We just received preliminary review comments on a project and this credit was marked pending as a result of one MDF product that uses a ULEF resin process. The reviewer is requesting that we "provide documentation from the manufacturer confirming that the material contains no added urea-formaldehyde." We submitted product information confirming the ULEF resin and that it is also ECC certified, and complies with CARB 93120 for formaldehyde emission limits. It is my understanding from ID# 10250, that products found compliant with CARB 93120 and/or meeting the requirements for ULEF can contribute to IEQc4.4.
Am I misunderstanding ID# 10250? Has there been a more recent interpretation that I am overlooking? Or, is the reviewer in err here?
Valerie Molinski
Environmental Stewardship ManagerTarkett North America
102 thumbs up
June 25, 2015 - 10:37 am
I had a similar issue pop up on a project. I found this blog entry on here at that time and it was very helpful.
http://www.leeduser.com/blogs/new-rules-urea-formaldehyde-ieqc44-uf-nauf...
William Weaver
LEED Fellow, WELL APJLL
181 thumbs up
June 25, 2015 - 10:49 am
Thanks Val.
Boiling that blog and subsequent commentary down to the basics, it appears that CARB/ULEF is acceptable for v4, but we must still show no urea-formaldehyde compliance for v3. The product we used may still be complaint, but the documentation is insufficient for v3.
Okay, but... We are allowed to use v4 templates on v3 projects for other credits. So, why not this one as well?
Kristina Bach
VP of InnovationSustainable Investment Group
151 thumbs up
June 25, 2015 - 4:49 pm
You could substitute the v4 credit for the v2009 one. HOWEVER - you have to substitute all of the IEQc4 credits to do that. You are not allowed to substitute just one of them. The point thresholds you actually get awarded in v2009 then varies based on how many points you demonstrate in the v4 credit. See specifically the ** footnote: http://www.usgbc.org/articles/use-v4-credits-your-v2009-project/
My guess would be that your other IEQc4 credits didn't have issues and so the reviewer was maybe trying to point you towards the potentially easier fix of just addressing this one credit rather than re-documenting all of the other credits again to the v4 standards?
Jon Clifford
LEED-AP BD+CGREENSQUARE
LEEDuser Expert
327 thumbs up
June 26, 2015 - 6:21 am
I have been looking at LEEDv4 Credit Substitutions for Low-Emitting Materials, and the substitution is not as straightforward as one might think, especially once a project reaches the review stage.
While the “Composite Wood Evaluation” may offer more flexibility than IEQc4.4 does in v3, the “Additional VOC Content Requirements for Wet-Applied Products” uses newer, more stringent SCAQMD standards than IEQc4.1 & IEQc4.2 did.
Also new to v4 is “General Emissions Evaluation” using emissions-based material test data. Finally, the v4 substitution requires using the “Option 2 Budget Calculation” which involves calculating the area of each layer of paint, coatings, adhesives, sealants, flooring, and insulation in each wall, ceiling, & flooring assembly, plus furniture. This kind of data probably was not gathered as documentation for LEEDv3.
The v4 Credit Substitution might be great for a new v3 that was still in Design or just starting Construction, but, as Kristina notes, backtracking to get all the extra data would be a burden once a project gets further along, let alone complete.
William, you may have better luck just doing as the reviewer suggests. Contact the manufacturer of the ULEF product to clarify whether their product contains any added UF. You might get lucky.
Jon Clifford
LEED-AP BD+CGREENSQUARE
LEEDuser Expert
327 thumbs up
June 26, 2015 - 6:26 am
Another observation: I looked again at LI#10250 and at the LEEDuser post that Valerie cites above. USGBC originally ruled on LI#10250 in October 2012. They revised it in April 2013, adding language to clarify that only NAUF composites are acceptable under LEED-2009.
If you registered your project before April 1, 2013, and especially if the MDF was approved between October 1, 2012 & April 1, 2013, you may be able to justify accepting the product based on the wording of the original ruling.
This tack may be worth a try if you discover that the MDF contains added UF.
Michele Helou
PrincipalSage Design & Consulting
72 thumbs up
July 16, 2018 - 6:38 pm
back to the April 2013 revised ruling -
'If the composite wood product using MUF can meet the testing requirements and is found compliant with the California Air Resource Board (CARB) Airborne Toxic Control Measure (ATCM) 93120 requirements for no-added formaldehyde based resins or the requirements for ultra-low-emitting formaldehyde resins (ULEF), the product can contribute to IEQ credit 4.4'
This applied to all LEED versions - correct? So if I have a composite wood product with documents stating it is made with MUF and it meets CARB 93120 for ULEF, is it compliant for LEED CI v2009? I think yes, it should be compliant based on the LEED Interpretation and its applicability to LEED CI v2009. But there are posts here to say not everyone agrees.
Brent Ehrlich
Products and materials specialistBuildingGreen
LEEDuser Expert
33 thumbs up
July 17, 2018 - 2:33 am
Yes. This is correct. Interpretation 10250 allows the use of MUF in 2009 as long as it meets ULEF testing requirements https://www.usgbc.org/content/li-10250. In v4, if the product meets ULEF requirements, then it is also good to go.