United States;^Sm_
Environmental ProtecfjoFT
-Agency .,-•'^^SfiSBaaL
Jan 51
Industry
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE ADMINISTRATOR
Message from the Administrator
Over the past 25 years, our nation has made tremendous progress in protecting public health and
our environment while promoting economic prosperity. Businesses as large as iron and steel
plants and businesses as small as the dry cleaner on the corner have worked with EPA to find
ways to operate cleaner, cheaper, and smarter. As a result, we no longer have rivers catching on
fire. Our skies are clearer. American environmental technology and expertise are in demand
throughout the world.
The Clinton Administration recognizes that to continue this progress, we must move beyond the
pollutant-by-pollutant approaches of the past to comprehensive, facility-wide approaches for the
future. Industry by industry and community by community, we must build a new generation of
environmental protection.
Within the past two years, the Environmental Protection Agency undertook its Sector Notebook
Project to compile, for a number of key industries, information about environmental problems and
solutions, case studies and tips about complying with regulations. We called on industry leaders,
state regulators, and EPA staff with many years of experience in these industries and with their
unique environmental issues. Together with notebooks for 17 other industries, the notebook you
hold in your hand is the result.
These notebooks will help business managers to better understand their regulatory requirements,
learn more about how others in their industry have undertaken regulatory compliance and the
innovative methods some have found to prevent pollution in the first instance. These notebooks
will give useful information to state regulatory agencies moving toward industry-based programs.
Across EPA we will use this manual to better integrate our programs and improve our compliance
assistance efforts.
I encourage you to use this notebook to evaluate and improve the way that together we achieve
our important environmental protection goals. I am confident that these notebooks will help us to
move forward in ensuring that ~ in industry after industry, community after community —
environmental protection and economic prosperity go hand in hand.
Carol M. Brown
Recycled/Recyclable • Printed with Vegetable Based Inks on Recycled Paper (20% Postconsumer)
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Wood Furniture and Fixtures
Sector Notebook Project
EPA/310-R-95-003
EPA Office of Compliance
Sector Notebook Project
Profile of the Wood Furniture and
Fixtures Industry
September 1995
Office of Compliance
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
401 M St., SW (MC 2221-A)
Washington, DC 20460
for sale by the U.S. Government Printing Office
Superintendent of Documents, Mail Stop: SSOP, Washington, DC 20402-9328
ISBN 0-16-048270-4
SIC Code 25
September 1995
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Sector Notebook Project
Wood Furniture and Fixtures
This report is one in a series of volumes published by the U.S. Environmental
Protection Agency (EPA) to provide information of general interest regarding
environmental issues associated with specific industrial sectors. The documents
were developed under contract by Abt Associates (Cambridge, MA), and Booz-
Allen & Hamilton, Inc. (McLean, VA). This publication may be purchased from
the Superintendent of Documents, U.S. Government Printing Office. A listing of
available Sector Notebooks and document numbers is included at the end of this
document.
All telephone orders should be directed to:
Superintendent of Documents
U.S. Government Printing Office
Washington, DC 20402
(202) 512-1800
FAX (202) 512-2250
8:00 a.m. to 4:30 p.m., EST, M-F
Using the form provided at the end of this document, all mail orders should be
directed to:
U.S. Government Printing Office
P.O. Box 371954
Pittsburgh, PA 15250-7954
Complimentary volumes are available to certain groups or subscribers, such as
public and academic libraries, Federal, State, local, and foreign governments, and
the media. For further information, and for answers to questions pertaining to
these documents, please refer to the contact names and numbers provided
within this volume.
Electronic versions of all Sector Notebooks are available on the EPA Enviro$en$e
Bulletin Board and via Internet on the Enviro$en$e World Wide Web.
Downloading procedures are described in Appendix A of this document.
September 1995
SIC Code 25
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Sector Notebook Contacts
The Sector Notebooks were developed by the EPA's Office of Compliance. Particular questions regarding the
Sector Notebook Project in general can be directed to:
Seth Heminway, Sector Notebook Project Coordinator
US EPA, Office of Compliance
401 M St., SW (2223-A)
Washington, DC 20460
(202) 564-7017 fax (202) 564-0050
E-mail: heminway.seth@epamail.epa.gov
Questions and comments regarding the individual documents can be directed to the appropriate specialists listed
below.
Document Number
EPA/310
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
-R-95-001.
-R-95-002.
-R-95-003.
-R-95-004.
-R-95-005.
-R-95-006.
-R-95-007.
-R-95-008.
-R-95-009.
-R-95-010.
-R-95-011.
-R-95-012.
-R-95-013.
-R-95-014.
-R-95-015.
-R-95-016.
-R-95-017.
-R-95-018.
•R-97-001.
•R-97-002.
-R-97-003.
-R-97-004.
R-97-005.
•R-97-006.
•R-97-007.
•R-97-008.
•R-97-009.
•R-97-010.
EPA/310-B-96-003.
Industry
Dry Cleaning Industry
Electronics and Computer Industry
Wood Furniture and Fixtures Industry
Inorganic Chemical Industry
Iron and Steel Industry
Lumber and Wood Products Industry
Fabricated Metal Products Industry
Metal Mining Industry
Motor Vehicle Assembly Industry
Nonferrous Metals Industry
Non-Fuel, Non-Metal Mining Industry
Organic Chemical Industry
Petroleum Refining Industry
Printing Industry
Pulp and Paper Industry
Rubber and Plastic Industry
Stone, Clay, Glass, and Concrete Industry
Transportation Equipment Cleaning Ind.
*Air Transportation Industry
Ground Transportation Industry
* Water Transportation Industry
Metal Casting Industry
Pharmaceutical Industry
Plastic Resin and Man-made Fiber Ind.
*Fossil Fuel Electric Power Generation Ind.
* Shipbuilding and Repair Industry
Textile Industry
*Sector Notebook Data Refresh, 1997
Federal Facilities
Contact
Joyce Chandler
Steve Hoover
Bob Marshall
Walter DeRieux
Maria Malave
Seth Heminway
Scott Throwe
Keith Brown
Suzanne Childress
Jane Engert
Keith Brown
Walter DeRieux
Tom Ripp
Ginger Gotliffe
Maria Eisemann
Maria Malave
Scott Throwe
Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Jane Engert
Emily Chow
Sally Sasnett
Rafael Sanchez
Suzanne Childress
Belinda Breidenbach
Seth Heminway
Jim Edwards
Phone (202)
564-7073
564-7007
564-7021
564-7067
564-7027
564-7017
564-7013
564-7124
564-7018
564-5021
564-7124
564-7067
564-7003
564-7072
564-7016
564-7027
564-7013
564-7057
564-7057
564-7057
564-7057
564-5021
564-7071
564-7074
564-7028
564-7018
564-7022
564-7017
564-2461
*Currently in DRAFT anticipated publication in September 1997
This page updated during June 1997 reprinting
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Wood Furniture and Fixtures
Sector Notebook Project
WOOD FURNITURE AND FIXTURES
(SIC 25)
TABLE OF CONTENTS
Page
LIST OF EXHIBITS vii, viii
LIST OF ACRONYMS ix,x
I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT 1
LA. Summary of the Sector Notebook Project 1
I.E. Additional Information 2
n. INTRODUCTION TO THE WOOD FURNITURE AND FIXTURES INDUSTRY 4
II.A. Introduction, Background, and Scope of the Notebook 4
II.B. Characterization of the Wood Furniture and Fixtures Industry...6
II.B.l. Industry Size and Geographic Distribution 6
II.B.2. Product Characterization 10
E.B.3. Economic Trends 11
m. INDUSTRIAL PROCESS DESCRIPTION 13
IH.A. Industrial Processes in the Wood Furniture and Fixtures
Industry 13
HI.A.1. Drying 13
ni.A.2. Machining 15
HI.A.3. Assembly 16
in.A.4. Pre-finishing 17
ni.A.5. Coating Application 17
m.A.6. Finishing 19
ffi.B. Raw Material Inputs and Pollution Outputs 24
HI.B.1. Drying 24
ffl.B.2. Machining 26
UI.B.3. Assembly 26
EI.B.4. Pre-finishing 26
EI.B.5. Coating Application 27
SIC Code 25
IV
September 1995
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Sectot Notebook Project
Wood Furniture and Fixtures
IV.
V.
VI.
WOOD FURNITURE AND FIXTURES
(SIC 25)
TABLE OF CONTENTS (CONT'D)
Page
III.B.6. Finishing 28
III.B.7. Cleanup Operations 30
ni.C. Management of Chemicals in Wastestream 34
CHEMICAL RELEASE AND TRANSFER PROFILE 36
IV.A. EPA Toxic Release Inventory for the Wood Furniture and
Fixtures Industry 39
IV.B. Summary of the Selected Chemicals Released 44
IV.C. Other Data Sources 49
IV.D. Comparison of Toxic Release Inventory Between Selected
Industries 50
POLLUTION PREVENTION OPPORTUNITIES 53
V.A. Identification of Pollution Prevention Activities in Use and
Environmental and Economic Benefits of Each Pollution
Prevention Activity 54
V.B. Pollution Prevention Case Studies 60
SUMMARY OF FEDERAL STATUTES AND REGULATIONS 64
VI.A. General Description of Major Statutes 64
VLB. Industry-specific Regulatory Requirements 79
VI.C. Pending and Proposed Regulatory Requirements 81
September 1995
SIC Code 25
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Wood Furniture and Fixtures
Sector Notebook Project
WOOD FURNITURE AND FIXTURES
(SIC 25)
TABLE OF CONTENTS (CONT'D)
Page
VII. COMPLIANCE AND ENFORCEMENT HISTORY 86
VILA. Furniture and Fixtures Industry Compliance History 90
VII.B. Comparison of Enforcement Activity Between Selected
Industries 92
Vn.C. Review of Major Legal Actions 97
VH.C.1. Review of Major Cases 97
VTI.C.2. Supplemental Environmental Projects 97
VIII. COMPLIANCE ACTIVITIES AND INITIATIVES 98
VTH.A. Sector-related Environmental Programs and Activities 98
VHI.B. EPA Voluntary Programs 99
Vffl.C. Trade Association/Industry Sponsored Activity 104
VTH.C.l. Environmental Programs 104
VDI.C.2. Summary of Trade Associations 104
DC.
CONTACTS/ACBCNOWLEDGMENTS/RESOURCE MATERIALS/
BIBLIOGRAPHY
.108
SIC Code 25
VI
September 1995
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Sector Notebook. Project
Wood Furniture and Fixtures
WOOD FURNITURE AND FIXTURES
(SIC 25)
EXHIBITS INDEX
Page
Exhibit 1 Facility Size Distribution of Household Furniture Manufacturers..6
Exhibit 2 Facility Size Distribution of Wood Furniture Manufacturers 7
Exhibit 3 Geographic Distribution of the Furniture and Fixtures Industry 8
Exhibit 4 Geographic Distribution of the Wood Furniture and
Fixtures Industry 9
Exhibit 5 Top Ten Wood Furniture Manufacturers - 1990 10
Exhibit 6 Chemical Components of Pigments Found in Paint 21
Exhibit 7 Flow Diagram for Wood Furniture Manufacturing 23
Exhibit 8 Relative VOC Emissions 29
Exhibit 9 Inputs and Outputs of Wood Furniture Manufacturing
Facilities 31,32,33,34
Exhibit 10 Source Reduction and Recycling Activity for (SIC 25) 35
Exhibit 11 Top 10 TRI Releasing Furniture Manufacturing
Facilities (SIC 25) 40
Exhibit 12 Top 10 TRI Releasing Furniture and Fixtures Facilities 40
Exhibit 13 TRI Reporting Furniture Manufacturing Facilities
(SIC 25) by State 41
Exhibit 14 Releases for Furniture Manufacturing Facilities (SIC 25) in
TRI, by Number of Facilities 41,42
Exhibit 15 Transfers for Furniture Manufacturing Facilities (SIC 25) in
TRI, by Number of Facilities 43
Exhibit 16 Pollutant Releases (Short Tons/Year) 49
Exhibit 17 Summary of 1993 TRI Data , 51
Exhibit 18 Toxic Release Inventory for Selected Industries 52
Exhibit 19 Pollution Prevention Matrix 58,59, 60
Exhibit 20 Ethan Allen Pollution Prevention Case Study Summary 63
Exhibit 21 Impacts of Environmental Statutes on the Wood Furniture
Manufacturing Industry 76, 77, 78, 79
Exhibit 22 Summary of Proposed MACT Emission Limit 84
Exhibit 23 Summary of Work Practice Standards for the MACT and CTG 85
Exhibit 24 Five Year Enforcement and Compliance Summary for the
Furniture Industry 91
Exhibit 25 Five Year Enforcement and Compliance Summary for
Selected Industries 93
September 1995
Vll
SIC Code 25
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Wood Furniture and Fixtures
Sector Notebook Project
WOOD FURNITURE AND FIXTURES
(SIC 25)
EXHIBITS INDEX (CONT'D)
Page
Exhibit 26 One Year Enforcement and Compliance Summary for
Selected Industries 94
Exhibit 27 Five Year Inspection and Enforcement Statute for
Selected Industries 95
Exhibit 28 One Year Inspection and Enforcement Summary by Statute for
Selected Industries 96
SIC Code 25
Vlll
September 1995
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Sector Notebook: Project
Wood Furniture and Fixtures
WOOD FURNITURE AND FIXTURES
(SIC 25)
LIST OF ACRONYMS
AFS - AIRS Facility Subsystem (CAA database)
AIRS - Aerometric Information Retrieval System (CAA database)
BIFs - Boilers and Industrial Furnaces (RCRA)
BOD - Biochemical Oxygen Demand
CAA - Clean Air Act
CAAA - Clean Air Act Amendments of 1990
CERCLA- Comprehensive Environmental Response, Compensation and
Liability Act
CERCLIS - CERCLA Information System
CFCs - Chlorofluorocarbons
CO- Carbon Monoxide
COD - Chemical Oxygen Demand
CSI - Common Sense Initiative
CWA - Clean Water Act
D&B - Dun and Bradstreet Marketing Index
ELP- Environmental Leadership Program
EPA - United States Environmental Protection Agency
EPCRA - Emergency Planning and Community Right-to-Know Act
FIFRA - Federal Insecticide, Fungicide, and Rodenticide Act
FINDS - Facility Indexing System
HAPs - Hazardous Air Pollutants (CAA)
HSDB - Hazardous Substances Data Bank
IDEA - Integrated Data for Enforcement Analysis
LDR - Land Disposal Restrictions (RCRA)
LEPCs - Local Emergency Planning Committees
MACT - Maximum Achievable Control Technology (CAA)
MCLGs- Maximum Contaminant Level Goals
MCLs- Maximum Contaminant Levels
MEK - Methyl Ethyl Ketone
MSDSs - Material Safety Data Sheets
NAAQS - National Ambient Air Quality Standards (CAA)
NAFTA - North American Free Trade Agreement
NCDB - National Compliance Database (for TSCA, FIFRA, EPCRA)
NCP - National Oil and Hazardous Substances Pollution Contingency
Plan
NEIC - National Enforcement Investigation Center
NESHAP - National Emission Standards for Hazardous Air Pollutants
NO2~ Nitrogen Dioxide
NOV - Notice of Violation
September 1995
IX
SIC Code 25
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Wood Furniture and Fixtures
Sector Notebook Project
WOOD FURNITURE AND FIXTURES
(SIC 25)
LIST OF ACRONYMS (CONT'D)
NOx - Nitrogen Oxide
NPDES - National Pollution Discharge Elimination System (CWA)
NPL - National Priorities List
NRC - National Response Center
NSPS - New Source Performance Standards (CAA)
OAR - Office of Air and Radiation
OECA - Office of Enforcement and Compliance Assurance
OPA - Oil Pollution Act
OPPTS - Office of Prevention, Pesticides, and Toxic Substances
OSHA - Occupational Safety and Health Administration
OSW - Office of Solid Waste
OSWER - Office of Solid Waste and Emergency Response
OW - Office of Water
P2- Pollution Prevention
PCS - Permit Compliance System (CWA Database)
POTW - Publicly Owned Treatments Works
RCRA - Resource Conservation and Recovery Act
RCRIS - RCRA Information System
SARA - Superfund Amendments and Reauthorization Act
SDWA - Safe Drinking Water Act
SEPs- Supplementary Environmental Projects
SERCs - State Emergency Response Commissions
SIC - Standard Industrial Classification
SO2- Sulfur Dioxide
TOC - Total Organic Carbon
TRI - Toxic Release Inventory
TRIS - Toxic Release Inventory System
TCRIS - Toxic Chemical Release Inventory System
TSCA - Toxic Substances Control Act
TSS - Total Suspended Solids
UIC - Underground Injection Control (SDWA)
UST - Underground Storage Tanks (RCRA)
VOCs - Volatile Organic Compounds
SIC Code 25
September 1995
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Sector Notebook Project
Wood Furniture and Fixtures
WOOD FURNITURE AND FIXTURES
(SIC 25)
I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT
I.A. Summary of the Sector Notebook Project
Environmental policies based upon comprehensive analysis of air,
water, and land pollution are an inevitable and logical supplement
to traditional single-media approaches to environmental
protection. Environmental regulatory agencies are beginning to
embrace comprehensive, multi-statute solutions to facility
permitting, enforcement and compliance assurance,
education/outreach, research, and regulatory development issues.
The central concepts driving the new policy direction are that
pollutant releases to each environmental medium (air, water, and
land) affect each other, and that environmental strategies must
actively identify and address these inter-relationships by designing
policies for the "whole" facility. One way to achieve a whole facility
focus is to design environmental policies for similar industrial
facilities. By doing so, environmental concerns that are common to
the manufacturing of similar products can be addressed in a
comprehensive manner. Recognition of the need to develop the
industrial "sector-based" approach within the EPA Office of
Compliance led to the creation of this document.
The Sector Notebook Project was initiated by the Office of
Compliance within the Office of Enforcement and Compliance
Assurance (OECA) to provide its staff and managers with summary
information for eighteen specific industrial sectors. As other EPA
offices, States, the regulated community, environmental groups,
and the public became interested in this project, the scope of the
original project was expanded. The ability to design
comprehensive, common sense environmental protection
measures for specific industries is dependent on knowledge of
several inter-related topics. For the purposes of this project, the key
elements chosen for inclusion are: general industry information
(economic and geographic); a description of industrial processes;
pollution outputs; pollution prevention opportunities; Federal
statutory and regulatory framework; compliance history; and a
description of partnerships that have been formed between
regulatory agencies, the regulated community, and the public.
September 1995
SIC Code 25
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Wood Furniture and Fixtures
Sector Notebook Project
For any given industry, each topic listed above could alone be the
subject of a lengthy volume. However, in order to produce a
manageable document, this project focuses on providing summary
information for each topic. This format provides the reader with a
synopsis of each issue, and references where more in-depth
information is available. Text within each profile was researched
from a variety of sources, and was usually condensed from more
detailed sources pertaining to specific topics. This approach allows
for a wide coverage of activities that can be further explored based
upon the citations and references listed at the end of this profile. As
a check on the information included, each notebook went through
an external review process. The Office of Compliance appreciates
the efforts of all those that participated in this process and enabled
us to develop more complete, accurate, and up-to-date summaries.
Many of those who reviewed this notebook are listed as contacts in
Section IX and may be sources of additional information. The
individuals and groups on this list do not necessarily concur with
all statements within this notebook.
I.B. Additional Information
Providing Comments
OECA's Office of Compliance plans to periodically review and
update the notebooks and will make these updates available both in
hard copy and electronically. If you have any comments on the
existing notebook, or if you would like to provide additional
information, please send a hard copy and computer disk to the EPA
Office of Compliance, Sector Notebook Project, 401 M St., SW (2223-
A), Washington, DC 20460. Comments can also be uploaded to the
Enviro$en$e Bulletin Board or the Enviro$en$e World Wide Web
for general access to all users of the system. Follow instructions in
Appendix A for accessing these data systems. Once you have logged
in, procedures for uploading text are available from the on-line
Enviro$en$e Help System.
Adapting Notebooks to Particular Needs
The scope of the existing notebooks reflect an approximation of the
relative national occurrence of facility types that occur within each
sector. In many instances, industries within specific geographic
regions or States may have unique characteristics that are not fully
captured in these profiles. For this reason, the Office of Compliance
encourages State and local environmental agencies and other
groups to supplement or re-package the information included in
SIC Code 25
September 1995
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Sector Notebook Project
Wood Furniture and Fixtures
this notebook to include more specific industrial and regulatory
information that may be available. Additionally, interested States
may want to supplement the "Summary of Applicable Federal
Statutes and Regulations" section with State and local
requirements. Compliance or technical assistance providers may
also want to develop the "Pollution Prevention" section in more
detail. Please contact the appropriate specialist listed on the opening
page of this notebook if your office is interested in assisting us in the
further development of the information or policies addressed
within this volume.
If you are interested in assisting in the development of new
notebooks for sectors not covered in the original eighteen, please
contact the Office of Compliance at 202-564-2395.
September 1995
SIC Code 25
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Wood Furniture and Fixtures
Sector Notebook Project
n. INTRODUCTION TO THE WOOD FURNITURE AND FIXTURES INDUSTRY
This section provides background information on the size,
geographic distribution, employment, production, sales, and
economic condition of the Wood Furniture and Fixtures industry.
The type of facilities described within the document are also
described in terms of their Standard Industrial Classification (SIC)
codes. Additionally, this section contains a list of the largest
companies in terms of sales.
H.A. Introduction, Background, and Scope of the Notebook
The furniture and fixtures industry encompasses companies that
manufacture household, office, store, public building, and
restaurant furniture and fixtures. These practices correspond to the
Standard Industrial Classification (SIC) code 25 created by the
Bureau of the Census to track the movement of goods and services
within the economy. Although it is difficult to determine the exact
number of facilities that fall within SIC code 25, 1987 Census data
indicate that there were approximately 11,000 furniture
manufacturing facilities in operation (complete 1992 Census data
were not available).
SIC 25, Furniture and Fixtures, consists of the following five three-
digit industry groups:
SIC 251 - Household Furniture
SIC 252 - Office Furniture
SIC 253 - Public Building and Related Furniture
SIC 254 - Partitions, Shelving, Lockers, and Office and
Store Fixtures
SIC 259 - Miscellaneous Furniture and Fixtures.
The following discussion focuses on SIC 251 because a majority of
the wood furniture manufacturing facilities fall into this SIC code
and the facilities in this SIC code tend to be the most heavily
regulated. The Bureau of the Census estimates that in 1992, 256,000
people were employed by the household furniture manufacturing
sector (SIC 251) of the furniture industry, a decline of approximately
10 percent from 1987. The 1993 value of shipments for these firms
exceeded $22 billion, representing an increase of approximately
seven percent over the previous year. Sales from the household
furniture manufacturing industry were expected to rise by four
percent in 1994.
SIC Code 25
September 1995
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Sector Notebook Project
Wood Furniture and Fixtures
The household furniture manufacturing industry (SIC 251) consists
of producers of wood furniture (SIC 2511), accounting for 42 percent
of household furniture industry shipments in 1993; upholstered
furniture (SIC 2512), accounting for 30 percent of shipments; metal
furniture (SIC 2514), accounting for ten percent of shipments; and
miscellaneous furniture (SIC 2517 and 2519), accounting for four
percent of shipments.
This industry is comprised of the production of many different
types of products including wood household furniture, metal
household furniture, mattresses, machine cabinets, shelving, and
lockers. Because the items produced vary greatly in design
depending upon the type of material used, style, price, and final use,
the different types of machinery used in the various phases of
production can reach into the hundreds or even thousands. This
diversity of products provides a challenge for most manufacturers.
Production lines for assembling furniture are costly, and because of
this most manufacturers do not supply an exceptionally large range
of items. To combat this problem, many firms specialize their
production processes, allowing facilities to fill a specific niche in the
market while still retaining flexibility in their manufacturing area.
Manufacturers may specialize depending on the product
manufactured, the product group, or the production process.
Specialization has also allowed manufacturers to focus on quality by
more carefully monitoring the entire production process, from raw
material to finished product.
Because SIC 25 covers such a diverse group of products, much of
this profile will concentrate on the wood furniture manufacturing
industry as defined by the following SIC codes:
SIC 2511 - Wood Household Furniture, Except
Upholstered
SIC 2512 - Wood Household Furniture, Upholstered
SIC 2517 - Wood Television, Radio, Phonograph, and
Sewing Machine Cabinets
SIC 2521 - Wood Office Furniture
SIC 2531 - Public Building and Related Furniture
SIC 2541 - Wood Office and Store Fixtures, Partitions,
Shelving, and Lockers.
All discussions on production processes and applicable regulations
will be limited to activities covered by these four-digit SIC codes.
September 1995
SIC Code 25
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Wood Furniture and Fixtures
Sector Notebook Project
II.B. Characterization of the Wood Furniture and Fixtures Industry
The discussion of the characterization of the wood furniture and
fixtures industry is divided into the following four topics: industry
size and geographic distribution, profile of the top ten furniture
manufacturers, characterization of products, and economic health
and outlook.
II.B.l. Industry Size and Geographic Distribution
Variation in facility counts occur across data sources due to many
factors, including reporting and definitional differences. This
document does not attempt to reconcile these differences, but rather
reports the data as they are maintained by each source.
Size Distribution
According to 1987 Census data, approximately 63 percent of
household furniture manufacturing facilities (SIC 251) have fewer
than 20 employees. Approximately 53 percent of facilities within
this SIC code produce wood household furniture, while
approximately 20 percent produce upholstered household furniture.
Exhibit 1 provides a distribution by facility size for household
furniture manufacturing facilities.
Exhibit 1
Facility Size Distribution of Household Furniture Manufacturers
Type of Furniture Facility
Wood Household
SIC: 2511
Upholstered Household
SIC: 2512
Metal Household
SIC: 2514
Mattresses and Bedsprings
SIC: 2515
Wood Television and Radio
Cabinets
SIC: 2517
Household Furniture (misc.)
SIC: 2519
Total
Facilities
with 1 to 19
employees
2,084
574
207
504
44
126
3,539
Facilities with
20 to 99
employees
573
358
123
282
22
38
1,396
Facilities with
100 or more
employees
291
218
88
53
14
13
677
Total
2,948
1,150
418
839
80
177
5,612
Source: 1987 Census of Manufacturers Industry Series.
SIC Code 25
September 1995
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Sector Notebook Project
Wood Furniture and Fixtures
According to information contained in EPA's October 1991 draft
guidelines for the Control of Volatile Organic Compound
Emissions from Wood Furniture Coating Operations,
approximately 86 percent of the wood furniture industry (SIC codes
2434, 2511, 2512, 2517, 2519, 2521, 2531, and 2541) have fewer than 50
employees. Approximately 37 percent of facilities in this listing are
wood household furniture manufacturers, while approximately 34
percent are wood kitchen cabinet manufacturers. Exhibit 2 provides
a breakdown by facility size for the wood furniture manufacturers.
Exhibit 2
Facility Size Distribution of Wood Furniture Manufacturers
Type of Furniture Facility
Wood Kitchen Cabinets
SIC: 2434
Wood Household Furniture,
except upholstered
SIC: 2511
Wood Household Furniture,
upholstered
SIC: 2512
Wood Television, Radios,
Phonograph, and Sewing
Machine Cabinets
SIC: 2517
Household Furniture, not
elsewhere classified
SIC: 2519
Wood Office Furniture
SIC: 2521
Public Building and Related
Furniture
SIC: 2531
Wood Office and Store Fixtures,
Partitions, Shelving, and
Lockers
SIC: 2541
Total
Facilities
with 1 to 49
employees
3,460
2,466
782
61
150
505
381
1,672
9,477
Facilities
with 50 to 249
employees
218
344
292
11
22
113
95
184
1,279
Facilities with
250 or more
employees
35
138
76
8
5
31
15
10
318
Total
3,713
2,948
1,150
80
177
649
491
1,866
11,074
Source: EPA Draft Guidelines for the Control of Volatile Organic Compound Emissions from
Wood Furniture Coatin? Operations.
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Geographic Distribution
According to 1987 Census data, of the estimated 11,000 furniture
manufacturing facilities (SIC 251), approximately 17 percent are
located in California. North Carolina is home to approximately
seven percent of these facilities, even though four of the top ten
facilities are located in this State. Exhibit 3 provides a geographic
distribution of the number of furniture and fixtures manufacturers
(State totals are based on the number of facilities per State with 150
or more employees in a given industry sector).
Exhibits
Geographic Distribution of the Furniture and Fixtures Industry
Source: 1987 Census of Manufacturers Industry Series.
Information contained in EPA's draft guidelines for the Control of
Volatile Organic Compound Emissions from Wood Furniture
Coating Operations shows that of the estimated 10,757 wood
furniture manufacturing facilities (SIC codes 2434, 2511, 2512, 2517,
2519, 2521, 2531, and 2541) approximately 17 percent are located in
California. Although more facilities are located in California, the
largest furniture manufacturing facilities and those responsible for
producing the highest volume of furniture are located in North
Carolina. Exhibit 4 provides a geographic distribution of the wood
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furniture manufacturing industry (information is not available for
Alaska, Delaware, Hawaii, Montana, Washington D.C., and
Wyoming).
Exhibit 4
Geographic Distribution of Wood Furniture Manufacturing Facilities
Source: EPA Draft Guidelines for the Control of Volatile Organic Compound Emissions from
Wood Furniture Coatinv Operations.
According to a 1990 ranking by total annual sales of the top 300
wood furniture manufacturing facilities in Furniture Design and
Manufacturing Magazine, Masco Corporation is the largest
residential wood furniture manufacturer, with annual sales of $1.2
billion. Steelcase, Inc. is the largest manufacturer of wood
off ice/institutional furniture, with annual sales of $1.8 billion.
Exhibit 5 provides a breakdown of the top ten manufacturers of
residential wood furniture and wood off ice/institutional furniture
(sales figures are based on 1988 and 1989 data and are estimates in
some instances).
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Exhibit 5
Ten Wood Furniture Manufacturers - 1990
Rank I Name of Manufacturer
Annual Sales,
$ million
Residential Furniture
1
2
3
4
5
6
7
8
9
10
Masco Corporation
Interco
Ohio Mattress Company
La-Z-Boy Chair Company
Bassett Furniture Industries, Inc.
Ladd Furniture
Simmons USA
Thomasville Furniture Industries, Inc.
Mohasco Corporation
Klaussner Furniture Industries
1,200
1,100
700
553
466
450
425
417
400
250
Office/Institutional Furniture
1
2
3
4
5
6
7
8
9
10
Steelcase, Inc.
Herman Miller, Inc.
Hanworth, Inc.
HON Industries, Inc.
Kimball International, Inc.
Knoll International
Allsteel, Inc.
Virco Manufacturing Corporation
Westinghouse Furniture Systems
Shelby William Industries, Inc.
1,800
793
>500
500
475
275
220
183
170
169
Source: Furniture Design and Manufacturing Magazine.
H.B.2. Product Characterization
The furniture and fixtures industry, as defined by SIC 25,
manufactures a wide variety of products, including wood and
metal furniture, mattresses, draperies, public seating (i.e.
stadium seats and bleachers), lockers, and restaurant furniture.
Because this profile focuses on the wood furniture portion of the
industry (SIC codes 2511,2512,2517,2521,2531, and 2541), the
product characterization of the profile is limited in scope.
Products covered under the relevant four-digit SIC codes include
wood household furniture, such as beds, tables, chairs,
bookshelves; wood television and radio cabinets; wood office
furniture such as cabinets, chairs, and desks; and wood office and
store fixtures and partitions, such as bar fixtures, counters,
lockers, and shelves.
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II.B.3. Economic Trends
According to the American Furniture Manufacturers Association
(AFMA), wood furniture comprises approximately 50 percent of all
furniture shipments nationally. Following a steady decline
beginning in 1989, the furniture industry experienced moderate
increases in 1992 and 1993. This is in part attributed to the fact that
private housing starts increased for the second consecutive year and
the value of new residential construction rose an estimated seven
percent. This rise in home sales and residential construction figures
translated into a five percent increase in furniture shipments in
1993. Employment in the furniture and fixtures industry increased
by two percent in 1993 following a five year decline.
Wood furniture manufacturers' profits did not rise by as much as
the increased shipments would suggest. Major increases in lumber
prices, over 30 percent for softwood in approximately one year,
significantly gouged profits in 1993. A similar rise in hardwood
prices occurred in early 1992. Although lumber prices may fluctuate
mildly, they are not expected to fall to the reduced levels of 1991 or
early 1992.
In 1993, wood furniture accounted for 48 percent of total furniture
exports, followed by upholstered furniture (19 percent), metal
furniture (10 percent), plastic furniture (four percent), and
mattresses and bedsprings (three percent). Although overall U.S.
household furniture exports increased five percent to $1.2 billion in
1993, imports rose more than 14 percent in the same time period.
The resulting $2.3 billion furniture and fixtures industry trade
deficit mimicked that of 1989. However, U.S. exports increased
almost 150 percent from 1989 through 1993 while imports increased
only 25 percent in the same time period. As foreign markets
become increasingly important to U.S. manufacturers of household
furniture, attention is being focused on international agreements to
ease trade restrictions. For example, many furniture manufacturers
favored the North American Free Trade Agreement (NAFTA).
Under this agreement, Mexico, a major importer of American
home furniture, will immediately eliminate taxes on 21 percent of
all imports of U.S. household furniture, with additional reductions
to follow.
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The real value of U.S. shipments of household furniture is expected
to increase by four percent to an estimated $23 billion in 1994 due to
improvements in the economy and consumer confidence. Over the
next five years, household furniture shipments are expected to
increase three to five percent annually. This prediction relies
primarily upon increases in product prices rather than overall
furniture units produced.
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HI. INDUSTRIAL PROCESS DESCRIPTION
This section describes the major industrial processes within the
Wood Furniture and Fixtures industry, including the materials and
equipment used, and the processes employed. The section is
designed for those interested in gaining a general understanding of
the industry, and for those interested in the inter-relationship
between the industrial process and the topics described in
subsequent sections of this profile — pollutant outputs, pollution
prevention opportunities, and Federal regulations. This section
does not attempt to replicate published engineering information
that is available for this industry. Refer to Section IX for a list of
reference documents that are available.
This section specifically contains a description of commonly used
production processes, associated raw materials, the byproducts
produced or released, and the materials either recycled or
transferred off-site. This discussion, coupled with schematic
drawings of the identified processes, provide a concise description of
where wastes may be produced in the process. This section also
describes the potential fate (air, water, land) of these waste products.
III.A. Industrial Processes in the Wood Furniture and Fixtures Industry
The following description of production processes focuses on the
manufacturing of wood furniture. The primary input for wood
furniture manufacturing is raw lumber, and the production
processes include steps such as drying, sawing, planing, sanding,
gluing, and finishing. Each of these activities is described below.
III.A.I. Drying
Some furniture manufacturing facilities may purchase dried
lumber, but others perform drying on-site. Drying of raw lumber is
accomplished by using a drying kiln or oven, fired by a boiler.
According to EPA document AP-42, furniture manufacturing
facilities generally burn wood waste (from later stages of the
production process) in boilers to heat the drying kilns and to
alleviate possible solid waste disposal problems. The following
boiler firing configurations are used for burning wood waste: Dutch
oven; fuel cell oven; spreader stoker; suspension-fired; and
fluidized bed combustion. The primary outputs of burning wood
waste in boilers are point-source emissions to the atmosphere. A
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more detailed discussion of all material inputs and pollution
outputs will be covered in the following section.
Types of Boilers
One common type of boiler used in smaller operations is the Dutch
oven. This unit is widely used because it can burn fuels with very
high moisture content. Wood waste is used as fuel and is fed into
the oven through an opening in the top of a refractory-lined
furnace. The fuel accumulates in a cone-shaped pile on a flat or
sloping grate. Combustion is accomplished in two stages: 1) drying
and gasification, and 2) combustion of gaseous products. The first
stage takes place in the primary furnace, which is separated from the
secondary furnace chamber by a bridge wall. Combustion is
completed in the secondary chamber before gases enter the boiler
section.
In the fuel cell oven, fuel is dropped onto suspended fixed grates
and is fired in a pile. Unlike the Dutch oven, the refractory-line
fuel cell also uses combustion air preheating and positioning of
secondary and tertiary air injection ports to improve boiler
efficiency. Because of their overall design and operating
similarities, fuel cell and Dutch oven boilers have comparable
emission characteristics.
The most common firing method employed for wood-fired boilers
larger than 45,000 kg/hr steam generation rate is the spreader stoker.
With this boiler, wood enters the furnace through a fuel chute and
is spread either pneumatically or mechanically across the furnace,
where small pieces of the fuel burn while in suspension.
Simultaneously, larger pieces of fuel are spread in a thin, even bed
on a stationary or moving grate. The burning is accomplished in
three stages in a single chamber: 1) moisture evaporation; 2)
distillation and burning of volatile matter; and 3) burning of fixed
carbon. This type of operation has a fast response to load changes,
has improved combustion control, and can be operated with
multiple fuels. Natural gas or oil is often fired in spreader stoker
boilers as auxiliary fuel. This is done to maintain constant steam
when the wood waste supply fluctuates and to provide more steam
than can be generated from the wood waste alone.
The suspension-firing boiler can be used for wood combustion, and
differs from a spreader stoker in that small-sized fuel (normally less
than 2 mm) is blown into the boiler and combusted by supporting it
in air rather than on fixed grates. Rapid changes in combustion
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rate, and therefore steam generation rate, are possible because the
finely divided fuel particles burn very quickly.
A recent development in wood firing is the fluidized bed
combustion boiler. A fluidized bed consists of inert particles
through which air is blown so that the bed behaves as a fluid.
Wood waste enters in the space above the bed and burns both in
suspension and in the bed. Because of the large thermal mass
represented by hot inert bed particles, fluidized beds can handle
dirty fuels (up to 30 percent inert material). Wood fuel is burned
faster in a fluidized bed than on a grate due to its immediate contact
with hot bed material. As a result, combustion is rapid and results
in nearly complete combustion of the organic matter, minimizing
unburned organic compound emissions.
III.A.2. Machining
Once the lumber is dried, it is sawed into a shape of the approximate
dimensions of the final furniture part, such as a table leg or a chair
rung. Sawing across the grain in called crosscutting, and sawing
parallel with the grain is referred to as ripping. Types of power saws
used in furniture manufacturing include circular saws, band saws,
scroll saws, radial saws, and portable handsaws.
After sawing, the surfaces of the wood which will be flat in the final
product are planed. Planing involves shaving one surface of wood
by using a wide edged blade or blades called a planer. The type of
power planer usually used in this manufacturing process is the
jointer or jointer planer, which consists of blades fastened to a
rotating cutterhead. The primary outputs from the sawing and
planing processes are wood chips.
The design of some furniture pieces requires that certain wooden
parts be bent. This production step follows the planing process and
usually involves the application of pressure in conjunction with a
softening agent and increased atmospheric pressure. While soaking
wood in water alone does increase its plasticity, the combination of
heat and steam does increase further the plasticity of wood. The
actual bending is accomplished by compressing the wood into the
desired shape and then drying it to remove excess moisture. Drying
after bending is accomplished in much the same way as the drying
of raw lumber, in drying kilns using boilers to generate heat.
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EI.A.3. Assembly
Wood furniture can either be finished (coated) and then assembled,
or assembled and then finished. Residential and
off ice/institutional furniture manufactured in the U.S. is generally
made up of irregularly shaped, curved components, and for ease of
production is assembled and then finished. Cabinets manufactured
in the U.S., however, are frequently finished before assembly.
After the wood parts have been planed and, if necessary, bent, they
are assembled to form one furniture part, such as a tabletop. The
assembly process usually involves the use of adhesives (either
synthetic or natural) in conjunction with other joining methods,
such as nailing. The wood furniture manufacturing industry uses
adhesive formulations containing solvents (typically used for
upholstered wood furniture) and hot melts or polyvinyl acetate
(typically used for non-upholstered wood furniture). According to a
representative of Masco Corporation, the vast majority of adhesives
used to assemble non-upholstered wood furniture are hot melts or
polyvinyl acetate. The amount of adhesives used depends on the
type of product.
The next step in the production process is the application of veneer.
Veneer is a thin piece of wood of uniform thickness which is
usually rotary-cut from a bolt of wood using a lathe. Not all
furniture manufacturing involves the application of veneer. The
production of veneer falls under SIC code 24 (lumber and wood
products). The veneer is applied to the furniture part using
adhesives, some of which require the use of heat and/or pressure.
While not a significant source of releases, gluing operations and the
use of adhesives for assembly and veneer are a source of
atmospheric solvent releases.
After veneer application or furniture assembly, the furniture part is
sanded to ensure that its surface is as smooth as possible for the
finishing stages of the production process. Sanding is usually
accomplished by a disk, belt, or roller sanding machine using either
open- or closed-coated sand paper. For open-coated sand paper,
approximately 50 to 70 percent of the paper surface is coated with
abrasive. For closed-coated sand paper, the paper surface is
completely covered with abrasive. Closed-coated sand paper is
generally used in operations requiring higher removal rates. The
sanding process can also be employed at other stages of the
production process, such as prior to the application of veneer or
between the application of several coats of varnish during the
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finishing process. The primary outputs from, sanding are wood
p articulates.
III.A.4. Pre-finishing
After initial sanding, an even smoother surface is attained by
spraying, sponging, or dipping the furniture part with water, which
causes the fibers of the wood to swell and "raise." After the surface
is dried, a solution of glue or resin is applied and allowed to dry,
causing the raised fibers to become more brittle. The raised fibers
are then sanded down to form a particularly smooth surface. The
primary outputs from second sanding are wood and glue or resin
p articulates.
Because certain types of wood contain rosin (a naturally occurring
resin) which can interfere with the effectiveness of certain finishes,
a process known as derosination may be employed. Derosination is
accomplished by applying a mixture of acetone and ammonia to the
surface of the wood. Spent acetone and ammonia are the primary
outputs from derosination.
Once the unwanted rosin is removed from the wood, a process
known as bleaching is used to lighten the color of the wood when
the natural color is darker than that of the stain or finish to be
applied. The process entails spraying, sponging, or dipping the
wood into a bleaching agent, such as hydrogen peroxide. Spent
bleaching agents are the primary outputs of this step of the
production process.
III.A.5. Coating Application
There are various coating application techniques used by the wood
furniture manufacturing industry for applying finishing coatings.
The two principal methods are flatline finishing and spray
application. Flatline finishing is used only to coat truly flat
furniture parts and cannot be used for curved pieces, preassembled
pieces, or pieces with many recesses. Although, spray application is
the most commonly-used method to finish these furniture parts,
brushing and dipping can also be used.
The two principal ways of performing flatline finishing are roll
coating and curtain coating. Roll coating involves the transfer of
coating material by a roller or series of rollers, while curtain coating
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involves passing the furniture part through a cascade, or curtain, of
coating material.
The methods used to spray apply coatings include air, airless, air-
assisted airless, high-volume low-pressure (HVLP), electrostatic,
and the UNICARB® spray system. The conventional air spray
technique uses compressed air to atomize the coating materials as
they are being sprayed, by forcing them through a small opening at
high pressure. The liquid coating is not mixed with air before
exiting the nozzle. Air-assisted airless spray uses an airless spray
unit with a compressed air jet to finalize the breakup of the coating
material.
HVLP spraying involves the use of a high volume of air delivered
at low pressure to atomize the coating material into a pattern of
low-speed particles. The use of low pressure can result in decreased
overspray, which translates into less coating usage and less volatile
organic compound (VOC) emissions.
Electrostatic spraying has long been used in the metalworking and
automobile industries to coat metal products. In the wood
furniture industry, electrostatic spraying has somewhat limited use,
mostly by cabinet and chair manufacturers. This finishing process is
performed by spraying negatively-charged coating particles onto
positively-charged wood products. If the wood piece has a sufficient
moisture content, it can be electrostatically sprayed without
pretreatment. However, some wood must be pretreated to allow
the piece to hold a positive charge. The material used for
pretreatment often contains VOCs.
The UNICARB® system is a relatively new system for spray coating
developed by Union Carbide. A coating normally contains both
coalescing (slow-evaporating) and diluent (fast-evaporating)
solvents. The UNICARB® technology replaces the diluent solvents
with liquid carbon dioxide. The carbon dioxide/coalescing solvent
coating mixture is used to coat the wood with an airless spray gun.
When the coating leaves the spray nozzle, the carbon dioxide in the
mixture immediately flashes, and the coating material, which still
contains coalescing solvents, continues enroute to the piece and
cures in the conventional way. As of June 1991, the UNICARB®
system was being tested in several coatings applications, but was not
yet being used commercially in any production coating operation.
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III.A.6. Finishing
The finishing of wood furniture can be subdivided into two
different categories, interior finishing (furniture for indoor use) and
exterior finishing (furniture for outdoor use), although the actual
production processes involved are fairly similar. The main
difference between interior and exterior finishing is the type of
coating material applied, not the application processes. The
following discussion outlines the production processes involved in
interior finishing; exterior finishing will be mentioned only when
the process differs from that of interior finishing.
Wood finishing processes include coating, drying, and sanding the
furniture in a series of steps which are repeated until the desired
final appearance is achieved. While in small facilities the
assembled furniture is sometimes moved between finishing
stations manually, in most facilities the furniture is moved along
the finishing line mechanically by tow-lines, overhead chain
conveyors, and other conveyors including belt, roller, and slat
conveyors. Tow-lines, chains or cables mounted in or on the floor,
move a pallet, on which the assembled piece of furniture rides
along the finishing line. The pallets can rotate and can be
automatically disengaged from and reengaged to the tow-line to
allow for pauses, as needed. Some facilities move the furniture on
pallets that are hung from overhead chain conveyors. Many
facilities use a combination of these methods to transport the
furniture along the finishing line.
Many of the finishing application methods use relatively high
concentrations of VOCs which volatilize when the coating is
applied. For example, solvents are used in the stains, paints, and
finishes as well as in the inks used to print simulated wood grain
onto plywood and particleboard. In addition, solvents are used in
cleanup operations (i.e., to remove overspray from spray booths and
to rinse solvent-based finishes from spray lines and equipment
between color changes). The primary outputs from the following
finishing applications are point-source and fugitive air emissions,
as well as wood and coating material particulates.
Staining involves the application of a clear colorant which
adds initial color, evens out color, and accents without hiding the
natural wood grain. Stains usually consist of transparent or
semitransparent color solids (typically less than five percent by
volume) suspended in a volatile liquid solution with a certain
amount of a nonvolatile binder, which facilitates spreading,
penetration, and fixation of color. Commonly-used stains, all of
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which are used in conjunction with organic solvents, include:
nongrain-raising, dye-type, no-wipe, and toners.
Nongrain raising stains are dye-type stains which are intended to
give clarity and depth to the wood finish. Dye-type stains consist of
dyes that are completely dissolved in methanol. No-wipe stains are
pigmented stains, containing a small amount of oil, pigment, and
solvent, that are sprayed on and not wiped off. No-wipe stains are
used to accent the wood grain, provide color uniformity and color
retention. Toners are stains that contain nitrocellulose or vinyl
binders, dissolved in solvent. Toners are not wiped, and are often
pigmented.
After staining, a washcoat, consisting of 2 to 13 percent solids by
volume, is applied to the furniture piece. Washcoating is used to
aid in adhesion, assist in filling or color uniformity, and partially
seal the wood from subsequent staining operations. Washcoat also
prepares the wood surface for another sanding after stain
application. Some facilities buy sealer in bulk, and dilute their
sealer to make washcoat. There are three main types of washcoat
materials: standard nitrocellulose; vinyl or modified vinyl; and
vinyl-modified/"conversion" types. Advantages of nitrocellulose
washcoats include quick drying, easy sanding, and clarity. Vinyl and
vinyl-modified washcoats consist of nitrocellulose and vinyl and
provide better toughness and adhesion than pure nitrocellulose
washcoats; however, some clarity is sacrificed. The "conversion" or
precatalyzed-type washcoats also provide good adhesion and
toughness, and are good for open pore woods. Because they react in
place, they are impervious to solvents contained in subsequently
applied sealers and topcoats.
Fillers are applied to the wood surface to produce a smooth,
uniform surface for later stages in the finishing process. Fillers,
which consist of colorless or covering pigments, can be combined
with stains or other pigments and are usually dispersed in a vehicle
of drying oils, synthetic resins, and thinners based on organic
solvents. Fillers are usually supplied as heavily pigmented, high-
solids, low-VOC materials, which are reduced on the job. As
supplied, solids contents of fillers are in the 75 percent solids by
volume range. Once reduced, the solids contents usually range
from 10 percent to 45 percent by volume. Fillers are usually spray
applied, then wiped into the wood.
Sealing, which is completed after staining and either before or after
filling, consists of applying one or many coats of sealer. Sealers are
usually a nitrocellulose-based lacquer, although vinyl or vinyl-
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modified sealers and catalyzed sealers are also available and provide
advantages similar to those of the washcoat counterparts. The
primary purposes of sealers are to provide adhesion, make sanding
more effective, and to seal the wood and establish a foundation for
further coating applications. Solids contents of sealers typically
range from ten to 30 percent by volume.
For outdoor furniture, instead of, or in addition to, the filling and
sealing processes, the wood surface is treated through a process
known as priming. Priming treatments commonly used for
outdoor wooden furniture include the application of fungicide and
water-repellent.
One alternative to staining is painting. The process for applying
paints is similar to that of applying stains or other finishes,
although the chemical composition of paints differs from the other
finishes. Paint is a viscous fluid, usually consisting of a binder or
vehicle, a pigment, a solvent or a thinner, and a drier. Pigments are
insoluble in the coating material and are deposited onto the wood
surface as the vehicle dries. The chemical composition of a pigment
varies according to its color as illustrated in Exhibit 6.
Exhibit 6
Chemical Components of Figments Found in Faint
Pigment Color
White
Red
Orange
Brown
Yellow
Green
Blue
Purple
Black
Chemical Components
Titanium dioxide, white lead, zinc oxide
Iron oxides, calcium sulf ate, cadmium
selenide
Lead chromate-molybdate
Iron oxides
Iron oxides, lead chromate, calcium sulfide
Chromium oxide, copper, phosphotungstic
acid, phosphomolybdic acid
Ferric ferrocyanide, copper
Manganese phosphate
Black iron oxide
Source: McGraw-Hill Encyclopedia of Science and Technology. 1987.
After the furniture part has been stained or painted, a topcoat, such
as varnish or shellac, is applied in one of the final stages of the
finishing process. Topcoats provide a clear coat whose function is to
protect the color coats, enhance the beauty of the furniture, and
provide a durable final finish. Typical solids contents range from 13
to 30 percent solids by volume. There are four categories of
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topcoats: standard nitrocellulose topcoats; acrylic topcoats; catalyzed
topcoats; and conversion varnishes.
Nitrocellulose lacquers provide the best clarity, pick up little dirt,
dry quickly, and are easy to wipe off and repair. Acrylic lacquers are
used over white or pastel finishes as protection from common
household cleaning products. They can also be applied over
nitrocellulose topcoats for color retention. The clarity of acrylic
lacquers is not as good as the nitrocellulose lacquers. Catalyzed
topcoats are available in one- and two-pack form. The one-pack
coatings are precatalyzed, and contain nitrocellulose resins and a
small amount of urea resin. Because only a small amount of
catalyst is added, it can take up to three to four weeks after
application until the coating is completely cured, although it dries
to the touch much sooner. The shelf life of precatalyzed coatings is
more than six months. Conversion varnishes do not dry as quickly
as nitrocellulose topcoats, and are difficult to spot repair, with
washoff also being difficult or impossible. Conversion varnishes,
like two-pack coatings, have a limited pot life.
The two-pack coatings consist of two packs, one containing urea or
melamine-based resins, and the other containing the catalyst. The
two components are mixed before use. More catalyst is added to
two-pack catalyzed coatings, so cure time is short (on the order of
minutes or hours). Two-pack catalyzed coatings have a limited pot
life after mixing (from one day to more than a week).
In the U.S., lacquers (mostly nitrocellulose-based) are used by
approximately 75 percent of the wood furniture industry; mostly by
residential furniture manufacturers. Nitrocellulose lacquers have
been used in the residential wood furniture industry for many
years; they are easy to use, quick drying, and easy to repair.
Approximately 15 percent of the wood furniture industry, primarily
the cabinet and off ice/institutional furniture manufacturers, use
conversion coatings (mostly acid-catalyzed coatings). Cabinets and
off ice/institutional furniture require the chemical and mechanical
resistance offered by catalyzed finishes. As of October 1991,
polyurethane and unsaturated polyester and unsaturated
polyacrylate coatings have had limited use in the United States.
Rubbing, polishing, and cleaning are the final steps of the
production process. Rubbing consists of the application of an
abrasive in conjunction with a lubricant to level or dull the luster.
Polishing consists of the application of soft abrasives or possibly
only waxy ingredients to increase the gloss. The furniture parts are
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then ready for shipment and sale after a final assembly stage, if
appropriate (i.e., attaching table legs to a table top). Exhibit 7
illustrates the steps of the wood furniture manufacturing process.
Exhibit 7
Flow Diagram for Wood Furniture Manufacturing
Raw
Lumber
Interior [Washcoating | ™"Q^ s
inishing L i I ^^-^
Source: Process Flow Diagram for Franklin Furniture of Greeneville, Tennessee found in Pollution Prevention
Ovtions in Wood Furniture Manufacturing. 1992.
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III.B. Raw Material Inputs and Pollution Outputs
The following discussion of raw material inputs and pollution
outputs is organized along the same lines as the production process
description. While there are solid waste and process wastewater
implications for the wood furniture manufacturing industry, the
vast majority of outputs from this industry are air emissions
resulting from the solvent-intensive finishing operations.
IH.B.1. Drying
The major emissions of concern from drying the raw lumber using
wood boilers is particulate matter (PM), although other pollutants,
particularly carbon monoxide (CO) and organic compounds, may be
emitted in significant quantities if the boiler is in poor operating
condition. The type and amount of the emissions depend on a
number of variables, including the composition of the waste fuel
burned, the degree of fly ash reinjection employed, and furnace
design and operating condition.
The composition of wood waste depends largely on the industry
from which it originates. Furniture manufacturing generates a
clean, dry wood waste (e.g., 2 to 20 weight percent moisture) which
produces relatively low particulate emission levels when properly
burned. However, other operations, such as pulp manufacturing,
produce great quantities of bark which may contain a much higher
weight percent moisture, possibly causing bark boilers to emit
considerable particulate matter to the atmosphere unless they are
well controlled.
Furnace design and operating conditions are particularly important
when firing wood waste. Because of the high moisture content that
may be present in wood waste, a larger than usual area of refractory
surface is often necessary to dry the fuel before combustion. In
addition, sufficient secondary air must be supplied over the fuel bed
to burn the volatiles that account for most of the combustible
material in the waste. When proper drying conditions do not exist,
or when secondary combustion is incomplete, the combustion
temperature is lowered, and increased PM, CO, and organic
compound emissions may result. Short-term emissions can
fluctuate with significant variations in fuel moisture content.
Fly ash reinjection, which is commonly used with larger boilers to
improve fuel efficiency, has a considerable effect on PM emissions.
Because a fraction of the collected fly ash is reinjected into the
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boiler, the dust loading from the furnace and, consequently, from
the collection device increase significantly per unit of wood waste
burned. More recent boiler installations typically separate the
collected particulate into large and small fractions in sand classifiers.
The smaller particles, mostly inorganic ash and sand, are sent to ash
disposal.
The four most common control devices used to reduce PM
emissions from wood-fired boilers are mechanical collectors, wet
scrubbers, electrostatic precipitators (ESPs), and fabric filters.
Fabric filters (i.e., baghouses) and ESPs are employed when
collection efficiencies above 95 percent are required. However,
fabric filters have had limited applications to wood-fired boilers.
The principle drawback to fabric filtration, as perceived by potential
users, is a fire danger arising from the collection of combustible
carbonaceous fly ash. Steps can be taken to reduce this hazard,
including the installation of a mechanical collector upstream of the
fabric filter to remove large burning particles of fly ash.
Emissions of nitrogen oxides (NOX) from wood-fired boilers are
lower than those from coal-fired boilers due to the lower nitrogen
content of wood and the lower combustion temperatures which
characterize wood-fired boilers.
According to the AFMA document Integrated Waste Management
Program Applicable to the On-site Management of Certain Non-
hazardous Wood Product Finishing Wastes, dated May 1993, the
operating temperatures of boilers used by this industry are sufficient
to adequately combust the chemical constituents of wood product
finishing waste (i.e., sawdust mixed with dust from the various
coating materials used in furniture finishing operations such as
dried lacquer chips). Based on its interpretation of hazardous waste
as defined in 40 CFR 261.21(a)(2), the AFMA determined that wood
product finishing waste was acceptable for combustion in a boiler.
The State of North Carolina Department of Environment, Health,
and Natural Resources initially disagreed with this interpretation.
However, according to the AFMA, the Director of the Division of
Solid Waste Management, in a March 9, 1994 meeting, approved the
AFMA's interpretation.
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LB.2. Machining
The primary outputs from the sawing and planing processes are
wood chips and sawdust, which are used as fuel in boilers for other
furniture production processes. Wood chips may also be sold to
manufacturers of other wood-based products, such as pulp and
paper mills. Because no coating materials have been applied to the
furniture prior to machining, the particles are almost completely
composed of wood, unlike outputs from later sandings which
contain particles of finishing material as well as wood particles.
HI.B.3. Assembly
Adhesives can be either natural or synthetic in origin and typically
contain solvents. Commonly used adhesive formulations contain
solvents such as methyl isobutyl ketone, methyl ethyl ketone,
xylene, toluene, and 1,1,1-trichloroethane. Solvents are also used to
clean adhesive application equipment such as spray guns.
Adhesives used to apply veneer can differ from adhesives used for
assembly and usually include phenolics, ureas, melamines,
polyvinyl resin emulsions, hot melts, contacts, and mastics.
Application of some of the above-mentioned adhesives requires the
use of heat and/or pressure. Solvent release from the use of
adhesives during assembly and veneer application (either as a
product carrier or cleaning agent) can be significant.
According to a representative of Masco Corporation, the wood
furniture industry primarily uses hot melts or polyvinyl acetate
which do not contain volatile organic compounds and therefore
have little or no emissions implications. Wood chips and sawdust
are outputs of the sanding performed after the assembly and
application of veneer.
HI.B.4. Pre-finishing
Typical outputs of the pre-finishing steps of the manufacturing
process are spent solvents from the derosination process and spent
bleaching agents from the bleaching process. Derosination entails
the application of ammonia and acetone to remove the natural
resin in the wood. The outputs from this step are, therefore, spent
ammonia and acetone, as well as any of the naturally-occurring
resin removed by this process. Bleaching agents typically used by
the wood furniture industry include hydrogen peroxide, sodium
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bisulfite, sodium hyposulfite, sodium perborate, oxalic acid,
potassium permanganate, and sodium or calcium hypochlorite.
III.B.5. Coating Application
In the wood furniture industry, coatings are usually applied in spray
booths, using various types of spray application equipment. The
booths generally do not have any temperature or humidity control,
and are maintained at ambient conditions. Often, both manual and
automatic spray booths are equipped with dry filters, typically a
paper material, to control particulates. In the past, water curtains
had been used to control particulates. However, since the spent
water had to be disposed of as a hazardous waste, and as hazardous
waste disposal costs increased, the cost effectiveness of water curtain
filtration decreased. Therefore, most of the new and modified spray
booths in the wood furniture industry that use filters are equipped
with dry filters. Some water-wash spray booths are still in use.
Recirculating a portion of the exhaust from the spray booth
increases the concentration of VOCs in the exhaust air leaving the
spray booth and discharged to an end-of-pipe control system.
According to a document entitled Demonstration of Paint Spray
Booth Air Recirculation and Flow Partitioning: Design Validation,
the concept of recirculation was patented by John Deere Corporation
in 1979, but a large segment of the coating industry mistakenly
believed that this practice was prohibited by OSHA regulations.
During approved recirculation practices, equal portions of fresh air
and recirculated air are pumped back into the booth. One advantage
of using recirculation is the decreased exhaust flow volume emitted
to the atmosphere and decreased capitol and operating costs of the
VOC control system. A joint EPA and U.S. Air Force research and
development program developed these emissions control concepts
for hazardous air pollutants (HAPs).
There are two types of add-on control devices, technologies used to
capture pollutants from point-source air emissions: combustion
control devices and recovery devices. Combustion control devices
are used to destroy contaminants, converting them primarily to
carbon dioxide and water. Combustion control devices used by the
furniture industry include thermal incineration, with recuperative
and regenerative heat recovery, and catalytic incineration.
Recovery devices are used to collect VOCs prior to their final
disposition. One recovery device is carbon adsorption used in
conjunction with regeneration of the carbon bed by steam or hot air.
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By using either steam or hot air, the VOCs may be recovered or
disposed of following regeneration.
Thermal incineration is a process by which waste gas is brought to
adequate temperature, and held at that temperature for a sufficient
time for the organic compounds in the waste gas to oxidize.
Catalytic incineration is comparable to thermal incineration in that
VOCs are heated to a temperature sufficient for oxidation to occur.
However, with catalytic incineration, the temperature required for
oxidation is considerably lower than that required for thermal
incineration because a catalyst is used to promote oxidation of
contaminants. Platinum is the most widely used catalyst;
palladium is also commonly used. Because the metals used as
catalysts are expensive, only a thin film is applied to the supporting
substrate. A commonly used substrate is ceramic.
ffl.B.6. Finishing
The primary outputs of the finishing steps of the manufacturing
process include solvent emissions to the atmosphere, as well as
spent solvents, and particles of wood and coating materials applied
to the furniture. Solvents or thinners typically used in paints
include toluene or xylene. Rubbing and polishing, performed after
finishing, require the use of materials containing lubricants, such as
detergents and petroleum-based thin oils, and abrasives, such as
pumice, tripoli, and diatomaceous earth. Because wood furniture
finishing is a solvent-intensive process, the primary outputs are
spent solvents and solvent emissions.
Flashoff areas are areas that are either between spray booths, or
between a spray booth and an oven, in which solvent is allowed to
volatilize from the coated piece. While some flashoff areas have
forced air circulation and are referred to as forced-flashoff areas,
most flashoff areas do not have a separate exhaust. The length of
flashoff areas varies significantly by facility, and even within a
facility, depending on whether the coating will be cured in an oven.
A flashoff area that is not followed by an oven is often longer than
one that is located in between a booth and an oven.
Ovens are used between some coating steps to cure the coating prior
to the next step in the finishing sequence. Many types of ovens are
used in the wood furniture industry. Most are steam-heated using
either a wood- or coal-fired boiler; others are gas-fired. Infrared or
ultraviolet ovens are also used, but their use in the wood furniture
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industry is limited at this time. Oven temperatures can range from
less than 38 to 121 degrees Celsius depending on the type of coating
used, the piece being coated, and the oven residence time. The
exhaust rate from ovens also varies, and can range between 21.2 and
425 cubic meters per minute.
Exhibit 8 contains the relative VOC emissions for three different
model plants: a residential furniture manufacturing facility using a
long finishing sequence (consisting of a total of three or more stain
applications; a single application of wash coat, filler, sealer, and
highlight; and two or three topcoat applications); a residential
furniture manufacturing facility using a short finishing sequence
(consisting of two stain applications, one application of washcoat
and sealer, and two topcoat applications); and an off ice/cabinet
manufacturing facility using a short finishing sequence (consisting
of one application of stain, sealer, and topcoat). The relative VOC
emissions are presented as a percent of each coating applied for each
model plant.
Exhibit 8
Relative VOC Emissions
Type of plant
Stain
Washcoat
Filler
Wiping stain/glaze
Sealer
Highlight
Topcoat
Total
Furniture long
26 percent
4 percent
3 percent
8 percent
18 percent
1 percent
40 percent
100 percent
Furniture short
28 percent
4 percent
...
32 percent
...
36 percent
100 percent
Office/cabinet
32 percent
.._
...
32 percent
...
36 percent
100 percent
Source: EPA Draft Guidelines for the Control of Volatile Organic Compound Emissions
from Wood Furniture Coatin? Operations.
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III.B.7. Cleanup Operations
Solvent-borne nitrocellulose lacquers are the predominant type of
coatings used by the wood furniture industry today. The resins in
such coatings are relatively "difficult" to dissolve, so a high-
solvency-rated solvent must be used in their formulation.
Similarly, thinning of these coatings requires the use of the same
solvent or one with equivalent solvency. This solvent is
generically referred to as "lacquer thinner." The current practice is
to use lacquer thinner for both incidental thinning of premixed
coatings and for cleanup of the coatings. Advantages of the lacquer
thinner include its compatibility with the finishing materials and
the ease with which it removes cured nitrocellulose lacquers.
In wood-coating operations, industrial solvents are used
predominantly for cleaning application equipment. In addition,
cleanup solvent can also be used to clean out piping, clean booths
and rails, strip cured coatings from wood parts or machinery, and
periodically clean centralized coating storage and distribution
(pump room) equipment.
Application equipment must be cleaned every time there is a color
change, and usually before the equipment is to be idle for a period of
time (e.g., at the end of the day). For spray coating application,
equipment cleaned with solvents includes spray guns, feed lines,
and coating reservoirs (where applicable). In the case of roll coating
operations, the rollers and spray bar nozzles must be cleaned
periodically to maintain application quality as well as prior to color
changes.
Spray guns have traditionally been cleaned by sending pure solvent
from the coating reservoir through the gun, and atomizing the
solvent into the booth ventilation system. Recognizing that this
results in significant emissions of solvent, some operators cut off
the atomizing air to the spray gun and pump the cleanup solvent
through the gun into a container. This procedure can work if the
gun is the type that does not depend on the flow of the atomizing
air to pump the coating (or cleanup solvent) through the
mechanism. Alternately, cleanup may involve soaking the entire
gun in solvent. This guards against the possibility that small
amounts of coating inadvertently missed during the cleaning will
cure and clog the small orifices of the gun. Cleanup solvent is often
reused within a facility, and eventually recycled in-house or sent
out for recycling/disposal. Exhibit 9 provides an overview of the
material inputs and pollution outputs for each step of the wood
furniture manufacturing process.
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Exhibit 9
Inputs and Outputs of Wood Furniture Manufacturing Facilities
Process
Material Input
Air Emissions
Process Wastes
Other Wastes
Drying
Ovens/Drying
Kilns (boilers
covered below)
Raw lumber
Emissions,
including water
and possible
chemicals used in
pretreatment of
raw lumber
Machining
Sawing/Planing/
Sanding
Bending/Drying
(boilers covered
below)
Dried lumber
Lumber
Wood chips,
sawdust
Emissions,
including water
and possible
chemicals used in
pretreatment of
raw lumber
Wood chips,
sawdust
Wood chips,
sawdust
Assembly
Gluing/Veneer
Application
Sanding
Hot melts, polyvinyl
acetate, solvent-
based adhesives (e.g.,
methyl isobutyl
ketone, methyl ethyl
ketone, xylene,
toluene, 1,1,1-
trichloroethane)
Assembled furniture
Solvent emissions
(e.g., methyl
isobutyl ketone,
methyl ethyl
ketone, xylene,
toluene, 1,1,1-
trichloroethane)
Wood chips,
sawdust
Wood chips,
sawdust
Spent solvent-
based adhesives
(e.g., methyl
isobutyl ketone,
methyl ethyl
ketone, xylene,
toluene, 1,1,1-
trichloroethane)
Wood chips,
sawdust
Pre-finishing
Watering/Sanding
Derosination
Assembled furniture,
water, adhesives,
resins
Ammonia, acetone
Solvent emissions
(e.g., acetone)
Wood chips,
sawdust,
adhesive, and
resin particles
Spent acetone,
ammonia,
natural resin
from wood
Wood chips,
sawdust,
adhesive, and
resin particles
Spent acetone,
ammonia,
natural resin
from wood
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Exhibit 9 (cont'd)
Inputs and Outputs of Wood Furniture Manufacturing Facilities
Process
Material Input || Air Emissions
Process Wastes
Other Wastes
Pre-finishing (continued)
Bleaching
Bleaching agents
(e.g., hydrogen
peroxide, sodium
bisulfite, sodium
hyposulfite, sodium
perborate, oxalic
acid, potassium
permanganate,
sodium or calcium
hypochlorite)
Spent bleaching
agents (e.g.,
hydrogen
peroxide, sodium
bisulfite, sodium
hyposulfite,
sodium perborate,
oxalic acid,
potassium
permanganate,
sodium or calcium
hypochlorite)
Spent bleaching
agents (e.g.,
hydrogen
peroxide, sodium
bisulfite, sodium
hyposulfite,
sodium perborate,
oxalic acid,
potassium
permanganate,
sodium or calcium
hypochlorite)
Finishing
Staining
Washcoating
Filling
Mineral spirits,
alcohol, solvents,
pigments (e.g., iron
oxides, lead
chromate, calcium
sulfate, cadmium
selenide)
Nitrocellulose-based
lacquers, acrylic
lacquers, varnish,
shellac,
polyurethane,
solvents
Pigments (e.g., iron
oxides, lead
chromate, calcium
sulfate, cadmium
selenide), stains,
drying oils, synthetic
resins, solvent-based
thinners
Solvent
emissions
Solvent
emissions
Solvent
emissions
Pigment wastes
(e.g., iron oxides,
lead chromate,
calcium sulfate,
cadmium
selenide), solvent
wastes
Spent solvents,
nitrocellulose-
based lacquers,
acrylic lacquers,
varnish, poly-
urethane, and
shellac
Spent solvents,
stains, drying
oils, synthetic
resins, thinners,
and pigments
(e.g., iron oxides,
lead chromate,
calcium sulfate,
cadmium
selenide)
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Exhibit 9 (cont'd)
Inputs and Outputs of Wood Furniture Manufacturing Facilities
Process || Material Input || Air Emissions
Process Wastes
Solid Wastes
Finishing (continued)
Sealing
Priming
Painting
Topcoat Application
Sanding (occurs
intermittently
between each of the
above finishing
applications)
Rubbing/Polishing
Nitrocellulose-based
lacquers, acrylic
lacquers, varnish,
shellac, solvents,
polyurethane
Fungicide, water-
repellent
Toluene, pigments
(e.g., titanium
dioxide, iron oxides,
lead chromate),
epoxy-ester resins,
aromatic
hydrocarbons, glycol
ether, halogenated
hydrocarbons, vinyl
acetate, acrylic
Denatured alcohols,
resins, shellac,
petroleum distillates,
toluene, disocyanate
Finished piece of
furniture
Lubricants,
detergents,
petroleum-based thin
oils, pumice, tripoli,
diamaceous earth
Solvent
emissions
Solvent
emissions (e.g.,
toluene)
Solvent
emissions (e.g.,
toluene)
Particles that
include wood,
adhesive,
resin,
nitrocellulose
lacquer, paint,
stain, filler,
and sealer
Particles that
include wood,
adhesive, resin,
nitrocellulose
lacquer, paint,
stain, filler,
and sealer
Spent solvents,
nitrocellulose-
based lacquers,
acrylic lacquers,
varnish, shellac,
polyurethane
Spent solvents
(e.g., toluene),
pigments (e.g.,
titanium dioxide,
iron oxides, lead
chromate),
epoxy-ester
resins, aromatic
hydrocarbons,
glycol ether,
halogenated
hydrocarbons,
vinyl acetate,
acrylic
Spent denatured
alcohols, resins,
shellac,
petroleum
distillates,
toluene,
disocyanate
Particles that
include wood,
adhesive, resin,
nitrocellulose
lacquer, paint,
stain, filler, and
sealer
Spent lubricants,
detergents, oils
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Exhibit 9 (cont'd)
Inputs and Outputs of Wood Furniture Manufacturing Facilities
Process
Material Input
Air Emissions
Process Wastes
Solid Wastes
Cleanup Operations
Brush Cleaning/
Spray Gun Cleaning
Boilers
Boilers
Acetone, toluene,
petroleum distillates,
methanol, methylene
chloride,
isopropanol, mineral
spirits, alcohols
Wood and coating
material particulates
from the finishing
process
Solvent
emissions (e.g.,
acetone,
toluene,
methanol,
methylene
chloride)
Spent solvents
(e.g., acetone,
toluene,
methanol,
methylene
chloride),
mineral spirits,
alcohols,
petroleum
distillates
Spent solvents
(e.g., acetone,
toluene,
methanol,
methylene
chloride),
mineral spirits,
alcohols,
petroleum
distillates
Boiler ash
particulates
Boiler ash
Source: Pollution Prevention Options m Wood Furniture Manufacturing. 1992.
III.C Management of Chemicals in Wastestream
The Pollution Prevention Act of 1990 (EPA) requires facilities to
report information about the management of TRI chemicals in
waste and efforts made to eliminate or reduce those quantities.
These data have been collected annually in Section 8 of the TRI
reporting Form R beginning with the 1991 reporting year. The data
summarized below cover the years 1992-1995 and is meant to
provide a basic understanding of the quantities of waste handled by
the industry, the methods typically used to manage this waste, and
recent trends in these methods. TRI waste management data can be
used to assess trends in source reduction within individual
industries and facilities, and for specific TRI chemicals. This
information could then be used as a tool in identifying
opportunities for pollution prevention compliance assistance
activities.
While the quantities reported for 1992 and 1993 are estimates of
quantities already managed, the quantities reported for 1994 and
1995 are projections only. The EPA requires these projections to
encourage facilities to consider future waste generation and source
reduction of those quantities as well as movement up the waste
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management hierarchy. Future-year estimates are not
commitments that facilities reporting under TRI are required to
meet.
Exhibit 10 shows that the furniture and fixtures industry managed
about 47 million pounds of production-related waste (total quantity
of TRI chemicals in the waste from routine production operations)
in 1993 (column B). Column C reveals that of this production-
related waste, 98 percent was either transferred off-site or released to
the environment. Column C is calculated by dividing the total TRI
transfers and releases by the total quantity of production-related
waste. In other words, about one percent of the industry's TRI
wastes were managed on-site through recycling, energy recovery, or
treatment as shown in columns D, E and F, respectively. The
majority of waste that is released or transferred off-site can be
divided into portions that are recycled off-site, recovered for energy
off-site, or treated off-site as shown in columns G, H, and I,
respectively. The remaining portion of the production-related
wastes (90.6 percent), shown in column J, is either released to the
environment through direct discharges to air, land, water, and
underground injection, or it is disposed off-site.
From the yearly data presented below it is apparent that the portion
of TRI wastes reported as recycled on-site has remained steady and
the portions treated or managed through energy recovery orv-site
have decreased slightly between 1992 and 1995 (projected).
Exhibit 10
Source Reduction and Recycling Activity for SIC 25
A
Year
1992
1993
1994
1995
B
Production
Related
Waste
Volume
(106lbs.)
44
47
44
44
C
% Reported
as Released
and
Transferred
100%
98%
—
—
D
F
On-Site
%
Recycled
0.66%
0.70%
0.76%
0.73%
% Energy
Recovery
0.00%
0.02%
0.00%
0.00%
% Treated
0.57%
0.42%
0.46%
0.46%
G
ii
I
Off-Site
%
Recycled
2.32%
2.38%
2.47%
2.60%
% Energy
Recovery
6.55%
5.10%
4.60%
5.19%
%
Treated
0.90%
0.80%
0.78%
0.72%
J
Remaining
Releases
and
Disposal
89.35%
90.58%
90.93%
90.31%
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IV. CHEMICAL RELEASE AND TRANSFER PROFILE
This section is designed to provide background information on the
pollutant releases that are reported by this industry. The best source
of comparative pollutant release information is the Toxic Release
Inventory System (TRI). Pursuant to the Emergency Planning and
Community Right-to-Know Act, TRI includes self-reported facility
release and transfer data for over 600 toxic chemicals. Facilities
within SIC Codes 20-39 (manufacturing industries) that have more
than 10 employees, and that are above weight-based reporting
thresholds are required to report TRI on-site releases and off-site
transfers. The information presented within the sector notebooks is
derived from the most recently available (1993) TRI reporting year
(which then included 316 chemicals), and focuses primarily on the
on-site releases reported by each sector. Because TRI requires
consistent reporting regardless of sector, it is an excellent tool for
drawing comparisons across industries.
Although this sector notebook does not present historical
information regarding TRI chemical releases over time, please note
that in general, toxic chemical releases have been declining. In fact,
according to the 1993 Toxic Release Inventory Data Book, reported
releases dropped by 42.7% between 1988 and 1993. Although on-site
releases have decreased, the total amount of reported toxic waste
has not declined because the amount of toxic chemicals transferred
off-site has increased. Transfers have increased from 3.7 billion
pounds in 1991 to 4.7 billion pounds in 1993. Better management
practices have led to increases in off-site transfers of toxic chemicals
for recycling. More detailed information can be obtained from
EPA's annual Toxics Release Inventory Public Data Release book
(which is available through the EPCRA Hotline at 1-800-535-0202),
or directly from the Toxic Release Inventory System database (for
user support call 202-260-1531).
Wherever possible, the sector notebooks present TRI data as the
primary indicator of chemical release within each industrial
category. TRI data provide the type, amount, and media receptor of
each chemical released or transferred. When other sources of
pollutant release data have been obtained, these data have been
included to augment the TRI information.
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TRI Data Limitations
The reader should keep in mind the following limitations
regarding TRI data. Within some sectors, the majority of facilities
are not subject to TRI reporting because they are not considered
manufacturing industries, or because they are below TRI reporting
thresholds. Examples are the mining, dry cleaning, printing, and
transportation equipment cleaning sectors. For these sectors, release
information from other sources has been included.
The reader should also be aware that TRI "pounds released" data
presented within the notebooks is not equivalent to a "risk"
ranking for each industry. Weighting each pound of release equally
does not factor in the relative toxicity of each chemical that is
released. The Agency is in the process of developing an approach to
assign toxicological weightings to each chemical released so that one
can differentiate between pollutants with significant differences in
toxicity. As a preliminary indicator of the environmental impact of
the industry's most commonly released chemicals, the notebook
briefly summarizes the toxicological properties of the top five
chemicals (by weight) reported by each industry.
Definitions Associated With Section IV Data Tables
General Definitions
SIC Code — the Standard Industrial Classification (SIC) is a statistical
classification standard used for all establishment-based Federal
economic statistics. The SIC codes facilitate comparisons between
facility and industry data.
TRI Facilities — are manufacturing facilities that have 10 or more
full-time employees and are above established chemical throughput
thresholds. Manufacturing facilities are defined as facilities in
Standard Industrial Classification primary codes 20-39. Facilities
must submit estimates for all chemicals that are on the EPA's
defined list and are above throughput thresholds.
Data Table Column Heading Definitions
The following definitions are based upon standard definitions
developed by EPA's Toxic Release Inventory Program. The
categories below represent the possible pollutant destinations that
can be reported.
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Wood Furniture and Fixtures
Sector Notebook Project
RELEASES — are an on-site discharge of a toxic chemical to the
environment. This includes emissions to the air, discharges to
bodies of water, releases at the facility to land, as well as contained
disposal into underground injection wells.
Releases to Air (Point and Fugitive Air Emissions) — Include all air
emissions from industry activity. Point emissions occur through
confined air streams as found in stacks, ducts, or pipes. Fugitive
emissions include losses from equipment leaks, or evaporative
losses from impoundments, spills, or leaks.
Releases to Water (Surface Water Discharges) - encompass any
releases going directly to streams, rivers, lakes, oceans, or other
bodies of water. Any estimates for stormwater runoff and non-
point losses must also be included.
Releases to Land — includes disposal of waste to on-site landfills,
waste that is land treated or incorporated into soil, surface
impoundments, spills, leaks, or waste piles. These activities must
occur within the facility's boundaries for inclusion in this category.
Underground Injection — is a contained release of a fluid into a
subsurface well for the purpose of waste disposal.
TRANSFERS — is a transfer of toxic chemicals in wastes to a facility
that is geographically or physically separate from the facility
reporting under TRI. The quantities reported represent a
movement of the chemical away from the reporting facility. Except
for off-site transfers for disposal, these quantities do not necessarily
represent entry of the chemical into the environment.
Transfers to POTWs — are wastewaters transferred through pipes or
sewers to a publicly owned treatments works (POTW). Treatment
and chemical removal depend on the chemical's nature and
treatment methods used. Chemicals not treated or destroyed by the
POTW are generally released to surface waters or landfilled within
the sludge.
Transfers to Recycling - are sent off-site for the purposes of
regenerating or recovering still valuable materials. Once these
chemicals have been recycled, they may be returned to the
originating facility or sold commercially.
Transfers to Energy Recovery — are wastes combusted off-site in
industrial furnaces for energy recovery. Treatment of a chemical by
incineration is not considered to be energy recovery.
SIC Code 25
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Wood Furniture and Fixtures
Transfers to Treatment — are wastes moved off-site for either
neutralization, incineration, biological destruction, or physical
separation. In some cases, the chemicals are not destroyed but
prepared for further waste management.
Transfers to Disposal — are wastes taken to another facility for
disposal generally as a release to land or as an injection
underground.
IV.A. Toxic Release Inventory for the Wood Furniture and Fixtures
Industry
Exhibits 13-15 illustrate the TRI releases and transfers for the entire
furniture and fixtures industry (SIC 25). For the industry as a
whole, solvents (such as toluene, methanol, xylene, methyl ethyl
ketone, and acetone) comprise the largest number of TRI releases.
The large number of solvent releases, both fugitive and point
source emissions, result from the solvent-intensive finishing
processes employed by this industry. In addition to being used as
vehicle carriers, solvents are also used to clean the coatings
application equipment.
The TRI database contains a detailed compilation of self-reported,
facility-specific chemical releases. The top reporting facilities for
this sector are listed below. Facilities that have reported only the
SIC codes covered under this notebook appear in Exhibit 11. Exhibit
12 contains additional facilities that have reported the SIC code
covered within this report, and one or more SIC codes that are not
within the scope of this notebook. Therefore, Exhibit 12 includes
facilities that conduct multiple operations — some that are under
the scope of this notebook, and some that are not. Currently, the
facility-level data do not allow pollutant releases to be broken apart
by industrial process.
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Wood Furniture and Fixtures
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Exhibit 11
Top 10 TRI Releasing Furniture Manufacturing Facilities (SIC 25)
Rank
1
2
3
4
5
6
7
8
9
10
Total TRI
Releases in
Founds
1,277,737
831,751
723,669
700,675
688,907
662,695
661,059
642,385
639,345
502,582
Facility Name
Broyhill Furniture Ind., Inc. Complex
Broyhill Furniture Ind., Inc., Lenoir
Furn. & Occas.
Singer Furniture Co.
Korn Ind., Inc.
Lane Co., Inc.
Okla Homer Smith Furniture Co., Inc.
Stanley Furniture Co.
J. D. Bassett Mfg. Co.
Peters-Revington Furniture
Bassett Superior Lines
City
Lenoir
Lenoir
Lenoir
Sumter
Altavista
Fort Smith
Stanleytown
Bassett
Delphi
Bassett
State
NC
NC
NC
sc
VA
AR
VA
VA
IN
VA
Source: U.S. EPA, Toxics Release Inventory Database,
Exhibit 12
Top 10 TRI Releasing Furniture and Fixtures Facilities
SIC Codes
2522, 2542,
2521
2511
2542,2541
2511
2522, 2542,
2521
2511
2511
2511
2511
2511
Total TRI
Releases in
Pounds
1,321,283
1,277,737
939,055
831,751
809,096
723,669
700,675
688,907
662,695
661,059
Facility Name
Steelcase Inc.
Broyhill Furniture Ind.
Complex
Radix, Inc.
Broyhill Furniture Ind., Inc.
Lenoir Furn. & Occas.
Steelcase Inc.
Singer Furniture Co.
Korn Ind., Inc.
Lane Co., Inc.
Okla Homer Smith
Furniture Co., Inc.
Stanley Furniture Co.
City
Grand Rapids
Lenoir
Goodwater
Lenoir
Kentwood
Lenoir
Sumter
Altavista
Fort Smith
Stanleytown
State
MI
NC
AL
NC
NI
NC
SC
VA
AR
VA
Source: U.S. EPA, Toxics Release Inventory Database, WV6.
Note: Being included on this list does not mean that the release is associated with non-compliance
with environmental laws.
SIC Code 25
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Sector Notebook Project
Wood Furniture and Fixtures
Exhibit 13
TRI Reporting Furniture Manufacturing Facilities (SIC 25) by State
State
AL
AR
AZ
CA
CO
CT
PL
GA
IA
IL
IN
KS
KY
MA
ME
MI
MN
MO
Number of
Facilities
7
8
2
23
2
1
3
5
3
2
27
3
4
6
2
6
5
5
State
MS
NC
NE
NH
NY
OH
OK
OR
PA
SC
TN
UT
VA
VT
WA
WI
wv
Number of
Facilities
3
92
2
1
14
4
2
3
9
5
13
2
32
3
3
10
1
Source: U.S. EPA, Toxics Release Inventory Database, 2933.
Exhibit 14
Releases for Furniture Manufacturing Facilities (SIC 25) in TRI, by Number
Facilities (Releases reported in pounds/year)
of
Chemical Name
Toluene
Methanol
Xylene (Mixed Isomers)
Methyl Ethyl Ketone
Acetone
N-Butyl Alcohol
Methyl Isobutyl Ketone
Glycol Ethers
1,1,1 -Trichloroethane
Ethylbenzene
Isopropyl Alcohol
(Manufacturing)
Dichloromethane
Formaldehyde
Styrene
Di(2-Ethylhexyl) Phthalate
# Facilities
Reporting
Chemical
247
178
174
166
115
99
55
26
25
21
11
6
6
6
4
Fugitive
Air
1456881
908347
742449
439743
282555
151616
206847
68627
262643
120246
9747
102811
30226
2744
255
Point Air
10541044
8166501
5085471
4241878
3157999
2208962
1293417
413901
1334203
241345
278413
43894
1086
42252
12458
Water
Discharges
5
10
5
5
5
5
5
0
0
0
0
0
0
0
0
Under-
ground
Injection
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Land
Disposal
70819
7347
14064
21507
28328
13531
58491
0
4900
0
0
0
0
0
0
Total
Releases
12068749
9082205
5841989
4703133
3468887
2374114
1558760
482528
1601746
361591
288160
146705
31312
44996
12713
Average
Releases
per
Facility
48861
51024
33575
28332
30164
23981
28341
18559
64070
17219
26196
24451
5219
7499
3178
September 1995
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Wood Furniture and Fixtures
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Exhibit 14 (cont'd)
Releases for Furniture Manufacturing Facilities (SIC 25) in TRI, by Number of
Facilities (Releases reported in pounds/year)
Chemical Name
Ethylcnc Glycol
1,2,4-Trimethylbenzene
Trichlorocthylenc
Barium Compounds
Manganese
Melhylenebis
(Phenylisocyanate)
Naphthalene
Aluminum Oxide (Fibrous
Form)
Ammonia
Chromium
Copper
Cumene
Dibutyl Phthalate
Diethyl Sulfatc
Lead
Maleic Anhydride
Nickel
Phenol
Sulfuric Acid
Vinyl Acetate
Totals
# Facilities
Reporting
Chemical
4
4
3
2
2
2
2
1
1
1
1
1
1
1
1
1
1
1
1
1
313
Fugitive
Air
616
2159
1600
0
251
10
6
11
250
250
250
6
6
869
250
0
250
1
0
1
4,792,523
Point Air
26576
39987
41781
0
3
0
113
224
17000
0
0
114
110
16516
0
0
0
19
0
1163
37,206,430
Water
Discharges
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
40
Under-
ground
Injection
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Land
Disposal
0
0
0
518
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
219,505
Total
Releases
27192
42146
43381
518
254
10
119
235
17250
250
250
120
116
17385
250
0
250
20
0
1164
42,218,498
Average
Releases
per
Facility
6798
10537
14460
259
127
5
60
235
17250
250
250
120
116
17385
250
0
250
20
0
1164
134,883
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
SIC Code 25
42
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Wood Furniture and Fixtures
Exhibit 15
Transfers for Furniture Manufacturing Facilities (SIC 25) in TRI, by Number of
Facilities (Transfers reported in pounds/year)
Chemical Name
Toluene
Methanol
Xylene (Mixed
Isomers)
Methyl Ethyl Ketone
Acetone
N-Butyl Alcohol
Methyl Isobutyl Ketone
Glycol Ethers
1,1,1 -Trichloroethane
Ethylbenzene
Isopropyl Alcohol
(Manufacturing)
Dichloromethane
Formaldehyde
Styrene
Di(2-Ethylhexyl)
Phthalate
Ethylene Glycol
1,2,4-
Trimethylbenzene ,
Trichloroethylene
Barium Compounds
Manganese
Methylenebis
(Phenylisocyanate)
Naphthalene
Aluminum Oxide
(Fibrous Form)
Ammonia
Chromium
Copper
Cumene
Dibutyl Phthalate
Diethyl Sulfate
Lead
Maleic Anhydride
Nickel
Phenol
Sulfuric Acid
Vinyl Acetate
Totals
# Facilities
Reporting
Chemical
247
178
174
166
115
99
55
26
25
21
11
6
6
6
4
4
4
3
2
2
2
2
1
1
1
1
1
1
1
1
1
1
1
1
1
313
POTW
Discharges
3737
2114
2869
1540
1030
531
260
0
0
255
499
0
250
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
13,085
Disposal
48124
33630
43912
38830
250
1925
5905
31500
750
204,826
Recycling
400040
162308
83315
176031
281800
40077
7812
7455
17979
8520
1331
1,186,668
Treatment
117454
25295
43768
57181
33469
26163
67211
1284
165
330
10430
0
382,750
Energy
Recovery
746458
387147
212406
530621
304307
81491
63094
43794
5608
10363
28509
4000
131
1625
3393
2,422,947
Total
Transfers
1315821
610494
386270
804953
620606
148762
140552
52533
11513
60262
29338
14430
250
8651
1625
0
3393
1331
750
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
4,211,534
Average
Transfers
per
Facility
5327
3430
2220
4849
5397
1503
2555
2021
461
2870
2667
2405
42
1442
406
0
848
444
375
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
13,455
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
September 1995
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IV.B. Summary of the Selected Chemicals Released
The following is a synopsis of current scientific toxicity and fate
information for the top chemicals (by weight) that facilities within
this sector self-reported as released to the environment based upon
1993 TRI data. Because this section is based upon self-reported
release data, it does not attempt to provide information on
management practices employed by the sector to reduce the release
of these chemicals. Information regarding pollutant release
reductions over time may be available from EPA's TRI and 33/50
programs, or directly from the industrial trade associations that are
listed in Section IX of this document. Since these descriptions are
cursory, please consult the sources referenced below for a more
detailed description of both the chemicals described in this section,
and the chemicals that appear on the full list of TRI chemicals
appearing in Section IV.A.
The brief descriptions provided below were taken from the 1993
Toxics Release Inventory Public Data Release (U.S. EPA, 1994), the
Hazardous Substances Data Bank (HSDB), and the Integrated Risk
Information System (IRIS), both accessed via TOXNET1. The
information contained below is based upon exposure assumptions
that have been conducted using standard scientific procedures. The
effects listed below must be taken in context of these exposure
assumptions that are more fully explained within the full chemical
profiles in HSDB.
1 TOXNET is a computer system run by the National Library of Medicine that includes a number of
toxicological databases managed by EPA, National Cancer Institute, and the National Institute for
Occupational Safety and Health. For more information on TOXNET, contact the TOXNET help line
at 1-800-231-3766. Databases included in TOXNET are: CCRIS (Chemical Carcinogenesis Research
Information System), DART (Developmental and Reproductive Toxicity Database), DBIR
(Directory of Biotechnology Information Resources), EMICBACK (Environmental Mutagen
Information Center Backfile), GENE-TOX (Genetic Toxicology), HSDB (Hazardous Substances
Data Bank), IRIS (Integrated Risk Information System), RTECS (Registry of Toxic Effects of
Chemical Substances), and TRI (Toxic Chemical Release Inventory). HSDB contains chemical-
specific information on manufacturing and use, chemical and physical properties, safety and
handling, toxicity and biomedical effects, pharmacology, environmental fate and exposure
potential, exposure standards and regulations, monitoring and analysis methods, and additional
references.
SIC Code 25
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Sector Notebook Project
Wood Furniture and Fixtures
Toluene
The top TRI releases for the furniture and fixtures industry (SIC 25)
as a whole, include:
Toluene
Methanol
Xylene
Methyl ethyl ketone
Acetone
N-butyl alcohol
1 1,1-trichloroethane
Dichloromethane.
Summaries of some of these chemicals follow.
Toxicity. Inhalation or ingestion of toluene can cause headaches,
confusion, weakness, and memory loss. Toluene may also affect the
way the kidneys and liver function.
Reactions of toluene (see environmental fate) in the atmosphere
contribute to the formation of ozone in the lower atmosphere.
Ozone can affect the respiratory system, especially in sensitive
individuals such as asthma or allergy sufferers.
Some studies have shown that unborn animals were harmed when
high levels of toluene were inhaled by their mothers, although the
same effects were not seen when the mothers were fed large
quantities of toluene. Note that these results may reflect similar
difficulties in humans.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
Environmental Fate. The majority of releases of toluene to land
and water will evaporate. Toluene may also be degraded by
microorganisms. Once volatized, toluene in the lower atmosphere
will react with other atmospheric components contributing to the
formation of ground-level ozone and other air pollutants.
Physical Properties. Toluene is a volatile organic chemical.
September 1995
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Sector Notebook Project
Methanol
Toxicity. Methanol is readily absorbed from the gastrointestinal
tract and the respiratory tract, and is toxic to humans in moderate to
high doses. In the body, methanol is converted into formaldehyde
and formic acid. Methanol is excreted as formic acid. Observed
toxic effects at high dose levels generally include central nervous
system damage and blindness. Long-term exposure to high levels of
methanol via inhalation cause liver and blood damage in animals.
Ecologically, methanol is expected to have low toxicity to aquatic
organisms. Concentrations lethal to half the organisms of a test
population are expected to exceed 1 mg methanol per liter water.
Methanol is not likely to persist in water or to bioaccumulate in
aquatic organisms.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
Environmental Fate. Liquid methanol is likely to evaporate when
left exposed. Methanol reacts in air to produce formaldehyde which
contributes to the formation of air pollutants. In the atmosphere it
can react with other atmospheric chemicals or be washed out by
rain. Methanol is readily degraded by microorganisms in soils and
surface waters.
Physical Properties. Methanol is highly flammable.
Xvlene (Mixed Isomers)
Toxicity. Xylenes are rapidly absorbed into the body after inhalation,
ingestion, or skin contact. Short-term exposure of humans to high
levels of xylenes can cause irritation of the skin, eyes, nose, and
throat, difficulty in breathing, impaired lung function, impaired
memory, and possible changes in the liver and kidneys. Both short-
and long-term exposure to high concentrations can cause effects
such as headaches, dizziness, confusion, and lack of muscle
coordination. Reactions of xylenes (see environmental fate) in the
atmosphere contribute to the formation of ozone in the lower
atmosphere. Ozone can affect the respiratory system, especially in
sensitive individuals such as asthma or allergy sufferers.
Carcino genicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
SIC Code 25
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Wood Furniture and Fixtures
Environmental Fate. The majority of releases to land and water
will quickly evaporate, although some degradation by
microorganisms will occur.
Xylenes are moderately mobile in soils and may leach into
ground water, where they may persist for several years.
Xylenes are volatile organic chemicals. As such, xylenes in the
lower atmosphere will react with other atmospheric components,
contributing to the formation of ground-level ozone and other air
pollutants.
Methyl Ethvl Ketone
Acetone
Toxicity. Breathing moderate amounts of methyl ethyl ketone
(MEK) for short periods of time can cause adverse effects on the
nervous system ranging from headaches, dizziness, nausea, and
numbness in the fingers and toes to unconsciousness. Its vapors are
irritating to the skin, eyes, nose, and throat and can damage the
eyes. Repeated exposure to moderate to high amounts may cause
liver and kidney effects.
Carcinogenicity. No agreement exists over the carcinogenicity of
MEK. One source believes MEK is a possible carcinogen in humans
based on limited animal evidence. Other sources believe that there
is insufficient evidence to make any statements about possible
carcinogenicity.
Environmental Fate. Most of the MEK released to the environment
will end up in the atmosphere. MEK can contribute to the
formation of air pollutants in the lower atmosphere. It can be
degraded by microorganisms living in water and soil.
Physical Properties. Methyl ethyl ketone is a flammable liquid.
Toxicity. Acetone is irritating to the eyes, nose, and throat.
Symptoms of exposure to large quantities of acetone may include
headache, unsteadiness, confusion, lassitude, drowsiness, vomiting,
and respiratory depression.
Reactions of acetone (see environmental fate) in the lower
atmosphere contribute to the formation of ground-level ozone.
Ozone (a major component of urban smog) can affect the respiratory
September 1995
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Wood Furniture and Fixtures
Sector Notebook Project
system, especially in sensitive individuals such as asthmatics or
allergy sufferers.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
Environmental Fate. If released into water, acetone will be
degraded by microorganisms or will evaporate into the atmosphere.
Degradation by microorganisms will be the primary removal
mechanism.
Acetone is highly volatile, and once it reaches the troposphere
(lower atmosphere), it will react with other gases, contributing to
the formation of ground-level ozone and other air pollutants. EPA
is reevaluating acetone's reactivity in the lower atmosphere to
determine whether this contribution is significant.
Physical Properties. Acetone is a volatile and flammable organic
chemical.
Note: Acetone was removed from the list of TRI chemicals on June
16, 1995 (60 FR 31643) and will not be reported for 1994 or
subsequent years.
1,1,1-Trichloro ethane
Toxicity. Repeated contact of 1,1,1-trichloroethane (TCE) with skin
may cause serious skin cracking and infection. Vapors cause a slight
smarting of the eyes or respiratory system if present in high
concentrations.
Exposure to high concentrations of TCE causes reversible mild liver
and kidney dysfunction, central nervous system depression, gait
disturbances, stupor, coma, respiratory depression, and even death.
Exposure to lower concentrations of TCE leads to light-headedness,
throat irritation, headache, disequilibrium, impaired coordination,
drowsiness, convulsions and mild changes in perception.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
Environmental Fate. Releases of TCE to surface water or land will
almost entirely volatilize. Releases to air may be transported long
distances and may partially return to earth in rain. In the lower
atmosphere, TCE degrades very slowly by photooxidation and
SIC Code 25
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Sector Notebook. Project
Wood Furniture and Fixtures
slowly diffuses to the upper atmosphere where photodegradation is
rapid.
Any TCE that does not evaporate from soils leaches to groundwater.
Degradation in soils and water is slow. TCE does not hydrolyze in
water, nor does it significantly bioconcentrate in aquatic organisms.
IV.C. Other Data Sources
The Aerometric Information Retrieval System (AIRS) contains a
wide range of information related to stationary sources of air
pollution, including the emissions of a number of air pollutants
which may be of concern within a particular industry. With the
exception of volatile organic compounds (VOCs), there is little
overlap with the TRI chemicals reported above. Exhibit 16
summarizes annual releases of carbon monoxide (CO), nitrogen
dioxide (NC>2), particulate matter of 10 microns or less (PM10), total
particulates (FT), sulfur dioxide (SC>2), and volatile organic
compounds (VOCs).
Exhibit 16
Pollutant Releases (Short Tons/Year)
Industry
U.S. Total
Metal Mining
Nonmetal Mining
Lumber and Wood
Products
Wood Furniture and
Fixtures
Pulp and Paper
Printing
Inorganic Chemicals
Organic Chemicals
Petroleum Refining
Rubber and Misc. Plastic
Products
Stone, Clay, Glass, and
Concrete
Iron and Steel
Nonferrous Metals
Fabricated Metals
Electronics
Motor Vehicles, Bodies,
Parts, and Accessories
Dry Cleaning
CO
97,208,000
5,391
4,525
123,756
2,069
624,291
8,463
. 166,147
146,947
419,311
2,090
58,043
1,518,642
448,758
3,851
367
35,303
101
NO2
23,402,000
28,583
28,804
42,658
2,981
394,448
4,915
108,575
236,826
380,641
11,914
338,482
138,985
55,658
16,424
1,129
23,725
179
PMio
45,489,000
39,359
59,305
14,135
2,165
35,579
399
4,107
26,493
18,787
2,407
74,623
42,368
20,074
1,185
207
2,406
3
PT
7,836,000
140,052
167,948
63,761
3,178
113,571
1,031
39,082
44,860
36,877
5,355
171,853
83,017
22,490
3,136
293
12,853
28
SO2
21,888,000
84,222
24,129
9,149
1,606
341,002
1,728
182,189
132,459
648,153
29,364
339,216
238,268
373,007
4,019
453
25,462
152
voc
23,312,000
1,283
1,736
41,423
59,426
96,875
101,537
52,091
201,888
309,058
140,741
30,262
82,292
27,375
102,186
4,854
101,275
7,310
Source U.S. EPA Office of Air and Radiation, AIRS Database, May 1995.
September 1995
49
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Wood Furniture and Fixtures
Sector Notebook Project
IV.D. Comparison of Toxic Release Inventory Between Selected Industries
The following information is presented as a comparison of
pollutant release and transfer data across industrial categories. It is
provided to give a general sense as to the relative scale of releases
and transfers within each sector profiled under this project. Please
note that the following table does not contain releases and transfers
for industrial categories that are not included in this project, and
thus cannot be used to draw conclusions regarding the total release
and transfer amounts that are reported to TRI. Similar information
is available within the annual TRI Public Data Release book.
Exhibit 17 is a graphical representation of a summary of the 1993
TRI data for the Wood Furniture and Fixtures Industry and the
other sectors profiled in separate notebooks. The bar graph presents
the total TRI releases and total transfers on the left axis and the
triangle points show the average releases per facility on the right
axis. Industry sectors are presented in the order of increasing total
TRI releases. The graph is based on the data shown in Exhibit 18
and is meant to facilitate comparisons between the relative
amounts of releases, transfers, and releases per facility both within
and between these sectors. The reader should note, however, that
differences in the proportion of facilities captured by TRI exist
between industry sectors. This can be a factor of poor SIC matching
and relative differences in the number of facilities reporting to TRI
from the various sectors. In the case of the Wood Furniture and
Fixtures Industry, the 1993 TRI data presented here covers 313
facilities. These facilities listed SIC 25, Wood as a primary SIC code.
SIC Code 25
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September 1995
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Sector Notebook Project
Wood Furniture and Fixtures
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September 1995
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SIC Code 25
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Wood Furniture and Fixtures
Sector Notebook Project
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SIC Code 25
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September 1995
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Sector Notebook Project
Wood Furniture and Fixtures
V. POLLUTION PREVENTION OPPORTUNITIES
The best way to reduce pollution is to prevent it in the first place.
Some companies have creatively implemented pollution
prevention techniques that improve efficiency and increase profits
while at the same time minimizing environmental impacts. This
can be done in many ways such as reducing material inputs, re-
engineering processes to reuse by-products, improving
management practices, and employing substitution of toxic
chemicals. Some smaller facilities are able to actually get below
regulatory thresholds just by reducing pollutant releases through
aggressive pollution prevention policies.
In order to encourage these approaches, this section provides both
general and company-specific descriptions of some pollution
prevention advances that have been implemented within the
Wood Furniture and Fixtures industry. While the list is not
exhaustive, it does provide core information that can be used as the
starting point for facilities interested in beginning their own
pollution prevention projects. When possible, this section provides
information from real activities that can, or are being implemented
by this sector — including a discussion of associated costs, time
frames, and expected rates of return. This section also provides the
context (in terms of type of industry and/or type of process affected)
in which the pollution prevention technique can effectively be
used.
The following discussion of pollution prevention initiatives is
based mainly on the EPA document Pollution Prevention Options
in Wood Furniture Manufacturing and identifies those steps in the
manufacturing process for which pollution prevention initiatives
can and have been implemented. Exhibit 19 provides examples of
process modification, material substitution, waste reduction, and
recycling options for finishing and gluing operations. The EPA
document from which this exhibit was developed does not indicate
the methods used to compute cost savings.
September 1995
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Sector Notebook Project
V.A. Identification of Pollution Prevention Activities in Use and
Environmental and Economic Benefits of Each Pollution Prevention
Activity
Pollution prevention techniques and processes currently used by
the wood furniture and fixtures industry can be grouped into the
following general categories:
Production planning and sequencing
Process or equipment modification
Raw material substitution or elimination
Loss prevention and housekeeping
Waste segregation and separation
Solvent recycling
Training and supervision.
Each of these categories is discussed below briefly. Refer to Exhibit
19 for specific pollution prevention techniques and associated costs,
savings, and other information.
Production planning and sequencing is used to ensure that only
necessary operations are performed and that no operation is
needlessly "undone" by a following operation. One example is to
sort out reject parts prior to painting or finishing. A second
example is to reduce the frequency of cleaning equipment by
staining or painting all products of the same color at the same time.
A third example is to schedule batch processing of lighter shades of
paint prior to darker shades of paint so that equipment need not be
cleaned between batches.
Process or equipment modification is used to reduce the amount of
waste generated. Manufacturers can change to a paint application
technique that is more efficient than spray gun systems, such as
airless and air-assisted airless systems, electrostatic spray systems, or
flat line finishing.
Several technologies currently in the development stage could
potentially apply to the wood furniture industry. These
technologies are in the areas of spray booth design and curing
methods. The spray booth designs discussed in this section include
the Classic System Campbell Spray Booth and the Mobile Zone.
Both designs seek to reduce the volume of air exhausted.
Classic Systems has developed the Campbell spray booth, which the
company indicates can reduce the volume of exhaust air by
SIC Code 25
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Sector Notebook Project
Wood Furniture and Fixtures
approximately 80 percent. The basic design of the Campbell spray
booth involves the use of air curtains; the worker stands outside of
the booth and sprays through the air curtain. The air curtain
provides a barrier between the worker and the solvent emissions
inside the booth resulting from coating the piece. A pilot system
has been built, and a full-scale system has been designed.
Mobile Zones Associates has developed a device which, when
installed on a spray booth, enables the worker(s) to spray coatings
from a partially enclosed mobile work platform. The worker stands
inside a "cab," the movement of which is controlled from inside the
cab by the worker. Within the Mobile Zone cab, fresh ventilating
air passes across the painter from an open "moving window" at his
rear. The remaining section of the mobile work platform is
ventilated using recirculated air. The Mobile Zone design contrasts
with a conventional spray booth, in which the entire length of the
booth is supplied with fresh ventilating air.
Ultraviolet (UV)-curable coatings are frequently used by flatline
furniture coating operations. Since the pieces are flat, curing in a
conventional UV-cure oven is straightforward. Although UV-
curable coatings are also applied to case goods (nonflat pieces), the
UV-curing process with such pieces is more difficult. In order for a
UV-curable coating to cure, all coating must be exposed to the UV-
light. The lamps in the UV-oven must be situated to ensure
exposure to all areas of the case goods, including recessed areas,
carvings, etc. The UV-lamp locations would need to be set for each
type of case good depending on its configuration. Because furniture
manufacturers typically produce many different types of case goods
on a single line at any time, realignment of the UV-lamps for each
type of case good is not feasible. However, if a manufacturer
produces a single piece continuously for a length of time, the lamps
could be arranged for that configuration. Then, after the lamps are
adjusted,. another type of piece could be produced for a length of
time.
Biofiltration is a control technology which sends contaminated
exhaust air through a biofilter for contaminant removal. The
biofilter consists of organic matter, such as tree bark and compost,
the pores of which are filled with water. Biologically active micro-
organisms are present, partly free-floating in the water and partly
attached to the organic matter.
Raw material substitution or elimination is the replacement of
existing raw materials with other materials that produce less waste,
or a non-toxic waste. Some examples include substituting water-
September 1995
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Wood Furniture and Fixtures
Sector Notebook Project
based finishes for solvent-based finishes or replacing volatile liquid
finishes with electrostatically-applied powder finishes.
Volatile organic compound (VOC) emissions from wood furniture
finishing operations (primarily the hazardous air described in
Section IV.B.) can be reduced by reformulating coating materials so
that they contain fewer VOCs. Currently, in wood furniture
finishing operations, VOC emissions result from the application
and subsequent evaporation of finishing materials. Efforts are being
made to reformulate the finishing materials used in the wood
furniture industry so that they contain fewer VOCs.
Waterborne finishing materials are currently being used by some
furniture manufacturers. The potential exists for waterborne
coatings to be used by all segments of the wood finishing industry.
However, the waterborne coatings currently available are better
suited to certain applications than others. For example:
• Open pore woods are considered easier to finish with
waterborne coatings than filled pores
• Darker woods sometimes appear cloudy when finished with
waterborne coatings, though the clarity has improved over
the last ten years
• Waterborne finishes do not have the rubbability of
nitrocellulose lacquers and the finish is therefore not as
glossy where a glossy finish is required
• Waterborne coatings may require a modified drying method
(increased airflow and temperature).
Ultraviolet (UV)-curable coatings are currently used in various
segments of the wood finishing industry. UV-curable coatings can
be applied using spray equipment, roll coaters, or curtain coaters.
Therefore, the potential exists for UV-curable coatings to be used on
case good as well as flat pieces, and progress in this direction has
been made. However, as mentioned previously, curing of the
three-dimensional pieces remains difficult because all of the coating
materials must be exposed to the UV radiation. Problems arise in
curing of recessed surfaces that do not get direct exposure to the
radiation. Many studies are being conducted so that UV-curable
materials may experience more widespread use in the future.
Polyurethane coatings are used in some segments of the wood
finishing industry. Polyurethane materials can be spray applied, or
applied by curtain or roll coat, and are cured in the conventional
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September 1995
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Sector Notebook Project
Wood Furniture and Fixtures
manner. Polyurethane coatings are characterized by a high-gloss
look, which may not be desirable to certain segments of the wood
furniture industry. Other limitations that prevent its widespread
use include the need for a clean room environment, the short pot
life (one to six hours), and the difficulty in repairing.
Polyester coatings are similar to polyurethanes in their uses and
their limitations. The film properties of the polyester coatings are
good; they provide good build and good chemical, mechanical, and
heat resistance. However, application requires a clean room
environment which can be very expensive and difficult to
maintain.
Loss prevention and housekeeping is the performance of
preventive maintenance and equipment and materials
management so as to minimize opportunities for leaks, spills,
evaporative losses, and other releases of potentially toxic chemicals.
For example, spray guns can be cleaned by submerging only the
front end of the gun in the cleaning solvent; or routine
maintenance of spray gun equipment can prevent equipment from
breaking down and leaking.
Waste segregation and separation involves avoiding the mixture of
different types of wastes and avoiding the mixture of hazardous
wastes with non-hazardous wastes. This makes the recovery of
hazardous wastes easier by minimizing the number of different
hazardous constituents in a given waste stream. Also, it prevents
the contamination of non-hazardous wastes. Specific examples
include segregating spent solvents by solvent types, and segregating
non-hazardous paint solids from hazardous paint solvents and
thinner s.
Solvent recycling is the use or reuse of a waste as an ingredient or
feedstock in the production process on-site. Recycling in which a
waste is recovered and reused in the production process on-site as
an input is a form of pollution prevention. One example is the use
of a small on-site still to recycle xylene or lacquer thinner.
Training and supervision provides employees with the
information and the incentive to minimize waste generation in
their daily duties. This might include ensuring that employees
know and practice proper and efficient use of tools and supplies,
and that they are aware of, understand, and support the company's
pollution prevention goals.
September 1995
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Wood Furniture and Fixtures
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Exhibit 19
Pollution Prevention Matrix
Process
Application
of finish and
pre-finish
coatings
Pollution Prevention Process
Process Modification
Implement alternatives to compressed
air spray gun systems including:
1. Airless and air assisted airless
2. Electrostatic spray systems
3. Flat line finishing
Material Substitution
Substitution of solvent-based inks
with water-based inks
Waste Reduction
Replace water-based paint booth
filters with dry filters. Dry filters
will double paint booth life and allow
more efficient treatment of
wastewater.
Process Modification
Train spray gun operators in proper
spray techniques to minimize coating
waste generation
Economic and Environment
Savings and Benefits
• Material consumption
reduction: 15%
• Annual cost savings:
$55,000
• Waste volume from
spray booth cleanup
reduction: 50%
• Annual cost savings:
$150,000
• Waste savings/
reduction from wiping
stain compared to
conventional spray
units: 25%
• Annual savings in
total coating costs:
20-30%
• Waste savings/
reduction in VOCs:
25%
• Annual cost savings in
raw materials:
$75,000
• Annual cost savings in
disposal costs:
$37,000
• Annual cost savings:
$1,500
• Waste savings/
reductions: 3,000
gallons/year
• Annual cost savings:
$50,000 to $70,000
• Finishing material
required reduction:
8-10%
Payback
Period
Payback
period: 1
year
Payback
period: 2
years
Payback
period: 2
years
Information
not available
Information
not available
Information
not available
SIC Code 25
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September 1995
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Sector Notebook Project
Wood Furniture and Fixtures
Exhibit 19 (cont'd)
Pollution Prevention Matrix
Process
Application
of finish and
pre-finish
coatings
(continued)
Pollution Prevention Process
Recycling
Recycle spent solvents with recovery
units including:
1. Small on-site solvent recovery
still to recycle spent lacquer
thinner
2. Small in-house still to recycle
methylene chloride
3. In-house still to recycle xylene
4. Batch distillation unit to recover
xylene from paint equipment
cleaning
5. Batch distillation to recover
isopropyl acetate generated
during equipment cleaning
6. Recovery system for solvents
contained in air emissions
7. Small solvent recovery still to
recover spent paint thinner from
spray gun cleaning and excess
paint batches
Economic and Environment
Savings and Benefits
• Annual cost savings:
$5,700
• Incentive was to
avoid RCRA liability
related to disposal
Information not
available
• Annual savings:
$5,000
Information not available
• Annual savings:
$1,000
• Capital investment
for a 15-gallon
capacity still: $6,000
• Annual savings in new
thinner: $3,600
• Annual disposal
savings: $5,400
• Waste savings/
reduction: 75% (745
gallons of thinner
recovered from 1,003
gallons)
• Product/waste
throughput
information: 1,500
gallons of spent
thinner processed per
year
Payback
Period
Payback
period: 1
year
Payback
period: 2
years
Payback
period: 13
months
Payback
period: 13
months
Payback
period: 2
years
Information
not available
Payback
period: less
than one year
September 1995
59
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Wood Furniture and Fixtures
Sector Notebook Project
Exhibit 19 (cont'd)
Pollution Prevention Matrix
Process
Application
of finish and
pre-finish
coatings
(continued)
Equipment
cleaning
Pollution Prevention Process
8. Solvent recovery system to
recover and reuse spent methyl
ethyl ketone.
Process Modification
Flush equipment first with dirty
solvent before final cleaning with
virgin solvent and use cleanup solvents
in formulation of subsequent batches of
paint
Economic and Environment
Savings and Benefits
• Annual savings:
$43,000
• MEK recovery rate:
20 gallons/day
(reflecting a 90%
reduction in waste)
• Waste savings/
reduction: 98%
• Paint cleanup solvents
reduction: from 25,000
to 400 gallons
Payback
Period
Information
not available
Information
not available
Source: Pollution Prevention Options in Wood Furniture Manutactunny, 1M2.
V.B. Pollution Prevention Case Studies
Henredon Furniture Industries, located in California, applies stains
and other finishes to chairs, benches, and a variety of other
furniture items. Because the conventional spray guns that
Henredon had been using were not meeting current regulations for
VOC emissions, the company researched the feasibility of high-
volume low-pressure (HVLP) spray guns.
Henredon tested guns by a variety of manufacturers to find those
that best fit their needs. The HVLP guns ultimately selected operate
on air pressures from 7 to 10 psi, which is within the definitions set
by California's South Coast Air Quality Management District. The
lower pressure results in less overspray and more efficient use of
material.
The new HVLPs increased efficiency such that average material
usage was reduced by 13 to 15 percent. Employee training on
application techniques was also conducted to improve efficiency.
The new guns improved product quality without slowing
production rates. Henredon is currently using the HVLP guns to
apply lacquers, sealers, and stains at three plant locations.
Henredon saves approximately 18,512 gallons of raw material
annually by using the more efficient guns. These savings equate to
a reduction in VOC emissions of 126,060 pounds per year.
SIC Code 25
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September 1995
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Sector Notebook Project
Wood Furniture and Fixtures
Purchase and installation cost between $350 and $500 per gun.
Henredon figures to save approximately $119,673 per year in raw
material usage, for an average payback period of 3.5 months.
Thomson Crown Wood Products, Inc., manufactures wood
television cabinets. Parts of these cabinets were sprayed with
finishing materials by an air-assisted airless spray gun, resulting in
the production of VOCs and a large paint waste stream. To
ameliorate this problem, Crown Wood proposed to test high-
volume low-pressure (HVLP) spray guns and evaluate their success
in reducing these waste streams.
Through in-house, on-line production testing, Crown Wood
reviewed four different HVLP spray guns using penetrating stain
(no-wipe), glaze, sap stain, equalizer, toner, shade, and water-based
black paint. An HVLP spray gun manufactured by one company
gave excellent performance during the penetrating stain and regular
glaze applications. This gun was also highly recommended by the
sprayers for its size, weight, triggering, and cleaning ease. However,
because the sprayer did not hold a specific spray pattern very well, it
could not be used for heavier finishes. Instead, an HVLP spray gun
manufactured by another manufacturer, which also received good
ratings by the sprayers, gave much more consistent coverage and
spray pattern for the water-based black, sap stain, equalizer, shade,
and toner finishes.
With the new HVLP spray guns, Crown Wood has experienced
material reductions of 65 percent for equalizer, 65 percent for stain,
54 percent for toner, 35 percent for glaze, 35 percent for no-wipe, and
53 percent for water-based black finishes. These reductions total
over 13,300 gallons per year, which also results in reductions in
VOCs and paint waste.
A total of $137,448 per year is the estimated savings from purchasing
the new spray guns. Costs associated with paint waste reduction
have not been determined, but a reduction in the amount of
clean-up waste was evident. The cost of the project was $21,350.
In July 1992, Crown Wood altered its printing process room to
incorporate the lay-down or roll-on finishing top and end panels of
the outside cabinet. With this process modification, 60 percent of
the spraying operation is now diverted to the printing room. Along
with paint waste and VOC discharges, this new application
procedure reduced finishing purchases by 50 percent.
September 1995
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Wood Furniture and Fixtures
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Ethan Allen, Inc., manufactures dining and bedroom furniture.
Coating procedures in the finishing operations produced
approximately 37,000 pounds of hazardous waste annually. To
reduce the quantity and disposal cost of this waste, the company
made the equipment substitutions and cleanup changes discussed
below.
Some of the modifications resulted directly from employee
suggestions. The company implemented a cost reduction program
to facilitate employee involvement in waste/cost reduction
activities. Employees submit waste/cost reduction ideas, which are
evaluated by a cost reduction committee, and valid suggestions are
assigned for savings calculations.
Three main components of the coating operation generate the
hazardous waste: overspraying collection systems, material
transport systems, and equipment cleanup procedures.
Overspray Collection Systems
• Metal filters replaced paper/cardboard filters for all the
coating operations. The metal filters are cleaned in a tank in
which solvent is circulated with a diaphragm pump. The
waste solvent/coating mix is distilled, and only the overspray
is drummed for disposal. The cleaning solvent is reused.
The metal filters used for lacquer and sealer overspray are
hand wiped, and the dust is sent-off site for recycling.
• A fabricated, sloped polyethylene-lined trough replaced
absorbent wood shavings used to catch overspray. In the
wiping stain booths, the trough is squeezed into a pan, and
only the liquid overspray is drummed for disposal.
• High-volume, low-pressure (HVLP) spray guns replaced
conventional air-assisted spray gun equipment. As a result,
the quantity of overspray to be filtered is reduced, and
spraying efficiency is increased. Also, each operator is
required to attend an annual technical training session.
Training is provided by a representative of the spray gun
manufacturer.
Material Transport Systems
• Polyethylene covers replaced cardboard covers for pallets
used to transport products through coating operations. The
overspray is peeled off the polyethylene cover and drummed
for disposal.
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Wood Furniture and Fixtures
• The racks used to transport material on the conveyor system
are cleaned periodically during the boiler watchman's free
time. Thus, the employee's time is utilized, and the racks can
be reused. This procedure lengthens the life of the racks,
which must be cleaned or disposed of as a solid hazardous
waste.
Cleanup Operations
• A solvent distillation unit was installed to recover usable
solvents and reduce hazardous waste generation. A seven-
gallon batch still, which is run twice daily, recovers five
gallons of reusable solvent for every seven gallons of cleanup
waste.
These equipment substitutions and changes in cleanup procedures
resulted in the elimination of 25,900 pounds of hazardous waste
annually, for an estimated cost savings of $129,465 per year. The
following exhibit lists the process, cost of implementation, quantity
of waste reduction, and annual cost savings.
Exhibit 20
Ethan Allen Pollution Prevention Case Study Summary
Process
Metal Filters
Lacquer and
Sealer Recycle
Polyethylene
Trough
HVLP Spray
Guns (12 guns @
$250)
Polyethylene
Pallet Covers
Rack Cleaning
Solvent
Distillation
Total
Capitol
Investment, $
7,000
1,500
400
3,000
2,050
200
4,500
$68,650
Waste Reduction,
Ibs/year
10,000
2,300
6,100
Material Use Reduction:
Sap Stain 27%
Sealer 20%
Lacquer 11%
3,700
1,900
1,900
25,900
Savings,
$/year
48,125
6,150
38,430
Material Use Savings:
15,000 to 20,000
7,450
8,250
3,200
$129,465
Source: North Carolina Department
Pollution
of Environment, Health, and Natural Resources
Prevention Program.
September 1995
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Wood Furniture and Fixtures
Sector Notebook Project
VI. SUMMARY OF FEDERAL STATUTES AND REGULATIONS
This section discusses the Federal statutes and regulations that may
apply to this sector. The purpose of this section is to highlight, and
briefly describe the applicable Federal requirements, and to provide
citations for more detailed information. The three following
sections are included.
• Section IV.A contains a general overview of major statutes
• Section IV.B contains a list of regulations specific to this
industry
• Section IV.C contains a list of pending and proposed
regulations
The descriptions within Section IV are intended solely for general
information. Depending upon the nature or scope of the activities
at a particular facility, these summaries may or may not necessarily
describe all applicable environmental requirements. Moreover,
they do not constitute formal interpretations or clarifications of the
statutes and regulations. For further information, readers should
consult the Code of Federal Regulations and other state or local
regulatory agencies. EPA Hotline contacts are also provided for each
major statute.
VI.A. General Description of Major Statutes
Resource Conservation And Recovery Act
The Resource Conservation And Recovery Act (RCRA) of 1976
which amended the Solid Waste Disposal Act, addresses solid
(Subtitle D) and hazardous (Subtitle C) waste management
activities. The Hazardous and Solid Waste Amendments (HSWA)
of 1984 strengthened RCRA's waste management provisions and
added Subtitle I, which governs underground storage tanks (USTs).
Regulations promulgated pursuant to Subtitle C of RCRA (40 CFR
Parts 260-299) establish a "cradle-to-grave" system governing
hazardous waste from the point of generation to disposal. RCRA
hazardous wastes include the specific materials listed in the
regulations (commercial chemical products, designated with the
code "P" or "U"; hazardous wastes from specific industries/sources,
designated with the code "K"; or hazardous wastes from non-
specific sources, designated with the code "F") or materials which
exhibit a hazardous waste characteristic (ignitibility, corrosivity,
reactivity, or toxicity and designated with the code "D").
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Regulated entities that generate hazardous waste are subject to
waste accumulation, manifesting, and recordkeeping standards.
Facilities that treat, store, or dispose of hazardous waste must obtain
a permit, either from EPA or from a State agency which EPA has
authorized to implement the permitting program. Subtitle C
permits contain general facility standards such as contingency plans,
emergency procedures, recordkeeping and reporting requirements,
financial assurance mechanisms, and unit-specific standards.
RCRA also contains provisions (40 CFR Part 264 Subpart S and
§264.10) for conducting corrective actions which govern the cleanup
of releases of hazardous waste or constituents from solid waste
management units at RCRA-regulated facilities.
Although RCRA is a Federal statute, many States implement the
RCRA program. Currently, EPA has delegated its authority to
implement various provisions of RCRA to 46 of the 50 States.
Most RCRA requirements are not industry specific but apply to any
company that transports, treats, stores, or disposes of hazardous
waste. Here are some important RCRA regulatory requirements:
• Identification of Solid and Hazardous Wastes (40 CFR Part
261) lays out the procedure every generator should follow to
determine whether the material created is considered a
hazardous waste, solid waste, or is exempted from regulation.
• Standards for Generators of Hazardous Waste (40 CFR Part
262) establishes the responsibilities of hazardous waste
generators including obtaining an ID number, preparing a
manifest, ensuring proper packaging and labeling, meeting
standards for waste accumulation units, and recordkeeping
and reporting requirements. Generators can accumulate
hazardous waste for up to 90 days (or 180 days depending on
the amount of waste generated) without obtaining a permit.
• Land Disposal Restrictions (LDRs) are regulations prohibiting
the disposal of hazardous waste on land without prior
treatment. Under the LDRs (40 CFR 268), materials must
meet land disposal restriction (LDR) treatment standards
prior to placement in a RCRA land disposal unit (landfill,
land treatment unit, waste pile, or surface impoundment).
Wastes subject to the LDRs include solvents, electroplating
wastes, heavy metals, and acids. Generators of waste subject
to the LDRs must provide notification of such to the
designated TSD facility to ensure proper treatment prior to
disposal.
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• Used Oil Management Standards (40 CFR Part 279) impose
management requirements affecting the storage,
transportation, burning, processing, and re-refining of the
used oil. For parties that merely generate used oil,
regulations establish storage standards. For a party
considered a used oil marketer (one who generates and sells
off-specification used oil directly to a used oil burner),
additional tracking and paperwork requirements must be
satisfied.
• Tanks and Containers used to store hazardous waste with a
high volatile organic concentration must meet emission
standards under RCRA. Regulations (40 CFR Part 264-265,
Subpart CC) require generators to test the waste to determine
the concentration of the waste, to satisfy tank and container
emissions standards, and to inspect and monitor regulated
units. These regulations apply to all facilities who store such
waste, including generators operating under the 90-day
accumulation rule.
• Underground Storage Tanks (USTs) containing petroleum
and hazardous substance are regulated under Subtitle I of
RCRA. Subtitle I regulations (40 CFR Part 280) contain tank
design and release detection requirements, as well as
financial responsibility and corrective action standards for
USTs. The UST program also establishes increasingly
stringent standards, including upgrade requirements for
existing tanks, that must be met by 1998.
• Boilers and Industrial Furnaces (BIFs) that use or burn fuel
containing hazardous waste must comply with strict design
and operating standards. BIF regulations (40 CFR Part 266,
Subpart H) address unit design, provide performance
standards, require emissions monitoring, and restrict the type
of waste that may be burned.
EPA's RCRA/Superfund/UST Hotline, at (800) 424-9346, responds
to questions and distributes guidance regarding all RCRA
regulations. The RCRA Hotline operates weekdays from 8:30 a.m.
to 7:30 p.m., EST, excluding Federal holidays.
Comprehensive Environmental Response, Compensation, And Liability Act
The Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA), a 1980 law commonly known as Superfund,
authorizes EPA to respond to releases, or threatened releases, of
hazardous substances that may endanger public health, welfare, or
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the environment. CERCLA also enables EPA to force parties
responsible for environmental contamination to clean it up or to
reimburse the Superfund for response costs incurred by EPA. The
Superfund Amendments and Reauthorization Act (SARA) of 1986
revised various sections of CERCLA, extended the taxing authority
for the Superfund, and created a free-standing law, SARA Title III,
also known as the Emergency Planning and Community Right-to-
Know Act (EPCRA).
The CERCLA hazardous substance release reporting regulations (40
CFR Part 302) direct the person in charge of a facility to report to the
National Response Center (NRC) any environmental release of a
hazardous substance which exceeds a reportable quantity.
Reportable quantities are defined and listed in 40 CFR § 302.4. A
release report may trigger a response by EPA, or by one or more
Federal or State emergency response authorities.
EPA implements hazardous substance responses according to
procedures outlined in the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP) (40 CFR Part 300). The NCP
includes provisions for permanent cleanups, known as remedial
actions, and other cleanups referred to as "removals." EPA
generally takes remedial actions only at sites on the National
Priorities List (NPL), which currently includes approximately 1300
sites. Both EPA and states can act at other sites; however, EPA
provides responsible parties the opportunity to conduct removal
and remedial actions and encourages community involvement
throughout the Superfund response process.
EPA's RCRA/Superfund/UST Hotline, at (800) 424-9346, answers
questions and references guidance pertaining to the Superfund
program. The CERCLA Hotline operates weekdays from 8:30 a.m. to
7:30 p.m., EST, excluding Federal holidays.
Emergency Planning And Community Right-To-Know Act
The Superfund Amendments and Reauthorization Act (SARA) of
1986 created the Emergency Planning and Community Right-to-
Know Act (EPCRA, also known as SARA Title III), a statute
designed to improve community access to information about
chemical hazards and to facilitate the development of chemical
emergency response plans by State and local governments. EPCRA
required the establishment of State emergency response
commissions (SERCs), responsible for coordinating certain
emergency response activities and for appointing local emergency
planning committees (LEPCs).
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EPCRA and the EPCRA regulations (40 CFR Parts 350-372) establish
four types of reporting obligations for facilities which store or
manage specified chemicals:
EPCRA §302 requires facilities to notify the SERC and LEPC of
the presence of any "extremely hazardous substance" (the list
of such substances is in 40 CFR Part 355, Appendices A and B)
if it has such substance in excess of the substance's threshold
planning quantity, and directs the facility to appoint an
emergency response coordinator.
• EPCRA §304 requires the facility to notify the SERC and the
LEPC in the event of a release exceeding the reportable
quantity of a CERCLA hazardous substance or an EPCRA
extremely hazardous substance.
• EPCRA §§311 and 312 require a facility at which a hazardous
chemical, as defined by the Occupational Safety and Health
Act, is present in an amount exceeding a specified threshold
to submit to the SERC, LEPC, and local fire department
material safety data sheets (MSDSs) or lists of MSDSs and
hazardous chemical inventory forms (also known as Tier I
and II forms). This information helps the local government
respond in the event of a spill or release of the chemical.
• EPCRA §313 requires manufacturing facilities included in SIC
codes 20 through 39, which have ten or more employees, and
which manufacture, process, or use specified chemicals in
amounts greater than threshold quantities, to submit an
annual toxic chemical release report. This report, commonly
known as the Form R, covers releases and transfers of toxic
chemicals to various facilities and environmental media, and
allows EPA to compile the national Toxic Release Inventory
(TRI) database.
All information submitted pursuant to EPCRA regulations is
publicly accessible, unless protected by a trade secret claim.
EPA's EPCRA Hotline, at (800) 535-0202, answers questions and
distributes guidance regarding the emergency planning and
community right-to-know regulations. The EPCRA Hotline
operates weekdays from 8:30 a.m. to 7:30 p.m., EST, excluding
Federal holidays.
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Clean Water Act
The primary objective of the Federal Water Pollution Control Act,
commonly referred to as the Clean Water Act (CWA), is to restore
and maintain the chemical, physical, and biological integrity of the
nation's surface waters. Pollutants regulated under the CWA
include "priority" pollutants, including various toxic pollutants;
"conventional" pollutants, such as biochemical oxygen demand
(BOD), total suspended solids (TSS), fecal coliform, oil and grease,
and pH; and "non-conventional" pollutants, including any
pollutant not identified as either conventional or priority.
The CWA regulates both direct and indirect discharges. The
National Pollutant Discharge Elimination System (NPE>ES)
program (CWA §402) controls direct discharges into navigable
waters. Direct discharges or "point source" discharges are from
sources such as pipes and sewers. NPDES permits, issued by either
EPA or an authorized State (EPA has presently authorized forty
States to administer the NPDES program), contain industry-specific,
technology-based and/or water quality-based limits, and establish
pollutant monitoring and reporting requirements. A facility that
intends to discharge into the nation's waters must obtain a permit
prior to initiating its discharge. A permit applicant must provide
quantitative analytical data identifying the types of pollutants
present in the facility's effluent. The permit will then set forth the
conditions and effluent limitations under which a facility may
make a discharge.
A NPDES permit may also include discharge limits based on Federal
or State water quality criteria or standards, that were designed to
protect designated uses of surface waters, such as supporting aquatic
life or recreation. These standards, unlike the technological
standards, generally do not take into account technological
feasibility or costs. Water quality criteria and standards vary from
State to State, and site to site, depending on the use classification of
the receiving body of water. Most States follow EPA guidelines
which propose aquatic life and human health criteria for many of
the 126 priority pollutants.
Storm Water Discharges
In 1987 the CWA was amended to require EPA to establish a
program to address storm water discharges. In response, EPA
promulgated the NPDES storm water permit application
regulations. Storm water discharge associated with industrial
activity means the discharge from any conveyance which is used for
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collecting and conveying storm water and which is directly related
to manufacturing, processing or raw materials storage areas at an
industrial plant (40 CFR 122.26(b)(14)). These regulations require
that facilities with the following storm water discharges apply for a
NPDES permit: (1) a discharge associated with industrial activity; (2)
a discharge from a large or medium municipal storm sewer system;
or (3) a discharge which EPA or the State determines to contribute to
a violation of a water quality standard or is a significant contributor
of pollutants to waters of the United States.
The term "storm water discharge associated with industrial activity"
means a storm water discharge from one of 11 categories of
industrial activity defined at 40 CFR 122.26. Six of the categories are
defined by SIC codes while the other five are identified through
narrative descriptions of the regulated industrial activity. If the
primary SIC code of the facility is one of those identified in the
regulations, the facility is subject to the storm water permit
application requirements. If any activity at a facility is covered by
one of the five narrative categories, storm water discharges from
those areas where the activities occur are subject to storm water
discharge permit application requirements.
Those facilities/activities that are subject to storm water discharge
permit application requirements are identified below. To
determine whether a particular facility falls within one of these
categories, the regulation should be consulted.
Category i: Facilities subject to storm water effluent guidelines, new
source performance standards, or toxic pollutant effluent standards.
Category ii: Facilities classified as SIC 24-lumber and wood products
(except wood kitchen cabinets); SIC 26-paper and allied products
(except paperboard containers and products); SIC 28-chemicals and
allied products (except drugs and paints); SIC 29-petroleum refining;
and SIC 311-leather tanning and finishing.
Category iii: Facilities classified as SIC 10-metal mining; SIC 12-coal
mining; SIC 13-oil and gas extraction; and SIC 14-nonmetallic
mineral mining.
Category iv: Hazardous waste treatment, storage, or disposal
facilities.
Category v: Landfills, land application sites, and open dumps that
receive or have received industrial wastes.
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Category vi: Facilities classified as SIC 5015-used motor vehicle
parts; and SIC 5093-automotive scrap and waste material recycling
facilities.
Category vii: Steam electric power generating facilities.
Category viii: Facilities classified as SIC 40-railroad transportation;
SIC 41-local passenger transportation; SIC 42-trucking and
warehousing (except public warehousing and storage); SIC 43-U.S.
Postal Service; SIC 44-water transportation; SIC 45-transportation by
air; and SIC 5171-petroleum bulk storage stations and terminals.
Category ix: Sewage treatment works.
Category x: Construction activities except operations that result in
the disturbance of less than five acres of total land area.
Category xi: Facilities classified as SIC 20-food and kindred products;
SIC 21-tobacco products; SIC 22-textile mill products; SIC 23-apparel
related products; SIC 2434-wood kitchen cabinets manufacturing;
SIC 25-furniture and fixtures; SIC 265-paperboard containers and
boxes; SIC 267-converted paper and paperboard products; SIC 27-
printing, publishing, and allied industries; SIC 283-drugs; SIC 285-
paints, varnishes, lacquer, enamels, and allied products; SIC 30-
rubber and plastics; SIC 31-leather and leather products (except
leather and tanning and finishing); SIC 323-glass products; SIC 34-
fabricated metal products (except fabricated structural metal); SIC 35-
industrial and commercial machinery and computer equipment;
SIC 36-electronic and other electrical equipment and components;
SIC 37-transportation equipment (except ship and boat building and
repairing); SIC 38-measuring, analyzing, and controlling
instruments; SIC 39-miscellaneous manufacturing industries; and
SIC 4221-4225-public warehousing and storage.
Pretreatment Program
Another type of discharge that is regulated by the CWA is one that
goes to a publicly-owned treatment works (POTWs). The national
pretreatment program (CWA §307(b)) controls the indirect discharge
of pollutants to POTWs by "industrial users." Facilities regulated
under §307(b) must meet certain pretreatment standards. The goal
of the pretreatment program is to protect municipal wastewater
treatment plants from damage that may occur when hazardous,
toxic, or other wastes are discharged into a sewer system and to
protect the quality of sludge generated by these plants. Discharges to
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a POTW are regulated primarily by the POTW itself, rather than the
State or EPA.
EPA has developed technology-based standards for industrial users
of POTWs. Different standards apply to existing and new sources
within each category. "Categorical" pretreatment standards
applicable to an industry on a nationwide basis are developed by
EPA. In addition, another kind of pretreatment standard, "local
limits," are developed by the POTW in order to assist the POTW in
achieving the effluent limitations in its NPDES permit.
Regardless of whether a State is authorized to implement either the
NPDES or the pretreatment program, if it develops its own
program, it may enforce requirements more stringent than Federal
standards.
EPA's Office of Water, at (202) 260-5700, will direct callers with
questions about the CWA to the appropriate EPA office. EPA also
maintains a bibliographic database of Office of Water publications
which can be accessed through the Ground Water and Drinking
Water resource center, at (202) 260-7786.
Safe Drinking Water Act
The Safe Drinking Water Act (SDWA) mandates that EPA establish
regulations to protect human health from contaminants in
drinking water. The law authorizes EPA to develop national
drinking water standards and to create a joint Federal-State system
to ensure compliance with these standards. The SDWA also directs
EPA to protect underground sources of drinking water through the
control of underground injection of liquid wastes.
EPA has developed primary and secondary drinking water
standards under its SDWA authority. EPA and authorized States
enforce the primary drinking water standards, which are,
contaminant-specific concentration limits that apply to certain
public drinking water supplies. Primary drinking water standards
consist of maximum contaminant level goals (MCLGs), which are
non-enforceable health-based goals, and maximum contaminant
levels (MCLs), which are enforceable limits set as close to MCLGs as
possible, considering cost and feasibility of attainment.
The SDWA Underground Injection Control (UIC) program (40 CFR
Parts 144-148) is a permit program which protects underground
sources of drinking water by regulating five classes of injection
wells. UIC permits include design, operating, inspection, and
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monitoring requirements. Wells used to inject hazardous wastes
must also comply with RCRA corrective action standards in order
to be granted a RCRA permit, and must meet applicable RCRA land
disposal restrictions standards. The UIC permit program is
primarily State-enforced, since EPA has authorized all but a few
States to administer the program.
The SDWA also provides for a Federally-implemented Sole Source
Aquifer program, which prohibits Federal funds from being
expended on projects that may contaminate the sole or principal
source of drinking water for a given area, and for a State-
implemented Wellhead Protection program, designed to protect
drinking water wells and drinking water recharge areas.
EPA's Safe Drinking Water Hotline, at (800) 426-4791, answers
questions and distributes guidance pertaining to SDWA standards.
The Hotline operates from 9:00 a.m. through 5:30 p.m., EST,
excluding Federal holidays.
Toxic Substances Control Act
The Toxic Substances Control Act (TSCA) granted EPA authority to
create a regulatory framework to collect data on chemicals in order
to evaluate, assess, mitigate, and control risks which may be posed
by their manufacture, processing, and use. TSCA provides a variety
of control methods to prevent chemicals from posing unreasonable
risk.
TSCA standards may apply at any point during a chemical's life
cycle. Under TSCA §5, EPA has established an inventory of
chemical substances. If a chemical is not already on the inventory,
and has not been excluded by TSCA, a premanufacture notice
(PMN) must be submitted to EPA prior to manufacture or import.
The PMN must identify the chemical and provide available
information on health and environmental effects. If available data
are not sufficient to evaluate the chemical's effects, EPA can impose
restrictions pending the development of information on its health
and environmental effects. EPA can also restrict significant new
uses of chemicals based upon factors such as the projected volume
and use of the chemical.
Under TSCA §6, EPA can ban the manufacture or distribution in
commerce, limit the use, require labeling, or place other restrictions
on chemicals that pose unreasonable risks. Among the chemicals
EPA regulates under §6 authority are asbestos, chlorofluorocarbons
(CFCs), and poly chlorinated biphenyls (PCBs).
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EPA's TSCA Assistance Information Service, at (202) 554-1404,
answers questions and distributes guidance pertaining to Toxic
Substances Control Act standards. The Service operates from 8:30
a.m. through 4:30 p.m., EST, excluding Federal holidays.
Clean Air Act
The Clean Air Act (CAA) and its amendments, including the Clean
Air Act Amendments (CAAA) of 1990, are designed to "protect and
enhance the nation's air resources so as to promote the public
health and welfare and the productive capacity of the population."
The CAA consists of six sections, known as Titles, which direct EPA
to establish national standards for ambient air quality and for EPA
and the States to implement, maintain, and enforce these standards
through a variety of mechanisms. Under the CAAA, many
facilities will be required to obtain permits for the first time. State
and local governments oversee, manage, and enforce many of the
requirements of the CAAA. CAA regulations appear at 40 CFR
Parts 50-99.
Pursuant to Title I of the CAA, EPA has established national
ambient air quality standards (NAAQSs) to limit levels of "criteria
pollutants," including carbon monoxide, lead, nitrogen dioxide,
particulate matter, ozone, and sulfur dioxide. Geographic areas that
meet NAAQSs for a given pollutant are classified as attainment
areas; those that do not meet NAAQSs are classified as non-
attainment areas. Under §110 of the CAA, each State must develop
a State Implementation Plan (SIP) to identify sources of air
pollution and to determine what reductions are required to meet
Federal air quality standards.
Title I also authorizes EPA to establish New Source Performance
Standards (NSPSs), which are nationally uniform emission
standards for new stationary sources falling within particular
industrial categories. NSPSs are based on the pollution control
technology available to that category of industrial source but allow
the affected industries the flexibility to devise a cost-effective means
of reducing emissions.
Under Title I, EPA establishes and enforces National Emission
Standards for Hazardous Air Pollutants (NESHAPs), nationally
uniform standards oriented towards controlling particular
hazardous air pollutants (HAPs). Title III of the CAAA further
directed EPA to develop a list of sources that emit any of 189 HAPs,
and to develop regulations for these categories of sources. To date
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EPA has listed 174 categories and developed a schedule for the
establishment of emission standards. The emission standards will
be developed for both new and existing sources based, on
"maximum achievable control technology" (MACT). The MACT is
defined as the control technology achieving the maximum degree
of reduction in the emission of the HAPs, taking into account cost
and other factors.
Title II of the CAA pertains to mobile sources, such as cars, trucks,
buses, and planes. Reformulated gasoline, automobile pollution
control devices, and vapor recovery nozzles on gas pumps are a few
of the mechanisms EPA uses to regulate mobile air emission
sources.
Title IV establishes a sulfur dioxide emissions program designed to
reduce the formation of acid rain. Reduction of sulfur dioxide
releases will be obtained by granting to certain sources limited
emissions allowances, which, beginning in 1995, will be set below
previous levels of sulfur dioxide releases.
Title V of the CAAA of 1990 created a permit program for all "major
sources" (and certain other sources) regulated under the CAA. One
purpose of the operating permit is to include in a single document
all air emissions requirements that apply to a given facility. States
are developing the permit programs in accordance with guidance
and regulations from EPA. Once a State program is approved by
EPA, permits will be issued and monitored by that State.
Title VI is intended to protect stratospheric ozone by phasing out
the manufacture of ozone-depleting chemicals and restrict their use
and distribution. Production of Class I substances, including 15
kinds of chlorofluorocarbons (CFCs), will be phased out entirely by
the year 2000, while certain hydrochlorofluorocarbons (HCFCs) will
be phased out by 2030.
EPA's Control Technology Center, at (919) 541-0800, provides
general assistance and information on CAA standards. The
Stratospheric Ozone Information Hotline, at (800) 296-1996,
provides general information about regulations promulgated under
Title VI of the CAA, and EPA's EPCRA Hotline, at (800) 535-0202,
answers questions about accidental release prevention under CAA
§112(r). In addition, the Technology Transfer Network Bulletin
Board System (modem access (919) 541-5742)) includes recent CAA
rules, EPA guidance documents, and updates of EPA activities.
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Exhibit 21 provides an overview of the statues and certain
regulations applicable to the wood furniture manufacturing
industry. The information contained in this matrix is based on data
from the American Furniture Manufacturers Association
document, Environmental Guide for the Furniture Industry.
Exhibit 21
Impacts of Environmental Statutes on the Wood Furniture Manufacturing
Industry
Statute &
Section
Drying
(ovens, boilers)
Machining
(sawing,
planing,
sanding)
Assembly
(gluing,
veneer
application)
Pre-finishing/
Finishing
(all coating
applications)
Cleanup/
Shipping
(cleanup,
equipment
maintenance,
warehousing)
Resource Conservation and Recovery Act
Section 6921
(3)(A)
(Hazardous
Waste)
Section 6941
(Solid
Waste)
State /Local
Regulations
Section 6991
(USTs)
Boiler water
treatment
chemicals may
be regulated
Non-hazardous
boiler ash may
be regulated
Underground
fuel tanks may
be regulated
N/A
Wood waste
maybe
regulated
N/A
Unused
commercial
chemical
products may
be regulated
Wood and
adhesive
waste may be
regulated
Adhesive and
solvent under-
ground storage
tanks may be
regulated
Unused
commercial
chemical
products and
potentially
ignitable non-
liquid wastes
are likely to be
regulated
N/A
Solvent under-
ground storage
tanks are
likely to be
regulated
Solvent cleanup
solutions,
burning of
potentially
ignitable
wastes, and
chemical
storage and
spills may be
regulated
Equipment
maintenance
materials may
be regulated
N/A
Comprehensive Environmental Response, Compensation, and Liability Act
CERCLA
N/A
N/A
N/A
Potential spill
and disposal
problems are
likely to occur
Potential spill
and disposal
problems may
occur
Source: AFMA Environmental (jUiae for me turmture industry.
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Exhibit 21 (cont'd)
Impacts of Environmental Statutes on the Wood Furniture Manufacturing
Industry
Statute &
Section
Drying
(ovens, boilers)
Machining
(sawing,
planing,
sanding)
Assembly
(gluing,
veneer
application)
Pre-finishing/
Finishing
(all coating
applications)
Cleanup/
Shipping
(cleanup,
equipment
maintenance,
warehousing)
Emergency Planning and Community Right-to-Know Act, SARA Title III
Sections
301-303
Section 304
Sections
311-312
Section 313
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Adhesives
maybe
regulated
Adhesives
spills may be
regulated
Adhesives
maybe
regulated
Emissions
from solvent-
based
adhesives
may be
regulated
Finishing
materials are
likely to be
regulated
Finishing
materials
spills are
likely to be
regulated
Finishing
materials are
likely to be
regulated
Hazardous
finishing
materials are
likely to be
regulated
Finishing and
maintenance
materials are
likely to be
regulated
Maintenance
materials
spills may be
regulated
Finishing and
maintenance
materials are
likely to be
regulated
Hazardous
chemical
emissions
disposal may
be regulated
Clean Water Act
Wastewater
Discharge
Permitting
Program
SPCC
Planning
Wastewater
discharge from
boilers,
compressors,
cooling water,
and drying kiln
condensate may
be regulated
N/A
N/A
N/A
Adhesive
wash and
water
discharge
maybe
regulated
Adhesive
management
maybe
regulated
Wastewater
discharge from
water-wash
spray booths
and rag
laundering are
likely to be
regulated
Finishing oil
management is
likely to be
regulated
N/A
Storage and use
of fuels and
lube oils may be
regulated
Source: AFMA Environmental Guide for the Furniture Industry.
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Exhibit 21 (cont'd)
Impacts of Environmental Statutes on the Wood Furniture Manufacturing
Industry
Statute &
Section
Drying
(ovens, boilers)
Machining
(sawing,
planing,
sanding)
Assembly
(gluing,
veneer
application)
Pre-finishing/
Finishing
(all coating
applications)
Cleanup/
Shipping
(cleanup,
equipment
maintenance,
warehousing)
Clean Water Act (continued)
Storm Water
Discharge
Permitting
Program
Wood storage
maybe
regulated
Wood
particulates
in runoff are
likely to be
regulated
Adhesive
storage may
be regulated
Finishing
materials
management is
likely to be
regulated
Fuel and
maintenance
chemical
management
and material
storage may be
regulated
Clean Air Act
Section 7411
(NSPS)
Section 7411
(New Source
Review)
Section 7411
(Control
Techniques
Guidelines)
Section 7501
(Nonattain-
ment Areas)
Section 7412
(Hazardous
Air
Pollutants)
Section 7410
(a)(2)
(Operating
Permits
Program)
May apply to
certain boilers
Permit required
before
construction of
new source
N/A
Sources in CO,
SO2, NOX, O3
(VOC), PM10, or
Pb nonattain-
ment areas may
be subject to
additional
requirements
N/A
Permit required
for all major
and certain non-
major sources
N/A
Permit
required
before
construction of
new source
N/A
Sources in
PM10
nonattainmen
t areas may be
subject to
additional
requirements
N/A
Permit
required for
all major and
certain non-
major sources
N/A
Permit
required
before
construction of
new source
N/A
N/A
Currently
being
finalized;
scheduled for
release in
November,
1995
Permit
required for
all major and
certain non-
major sources
N/A
Permit required
before
construction of
new source
Draft form
scheduled for
release in
August, 1995
Sources in O3
(VOC) and
PM10
nonattainment
areas may be
subject to
additional
requirements
Currently being
finalized;
scheduled for
release in
November, 1995
Permit required
for all major
and certain non-
major sources
N/A
Permit required
before
construction of
new source
N/A
N/A
N/A
Permit required
for all major
and certain non-
major sources
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Exhibit 21 (cont'd)
Impacts of Environmental Statutes on the Wood Furniture Manufacturing
Industry
Statute &
Section
Drying
(ovens, boilers)
Machining
(sawing,
planing,
sanding)
Assembly
(gluing,
veneer
application)
Pre-finishing/
Finishing
(all coating
applications)
Cleanup/
Shipping
(cleanup,
equipment
maintenance,
warehousing)
Clean Air Act (continued)
Section 7411
(Enhanced
Monitoring)
Certain boilers
may be subject
to enhanced
monitoring
requirements
depending on
the magnitude
of emissions
Large
operations
may be subject
to enhanced
monitoring
requirements
Sources may
be subject to
enhanced
monitoring
requirements
depending on
the
magnitude of
emissions
Sources may be
subject to
enhanced
monitoring
requirements
depending on
the magnitude
of emissions
N/A-
Spill Reporting
Spill
Reporting
Boiler fuels
maybe
regulated
N/A
Adhesives
and solvents
maybe
regulated
Toxic finishing
materials are
likely to be
regulated
Maintenance
chemicals and
oils may be
regulated
Source: AFMA Environmental Guide for the Furniture Industry.
VLB. Industry-specific Regulatory Requirements
Clean Air Act CCAA)
The Clean Air Act as amended in 1990 established the basis for the
EPA to set new requirements for hazardous air pollutants (HAPs)
that apply to emissions of 189 toxic chemicals listed in the Clean Air
Act. EPA recently proposed Maximum Available Control
Technology (MACT) standards for the wood furniture
manufacturing industry.
In addition, the Agency is developing a control techniques
guideline (CTG) for the industry to reduce the emissions of VOCs.
While a CTG is not a rule, States generally follow the CTG guidance
in developing rules for facilities located in ozone non-attainment
areas and the ozone transport region. A preliminary draft model
rule containing a preview of the reasonably available control
technologies (RACT) that will be recommended in the draft CTG
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has been made publicly available for the wood furniture industry.
A more detailed discussion of both the draft CTG and the MACT
standards can be found in the following section pertaining to
pending regulatory requirements.
The Economic Incentive Program (EIP) rules, promulgated on April
7, 1994 (59 FR 16690), provide general information on using
innovative strategies to meet the Clean Air Act requirements,
including RACT. (The RACT applicability threshold for this model
rule is 10 tons for a wood furniture facility located in an extreme
ozone nonattainment area and 25 tons per year for a wood furniture
facility located in a marginal, moderate, serious, or severe ozone
nonattainment area or in the ozone transport region; EPA Method
24 is used as the basis for evaluating VOC data on coatings). The EIP
rule contains a range of options for States to use in incorporating
economic incentives and/or innovative strategies into their State
Implementation Plans (SIPs).
Resource Conservation and Recovery Act (RCRA)
The Resource Conservation and Recovery Act (RCRA) regulates the
generation, transportation, treatment, storage, and disposal of
hazardous waste. Although the furniture industry does not tend to
generate listed hazardous wastes, it may produce characteristic
hazardous wastes. The wood furniture manufacturing industry
uses many solvents. Spent solvents and solvent still bottoms are
often characterized as hazardous wastes. In addition, furniture
manufacturing facilities may generate ignitable or toxic wastes.
Many wastes generated from the use of paints, wood treatments,
stains, varnishes, and adhesives may be ignitable or might fail the
Toxicity Characteristic Leaching Procedure (TCLP) test.
If a facility generates 100 kilograms or more of hazardous waste (or
one kilogram of acutely hazardous waste) per month, it may be
subject to accumulation time limits, storage restrictions, personnel
training requirements, manifesting, and land disposal restrictions
for these wastes.
Emergency Planning and Community Right-to-Know Act (EPCRA)
Furniture manufacturers may store extremely hazardous substances
(EHS) and hazardous chemicals. If so, facilities would be subject to
the emergency planning and hazardous chemical inventory
provisions of EPCRA. If they release an EHS or a CERCLA
hazardous substance such as toluene or acetone, they may need to
report it under the emergency release reporting requirements of
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Wood Furniture and Fixtures
SARA Title III. The Toxic Chemical Release Inventory affects only
relatively large furniture companies that use toxic chemicals, such
as toluene disocyanate or methylene chloride, above 10,000 pounds
annually.
Clean Water Act (CWA)
The Clean Water Act (CWA) regulates discharges of various
pollutants into the surface waters of the U.S. or to publicly owned
treatment works (POTWs). The effluent provisions of 40 CFR Part
429, Subpart L, regulate facilities which conduct wood finishing
activities such as staining and dipping, and require that sources not
discharge untreated process wastewater into navigable waters.
CWA regulations also regulate wood furniture manufacturers both
with water wash spray booths (40 CFR Part 429, Subpart P) and
without wash spray booths (40 CFR 429 Subpart O). Both Subparts
require that sources not discharge process wastewater pollutants
directly into navigable waters. Both effluent limitations greatly
restrict the amount of effluent from process wastewaters which may
be released into POTWs and require monitoring and recordkeeping
activities. For sources discharging to POTWs, Subpart P
requirements are similar to those in Subpart O with the exception
that pH levels and levels of solids that settle are regulated for the
best practicable technology requirements.
VI.C. Pending and Proposed Regulatory Requirements
Information contained in this section was obtained from the Fact
Sheet on the Proposed MACT and CTG for the Wood Furniture
Finishing Industry developed and distributed by the Small Business
Ombudsman of North Carolina. The Clean Air Act as amended in
1990 established the basis for the EPA to set new requirements for
HAPs and to develop control techniques guidance (CTG) to reduce
VOC emissions. The EPA recently proposed a MACT standard for
the wood furniture manufacturing industry, which applies to 189
toxic chemicals listed in the Clean Air Act as HAPs. To help States
meet the ambient air quality standard for ozone, the Agency is also
developing a CTG for the industry to reduce emissions of VOCs.
The MACT and CTG are concerned with two different types of
emissions. The MACT will regulate emissions of HAPs from all
wood furniture surface coating operations nationwide. The CTG
will address emissions of VOCs from wood furniture finishing,
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cleaning, and washoff operations at facilities located in ozone non-
attainment areas or in the ozone transport region.
The MACT standard will apply to "major sources" in the wood
furniture manufacturing industry. A major source is one that
emits or has the potential to emit 10 tons per year (tpy) of an
individual HAP or 25 tpy of a combination of HAPs per year. The
recommended application of the CTG is for sources that emit or
have the potential to emit 10 tpy of VOCs in an extreme non-
attainment area and 25 tpy per year of VOCs in any other ozone
non-attainment area and in the ozone transport region.
Sources using or agreeing to use no more that 250 total gallons per
month, or 3,000 gallons per rolling 12-month period, of finishing,
contact adhesives, and cleaning materials are not major sources and
are exempted from the MACT standard.
The MACT standard proposes numerical emission limits for surface
coating operations including finishing, gluing, and peelable spray
booth coating. Finishes include stains, washcoats, basecoats, fillers,
sealers, glazes, highlighters, enamels, and topcoats. The CTG
preliminary draft proposes numeric emissions limits for finishing
and cleaning operations and for strippable booth coatings.
In addition to numeric emissions limits, the MACT standard and
CTG propose work practice standards that include inspection and
maintenance of equipment, good housekeeping practices such as
closed tops on solvent and mixing containers, procedures to account
for solvent use, and some limitations on the use of conventional
air spray guns, promoting the use of more efficient spray guns.
A source may be affected by both the MACT and CTG. For example,
if a wood furniture manufacturer is located in an ozone non-
attainment area, uses VOCs and potentially emits greater than 25
tons per year of total VOC emissions, and is a major source for
HAPs, the facility would be subject to both requirements.
The following implementation/compliance schedule is proposed
with respect to the MACT and CTG:
• A preliminary draft model rule to reduce VOCs was
distributed to State and local air agencies in June 1994. This
preliminary rule contains emission limits based on RACT for
reducing VOCs. RACT requirements may vary among states
and local governments as some will set more stringent
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Wood Furniture and Fixtures
requirements to accommodate their specific air quality
problems.
• Under a court-ordered deadline, the MACT standard was
proposed November 21, 1994. November 1995 is the
scheduled date for final adoption.
• Sources emitting more than 50 tpy of HAPs will have until
November 21, 1997 to comply with the final rule.
• Sources emitting less than 50 tpy of HAPs will have
approximately three years to comply with the final rule. This
date will probably be November 1998.
Compliance with the MACT standard can be achieved with
compliant coatings; that is, either non-HAP coatings or those
meeting the limits, such as 1.0 Ib of HAP per pound of solid. High-
solids coatings and water-based coatings have fewer VOCs and
HAPs, and are becoming more readily available. Although add-on
control may also be used to meet the standards, the use of less
solvent and fewer toxics in coatings and finishes is likely to be the
route most manufacturers take towards compliance (and may be
more economical).
The basis for the recommended standards for finishing operations is
the use of low-HAP materials or control devices such as
incinerators. For cleaning operations, the standards are based on
use of low-VOC strippable coatings for spray booths.
In addition to numeric standards, the proposed rules minimize
evaporative emissions through work practices covering storage,
transfer, and applications in finishing, contact adhesive, cleaning,
and washoff operations. These practices include employee training,
inspection and maintenance, and housekeeping measures (such as
"containers should be closed when not in use").
Exhibits 22 and 23 provide an overview of the proposed MACT
emissions limits and work practice standards for the MACT and
CTG. This information was obtained from the Fact Sheet on the
Proposed MACT and CTG for the Wood Furniture Finishing
Industry.
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Exhibit 22
Summary of Proposed MACT Emission Limit
Emission Point
Finishing Operations
(1) Achieve a weighted average HAP content across all
coatings (maximum Ib VHAP/lb solids)
(2) Use compliant finishing materials (maximum Ib
VHAP/lb solids)
- stains
- washcoats
- sealers
- topcoats
- basecoats
- enamels
- thinners (maximum percent HAP allowable)
(3) As an alternative, use add-on control device
(4) Use a combination of (2) and (3)
Cleaning Operations
Strippable spray booth material (max VHAP content = Ib
VOC/lb solids)
Contact Adhesive Operations
(1) Use compliant contact adhesives (max VHAP content, as
applied (Ib VHAP/lb solids)
(i) For foam adhesives used in products that meet
flammability requirements
(ii) For all other adhesives (including foam adhesives
used in products not meeting flammability
requirements); or
(2) Use a control device
Existing
Source
1.0a
1.0a
1.0a'b
1.0a
1.0a
1.0a'b
1.0a'b
10.0
1.0C
1.0
0.8
1.8
1.0
1.0d
New Source
0.8a
1.0a
0.8a'b
0.8a
0.8a
0.8a'b
0.8a'b
10.0
0.8C
0.8
0.8
0.2
0.2
0.2d
Source: Fact Sheet on the Proposed MACT and CTGfor the Wood Furniture Hmsmng industry.
a The limits refer to the HAP content of the coating as applied.
b Compliant washcoats, basecoats, and enamels must be used if they are purchased premade; that is, they are not
formulated on-site by thinning other finishing materials. If they are formulated on-site, they must be formulated
with compliant finishing materials and thinners containing no more than three percent HAP by weight.
c The control device must operate at an efficiency equivalent to no greater than 1.0 Ibs. (or 0.8 Ibs.) of HAP being
emitted from the affected emission source per pound of solids used.
d The control device must operate at an efficiency that is equivalent to no more than 1.0 Ibs. Volatile HAP
(VHAP) emitted from the affected emission point per pound of solids used.
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Exhibit 23
Summary of Work Practice Standards for the Proposed MACT and CTG
Emission Source
Finishing Operations
Transfer Equipment Leaks
Storage containers
including mixing
equipment
Application equipment
Finishing materials
Work Practice
• Develop written inspection and maintenance plan to address and
repair leaks. The plan must identify a minimum inspection
frequency of one per month and procedures for addressing
malfunctions.
• When such containers are used for VOC- or HAP-containing
materials, keep covered when not in use.
• Limit use of conventional air spray guns and encourage .use of more
efficient technology.
• Demonstrate usage of HAPs of potential concern have not
increased except as allowed by the standards; document in the
formulation assessment (MACT only).
Cleaning Operations
Gun/line cleaning
Spray booth cleaning
Wash-off tanks/ general
cleaning
• Collect cleaning solvent into a closed container.
• Cover all containers associated with cleaning when not in use.
• Do not use solvents unless cleaning conveyors or metal filters.
• Do not use chemicals that are known, probable, or possible
carcinogens, as identified in section 112(g), in concentrations
subject to MSDS reporting, as required by OSHA (MACT only).
• Keep wash tank covered when not in use.
• Minimize dragout by tilting and/or rotating part to drain as
much solvent as possible and allowing sufficient time to dry.
• Maintain log of the quantity ^and type of solvent used for .
washoff cleaning as well as the quantity of waste shipped off
site and the fate of this waste (recycling or disposal).
• Maintain a log of the number of pieces washed off and the reason
for washoff.
Miscellaneous
Operator training
Implementation plan
• All operators shall be trained on proper application, cleanup,
and equipment use.
• The training program shall be written and retained on site.
• Develop a plan to implement work practice standards.
• Maintain plan on site.
Source: Fact Sheet on the Proposed MACT and CTG for the Wood Furniture Finishing Industry.
The work practice standards apply to both existing and new major sources. Air guns will be allowed only in the
following instances:
when used in conjunction with coatings less than 1.0 Ib. VOC/lb. of solids
for touch up and repair under limitedconditions
when spray is automated
when add-on controls are used
if the cumulative application is less than 5 percent of total gallons of coating applied.
if the permitting agency determines other application technology is economically or technically
unfeasible.
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VII. COMPLIANCE AND ENFORCEMENT HISTORY
Background
To date, EPA has focused much of its attention on measuring
compliance with specific environmental statutes. This approach
allows the Agency to track compliance with the Clean Air Act, the
Resource Conservation and Recovery Act, the Clean Water Act, and
other environmental statutes. Within the last several years, the
Agency has begun to supplement single-media compliance
indicators with facility-specific, multimedia indicators of
compliance. In doing so, EPA is in a better position to track
compliance with all statutes at the facility level, and within specific
industrial sectors.
A major step in building the capacity to compile multimedia data
for industrial sectors was the creation of EPA's Integrated Data for
Enforcement Analysis (IDEA) system. IDEA has the capacity to
"read into" the Agency's single-media databases, extract compliance
records, and match the records to individual facilities. The IDEA
system can match Air, Water, Waste, Toxics/Pesticides/EPCRA,
TRI, and Enforcement Docket records for a given facility, and
generate a list of historical permit, inspection, and enforcement
activity. IDEA also has the capability to analyze data by geographic
area and corporate holder. As the capacity to generate multimedia
compliance data improves, EPA will make available more in-depth
compliance and enforcement information. Additionally, sector-
specific measures of success for compliance assistance efforts are
under development.
Compliance and Enforcement Profile Description
Using inspection, violation, and enforcement data from the IDEA
system, this section provides information regarding the historical
compliance and enforcement activity of this sector. In order to
mirror the facility universe reported in the Toxic Chemical Profile,
the data reported within this section consists of records only from
the TRI reporting universe. With this decision, the selection
criteria are consistent across sectors with certain exceptions. For the
sectors that do not normally report to the TRI program, data have
been provided from EPA's Facility Indexing System (FINDS) which
tracks facilities in all media databases. Please note, in this section,
EPA does not attempt to define the actual number of facilities that
fall within each sector. Instead, the section portrays the records of a
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Wood Furniture and Fixtures
subset of facilities within the sector that are well defined within
EPA databases.
As a check on the relative size of the full sector universe, most
notebooks contain an estimated number of facilities within the
sector according to the Bureau of Census (See Section II). With
sectors dominated by small businesses, such as metal finishers and
printers, the reporting universe within the EPA databases may be
small in comparison to Census data. However, the group selected
for inclusion in this data analysis section should be consistent with
this sector's general make-up.
Following this introduction is a list defining each data column
presented within this section. These values represent a
retrospective summary of inspections and enforcement actions, and
solely reflect EPA, State, and local compliance assurance activities
that have been entered into EPA databases. To identify any changes
in trends, the EPA ran two data queries, one for the past five
calendar years (August 10, 1990 to August 9, 1995) and the other for
the most recent twelve-month period (August 10, 1994 to August 9,
1995). The five-year analysis gives an average level of activity for
that period for comparison to the more recent activity.
Because most inspections focus on single-media requirements, the
data queries presented in this section are taken from single media
databases. These databases do not provide data on whether
inspections are State/local or EPA-led. However, the table breaking
down the universe of violations does give the reader a crude
measurement of the EPA's and States' efforts within each media
program. The presented data illustrate the variations across regions
for certain sectors.2 This variation may be attributable to
State/local data entry variations, specific geographic concentrations,
proximity to population centers, sensitive ecosystems, highly toxic
chemicals used in production, or historical noncompliance. Hence,
the exhibited data do not rank regional performance or necessarily
reflect which regions may have the most compliance problems.
2 EPA Regions include the following States: 1 (CT, MA, ME, RI, NH, VT); 2 (NJ, NY, PR, VI); 3
(DC, DE, MD, PA, VA, WV); 4 (AL, FL, GA, KY, MS, NC, SC, TN); 5 (IL, IN, MI, MN, OH, WI); 6
(AR, LA, MM, OK, TX); 7 (IA, KS, MO, NE); 8 (CO, MT, ND, SD, UT, WY); 9 (AZ, CA, HI, NV,
Pacific Trust Territories); 10 (AK, ID, OR, WA).
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Compliance and Enforcement Data Definitions
General Definitions
Facility Indexing System (FINDS) — this system assigns a common
facility number to EPA single-media permit records. The FINDS
identification number allows EPA to compile and review all permit,
compliance, enforcement, and pollutant release data for any given
regulated facility.
Integrated Data for Enforcement Analysis (IDEA) — is a data
integration system that can retrieve information from the major
EPA program office databases. IDEA uses the FINDS identification
number to "glue together" separate data records from EPA's
databases. This is done to create a "master list" of data records for
any given facility. Some of the data systems accessible through
IDEA are: AIRS (Air Facility Indexing and Retrieval System, Office
of Air and Radiation), PCS (Permit Compliance System, Office of
Water), RCRIS (Resource Conservation and Recovery Information
System, Office of Solid Waste), NCDB (National Compliance Data
Base, Office of Prevention, Pesticides, and Toxic Substances),
CERCLIS (Comprehensive Environmental and Liability
Information System, Superfund), and TRIS (Toxic Release
Inventory System). IDEA also contains information from outside
sources such as Dun and Bradstreet and the Occupational Safety and
Health Administration (OSHA). Most data queries displayed in
notebook Sections IV and VII were conducted using IDEA.
Data Table Column Heading Definitions
Facilities in Search - are based on the universe of TRI reporters
within the listed SIC code range. For industries not covered under
TRI reporting requirements, the notebook uses the FINDS universe
for executing data queries. The SIC code range selected for each
search is defined by each notebook's selected SIC code coverage
described in Section n.
Facilities Inspected — indicates the level of EPA and State agency
facility inspections for the facilities in this data search. These values
show what percentage of the facility universe is inspected in a 12 or
60 month period. This column does not count non-inspectional
compliance activities such as the review of facility-reported
discharge reports.
Number of Inspections — measures the total number of inspections
conducted in this sector. An inspection event is counted each time
it is entered into a single media database.
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Average Time Between Inspections — provides an average length of
time, expressed in months, that a compliance inspection occurs at a
facility within the defined universe.
Facilities with One or More Enforcement Actions ~ expresses the
number of facilities that were party to at least one enforcement
action within the defined time period. This category is broken
down further into Federal and State actions. Data are obtained for
administrative, civil/judicial, and criminal enforcement actions.
Administrative actions include Notices of Violation (NOVs). A
facility with multiple enforcement actions is only counted once in
this column (facility with 3 enforcement actions counts as 1). All
percentages that appear are referenced to the number of facilities
inspected.
Total Enforcement Actions ~ describes the total number of
enforcement actions identified for an industrial sector across all
environmental statutes. A facility with multiple enforcement
actions is counted multiple times (a facility with 3 enforcement
actions counts as 3).
State Lead Actions — shows what percentage of the total
enforcement actions are taken by State and local environmental
agencies. Varying levels of use by States of EPA data systems may
limit the volume of actions accorded State enforcement activity.
Some States extensively report enforcement activities into EPA data
systems, while other States may use their own data systems.
Federal Lead Actions ~ shows what percentage of the total
enforcement actions are taken by the U.S. EPA. This value includes
referrals from State agencies. Many of these actions result from
coordinated or joint State/Federal efforts.
Enforcement to Inspection Rate — expresses how often enforcement
actions result from inspections. This value is a ratio of enforcement
actions to inspections, and is presented for comparative purposes
only. This measure is a rough indicator of the relationship between
inspections and enforcement. This measure simply indicates
historically how many enforcement actions can be attributed to
inspection activity. Related inspections and enforcement actions
under the Clean Water Act (PCS), the Clean Air Act (APS) and the
Resource Conservation and Recovery Act (RCRA) are included in
this ratio. Inspections and actions from the TSCA/FIFRA/EPCRA
database are not factored into this ratio because most of the actions
taken under these programs are not the result of facility inspections.
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This ratio does not account for enforcement actions arising from
non-inspection compliance monitoring activities (e.g., self-reported
water discharges) that can result in enforcement action within the
CAA, CWA and RCRA.
Facilities with One or More Violations Identified — indicates the
number and percentage of inspected facilities having a violation
identified in one of the following data categories: In Violation or
Significant Violation Status (CAA); Reportable Noncompliance,
Current Year Noncompliance, Significant Noncompliance (CWA);
Noncompliance and Significant Noncompliance (FIFRA, TSCA,
and EPCRA); Unresolved Violation and Unresolved High Priority
Violation (RCRA). The values presented for this column reflect the
extent of noncompliance within the measured time frame, but do
not distinguish between the severity of the noncompliance.
Percentages within this column can exceed 100 percent because
facilities can be in violation status without being inspected.
Violation status may be a precursor to an enforcement action, but
does not necessarily indicate that an enforcement action will occur.
Media Breakdown of Enforcement Actions and Inspections — four
columns identify the proportion of total inspections and
enforcement actions within EPA Air, Water, Waste, and
TSCA/FIFRA/EPCRA databases. Each column is a percentage of
either the "Total Inspections," or the "Total Actions" column.
VILA. Furniture and Fixtures Industry Compliance History
Exhibit 24 provides a Regional breakdown of the five year
enforcement and compliance activities for the furniture and
fixtures industry. Region IV conducted approximately 68 percent of
the inspections of furniture manufacturing facilities performed in
the United States. This large percentage is due to the concentration
of furniture manufacturers in the Southeastern U.S., specifically in
North Carolina.
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Wood Furniture and Fixtures
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September 1995
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VII.B. Comparison of Enforcement Activity Between Selected
Industries
Exhibits 25-28 contain summaries of the one and five year
enforcement and compliance activities for the furniture and
fixtures industry, as well as for other selected industries. As
indicated in Exhibits 25 and 26, the furniture and fixtures industry
has a low enforcement to inspection rate compared to other
industries. Exhibits 27 and 28 provide a breakdown of inspection
and enforcement activities by statute. Of all the furniture and
fixtures industry inspections, approximately 52 percent were
performed under the Clean Air Act, while approximately 45 percent
were conduced under RCRA. The large percentages of CAA and
RCRA inspections for this industry are due to the VOC emissions
and spent finishing materials resulting from the solvent intensive
processes used by this industry.
SIC Code 25
92
September 1995
-------
Sact
-------
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Sector Notebook Project
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94
September 1995
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Sector Notebook Project
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96
September 1995
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Sector Notebook Project
Wood Furniture sand Fixtures
VII.C. Review of Major Legal Actions
This section provides summary information about major cases and
supplemental enforcement projects that pertain to the Wood
Furniture and Fixtures Industry. Information in this section is
provided by the Office of Enforcement and Compliance Assurance
and EPA's Enforcement Accomplishments Report.
VII.C. 1. Review of Major Cases
As indicated in EPA's Enforcement Accomplishments Report,
FY1991, FY1992, FY1993 publications, two significant enforcement
actions were resolved between 1991 and 1993 for the furniture and
fixtures industry, involving RCRA violations. One of the RCRA
enforcement cases also included CWA violations. The companies
against which the cases were brought include a school furniture
manufacturer and a furniture refinisher.
Of the two actions involving RCRA violations, one was a civil
action for penalties and injunctive relief against the school
furniture manufacturer. The action was based on 29 RCRA and
significant CWA violations discovered by EPA inspectors. The
violations resulted primarily from the use of two unlined surface
impoundments as part of a waste water treatment facility. The
second case involving RCRA violations was against a furniture
refinisher and resulted in a conviction on four counts of illegal
disposal of hazardous waste and imposition of a jail sentence. The
hazardous waste consisted primarily of furniture stripping solvents.
VII.C.2. Supplemental Environmental Projects
SEPs are compliance agreements that reduce a facility's stipulated
penalty in return for an environmental project that exceeds the
value of the reduction. Often, these projects fund pollution
prevention activities that can significantly reduce the future
pollutant loadings of a facility. The yearly Regional updates and the
Enforcement Accomplishments Reports, FY1991, FY1992, and
FY1993 did not provide information on any SEPs entered into by
furniture or fixture manufacturing facilities.
September 1995
97
SIC Code 25
-------
Wood Furniture and Fixtures
Sector Notebook Project
VIII. COMPLIANCE ACTIVITIES AND INITIATIVES
This section highlights the activities undertaken by this industry
sector and public agencies to voluntarily improve the sector's
environmental performance. These activities include those
independently initiated by industrial trade associations. In this
section, the notebook also contains a listing and description of
national and regional trade associations.
VIII.A. Sector-related Environmental Programs and Activities
One major sector-related environmental research project has been
undertaken at the Furniture and Manufacturing and Management
(FMM) Center at North Carolina State University (NCSU),
organized in 1991 as an outgrowth the Furniture Manufacturing
and Management curriculum, which began in 1948. The mission of
the FMM Center is three-fold:
• To conduct applied research on manufacturing and
engineering issues for the benefit of the furniture industry;
• To carry out an extension program providing ongoing
technical assistance and technology transfer in support of the
furniture industry. Extension services focus on the areas of
upholstery furniture manufacturing, case goods
manufacturing, and environmental management;
• To educate engineers with specific knowledge of furniture
manufacturing.
The Environmental Program of the FMM Center is divided into
applied research activities and extension services. Research
activities are related to the industry in general rather than a
particular company. Currently, the FMM Center has two ongoing
research projects related to environmental issues:
• Development of environmental recordkeeping software and
a computerized tracking system for chemical usage and
emission reporting;
• Exploration of a biofiltration project, a method for
destruction of VOC and HAP emissions from finishing
operations.
The following project, requested by the U.S. EPA, may be
undertaken in the near future:
SIC Code 25
98
September 1995
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Sector Notebook. Project
Wood Furniture and Fixtures
• Use of very low VOC/HAP coatings for wood finishing
processes as a pollution prevention option for complying
with the MACT and CTG.
The purpose of the environmental extension program is to
promote cooperation between the furniture industry and the FMM
Center. Activities include providing technical assistance and
advisory guidance, conducting literature searches, acting as liaison,
and providing training, and other requested services, including:
• Quarterly environmental forum for environmental
managers and engineers in the furniture industry
• Information dissemination, including free computerized
literature searches
Technical assistance on an individual
including short-term consultations
Workshops and training.
company basis,
In addition to the FMM initiatives, the North Carolina Small
Business Ombudsman has been active in increasing awareness
about the proposed MACT and CTG for the wood furniture
finishing industry by issuing a fact sheet. The Small Business
Ombudsman and some of the larger trade associations have also
been involved in other compliance-related initiatives (see Section
vm.c.i.).
VIII.B. EPA Voluntary Programs
33/50 Program
The "33/50 Program" is EPA's voluntary program to reduce toxic
chemical releases and transfers of 17 chemicals from manufacturing
facilities. Participating companies pledge to reduce their toxic
chemical releases and transfers by 33 percent as of 1992 and by 50
percent as of 1995 from the 1988 baseline year. Certificates of
Appreciation have been given to participants who met their 1992
goals. The list of chemicals includes 17 high-use chemicals reported
in the Toxics Release Inventory.
Of the 17 chemicals covered by the 33/50 Program, 11 are used by
and are outputs of the wood furniture manufacutring industry. All
but three of these eleven chemicals are solvents which are sued
September 1995
99
SIC Code 25
-------
Wood Furniture and Fixtures
Sector Notebook Project
throughout furniture production, particularly in the finishing
stages of the process.
Exhibit 28 lists those companies participating in the 33/50 program
that reported under SIC code 25 to TRI. Many of the participating
companies listed multiple SIC codes (in no particular order), and are
therefore likely to conduct operations in addition to Wood
Furniture and Fixtures Industry. The table shows the number of
facilities within each company that are participating in the 33/50
program; each company's total 1993 releases and transfers of 33/50
chemicals; and the percent reduction in these chemicals since 1988.
According to EPA, 359 furniture manufacturing companies
comprise the potential 33/50 universe. Of those companies, 31 or
8.64 percent are participating in the program, which is less than the
average for all industries of 14 percent participation.
Exhibit 28
Wood Furniture and Fixtures Facilities Participating in the 33/50 Program
Parent Facility name
Armstrong World Industries
Bassclt Superior Lines
Best Chairs Inc.
Geiger Group Inc
Hamilton Industries Inc
Haworth Inc
Heidelberg Cement Inc
Itr Industries Inc
Joyce International Inc (De)
Klipsch & Associates Inc
La-Z-Boy Chair Company
Lozier Corporation
Madix Inc
Marmon Group, Inc
Mascotech
North American Philips Corp
Oklahoma Fixture Co.
Scely Pine Furniture Inc.
Shuford Industries Inc
Silver Furniture Co Inc
Parent City
Lancaster
Bassett
Ferdinand
Atlanta
Two Rivers
Holland
Allentown
Deer Park
New York
Indianapolis
Monroe
Omaha
Terrell
Chicago
Taylor
New York
Tulsa
Berkeley
Springs
Hickory
Knoxville
ST
PA
VA
IN
GA
WI
MI
PA
NY
NY
IN
MI
NE
TX
EL
MI
NY
OK
wv
NC
TN
SIC Codes
2511
2511
2511
2521
2521
•2522, 2521
2511
2511
2541
2517, 2519,
3651
2511
2542, 2541
2542, 2541
2541
2511
2517
2541
2511
2511
2511
# of
Participating
Facilities
11
12
1
1
1
2
1
1
2
1
7
2
1
1
17
1
2
1
3
1
1993
Releases
and
Transfers
(Ibs.)
1,109,350
2,063,109
51,700
45,078
31,875
194,050
119,957
34,882
118,847
11,521
572,153
186,715
623,805
1,092,218
3,163,830
1,281,928
236,975
22,996
1,613,303
73,705
%
Reduction.
1988 to
1993
*
50
***
81
7
50
*
*
25
#
**
85
55
1
35
50
***
***
58
45
SIC Code 25
100
September 1995
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Sector Notebook Project
Wood Furniture and Fixtures
Exhibit 28
Wood Furniture and Fixtures Facilities Participating in the 33/50 Program
(cont'd)
Parent Facility name
Steelcase Inc
Suba Mfg. Inc
Thomson Consumer Electronics
W. J. Roscoe Co.
White Consolidated Industries
Parent City
Grand Rapids
Benicia
Indianapolis
Akron
Cleveland
ST
MI
CA
IN
OH
OH
SIC Codes
2522, 2542,
2521
2541
2517
2851, 2891,
2517
3585, 2542,
2541
# of
Participating
Facilities
5
1
1
1
1
1993
Releases
and
Transfers
(Ibs.)
2,042,735
5,949
2,110,314
40,051
808,298
%
Reduction
1988 to
1993
20
25
43
50
81
* = not quantifiable against 1988 data.
** = use reduction goal only.
*** = no numerical goal.
Environmental Leadership Program
Project XL
The Environmental Leadership Program (ELP) is a national
initiative piloted by EPA and State agencies in which facilities have
volunteered to demonstrate innovative approaches to
environmental management and compliance. EPA has selected 12
pilot projects at industrial facilities and Federal installations which
will demonstrate the principles of the ELP program. These
principles include: environmental management systems,
multimedia compliance assurance, third-party verification of
compliance, public measures of accountability, community
involvement, and mentoring programs. In return for participating,
pilot participants receive public recognition and are given a period
of time to correct any violations discovered during these
experimental projects. (Contact: Tai-ming Chang, ELP Director, 202-
564-5081 or Robert Fentress, 202-564-7023)
Project XL was initiated in March 1995 as a part of President
Clinton's Reinventing Environmental Regulation initiative. The
projects seek to achieve cost effective environmental benefits by
allowing participants to replace or modify existing regulatory
requirements on the condition that they produce greater
environmental benefits. EPA and program participants will
negotiate and sign a Final Project Agreement, detailing specific
objectives that the regulated entity shall satisfy. In exchange, EPA
September 1995
101
SIC Code 25
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Wood Furniture and Fixtures
Sector Notebook Project
will allow the participant a certain degree of regulatory flexibility
and may seek changes in underlying regulations or statutes.
Participants are encouraged to seek stakeholder support from local
governments, businesses, and environmental groups. EPA hopes
to implement fifty pilot projects in four categories including
facilities, sectors, communities, and government agencies regulated
by EPA. Applications will be accepted on a rolling basis and projects
will move to implementation within six months of their selection.
For additional information regarding XL Projects, including
application procedures and criteria, see the May 23, 1995 Federal
Register Notice, or contact Jon Kessler at EPA's Office of Policy
Analysis (202) 260-4034.
Green Lights Program
EPA's Green Lights program was initiated in 1991 and has the goal
of preventing pollution by encouraging U.S. institutions to use
energy-efficient lighting technologies. The program has over 1,500
participants which include major corporations; small and medium
sized businesses; Federal, State and local governments; non-profit
groups; schools; universities; and health care facilities. Each
participant is required to survey their facilities and upgrade lighting
wherever it is profitable. EPA provides technical assistance to the
participants through a decision support software package,
workshops and manuals, and a financing registry. EPA's Office of
Air and Radiation is responsible for operating the Green Lights
Program. (Contact: Susan Bullard at 202-233-9065 or the Green
Light/Energy Star Hotline at 202-775-6650)
WasteWi$e Program
The WasteWi$e Program was started in 1994 by EPA's Office of
Solid Waste and Emergency Response. The program is aimed at
reducing municipal solid wastes by promoting waste minimization,
recycling collection, and the manufacturing and purchase of
recycled products. As of 1994, the program had about 300 companies
as members, including a number of major corporations. Members
agree to identify and implement actions to reduce their solid wastes
and must provide EPA with their waste reduction goals along with
yearly progress reports. EPA in turn provides technical assistance to
member companies and allows the use of the WasteWi$e logo for
promotional purposes. (Contact: Lynda Wynn, 202-260-0700 or the
WasteWi$e Hotline at 1-800-372-9473).
SIC Code 25
102
September 1995
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Sector Notebook. Project
Wood Furniture and Fixtures
According to a representative from the Business and Institutional
Furniture Manufacturers Association (BIFMA), BIFMA has recently
joined the EPA's Waste Wi$e Program.
Climate Wise Recognition Program
NICE3
The Climate Change Action Plan was initiated in response to the
U.S. commitment to reduce greenhouse gas emissions in
accordance with the Climate Change Convention of the 1990 Earth
Summit. As part of the Climate Change Action Plan, the Climate
Wise Recognition Program is a partnership initiative run jointly by
EPA and the Department of Energy. The program is designed to
reduce greenhouse gas emissions by encouraging reductions across
all sectors of the economy, encouraging participation in the full
range of Climate Change Action Plan initiatives, and fostering
innovation. Participants in the program are required to identify
and commit to actions that reduce greenhouse gas emissions. The
program, in turn, gives organizations early recognition for their
reduction commitments; provides technical assistance through
consulting services, workshops, and guides; and provides access to
the program's centralized information system. At EPA, the
program is operated by the Air and Energy Policy Division within
the Office of Policy Planning and Evaluation. (Contact: Pamela
Herman, 202-260-4407)
The U.S. Department of Energy and EPA's Office of Pollution
Prevention are jointly administering a grant program called The
National Industrial Competitiveness through Energy,
Environment, and Economics (NICE^). By providing grants of up
to 50 percent of the total project cost, the program encourages
industry to reduce industrial waste at its source and become more
energy-efficient and cost-competitive through waste minimization
efforts. Grants are used by industry to design, test, demonstrate, and
assess the feasibility of new processes and/or equipment with the
potential to reduce pollution and increase energy efficiency. The
program is open to all industries; however, priority is given to
proposals from participants in the pulp and paper, chemicals,
primary metals, and petroleum and coal products sectors. (Contact:
DOE's Golden Field Office, 303-275-4729)
September 1995
103
SIC Code 25
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Wood Furniture and Fixtures
Sector Notebook Project
VIII.C Trade Association/Industry Sponsored Activity
The following discussion will provide an overview of the larger
trade associations representing the wood furniture
manufacturing industry, with contact names, addresses, and
summaries of activities undertaken by the associations to
heighten their member companies' awareness of environmental
regulations and compliance issues.
VDI.C.l. Environmental Programs
The larger trade associations with member companies from the
wood furniture manufacturing industry have undertaken
campaigns to educate further their membership on environmental
regulations and compliance issues. The American Furniture
Manufacturers Association (AFMA), in conjunction with 3M
Environmental Engineering, Akzo Nobel, and Radian Corporation,
has developed an industry compliance notebook and training
course to inform facility managers of environmental regulations
which could apply to their manufacturing operations. Similarly,
Business and Institutional Furniture Manufacturers Association
(BIFMA), AFMA, and the Kitchen Cabinet Manufacturers
Association (KCMA) have already conducted four training seminars
on the draft CTG and MACT standards for the wood furniture
industry and how to comply with the new requirements. In
addition, AFMA, BIFMA, KCMA, and the National Paint and
Coatings Association were the primary industry trade association
representatives in the lengthy regulatory negotiation process with
EPA and other interested parties on the CTG and MACT standards.
VHLC.2. Summary of Trade Associations
American Furniture Manufacturers
Association (AFMA)
P.O. Box HP-7
High Point, NC 27261
Phone: (910)884-5000
Fax: (910)884-5303
Members: 336
Staff: 14
Founded in 1984, this trade association includes manufacturers
seeking to provide a unified voice for the furniture industry and to
aid in the development of personnel. The group provides market
research data, industrial relations services, costs and operating
statistics, and general management and information services. The
SIC Code 25
104
September 1995
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Secton Notebook Project
Wood Furniture and Fixtures
AFMA has annual meetings and publishes a membership directory
once a year.
Business and Institutional Furniture
Manufacturers Association (BIFMA)
2680 Horizon Drive S.E., Suite A-l
Grand Rapids, MI 49546
Fax: (616)285-3765
Members: 221
Staff: 6
Budget: $700,000
Contact: Russell Coyner, Exec. Dir.
Phone: (616)285-3963
This trade association consists of firms that manufacture furniture
intended for use in offices, public spaces, and non-live-in
institutions (including seating and space divider manufacturers).
BIFMA is involved in industry relations, government relations,
and maintains and provides industry information and statistics.
The group conducts annual management conferences and publishes
an annual membership directory, a bimonthly newsletter, and
various statistical reports for its membership.
Futon Association International (FAI)
P.O. Box 6548
Chico, CA 95927-6548
Phone: (916)534-7833
Toll free: (800) 327-3262
Fax: (916)534-7875
Members: 450
Staff: 2
Contact: Timothy Jacobs,
Executive Director
The FAI includes manufacturers, suppliers, wholesalers, and
retailers of futons. This trade association facilitates contact and
communication within the futon industry and keeps members
informed of changes in the bedding industries codes, laws, and
regulations. The FAI annually hosts a Futon EXPO and publishes
periodic bulletins, membership directories, and a quarterly
document entitled Updates.
September 1995
105
SIC Code 25
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Wood Furniture and Fixtures
Sector Notebook Project
Grand Rapids Area Furniture Manufacturers
Association (GRAFMA)
4362 Cascade Road, S.E., Suite 113
Grand Rapids, MI 49506
Phone: (616)942-6225
Fax: (616)942-1730
Members: 56
Staff: 2
Budget: $97,000
Contact: Carol Kooistra,
Executive Director
This association consists of furniture manufacturers located in
western Michigan. The organization conducts wage surveys,
compiles statistics, sponsors periodic seminars on furniture
technology, and publishes brochures, newsletters, and the
document entitled Roster.
International Home Furnishings Marketing
Association (IHFMA)
P.O. Box 5687
High Point, NC 27262
Phone: (910)889-0203
Fax: (910)889-7460
Members: 55
Staff: 2
Contact: Richard Barentine,
Executive Director
Founded in 1955, this furniture manufacturers' group works to
create a cooperative business environment. The IHFMA holds
semiannual meetings in North Carolina and publishes various
brochures and pamphlets.
International Wholesale Furniture
Association (IWFA)
P.O. Box 2482
164 S. Main Street, Suite 404
High Point, NC 27261
Phone: (910)884-1566
Members: 127
Staff: 2
Contact: Sonny Berry,
Executive Director
The IWFA consists mainly of wholesalers of home furniture but
also includes some supplier firms that manufacture products
offered for sale by wholesale-distributor members. This trade
association hosts semiannual banquets and publishes a monthly
newsletter entitled National Wholesale Furniture Association and
an annual publication Who's Who in Furniture Distribution.
SIC Code 25
106
September 1995
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Sector Notebook. Project
Wood Furniture and Fixtures
IX.
CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/BIBLIOGRAPHY
For further information on selected topics within the furniture and fixtures
industry, a list of publications is provided below:
General Profile
Encyclopedia of Associations, 27th ed., Deborah M. Burek, ed., Gale Research Inc.,
Detroit, Michigan, 1992.
Enforcement Accomplishments Report, FY 1991, U.S. EPA, Office of
Enforcement (EPA/300-R92-008), April 1992.
Enforcement Accomplishments Report, FY 1992, U.S. EPA, Office of
Enforcement (EPA/230-R93-001), April 1993.
Enforcement Accomplishments Report, FY 1993, U.S. EPA, Office of
Enforcement (EPA/300-R94-003), April 1994.
Standard Industrial Classification Manual, Office of Management and Budget,
1987.
1992 Toxic Release Inventory (TRI) Public Data Release, U.S. EPA, Office of
Pollution Prevention and Toxics, April 1994. (EPA/745-R94-001)
U.S. Industrial Outlook 1994 - Household Consumer Durables, Department of
Commerce.
1987 Census of Manufacturers, Industry Series: Household Furniture, Bureau of
the Census. (MC87-I-25A)
1992 Census of Manufacturers, Preliminary Report Industry Series: Household
Furniture, Bureau of the Census, May 1994. (MC92-I-25A(P))
Process Descriptions
Draft Guidelines for the Control of Volatile Organic Compound Emissions from
Wood Furniture Coating Operations, U.S. EPA, Office of Air and Radiation,
October 1991.
EPA Document AP-42 - Compilation of Air Pollutant Emission Factors
McGraw-Hill Encyclopedia of Science & Technology, 6th ed., vols. 5, 6, 11, 13, 14,
16, 18,19, McGraw-Hill Book Company, New York, New York, 1987.
September 1995
107
SIC Code 25
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Wood Furniture and Fixtures
Sector Notebook Project
Regulatory Profiles
Draft Control Techniques Guidelines (CTGs) - Appendix B: Preliminary Draft
Model Rule for Wood Furniture Finishing and Cleaning Operations, U.S. EPA.
Environmental Guide for the Furniture Industry, AFMA, 3M Environmental
Engineering, Akzo Nobel, Radian Corporation, Research Triangle Park, North
Carolina, 1994.
Furniture/Wood Manufacturing and Refinishing, U.S. EPA, RCRA Fact Sheet.
(EPA/530-SW-90-027c)
Pollution Prevention
Pollution Prevention Options in Wood Furniture Manufacturing, A
Bibliographic Report, U.S. EPA, Office of Pollution Prevention and Toxics,
February 1992. (EPA/560/8-92/001C)
Contacts*
Name
Rosalyn Hughes
David Stout
Gary Bell
Stan Payne
Ronald Pridgeon
John Cullen
Larry Runyan
Bob Naboicheck
Sholeh Azar
Bob McCrillis
Bob Marshall
Madeliene Strum
Paul Eisele
Organization
U.S. EPA, Region IV (inspector)
Broyhill Corporation
La-Z-Boy Chair Company
Bassett Furniture
NC Department of Environment,
Health, and Natural Resources
Masco Corporation
American Furniture Manufacturers
Association
Futon Association International
NC State University
U.S. EPA, Office of Research and
Development
U.S. EPA, OECA
U.S. EPA, RTP
Masco Corporation
Telephone
404-347-2904
704-758-3111
313-242-1444
703-629-6000
919-571-4000
313-274-7400
910-884-5000
203-549-2000
919-515-6400
919-541-2733
202-564-7021
919-541-2383
313-274-7400
Many of the contacts listed above have provided valuable background information and comments during the
development of this document. EPA appreciates this support and acknowledges that the individuals listed do
not necessarily endorse all statements made within this notebook.
SIC Code 25
108
September 1995
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Sector Notebook Project
IVood Furniture and Fixtures
Name
Edyth McKinney
John Lank
Organization
Small Business Ombudsman,
North Carolina
U.S. EPA, Region IV (inspector)
Telephone
800-829-4841
404-347-7603
September 1995
109
SIC Code 25
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APPENDIX A
INSTRUCTIONS FOR DOWNLOADING THIS NOTEBOOK
Electronic Access to this Notebook via the World Wide Web (WWW)
This Notebook is available on the Internet through the World Wide Web. The Enviro$en$e
Communications Network is a free, public, interagency-supported system operated by EPA's Office
of Enforcement and Compliance Assurance and the Office of Research and Development. The
Network allows regulators, the regulated community, technical experts, and the general public to
share information regarding: pollution prevention and innovative technologies; environmental
enforcement and compliance assistance; laws, executive orders, regulations, and policies; points of
contact for services and equipment; and other related topics. The Network welcomes receipt of
environmental messages, information, and data from any public or private person or organization.
ACCESS THROUGH THE ENVIRO$EN$E WORLD WIDE WEB
To access this Notebook through the EnviroSenSe World Wide Web, set your World Wide
Web Browser to the following address:
http://eS.inel.gov/OCCa - then select "EPA Sector Notebooks"
Of after 1997, (when EPA plans to have completed a restructuring of its web site) set
your web browser to the following address:
WWW.epa.gOV/OeCa - then select the button labeled Gov't and Business
The Notebook will be listed.
HOTLINE NUMBER FOR E$WWW: 208-526-6956
EPA E$WWW MANAGERS: Louis Paley 202-564-2613
Myles Morse 202-260-3151
(This page updated June 1997)
Appendix A
-------
-------
United States Government
INFORMATION
PUBLICATIONS * PERIODICALS * ELECTRONIC PRODUCTS
Order Processing Code:
* 3212
Charge your order.
It's easy!
Fax your orders (202) 512-2250
Phone your orders (202) 512-1800
jitH^x
Qty.
»«S'!^.**sCJ-**»is^«i5K7i:Ci
Stock Number
055-000-00512-5
055-000-00513-3
055-000-00518-4
055-000-00515-0
055-000-00516-8
055-000-00517-6
055-000-00519-2
055-000-00520-6
055-000-00521-4
055-000-00522-2
055-000-00523-1
055-000-00524-9
055-000-00525-7
055-000-00526-5
055-000-00527-3
055-000-00528-1
• 055-000-00529-0
055-000-00514-1
Sjf^sss^^^-^soi&fi^i^sss^x^iss^s^^iv^ -"-T^^'ja^aus?'^' • -
Published in 1995 Title
Dry Cleaning Industry, 1 04 pages
Electronics and Computer Industry, 160 pages
Fabricated Metal Products Industry, 164 pages
Inorganic Chemical Industry, 136 pages
Iron and Steel Industry, 1 28 pages
Lumber and Wood Products Industry, 136 pages
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Motor Vehicle Assembly Industry, 1 56 pages
Nonferrous Metals Industry, 140 pages
Non-Fuel, Non-Metal Mining Industry, 1.08 pages
Organic Chemical Industry, 152 pages
Petroleum Refining Industry, 160 pages
Printing Industry, 1 24 pages
Pulp and Paper Industry, 156 pages
Rubber and Plastic Industry, 1 52 pages
Stone, Clay, Glass and Concrete Industry, 1 24 pages
Transportation Equipment Cleaning Industry, 84 pages
Wood Furniture and Fixtures Industry, 1 32 oaaes
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Price
Each
$ 6.50
11.00
11.00
9.00
8.00
9.00
10.00
11.00
9.00
6.50
11.00
11.00
7.50
11.00
11.00
7.50
5.50
8.00
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Total I
Price
I
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Qty.
Stock Number
055-000-00570-2
055-000-00571-1
055-000-00572-9
055-000-00573-7
055-000-00574-5
055-000-00575-3
055-000-00576-1
055-000-00577-0
055-000-00578-8
055-000-00579-6
Published in 1997 Title
Air Transportation Industry, 90 pages
Ground Transportation Industry, 130 pages
Water Transportation Industry, 90 pages
Metal Casting Industry, 1 50 pages
Pharmaceutical Manufacturing Industry, 147 pages'
Plastic Resin & Man-made Fiber Industry, 1 80 pages
Fossil Fuel Electric Power Generation Industry, 160 pages
Shipbuilding and Repair Industry, 1 20 pages
Textile Industry, 1 30 pages
Sector Notebook Data Refresh -1 997, 21 0 pages
Price
Each
$ 7.50 .
.10.00
7.50
13.00
13.00
15.00
14.00
9.50
10.00
17.00
Total for Publications
Total i
Price i
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The total cost of my order is
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