New Rules for Formaldehyde in IEQc4.4
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.