MR4 -vs- MR7 credits

FSC-Certified wood that has recycled content counts either to MRc4 or MRc7, but not to both. As noted above, in the LEEDuser “Bird Eye View” FAQ comments, LI #10372 (issued April 2014) stated: “Products identified as FSC Mix Credit or FSC Mix [NN] % also have pre- or post-consumer recycled content, the latter of which is commonly reported separately by the product manufacturer. In these instances the project team must choose whether to classify the product (or some fraction of the assembly) as FSC certified or as recycled content; the material cannot contribute to both claims simultaneously. Specifically claims may be made under either MRc4: Recycled Content, or MRc7: Certified Wood. Note that for recycled content claims the material must meet the definition of ISO 14021 as required by LEED.” Note that the ruling leaves the classification up to the project team. If you are a fabricator/supplier, work with the project team to determine how best to count wood that contains recycled content. (This may require breaking it down both ways.) Also see Tristan & Jason’s April 7 comment thread below.

Esther - As a guest, you can't see the Bird's Eye View above that Jon refers to. Here is a link to the LI - http://www.usgbc.org/leed-interpretations?keys=10372. Here's some of the relevant verbiage from the FAQ above: "Some FSC Mix products combine recycled and "new" content, in which case project teams must decide how to classify the product...In other words, if a product is FSC Mix and also has recycled content, project teams have to choose which "environmental attribute" they will use to classify the product, and it (and its dollar value) will either go into an FSC "bucket" or into a recycled-content "bucket."" I recently had some FSC Mix Credit products on a job and thought I might use recycled instead of FSC due to the invoice requirement. Yet the supplier did not have a recycled content percentage noted. So since I didn't know what the percentage was in order to include it in the BDC Materials and Resources calculator, I had to count it under MRc7.

The FAQ above states: "Because this credit focuses on "new" wood, products that are 100% recycled content may not be counted as certified wood under MRc7, and should be excluded from the total cost of new wood materials. However, those purchases could qualify for credit under MRc4: Recycled Content." I don't see that in the LI but LEEDuser staff may have another resource for this information. It seems to make sense in your situation. If I were you, I would just put it under MRc4 and save myself the MRc7 invoice hassle.

I think that both this particular FAQ and the MRc7 spreadsheet are out of date in light on the LEED Interpretation that Michelle references above. If a wood product bears an FSC Mix (X% or Credit) claim, then under the new Interpretation it can count toward MRc7 even if it is 100% recycled content, or it can count toward MRc4, but not both, at the option of the project team. If it bears an FSC Recycled (X% or Credit) claim, then it can only count toward MRc4.

FYI not all FSC Recycled products can apparently count for MR4. I just had an FSC Recycled product rejected from MR4 because it was reclaimed lumber that had gone through a process to convert it from whatever it previously was to wall paneling. The reviewer interpreted the product as refurbished rather than remanufactured and cited the ISO definition. Though I would have said the product was "consumer waste" from "construction debris" or "discarded" material and of course it was FSC Recycled, the reviewer stood firm based on the difference between remanufactured and refurbished.

Jason – Your reading of LI#10372 matches mine. When I cited the LI above, I emphasized the need to consult the project team. If they specified, purchased, & paid for FSC, there is a high probability that they would prefer to count it toward MRc7. On the other hand, if the project’s registration predates the April 2014 Ruling, and if their MRc7 tallies to-date have ignored recycled wood, they may choose not to apply the newer Interpretation. M Rosenberger – Was your review before or after LI#10372 was issued in April 2014? If your project was registered before April, reviewers may not have applied the LI to your project. MRc7 is a challenging credit to document already, but the frequent revisions to MRc7 requirements through new addenda & interpretations have compounded the confusion among project teams, woodworkers, & LEED reviewers.

Hi Jon, My review was returned 6/3/14, however the project was registered in 2012. I didn't read the recent LI referenced above as making any statement about FSC Recycled or it being impacted by remanufacturing vs. refurbishing definitions. I'm operating under previous understandings about FSC Recycled. You're right it's brutally difficult to keep up with the nuances, and we unfortunately are at the stage of not encouraging this credit for most our client's projects even here in the Pacific Northwest where it is theoretically available due to the difficulties of documentation and frankly the issues surrounding the need for small millwork and casework subs to be chain of custody holders. Part of LEED's appeal for us is that it has always been about intent. So it is particularly troublesome when we are forced to elevate the letter of the law over the spirit. Somehow that seems unbecoming when it comes to sustainability.

"MRc7 is a challenging credit to document already, but the frequent revisions to MRc7 requirements through new addenda & interpretations have compounded the confusion among project teams, woodworkers, & LEED reviewers." Agreed, Jon, but as someone who supported the development of the latest round of MRc7 addenda/interpretations, the hope and intent is that these policy changes resolve some longstanding problems and sources of confusion and that further changes won't be needed for a good long while. "You're right it's brutally difficult to keep up with the nuances, and we unfortunately are at the stage of not encouraging this credit for most our client's projects even here in the Pacific Northwest where it is theoretically available due to the difficulties of documentation and frankly the issues surrounding the need for small millwork and casework subs to be chain of custody holders." I sympathize, Michelle. Now that the policy has settled out, at least there is a clear and do-able compliance pathway for those millwork/casework subs that opt for FSC CoC certification. For what it's worth, small shops in the PNW can get a price break on CoC certification as well as technical guidance and support through Sustainable Northwest: http://www.sustainablenorthwest.org/what-we-do/programs/FSC-group-certification

Hi Jason, Thanks for the response. You're right Sustainable Northwest is a great approach to trying to address this issue. I hope that more of our local guys are able to take advantage of it. We'll keep trying.

Esther – Forgive us for hijacking this thread. Obviously, you hit a chord. Jason & Michelle – This latest ruling DOES significantly resolve & simplify the longstanding MRc4/MRc7 conflict. It’s just hard to keep everybody on track as the sawdust shifts under our feet. Now, LEEDv4 folds Recycled Content, Certified Wood, & other criteria into a single credit, which, I hope, will simplify things further. However, since all these critera will count for only one point, the challenge for USGBC, LEEDuser, & LEED Project Teams will be to develop tools & consistent policies that will streamline credit documentation. Now, Jason – Any good advice for Esther?

The only additional advice I can think to offer Esther is to contact FSC US (I would try to get ahold of Lori Knosolla) and see if there are any FSC CoC Groups similar to Sustainable NW that serve companies in her region that she might join to reduce the costs of FSC CoC and get more support than she is receiving from her current FSC certifying body. It would also be good for FSC US to hear from Esther that there is a need for FSC US to develop a definitive guidance document for custom woodworkers who want to obtain FSC CoC and comply with LEED requirements.

Esther – The fine for improper LEED submittals is problematic. You may wish to submit a Request for Interpretation/Information (RFI) through the Prime Contractor or Construction Manager asking how to proceed. If answers to the following questions are not spelled out clearly in the Contract Document (Drawings & Specs), ask the LEED Administrator to clarify: 1. On what date was the LEED Project registered? 2. Does the LEED Administrator anticipate applying any Addenda or LEED Interpretations issued by USGBC after the project’s registration that would affect MRc7 requirements? 3. If so, which ones? Emphasize that you are trying to save the Administrator’s time and ensure that your submittal aligns with the project’s LEED goals and documentation requirements. This puts the ball in the Administrator’s court and (if he/she is not overwrought) maybe win you an ally. It will also provide clear instruction on how to treat recycled content.

I had an email exchange about this with GBCI in March 2014. Not sure if the April information changes anything? My question to GBCI: Is pre-consumer recycled content that goes into an FSC Mix (not FSC MIX-NN% but FSC MIX) MDF product considered “new wood”? I have heard some rumors that this is supposed to be included but I have also heard that only virgin wood is supposed to be counted. Let’s assume that we are not using this product for any recycle content claims. Page 272 of the LEED CI reference guide adds to my confusion because it has a table that excludes postconsumer wood from a product’s new wood value. It doesn’t mention excluding pre-consumer recycled wood or all recycled wood. GBCI response: Correct, only virgin inputs are included in the scope of MRc7. Sometimes there are virgin wood materials that are from a manufacturing process that could be considered pre-consumer content. The product manufacturer will know how to document the wood components (as new wood which will not be counted as recycled content) based on the FSC rules. However, because of the FSC definition of the “Mixed” label it is possible for the same wood product to contain virgin and recycled content inputs. Project teams may make recycled content and certified wood claims on a product as long as the percentage by weight allocated to each claim does not add up to more than 100%. See LEED Interpretation #1702. " I also asked if there was a webinar on this and was told "there is a separate webinar on FSC and Chain of custody in the “tough credits” series that covers MR credits 6 and 7"

GBCI's response conflicts with LI#10372. The statement that "only virgin inputs are included in the scope of MRc7" is no longer correct in light of this new interpretation. Hopefully GBCI is getting their arms around their own policy changes.

wow. yeah. I will just follow #10372 and upload the LI with my credit to make sure my LEED reviewer is aware of this clarification.

Was there a consensus that it's even possible for 100% recycled particleboard to count towards MRc7? I don't care about MRc4, I'm already at my threshold. I'm going out on a limb and say if given an option, most teams would want it to count towards the MRc7 (much more difficult) rather than MRc4. I need these FSC product in my calcs to meet the 50%, eliminating them hurts me. That said, is it even realistic to think that any POST-consumer recycled product could even be FSC? It would have to be a young product (FSC has only been around since '93), and you'd need original CoC. Seems the only way to prove this would be for a PRE-consumer product taken from FSC scrap at an FSC mill. Amiright?

This string seems to reflect more confusion than consensus, but I am standing by my previously stated position: according to LEED Interpretation #10372, if a wood product is invoiced with an FSC Mix (X% or Credit) claim, then it can count toward MRc7 even if it is 100% recycled content, or it can count toward MRc4, but not both, at the option of the project team. If it bears an FSC Recycled (X% or Credit) claim, then it can only count toward MRc4. There are lots of post-consumer recycled products out there that are FSC certified. See for example http://windfalllumber.com. You don't need "the original CoC" -- you need to meet a specific standard that FSC established for reclaimed wood products. Basically, you need to use pictures and documentation to prove to the auditor that the wood is reclaimed.