Alternative Compliance - LEED Reviewer Response

You say "for the first time ever". Does this mean you have submitted an alt compliance path for one of the IEQ4 credits in the past (with version 2009), and were not required to follow an alt compliance path for the rest of the IEQ4 credits?

Full disclosure - I am Technical Information & Public Affairs Manager for GREENGUARD Environmental Institute.

Alison - You state alternative compliance in your question - in the LEED for Schools program the EQc4.2 criteria is meeting the testing and product requirements of the California Department of Health Services Standard Practice for the Testing of Volatile Organic Emissions from Various Sources Using Small-Scale Environmental Chambers, including 2004 Addenda (CA 01350). If a product is certified to the GREENGUARD Children & Schools certification program then it shows compliance to CA 01350 along with looking at an additional 330 chemicals and setting a total chemical limit. So this should not be viewed as an alternative compliance path.

LEED for Schools EQc4.2 can have compliance shown by having products that meet GREENGUARD Children & Schools, Scientific Certification Systems Indoor Advantage Gold, or an independent test laboratory report for the product that shows that they pass CA 01350 test methodology. All paints & coatings should not have to show any one third-party certification. Additionally, if you have some products that have not been able to show compliance to the emission criteria, USGBC has approved utilizing the content pass/fail criteria that is used in other LEED Rating Systems.

A question for Josh Jacobs - if a product is certified to the GREENGUARD Children & Schools certification program, does it also provide compliance with SCAQMD Rule #1168?

The simple answer is no. GREENGUARD's standards are focused on minimizing harmful chemicals which can emit from products. SCAQMD's rules are focused on the minimization of VOC content in liquid products (such as adhesives & paints) so as to minimize the potential harm to the outdoor environment - smog and ground level ozone proliferation. They were never meant to be utilized to help prove that a product was low-emitting for the indoor environment. In fact, the Manager of Indoor Exposure Assessment Section for the California Air Resource Board, Peggy Jenkins, stated in public comments last summer for the International Green Counstruction Code that emission criteria is what needs to be used to show that a product is low-emitting for the indoor environment, not simply content.

You are correct, CA 01350 was officially updated in February 2010 and there were changes and updates to the document. To stay current with the latest science and requirements, GREENGUARD updated the requirements for the Children & Schools certification program. Through multiple discussions with USGBC by not only GREENGUARD Environmental Institute, but other product emission practitioners as well, USGBC understood the changes and agreed that they would accept the new standard as compliant with the old criteria. I can't speak for others' methods, but I believe that Scientific Certificaiton Systems' Indoor Advantage Gold also updated their requirements at this time along with some of the major product emission laboratories around the country that do testing for the CA 01350 standard method/criteria. Since this has all taken place GREENGUARD Children & Schools and SCS' Indoor Advantage Gold have continued to be accepted methods of proving compliance to EQc4.0 in LEED for Schools by USGBC.

I have been following this thread and would like to share my experience with IEQc4.2 and the PIEACP amended for LEED 2009 for Schools dated 9/29/2009. On my first LEED Gold certified school under the new rating system I chose the Alternative Compliance method for IEQc4.1-IEQc4.4. The way I understand the PIEACP is that I can either follow the LEED for Schools option OR LEED 2009 for New Construction. I have heard from someone in the wood door industry that you can't jump between the two options. With that said the way I read the PIEACP is that for each credit you have two options, LEED for Schools or LEED 2009 for New Construction. You should be able to take the path of your choosing for each individual credit. I have renewed interest in this topic because we want to use a Dry Erase paint on a school project. Does anyone have LEED 2009 experience with this topic?

This issue of whether the alternative compliance approach is an all or nothing option is very confusing. It seems to me that it would be completely ridiculous if GBCI were to reject IEQc4.2, for example, if 10 products were listed as meeting Greenguard Children and Schools or SCS Indoor Advantage Gold (and thereby meeting the CA standard) with 1 product being shown to meet SCAQMD Rule 1113. Why would that be a bad thing? The PIEACP language itself states, "LEED for Schools project teams are encouraged to use LEED for Schools EQc4 Low-Emitting Materials credits where possible, but may substitute LEED for New Construction credit requirements as needed." I see no LEED addenda and no CIRs that state a one or the other/all or nothing approach is necessary.

Has anyone actually been rejected for submitting with a bunch of Ca standard-compliant products and some NC-compliant products for the same credit? If so, did the project team challenge GBCI and what was the final result?