This credit signifies a huge step in a positive direction for the building industry. It endorses a hazard-based approach to product improvement, rewards targeted transparency to inform product selection and implicitly acknowledges that EPDs do not satisfactorily address health impacts. However, the credit must be adjusted in order to be implementable by project teams. Suggestions for improvement fall into one of two general categories: procedure or substance. PROCEDURE As noted by Carly Ruggieri elsewhere here, the MR credits are getting quite disparate in their tracking requirements. As it is written, this credit has disparate processes applying to each point for this credit and the point allocation is unclear. The second point should build on the foundational effort by project teams to complete the requirements of the first point. Instead of necessitating a different information set for each, the credit should expand by going deeper with the data already in-hand. The metrics must be identical to standardize communication with manufacturers and allow for clear and uniform tracking procedures by project teams. The current requirement to document 25% of all permanently installed products used (by cost) is a gargantuan task, and would necessitate researching a majority of specified products to achieve the stated goal. The volume of effort is out of scale with the reward, and beyond what is possible within current market limitations. Instead, the second portion of the credit should build on the requirements of the first portion of the credit. Since 1 point can be earned for inventorying 20 products, the second point should reward project teams that either document ingredient inventories of more products or demonstrate that a portion of the products already inventoried avoid worst-in-class chemicals. Both of these avenues yield the desired result to “encourage the use of products and materials for which life-cycle information is available and that have environmentally, economically, and socially preferable life-cycle impacts”. For example, the credit could be restructured as follows: 1 point (total): Inventory the content of 20 products to at least 0.1% (1000 ppm). 2 points (total): Inventory the content of 40 products to at least 0.1% (1000 ppm), OR Inventory the content of 20 products to at least 0.1% (1000 ppm) AND demonstrate that at least 10 of these products avoid worst-in-class chemicals. SUBSTANCE One major limitation of this credit is the varying degrees of transparency in the approved compliance paths. As it stands, the credit equally values reporting to the end user (such as with the Health Product Declaration) and reporting to a third party assessor (Cradle to Cradle v2). For project teams to make informed and comparative decisions, it is their right to know the so-called reported information. Fractional contribution of products to credit achievement presents another significant concern from the perspective of quantifying hazard and exposure. Comments are organized by compliance path below: Cradle to Cradle (C2C): • C2C Version 2 is not transparent about the standards for its protocol; Version 3 appears much more transparent. The credit should recognize compliance with C2C v3 – not v2. • With respect to the first point (reporting), C2C v2 certification at the Silver level does not share product inventory information with the end user and has few absolute limits on hazardous content. The credit should require C2C v3 certification at the Silver level together with a published report card that indicates (at minimum) the optimization status of the specific product for each category evaluated. Health Product Declaration (HPD) Open Standard: • The HPD supports a range of levels of disclosure and is a good fit as a compliance path for this credit. However, the credit needs to more specifically define the threshold level within the HPD Open Standard that meets the credit intent. As such, the credit language should indicate that the documentation should be a “Complete HPD, with (at minimum) a Full Disclosure of Known Hazards”. Manufacturer Inventory: • Since the HPD Open Standard offers a template that mirrors the credit requirements and facilitates manufacturer disclosure in a consistent fashion, it is redundant to include “Manufacturer Inventory” as a separate compliance path. GreenScreen: • The technical requirements for GreenScreen List Translator Benchmark 2 are far greater than those of GreenScreen Benchmark 1. This compliance path should also include an intermediate, more attainable, option. Add GreenScreen List Translator Possible Benchmark 1 as an intermediary valued at 150% of cost. Increase the full GreenScreen Benchmark 2 value to 200% of cost. Under the simpler product count approach outlined above, this would mean that a product whose ingredients all pass GreenScreen Benchmark 2 would count as 2 products toward the 10 product total requirement. • The credit language should mention that the HPD can document a product’s compliance with this performance-based path. REACH: • This compliance path is highly problematic – it gives international projects a virtually “free ride” compared to those manufactured domestically. This is because the REACH Authorization and Candidate lists are included within and are only a very small subset of the GreenScreen List Translator, (noted as a parallel compliance path for this point). There is no material reason why international projects and products should be exempt from the additional requirements outlined in this credit. To the favor of international project teams, most European manufacturers have already eliminated all of the REACH Authorization chemicals and are also avoiding the REACH Candidate list chemicals if they can. Fractional Contributions: • It is imperative that the allowance for fractional product contributions is removed as a compliance path from this credit. Hazard from a toxic ingredient is not necessarily a function of the percentage of content. Consider, for example, that an insulation product with a halogenated flame retardant may only contain 1% or less of that ingredient. The fractional contribution approach results in 99% applied value towards the credit, even though 100% of the product is ‘contaminated’ with a serious potential health hazards for end users.
Policy Director
Healthy Building Network
LEEDuser Basic Member
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