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Board of Review American Lumber Standard Committee, Incorporated

R.B. Parrish, Chairman R.L. Ethington W.T. Hawks T.D. Searles, President

VIAE-MAIL

TO:

FROM:

DATE:

SUBJ:

ALSC MEMBERS & ALTERNATES

THOMAS D. SEARLES

DECEMBER 23, 2011

ADDITIONAL INFORMATION ON THE SPIB DESIGN VALUE ISSUE

P.O. Box 210 Germantown, Maljlland 20875.(J210

Telephone: 301.972.1700 Fax: 301.540.8004

E·Mail: alsc@alsc.org

For your information attached is some additional correspondence regarding the SPIB design value issue,

Thank you.

TDS:tw

cc: Board of Review Counsel

POST OFPfCE aQ>e 3457/ [140ULTRIE, GEOPG1A 31776/ PHONE 228"CttJ5"o9gf;'

TO:

December 19, 2011

Tom Searles, President, American Lumber Standard Committee Please forward to the ALSC Board of Review

R.B. Parris, Chairman R.L. Ethington W.T.Hawks

FROM: C. Victor Beadles

RE: Southern Pine design value meeting of the Board of Review January 5, 2012

I am a member of the SPIB Board of Governors representing the state of Georgia having served since 2002. Many years ago, I was an alternate to the American Lumber Standards Committee and was active for years on the Grading & Standards Committee (serving as chairman) of the Southeastern Lumber Manufacturers Association. I have for many years had a sincere interest in seeing Southern Pine lumber being properly graded, recognized, and responsive to its many end users and uses.

I recently attended the SFPA Forum in Atlanta and support their report to you concerning the recent issues involving Southern Pine design values.

I want to bring one issue only to the Board of Review in this letter, that of juvenile wood and its effect on the design values of Southern Pine lumber. The timber resource and manufacturing processes have been changing for some time as increasing amounts of smaller and younger pine logs containing a high percentage of juvenile wood have been processed into low strength Southern Pine lumber, primarily in 2x4's.

When larger, more mature trees are harvested from our resource, as was practiced more in the past, the 2x4' s came from the outside of the log and were therefore of better qUality. Today many chip-n-saw operations or mills cutting "super pulpwood" produce lumber with a high percentage of the pith or juvenile wood present in the final product.

It doesn't seem right to reduce design values on all visually graded Southern Pine widths and grades when the root cause of the present problem can be addressed by changing the grade rules to limit this juvenile wood in some of the present grades.

I think, as do others, that proper tests will show as many already have, that the design values will not have to be reduced as much if some grading rule changes were made. The simplest and most effective way would be to reinstitute a meaningful grain (annual rings) and surnmerwood (late wood) requirement into the #2 and higher grades of

Southern Pine. The present 15% summerwood with no grain requirement is an extremely weak and non-limiting rule. SPIB did put a medium grain definition into its rules in 2004 but did not make it a requirement for any of the grades. Density has always been recognized and proven to be a factor in the strength of Southern Pine and a grain requirement would also address the coarse grain strength problems in all widths and not just the lumber cut from younger trees.

The presence of pith is less of a problem in wider widths of lumber as the percentage of the pith is lower and coupled with the difficulty of grading out the pith, a grain requirement is the best answer as it will effectively deal with the juvenile wood and not penalize lumber from mature trees with a pith center which contain medium or denser grain beyond the pith.

I am enclosing just a few notes and articles to show how others including the Forest Products Laboratory and SPIB itself have been warning about this juvenile wood encroachment into Southern Pine lumber.

I would hope and ask the Board of Review to direct the SPIB to bring back different recommendations in design values in #2 and higher visually graded lumber with some medium grainlsummerwood requirements for these grades.

CVB/lg

Enclosures

Sincerely,

C. Victor Beadles CEO Beadles Lumber Company

Moultrie, GA & Balfour Lumber Company Thomasville, GA

±+~':~"''-~'.'

• - pavid E. kret.c::bIIana Research Eng:f.neer

Engineering Properties ot Wood

USDA .. Forest Product_ Laboratory

Kadison .. WI, USA 53705-2398

In order to Bat~.ry the increased deaand ror rorest product. ~e

addressing ennron-ental concerus.. .uch of t'uture tiJaber aupp1y rill be t'ro..

t-proved trees grown on aanaaed pl.antat~oll.8. These trees vil..l. be harv~ted i.n

short-rotation. cycl.es and will contain l.arger than DOr-al. quantities of juven.il.e

wood. This talk vi..ll address vhat intl.uen.ce juvenil.e wood haa on the structural.

perfoDlllUlce and 1..:pllcations for the aradina ot' d!.ension lU1Dber. The resu1 ts

are ot slgnit~cance to al.l. producera because of concern that the luaber fn.; the

fast-grown pl.antations aay have l.over aechan:ica1 properties than indicated by

curren t design codes.

Early research on anatomical. characteristics and .echanical. properties of

c.lear wood demonstrated that juveni.l.e wood or soft wood species is substantial..ly

10wer in mechanical. properties than ... ature wood.. and general.l.y a.ccoun.ts for the

inferior properties of plantation grown trees COIIIIpared with those grown. in

natural. forests. Because of t.hese earl.y research resu1ts .. there are concerns

that al.l.owable stresses assigned to lumber do not adequatel.y refl.ect the

changing resource. In the 1.960' s.. researchers began to directl.y assess the

mechanical. properties of this .aatecial..

cut froa the juvenile wood zone of l.ogs

at least t'or Douglas-fir and Southern

1 The literature indicates that lumber

obtaiJJ.ed froca young-growth plantations,

Pine. tdll not -.eet c:urrent design requirements. Reported ratios of .21::'·s

containing a.ll juvenile wood to those containi.ng al.1 aature wood strength and

stiffness values have ranged fro.. 045-59 :t and 51-72·% respectivel.y. Juven:Uity

I appears to be IKlre severe in the Southern Pines than in Douglas-fir and aodulus

o~ el.asticity (MOE) is infl.uenced -.ore by juveniJ.e wood than is strength.

Vi.sual. grading r:ul.es in the United States and Canada current1y attecpt to

address this questi.on with restrictiona on growth characteri.stics and

l..ightweight wood. Other aspects of the current grading Systems such as knot

size and slope of grain do Dot separate juven.i.l.e vood froa mature wood. To

acc:oamodate the new plantation. resource.. it appears that grading r:ul.es and/or

a.1.1owabl.e design st.resses vill need to be -adified. The objecti.ve of new ~ V

~grading pract~ces will be to downgrade those pieces that do Dot confor.. to "7\' ~sign and at the same time a:i..n.i.a.ize the downgrade of pieces that do a.eet

~esie.: In visual. grading percentage late vood.. rate of growth (rings per

inch) .. specific gravity .. and the presence or absence of the pith al.l. relate to

juven.i.l.ity and show sa.e potential. for identifying low strength/l.ow st.tffness

pieces. These pbysical properties used individual.l.y as sorting criteria ..

bowever.. are costly to yield because there is considerable overlap betveen the

property distributions for pieces that confor. to design and those that do not.

More work is needed understand the impact various COII\binations of anatOldcal.

predictor variabl.es can have wben used a Buppleaent to visual grading

techni.que.

Machine stress rating balds the most promise for aaintaining a specified

strength level. HOE changes encountered with juveni..l.e wood can be handled by

automatic procedures that include HOE .easureate.nts. Research also indicates

that ratios between lumber strength properties are Dot greatly affected by the

presence of juvenile \lOOd.

1 , , I I

I ~

Southern Pine . Inspection Bureau ®

August 31, 1984

Mr. C. Victor Beadles Beadles Lumber Company P. O. Box 987 Moultrie, GA 31768

Dear Mr. Beadles:

4709 SCENIC HIGHWAY

PENSACOLA. FL 32504·9094

{904J 434-2611

M. S. TOLLESON. CHAIRMAN

J. B. SWIFT. JR .. VICE-CHAIRMAN

R. G. KIMBELL. JR .. PRESIDENT

E. E. JONES. SECRETARY

Thank you for your response to our SPIB Newsletter article on juvenile wood.

In June 1984 the University of North Carolina, Raleigh, North Carolina sponsored a symposium on "Our Changing Resource." Several papers on juvenile wood were presented. We have ordered extra copies and will send you one as soon as they arrive. Copies of two papers that were presented are enclosed.

Further information can be obtained by contacting the United States Forest Products Research Society at 608-231-1361 and asking for a bibliography of papers and articles on the subject. The FPRS charges according to the number of articles cited and whether you are an FPRS member.

~ohn A. Sebelius Technical Director

JAS:jk

Enclosures

AN EQUAL OPPORTUNITY EMPL.OYER

· .

Abstract

l'ESTrNG AND STRESS GRADING TODAY'S SOUTHERN PINE LUMBER

John A. Sebelius Southern Pine Inspection Bureau

Pensacola, Florida

Stress Grading in the United States has evolved over sixty years. It began with the U.S. Forest Service testing of large timbers in a few species and small clear samples in almost all species. Methods for establishing stress grades have tracked the evolution process as ASTM consensus standards. The method for appraising dense lumber visually today is virtually unchanged since 1915.

Twenty years ago, large scale tests of full-size dimension lumber marked the beginning of a change in the information base for stress grading common sizes of lumber. The influence of fast growth on dimension lumber strength began to emerge, but as more data was gathered, more became needed.

Product liability, and long range marketing concerns led to the U.S. In-Grade Testing Program which began in 1978, and involved full­size testing for three properties in virtually all commercial softwood species in North America. One major benefit is expected to be improved handling of design value assignments based on actual field assessment of density, knots and slope-of-grain in full-size lumber. Another will be a method for periodically monitoring changes in the future.

Silvicultural practices which take quality of fiber into account and .genetic engineering are seen as important development areas for the

"

long range. Improved sawmilling, drying and· grading will be needed in .. '.' the near future to deal effectivelY with increasing quantities of plantation timber. .

The second phase of the program involved testing 2x4 through 2xlO, Select Structural, No. 1 and No. 2 grades in bending, tension and compression parallel to grain in practically all U.S. commercial soft­wood species where two inch dimension is produced. The data collection of this final phase has just been completed along with other cooperative studies on the effect of moisture content on strength and stiffness of full-sized lumber. Summarization and analyses, interpretation, standards development, design procedures development, code presentations, and implementation will take place in the next two years.

Among the data collected are specific gravity determined by the Forest Products Laboratory from three inch cuttings taken from the ends of all 2x4's tested, rings per inch and percent summerwood on all specimens. Of course knots and slope-of-grain are also coded. The rings-per-inch, percent summerwood and specific gravity data will enable us to fine tune the visual grading system as necessary in.~lation to how the general quality of the wood substance is appraised·in the visual grading process.

Juvenile Wood in Stress Graded Lumber Today and Tomorrow

Today the prohibition on exceptionally light weight pieces in structural lumber, which dates back to the first rule proposed by the Forest Products Laboratory in 1934, is our only protection against juvenile wood in stress graded lumber which otherwise meets the grading rule requirements for warp and knots. hTO.";;:'W,t;l'ic.t±;ll.lS!;~P;t;l.q,n,!lcl"'y light 7f weight pieces, SPIB l;l.lI1its.stress gra ng··'f6:.·ciiiffY'lumberwhich·contains .­a minimUlllof;f1:~teenpe·rCent late wood, but this by no means eliminates juvenile wQod from..the .. p .. roce .. s .. ~ It is fairlY' well documented that a 7:­percent late.wood requiZ;~1l!ent is more precise. in limiting wood for specific gravity than rings-per-inch alone, however. .

When the results of the In-grade program is implemented, we will have substantial data on how effective these visual methods for sorting density are on the resource sampled. We can compare its effectiveness in slow growth verses that in fast growth. Hopefully, we Can conclude that visual appraisal continues to be workable, whether in our present form or with improvements suggested by the research.

To the extent that it is inefficient, recommend design values for visual graded lumber will probablY compensate with conservatism. However, there are several mitigating factors which may prevent catastrophic change in visual grading procedures. These include:

l} the masking effect which full-sized lumber characteristics have Qn sources Qf variation in quality Qf clear WQod. The moisture content effect is a notable example of this; it is far greater in clear wood than full-sized lumber.

2) The development of system design procedures based on In-grade test data. The new design procedures will provide for more recognition of load sharing than is presently made in light frame systems.

3) Knots, warp and Wane. Some recovery figures from a few preliminary studies of plantation grown pine have indicated large percentages of this lumber is of low grade by the time it hits the grading station due to warp and large knots, and is thus eliminated from current stress grades.

4):liachine stress rated inplant quality control development over the last decade along with research on proof loading techniques for quality control have lead to a possible feaSibility of low cost proof lo·ading the statistical control of visual grading operations.

In the future, we expect greater volume of plantation gr~wn wood to be converted into lumber. It will be important to developsilvi~ultural practices which take into account quality of the fiber being produced as well as quantity.

As industry standards developers, rules-writing agencies are responsive to the needs of industries to maintain a competitive, realiable building material in which architects and engineers continue to have confidence. Continuing Joint research programs, commun1Cation among researchers and between research and industry are necessarY to correctly approach the issue and,deal with it •. we;have'"_%dou~Itat::1~~~!g~1;:t~~t~"Changes/ . wii~~~1[t~~=4~ .. n ... ~~'",~e~~J;4)\!lWJ!';,¢~1!JJ-'J,g,"1fftfi,3\ivenf:le :> ¥: W'o .' - ro~~tu.._" -';. . _ ' ere

~ -,---_ .. -,.--,.- .

For one th1ng,·~ major refinement of the kiln drying process to economically reduce unnecessary warp and other drying degrades is needed. Better sawmill techniques, new grades and new silvicultural practices based on quality of the end product will have to be developed and im­plemented sooner or later •.

One ~ield of new technology which may have a profound impact on the future development of juvenile wood in plantation stock may be genetic engineering. It has been suggested in the literature that the development of juvenile wood at various ages and in various intensities may be heritable. If this is the case, a genetic approach to coaxing the resource into switching from juvenile wood to mature wood at an earlier age could have. profound implications on the future utility value of w.ood fiber for all end uses. . }

, , • • • , f

COMMITTEE USE ONLY

SOUTHERNj)INE INSPECTION BUREAU

TECHNICAL COMMITTEE MEETING BOOK

HOLlDAYINN NAVARRE BEACH, FLORIDA

JULY 13,2001

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• • • • • • • • I I

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provide guidance on whether the differences are acceptable. The information obtained will be used by the ALSC Board of Review to determine the need for changes in policy.

Mr. Dick Enloe inquired as to the fire rating of finger jointed lumber. Lisa commented that at the present time, the wording in the building codes states that end-jointed lumber may be used interchangeably with solid sawn. Mr. Walter Boyles injected that the Forest Products Laboratory is in the process of testing glulams for fire rating.

Monitoring Modulus of Elasticity of Southern

Pine

Ms. Lisa Johnson gave an overview of the Resource Monitoring Program for 2000. As requested by the Technical Committee last year, No.2 Prime was not excluded from the sampling. The information presented 'showed that the MOE remains above the In-Grade Testing results. Mr. Brodie asked what work has been done on evaluating the appropriateness of the current trigger point. Mrs. Johnson referenced the FPL paper by Dave Kretschman discussing trigger points and the changes in MOR with changes in MOE. This ite . s a to ic for committee consideration.

Small-Log Volume Overview

A presentation by Mr. Jim Loy reviewed the impact of small logs on lumber products. Much of this material has a high percentage of juvenile wood. Juvenile wood may have different properties from mature wood. New equipment that allows recovery oflumber from small diameter logs has allowed not only logs with a small diameter at the base to be processed but have allowed recovery from the tops of trees. These tops have the same percentage of juvenile wood as young trees. A lengthy discussion evolved on the viability of SYP products from this technology. Impacts on treating, stability, and density were brought up. Motion: The committee recommends that the Board of Governors consider the viability of the short rotation plantation log resource (including thinnings) as it relates to both marketability and the design properties of southern pine dimension lumber. (Lavoyd Hudson, Furman Brodie seconded) The motion

~ carried •

----------~ ASTM-Update 1/

The ASTM standard for mechanically graded lumber received final approval on June 10, 2000. The new standard will be published in the 2001 Book of Standards however it should be available as a separate document in September 2000. The designation for this new standard is ASTM D-6570.

PERMISSION TO RE~H . .LNT l:d"llil'lJ..l'.i1J .L>..L, ..

WESTERN MILLS TODAY

Western Mills Today March, 1991 Page 3

Properties of Juvenile Wood Studied at FP Laboratory Juvenile wood is the wood a tree

lays down in its first 5 to 20 years of growth, which has different charac­teristics than normal or mature wood. In conifers, it has lower spe­cific gravity, shortertracheids, larger fibril angle, lower transverse shrinkage, higher longitudinal shrinkage, lower strength, lower percentageoflatewood, more com­pression wood, thinner celI walls, larger lumen diameters, and lower cellulose but higher lignin content.

Within the juvenile wood core, these properties are not uniform from the pith outward. Rather, the wood in the first few rings from the pith has the most extreme differ­ences (for example, lowest specific gravity), but the characteristics of laterccllsgradual1yimproveduring

t;

a "transition" period until normal or mature wood is produced. Tree spe­cies vary in how many annual rings of juvenile wood are created before the mature wood appears.

AlI trees have juvenile wood, but it had little significance when the timber supply was primarily old­growth trees grown in natural forest conditions. On such trees, the juve­nile wood core was small because early growth was suppressed by competition from surrounding trees, In addition, the percentage of juve­nile wood in the total volume was small because trees grew to a very large diameter before they were har­vested. Now, Improved trees grown on intensively managed plantations reach sawtimber size and are har­vested at a young age. Because di-

ameter growth is generally fastest during the years juvenile wood is produced, the juvenile wood core may be a very significant part ofthe harvest.

The paper industry has adapted to the increasing proportion of juve­nile wood in their raw material by blending it with mature wood of other trees or species and/or by improved pulping technology. Some properties of paper are actually im­proved with juvenile wood.

1 For most solid wood products,

juvenile wood. is inferior to mature wood. The lower strength and stiff· ness and the higher shrinkage in the lengthwise direction are the princi-pal problems. The higher shrinkage can result in excessive wa"fp in lumber, especially when a piece has

juvenile wood on one side and nor­mal wood on the other. Research is demonstrating that warp can be controlled within acceptable limits by sawing and drying techniques such as the saw,dry and rip process.

Juvenile wood's effect on the ul­timate strength of dimension lum­ber continues to be of concern. Re­cent research shows that dimension lumber cut from the juvenile wood core may have only 50 to 70 percent

f the strength and stiffness of lum­'er cut from mature wood, depend­

iing on the grade and species. The 'ationalln-GradeTesting Program

measured the actual strength and stiffuess of lumber currently on the market. These results are helping lumber standards groups modify design stresses to account for the

WESTERN MILLS TODAY Vol. 3 No.2 March, 1991

President and Publisher John L. Nederlee Vice President Shirley Nederlee Editor Dennis Sluhaug Graphic Production Joanne Branch Sales John Nederlee

EDITORIAUADVERTISING OFFICE P.O. 80x 610 Edmonds, WA 9802()'0610

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POSTMASTER: Pleasasond changes I:) TImbefM'tsl. P.O. 80:1610, Edmcm!s, Washlngltn, 90020-0610.

changing timber resource. However, astheindustryharvestsmoreyoung, fast-growth, plantation-grown trees with high proportions of juvenile wood,allowabledesignstressesmay eed to be modified further.

Current research is focusing on evaluating the strength and stiff­ness oflumber cut from fast-growth loblolly pine plantations. The influ­ence of varying amounts of juvenile wood on the dimensional stability and mechanical properties of lami­nated veneer lumber processed from fast-growth Douglas fir and south­ern pine lumber is also being evalu­ated.

\

For more information, contact Al Bendtsen, Project Leader; Forest Products Laboratory; telephone (608) 231-9200.

pi

in members subjected to bending, grading rules therefore restrict shake most closely in those parts, of a bending mem­ber where shear stresses are highest. In members with limited cross grain, which are subjected only to tension or compres­sion, shake does not affect strengtb greatly. Shake may be limited in a grade because of appearance and because it permits entrance of moisture, which results in decay,

<: Stren is related to the mass per unit volume (density) of clear wood. Properties assigned to lumber are sometimes modified by using the rate of growtb and percentage of late­wood as measures of density. Typically, selection for density requires that the rings per unit lengtb and the percentage of latewood be within a specified range. It is possible to elimi­nate some very low-strength piecllS from a grade by exclud­ing those that are exceptionally low in density . • Decay Decay in most forms should be prohibited or severely re­stricted in stress grades because the extent of decay is difficult to determine and its effect on strength is often greater than visual observation would indicate. Decay of the pocket type (for example, Fornes pin<) can be permitted to some extent in stress grades, as can decay that occurs in knots but does not extend into the surrounding wood,

Heartwood and Sapwood Heartwood does not need to be taken into account in stress grading because heartwood and sapwood have been assumed to have equal mechanical properties. However, heartwood is sometimes specified in a visual grade because the heartwood of some species is more resistant to decay than is the sap­wood; heartwood may be required if untreated wood will be exposed to a decay hazard. On the other hand, sapwood takes preservative treatment more readily than heartwood and it is preferable for lumber that will be treated with preservatives.

Pitch Pockets Pitch pockets ordinarily have so little effect on structural lumber that they can be disregarded in stress grading if they are small and limited in number. The presence of a large number of pitch pockets, however, may indicate shake or weakness of bond between armual rings.

Wane Wane refers to bark or lack of wood on the edge or comer of a piece oflumber, regardless of cause (except eased edges), Requirements of appearance, fabrication, or ample bearing or nailing surfaces generally impose stricter limitations on wane than does strength, Wane is therefore limited in structural lumber on those bases.

Procedures for Deriving Design Properties The mechanical properties of visually graded lumber may be established by (a) tests ofa representative sample of full-size

members (ASTM Dl990 in-grade testing procedure) or (b) appropriate modification oftest results conducted on small clear specimens (ASTM D245 procedure for small clear wood), Design properties for the major commercial softwood dimension lumber species given in current design specification and codes in the United States have been de­rived from full-size member test results, However, design properties for most hardwood dimension and structural tim­bers (larger than standard 89-mm- (nominaI4-in,-, actual 3-1I2-in.-) thick "timbers") of all species are still derived using results of tests on small clear samples.

Procedure for Small Clear Wood The derivation of mechanical properties of visually graded lumber was historically based on clear wood properties with appropriate modifications for the lumber characteristics al­lowed by visual sorting criteria. Sorting criteria that influ­ence mechanical properties are handled with "strength ratios" for the strength properties and with "quality factors" for the modulus of elasticity.

From piece to piece, there is variation in both the clear wood properties and the occurrence of growth characteristics, The influence of this variability on lumber properties is handled differently for strengtb properties than for modulus of elasticity,

Strength Properties--Each strengtb property of a piece of lumber is derived from the product of the clear wood strength for the species and the limiting strengtb ratio. The strength ratio is the hypothetical ratio of the strengtb of a piece of lumber with visible strength-reducing growth characteristics to its strengtb if those characteristics were absent. The true strengtb ratio of a piece of lumber is never known and must be estimated, Therefore, the strength ratio assigned to a growth characteristic serves as a predictor of lumber strengtb. Strength ratio is expressed as a percentage, ranging from o to 100.

Estimated strength ratios for cross grain and density have been obtained empirically; strength ratios for other growth characteristics have been derived theoretically, For example, to account for the weakening effect of knots, the assumption is made that the knot is effectively a hole through the piece, reducing the cross section, as shown in Figure 6-2. For a beam containing an edge knot, the bending strengtb ratio can be idealized as the ratio of the bending moment that can be resisted by a beam with a reduced cross section to that of a beam with a full cross section:

where SR is strength ratio, k knot size, and h width of face containing the knot. This is the basic expression for the effect of a knot at the edge of the vertical face ofa beam that is deflected vertically, Figure 6-3 shows how strengtb ratio changes with knot size according to the formula.

S-I 133

T

f[5)rE © ~ il WI ~D lfll DEC 2 1 2011 IV TDS JHM FILE _______ I RR TW JW JJ

• P. O. BOX 1877 • 1870) 862-3414 • El DORADO, AR 71730

Via Email and FedEx

December 20, 2011

R. B. Parrish, Chairman

T. D. Searles, President

and

Members of the Board of Review,

American Lumber Standard Committee, Incorporated

Re: Proposed Reduction of Southern Pine Lumber Design Values

Dear Mr. Chairman and Members:

AUBRA ANTHONY, JR. President and CEO Fax (870) 863-0809

E~mail: aanthony@anlhonyforest.com

I write respectfully to urge the American lumber Standard Committee Board of Review IALSCj to

step back from the latest deadline on January 5,2012 to make any final decisions about the proposed

reduction of design values of southern pine lumber. This is the same request I made in futility to the

Southern Pine Inspection Bureau (SPIB) Board of Governors on August 24, 2011 (a copy of which letter is

enclosed for the record).

Sadly, my fears about the consequences of the compulsive process at SPIB have become true. The

eventual leak of the proposed overnight reduction of design values of product already in commerce produced

chaos in the market. The resulting industry outcry, identification of more technical compliance issues in the

SPIB test sample and selective adherence to ASTM D 1990, and concerns about due process - notice,

transparency and participation - all are a result of SPIB's haste. As Proverbs warns us, it does make waste.

In the larger North American perspective, which I take as a member of the new Softwood Lumber

. Board, we need a better process established for all lumber species being evaluated. Further self inflicted

damage to use of wood is particularly foolish in these days and times.

Anthony Forest Products was privileged to have our Kerlin Drake on SPIB's special Technical

Committee during the past year of testing. He also is a participant/task group member with the Southern

Forest Products Association's Design Value Forum created to sort through this mess and involve customers.

We are, thus, actively involved and well informed.

For the reasons articulated below, we request that the AlSC remand the proposal to the SPIB for

resolution of original sampling and analysis issues and to complete properly the planned testing of the other

five cells in the matrix, to include other grades and the wider dimensions.

ALSC Board of Review

Page 3 of 3

4. Dense Classifications:

Page 18 Section 8.0 of the SPIB Design Value Submission to ALSC dated September 2011: Dense . Classifications for Southern Pine - Since density is an integral part of the specific gravity, do not take

away from component manufacturers and stick framers the ability to purchase dense lumber grades

but while still maintaining the higher design values for dense lumber. Since visually graded lumber

will be reduced in design values by an unknown amount, please allow for the component customer

base to keep dense grades and their higher design values that accompany the grade. As SPIB pointed

out in section 8.0, "there is not enough data to justify publishing separate design values for lumber

visually graded as dense." Therefore, the answer is to wait until further testing and data is collected

before this action is taken.

5. Design Value Adoption Process:

As a former Federal practice lawyer in Washington, DC, I believe the lumber industry has to find a

smarter, more fairway to introduce potential design value reductions whereby the stakeholders

have a comment and review period before any approvals by the ALSC.

Whether or not legally required by the Administrative Procedure Act, the principles of due process

are prudently to be applied here.

Before irreparable reputational and real financial harm are caused to timber owners, manufacturers

and customers, along with everyone else, we need to step back and look into the entire process of design

value submittals and make sure the stakeholders in our industry have adequate time to review all data, a

comment period and provide for a transition time of implementation.

In the opinion of many, once Southern Pine's, or any other specie's design values are reduced in the

market place, even if later tests reveal an upward correction for the wider widths, market credibility can

never be recovered. Therefore, having the correct truth now is imperative. The industry should only make

one announcement on any design value changes for any specie after all testing has been completed for all six

cells.

This should create more confidence that we are doing the .right thing, for right reasons', for our

neighbors who live, work and play in structures made of our North American wood.

Sinc~

Aubra Anthony, Jr.

ANTHQN\( ANTHONY .... 'f', ",'" ~ CO.

0-fl "", ,,-~81' PROO.f.'

Via Email and Fed Ex

August 24, 2011

R.M. Shakelford, iii, Chairman

and Members of the Board of Governors

Southern Pine Inspection Bureau

(5)~ © [G ~ w ~Inn~\ ru DEC 2 1 2011 ~ TDS JHM FILE .. ______ .

,RR TW JW JJ="". ===~~~~=.I

• P. O. BOX 1877 • 1870) 862·3414 ,EL DORADO, AR 71730

AUBRA ANTHONY, JR. President and CEO Fax (870) 863·0809

E~mail: aanthony@anlhonyforest.com

Re: Proposed Devaluation of Southern Pine Lumber

Dear Mr. Chairman and Members:

I write respectfully to implore the Board to step back from the artificial deadline of this Friday to

make any new decisions about the reduction of design values of southern pine lumber. Proverbs

reminds us that haste maketh waste.

You need more time to consider the legitimate questions about the validity of undisclosed test

data as well as an imperfect process. In consumer protection issues, lesson No.1 is to get all the facts

straight. Postponement to bring confidence through a more transparent and inclusive process is an easy

immediate solution.

Anthony Forest was privileged to have Kerlin Drake on your special Technical Committee, and, consequently, we have inside knowledge. We did not support any immediate changes because of

questions within the data analysis, our experience with the consequences of overly·dried wood samples,

and the fear factor being used to prompt hasty action. While we voted later to support the reduction in

design values for 2x4 #2 and lower grades, we urge you not to take any precipitous action until further

technical review of the data sets and analyses.

Moreover, no one has been able to explain to me why, if the forest resources have so

dramatically changed, mathematical models built on correlations in a historic resource base are still

valid to apply to all grades and widths.

Please remember that a 2.1 safety factor is already built into structural wood member deSign.

There is no life or safety emergency. Therefore, there is no need for a panicked process driven,

appa rently, by fear of some possible liability risk.

Otherwise, on the other edge of the negligence and liability sword, precipitous action can be

characterized as reckless disregard of the information and analysis problems which have been called to

your attention. Before irreparable reputational and real financial harm are caused to timber owners,

manufacturers and customers, there is a high duty of care to your subscribers, along with everyone else,

to be sure you are not standing on this data regarding 2x4's, or questionable "extrapolations" to other

SPIB Board of Governors Page 2

widths unsupported by additional test data as recommended by the Technical Committee. I do not use

the term "gross negligence" flippantly.

My alarm and motivation are based upon my legal experience and are grounded in the lessons learned while I was honored to be a leader of our North American industry. There are right ways and

wrong ways to deal with potentially negative issues such as are before all of us. Experienced counsel has been identified though the American Forest and Paper Association, and additional advice should

prudently be solicited" on the front end.

In the opinion of many, once Southern Pine is devalued In the market place, even If later tests

reveal an upward correction for the wider widths, market credibility can never be recovered. Therefore,

having the correct truth now is imperative.

Beyond Southern Pine alone, I fear unintended negative consequences for the competitive

promotion of all lumber building products by the new Softwood Lumber Board. Already a challenge in

today's economic climate, wrong bad news can undermine the goal of growing our markets" to the

delight of our building products competitors.

So that everyone is on the same page about the identified problems, I am enclosing the August

20 memorandum by the American Wood Council's professional observer to your process. Having been a

participant on your special Technical Committee, we have enough professional experience to concur

with the AWC's concerns, especially about the effect of low moisture and lack of explanation of the

dense lumber anomaly. We question also where the data is from the SPIB's years of the continuous

testing program. How does it compare and why?

As to best industry practices on process, and as to lessons to be learned from our recent history

of the last design value changes, we refer you to the enclosed descriptio~by Catherine Marx Kaake, P.E.

Let's go back to the thoughtful, transparent and Inclusive model.

In that vein, please think also of all of those in the industry who are not in this tight information

circle. No one should be ambushed.

One of our local trial lawyers in a very complex case once admonished the jury to "keep your

eye on the squirreL" In our present circumstances, I respectfully suggest that the squirrel is more

transparency and more information made available, as well as increased technical review. This should

create more confidence that we are doing the right thing, for right reasons, for our neighbors who live, work and play in structures made of our wood.

Enclosures

f1

Sincerel~

Aubra Anthony, Jr.

·.-.--_._-_ ....... _-_._ .• _. __ .... _--_ ... _._-------_._-

®

SOUTHERN PINE INSPECTION

BUREAU, INC.

POS" OP"Ic.: UOX 10915 • P.:~SAC()I.A •• -1. J2524 850-0,),2611 • FAX 850-IJJ-5594 • VOICE MAli. 850-432-6106

Southern Pine Producers Lumber Industry Associates:

I would like 10 address Ihe considerable misinfonllalion which has becn cireulaled regarding Soulhern Pine Inspeclion Bureau's roles and responsibililies in proposing new lumber design values for soulhern pine. SPIB plays a very limited and specific role in our induslry. We are responsible for conducting Ihe lechnical wori< for Ihe induslry which includes the settin1\ of lumber grades and their associaled design values and providing for third party quality audit programs al our subser!ber mills to ensure they are meeting Ihe published standards of Ihe vaflOUs grades. All oflhese aclivili .. , areconducled under Ihe regulalory umbrclla of the American Lumber Siandards Commillce.

SPlB was created in 1940 as a result of an antilrusl lawsuil filed by Ihe United Stat ... Department of Justice against the Soutl.em Pine Association. A consenl decree was issued to· settle the lawsuit which created an independent technical and lumber grading bureau (S!'IB) nud a separate "Irade association" (now thc Soulhern Foresl Producls Association) which would pcrforn. Ihe marketing functions for the iudustry.

As noted above, a key r ... ponsibility ofSl'1B is to monitor Iwnber grades and strength properties. In-grade testing of filII-sized southern pine lumber WaS initiated in the late 1970's to establish the global design values published in the 1991 and 2002 Standard Grading Rules for Southern Pine Lumber. Global design values for a lumber species are applicable to all of the population ofa given lumber grade regardless of where in Ihe growing region the lumber originates. By Iheir very nature, global design values must be conservative to protect consumers due to Ihe highly variable nature of wood.

Indusuy professionals nnd scientisL. from tlw USDA FOfCSll'rodueL' Laboratory took a consensus approach 10 creating ASTM Standard 01990 which governed the tesling and analysis of in-grade d.... The proCedUfCS were explicil as to how lumbersamples of all species were to be collecled,tested and the dam evaluated. ASTM 01990 also required Ihal properties be reevaluated if there was suflieiem reuson to believe Ihat a significant global change in lumber property values had occurred.

We were made aware of concerns during the summer of 2010 thai published design values for visually graded lumber migln not be aecurate. If true, visually graded southern pine lumber could be "weaker" than expected, and serious perfonnanee issues could result. II is paramount thai published strength properties for visually-graded southern pine bc reliable for Ihe design and construction of homes, apartments, hOlels and schools.

The SPIB Board of Governors instracted the technical staff to initiale random lesting to eSlablish whelher or not a substantive change had occurred and propose neIV design values if lumber property value changcs were evident. 11,e SPIB testing procedures were approved by

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the USDA Forest Produels Labor,nory which has uhimate oversight in Ihe testing of samples aud tl.e analysis of dat •. Test samples were taken from mills in all regions as directed by FPL. Testing was condueled over several months by S!'IB aud Timber Products Inspection. The collected dala were analyzed by SPIB staff as prescribed by ASTM 01990 and Ihe USI)A Forest Products Laboratory's approved lest protocol. 2x4 #2 common soulhern pine lumber was tested initially to measure property changes across Ihe Soulh. The 2x4 data suggested d.at sj~nifieant property changes (as much as 30% lower) had occurred over tllne, .~d it was highly likely that subslnntial property changes would be found on the rcmaining tcsl cells (2x4 #2 was one of the original six test cells). 11.e property changes were so large, in facl, Ihat modifications to the gl"'c:lding rules were deemed insufficient to overcome the m:C'dosurcd decline in strength. The Board instrueled staff to propare new dcsign values based on Ihe empirical dam and malhemalical extrapolalions of the data based on ... tablished and recognized computalional processc.' SCI fom, in D 1990 as quickly as possible to preven! the misapplication of lumber.

The proposed design values were submitted 10 ALSC wilh a recommendation for adoption. ThcALSC Ihen forwarded the data to the USDA Forc..I!'roducts Laboralory for verification of sampling procedures and lesl resuhs. FPL acknowledged 10 ALSC in wriling that the teSling and analyses were done 8.' prescribed.

Questions huvc been rclised about timing, cOl1l1Jlcrcial concerns, and lranspareney. Some key points to consider:

•

SI'IB wrote a leiter 10 our subscribers and various lumber organizalions and published a notice on our web site in the summer of 20 10 stating d181 we were testing lumber, and Ihat designers and builders consider using machine stress rated lumber or be very conservalive in engineering designs while lumber lesting was ongoing.

SPlB's rolc is strictly Icclmic_1 in nalure. The initial testing indica led substanli_1 reduelions in lumber propenies had occurred, and SPIB w·.s ubligaled to propose new and reliable design values as quickly as possible. While commercial impacls from rapid deployment of new values are real, Ihe "data are the data". I'erformance failure risks which mighl occur during" pha..ed-in approach arc for others to evaluate and accepl.

Commercial impacts are outside Ihe scope ofS!'IB. Thc eonsen! decree of 1940 clearly staled that marketing and commereial considerations were not a responsibilicy of the independent, lesting bureau. In facl, those activities arc prohibited.

Detennining the reasons that the changes occurred will require substantial sJUdy. They did nol occur overnight, and they arc the likely result of a number of faelors. It is important thaI we understand the root causes, but the immediate resl,onse was 10 provide reliable lumber properties.

SPIB rccommends thai our subscribers aud euslomers allow Ihe ALSC proc .... 10 work as prescribed. We necd reliable d ... ign values published for propor engineering design and perfonnance. We hope you will help us do thaI.

Jim

Jallles E. Loy

Pre.idenl

Soulhcrn !'ine Inspection Bureau

FAX: 800-524-4982