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relied upon by engineers, architects, governments, builders, and consumers .... website (www.awpa.com) and is also published in the AWPA Book of Stand...
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Chapter 20

The Development of Consensus-Based Standards for Wood Preservatives/Protectants and Treated Wood Products Colin A. McCown* American Wood Protection Association, Post Office Box 361784, Birmingham, Alabama 35236-1784 U.S.A. *E-mail: [email protected].

Consensus-based standards for wood preservatives and treated wood products have been developed by the American Wood Protection Association (AWPA) for over a century. AWPA’s standards development process is open to all persons and allows for consideration of all viewpoints. The AWPA Technical Committee Regulations provide the procedures and basic framework for the standards development process, leading to promulgation of credible wood protection standards that are relied upon by engineers, architects, governments, builders, and consumers in the United States and around the world.

Introduction Standards play a significant role in society, but we are rarely aware of their value. When was the last time you considered the color of traffic signals and signs, or how information is transmitted over the Internet? Standards are very important to society in that they establish minimum levels of quality acceptable to consumers, and often level the playing field between competitors. AWPA’s development of standards for treated wood products is subject to an open, consensus-based process which provides due process for all participants. This, in turn, leads to the promulgation of technically competent and reliable standards for use by specifiers of treated wood products.

© 2014 American Chemical Society In Deterioration and Protection of Sustainable Biomaterials; Schultz, T., et al.; ACS Symposium Series; American Chemical Society: Washington, DC, 2014.

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AWPA History The American Wood Protection Association (AWPA) was established in 1904 at the World’s Fair in St. Louis, Missouri, by a delegation of individuals engaged in the business of preserving wood, primarily for telegraph poles, railroad crossties, and trestle materials. At their first scheduled meeting, the members set out to create industry standards for preservatives used at that time, which were coal tar creosote and zinc chloride. Since that time over a century ago, AWPA has continued to develop and improve standards for additional preservative systems, methods of analyzing for preservatives, quality control procedures, tests for evaluation of wood preservative performance, and specifications for treated wood products. Another key development was the establishment of the AWPA Use Category System, first promulgated in 1999. AWPA has also expanded its membership to include individuals from diverse interest groups, such as producers of preservatives and components of preservative systems, producers of treated and untreated forest products, end users, engineers, architects, building code officials, government employees, academics, and others interested in wood protection. Today, AWPA’s Use Category System Standards (U1 and T1) are recognized worldwide as credible and reliable standards for preservative treated wood products. AWPA Standard U1 is typically specified by architects and engineers, required by major model building codes, and referenced in material specifications for wood products used in railroad, utility, and other commercial/industrial construction.

Current AWPA Standards AWPA publishes an annual Book of Standards which contains all standards currently maintained by the Association. The general classes of AWPA Standards are as follows: U: T: P: HS: A: M: E:

User Specifications for Treated Wood Processing and Treatment Preservatives/Protectants Hydrocarbon Solvents Analytical Methods Miscellaneous Standards Evaluation Methods

At present, there are 172 standards, all of which are under “continuous maintenance”. This means that proposals to create new standards, revise or reaffirm existing standards, or to withdraw standards may be made at any time by any person in accordance with the AWPA Technical Committee Regulations. In order to ensure that standards remain up-to date, performance data must be submitted every five years to reaffirm each preservative/protectant standard. All other classes of standards must be either revised or reaffirmed every five years. 342 In Deterioration and Protection of Sustainable Biomaterials; Schultz, T., et al.; ACS Symposium Series; American Chemical Society: Washington, DC, 2014.

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ANSI Accreditation AWPA is an American National Standards Institute (ANSI) accredited standards developer, which means that the procedures which govern AWPA’s standards development process have been reviewed by ANSI and are found to be in conformance with the ANSI Essential Requirements. These procedures are found within the AWPA Technical Committee Regulations (TCR). TheTCR are maintained by, and are under the jurisdiction of the AWPA Executive Committee, an elected body representing the Association membership and serving as its board of directors. The TCR contains the elements of due process, consensus, public review, consideration of all viewpoints, incorporation of proposed changes to AWPA Standards, and right to appeal by any participant. ANSI itself does not write or review the technical content of any AWPA Standard. ANSI accreditation simply demonstrates that AWPA’s standards development process is open, consensus-based, and affords each participant with due process. AWPA’s Executive Committee continues to revise the TCR to maintain ANSI accreditation as well as to make the standards development process more efficient and transparent.

AWPA Technical Committees To develop effective standards, AWPA relies heavily upon the knowledge of the individual members of its Technical Committees. These volunteers donate their time and expertise to the standards development process. Each committee has jurisdiction over specific standards or portions of standards. These members consider and deliberate all standardization proposals submitted to their committee, and ultimately vote to approve or reject each proposal as originally submitted or as modified during the meeting of the committee. The current AWPA Technical Committees are as follows:

P-1: P-3: P-4: P-5: P-6: P-8: P-9: T-1: T-2: T-3: T-4: T-7: T-8: T-10:

Preservatives/Protectants Coordination Oilborne and Creosote-Based Preservative Systems Waterborne Preservative Systems Methods for Chemical Analysis of Preservatives Methods for the Evaluation of Wood Preservatives Nonpressure Preservatives Nonbiocidal Wood Protection Treatments Coordination Lumber and Timbers Piles and Ties Poles and Posts Quality Control and Inspection Composites Millwork and Manufactured Wood Products 343

In Deterioration and Protection of Sustainable Biomaterials; Schultz, T., et al.; ACS Symposium Series; American Chemical Society: Washington, DC, 2014.

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Membership in a Technical Committee is limited so as to strive for balance and avoid dominance. Except for Committees P-1 and T-1, which are comprised of the officers of all related committees, there can be no majority representation of any single interest group (i.e., User, Producer, or General Interest), nor can there be more than one member representing any single organization. Any individual, whether or not they are a member of AWPA, may apply for Technical Committee membership. Persons with expertise on the subject matter considered by each committee are sought for active participation. It is also important to note that AWPA has several Special Committees which do not develop standards, but serve important functions within the Association. These are as follows: S-2: S-3: S-8:

Wood Preservation Research Treated Wood Use, Handling, and Disposal/ Recycle/Reuse Plant Operations

Data Requirements It is understood that when evaluating the performance of a wood protection system against biological agents of deterioration, it can be quite challenging to develop a perfect data package to accompany a standardization proposal. With that in mind, AWPA’s Technical Committees have published a number of Guidance Documents to help those developing proposals for new wood protection systems and treated wood products. These documents define the Technical Committees’ expectations for the type and quality of data necessary for the Committee to evaluate the product’s performance. Due to past experience and the anticipated variability in many evaluation test results, the development of static criteria for approval of wood protection systems has proven futile. For this reason, the data requirements set forth in the Guidance Documents may be subject to waiver by the relevant Technical Committee if justification is provided along with the data package. Some of the current AWPA Guidance Documents which provide data requirements or testing protocols are as follows: A. Data Requirement Guidelines for Listing Wood Preservatives in the AWPA Standards B. Guidelines for Evaluating New Fire Retardants for Consideration by AWPA C. Protocol for Standardization of New Millwork Preservative Systems D. Protocol for Standardization of New Wood Preservative Finishes E. Recommended Method for Determining the Treatability of a Species for Inclusion in AWPA Use Category System Commodity Specifications for Sawn Material F. Guidelines for Evaluating Composite Wood Products Preservative Treated Using Nonpressure Processes 344 In Deterioration and Protection of Sustainable Biomaterials; Schultz, T., et al.; ACS Symposium Series; American Chemical Society: Washington, DC, 2014.

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G. Surface Applied Wood Preservative Finish Performance Testing Guideline H. Evaluating Preservatives for Remedial Treatment K. Data Requirement Guidelines for Solvents Used with Oil-borne Preservatives L. Data Requirement Guidelines for Listing Chemically Modified Wood with Enhanced Durability in the AWPA Standards M. Data Requirement Guidelines for Evaluating Performance Enhancing Additives (PEA) (Note that Guidance Documents I and J are not in this list, as they do not provide specific data requirements or testing protocols.) The complete text of each Guidance Document is available on the AWPA website (www.awpa.com) and is also published in the AWPA Book of Standards.

General Procedures for Standardization As mentioned previously, AWPA’s standardization procedures are governed by the Technical Committee Regulations (TCR). AWPA Staff and all other persons involved in the standardization process are required to abide by the TCR so as to promote an open, consensus based standards development environment. Data Development In some cases, organizations considering standardization of their products will attend the AWPA Technical Committee Meetings to gauge interest. If the organization chooses to engage in the standardization process, they will often request that a Task Group be formed to assist them in developing a proposal for submittal to that Technical Committee. Much of the data required by the appropriate Guidance Document has already been gathered at that point, so the intent of the task group is to look for deficiencies in the data package, and help the organization develop a proposal for standardization. However, most of the organizations familiar with AWPA’s procedures may choose to submit a proposal directly to the appropriate Technical Committee without requesting formation of a Task Group. Preservatives Review Board The AWPA Preservatives Review Board (PRB) is an optional procedure which was designed to assist manufacturers of new preservative systems in developing a data package and proposal for submission to the appropriate AWPA Technical Committee. It is intended to take the place of a Task Group if the manufacturer prefers expert review of a data package in an expedited manner. The PRB is beneficial to manufacturers who are unfamiliar with AWPA’s standardization procedures and are concerned about the relatively slow rate 345 In Deterioration and Protection of Sustainable Biomaterials; Schultz, T., et al.; ACS Symposium Series; American Chemical Society: Washington, DC, 2014.

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at which Task Groups operate. This procedure is optional, so a preservative manufacturer is still free to request formation of a Task Group if they so choose. The PRB is randomly selected from a pool of qualified reviewers, and is required to generate a report within a specific time frame. While AWPA charges no fees to promulgate standardization of any product, the cost for this optional review is currently $3500 for the review itself, plus a $500 administrative fee. The PRB procedures are covered in AWPA Guidance Document J, which is published in the AWPA Book of Standards and on the AWPA website. Proposal Submission The proponent would first obtain a copy of the standardization proposal form from the AWPA website. A proponent can be any person, whether or not they are members of AWPA or a Technical Committee. The proponent would complete the fields for contact information, the type of proposal and a brief description of and rationale for the proposal. In the “Proposal” section, the proponent would show exactly how a current standard is being revised by using strikethrough text for deletions, and underlined text for insertions. For new standards, a complete version of the proposed new standard without any formatting marks is inserted in the form or attached as a separate document. Finally, all relevant data must be included with the form. The proposal form and data package must be submitted to AWPA at least 60 days prior to the commencement of the Technical Committee Meetings, which take place in September of each year, when all AWPA Technical and Special Committees are required to meet. Time sensitive or urgent proposals may be submitted 60 days prior to the AWPA’s Annual Meeting, which occurs in the spring of each year. If proposals for the Spring cycle are received on time, the committee to which the proposal is made will meet in conjunction with the Annual Meeting. Technical Committee and Public Review All proposals are then posted to the appropriate committee web page in the member-accessible section of the website as soon as possible after they are received, but normally at least 50 days prior to the commencement of the Technical Committee meetings, or AWPA’s Annual Meeting if any time-sensitive or urgent proposals have been submitted. Notification is made to all committee members, and a summary of proposals is posted to the AWPA website. All persons are advised to provide any comments and/or questions to the proponent at least 20 days prior to the technical committee meeting. Technical Committee Meetings During the Technical Committee meetings, each proponent is provided an opportunity to briefly present their proposal, answering any questions and responding to any comments made during the meeting. If deemed necessary by the committee, modifications to a proposal can be made from the floor. If a member of the committee makes a motion to adopt the proposal, whether as 346 In Deterioration and Protection of Sustainable Biomaterials; Schultz, T., et al.; ACS Symposium Series; American Chemical Society: Washington, DC, 2014.

originally proposed or as modified, and at least two-thirds of the committee members present and voting at the meeting approve the motion, the proposal moves forward to letter ballot of the full committee.

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Letter Ballot The letter ballot is developed by AWPA staff for each proposal approved during the committee meetings. The ballot form itself, along with a combined supporting data file for all proposals is posted to a member-accessible page on the AWPA website. The ballot forms are disseminated to all committee members, and the ballot is open for at least 30 days, but will remain open until at least a 60% return rate is achieved. All ballot items with no negative votes or objections move forward to procedural review and final action by the AWPA Executive Committee. Ballot items not receiving at least two-thirds affirmative votes are submitted to the Executive Committee for final action and a hearing of appeals, if any. Should a ballot item receive at least two-thirds affirmative votes, but also has negative votes and/or objections, these items are subject to resolution and disposition procedures.

Resolution and Disposition of Objections If there are any public review comments objecting to a proposal, or if there are any negative votes on a proposal, an effort is made by the Technical Committee chair to resolve these comments. Since the TCR does not permit substantive changes to proposals after the meeting of the Technical Committee, only those objections which would result in an editorial change tend to cause the negative voter and/or objector to change their vote or withdraw their comment. In many cases, objectors simply decide that their concerns were very minor and change their vote at this time. In both cases, the objections are deemed “resolved”. Those persons strongly objecting to a proposal tend to maintain their negative vote or objection, since no substantive changes are permitted. In this case, the objections are considered “unresolved” and the ballot is recirculated to the appropriate Technical Committee.

Recirculation Ballot (Re-Ballot) Each unresolved objection is attached to a recirculation ballot and sent to all committee members giving them an opportunity to respond, reaffirm, or change their vote on the original letter ballot. At the end of the recirculation period, each proposal on the ballot must be approved by two-thirds of members voting on the ballot item. If the ballot item passes with at least two-thirds in favor of a proposal, all unresolved negative voters and objectors are then notified that an appeals process exists within the TCR. If the ballot item fails, then the proponent is notified that they may resubmit their proposal, with or without modifications, in a future standardization cycle. 347 In Deterioration and Protection of Sustainable Biomaterials; Schultz, T., et al.; ACS Symposium Series; American Chemical Society: Washington, DC, 2014.

Procedural Review and Final Action

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The final step in the process is procedural review and final action by the AWPA Executive Committee. Any appeals received by the deadline are considered, and a determination is made as to whether or not all of the procedural aspects of the TCR were followed. If so, the Executive Committee takes final action on the proposals. The approved revisions or additions to the AWPA standards are fully promulgated at this time and are subsequently published in the latest annual edition of the AWPA Book of Standards.

Conclusion The development of standards for the protection of wood from biological agents of deterioration isn’t always easy. Fortunately, AWPA provides well-structured procedures in an open forum where the performance of products can be reviewed by nearly all of the experts in the field of wood protection in North America. There are no financial barriers to participation in the process, and the views of all persons must be considered. This results in stringent but effective standards which have served as the foundation for the treated wood industry since 1904.

348 In Deterioration and Protection of Sustainable Biomaterials; Schultz, T., et al.; ACS Symposium Series; American Chemical Society: Washington, DC, 2014.