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NC-v4.1 EQc2:Low-Emitting Materials

Composite wood - Compliance with CARB ATCM or TSCA Title VI is not enough?

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Project Manager
LEEDuser Basic Member
14 thumbs up

Hi LEED experts,

My project used composite wood with Test reports to show compliance with CARB ATCM and TSCA Title VI. But then I received the LEED review comment that "Composite wood must be "CERTIFIED" as an ultra-low emitting formaldehyde (ULEF) product or as a no added formaldehyde resins (NAF) product under California Air Resources Board (CARB) ATCM or TSCA Title VI. Note that compliance with CARB ATCM or TSCA Title VI is not as stringent as being certified CARB NAF/CARB ULEF/Title VI NAF/Title VI ULEF". In previous projects, I submitted the test reports according to CARB ATCM and TSCA Title VI and got approved. But this time is a big surprise for me. Is it true that compliance test reports according to CARB ATCM and TSCA Title VI are not enough? if certified CARB NAF/ULEF is more strigent, then what are additional criterior/standards? It is very hard to do this credit when there are hidden standards.

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Mon, 07/15/2024 - 17:51

Hi Michael - I'd love to see the documentation you submitted. Agreed that we typically provide a "Certificate of Compliance" from the Composite Panel Association affirming that the project "Has fulfilled the requirements of EPA TSCA Title VI... and CARB ATCM 93120.3..." without issue. If this is your standard approach, I recommend pushing back on the reveiwer for more detail or ask for a call to discuss. We're seeing some comments from GBCI reviewers recently that are either inaccurate or wrong and generally find that, when pressed for details/discussions, they come to their senses.
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Kristi Ennis
Sustainable Design Director
Boulder Associates Architects
LEEDuser Premium Member
20 thumbs up

Mon, 07/29/2024 - 21:16

Michael, The formaldehyde emissions evaluation in the credit requires that these products meet ULEF or NAF unless they are structural products that fall under other standards. (These are the first two bullets under the heading of "formaldehyde emissions evaluation" in the credit criteria.) These products actually recieve exemption under both regulations cited for meeting more stringent criteria, exempting them from some or all certification requirements. We have not had issues with this product category, but have always specified ULEF or NAF. You may have products that are marketed as "CARB compliant" that are actually ULEF/NAF (as all ULEF/NAF products are CARB compliant, but not vice versa). Hoping that you find yours are when you look into it! Sorry that previous reviewers appeared to have missed this. 

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