12.  Is wood packaging (e.g., pallets, crates) subject to the ATCM?   Since wood packaging may contain composite wood products (i.e., hardwood plywood, medium density fiberboard, and/or particleboard), wood packaging would be “finished goods” subject to the ATCM if one were to take a strict interpretation of the ATCM’s definition of “finished goods.”  However, it was not CARB’s intent to regulate wood packaging as “finished goods.”  To be consistent with this intent and provide fairness to the regulated community, CARB staff interprets the ATCM as not applying to wood packaging.  These products are not subject to any of the requirements of the ATCM.

By “wood packaging” we mean pallets, skids, boxes, crates, and containers used for handling, sorting, storing, shipping, and transporting goods.

13. How will packing material, such as “dunnage” or “offal” be considered in the ATCM?  Packing material, also referred to as “dunnage”, or “offal” (“dunnage” or “offal” is essentially loose, waste material such as composite wood products that are used for packaging or covering shipments in order to protect cargo from damage during transport) is not considered a finished good and is not appropriate for deconstructive emissions testing.  Hence, packing material of this type does not need to comply with the regulation.