taken as little as an inch
away from another boring in the same piece of wood and a wildly
different test result would be seen. We are convinced that the
variances exhibited through testing wood samples clearly show the
natural variances indicitive of the material being treated and, in
some cases, the methods used in the individual labs to perform the
tests. We appreciate the fact that this is being considered and would
very much like to be included in the analysis and discussion with
regards to changes in the process. We feel strongly that is the range
of pass versus fail is narrowed, it will make the problem more
pronounced. If any data or information from us at BB&S would be
helpful in this, please let me know.
From:
To:
Subject:
Date:
[email protected]
Rosalind Fazel
AC326 Comments
Wednesday, August 25, 2010 9:57:42 AM
Comments on Criteria AC326.
Larry Lang
Culpeper Wood Preservers
800-817-6215
[email protected]
Comments:
All Culpeper Wood Preservers facilties are and have been third party
inspected. We are dedicated to quality control and third party
inspection however I don't feel that the new proposed criteria
entirely considers the variability of product. I think that the 95%
retention requirement is to stringent. I would recommend a 90% or
18 out of 20 charges as acceptable criteria and compromise. The
variability of product is something that we struggle with everyday
and no one, including the third party inspection agencies have
explanations or solutions. Inorder to acheive proper retentions we
find ourselves grossly overtreating other products. In these tough
economic times we can not survive by adding unneeded cost.
From:
To:
Subject:
Date:
[email protected]
Rosalind Fazel
AC326 Comments
Wednesday, September 01, 2010 8:35:49 AM
Comments on Criteria AC326.
Eddie Strawn
Hixson Lumber Sales
870-550-5014
[email protected]
Comments:
I understand your desire to improve Acceptance Criteria and
Guideline Requirements on all products or materials that you
evaluate.However I believe the proposed changes with AC326
Proprietary Wood Preservative System too stringent in regards to
95% conformance rate on retention level. The cost to achieve this
level of compliance in regards to retention I would estimate to be a
cost increase of 20%. This would be very detrimental to all wood
preservers treating to this requirement as I am sure a large part of
their existing business is already priced going forward. It is my
opinion that the existing requirements are quite adequate. I have
been employed for 22 years with Hixson Lumber and during this
time I have experienced practically zero failures ,I am Vice President
I handle all complaints and problems. However we do retreat on
failures we find during our own Quality Control process, this process
is outlined by our Third Party Inspection Agency.I don't agree with a
plant not tagging the product that fails and selling product if that
plant is under Third Party Inspection. My question would be if the
existing criteria is not sufficient and presents a potential failure
problem with the variability's of wood based assay and penetration
results. Then perhaps the best alternative would be to increase the
required retention level or rather than taking such a drastic increase
in retention conformance lets increase the penetration conformance
from 80% to 85% and require all failures to be retreated and not
sold untagged.