By “not lishma” I meant printed sefrei kodesh. Things written by heretical sects and other religions were outside of the scope of that psak which I heard from someone who was gabbai seforim there about sheimos generated in his yeshiva.
Sam2: The din of Sefer Torah sh’kasvo min is a special din in a kosher Sefer Torah. If Phil Berg’s books are to be burned they would be burned as tashmishei a”z, not under the din you mentioned.