ANSI/BIFMA e3-2010 Furniture Sustainability Standard
HISTORICAL BACKGROUND Questions of intent, as well as requests for further explanation or clarification of various credits in the first edition of the standard, are reflected in the below list. These 55 opinions were rendered by individuals involved with the creation of the standard but under the auspices of BIFMA International prior to ANSI approval of the standard on 11-11-10. Future interpretations of the standard will be done by the Joint Committee on BIFMA e3 Furniture Sustainability. All interpretation requests should be directed to Joint Committee chairperson Matthew Realff c/o Mindy Costello (mcostello@nsf.org). e3 Interpretations 1 General 1.2 Scope Question E1: If a finished goods supplier makes product for multiple furniture manufacturers (OEMs), will the supplier be audited multiple times for level? For example, assume Supplier A was audited by CB X on behalf of OEM A. Supplier A may also be working with OEM B on products. Would Supplier A be required to be audited again by a different CB when they are having OEM B products certified? A second but related question is, would CB X audit Supplier A multiple times for level assuming they are manufacturing products for multiple furniture manufacturers all who are using CB X as their certifying body? Consensus Opinion: Yes to both questions, “Supplier A” may be required to be audited multiple times however, they may be able to use the same objective evidence for each audit. If "Supplier A" chooses to obtain product certification by working directly with a CB, and if the materials, processes, and/or facilities are the same for the product versions supplied to multiple OEMs, then the supplier could choose to share their documentation with the OEMs and may therefore avoid additional audits, regardless of whether multiple CBs are involved. Since it is a “product standard” each unique product boundary (scope) needs its own conformance certification. If the products have different boundaries, they need separate audits (unless negotiated approval among multiple OEMs is achieved they could get by with coordinated audits). Question E2: Should the scope of level certification include access flooring products? Movable walls are within the scope, but I would like to make sure I'm not straying out of bounds by considering raised flooring. It seems that these type of flooring products could be considered, but where to draw the line with other types of products is the question (e.g. ceiling systems). Consensus Opinion: Yes, at this time, the language in Section 1.2 is sufficiently broad to include the products mentioned. 3 Definitions Question E3: In Section 3.39, what is "…some reasonable time scale”? After all, petroleum is bio-based if one considers a geolithic time scale to be reasonable. Consensus Opinion: This definition does not affect conformance to any specific credit, however, we will consider modifying the definition in the next version of the standard. 4 Assessing Conformance, Evaluation, and Assessment Criteria Question E4: If a company has outsourced manufacturing to another country and that now constitutes their "entry gate", making the collection of adequate data difficult, does it effectively prevent them from getting many of the credits including Section 7.5.4.1 for hazardous waste? Consensus Opinion: An applicant could still achieve many credits. However, some of the facility-based credits are more difficult to obtain sufficient data. As with all of the gate-to-gate scope credits, you may be required to obtain information from the supply chain. The purpose of structuring the standard this way was to recognize all lifecycle impacts wherever they occur in the supply chain. If the information is not available or obtainable you cannot get the credit, including Section 7.5.4.1. Question E5:  If a manufacturer’s product has a restricted scope of conformance as described in BIFMA e3-2008 Section 4, paragraph 2, does the manufacturer have to communicate the restriction of certification scope on their certificates?  Does the manufacturer have to communicate the restriction of certification scope with their public claims of compliance? Consensus Opinion: Yes, the standard clearly states that the scope of conformance must be clearly communicated to potential purchasers. If a product has a restricted scope of compliance, the manufacturer must communicate that restriction with any public claims of compliance such as product literature, websites, bid responses, and marketing materials.  In the case of level™ certification, the certificates must include any applicable restrictions. Question F6: What is the recommended practice for communicating the “cut-off criteria for inclusion of inputs and outputs and the assumption on which the cut-off criteria are established” for credits where the scope of assessment can be either the facility where the “finished product is assembled” or the “finished product is manufactured”? Consensus Opinion: There is no requirement therefore there is no recommended practice to communicate the cut-off criteria to the customer. If the applicant organization uses a scope of assessment that exceeds the minimum requirements of the credit, they are free to communicate that as they see fit. 4.5 Baseline and Normalization Values Question E6: I am requesting clarification of how to consistently apply a single normalization value across the BIFMA e3 Furniture Sustainability Standard. Consensus Opinion: If you are not able to consistently use a normalization unit of measure, the standard allows you to use absolute values. Question E41: How would a company normalize a new product line? Consensus Opinion: The credits that require normalization are intended to show reductions of environmental impacts and that may not be feasible with a new product. 5.2 Climate Neutral Materials Question E7:  How are wood and other bio-based materials treated in the context of Credit 5.2? Consensus Opinion: As a practical matter, when the LCA (GHG Impact) results are tallied, applicants will usually find that wood and bio-based materials have significantly lower greenhouse gas emissions than metals, for example.  Otherwise, the process, to demonstrate conformance to Credit 5.2, is not different whether wood/biobased is involved or not.  Currently there is no widely agreed upon method for accounting for wood as a carbon sink therefore carbon sink accounting is not allowed in assessments for Credit 5.2. Question E8:  If an organization purchases renewable energy credits to apply toward Credit 5.2, can the REC also be applied to e3 Credit 6.8?  And if so, for purposes of Credit 6.8 is the total REC purchased for Credit 5.2 allowed or just that portion allocated to manufacturing and transportation in the calculation for Credit 5.2?   Consensus Opinion:  The purchase of renewable energy credits does not apply toward Credit 5.2 however they are applicable to Credit 6.8. 5.3 Life Cycle Assessment 5.3.1 Question F4: Does credit 5.3.1 require the company to incorporate the first two LCA components into product design for all new products? Or, is the requirement to have incorporated it for the product being certified only? The scope for this credit is product. If the latter is the correct interpretation (for the product being certified only) then my second question is; if the product has already been designed and is in production can the company do [the first two components of] an LCA and get the point? Consensus Opinion: Yes, the requirement is to have incorporated the first two of the four LCA components for the product being assessed only. If a product has already been designed and is in production, the applicant could still complete the first two components of an LCA by the time of the assessment to get the point. 5.4 Efficient Use of Materials Question E9: We are working on element 5.4.1 and 5.4.2 for some of our product lines.  During our discussion we questioned how to approach this over a product line...let's use our File Cabinets as an example (steel - we manufacture - with PVC tambour doors - we purchase).  There are over 1000 sku's of this cabinet in different sizes and with different internal components, shelves, drawers etc.  To test this product line for a material efficiency of 80% of the weight of the product to be assessed do we take an average of the various sku's, set or what is acceptable?  We will have this issue with other product lines where there are variable components dependent upon the configuration of the product.  Can we just state what are methodology is and use that consistently across the line and is that acceptable?  Or is there a standard method for this set?  We understand the formula and don't have an issue with the 60 or 70% material efficiency. Consensus Opinion:  The first requirement of 5.4 is to determine the mixture of materials that undergo a substantial conversion from the raw material into the product (minus incidental consumables) that make up 80% of the weight (Note:  for a clearer understanding of materials see the definition of Gate-to-Gate).  If you already have weights for all of the product line’s sku’s it will be easy to determine the weights of the materials, however if these weights are unavailable, points for Credit 5.4.1 and 2 can be earned for an entire product line by taking the worst case scenario of the entire product line and conducting an analysis.  Once the selection of raw materials that comprise 80% of the weight is identified, collect the following: input mass; the amount of materials that are recycled or disposed of as waste (the waste mass), and calculate the material efficiency by subtracting waste mass from input mass; dividing the result by the input mass and multiplying by 100. In the event that product specific data is not readily available, factory-wide material efficiency data may be utilized to demonstrate conformance, however, 80 percent of the product by weight and substantial conversion processes must still be accounted for in the assessment. Here’s an example calculation, purposely based on a very simple scenario: Example Calculation: The applicant is pursuing E3 certification of Product X, comprised of more than 80% aluminum.  The E3 evaluation, for element 5.4, may be based entirely on the applicant’s data for aluminum, used to manufacture Product X.  The applicant uses (100) tons/year of aluminum at the facility where Product X is manufactured.  At this facility, the applicant generates (25) tons/year of aluminum scrap, which is recycled off-site. The applicant has documentation on file, to demonstrate to the auditor that these quantities have been carefully tracked and reported. The Material Efficiency (ME) is calculated as follows: ME = [(100 tons/year – 25 tons/year)/(100 tons/year)] X 100% = 75% The applicant receives both points available under element 5.4.  5.5 Rapidly Renewable Materials Question E10: Does the use of renewable, or rapidly renewable material production waste, as alternative fuel, constitute disposal as used in Credit 5.5.2? Consensus Opinion: Yes.  The second point, described in Credit 5.5.2, is awarded only if the rapidly renewable material scrap is recycled or composted; not if the scrap is sent to a WTE facility. Example: If the product, to be assessed under Credit 5.5.2, contains  Material A as the sole rapidly renewable material, and the Material A scrap (from product manufacturing) is sent to a WTE facility, the second point will not be awarded.  The product would only be eligible for Credit 5.5.2 if the product contained a second rapidly renewable material, which meets all of the applicable criteria. 5.6 Bio-based Renewable Materials - Sustainable Wood Question E11: Is the applicant for points under 5.6 obligated to prohibit the use of CITES Appendices I or II in composite wood? Consensus Opinion: No. The requirement is to "not specify species listed in CITES Appendices I or II." The intent of the language is to discourage the use of CITES listed wood in products that achieve the points in this credit. Question E12: Is the applicant for points under 5.6 generally prohibited from specifying CITES Appendices I or II for use in products? Consensus Opinion: Yes. Question E13: Credit 5.6 indicates it is applicable to the "Product", however the language clearly applies to the "Organization" which would appear to make this a prerequisite. Which is correct? Consensus Opinion: It is a product credit. The prohibition on specifying species listed in CITES applies to that credit only. Question E14: Is "renewable" in the context of Credit 5.6 the same as "rapidly renewable" in Credit 5.5? Consensus Opinion: Not the same. "Renewable" in 5.6 is wood. Rapidly renewable is defined as renewable in less than 10 years. 5.7 Recycled Content Question E42a: In sections where worst case scenario needs to be used (such as recycled content), can a BIFMA typical be used to represent the product for this section? Consensus Opinion: Neither the standard, nor the Guidance Document specifically mention worst-case, as the basis for the calculation. Representative (worst-case) sample selection is only mentioned in Section 4 of the standard. This question comes up most often when systems (i.e. panels/work surfaces/storage) product lines are being assessed. It is important to apply worst-case sample selection in a manner that also accounts for a legitimate product configuration that is truly representative. An applicant may find that the BIFMA typical configuration could be used. For complex (e.g. systems products) assessments of recycled content conformance it may be advisable to select the option of using Table One. Question E42b: In the furniture industry, extruded aluminum has zero recycled content. If an applicant included extruded aluminum at just about any percentage level, would that prevent the product from meeting the minimum level of aluminum recycled content for the credit? Consensus Opinion: The presence of extruded aluminum in the product would not prevent the product from meeting Credit 5.7.1. The assumption that extruded aluminum has zero recycled content is not accurate. The Table One aluminum recycled content threshold does not apply to extruded aluminum per footnote 1 in the table. Question E43: After several conversations with packaging industry representatives, it appears there is no supply chain available for LDPE and LLPDE that meets the 25% Post-consumer requirement. There are several suppliers that can meet the 35% Total Recycle Content by using Pre-Consumer. In credit 5.7.3, does Table 2 require 25% post consumer + 10% something else to have a total of 35% recycled content? Or does Table 2 indicate that there must be at least 35% total recycled content (does not matter the post % + pre % makeup)? Consensus Opinion: The packaging material must meet both content hurdles outlined in the table. It is worth noting that these stretch goals were developed in an attempt to encourage the market to develop recycled content packaging materials. Question E44: In 5.7.3, does a packaging material need to meet the thresholds in both the post-consumer and total recycled content columns in order to get the point? Or can it just meet one of the criteria? We were under the assumption that it needs to meet both requirements (same for table one in 5.7.1), but when you look at the BIFMA tools you can meet either the post consumer or total recycled content amount for 5.7.3 and it gives you the point. We would like to clarify if our interpretation is correct or if the tool is correct. Consensus Opinion: The packaging material must meet both content hurdles outlined in the table. It is worth noting that these stretch goals were developed in an attempt to encourage the market to develop recycled content packaging materials. 5.8 Recyclable and Biodegradable Materials Question E17: Does the exclusion for waste to energy in Credit 5.8 apply to composite wood material? Consensus Opinion: Yes. The verification of availability of recycling/biodegradation facilities must not reference Waste-to-Energy (WTE) facilities, even if the product component in question is composite wood. It is worth noting that this credit may still be obtained, even for a product containing composite wood, if the composite wood or other product components, which may be recycled or biodegraded, are identified with the accompanying verification of facility availability. There is no threshold, within Credit 5.8, to limit the applicability of the credit to products containing some specified minimum percentage of recyclable or biodegradable content. 5.10 Solid Waste Management Question E18: Is waste-to-energy (WTE) an acceptable form of landfill diversion for Credit 5.10? Consensus Opinion: While WTE was explicitly excluded as counting for recycling; it was intended to be allowed for landfill diversion. The preferred waste management hierarchy is: reduce, reuse, recycle, recover, waste-to-energy, and landfill. The intent was to find options to landfilling, and WTE is one of those options. Question E19: Credit 5.10 appears to indicate that the first point is awarded for an organizational goal of 100% landfill diversion and a second is awarded for achieving 100% landfill diversion for the specific product being assessed. However, the Scope of the Credit is "Organization - Which is correct? Consensus Opinion: The scope of the first point is organizational however, per the standard language, the second point is a product point. The scorecard point categorization for the second point is an error to be corrected in the next issue of the standard. Question E45: Our auditor has indicated that waste diversion programs are required to be made publicly available based on the standard. 5.10 states, “the applicant shall receive a maximum of two points based on its published and implemented solid waste diversion program...”. Because of the word 'published', does it have to be publicly available? Consensus Opinion: No, by “published”, we meant something documented or written down, with some objective evidence that the goal was communicated to company employees, and is being pursued. 5.11 Water Management Question W1: The auditors who are working with our company are questioning whether the water formerly used to wash the rags is considered to be “process water”. Our company uses wiping rags as part of the furniture finishing process. Products such as stains and glazes are wiped down to give the desired color shading on the final product. We believe that water used to wash the wiping rags would definitely be considered process water even though this is not specifically listed in the BIFMA standard Section 5.11. Our company has been working with industries for over 20 years and it is generally accepted that water used by industries to help produce a product or affect a process is considered to be “process water.” The rags cannot be re-used in the finishing process unless they are cleaned. The rags are surely part of the finishing process, so the water used to clean them should be included as process water. Correct? The company did launder their own rags on site approximately 5-6 years ago; however, they have discontinued this practice and the rags are sent to an outside contractor to be cleaned. The outside contractor is able to clean the rags more efficiently resulting is less water usage per rag. Consensus Opinion: We agree that water used to clean the rags would qualify as process water. Where the standard states “process water includes”, and follows with a list of examples, the list was not meant to be all-inclusive. The outsourcing of the rag washing process would entitle the applicant to qualify if water efficiency is improved on an absolute basis. An applicant may not simply outsource process water use and count it as a reduction in water use. 6 Energy and Atmosphere 6.1 Prerequisite Question W3: Is the intent of this prerequisite to create another policy that overlaps the environmental policy like continuous improvements, setting goals and objectives, etc.? We've established an overall corporate policy and defined aspects like energy and others that fall within this policy. The auditor has indicated that the points listed in 6.1 have to be on the same policy page as energy. Do you agree with this position? Consensus Opinion: The intent is not to necessarily create a separate energy policy, the intent is to assure that all of the energy “policy” elements cited in Section 6.1 exist within the framework of the organization's overall corporate policies. 6.3 Building Energy Performance Rating Question E20: Regarding the Energy Star Rating System for buildings; they don't have a category that furniture manufacturing facilities fit into yet. There are industrial categories though. I'm being told by EPA that we are not eligible to receive a national energy performance rating. What was your experience when creating the credit relating to the building's energy performance? Consensus Opinion: If the building type is eligible for a performance rating by Energy Star's Portfolio Manager, then Portfolio Manager must be used to assess its Energy Star rating. If the building type is not eligible for a performance rating by Energy Star's Portfolio Manager, the alternative method to be used is described in the LEED-EB Reference Guide. 6.5 Embodied Energy Question F9: Can carbon offsets from renewable energy projects, certified to the same offset quality mechanism accepted in credit 5.2, be used to achieve the 10% reduction in embodied energy? Consensus Opinion: No, the intent of this credit is focused on a net reduction in embodied energy and not the source or carbon intensity of that energy. 6.6 Finished Product Energy Consumption Question F2: In Section 6.6.1, if a lighting product is included in the scope of certification for a product line, would information be needed from the lighting manufacturing facility in support of the facility level points? Was the intention of the standard to only receive documentation from the lighting supplier to show that the lighting products meet Title 24 of the 2007 California Energy Code and not to include this facility in the scope of certification? Consensus Opinion: For the first question: No, facility information is not needed for this credit. Second question: Yes, to earn this credit the product must only meet Title 24 of the 2007 California Energy Code. 6.8 On-site and Off-site Renewable Energy Question E24: Please confirm that wood waste (bio-mass as defined at 3.38), from manufacturing processes producing products assessed under the e3 standard, qualifies as renewable energy for purposes of Credit 6.8. Consensus Opinion: Energy recovery from secondary wood (all wood waste) may be used as a source of renewable energy for Credit 6.8. Question E25: If an organization purchases renewable energy credits to apply toward Credit 5.2, can the REC also be applied to e3 Credit 6.8? And if so, for purposes of Credit 6.8 is the total REC purchased for Credit 5.2 allowed or just that portion allocated to manufacturing and transportation in the calculation for Credit 5.2? Consensus Opinion: The purchase of renewable energy credits does not apply toward Credit 5.2 however they are applicable to Credit 6.8. Question E26: Please provide a link to the definition for "off-site renewable energy sources" on the Center for Resource Solution website. I am not able to find the reference specified in Credit 6.8.1. Consensus Opinion: It appears that the Center for Resource Solutions (CRS) has spun the Green-e program off as its own website (www.green-e.org) but still notes that it is a program of the CRS. The Green-e Standard has definitions of “eligible renewable” starting on page 2 of the Standard (see: http://www.green-e.org/docs/energy/Appendix%20D_Green-e%20Energy%20National%20Standard.pdf) but does not now differentiate between on-site and off-site technologies. We believe the intent of the original discussion was to help define the scope of the technologies that would be considered eligible for BIFMA e3 points, and would argue that the current Green-e Standard definitions of Eligible Renewables (it was updated in 2008) is what the e3 standard was trying to capture when it was written even though today it is not on the CRS website and currently makes no distinction between on- and off-site technologies. Question E27: If I can buy green off-site power from one network for plants that make up 50% of my production, can that "green power" credit be shared with other plants that are on a separate network that do not have a green power option? _ Consensus Opinion: If renewable energy credits or certificates (RECs) are purchased, they can be applied to any site. If off-site direct green power is purchased and the Green-e or equivalent REC is owned by the applicant, then it can be applied to the renewable energy percentage that the site claims. The applicant must own the rights to the green attributes to transfer the renewable energy. The renewable portion of the public utility's supply/portfolio can only be counted at the facility where it is used. 6.8.1- 4 Question F10: Can carbon offsets from renewable energy projects, certified to the same offset quality mechanism accepted in credit 5.2, be used to achieve the off-site renewable energy requirements in 6.8.1 - 4? Consensus Opinion: Yes, it would be considered an equivalent. 6.9 Greenhouse Gases Question F3 & F5: According to the BIFMA tools, the purchase of RECs/offsets can be used for both 6.8 and 6.9. We would like to confirm that RECs/offsets can be used for 6.9. Also, can the same set of RECs/offsets be used for both 6.8 and 6.9? Consensus Opinion: While the intent of Section 6.9 is to encourage greenhouse gas (GHG) emission reductions through energy conservation measures, at this time the credit language is sufficiently broad to allow other means of achieving GHG reductions. If offsets are used, they must meet the offset quality mechanism stated in Section 5.2. If RECs are used, they must meet the criteria established in Section 6.8.1. Yes, the same set of RECs/offsets may be applied to both 6.8 and 6.9. 7.4 Effects of Product, Manufacturing Process and Maintenance Chemicals Question E28: Could a product earn any material chemistry points under Section 7.4.1 if it uses recycled materials where the content could not be adequately characterized for MSDS reportable or Annex B chemicals? This is assuming that the recycled content is present in significant quantity to be encompassed by the appropriate threshold (i.e. 75% - 99.9% depending on points sought under the Basic, Intermediate, or Advanced levels). Consensus Opinion: Under 7.4.1.1, yes, a product could earn a point if it meets the requirements stipulated by OSHA 29 CFR 1910.1200. Credit 7.4.1.1 uses MSDS reportable chemicals to generate a list of chemicals that must be screened against Annex B to assess for chemicals of concern. For the intermediate and advanced levels, the answer is no, because the required identification of chemicals has not been satisfied. Both 7.4.1.2 and 7. 4.1.3 require that materials be assessed for chemicals present at a concentration down to 100 ppm. This requires chemical information beyond that provided by a MSDS. Question E29: Suppose a product has some parts made of 100% post consumer recycled plastic (content cannot be fully characterized for MSDS or Annex B chemicals) and those parts make up 6% of the product. Then the applicant would NOT be able to receive points under 7.4.1.1 (Basic; threshold is 95%), 7.4.1.2 (Int; threshold is 99%), and part of 7.4.1.3 (Adv; threshold 75, 90, and 99.9%). Is this correct? Consensus Opinion: MSDSs are generally required for industrial materials, including recycled plastics. Under 7.4.1.1, even though difficultly may exist in characterizing some materials a product could earn a point if it meets the requirements stipulated by OSHA 29 CFR 1910.1200. Credit 7.4.1.1 uses MSDS reportable chemicals to generate a list of chemicals that must be screened against Annex B to assess for chemicals of concern. Both 7.4.1.2 and 7. 4.1.3 require that materials be assessed for chemicals present at a concentration down to 100 ppm. This requires chemical information beyond that provided by a MSDS. Question E30: Continuing with the example above: The applicant has potential to earn up to three points under 7.4.1.3 because we're only talking about 6% of parts (by weight) that are wholly uncharacterizable for MSDS or Annex B chemicals and 6% is within the wiggle room of the 90% threshold. Is this correct? Consensus Opinion: Again, reference the previously established distinction between MSDS reportable chemicals and chemicals reported at 100 ppm. The applicant has the potential to earn up to 3 points based on assessing 90% of the product weight to 100 ppm. This requires chemical information beyond that provided by a MSDS. Question E31: Continuing with the example above: However, if the parts made up >25% (by weight), then the applicant could not receive any points under section 7.4.1. Is this correct? Consensus Opinion: Correct, if the applicant is unable to document materials that make up more than 25% of the product, they would not receive the points. Question E32: Continuing with the example above: In addition, the applicant would not be able to receive points under 7.5.1 since those points are contingent upon earning all four points under section 7.4.1.3. Is this correct? Consensus Opinion: Attaining points under 7.5.1 is contingent upon receiving the three points under 7.4.1.2 (intermediate level). Alternatively, the 7.5.1 credits can be contingent upon evaluating 99% of product weight under 7.4.1.3. Question E33: For Credit 7.4.2 Manufacturing Process Level (Process Chemicals), are MSDSs acceptable forms of compliance? The guidance document suggests MSDSs as a source of information. Consensus Opinion: MSDS sheets alone may not be enough to identify all chemical constituents to comply with the normative language as written. Question E34: For Credit 7.4.3 Maintenance/Operations Level, are MSDSs acceptable forms of compliance? The guidance document suggests MSDSs as a source of information. Consensus Opinion: MSDS sheets alone may not be enough to identify all chemical constituents to comply with the normative language as written. Question E46: In Section 7.4, the introduction references Annex B while Section 7.4.1.1 allows a point for identifying and assessing all MSDS reportable chemicals for materials that add up to 95% by weight of the final product, and doesn't specifically mention Annex B. Does Annex B need to be used or just MSDS reportable chemicals? Consensus Opinion: Under 7.4.1.1, yes, a product could earn a point if it meets the requirements stipulated by OSHA 29 CFR 1910.1200. Credit 7.4.1.1 uses MSDS reportable chemicals to generate a list of chemicals that must be screened against Annex B to assess for chemicals of concern. For the intermediate and advanced levels, the answer is no, because the required identification of chemicals has not been satisfied. Both 7.4.1.2 and 7. 4.1.3 require that materials be assessed for chemicals present at a concentration down to 100 ppm. This requires chemical information beyond that provided by a MSDS. Question E47: In Section 7.4.1.1, if a company is not based, or operating, in the United States and not subject to OSHA, how would they proceed? Consensus Opinion: The underlying intent of this credit is to use information as required by OSHA 29 CFR 1910.1200. In the United States this can be accomplished by using an MSDS. It is not the only way to show conformance. The organization must be able to provide chemical information that meets the requirements of the OSHA standard. Question E48: In Section 7.4.1.2, the assessment of chemicals within a product, requires information down to the 100 ppm level for chemicals found on Annex B. The question is around the physical state of those chemicals. For example, do I need to be concerned about the presence of carbon black, which is an additive used in order to achieve the specific color, however, this chemical is in an inert state after processing, and the risk of carbon black dust is no longer a potential once I receive my component and use it in my finished assembly. If this is the case, then do I need to address or mark down that carbon black is present within my product? Please note that most Stainless Steels used in our industry are Austenitic stainless steel and contain Nickel, so if the above direction is that this Carbon black is a concern in the finished state, then the usage of stainless would be of concern as well, right? Consensus Opinion: No, carbon black would not have to be identified as a chemical of concern if it is not present as an airborne, unbound particle of respirable size (as specified in Annex B) within the gate-to-gate boundaries. Yes, nickel would have to be identified as a chemical of concern in stainless steel as the standard does not include any qualifying requirement for exposure routes of nickel as it does with carbon black. The work group recognizes the limitations of this hazard based list approach where exposure routes are not taken into consideration. Question E49: 7.4.1.1, 7.4.2 and 7.4.3 ask that the chemicals listed on the MSDS are to be assessed for Human and Ecosystem and not use Annex B. The result will be that even the chemicals not listed on Annex B will also be assessed. Would you agree with this? For a basic introduction into section 7, it seems that more work is required than if Annex B was used. The guidance document for 7.4.2 and 7.4.3 indicates that MSDS can be used as a source of information, as long as it covers all of the materials, see below: - Collect and compile chemical information for the process chemicals used in each of the selected manufacturing processes: - Sources of chemical information include MSDS for each process chemical/formulation used. Supplemental information from the Supply Chain may be necessary. - Relevant chemical information includes the chemical name, CASRN and quantity of each chemical identified. In the absence of a CASRN, record “unknown”. The quantity of each chemical will most likely be expressed in units of mg/L, mg/Kg, ppm, % w/w, % w/v or % v/v. - Flag any chemical that is calculated to be present in the process aid / formulation at a quantity greater or equal to 1000 ppm. Consensus Opinion: No, Section 7.4 of the standard states: “The organization shall design safer products and processes by using design for the environment (DFE) protocol to identify and assess the human health and ecosystem health impacts of chemicals of concern by using reference lists in normative Annex B.” This language implies that Annex B shall be used to both identify and assess the chemicals present in the selected materials. The language prevails in all sub-credits unless explicitly stated otherwise as in Credit 7.4.1.1 where Annex B is not required for identification of the chemicals but it is required for assessment. In Sections 7.4.2 and 7.4.3, MSDS sheets alone may not be enough to comply with the normative language as written. 7.5 Reduction/Elimination of Chemicals of Concern Question E35: Is the second point in Credits 7.5.4.1 and 7.5.4.2 dependant on earning the first point? Consensus Opinion: No, the credits are independent. 7.5.4 Reduction of Hazardous Wastes and Air Emissions Question E36: Does 7.5.4 provide a di minimis threshold for qualifying HAP? Many common surface and fabric cleaners contain glycol-ethers, welding operations typically release metal HAP, machining conventional particleboard releases formaldehyde, powder coating operations release undetermined volatiles during the cure process; and in fact, even tap water releases chlorine. How should one quantify this type of HAP release? Consensus Opinion: HAPs should be quantified as identified on MSDS for production and process materials. 7.6 Low Emitting Furniture Question E37: I'm looking for someone to clarify how to go about testing our products for indoor air quality. We're having a debate over what is considered the worst case scenario and if one test can cover multiple lines of furniture. To explain: we make tables and chairs. For our tables we've done a table top separate and it covers all table top sizes. For the steel bases (of which we have multiple designs, but still just steel and powder coating) we tested a base with more surface area than any other design and use it as our worst case scenario justifying that all other steel bases will pass. We will do the same for aluminum bases as well. My question is, can this same strategy be used for seating, as long as the materials are the same and the worst-case scenario (most surface area) is tested. For the most part, all our chairs are made of the same materials, so we need to know if we could do one worst case scenario that has more surface area of each material than all the other lines of chairs. Or do we have to do a worst case scenario for each product line, due to the change in name of product? Consensus Opinion: Your assumptions are correct; you'll want to test the product that exhibits the worst-case potentials, both for greatest potential surface areas and including the materials (and/or finishes) with the greatest potential for emissions. If you group the products based on similar materials you should only have to test the worst case, regardless of product line name(s). The ANSI/BIFMA furniture emissions standards facilitate testing representative products to determine compliance of groups of products. The materials used, and the relative sizes (or surface area) are typically more important factors when determining representative products. Often products with the same or very similar materials can be represented by testing one representative product, even if the products are available under different names. It is also important to take manufacturing locations and associated suppliers into account. For example, a company could produce two products that appear to be identical but that are manufactured in different plants using materials from different suppliers. In this case, it may be appropriate to test each of the two different versions of this product. The key is to identify and focus on which materials are the potential worst-case sources of relevant VOC emissions. By conducting a series of small chamber screening tests on these materials, a manufacturer can determine which materials should be built into assembled products for seven day chamber testing. Working with the third-party certifier and testing laboratory can be a huge help in this area. The appendices in the ANSI/BIFMA M7.1 test method, as well as the representative sample guidance in the ANSI/BIFMA X7.1 standard both address this topic. 7.6 Low Emitting Furniture Question E38: A manufacturer has a product with only just enough points to achieve a given level of certification, and one of the points is for Section 7.6.1 or Section 7.6.2 where the product is compliant with private office requirements but not with the tougher open plan requirements. For example, a furniture system has achieved 32 to 44 points total, with only five product points, and one of the five product points is for e3 Section 7.6.1. Does the level™ certification for this product need to have the certification scope restricted to use in private offices? Consensus Opinion: Yes, if a product has enough total points to qualify for a given level but only had the minimum product points for the level and one of those product points included a restriction, then that restriction would apply to the level certification. Question E39: If a manufacturer has GREENGUARD, MAS, or SCS indoor air quality certified furniture, does that automatically qualify for credit under 7.6.1? Consensus Opinion: Possibly. However, the manufacturer should validate compliance of test methods and results to ANSI/BIFMA M7.1-2007 and ANSI/BIFMA X7.1-2007 by documentation of results. This may be accomplished by requesting documentation on the test report or certificate. As individual component criteria is not covered in the current ANSI/BIFMA X7.1-2007 any product outside of the current scope of the current ANSI/BIFMA X7.1-2007 would need further analysis, as referenced in paragraph 2 and 3 of Section 7.6 of the BIFMA e3-2008 standard, to show qualification for credit 7.6.1. Examples of individual components that would require additional verification include tables, file cabinets, and storage cabinets. Additional verifications can be supplied by the test laboratory or certification body. Question E40: If a manufacturer has furniture certified to GREENGUARD Children and Schools, MAS Certified Green, or SCS Indoor Advantage Gold, does that automatically qualify for credits under 7.6.2? Consensus Opinion: Possibly. However, the manufacturer should validate compliance of test methods and results to ANSI/BIFMA M7.1-2007 and the requirements of BIFMA e3-2008 Annex C. This may be accomplished by requesting documentation on the test report or certificate. Examples of criteria that are unique to Section 7.6.2 are the additional number of individual VOCs with criteria, as listed in Annex C, which must be compliant between 3 and 14 days. Note that seating must meet _ the limits for a workstation. Not all programs use these same requirements. Individual components would need further analysis, as referenced in paragraph 2 and 3 of Section 7.6 of the BIFMA e3-2008 standard, to show qualification for credit 7.6.2. Examples of individual components that would require additional verification include tables, file cabinets, and storage cabinets. Additional verifications can be supplied by the test laboratory or certification body. Section 7.6.2 Question F1: Will the relevant limit(s) for acetaldehyde in ANNEX C be updated to be based on the new December 2008 CA CREL value of 140 µg/m3 (i.e. 70 µg/m3 for workstations and 35 µg/m3 for seating) to be able to earn a point for credit 7.6.2? Consensus Opinion: Adopting this would be a substantive change to the standard and would require submittal to the Joint Committee for consideration. 8 Social Responsibility Question: It appears that the wording and use of the term “the organization” is not used consistently in section 8. The term “the organization” is used for credits that are facility or organization related per Annex D. We would like some clarity for sections 8.1.1, 8.1.2, 8.3, and 8.4 on what the credit boundaries for each credit are. Consensus Opinion: Annex D (the scorecard) and the Guidance Manual are both clear about the scope of the credits in question. In these credits, the word “organization” refers to the applicant organization. The applicant organization shall ensure that the policies and practices outlined in these prerequisites and credits are in place at the facility, or facilities, where final assembly occurs, regardless of whether the applicant organization owns or does not own the facility(ies).
This page updated 2011-03-03