“The proponents of these changes violated Section 5.5 of the AWPA Technical Committee Regulations requiring revisions be based upon relevant and adequate supporting data and Section 7.3, which requires that proposals to adjust standards be accompanied by a written statement that relevant data was not omitted,” said Ken DelleDonne president of Sunbelt Forest Products. During the presentation, proponents (which use a micronized copper azole treatment system for above ground lumber) showed photos of structural failures with above ground treated wood that they claimed were representative of widespread problems. They did not present actual statistical data to back up these claims, however.
“But this spring, when these same proponents were seeking to have micronized treatment standardized by the AWPA, they were suddenly able to produce data showing its efficacy in above ground applications. This was in direct contrast to the statements they made during the consideration of the revision, and would have likely materially impacted the outcome of the proposal consideration,” DelleDonne added.
“This was four-year-old data that they certainly were familiar with before the submission of the proposal to modify the U1 standard and that should have been presented during the consideration of its revision,” DelleDonne said. “According to AWPA bylaws, if data is withheld the proponent should be advised to either provide written explanation as to why the data was withheld or to resubmit the proposal at a later date to include relevant data.”
Any explanation for the data omission would be suspect, he said. “It seems highly unlikely that the same proponent who had only pictures to show during the revision presentation was unaware of the existence of this data that would have created legitimate concerns about the need for any changes in the U1 standard.”
“If the AWPA is going to remain the standard bearer for the pressure treated industry, it must recognize the questions about the validity of these important guidelines, questions that are raised by the omission of key existing data, whether intentional or accidental,” DelleDonne said. “The AWPA’s responsibility is to get the standards right on an industry-changing guideline like this one. We need to reconsider the proposal with all the facts, not just a few pieces of select information.”
Causes for concern: Commercialization, environmental impact and unnecessary costs
Sunbelt Forest Products is also expressing some misgivings about the possible commercialization of the AWPA U1 standard by members who could benefit from the changes. DelleDonne said the issue is important because the revised U1 ground contact standards have caused confusion in the industry and have caused unwarranted price increases. They could also be harmful to the environment long term.
“Some retailers and wood treatment companies appear to be under the mistaken impression that all treated wood used in outdoor applications must meet ground contact standards. But this is not the case,” he continued. Most recently, the AWPA T1 Education Task Force, a subgroup of the Technical Committee, worked in conjunction with the Softwood Lumber Board and Western Wood Preservers Institute to produce an infographic on the recent U1 standard revision that shows very clearly that joists and beams can use lumber treated to UC3B above ground, exterior construction standards.
Despite this graphic, certain producers and suppliers are forcing their retail and contractor customers to switch to all ground-contact wood because they say it is required by the AWPA revision. When only ground contact wood is available, retailers and contractors are forced to pay higher costs not only for the more heavily treated lumber but also for the more robust fasteners required with such wood. There are also environmental concerns, since ground contact lumber contains more copper than wood treated for above ground use.
“Large treaters, representing 70% of the total market, have used this revision as the basis for forcing their customers to all ground contact material, resulting in a 15% increase or more in retail prices,” DelleDonne said. “The rationale for the revisions was said to be misapplication of above ground treated products by consumers, however, our data shows misapplication occurs significantly less than 1% annually, making the revisions unnecessary and a costly correction to a problem that occurs once out of millions of successful installations.”
He also noted that even if there is a problem, it may be related to the type of treatment used for above ground wood. Companies that treat wood with Ecolife, ACQ and CAC have not experienced the quantity of problems that the non- AWPA standardized micronized treatment customers are reporting with their above ground lumber.
There are also concerns about the adoption of the revised AWPA standard by the International Building Code (IBC) and the International Residential Code (IRC). Both serve as the basis for state and local building codes in the U.S. and both reference AWPA Standard U1 in their requirements for deck construction.
“We are on a slippery slope of adding significant cost and environmental implications to the entire building construction industry on a revision based entirely upon irrelevant, incomplete data,” said DelleDonne. “The whole issue needs more discussion–and discussion backed this time by all available hard data.”
Specific requests in appeal
Sunbelt Forest Products will formally request several actions in its appeal of the revision to the Executive Committee:
- Rescind the AWPA Standard U1 2015 revisions relating to above ground and ground contact due to lack of relevant data and procedural abeyance resulting from data omission
- Resubmit the revision proposal at a later date including ALL relevant data.
- Immediately withdraw, prior to official printing, the U1 2015 revisions relating to above ground contact from the AWPA’s 2016 Book of Standards
- Notify the ICC to withdraw ICC AC326 Revisions as the AWPA U1 standard is in question due to data omission and lack of relevant data.
- Notify the IBC and IRC that the revisions to AWPA U1 standard is in question due to data omission and lack of relevant data.
The AWPA by-laws state the Executive Committee will give written notification of its decision. Given the immediate ramifications of the proposed revisions, Sunbelt Forest Products is going to request expedited consideration of its appeal.
Sunbelt Forest Products of Bartow, Florida, a wholly owned subsidiary of PalletOne, Inc., is one of the largest pressure treaters in the Southeast. Operating three locations in Alabama and Florida, Sunbelt’s manufacturing capabilities exceed 300 million board feet of pressure treated wood per year.
SOURCE Sunbelt Forest Products