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NC-v4 EQc2:Low emitting materials

NAF Manufacturer Statements

Had a review come back declaring that manufacturer statement or declaration of no added formaldehyde to their products are insufficient and they must apply to CARB/TSCA to be approved as a NAF manufacturer before LEED will recognize the documentation as vaild evidence of the composite wood evaluation. 

What is the reasoning behind this? What is the logic? If a manufacturer declares that they add no formaldehyde to thier particle board or plywood prodcuts, why does LEED expect them to obtain an expensive certificate to allow them to make that claim? It is not a trademark or proprietary product to say we do not add formaldehyde to our products. As manufacturers of the products they know every molecule that is in or added to their prodcut, as indicated by HPDs and SDS sheets. Their declaration as such should be acceptable. 

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Wed, 03/17/2021 - 22:44

Hi Leanne - As a building product manufacturer in the U.S. my understanding of this decision was to drive project teams to select products that are third-party certified as compliant to the new (at the time) formaldehyde regulations that went into effect for MDF, Particleboard, and Hardwood Plywood. Additionally, promoting the lowest possible emitting products in this category (which are those that have either a ULEF or NAF Exemption from  CARB/TSCA). That third party certification is the verification that the manufacturer is fully compliant and has been approved by the regulatory bodies (CARB or EPA). It also potentially makes it easier to source products/manufacturers since those exemptions are promoted via CARB's website. Hope that helps!

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