U.S. EPA TSCA Title VI ULEF Products

my guess is that you better check with your LEED coach. Manufacturers seem to be changing and or "updating" their documentation but that doesn't mean LEED has ingested and accepted them. you are rolling the dice on whether a GBCI review team will accept the documentation or not; Which sadly may have little to do with the product actually meeting the desired health and safety requirements.

Hello Marcia - When LEED v4 was developed, the EPA TSCA Title VI regulation was not in effect, so the language in LEED only referenced the CARB regulation. LEED v4.1 has addressed this with updated language in the Formaldehyde Emissions Evaluation - linked here https://www.usgbc.org/node/11963828?return=/credits/new-construction/v4.1

I hope this is helpful to you and others trying to source and qualify composite wood products for your LEED projects.

I believe we did Marcia! Thanks for sharing the info about your door "walls". Does that mean that the door manufacturer has to certify the door system to CDPH Standard Method V1.1-2010?

Very interesting Marcia,

can anyone else support that GBCI will consistently accept Wood doors as walls with General Emissions Evaluation? If nervous I would just use the v4.1 Credit Substitution or make sure you include the email from your LEED coach with the submitted documentation.

it seems that the certification your Door mfgr can provide should be OK according to this info taken from the doc linked below:

"The emission standards established by TSCA Title VI are not altered in this final rule. The requirements in this final rule are consistent, to the extent EPA deemed appropriate and practical considering TSCA Title VI, with the requirements currently in effect in California under the California Air Resources Board’s (CARB) Air Toxics Control Measure to Reduce Formaldehyde Emissions from Composite Wood Products (ATCM) (Ref. 1). "

https://www.epa.gov/sites/production/files/2016-07/documents/formaldehyde_frn_final-prepub_07.26.2016_0.pdf

however as previously suggested I would ask your LEED coach to confirm & possibly send the language above.

If you can keep us posted that would be very helpful and greatly appreciated :")

Debra Lombard

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."

There is a third option, CARB exemption through an executive order: https://ww2.arb.ca.gov/resources/documents/nafulef-executive-orders