Specific Exceptions are organized by chemical class, and are based on the limited availability of Red List–compliant options. Thresholds for compliance are based on industry reference standards that establish less hazardous thresholds for exposure. Because the lack of options for these products is well established, searching for Red List–compliant products for these Exceptions is not required in most cases. However, some research is encouraged since the market is always evolving.
Formaldehyde
RL-009a Formaldehyde
This Exception outlines compliance pathways for formaldehyde-containing products and materials. The General Pathway is available to all formaldehyde-containing products. Project teams using the following specific materials types and/or applications may choose to use an applicable Alternative Compliance Pathway:
- 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.
GENERAL PATHWAY (Available to all products):
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 I10 – Healthy Interior Performance Compliance Details under CDPH Clarifications.
Compliant Standards and Emissions Thresholds
Products manufactured in the region defined as Oceania may use the testing standards and formaldehyde limits identified in exception HH-005 Product Air Quality Testing in Oceania to demonstrate compliance with the General pathway.
ALTERNATIVE COMPLIANCE PATHWAYS:
Composite Wood Materials (Non-Structural):
Interior composite wood materials, defined as all particleboard, medium density fiberboard, and hardwood plywood, may contain formaldehyde, if labeled by a Third-Party Certifier (TPC) or declared by the manufacturer with one of the following standards, to demonstrate compliance with maximum allowable emissions of formaldehyde for each composite wood product type:
- 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
- Super E0 or E0 classification (and E1 for MDF and thin MDF only) when tested by an accredited laboratory and meeting the relevant Australian and New Zealand Standards (AS/NZS).
These products can alternatively use the approved testing standards outlined in the Compliant Standards and Emissions Thresholds table above, to demonstrate that the product does not emit greater than the following CARB/TSCA Title VI emission standards for formaldehyde:
- Hardwood plywood – 0.05 ppm
- Particleboard – 0.09 ppm
- MDF – 0.11 ppm
- Thin MDF – 0.13 ppm
As a final alternative, manufacturers may also submit documentation from an EPA TSCA Title VI TPC or CARB demonstrating that the product in question qualifies for reduced testing and/or third-party certification exemption if the product uses NAF or ULEF resins. Composite wood products and finished goods using urea-formaldehyde or melamine formaldehyde resins are not eligible for the NAF or ULEF resin exemption.
Composite Wood Members (Structural):
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). Super E0 and E0 classification (and E1 for MDF and thin MDF only) composite wood products manufactured in Oceania may demonstrate compliance by testing at an accredited laboratory and meeting the applicable standards issued by Standards Australia and Standards New Zealand (AS/NZS).
Foam Board Insulation:
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, 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.
Specific Exterior Applications:
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.
Monomeric, Polymeric and Organophosphate Halogenated Flame Retardants (HFRs)
RL-016 HFRs in Foam Insulation
Foam insulation with HFRs are allowed in the following applications when space is limited and alternative products cannot provide the required R-value performance:
- Structural Insulated Panels (SIPS)
- Insulation in hollow metal doors
- Spray insulation for renovation projects
- Under-slab insulation
- Roof and exterior insulation
Foam insulation in these cases must still meet all other Red List requirements.
Foam insulation is not allowed in cavity-fill applications where many alternative Red List-compliant options without HFRs are available on the market.
Per-and Polyfluoroalkyl Substances (PFAS)/Perfluorinated Compounds (PFCs)
RL-022 PFAS in Building Materials
A project team may use certain products that contain PFAS if all of the characteristics listed below under Required Product Characteristics are true, and the project team advocates to the manufacturer to design the PFAS chemical out of the current and future product formulations.
PFAS-containing products in the categories listed below under Excluded Product Categories are not eligible for use under this exception.
Required Product Characteristics
- The product is currently unable to meet performance requirements or perform its essential function without PFAS chemicals,
- There are no other Red List chemicals present, and
- The product has a published transparency label, such as Declare, or publicly available ingredient list at 100 ppm (0.01%).
Documentation Requirements
- Statement clearly articulating why the product was essential to meeting project performance requirements and couldn’t be avoided,
- List of the functions the PFAS provides in the product (e.g., stain repellant) if disclosed, and
- Evidence of advocacy to the manufacturer to design the PFAS chemical out of the current and future product formulations.
Excluded Product Categories
This exception does not apply to the following product categories, because ILFI is aware that compliant products exist, or that alternate product types provide a functional equivalency.
- Carpets, including broadloom and carpet tile
- Flooring, including Resilient and Hard Flooring
- Interior Ceiling Products
- Sealants, whether applied onsite or during fabrication.
- Upholstery
- Fabrics used for window or wall coverings
- Systems furniture
- Interior Paints
- Wires and cables subject to NFPA 90A, NFPA 262 or UL 910, and/or used in plenum spaces and other areas used to transport environmental air without enclosed raceways. Refer to Exception RL-023a Wire Sheathing subject to NFPA 90A, NFPA 262, UL® 910
Toxic Heavy Metals
Chromium
RL-010 Chromium VI in Plumbing Flush Fixtures
Chromium VI is allowed in the plating on flush levers and commercial flush valves due to the lack of alternative plating materials currently available in the market.
Lead (added)
RL-011 Lead (added)
Added lead is allowed in plumbing applications where products demonstrate compliance with the US federal definition of “lead-free” as defined in S. 3874 (111th): Reduction of Lead in Drinking Water Act, effective January 1, 2014.
RL-012 Lead in Commercial Water Systems
Commercial water systems that don’t use potable water, connect to potable water systems, and/or are part of a closed loop system are allowed to meet a higher lead content than regulated for potable water systems, in the following applications if alternatives are not found or not allowed by code:
- HVAC, pumping, pumps, and valves
- Sprinklers/irrigation systems
- Roof drains
- Backflow preventers
- Fire suppression systems
RL-013 Lead Products in Medical Facilities
When required for protection from internal radiation sources such as X-ray and MRI machines, hospital doors and other building products in medical facilities may contain lead. Non-protective doors and building products may not contain lead.
The project team must provide documentation stating why lead is necessary for specific products.
RL-014 Lead Regulation Limitations
Use of this exception requires ILFI approval in advance; see details below.
The Institute recognizes that there are circumstances in which established law specifying thresholds for Red List ingredients exceeding those endorsed by the Institute, combined with a remote location, make it difficult for project teams to source compliant products, creating a situation in which the local market is unlikely to be shifted by advocacy to manufacturers alone. The Institute has therefore created the following Exception:
In regions where:
- Enacted law provides for a higher lead concentration in products than permitted by US S. 3874 (111th): Reduction of Lead in Drinking Water Act, effective January 1, 2014 (0.25% lead level or lower; and
- Importing compliant products is infeasible for individual projects,
Project may teams may request approval to use products that comply with the lead content laws applicable in their location by submitting the following documentation in a Request for Ruling; ILFI approval must be received prior to initiation of the Ready Audit:
- Narrative stating the allowable lead levels and specific project or regional limitations (e.g., minimum order requirements, customs limitations, import fees or delays) to importing lower lead products; and
- Full disclosure of the percentage of Red List ingredients in the product.
- If approved, the project team must document the following:
- Advocacy to each selected supplier to reduce lead levels for future products without increasing other Red List ingredients, such as arsenic.
- Advocacy to the AHJ to reduce the maximum allowable lead content of metals and alloys in contact with drinking water to levels protective of human health.
Project teams in the following locations, where barriers to sourcing compliant products have already been demonstrated to the Institute, do not need to receive prior approval for use of products with lead concentrations exceeding the requirements of this Imperative:
- Oceania (defined as Australia, New Zealand, Melanesia, Micronesia, and Polynesia.)
Mercury
RL-015 Mercury in UV Disinfection Lamps
Mercury is allowed in UV disinfection lamps for projects that pursue the Water Petal if no other acceptable non-chemical filtration methods can be identified. Disposal plan of disinfection lamps must be outlined in project documentation.
