20-1216 Consolidated and Revised Red List Formaldehyde Exception
Revised December 2020
Note: Exception RL-009 Formaldehyde was published in the first version of the LBC4.0 Materials Petal Handbook in January, 2020. It consolidated several exceptions that addressed specific product types, and those individual exceptions were retired for LBC 4.0 (see exceptions listed at the bottom of this post). This staff post both revises RL-009 and hereby makes explicit that project teams pursuing any version of LBC released prior to 4.0, may use either RL-009 or the suite of exceptions it retired; a combination of both is not permitted.
- Composite Wood Materials (Non-Structural)
- Composite Wood Members (Structural)
- Foam Board Insulation (Phenol Formaldehyde-only)
- Specific Exterior Applications (LBC Exception Only)
Manufacturers and project teams using this Exception, which only addresses formaldehyde, should be aware that compliance with I10 Healthy Interior Performance requires VOC emissions testing compliance for a larger suite of chemicals.
Manufacturers of formaldehyde-containing products must demonstrate that emissions levels in the final product comply with the thresholds determined by one of the approved emissions standards outlined in the table below. Conformant product certifications that use one of the standards in the table are listed in the Health & Happiness Petal Handbooks, under CDPH Clarifications.
- California Air Resources Board (CARB) Airborne Toxic Control Measures (ATCM) Phase II
- Toxic Substances Control Act (TSCA) Title VI
- E1 or E0 classification formaldehyde limit when tested to EN 717-1
- Engineered Wood Products Association of Australasia (EWPAA) Super E0 or E0; E1 is accepted only for MDF and thin MDF
- Hardwood plywood - 0.05 ppm
- Particleboard – 0.09 ppm
- MDF – 0.11 ppm
- Thin MDF – 0.13 ppm
Structural composite wood members, including sheet goods, may contain formaldehyde in NAF or ULEF moisture-resistant adhesives if they meet APA The Engineered Wood Association (APA) definitions of, and applicable construction standards for, “engineered wood products” detailed in APA Technical Note J330D, published July 2018. Note J330D lists USA and Canadian production specifications for structural wood, and compares the formaldehyde emissions to other international specifications and formaldehyde emissions thresholds for these products, which are additionally accepted as demonstrating compliance for the purposes of this Exception. Alternatively, manufacturers of structural composite wood members may demonstrate compliance to EN 717-1 E1 emissions limits (<0.124 mg/m3 formaldehyde).
Foam board insulation may contain phenol formaldehyde polymers if the manufacturer or supplier can demonstrate compliant levels of free/residual formaldehyde by testing the polymer in accordance with one of the following standards? protocols?, and document that test results were below the CARB/TSCA Title VI formaldehyde limits (content or emissions):
- ISO 11402 (Formaldehyde content)
- EN 717-1 (Formaldehyde emissions), or
- one of the Approved Product Emissions Standards/Testing Methods or an equivalent standard
Foam insulation is subject to all other Red List requirements.
Only the following specific applications in the building’s exterior (defined as exterior to the rain and vapor barrier) may contain formaldehyde:
- Phenol formaldehyde (<2%) is allowed in rigid and semi-rigid mineral wool insulation for exterior applications (such as rain screen assemblies or foundation insulation).
- Formaldehyde is allowed in glass-mat gypsum sheathing products installed in the building exterior: underneath cladding.
Date revised: December 2020
Relevant superseded and retired exceptions:
I10-E6 9/2013 Glass-Mat Gypsum Sheathing
I10-E9 3/2013 Phenol Formaldehyde in Mineral Wool Insulation
I10-E10 8/2008 Structural Composite Wood Members
I10-E11 1/2009 Composite Wood Sheet Goods
I10-E22 6/2016 Formaldehyde in Systems Furniture Laminate
I10-E23 5/2017 Phenol Formaldehyde Polymers in Foam Board Insulation