I10-E27 Plenum Rated Electrical & Data Cable

Revised December 17, 2020

QUESTION:

The following dialogue post relates to halogens, specifically Halogenated Flame Retardants (HFRs), Polyvinyl Chloride (PVC) and Highly Fluorinated Chemicals, in electrical and data wiring and cabling. ILFI classifies some halogenated flame retardants and Polyvinyl Chloride (PVC) as red list ingredients, but neither the LBCv3.1 nor LBCv2.1 (which our project is pursuing) includes Fluorinated Ethylene Propylene (FEP) as a red list chemical despite the fluoropolymer industry's contribution to the demand for persistent, bio-accumulative, and toxic Perfluorinated Compounds (PFCS) such as Perfluorooctanoic acid (PFOAS), Perfluorooctanesulfonic Acid (PFOS), Perfluorinated Alkylated Substances (PFAS), GenX and other fluorosurfactants used in the emulsion polymerization process. While PFOAS, PFOS, PFAs, and Polytetrafluoroethylene (PTFE) are considered as red list ingredients in LBCv3.1, FEP is not included in the list of PFCS. FEP is commonly found in wiring and cabling, and is marketed as an alternate to PVC wiring. As FEP is not listed on the Red List many FEP wiring products exist with declare label and other documentation stating "red-list free". However, despite the "red-list" label, our project team still has concerns regarding FEP wiring, given the high quantity of halogenated chemicals present in the wiring, as per the supplemental charts provided by General Cable and Anixter, two common wiring manufacturers. Based on the two charts provided we can assume that 1 million feet of FEP wiring would produce between 52,700 to 66,300 pounds of halogens that could be easy avoided by taking a precautionary approach.

The Santa Monica City Services Project proposes that all wiring and cabling used on the project will be Low Smoke Halogen Free (LSHF,LSZH), with priority given to UL Certified products, which will drastically reduce to the furthest extent possible, all halogens used in these products, of which PVC, HFRS and PFC chemicals all fall under. This approach reflects the language in LBCv3.1 I10-E16 10/2013 regarding the encouragement to specify LSZH products. This will allow the project to reduce regrettable substitutions associated with selecting one halogenated polymer chemical (PVC) over another halogenated polymer (FEP). In addition to selecting products based on the LSHF/LSZH criteria, the project will also track for full documentation of compliance with the red list, but will not automatically choose Declare (red-list free) products, and instead defer to LSHF/LSZF as the most important criteria for the product selection. The project team is also committed to increased advocacy on this issue, and has worked extensively with the project's engineering team, wiring manufacturers and electrical sub-contractors to raise awareness about the dangers of halogens in wiring and cable products, which also include seriously concerns for the health of our first responders as they are often exposed to harmful gases produced by burning halogens, such as hydrogen chloride, during fire events.
Due to the recent findings of Highly Fluorinated Chemicals in drinking water across the United States, this project believes that taking action on PFCs, including FEP, is a necessary action in reducing the demand for these harmful chemicals, and can lessen risks to the wider population while the Environment Protection Agency (EPA) and other State regulatory organisations continue to conduct research on the toxicity of PFCs, and produce drinking water regulations on all Highly Fluorinated Chemicals. Please see attached EPA fact sheet and drinking water health advisory for more information.

ANSWER: 

See Update below for revised ruling and exception.

The project team’s plan to install LSZH/LSHF cable without Red List ingredients is in alignment with I-10 Red List requirements.

For plenum rated cable and cable applications with few or no identified Red List compliant product offerings, project teams must work to minimize dependence on PVC cable within the project, then prioritize cable products with full ingredient transparency. Project teams are not required to document compliance using the General Red List Exception if fully disclosed plenum rated products are used in the project. The Institute has developed the exception below to codify the prioritization of ingredient transparency.
Also note that project teams are not required to install Declare products for every application. Project teams may choose to install identified Red List compliant products and are not restricted to only Declare products for the identified application. LBC 3.0 and 3.1 projects must meet the minimum Declare label count requirement set for the project, but the specific Declare products installed are up to the discretion of the project team.
I10-E27: Plenum Rated Electrical and Data Cable
Project teams must demonstrate the design considerations taken early in the project to reduce and eliminate the need for Red List containing cable, including efforts to avoid plenum rated cable and to maximize the use of Low Smoke Zero Halogen and other Red List free cable products within the project. Where plenum-rated cable cannot be avoided, teams must source:
  • cable products with published and publicly available ingredient transparency for a minimum of 99% of the product at 100ppm (0.01%); cable or
  • cable or wire products with an active Declare label with any Declaration Status; or 
  • products with any level of Living Product Challenge certification.

Documentation: 

  • detailed design narrative noting the design considerations taken to maximize the use of Red List free cable products.
  • product ingredients list showing 99+% of the product's content.

Update December 17, 2020
After further evaluation and consideration, ILFI will not permit project teams to track Fluorinated ethylene propylene (FEP) as a regrettable substitution for PVC at this time. FEP based products represent an incremental improvement in the electrical and data cable industry and project teams should consider FEP jacketed products as a replacement for PVC jacketed products. Products specified before December 17, 2020 may document product compliance using the ruling above. Products specified after December 17, 2020 may not prioritize PVC based products over available FEP products, when the FEP product can demonstrate Red List compliance and the same performance criteria can be maintained. 

Project teams may leverage other chemical of concern lists in addition to the Red List during the Materials vetting process, but not in a way that prioritizes the installation of products with Red List ingredients. Project teams may not use “regrettable substitution” as the reasoning for installing a product with a Red List ingredient in lieu of installing a product with an active Declare label with a Declaration Status of Red List Free or Red List Approved without supporting research and ILFI approval through the Red List Change Request process referenced below..

Research must be performed by a licensed toxicologist or ILFI-preapproved industry expert. All researching individuals must be from neutral third parties and manufacturer or trade group funded research must be reviewed and approved by ILFI. ILFI will make the final determination of a chemical as a regrettable substitution in these instances.

ILFI evaluates the Red List annually and reserves the right to update the Red List and Watch List CAS Number Guide based on best available science. To request a specific chemical be considered as a regrettable substitution and/or considered for the LBC Red List and Watch List, teams and manufacturers are encouraged to complete the ILFI Red List Change Request Form

Exception Redraft: 
I10-E27: Electrical and Data Cable

Project teams must demonstrate the design considerations taken early in the project to reduce and eliminate the need for Red List containing cable, including but not limited to efforts to avoid PVC jacketed plenum rated cable and to maximize the use of Low Smoke Zero Halogen, FEP, and other Red List free cable products within the project. When Red List containing cable is required by code and the project team has exhausted exception I10-E5 Red List and Code or the team has fulfilled the required product research requirements and Red List containing cable cannot be avoided for a given application, teams must source: 

  • cable products with published and publicly available ingredient transparency for a minimum of 99% of the product at 100 ppm (0.01%); or
  • cable or wire products with an active Declare label with any Declaration Status; or 
  • products with any level of Living Product Challenge certification.

At the time of Certification, teams must provide: 

  • a brief narrative outlining the considerations taken to avoid Red List containing cable, highlighting design solutions considered and product substitutions. The narrative must explicitly state the project team’s use of product databases including the Declare Database, the Living Product Challenge Case Study page, the HPD Public Repository, and mindful Materials, when researching available electrical and data cable products with the required level of ingredient disclosure. 
  • The full ingredient disclosure or the Declare ID or LPC ID for each installed cable product utilizing this exception to demonstrate the required ingredient disclosure threshold was met. 
    • Products with full ingredient disclosure and no Red List ingredients at or above 100 ppm in the final product are considered Red List free and do not require tracking against this exception. 

Electrical and data cable products are not eligible for I10-E1 General Red List Exception until multiple project design solutions have been considered to eliminate Red List cable products and all referenced product transparency databases have been exhausted, per the requirements of this Exception, to source a Red List free or fully transparent product. Project teams must prioritize cable products per the steps below:

  1. Teams must first make a reasonable attempt to source a Red List free product. At minimum, the team must consider changes to the design to eliminate the need for PVC containing cable and product substitutions to source Red List free cable products. The referenced product databases must be exhausted before this step is considered complete. 
  2. When a Red List free product cannot be identified for the required application and performance criteria, the team may source Red List containing products with 99% or greater ingredient transparency to 100 ppm. The referenced product databases must be exhausted before this step is considered complete.
  3. Only after steps one and two are complete and documented may teams utilize I10-E1 General Red List Exception for the given application. 

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