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The Public Right-of-Way Accessibility Guidelines (PROWAG) rulemaking has concluded. The PROWAG final rule has been published in the Federal Register. Please visit the Access Board’s PROWAG page for the guidelines.

Building Products & Materials


The goal of the NIBS–IEQ Products & Materials Committee was to develop procedures and guidelines to aid persons in making informed material selections in order to construct a building that will be accessible to persons with multiple chemical sensitivities (MCS) and/or electromagnetic sensitivities (EMS). The NIBS IEQ-Materials Committee has reviewed existing standards and guidance for materials selection in building construction. The group has determined that certain features of the existing standards offer a reasonable starting point for the selection of building materials, and in some respects can offer a more accessible environment to persons with MCS and/or EMS. These existing standards are designed to create healthier indoor air quality by making appropriate building material selections, among other things. Though the existing standards may not result in material selections that will make a building accessible to the majority of persons with MCS and/or EMS, they will produce a healthier building, than one constructed without regard to these standards. Healthier buildings would be useable by people with other health conditions such as asthma and other respiratory conditions, allergies and migraine headaches.

The NIBS IEQ Materials Committee has attempted to take the best ideas or practices from the existing standards and guidelines to recommend material selections that will provide for healthier, more accessible buildings. If a designer follows the suggestions provided herein, it will result in a building that has the lowest chance of IEQ problems stemming from the materials and that has the best likelihood of being accessible to persons with MCS and/or EMS.

The standards reviewed by the Materials Group include:

  • Collaborative for High Performance Schools (CHPS) Section 01350
  • Green Guard Environmental Institute—Certification Standards for Low Emitting Products for the Indoor Environment
  • Green Seal—Environmental Standards
  • Green Guidelines for Healthcare—Materials and Resources
  • Reducing Occupant Exposure to Volatile Organic Compounds (VOCs) from Office Building Construction Materials: Non-Binding Guidelines—California Department of Health Services

    Two of the key elements involved in the materials selection process are a component content screening (what chemicals and compounds are known to be a part of the material) and an emissions testing protocol. Both the California Section 1350 Specification and the Green Guard Standards recommend emissions testing based on the ASTM Method ASTM standards D-5116-97 and D-6670-01. The Committee believes that both of these elements must be involved in making appropriate building material selections.

Overview - Design

The Products & Materials Committee believes that particular attention is critical during building design to assure that the needs of chemically and electromagnetically sensitive people are accommodated to the greatest extent possible. In general, this means selection of construction materials that are low-emitting or non-emitting and selection of finishes that do not absorb or react with chemicals emitted by other materials or products in the building. To begin to address some of the concerns of electromagnetically sensitive persons, areas of the building can be designed to have reduced electromagnetic fields. By making indoor environments that are safer for the most vulnerable among us, we can create indoor environments that are healthier for everyone, especially children.

Generally, this means selection of materials that are “hard” or non-porous where possible so that any chemicals that contact these materials are not retained in and re-emitted from them. Also, particular attention should be paid to selection of materials that will not require VOC-emitting chemicals later as part of maintenance. For instance, in designing building foundations and structures, particular attention should be paid to the need for preventing termite problems, since the pesticides commonly used to control termites can have a deleterious effect on humans, especially persons with multiple chemical sensitivities. So, even though the material itself might be low-emitting, the use of products meant to “preserve, protect, or maintain” the material selected might emit volatile fumes that degrade indoor environmental quality and result in a building that is not suitable for persons with MCS.

In addition, during building design particular attention must be paid to choice of electrical appliances, equipment and products that may produce higher than necessary electromagnetic fields. The NIBS-IEQ Materials Committee recognizes that there are selections that can be made during building design and construction that can provide a more healthful environment for persons with electromagnetic sensitivities. A few of these considerations are:

  • Incorporation of a foil vapor barrier or other metal shielding feature into the walls around electric equipment can reduce certain electromagnetic fields.
  • Wireless (“bluetooth” type) connections should be avoided, or areas of their use should be “contained” by using foil-backed drywall or other incorporation of a foil or metal barrier.
  • New construction should use twisted metal clad wiring and/or twisted wire placed in metal conduit.
  • Fiber optic connectivity is preferred for computer networks communication because these data lines may be run without concern for stray emissions.

Overview – Building Operations and Maintenance

Vigilance is required to assure that materials brought into the building throughout the course of its life are consistent with the standards provided herein, and are consistent with the design intent of the building.

For example, the Products & Materials Committee realizes that building operations and maintenance products might introduce materials that are not consistent with the initial design for an accessible, healthy building.

Building managers must also pay close attention to materials brought into the building environment by tenants or others to assure that these materials are consistent with provision of an accessible, healthy building for persons with multiple chemical sensitivities, electromagnetic sensitivities, and/or other health disorders. For instance, a tenant may bring furniture in that does not meet the design criteria presented in this document, and these materials could have detrimental effects on air quality within the entire building, depending on the design of the HVAC system. In addition, the chemicals and compounds used for maintenance can degrade environmental quality and seriously affect persons with multiple chemical sensitivities. Other products that can have detrimental effects on IEQ and/or certain individuals include paints and other finishes, carpeting, appliances and other electrical equipment, and others.

CHPS Section 01350 Part 1.3B and 1.4D and GREENGUARD Allowable Emission Levels

The NIBS–IEQ Products & Materials Committee believes that the CHPS Indoor Air Quality Emissions Testing Standards and the Green Guard Allowable Emission Levels offer tested and reviewed approaches to material and product selection for buildings. Given the range of guidance and standards available for material selection, these two standards provide the most widely accepted processes for making material selections to construct buildings that are healthier for the general public. It should be noted that the NIBS–IEQ Products & Materials Committee does not believe that either of these standards offers an entirely acceptable solution for persons with MCS and EMS. However, they provide a starting point in making material selections, and they provide the best available guidance on component screening and materials emission limits. Making materials selections that meet either the CHPS or the Green Guard allowable emission levels should be considered an absolute minimum requirement in creating a building or environment that is accessible to persons with MCS and EMS. No designer or other person making material selections should choose any materials that do not at least meet these standards. Even then, the other considerations discussed herein should be a part of the selection process to provide the best opportunity that the building will provide an environment accessible to persons with MCS and EMS.

The Green Guard Certification Standards list allowable emissions for a range of building products. A designer or other individual making a material selection must investigate product literature, for the material under consideration, to determine if the product meets at least the Green Guard standards. The Green Guard web site lists products that have been tested and have met their standards. However, it is possible that a product manufacturer has not submitted their product for certification to either Green Guard or CHPS. In this case, the person making a material selection must seek any published emissions testing data and product component data available from the manufacturer. Some manufacturers publish data on emissions from their products, and other manufacturers are moving quickly to provide such data. If such data is not currently published, the manufacturer must have the product or material tested in accordance with the testing regimen specified in the Green Guard or CHPS 01350 Certification Standards.

The CHPS Section 01350 protocols and the Green Guard Certification for IAQ data require the same chamber testing. The CHPS protocols and calculations go further than the Green Guard Certification Standards in that the designer is required to take published emissions rates and perform calculations based on the amount of material to be installed in the building and the zones and air handling capabilities of the HVAC systems in those zones. Also, the allowable emission level for formaldehyde is lower in the CHPS standard than the Green Guard standard. See the discussion below for more information on formaldehyde.

For both standards, all building materials are required to be tested in dynamic environmental chambers following ASTM standards D-5116-97 and D-6670-01, the U.S. Environmental Protection Agency’s testing protocol for furniture and the State of Washington’s protocol for interior furnishings and construction materials. Products are measured for emission levels according to the parameters set forth in the ASTM Standard for emissions testing.

California – Practice for Testing of VOC’s from Building Materials Using Small Chambers

The allowable emission levels of both standards can be found by clicking on the links below. In some cases, the Green Guard standards may appear to have lower standards for emissions of some VOCs than the CHPS Section 1350 standards. However, the person selecting materials for the building must bear in mind that the CHPS standard requires a detailed calculation for the building, the amount of material to be installed and the air change rate of the HVAC systems. Green Guard emissions standards are based on a “standard” model of a building, and a “standard” exchange rate of fresh air in the building.

CHPS Section 01350

CHPS Compliant Materials Table

Green Guard Allowable Emission Levels

Green Guard Certified Product Guide

Additional Resources

California Department of Health Services IAQ Program Voluntary Guidelines for Reducing Occupant Exposure to VOCs

California Materials Emissions Study

U.S. EPA Indoor Environment Program web site—VOCs


Formaldehyde is widely used by industry to manufacture building materials and numerous consumer products. It is also a by-product of combustion and certain other natural processes. Formaldehyde, by itself or in combination with other chemicals, serves a number of purposes in manufactured products. For example, it is used to add permanent-press qualities to clothing and draperies, as a component of glues and adhesives, and as a preservative in some paints and coating products.

In building materials, the most significant sources of formaldehyde are likely to be pressed wood products made using adhesives that contain urea-formaldehyde (UF) resins. Pressed wood products include: particleboard (used as sub-flooring and shelving and in cabinetry and furniture); hardwood-veneer plywood paneling (used for decorative wall covering and used in cabinets and furniture); and medium density fiberboard (used for drawer fronts, cabinets, and furniture tops). Medium density fiberboard contains a higher resin-to-wood ratio than any other UF pressed wood product and is generally recognized as being the highest formaldehyde-emitting pressed wood product.

Other pressed wood products, such as softwood plywood and flake or oriented strandboard, are produced for exterior construction use and contain the dark, or red/black-colored phenol-formaldehyde (PF) resin. Although formaldehyde is present in both types of resins, pressed woods that contain PF resin generally emit formaldehyde at considerably lower rates than those containing UF resin.

The NIBS–IEQ Products & Materials Committee is concerned about human exposure to formaldehyde, especially for individuals with multiple chemical sensitivities. The widespread use of formaldehyde, its known health effects, and the hyper-sensitivities of certain individuals create this concern. It may not be possible to make material selections that are completely free of formaldehyde, but where possible, the individual making material selections should make every effort to avoid products manufactured with formaldehyde. New soy-based adhesives are coming on to the market to replace formaldehyde resins used in many manufactured wood products. It may soon be possible to choose alternative products that are not formulated with this volatile organic compound (VOC).

The California Office of Environmental Health Hazard Assessment has determined that the lowest, reasonably achievable level of formaldehyde (because it is equal to ambient air concentrations) is 33 (milligrams per cubic meter) ug/m³, or 23 (parts per billion) ppb. Thus, the CHPS 01350 standard requires that a material must not emit a level of formaldehyde that results in a concentration of ½ of this level, or 16 ug/m³ (11 ppb). This limit is lower than the allowable emission level of the Green Guard standard. The NIBS–IEQ Products & Materials Committee believes that the 16 ug/m³ (11 ppb) level is a minimum requirement for formaldehyde emissions from building materials.

Following is a list of typical building materials and some considerations for selection. Note that the considerations listed below are in addition to the recommended emissions standards from CHPS 1350 and Green Guard.

Adhesives and Sealants

One objective of the IEQ–Products & Materials Committee is to reduce the quantity of indoor air contaminants created by adhesives and sealants that are potentially irritating and/or harmful to occupants of buildings. The use of VOC-emitting adhesives and/or sealants should be minimized to the greatest extent possible in order to create an accessible, comfortable environment for the greatest numbers of people.

The designer should specify application of only the minimum amounts of these materials necessary for satisfactory completion of each installation task. Additionally, the designer should select products that have the lowest possible VOC emissions, according to the emissions testing information provided, 00 while still meeting other performance requirements. Caution should be exercised when interpreting adhesive emission data because such data are usually provided without the associated installed products (e.g., flooring materials) and emissions from installed assemblies may differ from manufacturers’ reported adhesive emission rates. If possible, adhesives that contain formaldehyde should be avoided.

The Committee also recommends that paints and finishes be selected that do not contain biocides.

In any building where adhesive use is necessary, it is a good practice to ensure that maximum ventilation is supplied during and after application of these products.


Appliances can emit volatile fumes as well as create electromagnetic fields.

Electromagnetic fields and radiofrequencies can jeopardize the functioning and safe access of electromagnetically sensitive individuals. Examples of indoor appliances which can provoke health problems include:

  • cell and portable telephones,
  • fluorescent lights,
  • unshielded transformers and wiring,
  • battery re-chargers,
  • wireless devices including computers and personal communication services (“PCS”),
  • security and scanning equipment,
  • numerous common work place and household electronic appliances.

Many electrical appliances and equipment can be improved to varying degrees by appropriate shielding, and/or by being located in areas remote from vulnerable individuals.

It is not recommended that such equipment be eliminated from the built environment, but that exposure of vulnerable individuals to such equipment be voluntary or easily avoidable.


Of particular concern to the NIBS–IEQ Products & Materials Committee are T-bar suspended ceilings used as return air plenums in buildings, because both sides of the panels come in contact with indoor air. In addition, penetrations for sprinklers, alarms, and smoke detectors may significantly increase the area exposed to emissions. Temperatures near ceiling surfaces and in return air plenums are usually higher than those in occupied zones and, as a result, increased emissions from ceiling materials may occur. The individual selecting ceiling materials should carefully consider the acoustic, fire, and aesthetic requirements for each space prior to material selection. Nonporous materials are now available that combine aesthetic, acoustical, and fire code requirements.

Ceiling materials that contain organic materials present the possibility of mold contamination if the ceiling system becomes wet. Porous ceilings and ceiling finishes can also act as receptors for toxins and VOCs that are brought into the building and later re-emit them. Many ceiling tile products are made using urea formaldehyde. No products using urea formaldehyde should be allowed.

Composite Wood Products (plywood, particle board, OSB, paneling, etc.)

Because they emit formaldehyde and other VOCs, use of composite wood products should be minimized, if not eliminated. If it is absolutely necessary to use such products, the designer should select materials that meet the specified building criteria and are the lowest emitting products available according to emissions testing data. Formaldehyde emissions are of particular concern in composite wood products. Note that VOC-emitting wood preservatives may be used in some of these products. There are a number of manufacturers that are replacing formaldehyde adhesives in composite wood products with non-emitting adhesives and the Committee recommends using these alternative products whenever possible.


The use of fireproofing chemicals should be minimized when possible. Spray-on fireproofing can cause indoor air quality problems when chemical components are released into the air as a result of mechanical damage, air erosion, or deterioration of the binder. Also because spray-on materials have large, porous surface areas, they can act as sinks for adsorption and re-emittance of VOCs. If possible, seal the surface of spray-on fireproofing to reduce adsorption of VOCs. Ensure that the sealer: (a) will not change fire characteristics of the original fireproofing material; and (b) is not a high-VOC emitter. Also seal any penetrations of surfaces sprayed with fireproofing material to prevent damage of the material in the vicinity of penetrations.

Flooring & Floor Systems

The NIBS–IEQ Products & Materials committee recommends use of flooring products that are low or non-emitting and are non-porous. Consideration should also be given to maintenance products that will be necessary for the type of flooring selected. For instance, stripping and refinishing of wood flooring introduces hazardous chemicals into the air and are intolerable for persons with multiple chemical sensitivities. When selecting a floor system, the type of adhesives used with the flooring system must also be considered.

Stone, terra cotta, granite, marble, terrazzo, ceramic, brick, or sealed concrete flooring are best tolerated by individuals with chemical sensitivities, and provide a healthy, comfortable environment for the greatest number of people.

Wood flooring that has not been recently stripped or refinished and older vinyl flooring is also often well tolerated by people with chemical sensitivities.

Rubber, linoleum, and cork flooring are not recommended.

The Resilient Floor Covering Institute (RFCI) has recently introduced a new certification program for low emitting flooring products called the FloorScore™ program. The FloorScore program is a building materials emissions testing program that requires both independent laboratory testing and third-party certification to show compliance with CCHPS 01350 VOC emissions limits and includes certified site audit and documented control system requirements. The third-party certifier, Scientific Certification Systems, Inc. (SCS), not only reviews the results of the product VOC emissions report but also reviews raw material inputs and manufacturing processes to ensure that a product is consistently manufactured. SCS conducts site audits of manufacturing plants to ensure a quality management plan exists for continuing compliance of the product as defined in SCS-EC-10-2004 Environmental Certification Program—Indoor Air Quality Performance.

Resilient Floor Covering Institute—“Floor Score” Program

Floor Score List of Certified Products

Carpet systems contain a myriad of chemicals in their fiber, dyes, backing, padding, bonding agents, adhesives, antimicrobials, flame retardants, and stain resistance, anti-static, and color fast agents. They are reservoirs for tracked-in pesticides, dust, dust mites; foster mold growth; and absorb and re-emit volatile organic chemicals like fragrances and paint fumes. In addition, many solvent-based agents used to clean carpets emit toxic fumes.

The Carpet and Rug Institute (CRI) has established a rating system that involves emission testing that is based on CHPS Section 01350, and includes additional requirements. Carpets labeled with the CRI Green Label Plus are expected to have lower emissions than most carpets. However, even carpets emitting low levels of volatile organic chemicals (VOC’s) can cause adverse health effects in certain individuals.

CRI Green Label Plus

Some people with multiple chemical sensitivities have found that carpet squares with self-adhesive backing have been the best tolerated new carpeting. Others have reacted adversely to such products. More research is necessary to determine what factors in these carpets and/or which brands are best tolerated.

Older carpets are usually better tolerated by people with chemical sensitivities than new ones, as long as they have not become moldy.

Recommendations regarding carpeting (design, materials, and O&M issues):

  1. Minimize the use of carpeting
  2. Use area rugs in place of carpeting whenever possible
  3. Consider using self-adhesive carpet squares
  4. Tack rather than glue down (unless using self-adhesive carpet)
  5. If glue down, use low or no VOC adhesive
  6. Air out carpet for at least two weeks prior to installation
  7. Ventilate building with 100% outside (or fresh) air for as long as possible after installation
  8. Reduce the frequency of carpet replacement by maintaining them well (e.g., vacuum thoroughly and frequently and clean with low toxic products and procedures—(See recommendations by Operations & Maintenance Committee).
  9. Minimize amount of carpet that is replaced, limit replacement to damaged areas (an advantage of carpet square systems is that smaller sections can be more easily replaced).


The NIBS–IEQ Products & Materials committee realizes that insulation is an essential component in building systems to assure a comfortable environment. Insulation and insulating materials are generally hidden or covered, however emissions can still be encountered by building occupants. The Committee believes that polystyrene foam insulation is best tolerated by persons with multiple chemical sensitivities. Other insulating products, such as fiberglass, cellulose, or cotton/polyester blend insulating products may produce particulates, harbor mold, or emit problematic volatile fumes, depending on the product and the manufacturing techniques used.

The Committee has particular concerns about interior lined ductwork, due to the insulation’s ability to collect and trap chemical contaminants, dusts, microbes and fungi, as well as emissions from the adhesives used to secure the insulation. It is recommended that no interior-lined ductwork be used in the construction of buildings meant to be accessible to persons with MCS.

Lastly, insulation used anywhere in buildings must not contain urea-formaldehyde resins.


The NIBS–IEQ Products & Materials Committee determined that for some individuals, 100% acrylic paint and paints containing low-VOC emissions can be acceptable. Paints containing styrene-butadiene latex combinations, enamels, strippers and paint thinners are all problematic and should be avoided or their use minimized.

For some individuals, well-hardened enamel paint, baked-on enamel finish, or porcelainized steel provide optimum safety. These products provide a hard, durable surface that can be easily cleaned using non-toxic products.

Paints with biocides or biocide additives (mold/mildew resistant) should not be selected.


The NIBS–IEQ Products & Materials committee recommends sparing or no use of textiles in buildings. Though it may be possible to introduce textiles with no emissions, textiles provide a porous medium to trap chemical contaminants, dusts and microbes that can create an unhealthy environment. In addition, the dry cleaning and laundering of textiles poses additional problems due to the cleaning products.


Gypsum wallboard: Gypsum may be reasonably inert and extremely low in VOC emissions. However, additives used to produce mold-proof gypsum wallboard (i.e., “green board”), fire-resistant gypsum wallboard, or to improve the workability of the slurry during manufacture may include compounds that emit VOCs. Careful product selection and review of emissions testing data is necessary to assure that appropriate materials are chosen. Recycled paper covering both sides of gypsum wallboard may contain chemicals from previous uses, and additives or chemicals used in the production of the paper itself. Note that VOC emissions from gypsum wallboard can sometimes be significantly reduced by “painting” or laminating the surfaces. The more impervious the coating or covering, the greater will be the reduction in VOC emissions from gypsum wallboard. However, VOC emissions from surface treatment materials must be considered.

Gypsum wallboard can act as a sink for other VOCs in indoor air. Avoid exposing unpainted gypsum wallboard to indoor environments where emissions from other VOC sources exist. Taping and topping compounds can contain considerable quantities of VOCs, so emissions testing data for these products is also critically important. Use ventilation and heat to accelerate the drying process of these materials. Protect wallboard from exposure to contaminants and excessive moisture prior to installation.

Where possible, select material to reduce the need for paints, wallcoverings, or porous wall finishes in buildings. Most commercial structures are built using metal studs, a good selection for persons with MCS. Wood studs can emit terpenes and pinenes.


Wallpapers may contain vinyl, plasticizers, styrene-butediene latex combinations and other chemicals that can seal and trap moisture between the wallpaper and the wall fostering mold growth. The water-based pastes and glues used to adhere the wallpaper to the wall may contain mold retardants and pesticides. Adhesives can emit volatile fumes. For these reasons we recommend that wallpapers not be used.

Conclusion & Recommendations

In order to minimize the level of air pollutants emitted from building materials and create healthier indoor environments, the NIBS–IEQ Products & Materials Committee recommends that inert, non-porous materials be used to the greatest extent possible. This will increase access for the greatest number of chemically sensitive individuals. Choosing appliances and other equipment that create the lowest level of electromagnetic fields will increase access for those with electromagnetic sensitivities.

If materials are used that emit volatile fumes, the Committee recommends that these materials meet or exceed the CHPS Indoor Air Quality Emissions Testing Standards or Green Guard Allowable Emission Levels, as well as contain no formaldehyde or biocides. The Committee also recommends that, whenever possible, products and materials be aired out (preferably outside or in a separate well-ventilated space) for two weeks prior to being installed in a building.

While the Committee acknowledges that the CHPS Indoor Air Quality Emissions Testing Standards and Green Guard Allowable Emission Levels are the best current standards for selecting building materials that create healthier buildings, the Committee is concerned that these standards may not sufficiently protect the health of building occupants, especially those with chemical sensitivities and other vulnerable individuals.

Therefore, the Committee supports:

  1. Creation of more stringent emission standards and development of a wider range of less volatile and less hazardous building materials, especially in the areas of resilient flooring and carpeting.
  2. Full disclosure of product ingredients (on product labels or available upon request) to enable builders to make more informed decisions regarding selection of building materials.
  3. Consulting with chemically and electromagnetically sensitive individuals or organizations, especially employees and others who frequently use a building, prior to making final decisions regarding product selection.

Committee Members


Chair—Brent Kynoch, Kynoch Environmental Management, Inc.
Mary Lamielle, National Center for Environmental Health Strategies
Ann McCampbell, Multiple Chemical Sensitivities Task Force of New Mexico
Susan Molloy, National Coalition for the Chemically Injured
Toni Temple, Ohio Network for the Chemically Injured


Terry Brennan, Camroden Associates
Dave Rupp, Cabinet King, Inc.


Mike Preston, Burt Hill Kosar and Rittelman Associates