Avoidance of Chemicals of Concern Credit

Hi Anne,Yes, clearly a typo--it's easy to see how this happened looking at the redline version, which shows the bit in brackets below as having been deleted:"To increase the [use of products and materials that disclose chemical ingredient data and reduce the] concentrations of chemical contaminants that can damage air quality, human health, productivity, and the environment."Assuming they can get that corrected, what do you think about the rest of the updated language?

I give a big thumbs up to the USGBC for the progress they are making in defining a set of Chemicals of Concern credits to incentivize both disclosure and tiered avoidance performance. Disclosure and performance may still be highly contentious issues in relation to the LCA and wood related MR credits (as note other threads above here in LEEDuser), but I think on this chemicals of concern credit, the USGBC is doing something that should be able to be widely supported. These two credits are very important additions to LEED, representing a big leap forward in the efforts to more substantively address material content and health that we initiated in LEED for Health Care. The new credits will be well supported by the Health Product Declaration (www.hpdworkinggroup.org) which should be ready for public use by the time that LEED 2012 hits the streets. Kudos to staff for strengthening this important credit set in this round, including residuals in the disclosure, more important chemicals in the avoidance and setting a strong 100 ppm threshold.

I have a few questions, comments and suggestions about the specific language in the third public comment version to make this a fully functional credit:
20% of project materials criteria: Both credits are based upon meeting criteria for 20% of project materials by cost for at least 3 building product and material types. The USGBC will need to define what a product and material type is to meet the intention which I assume is to make sure that a diversity of materials is addressed and it is not met by just getting disclosure on three closely related big bulk structural materials. Given the importance of toxic content avoidance in the interiors where occupant exposure is greatest, I suggest that the requirements include that at least a portion of the criteria be met by interior products. Perhaps that at least 20% of interior products be included?

Disclosure criteria: Disclosure of chemical compounds is only required for those that trigger Clean Production Action’s Green Screen v1.2 Benchmark 1 and disclosure appears to be defined as either CAS number or Green Screen hazard. This is a novel use of the Green Screen, which was designed as a hazard avoidance and alternatives assessment tool rather than a disclosure and hazard communications tool. I think it can be done but some clear guidance for how to communicate will be needed. We’ll be providing guidelines in the HPD based upon the originating lists that Green Screen compiles that will be useful. My preference would be to require full disclosure of CAS number, but I think disclosure of hazard is a good next step (and indeed the HPD anticipates this pathway as well).

Multiple avoidance points: The avoidance credit is a two point credit, but the language is not clear whether it is an all or nothing 0 or two points or if there is a tiered step process to getting points. I suggest a stepped process to encourage engagement and continuous improvement. How about one point for each 10% and clear guidance for innovation points for going further?

Avoidance criteria: I suggest that there will need to be some clarification on the chemicals covered under the avoidance criteria that probably can be mostly handled in the reference guide. I’d suggest including compounds for all of the heavy metals and that there be some weeding of some of the non CAS specified listings on Prop 65 that are primarily industrially managed occupational hazards, such as wood dust. And I’m curious as to the rationale for a couple of exclusions, namely a) site cured MDI, since all the other EPA Action Plans chemicals are included, and b) REACH SVHCs for US projects.

Residuals: I note that residuals are included in the disclosure criteria but not the avoidance criteria. I expect that rationale may be that residuals are tougher to manage than intentionally added ingredients, but I’d still suggest starting to include them, even if at higher thresholds initially with a planned trajectory to bring them down.

So there are still some issues to work out to make these credits work well, but the USGBC staff has taken a huge step forward in addressing a complex issue. The basic structure is in place and sound to build from now. Good work!