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NC-v4 EQc2:Low emitting materials

NAUF in Low Emitting Calculator for Comp Wood

Given all the discussion and confusion about composite wood certification issues, why does the version 3 Low Emitting Materials Calculator include NAUF in the pull down for compliant composite wood products?

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Mon, 11/07/2016 - 18:28

For v3, NAUF is the requirement. For v4, NAUF is one of the options in the CARB referenced standard.

Mon, 11/07/2016 - 19:33

Hi Michelle, My confusion continues. NAUF is not a certification of any kind. It's simply a statement that no urea formaldehyde was added to the manufacturing process. NAUF is not commensurate with NAF or ULEF. How can NAUF be a v4 compliant option against general emissions requirements? If somehow it is, please confirm what backup documentation is required to demonstrate NAUF compliance for LEED v4.
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Jason Grant
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Jason Grant Consulting
LEEDuser Expert
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Mon, 11/07/2016 - 20:09

Michelle R. is right, NAUF is not referenced in the CARB standard. CARB provides special provisions for manufacturers of composite wood products that use no-added formaldehyde (NAF) or ultra-low-emitting formaldehyde resins (ULEF) resins. NAF-based resins are resins formulated with no added formaldehyde as part of the resin cross-linking structure. ULEF resins are formaldehyde-containing resins formulated such that the formaldehyde emissions from composite wood products are consistently below applicable Phase 2 emission standards. Manufacturers who demonstrate the use of NAF resins can receive an exemption from CARB formaldehyde testing and other requirements, and such manufacturers are “CARB exempt.” Manufacturers who use ULEF resins can apply for approval to have their products tested less frequently or for an exemption.

Mon, 11/07/2016 - 21:05

Thanks Jason. I see my second response didn't post. For your reading pleasure: https://www.arb.ca.gov/regact/2007/compwood07/fro-final.pdf Paula Melton's excellent Oct 2016 EBN VOC issue https://www.buildinggreen.com/downloads
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Allison Zuchman
Senior Sustainability Consultant
The Green Engineer
LEEDuser Basic Member
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Tue, 11/08/2016 - 13:56

For clarification, it would seem from Michelle Halle Stern's comments above (and the USGBC calculator) that either NAUF or ULEF/NAF (CARB) products are acceptable for LEEDv4. Is this correct? That means v3 compliant composite materials (NAUF) are also acceptable in v4? That was not my original understanding. Am I missing something? Thanks.

Tue, 11/08/2016 - 15:02

Not exactly. The v3 requirement is NAUF (urea-formaldehyde). The v4 option is NAF (no added formaldehyde of any type).
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Allison Zuchman
Senior Sustainability Consultant
The Green Engineer
LEEDuser Basic Member
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Tue, 11/08/2016 - 15:18

That would mean not all NAUF products necessarily meet NAF requirements (if the NAUF products have other types of formaldehyde)? If so, the NAUF option on the USGBC calculator is confusing. Upon further research, it would appear the not all NAUF products will meet CARB/ULEF requirements either. From the Building Green Website: "No-added-urea-formaldehyde (NAUF) products that meet testing requirements are now designated ultra-low-emitting (ULEF) by the California Air Resources Board (CARB) if they have emissions of 0.05 parts per million or lower."
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Allison Zuchman
Senior Sustainability Consultant
The Green Engineer
LEEDuser Basic Member
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Tue, 11/08/2016 - 15:32

And for clarity, the options for composite wood evaluation on the USGBC calculator are ULEF, NAUF, salvaged or reused, or does not meet criteria. The first three all comply. Is that a typo? Should NAUF be NAF?
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Dawn Garcia
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Roseburg Forest Products
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Tue, 11/08/2016 - 17:10

Commenting on Michelle Halle Stern's Nov. 8 note...for composite wood (particleboard, MDF or hardwood plywood) to meet the LEED v4 Low-Emitting Materials requirements, the products must be documented to meet the CARB ATCM for ULEF resins OR NAF resins. LEED v4 does not require all products to be no added formaldehyde. A list of approved manufacturers is available on CARB's website at https://www.arb.ca.gov/toxics/compwood/naf_ulef/listofnaf_ulef.htm

Tue, 11/08/2016 - 19:15

Thanks. Dawn is correct. I didn't intend to imply that NAF was the only option. I reviewed the calculator, the reference guide, and the CARB reference standard. First, keep in mind that the composite wood evaluation is only for products that do not fit into the other categories (floors, walls, ceilings, etc.) In my opinion the calculator drop down should be changed to read NAF rather than NAUF. I concur with you Allison, that v3 NAUF products should not be assumed to comply with v4.

Tue, 11/08/2016 - 19:33

Thanks all in the thread. So this is where I'm left. Composite wood products as defined by LEED v4 are only those products that CARB actually regulates. That means only the ones that Dawn has listed above - particleboard, MDF and hardwood plywood. Other formerly composite wood items like softwood plywood, OSB, LVLs, engineered flooring, engineered wall panels, etc. that was previously included in this category in v3 with the NAUF requirement is now exempt from this requirement entirely. This is analogous to unfinished solid wood flooring being exempt from the previous EQ4.3 Flooring System credit in v3. So we will only pursue low emitting compliance for v4 with those three composite wood products and assume that means compliance with the composite wood category in the Low Emitting credit. Further the requirement is that this subset of composite wood meet ULEF (which just happens to be confirmed by the testing protocol that is also used for NAF though NAF is not required.) And finally I can only assume the NAUF that's in the current version of the v4 calculator is an error. That the intent was actually NAF which though not required might also demonstrate compliance with the appropriate emissions protocol. Hopefully, we'll see some clarification on this from the USGBC soon.
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Craig Graber
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Atelier Ten
LEEDuser Premium Member
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Tue, 11/08/2016 - 19:52

Oh and one more thing... off site laminating adhesives used with composite wood assemblies are no longer covered either under v4.

Tue, 11/08/2016 - 20:58

Other products are not exempt. The only things that are exempt are inherently non-emitting materials (i.e. untreated wood flooring) and items outside the weatherproofing of the building. Most wood products need to follow the General Emissions Evaluation because they fall into the Category: Flooring, Ceilings/Walls/Thermal and Acoustic Insulation, or Furniture. In your example engineered flooring is Flooring, engineered wall panels are Walls. LVLs beams are ceilings. The Composite Wood Evaluation is designed to cover HW plywood, MDF, and particle board that don't fall under other categories. Products that don't fit into one of these buckets are simply non-compliant. True, offsite adhesives are not covered independently. However any product that needs to undergo the General Emissions Evaluation tests the product as a whole, thus covering whatever adhesives are embedded.

Tue, 11/08/2016 - 21:16

Hi Michelle, I understand your comment, thanks. But please note I am referring specifically to compliance with the Composite Wood category of the Low Emitting credit. If as a strategy, we are not pursuing compliance in the Flooring or Ceilings/Walls/Insulation categories, then we don't need to comply with the General Emissions requirements for the engineered flooring or the engineered wall panels to comply with the Composite Wood category.

Tue, 11/08/2016 - 21:53

Yes, you could comply for the composite wood category for composite wood products that don't fit into other categories.
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Allison Zuchman
Senior Sustainability Consultant
The Green Engineer
LEEDuser Basic Member
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Fri, 11/11/2016 - 15:10

And an update. I sent my assumptions to the USGBC for confirmation and received a different answer. "Your question is whether NAUF-compliant composite wood can contribute to this credit. Yes, these products are acceptable, and the Low-Emitting Materials calculator is correct. Page 659 of the LEED v4 Reference Guide provides the following guidance: "…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." This means products ULEF, NAUF, or NAF could contribute, assuming they otherwise comply with the credit requirements." I am going to write back for explanation. The NAUF option does not make sense to me, and if NAF is not an option on the calculator how do I choose that if I want to? To be continued.
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Allison Zuchman
Senior Sustainability Consultant
The Green Engineer
LEEDuser Basic Member
12 thumbs up

Thu, 11/17/2016 - 20:58

The GBCI updated their response as follows: The Low-Emitting Materials Calculator is incorrectly stating NAUF rather than NAF in the dropdowns for composite wood. Manufacturer statements of NAUF are no longer acceptable. We are working to get this corrected in the next round of calculator fixes. For now, you can select NAUF, but supporting documentation must demonstrate compliance with the Rating System requirements which are NAF or ULEF, and you can explain this in the "special circumstances" section of the credit form. Thanks for everyone's help solving this question!
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Erin Holdenried
Sustainable Design Director
Bell Architects
LEEDuser Premium Member
40 thumbs up

Wed, 10/25/2017 - 18:49

Glad to see I am not the only one confused by the composite wood testing requirements . . . . Are CARB EXEMPT plywood, particleboard, or MDF products acceptable? California Air Resources Board (CARB) exempt (NAF/ULEF) products that have no added formaldehyde (NAF) and/or ultra-low emitting formaldehyde (ULEF)? And is a simple statement by the manufacturer of no added formaldehyde (NAF) acceptable?
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Dawn Garcia
Marketing Communications
Roseburg Forest Products
LEEDuser Premium Member
14 thumbs up

Wed, 10/25/2017 - 19:08

In response to Michelle Rosenberger's 11/8/16 2:33 comment in this thread, there is now a LEED Interpretation related to structural wood products and Low-Emitting Materials - https://www.usgbc.org/leedaddenda/10466

Wed, 10/03/2018 - 15:29

The Low Emitting calculator from the credit resources page for this credit still lists NAUF in the dropdown options...two years after Allison got the above response (Nov 17, 2016) from GBCI stating that this was an error on the form. Am I to believe USGBC has gone 2 whole years without addressing this issue? Or is that response from GBCI incorrect?

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