Federal legislation has recently been passed instituting formaldehyde requirements that will mirror much of California Air Resources Board ATCM for formaldehyde Phase 2 (http://www.pharosproject.net/index/blog/mode/detail/record/68). The proposed composite woods and agri-fiber materials requirements (conformance to Phase 2) hence will essentially provide credit for what will soon become industry standard practice and hence not constitute a leadership standard. Given growing affirmation of the potency of formaldehyde at any level of exposure and the change that the CA ACTM and the federal concurrence has generated in the industry, LEED 2012 is an opportunity to reward the manufacturers that are leading rather than just give easy credits for legal conformance. The credits should reward avoidance of formaldehyde (California NAF) and/or compliance with California ULEF or broader scope VOC emissions testing should be rewarded not just meeting Phase 2 legal requirements.
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Randal Carter
Director, Global Product Safety and ComplianceSteelcase Inc.
91 thumbs up
January 11, 2011 - 8:48 am
Thanks Tom, you are right, the California composite wood formaldehyde emissions limits are in the process of adoption as a U.S. federal requirement. Please note the old composite wood credit, which provided a point for composite wood emissions compliance alone, has been eliminated in this proposal for everything except built-in cabinetry, architectural woodwork, and composite wood flooring, which effectively makes composite wood compliance to the pending federal requirements a pre-requisite when the law is completed.
Everyone involved with drafting the proposed credit agreed full VOC emissions testing for cabinets and woodwork would be best. Unfortunately there are two reasons that built-in cabinetry and architectural woodwork is not subject to full VOC emissions testing requirements in the proposed credit. #1. We need an exposure scenario with defined loading of cabinets (or woodwork) and airflow for each scenario (e.g., residential, classroom, commercial office) in order to translate test chamber measurements to a standard environment condition that is linked to actual buildings. #2. Many built-in cabinets are custom built on site, and therefore do not lend themselves to assembled cabinet testing in chamber very well. The FAQ document available under the Birds Eye View tab on this page also addresses this question.
Composite wood flooring was apparently a late addition to the proposal, which is inconsistent with the above problems (#1 and #2) as all flooring materials are subject to the full VOC emissions testing requirements.
Issues #1 and #2 are clear standard development needs that must be addressed before we can appropriately require full VOC emissions testing from built-in cabinets and architectural woodwork.