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

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!

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.

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.

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.

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.

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?

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.

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