In the IEQ: Low-Emitting Materials credit, under the heading Emissions and Content Requirements, section on General emissions evaluation, it says that “building products must be tested and determined compliant in accordance with CDPH Standard Method c1.1-2010, etc.”

Then in the section on Composite Wood Evaluation, it says that “composite wood... must be documented to have low formaldehyde emissions that meet the CARB ACTM for formaldehyde requirements for ULEF resins or no added formaldehyde resins.”

Question: If you have an engineered wood flooring product containing composite wood (e.g. w/ a plywood platform), in order to comply with the requirements of this credit, does the product need to undergo both evaluations, or does it only need to comply with the second one?

Comment & Related Question: The part of the CARB regulation that relates to ULEF and NAF resins doesn’t stipulate any limit to formaldehyde emissions. Rather, manufacturers that use these resins can be designated “CARB exempt” if they pass several tests that meet the CARB 2 emissions limits (there’s a table in the regulation that lays out the ppm limits for different categories of composite wood products). CARB exempt manufacturers don’t need to be audited and certified on an ongoing, annual basis. Both CARB exempt manufacturers and those that don’t use ULEF/NAF resins — but have been audited and are certified — can invoice their products as “CARB compliant.” This is the documentation that one uses to verify that a product meets CARB 2 formaldehyde emissions limits.

The question is whether compliant products are those that meet CARB 2 limits (in which case USGBC screwed this up pretty badly) or whether compliant products are only those that come from CARB exempt manufacturers (in which case USGBC still screwed up since this eliminates many, many manufacturers who are not using ULEF/NAF resins but whose formaldehyde emissions still meet CARB 2 — the most stringent formaldehyde regulation in the world).

As an aside, I am inquiring on behalf of a large flooring distributor/importer that regularly tests samples of products for formaldehyde emissions, and they have found that some products that use ULEF/NAF resins have higher emissions than those that don’t. They think this is because the former are made using cold-press methods, and the latter use hot-press methods that cause the release of the natural formaldehyde contained in the wood or bamboo itself.