New Rules for Formaldehyde in IEQc4.4

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Products and materials specialist BuildingGreen Feb 21 2013 LEEDuser Expert
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Editor's Update: As expected, LEED InterpretationLEED Interpretations are official answers to technical inquiries about implementing LEED on a project. They help people understand how their projects can meet LEED requirements and provide clarity on existing options. LEED Interpretations are to be used by any project certifying under an applicable rating system. All project teams are required to adhere to all LEED Interpretations posted before their registration date. This also applies to other addenda. Adherence to rulings posted after a project registers is optional, but strongly encouraged. LEED Interpretations are published in a searchable database at usgbc.org. #10250 was revisited by USGBC in its 4/1/13 release. The following language was added: "This ruling is intended to clarify how to address melamine, not prematurely adopt the LEED v4 credit language for composite woodComposite wood consists of wood or plant particles or fibers bonded by a synthetic resin or binder. Examples include particleboard, medium-density fiberboard (MDF), plywood, oriented-strand board (OSB), wheatboard, and strawboard.. Therefore, composite wood products using other amino resins must meet the no added urea-formaldehyde1. Formaldehyde is a naturally occurring VOC found in small amounts in animals and plants but is carcinogenic and an irritant to most people when present in high concentrations, causing headaches, dizziness, mental impairment, and other symptoms. When present in the air at levels above 0.1 ppm, it can cause watery eyes; burning sensations in the eyes, nose, and throat; nausea; coughing; chest tightness; wheezing; skin rashes; and asthmatic and allergic reactions. 2. A known carcinogen with no known safe exposure level. Formaldehyde occurs naturally, but appears in unnaturally high concentra­tions in many buildings because it is an ingredient in binders used in many building materials and furnishings. requirements of LEED 2009." LEEDuser understands this update to not affect the core meaning (including the confusions) of this Interpretation.

Composite wood products made with added urea formaldehydeUrea formaldehyde is a combination of urea and formaldehyde used in some glues and adhesives, particularly in composite wood products. At room temperature, ureaformaldehyde emits formaldehyde, a toxic and possibly carcinogenic gas. (UFUrea Formaldehyde (UF), used in some types of plywood, particleboard, MDF, and laminated wood products, is a synthetic resin created by condensing urea with formaldehyde.) are one of the few products that LEED has consistently banned under its longstanding IEQc4.4: Low-emitting Materials credit. However, LEED Interpretation #10250, issued January 1, 2013 and applicable to all LEED 2009 projects, as well NC-v2.2 and other systems, now allows for the use of urea in combination with melamine formaldehyde (MF) in certain circumstances. Are these rules in conflict?

According to Sara Cederberg, a LEED manager at the U.S. Green Building Council (USGBC), the Interpretation was meant to clarify longstanding questions about the use of MF resins. Currently, products that use MF resins without any urea are allowed, per the original credit language. However, many MF-containing products have a urea component. The Interpretation addresses those products as follows: 

• Urea, when used as part of a melamine-urea-formaldehyde (MUF) resin, is allowed as long as the composite wood product meets California Air Resource Board (CARBThe California Air Resources Board, part of the state government, is charged with maintaining clean air. This agency is unique at the state level: California was the only state that had such an agency before the passage of the federal Clean Air Act, and was allowed to keep it.) Airborne Toxic Control Measure (ATCM) 93120 requirements for ultra-low-emitting formaldehyde resins (ULEF), or 0.05 parts per million—requirements that are quite strict.

• Melamine-formaldehyde resins that use urea as a “scavenger” are not allowed, even with ULEF testing showing that they meet the same emissions standard.

“The language is confusing,” says Andre Verville, research and technical director at Uniboard, maker of ULEF melamine particleboard and other composite wood products. The Interpretation states that UF acting as a scavenger is not allowed, but urea formaldehyde is not used as a scavenger, per se. Urea itself “scavenges” leftover free formaldehyde from the MF reaction and converts it into another form, which should actually reduce formaldehyde emissions from the product, he explained, when compared with MF resins that don’t use urea scavengers. Verville said that pure MF products could have up to three times the emissions of those using the scavenger.

The chemistry of these resins is complicated, and Cederberg said stakeholders’ concerns that formaldehyde could be released over time from products using urea as a scavenger—particularly in hot, humid climates—informed the current Interpretation. USGBC is reviewing the policy, however, and Cederberg said that the Interpretation could be updated in April.

Overall, it makes sense for USGBC to evolve in its position on urea formaldehyde, because rather than basing its rules on the complexities of chemistry, it could move to a performance-based policy based on actual emissions, using standards that didn’t exist when it originally adopted the no-UF rule. That’s the direction USGBC is taking with LEED v4; draft language there calls for low formaldehyde emissions, as measured by CARB ULEF standards. In the meantime, however, this change to LEED 2009 adds confusion to what has been a fairly black-and-white, easily understood requirement.

10 Comments

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Erika Duran Sustainability Consultant Dagher Engineering
May 22 2014
LEEDuser Member
2078 Thumbs Up

CARB and ECO-Certified

I have a sub that just submitted documentation for Particle board that is "Third party certified (California ARB approve TPC-1) to comply with CCR 93120.2 (CARBThe California Air Resources Board, part of the state government, is charged with maintaining clean air. This agency is unique at the state level: California was the only state that had such an agency before the passage of the federal Clean Air Act, and was allowed to keep it. Composite WoodComposite wood consists of wood or plant particles or fibers bonded by a synthetic resin or binder. Examples include particleboard, medium-density fiberboard (MDF), plywood, oriented-strand board (OSB), wheatboard, and strawboard. ATCM). Also conforms to Formaldehyde1. Formaldehyde is a naturally occurring VOC found in small amounts in animals and plants but is carcinogenic and an irritant to most people when present in high concentrations, causing headaches, dizziness, mental impairment, and other symptoms. When present in the air at levels above 0.1 ppm, it can cause watery eyes; burning sensations in the eyes, nose, and throat; nausea; coughing; chest tightness; wheezing; skin rashes; and asthmatic and allergic reactions. 2. A known carcinogen with no known safe exposure level. Formaldehyde occurs naturally, but appears in unnaturally high concentra­tions in many buildings because it is an ingredient in binders used in many building materials and furnishings. emission requirements for particleboard in ANSI A208.1-2009." It is also "Eco-Certified" - on the eco certified website it says that it will help acheive LEED credit for IEQc4.4 - all this to say that it does not contain any NAUF commentary. I think I will push back and have the sub request NAUF documentation unless I am missing something and some of the items mentioned above demonstrate compliance. Thoughts?

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Tristan Roberts LEED AP BD+C, Executive Editor – LEEDuser, BuildingGreen, Inc. May 22 2014 LEEDuser Moderator

Erika, I checked with Brent, our expert here on composite woodComposite wood consists of wood or plant particles or fibers bonded by a synthetic resin or binder. Examples include particleboard, medium-density fiberboard (MDF), plywood, oriented-strand board (OSB), wheatboard, and strawboard., and we think your instincts are right—the product may comply with LEED, but the documentation isn't enough to show it.

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Nick _ Architect, LEED AP Aug 13 2014 Guest 976 Thumbs Up

On the LEED V4 low emitting materials page, the credit language seems to have relaxed to include ULEF per the CARBThe California Air Resources Board, part of the state government, is charged with maintaining clean air. This agency is unique at the state level: California was the only state that had such an agency before the passage of the federal Clean Air Act, and was allowed to keep it. code. Can someone confirm if this language would retroactively apply to 2009 projects?

http://www.usgbc.org/node/2614095?view=language

Composite WoodComposite wood consists of wood or plant particles or fibers bonded by a synthetic resin or binder. Examples include particleboard, medium-density fiberboard (MDF), plywood, oriented-strand board (OSB), wheatboard, and strawboard. Evaluation. Composite wood, as defined by the California Air Resources Board, Airborne Toxic Measure to Reduce Formaldehyde1. Formaldehyde is a naturally occurring VOC found in small amounts in animals and plants but is carcinogenic and an irritant to most people when present in high concentrations, causing headaches, dizziness, mental impairment, and other symptoms. When present in the air at levels above 0.1 ppm, it can cause watery eyes; burning sensations in the eyes, nose, and throat; nausea; coughing; chest tightness; wheezing; skin rashes; and asthmatic and allergic reactions. 2. A known carcinogen with no known safe exposure level. Formaldehyde occurs naturally, but appears in unnaturally high concentra­tions in many buildings because it is an ingredient in binders used in many building materials and furnishings. Emissions from Composite Wood Products Regulation, must be documented to have low formaldehyde emissions that meet the California Air Resources Board ATCM for formaldehyde requirements for ultra-low-emitting formaldehyde (ULEF) resins or no added formaldehyde resins.

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emily reese Sustainability Consultant, Jacobs Oct 20 2015 LEEDuser Member 1609 Thumbs Up

Any response for Nick's question above? We just had this come through for a product on our project, too. The subcontractor is claiming it is compliant b/c it passed CARBThe California Air Resources Board, part of the state government, is charged with maintaining clean air. This agency is unique at the state level: California was the only state that had such an agency before the passage of the federal Clean Air Act, and was allowed to keep it., but we aren't convinced for a 2009 NC project.

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Nick _ Architect, LEED AP Oct 20 2015 Guest 976 Thumbs Up

Emily, I never got a response. You could try submitting a question to the USGBC, but would potentially have to wait weeks for an answer. You could also ask the contractor to submit a letter from the USGBC confirming that their product meets the 2009 NC credit requirements.

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Jennifer Preston Apr 20 2017 LEEDuser Expert 87 Thumbs Up

It would be great to get a definitive answer to this important question! Nick, Emily any updates on how it worked out to GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC).? I am seeing much conflicting info on various pieces.

The first - The precise definition of ULEF...Brent states - 0.05ppm...Another source has it at 0.09ppm... the table on page 7 of this CARBThe California Air Resources Board, part of the state government, is charged with maintaining clean air. This agency is unique at the state level: California was the only state that had such an agency before the passage of the federal Clean Air Act, and was allowed to keep it. doc: www.arb.ca.gov/regact/2007/compwood07/fro-final.pdf tells me that is depends on whether it is particle board, mdfMedium-density fiberboard (MDF): Panel product used in cabinets and furniture; generally made from wood fiber glued together with binder; similar to particleboard, but with finer texture, offering more precise finishing. Most MDF is made with formaldehyde-emitting urea-formaldehyde binder., or plywood... Is this table the definitive source that other are using?

The second - is a long struggle to find a EU cabinet manufacturer that can meet IEQ4.4....I have been working with Poliform and they appear to have figured out a complaint substrate, the IDROLEB PB panel: http://www.grupposaviola.com/wp-content/uploads/GR-06-Grezzo-IDROLEB-Rev... Has anyone else used this to LEED credit success?

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Tristan Roberts LEED AP BD+C, Executive Editor – LEEDuser BuildingGreen, Inc.
Apr 02 2013
LEEDuser Moderator

update to LI #10250

As noted above, this LEED InterpretationLEED Interpretations are official answers to technical inquiries about implementing LEED on a project. They help people understand how their projects can meet LEED requirements and provide clarity on existing options. LEED Interpretations are to be used by any project certifying under an applicable rating system. All project teams are required to adhere to all LEED Interpretations posted before their registration date. This also applies to other addenda. Adherence to rulings posted after a project registers is optional, but strongly encouraged. LEED Interpretations are published in a searchable database at usgbc.org. was updated on 4/1/13, although it doesn't appear to have changed the  core meaning of the ruling.

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Joel McCreary Principal McCreary/Snow Architects, PA
Mar 06 2013
LEEDuser Member
201 Thumbs Up

IEQc4.4

We are not pursuing IEQc4.4 for our project. However, the contractor has stated that we may be able to add it. For solid core wood doors and some products with composite woods as minor components we are receiving certifications that the wood products comply with CARBThe California Air Resources Board, part of the state government, is charged with maintaining clean air. This agency is unique at the state level: California was the only state that had such an agency before the passage of the federal Clean Air Act, and was allowed to keep it. Phase 2 standards. I've researched this a little and so farFloor-area ratio is the density of nonresidential land use, exclusive of parking, measured as the total nonresidential building floor area divided by the total buildable land area available for nonresidential structures. For example, on a site with 10,000 square feet (930 square meters) of buildable land area, an FAR of 1.0 would be 10,000 square feet (930 square meters) of building floor area. On the same site, an FAR of 1.5 would be 15,000 square feet (1395 square meters), an FAR of 2.0 would be 20,000 square feet (1860 square meters), and an FAR of 0.5 would be 5,000 square feet (465 square meters). have not found any answers.

If we do pursue the credit and this is the level compliance for products being submitted, does it comply with the IEQc4.4 requirement?

If we don't pursue the credit and these products have this level of compliance, does it affect any other credit we may be pursuing?

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Tristan Roberts LEED AP BD+C, Executive Editor – LEEDuser, BuildingGreen, Inc. Mar 06 2013 LEEDuser Moderator

Joel, we'd need more information on the resins in your products to be able to answer the first question—see Brent's breakdown above.

For your second question, not directly, but theoretically it could affect IEQc3.2, and those products will have a bearing on MRc4, MRc7, and others.

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Joel McCreary Principal, McCreary/Snow Architects, PA Mar 06 2013 LEEDuser Member 201 Thumbs Up

Thanks for the speedy response. Your first answer is what I thought and the second has been noted to the Contractor. Thanks for your help.

Joel

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