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LEED 2012 – 2nd Public Comment – Indoor Environmental Quality (IEQ) Section

Key changes in the the Indoor Environmental Quality (IEQ) section of LEED-NC (part of LEED BD&C) in the second public comment draft of LEED 2012 are discussed below.
August 1, 2011

 Do you have comments or questions on this draft? Discuss them below with your fellow LEED professionals. Substantive comments posted here during USGBC's second public comment period  will be submitted to USGBC and considered "official" public comments.

More information on LEED 2012 certification and the second public comment

Indoor Environmental Quality (IEQ)

Major Changes

In a small but meaningful change for Schools projects, projects unable to meet the Minimum Acoustical Performance prerequisite due to limited scope of work can submit a narrative explaining their design decisions.

The Outdoor Air Delivery Monitoring, Increased Ventilation, and Indoor Chemical and Pollutant Source Control credits have all been eliminated.

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There is a new Enhanced Indoor Air Quality Strategies credit (1–2 points), which is largely a repackaging of key requirements from those eliminated credits. Option 1 in this new credit (1 point) includes the key track-off, exhaust, and filtering requirements from LEED 2009’s IEQc5, and includes the key natural ventilation requirements that are part of IEQc2: Increased Ventilation in LEED 2009. Option 2 for this credit requires meeting Option 1, plus requirements that are similar to LEED 2009 requirements for increased ventilation over ASHRAE 62.1 and for outdoor air delivery monitoring. Those requirements are a bit more sophisticated, however, incorporating use of modeling to show that air contaminants will be below key exposure levels.

The second draft of LEED 2012 brings us a second major overhaul of Low-Emitting Interiors (1–3 points), although the overall systems approach introduced in the first draft remains. In that system, the building interior is organized into five systems: flooring, ceilings, walls, thermal and acoustic insulation, and furniture (which must be included if it is in the scope of the project). In this draft, rather than accumulating points by complying with the requirements of one or more systems, projects would try to improve their “total % compliant” score. This score would be an average of the “% compliant” score for each of the key systems. Projects don’t have to be perfect in any of the areas: 50%–70% compliance gets 1 point, 70%–90% gets 2 points, and 90% or more gets three points, and 90% or greater compliance in a single area is considered 100% compliance for the purpose of the average. Projects not making an effort in any major category will be penalized: less than 50% compliance in a single area is considere 0% for the average. Percent compliance is based on surface area for walls, floors, and ceilings, and on cost for furniture. Products will need to show compliance with the 35 VOC emission limits within the California Department of Public Health (CDPH) Standard Method V1.1-2010, often referred to as California Section 01350, and they will also need to report their total TVOC levels.

Indoor Air Quality Assessment (1–2 points) is the new name for Construction IAQ Management Plan—Before Occupancy. The big change here is that the Option 1 flush-out path preferred by most LEED projects would be downgraded to one point, versus two points for Option 2: Air Testing. (Testing better ensures lower levels of contaminants, but introduces more uncertainty for project teams.) Changes to the testing requirements include specification that typical ventilation rates be used, and there are also changes to the chemicals. Testing of carbon monoxide and 4-PCH would no longer be required, but all target chemicals under CDPH Standard Method V1.1-2010 would be. In other changes, furniture would have to be installed, and samples from the entire building and “representative situations” would be explicitly required.

The new Interior Lighting credit (1–2 points) covers the scope of the LEED 2009 “Controllability of Lighting” credit, which falls under Option 1 (1 point), and Lighting Quality can optionally be pursued for a separate point under Option 2. Changes to the lighting control requirements put specific emphasis on providing three lighting levels (or “scenes”) for individual and multi-occupant spaces: on, off, and mid-level. For lighting quality, projects would have a choice of meeting four (changed from five under the first draft) out of eight (changed from 12) quality measures. These measures include color rendering index (CRI) requirements and use of reflective surfaces.

An Acoustic Performance credit (1 point) was previously only available to Schools projects remains available to NC projects in this draft. However, it has been overhauled: in place of a fairly vague, performance-based approach, projects would now have to achieve numerous, specific acoustical ratings defined in the credit language.

Minor Changes

Minimum IAQ Performance (required) still references minimum ASHRAE-62.1 requirements. Outdoor air delivery monitoring requirements are included for CS projects.

Environmental Tobacco Smoke Control sees a fine-tuning of requirements rather than any major change (such as absolute prevention of smoking). Non-smoking requirements extend to outdoor spaces used for business purposes, like patio seating. Language for residential projects that specifically prohibited smoking on balconies is eliminated.

Requirements for a Construction IAQ Management Plan during construction are remain largely unchanged (with some adjustments to wording), but have become a prerequisite instead of a credit.

The Thermal Comfort credit (1 point) is updated to newer standards such as ASHRAE 55-2010, but is otherwise mostly unchanged.

The Daylight credit (1–3 points), overhauled in the first draft of LEED 2012, doesn’t see many additional changes in this second draft. Two simulation options remain, Option 1: Simulation – Daylight Autonomy (2–3 points), and Option 2: Simulation – Illuminance Calculations (1–2 points). A third option, Measurement, remains for one point. With a new 90% threshold for Options 1–2, this credit has more value compared with LEED 2009.

The LEED 2009 credit on views became Quality Views (1 point) in the first LEED 2012 draft, and thus it remains. USGBC has tweaked some of the calculation details, noting, for example, that if fixed window treatments are used for the credit, occupants should be able to discern movement and faces through the treatment.

What do you think of the proposed changes for LEED 2012? Post your thoughts below.


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September 15, 2011 - 1:31 am

EQ PREREQUISITE: MINIMUM INDOOR AIR QUALITY PERFORMANCE: No Comment, other than I look forward to improvement of consistency for reviews. It seems that for as simple as the goal of this prereq, engineers have an awfully hard time satisfying the reviewers.
EQ PREREQUISITE: ENVIRONMENTAL TOBACCO SMOKE (ETS) CONTROL: When a city has an ordinance. No matter if it is more stringent or not. It should trump the LEED rules for this pre-req. Follow the Law of the Land and easily get this pre-req.
EQ PREREQUISITE: CONSTRUCTION INDOOR AIR QUALITY MANAGEMENT PLAN: Smart move to make this a prereq because everyone does it. I am just afraid that we have taken out SO MANY of the easy points that Certification will take a major jump compared to last time out. It does not feel like an incremental improvement after my review.
EQ CREDIT: OUTDOOR AIR DELIVERY MONITORING: Why is this credit going away? Seems like if you are requiring minimum ventilation we should provide a point for limiting it when not needed.
EQ CREDIT: LOW-EMITTING INTERIORS: This seems to be more complex, but I do like the idea of not having to track down a million cut sheets every single time.
EQ CREDIT: INDOOR AIR QUALITY ASSESSMENT: I like taking out CO and 4-PCH and adding Ozone.
EQ CREDIT: INTERIOR LIGHTING: Calculations for such a credit seem heavy on documentation and light on actual effectiveness on the intent.
EQ CREDIT: DAYLIGHT: I am so glad the calculation has been taken out, it was very onerous and the simulations are pretty mainstream at this point.
EQ CREDIT: QUALITY VIEWS: I like the change to include a minimum distance outside the glazing.

September 9, 2011 - 3:58 pm

I’d personally like to hear input from architects and project teams on some fundamental questions regarding coatings and sealants.

I’ll share my perspectives as a starting point for you to either build up or tear down. Either way, we collectively need some real world perspectives on the subject and that shouldn’t always be from NGOs, laboratories, certifiers and manufacturers (that’s me). Questions:

Is the proposed Low-Emitting Interiors credit system workable?

If you don’t think it is workable, what changes could you suggest?

Would you use the credit system as it exists and to what level of credit attainment?

The credit language is designed with specific goals in mind, but as a specialty product manufacturer I am concerned about attainability with regards to coatings and sealants since the credit is based on having conformant product on every layer in a given interior surface.

Being new to the IEQ TAG, I talked with someone who helped write the draft to better understand how the layer approach works. I’ll use a school floor as an example (and hope I get it right). Many schools contain a mixture of finished and decorative concrete and various coverings such as carpet and resilient materials. Throw in a locker room, a wood floored gymnasium and swimming pool and the materials list gets quite a bit longer. Our theoretical school has the following materials: carpet, linoleum, recycled rubber tiles, concrete curing compound, concrete stain, concrete hardener, concrete finish, epoxy in the locker rooms and laboratories, control joint sealants, a swimming pool coating and high-durability wood coating and line striping for the gym. That’s just for the floors.

In order to contribute to credit, every one of these materials would require testing. Any area with multiple layers where any one layer is not tested would not be eligible for credit. To put that in perspective, a concrete floor might have a general application of a curing compound and a hardener with carpet and adhesive applied over it. Even if every other material is tested, an adhesive that was not CDPH tested would cause that entire area to not count towards the credit percentage thresholds. That concerns me both for the ability of a project team to actually attain the credit and for my tested products to actually be counted should another layer not make it.

I’ve been monitoring comments and questions on related NC2.2, LEED for Schools and LEED 2009 LEEDUser forum areas. Many of the project team questions are related to proper VOC category assignments for specialty coatings. I have to assume this means the product’s manufacturers haven’t figured out how the LEED credit works to the point of assisting the project team with credit attainment.

If specialty product manufacturers are having trouble with assisting on credit attainment now based on straight regulatory compliance, what indicates the situation will improve with added layers of complexity?

I’m not an architect, but have heard frustration with the complexity of the regulatory VOC management systems in the context of LEED. I share your pain as the person responsible for figuring out how to make sure my employer keeps on the right side of the regulations and with personal legal liabilities should I fudge the numbers. However, as frustrating as that is, regulatory compliance is a basic requirement for market access in our rapidly multiplying area and state jurisdictions. I wish VOC compliance was like the IPC where all pipes are created equal in every state.

I agree that from an architect’s perspective a simple pass/fail based on CDPH emissions testing must appear less complex than the byzantine VOC regulatory system.

I’ll present a manufacturer’s perspective. Figuring out how to play in the CDPH emissions testing world is complex and foreign to the vast majority of coatings manufacturers compared to the VOC regulations we already have to follow. It adds staff and monetary overhead to products we opt to have tested. This includes opportunity cost for small formulators where we have to choose between R&D and customer support or navigating CDPH product and substrate prep, shipping, chain of custody forms, Certificates of Conformance and report management. Over 60% of coatings manufacturers have fewer than 100 employees to design, make, promote and distribute products. Around 50% have fewer than 50 employees. Even large manufacturers have to consider overhead costs for their individual SKUs. I know of one major coatings manufacturer with over 40,000 SKUs.

Like it or not, we live in a cost/benefit world. I support PROSOCO’s testing and certification requirements for concrete flatwork coatings. If we sell a near zero VOC anti-graffiti coating that would work for the interior CMU walls in a school, but only get a few random specifications, is that worth the companies’ resources to support CDPH testing? I’ve already had to answer that one for real life LEED for Schools projects. No, we did not spend the $2,800 for testing. As it turns out, what mattered a few years ago doesn’t matter today.

This brings me to the elephant in the room. LEED for Schools was the test bed for an all emissions testing approach. Based on the USGBC issuance of a PIEACP allowing substitution of regulatory VOC compliance for CDPH testing and personal experience with desperate project team members, it would appear the experiment has not been entirely successful. Take a look at the LEEDUser forum where the vast majority of questions relate to regulatory VOC categorization instead of the original CDPH testing requirement.


I look forward to your comments and criticisms.

September 14, 2011 - 10:00 pm

As an architect, former facilities manager, and LEED project administrator since 2000 I believe this credit group revision moves beyond feasible for many manufacturers, architects and contractors. Current IEQ4 credit requirements have greatly improved indoor air quality. At what point do we risk credit compliance or even projects abandoning LEED to achieve the next few percentage points of gain? If hospitals need the added protection then use LEED Health Care as the next test market and evolution catalyst. Added documentation, testing and calculations will a work against the credit group.

Dwayne noted the problems with the LEED for Schools version of the credit citing frustration shared by "desperate team members." I also use the PIEACP (alternative credit compliance approach) on my projects which deferred to LEEDv2.2. Please use this new version of LEED to clarify the process and apply lessons learned from past versions of LEED, not repeating the same problems or creating new ones.

A general comment for LEED 2012- When ASHRAE approves a directive they give manufacturers 3+ years to design, test and implement the new products to meet the more stringent requirements yet USGBC credit committees appear to believe this proposed major shift can happen in 10 months or less across many more diverse product lines. Many organizations and governments have adopted LEED compliance similar to a building code therefore I believe the ASHRAE comparison applies. Most of my past projects are LEED silver and gold certified, yet few could achieve enough credits, even with a 10% budget increase, to achieve basic certification under comment period v2012. One proposed v2012 credit could not be achieved because an independent certification process had yet to be created at the time of this comment period!

September 10, 2011 - 7:52 pm

For reasons mostly different than what Dwayne has stated above, I think this credit is clumsy and virtually unworkable. I hope there will be an active debate about this!

First, I'd like to note that the Low-Emitting Materials credits as they are now are already pretty time consuming. They take much more time proportional to the LEED credit we get for them (about 4% of points for something that takes maybe 10% of the total time). This change is going to make that equation even more lopsided.

Specifically, I'm referring to the requirement that all materials applied to floors, walls, and ceilings as well as insulation be calculated by surface area. What this means (as far as I can tell) is that for every applicable material submitted, we will have to figure out what surfaces it is being applied to, calculate the areas and add them all up. Moreover, we are asked to calculate based on manufacturer data about how to apply it. Finding these surface areas, and studying the manufacturer data about how fluids are applied, is an entirely new level of complexity.

I don't see the benefit over merely listing the products and their compliance as we do now. If amounts must be provided, how about using the product cost (as is allowed in the current draft for furniture) or the number of gallons for fluids.

In my estimation, the extra work in this credit will add cost to LEED projects without adding any extra IAQ benefit.

September 7, 2011 - 8:32 pm

There are requirements in this credit that originated in LEED for Healthcare due to the extra concern about health in its development. They are, however, robust credits that could and arguably should apply to any applicable BD&C project.
Most major batt insulation manufacturers now have a competitive formaldehyde free product offering so this requirement is not heroic to meet and will contribute to the heath profile of any project, not just a healthcare project.
The exterior applied product VOC content restrictions are probably even more important to include in any project for their smog reduction potential as for the direct health impact on adjoining occupancies.

September 9, 2011 - 12:16 pm

I agree with Tom on expanding the exterior applied wet applied product requirements from Healthcare to all BD&C projects. However, we also need to figure out how to deal with the inevitable oddball product where CARB 2007 SCM or Rule 1168 compliant products are not available. An all or nothing approach doesn’t quite make sense where every single product is counted. As an example, I don’t think the entire project should be penalized for using a graphic arts coating for minimal exterior painting. If the credit is unworkable, project teams won’t use it and we miss an opportunity to positively impact the environmental footprint for the project as a whole.

Reinhard, I appreciate your point regarding where exterior coatings, sealants and adhesives belong in LEED 2012. However, I believe there are enough applications on building exteriors near operative HVAC systems to merit using lower VOC products on the exterior. In general construction sequencing, the exterior finishes are among the last products to be installed on a building as site work must be complete and the job dirt removed prior to application on large panels. Use of the CARB 2007 SCM and Rule 1168 are a positive means to accomplish this.

This brings me to what I believe is a hole in the system. The BD&C interior requirements cover materials applied to the building interior defined as “everything within the waterproofing envelope”. The exterior Healthcare requirements cover materials applied to the building exterior defined as “everything outside the waterproofing membrane”.

So, where do the waterproofing materials fit?

We used to live in a world where buildings were built with no secondary drainage plane waterproofing materials or, at best, where a non woven sheet material was stapled in place. Due to many failed building envelopes involving materials degradation and water intrusion, the general design principles for building envelopes have changed. Sheet stock is rapidly being replaced with full surface adhesive rubberized asphalt sheets, spray applied polyurethane foam, and spray and roller applied bituminous, acrylic, epoxy and urethane coatings. Widespread use of these products has progressed so quickly that the regulatory system hasn’t entirely caught up. Some manufacturers classify products applied to gross square footage as sealants even though they would meet the definition of coatings.

For most of these products, the initial application causes few emissions or IEQ problems. They are applied in open field conditions to exterior walls not generally in proximity to operative HVAC systems. In construction sequencing, application is relatively early as the objective is to cover cavity and backer surfaces such as Densglass, concrete masonry units and plywood to prevent moisture intrusion and related microbial and fungal activity.

However, once the exterior sheathing and veneers are applied, the secondary drainage plane waterproofing and air barrier materials are closed in the wall cavity. Some of these products, high build materials in particular; evolve VOCs and other materials slowly over time.

Including waterproofing materials, including adhesive applied and self adhesive sheet goods, and treating them with the same rigor as other exterior applied materials opens a new suite of complicated issues. You are probably aware of the stakeholder conversations regarding SPF systems. That probably has to work through stakeholder discussions and will be covered outside the scope of coatings and sealants. However, I believe we can make a good start where it makes sense within the CARB 2007 SCM and Rule 1168 regulatory frameworks.

Reinhard, with regards to your comments regarding VOC content testing, where necessary for third party certification purposes I believe it appropriate to allow multiple options including USEPA’s Method 24 and ASTM D6886. I don’t know anything about the ISO standard you referenced, but would like to hear more about it. At least in the US regulatory system, because of the legal aspects I still believe we have to allow the regulatory default of calculation of VOC content.

Tom, you have a valid point regarding exempt VOCs. However, I think we need to be careful about overstating the problem with regards to exterior applications. Yes, acetone is exempt. Yes, it flashes rapidly. No, it isn’t particularly toxic except as an initial CNS depressant. A coatings manufacturer would not use an exempt solvent unless it was necessary for performance of the product. Every raw material input is more expensive than water. As green building advocates, we can help educate architects and owners about product attributes so they can weigh the benefits and choose the materials that will be help the building live to a ripe old age.

We can’t forget that coatings and sealants are meant to protect substrates from degradation and assure materials meet their life cycle objectives. Take a walk around D.C. and look at all of the weather damaged Indiana limestone and marble. If you could walk up to the Washington Monument, you would see large areas where the stone simply dissolved and was replaced with epoxy patching material. The National Cathedral uses no exterior coatings or treatments and is instead blessed with a full time masonry carving and restoration crew. The rest of the building inventory can’t be left to chance.

I’m not saying that all exempts are created equal and advocate for disallowing the use of methylene chloride and perchloroethylene as exempt solvents in all circumstances.

September 8, 2011 - 10:42 am

Interesting points Reinhard (both above and below). Thanks for weighing in. Due to the EPA exemptions there are still serious loopholes that allow a claim of low or no VOC content for a paint that still contains certain VOCs (like acetone) that while not smog precursors are directly hazardous to human health. That's why the Pharos Project assessments of wet applied products reward products that contain no VOC content, including EPA exempts, and we urge the USGBC to do the same in LEED to avoid regrettable substitutions..

We agree also that the VOC emissions standard needs improvement to adequately address wet applieds. We were deeply disappointed by the disbanding of the Joint Committee process and I have worked to encourage the sponsors to work together again. Until that work is completed, VOC content restriction - including VOC exempts - remains an important protection.

The question of whether the VOC requirement belongs in EQ or MR is a tricky one since it serves multiple intents. The bottom line is that material selection criteria probably should all be moved to MR since they are probably best merged into one credit set to encourage joint assessment of overlapping and sometimes divergent priorities.

September 8, 2011 - 4:25 am

I am not happy with the VOC content regulations for exterior applied products being in this credit here (Health Care only).

Low-Emitting Interiors credit deals with long-term exposure indoors, not with protection of outdoor air.

This could rather become part of Materials and Resources credit. And - the test method needs to be updated - the present test method works fine only for solvent-based products, it fails technically with many modern low-emitting products. ISO 11890 is the state-of-the-art testing standard.

September 7, 2011 - 1:29 am

I'm very pleased to see the VOC emissions testing requirements extended to all interior surfaces. I’m concerned, however, to see that the VOC content restrictions have been eliminated for wet applied products on interiors. Adding 01350 type emissions testing is probably a good thing for protecting long term chronic health of occupants. Remember, however, that this test does not start benchmarking emissions until 14 days after application of the finish or adhesive. Very high levels of VOCs can outgas quickly before the 14 day mark and may represent the bulk of the VOC impact. Evidence of this potential can be seen in paints can pass the 14 day emissions standard but have very high VOC content levels, such as Behr Premium Plus Interior/Exterior High Gloss Enamel Series which apparently passes GreenGuard Children & Schools but has a Coating VOC content of 142 g/l according to its MSDS: http://www.actiocms.com/VIEW_MSDS/AuthorDisplay_V402/msdsdisplaycode_aut...
This leaves two interior health issues and one exterior environmental health issue vulnerable that the previous VOC content restrictions helped address:

1) Installation crew: Painters and installers are exposed to the pre 14 day high levels of VOCs constantly.
2) Occupants: Realistically there often end up being occupants in adjoining spaces to construction, particularly in additions and CI projects that may be exposed to the short term high VOC levels as well.
3) Smog : Most of the VOCs that offgas from coating or adhesive applications to interior surfaces will end up ventilated to the outside environment. The total surface area of interior walls, floors, and ceilings will generally end up being far larger than the exterior surface area. Hence the potential contribution of reactive VOCs to the outside environment from interior painting and adhesives could be much larger with equivalent product VOC content.

Reduction of emissions of smog forming volatiles is probably sufficient reason to warrant keeping the SCAQMD and CA ACTM VOC content limitations in place for wet applied interior products. That is an exterior air quality issue, not an IEQ issue per se, but an important health impact nonetheless and should not be lost. Then there are the direct IEQ issues for installers and occupants from the short term emissions. VOC content is a crude measure, but until the industry establishes agreed upon methods for lab measurements of short term emissions from wet applied products and benchmarks for them it is the best we have and we can’t afford to throw it out.

September 14, 2011 - 1:10 pm

I want to reiterate Reinhard’s comments regarding safety management during product use. At the risk of sounding callous, construction activities are inherently dangerous and require job hazard analysis, planning and training in accordance with OSHA regulations and the general duty obligations of employers. We don’t propose to eliminate metal grinding or welding due to heavy metal emissions or ban cement flatwork because it exposes workers to an alkaline corrosive; we manage risk. In the case of chemicals management, that involves hazard communication, application of engineering controls and as a last line of defense utilizing PPE based on hazard potentials.

That’s not to say I favor using high risk chemicals inside buildings. Ultimately, specifiers need to balance risk, performance and longevity with every building component and system. Sometimes that means choosing a coating with an inconveniently high published VOC content. The CARB coating regulatory limits are the result of a market study of around 950 manufacturers supplying products in California and a two year technology review and rulemaking to set technology forcing VOC standards in each and every category. I mention the CARB rule as it is referenced in the exterior LEED for Healthcare credit system. I cannot support use of Rule 1113 for numerous reasons mentioned in my LEEDUser comments on the first draft of LEED 2012.

I’m glad Tom posted an example of a product in a category with a 150 g/L regulatory VOC limit. That number sounds high, and perhaps it would be in an 85% solids product with the balance being a high risk organic solvent such as xylene. Product selection is where professional judgment must come into play. I don’t make or compete with the example product, so I can put on my corporate safety hat and look at it objectively based on one hazard communication document and pretend it will used in my production facility or corporate office.

Based on the MSDS for this product, the primary VOC is ethylene glycol at 1-5% of the formulation. This would be consistent with a published VOC content of 57 g/L with water included in the calculation. Since it is over 1 pound per gallon solids, the calculated coating regulatory VOC content must be based on subtracting a primary carrier solvent, water, yielding a label VOC content of 142 g/L. The vapor pressure of ethylene glycol is negligible at 0.06 mm Hg; it will not volatilize quickly and any initial exposure to applicators should be minimal and easily remedied with minor cross-ventilation. The product is non-flammable with a NFPA rating of 1 for flammability.

This is the type of analysis I go through with construction management and corporate safety personnel when they call to talk about potential hazards and safety management in using my products. Most of my interior products have a similar or lesser risk profile, but I do have specialized products for problem substrates and applications that have higher risk potential. I talk through those problems honestly so they can apply appropriate engineering controls and procedures. They can also go back to their specifier and look for other options – I do have competition.

This particular example points to the problem of using gross VOC or emissions TVOC as the sole means to determine whether a product is good or bad. This product is relatively low risk and yet has been pointed to as being intrinsically bad because of the 142 g/L VOC content. Yes, it would be great if they could eliminate the ethylene glycol, but would the product still flow, form a proper film and meet ASTM performance standards and owner expectations for aesthetics and performance? Can it be touched up, or does the entire wall need to be re-coated if someone relocates a towel dispenser?

The one thing we collectively neglect in the debate over VOCs is that coatings and sealants, like every other component in a sustainable building, need to meet longevity and performance objectives. We don’t suggest making glass thinner solely because of GHG emissions during production. We don’t skimp on structural welds because of weld fumes. We don’t ban earth moving due to dust and diesel emissions.

If this were an intumescent coating, we would not suggest using a lesser material at risk of allowing structural steel to melt in a fire. If it were a rust preventative coating, a building owner has every right to expect that metals near the swimming pool or locker room won’t rot away. If it were a water repellent, there should be an expectation that it will prevent degradation of the substrate as specified.

My company works closely with conservators and building forensics specialists. Degradation to historic structures is disheartening. Products like terra cotta and Indiana limestone were supposed to be maintenance free “forever” building materials.

However, I am even more concerned about the state of our new building inventory. USGBC’s LEED system has successfully transformed the commercial and institutional construction market. Every building system and subsystem has been rethought. Building exterior assemblies are often composed of products that barely existed 15 years ago. Unfortunately, many 10 year old assemblies are already leaking water and have required extensive remediation. Coatings and sealants are critical components in those systems. As we earnestly discuss the potential of using CARB SCM and Rule 1168 VOC limits for all LEED project exteriors, how should performance questions help guide the debate?

September 8, 2011 - 4:19 am

This is a question of what belongs where.

VOC content restrictions do not correlate at all with indoor air quality and consumer exposure, as very most VOC evaporate within the first few hours. And the VOC content limits are so high that remaining VOCs will contribute significantly to consumer exposure indoors during several weeks, if not months.

VOC content restrictions protect not indoor air but outdoor air - therefore these could become part of Materials and Resources credit, but not of the Low-Emitting Interiors credit which deals with long-term exposure indoors. And if that would happen then the test method needs to be updated - the present test method works fine only for solvent-based products, it fails technically with many modern low-emitting products. ISO 11890 would be a standard representing recent state-of-the-art.

Subtraction of exempt compounds (not being an issue for smog formation) is another reason why VOC content limits will protect neither consumer nor painter. There are products on the market where most VOC is made of acetone, because this is an exempt compound and not counted as VOC by SCAQMD or Green Seal, even though this is not a good solution for healthy indoor air.

Short-term exposure while painting is another issue. Here you are having TWA air limit values published by NIOSH and OSHA that should be respected. Also here, VOC content and painters' exposure do not show any quantitative correlation. I wonder whether we really do need additional requirements in LEED. We do not have such specifications in LEED regarding workers exposure to other hazardous substances such as dust, fibres, etc.

September 7, 2011 - 8:21 pm

I am also quite concerned that VOC content restrictions have been eliminated for wet applied interior products.