Deciphering GBCI Rulings on Product Docs for LEED Projects
LEEDUser guest author Dave Hubka is sustainability practice leader at architecture firm EUA and has been working with sustainable design and LEED for 20+ years.
Hunting for documents when compiling a LEED application can be quite the adventure. The task requires a seasoned LEED explorer ready to battle the elements while crossing oceans, ascending mountains, and traversing deserts.
The task requires several lifelines in the form of product search engines like Ecomedes, UL Spot, Mindful Materials, Sustainable Minds, and Green Badger (my personal favorite—this ingenious platform functions as my “ruby slippers”).
Once a declaration, action plan, or testing report is found—Eureka!
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But wait, there’s more.
Beware: even the fine print has fine print
Like the French philologist who deciphered the Egyptian hieroglyphics of the Rosetta Stone, the LEED explorer must decipher this document to know whether it meets all the LEED requirements. A great deal of time may be required to ensure all the necessary information lies within – perhaps not the 20 years it took to decipher the Rosetta Stone – but it sure feels like it some days!
With bated breath, each QC checklist item is marked off until all requirements are confirmed. This ‘holy grail’ of documents is then uploaded to LEED Online and sent off for review by Green Business Certification Inc. (GBCI).
A month later, our LEED explorer receives an email that takes precedence over all other emails of the day. They have been notified that the LEED review report is ready.
Opening a LEED review report is akin to unwinding time itself. It commands a lifetime to process within just a few moments.
While it may be written in font size 4, the sentence “certification date of the test must cover the date the product was made” feels larger than life. Perhaps we will need a French philologist once again.
Next stop: the reference guide
A succinct list of pertinent dates would sure help with our journey through technical documentation. Here are four valuable dates listed within the LEED v4.1 July 2023 reference guide.
- Product declarations (Environmental / Health) must be valid at the time the product was produced.
- Life-Cycle Action Plans are valid for four years.
- Ingredient Action Plans are valid for five years.
- VOC / Emission testing reports must be less than three years old.
- Environmental Product Declarations and Material Ingredients—Product declarations include a date they expire. All product declarations must be valid at the time the product was purchased for the project.
- Environmental Product Declarations Option 2 (Life-Cycle Action Plan) and Material Ingredients Option 2 (Ingredient Action Plan)—Action plans include a date they were issued. Products that claim this action plan must be purchased before their expiration date. (Within four years for a Life-Cycle Action Plan and within five years for an Ingredient Action Plan.)
- Low-Emitting Materials—Emission testing reports include a certification period that is most typically three years in length. Products that claim this report must be purchased within this certification period.
Now it gets fun!
Looking at past LEED review reports, GBCI messages can feel as tangled as a pit of asps due to the complexity of product testing, manufacturing, and shipping as they relate to project phases and timelines.
Some examples (you can find some in this LEEDuser forum thread as well):
- GBCI may allow a product declaration to be valid if “selection” occurred prior to the expiration date.
- GBCI seems to allow claims up to five years old. Teams applying the guidance from the November 2020 addenda would probably be held to the three-year requirement. The time period is taken from when the product was selected by the design team.
- GBCI has explained to me that reviewers are checking that test report dates for Low-Emitting Materials overlap with the estimated manufacturing date of the product.
- More generally, GBCI has said that reviewers should accept a certificate with a certification period that overlaps the project’s estimated design/specification phase OR up to roughly a year before construction.
The one-year rule of thumb + four examples
Based on this key, it would appear that we may have success when specifying products with current declarations, action plans, and testing reports. This is typically within the 12 months prior to the start of construction.
Here are four examples.
Declaration has a date of issue September 7, 2020 and a period of validity of five years
- As long as this product is purchased by the contractor prior to Sept 7, 2025, it can still contribute to Environmental Product Declarations.
- As long as September 7, 2025, is after the start of construction, then the declaration should contribute.
- If construction starts after September 7, 2025, I believe GBCI would not allow the declaration to contribute.
Life-Cycle Action Plan has a creation date of September 7, 2020
- GBCI appears to be lenient with product selection dates as long as they are assumed to be within the 12-month window.
- As long as the design team specifies the product prior to September 7, 2024, it can still contribute to Environmental Product Declarations.
Greenguard Gold lists a certification period of September 7, 2017 to August 9, 2023
- The product would need to be specified within that time period.
The VOC emission test date is September 7, 2020
- The product would need to be selected before September 7, 2023 (or maybe September 7, 2025?) for this product to contribute to Low-Emitting Materials.
Second rule of thumb: explain yourself to GBCI!
Checking certifications, action plans, and testing dates during the specification phase is not enough: when you submit your application, make things easy on your team and your GBCI reviewer by providing an explanatory note within the LEED application.
The adventure of reviewing LEED documents can be daunting, even for the most seasoned LEED explorer. Understand that you are not alone and that all our missions—manufacturers, clients, consultants, designers, contractors, and GBCI reviewers—are aligned. Together we are venturing to transform how we design and construct our buildings. It takes all of us to spin this blue marble more sustainably.
Product manufacturers are at the forefront. Maintaining product certifications is key to ensuring that the built environment is a more environmentally and socially responsible, healthy, and prosperous port of call.
“So we beat on, boats against the current, borne back ceaselessly.”
–F. Scott Fitzgerald