I continue to think this credit is a good step forward. There are six issues I would suggest we discuss to strengthen it and make sure it meets the intent.
- Disclosure requirements: This credit will need a precise definition to insure that product manufacturers get a clear signal of what is required to be disclosed in the list of ingredients. I suggest aligning it with the requirements for participation in the US EPA’s Design for the Environment - full disclosure of all intentionally added ingredients regardless of percentage and of all residuals present at greater than 100 ppm.
- Red List selection: There is no perfect list of chemicals short enough to be reasonable to put in a credit or spec and also comprehensive enough to avoid regrettable substitutions. I suggest that the credit be designed to use tools that reflect evolving knowledge on chemical hazards and to point users and manufacturers toward tools for continuous improvement and substitution toward inherently safer chemistry. The Green Screen for Safer Chemicals (developed by Clean Production Action in partnership with the Business NGO Working Group for Safer Chemicals and Sustainable Materials) provides clear benchmarks towards inherently safer chemistry that can be used with a list of lists and a variety of tools available from Pharos and various MSDS providers.
- Focus of materials required – The current draft language requiring that “20% of all building products and materials” meet the criteria could potentially be met by a single set of bulk structural elements like cement or steel which wouldn’t meet the real intent of the credit. Let’s make sure there is a focus on disclosure and avoidance of chemicals of concern in materials used in the interior finishes of the project as the pathways for human exposure are most direct there. Either split the structural and non-structural products and materials into separate credit points (as in some other LEED 2012 MR credits) or focus the first phase of the credit on building interior materials (as in EQ Low-Emitting Interiors) and phase in other areas later.
- Verification: the current credit weights self-declared and certified declarations equally. Third party certifications should probably get more weight (double credit?). At the same time, we should be aware of the burden we are adding for small innovative companies with the costs of increasing numbers of certifications. I suggest the USGBC convene discussions on how to help small businesses deal with increasing certification burdens.
- Make it worthwhile: This credit will take some work and could have huge impact and teams should be encouraged to go beyond 20% of products. It certainly warrants at least a second point. And consider giving half credit for the disclosure and full credit for the avoidance of chemicals of concern.
- Full life cycle: It makes sense to start with the contents and use phase concerns. But we need to avoid chemicals of concern upstream and downstream as well. This may be more complex than LEED is ready to tackle in 2012 but let’s at least signal we are going there and start a committee discussion on this. Pharos tackles the manufacturing toxics in its scoring protocols and there are some LCA practitioners doing some interesting work to apply hazard assessment to LCA inventories as well.
Thanks for taking this step USGBC. Now let’s make it work.