I have a project looking to get LEED credit for kitchen casework. The boxes will be made of melamine-faced particleboard and the doors made of MDF.
The question is, if the particleboard and MDF are certified to comply with TSCA Title VI, does that satisfy the requirements for obtaining LEED points? It seems very confusing to me and the only guidance USGBC has given is what is on their website:
"Product meets one of the following:
- EPA TSCA Title VI or California Air Resources Board (CARB) ATCM for formaldehyde requirements for ultra-low-emitting formaldehyde (ULEF) resins or
- EPA TSCA Title VI or CARB ATCM formaldehyde requirements for no added formaldehyde resins (NAF)."
But it is not clear to me if being TSCA Title VI certified means that you automatically also meet the CARB ATCM for ULEF or NAF; or is TSCA Title VI just a baseline requirement and ULEF and NAF require adhering to a more stringent level of emissions than TSCA? Nowhere in my online research have I been able to locate a clear answer to this.
Any advice would be appreciated.
Erica Downs
Sustainability ConsultantThe Green Engineer
4 thumbs up
January 6, 2020 - 11:00 am
Hi Angela - I was just looking for the same info. Hopefully you've received an answer to your question, but just in case, check this thread under NCv4:
https://leeduser.buildinggreen.com/forum/us-epa-tsca-title-vi-ulef-products
Ralph Bicknese
PrincipalHellmuth & Bicknese Architects
20 thumbs up
May 15, 2020 - 2:46 pm
We have been working on the same issue but have not been able to find a definitive answer. We are taking the conservative approach that meeting TSCA Title VI does not necessarily mean that it meets either ULAF or NAF requirements, unless we have test results that state so. In one case we found manufacturer's literature that stated the product (specific mdf board) meets TSCA Title VI, but does not meet ULEF or NAF. The formaldehyde threshold for TSCA Title VI is stated as 0.11 (ppm i think) but have not found any thresholds for ULEF or NAF. But since NAF is no added formaldehyde a threshold may not be required.
Adam Yarnell
Sustainability ConsultantSteven Winter Associates
12 thumbs up
July 10, 2020 - 10:30 am
Hi all, we had a similar question pop up for a recent project, and we received the following reply from the LEED Coach:
"For LEED purposes the product must be labeled TSCA Title VI ULEF or TSCA Title VI NAF; it is not sufficient that the product is TSCA Title VI compliant.
Per the EPA.gov website, the label on composite wood panels must include the panel producer’s name, lot number, an EPA-recognized TSCA Title VI Third-Party Certifier number, and a TSCA Title VI compliance statement. Documentation of this label may be provided (such as a photograph of the label). Alternatively (preferably), a certificate from a recognized accreditation body (https://www.epa.gov/formaldehyde/recognized-accreditation-bodies-under-formaldehyde-emission-standards-composite-wood) or third-party certifier (https://www.epa.gov/formaldehyde/recognized-third-party-certifiers-under-formaldehyde-emission-standards-composite-wood) may be provided."
Erica Downs
Sustainability ConsultantThe Green Engineer
4 thumbs up
November 1, 2022 - 10:04 pm
I recently received a similar comment on a project, that a manufacturer statement, nor TSCA Title VI certification, were sufficient. But I have to find a particleboard or plywood product that has a certifcate specifically stating compliance with "TSCA Title VI ULEF" or "TSCA Title VI NAF". They say:
"EPA TSCA Title VI 40 CFR 770.18(d) Ultra low-emitting formaldehyde resins exemption from certification and testing", or
"EPA TSCA Title VI 40 CFR 770.18(c) Ultra low-emitting formaldehyde resins reduced testing" or
"CARB ATCM 93120.3(d) Special Provision for Manufacturers of HWPW, PB and MDF with Ultra-Low-Emitting Formaldehyde (ULEF) Resins".
But nothing that matches specifically the language in the Ref Guide. So what am I supposed to be looking for??