FSC assembly requirement for LEED

Hi Paul,

Sorry to be slow in responding to your post.

It is true that if a woodworker makes p-lam clad casework on FSC Mix MDF core with recycled content, then the casework does not HAVE to be manufactured as FSC certified. The recycled content materials can count toward MRc4, but not MRc7. This is straightforward enough.

Where it gets murky and absurdly complicated is if:

1) a project team is simultaneously pursuing MRc4 and MRc7, AND

2) the woodworker has FSC CoC and wants to/is able to make an FSC claim for the casework, AND

3) the woodworker is combining FSC-certified materials, recycled content materials, and FSC Mix materials that themselves are a combination of "new wood" and recycled content.

This combination of circumstances is a calculation and documentation nightmare that too many woodworkers and project teams have struggle with.

As is apparent elsewhere in this forum, there is a lot of confusion about FSC and recycled content. Many FSC Mix products have recycled content, and as you point out, FSC Mix products like MDF and particleboard may in fact be 100% recycled content (pre- and post-consumer) and still carry an FSC Mix rather than an FSC Recycled claim (FSC considers the sawmill by-products typically used in the production of these materials as "virgin fiber" rather than pre-consumer recycled content). To make matters worse, the nature of FSC's credit system is such that the actual proportions of recycled content vs. virgin fiber in any given product is impossible to calculate: the best a manufacturer can do is report historical averages.

All this argues for the clarification and simplification of the LEED requirements for FSC vs. recycled content wood products. My opinion is that the LEED requirement that only NEW wood count toward MRc7 should be revised. If a product with recycled content is invoiced as FSC Mix (credit or %) and the project team wishes to pursue the MRc7 point, then the appropriate dollar value should apply to MRc7 period and no further attempts should be made to parse recycled vs. virgin content. Where a product is FSC Mix and also has recycled content and the project team wishes to apply it to MRc4, then they can take the recycled content value and ignore the FSC claim. Project teams that are pursuing both MRc4 and MRc7 should have to choose which credit an FSC Mix w/ recycled content product will count toward; they should NOT be allowed to double-dip and have the same product apply to both credits as I believe they are currently able to do (not sure on this).

Of course, products that are invoiced as FSC Recycled (Mix or %) should only count toward MRc4, as is currently the case.

A revision along these lines is all the more important given that under LEED v4 FSC-certified wood and recycled content are rewarded under the same credit. Confusion and double-counting will persist until and unless this is cleared up.

Hi Jason,
Though project teams have to choose now between MR4 and MR7 claims because double dipping is in fact precluded, I agree with most of your comments and the overall complexity of documenting this credit. And I agree with Paul's point, FSC MDF is only new wood by policy. So if you're not making that new wood claim with your product, there is no reason to pay the FSC premium and it seems the wood cost would be excluded from your MR7 calc.

We are finding the casework/millwork sub needs to have a CoC to be particularly onerous for small shops who can't afford separate manufacturing lines. If you have a CI project, you likely can't get MR7 without the casework being FSC. We fear this favors large businesses to the detriment of our projects.

I couldn't agree more that this credit's documentation requirements need to be re-evaluated. We are at the point of advising against pursuit of MR7 in the Pacific Northwest where there is ample supply but too much brain damage in trying to achieve the credit. It is always unfortunate when the LEED requirements for documentation actually dissuade someone from pursuing the activity.

I'm with you on all this, Michelle. My hope is that, in revisiting the FSC-certified wood requirements for the LEED v4 reference guide, USGBC will go back to making FSC CoC optional rather than a requirement for casework/millwork subs. If this is the case, and architectural woodworkers opt for FSC CoC and are able to produce FSC-certified casework/millwork packages per FSC requirements, then they would have the benefit of including the costs of their off-site labor in their invoice. If the do not opt for FSC CoC or if there are some components of the millwork package that do not meet FSC requirements for "eligible inputs," then they could use vendor invoices to document the cost/value of FSC materials.