Ceramic Tile Again

Hi Panupant,

That's basically correct. I would just take a look at the language again:
"Mineral-based finish flooring products such as tile, masonry, terrazzo, and cut stone without integral organic-based coatings and sealants and unfinished/untreated solid wood flooring qualify for credit without any IAQ testing requirements. However, associated site-applied adhesives, grouts, finishes and sealers must be compliant for a mineral-based or unfinished/untreated solid wood flooring system to qualify for credit."

Ceramic tiles and wood flooring should be exempt from the LEED requirements. Ceramic tiles because there is nothing to see there. Wood because it already covered under EQc4.4.

The "however" comment serves to confuse people. It is basically telling you that if you pursue EQc4.3 any EQc4.1 and EQc4.2 products used to install or finish the flooring must comply with those credits, regardless of whether you purse those credits or not.

This type of cross-credit mixing of requirement is not supposed to occur in LEED. It occurred because a single individual was able convince --"confuse" is a better choice-- the USGBC that chamber testing of an entire finished flooring product was required, as well as required for all EQc4 related products.

Many years ago the single individual was a member of the IEQ Technical Advisory Group successfully forced the California 01350 standard into all of the EQ4 credits as the one and only reference standard. 01350 is an extremely expensive, chamber-testing, data gathering standard that a few IAQ "experts" in California use to analyze chemical components in products at an extreme level. The goal of the experts is to continual raise-the-bar for California's Proposition 65, a standard which limits the amounts of a wide range of chemicals used in manufacturing products sold in California.

The reason 01350 was forced into LEED was that the person who managed to convince the USGBC to include it worked very closely with the IAQ "experts." In fact they were all very good friends who were all convinced only they understood IAQ and nobody else in world did.

I complained during the LEED for schools public comment period about 01350 not being ready for prime-time, meaning the burden on manufacturers was excessive. None were willing to pay the cost of the expensive 01350 testing, and the required annual IAQ checkup fees. For example, when 01350 was released for use in LEED there were only couple adhesives that qualified. Imagine, to build your building you were limited just a fewer adhesives if you wanted to earn EQc4.1.

My comment about the problem of product availability was ignored by the USGBC. It took some time, but 01350 was mostly removed from LEED. The USGBC eventually figured out they made a grave error in allowing 01350 into LEED.

Hernando, what do you think about the appearance of Section 01350 as the principal emissions testing regimen in the Low-Emitting Interiors credit in the most recent LEED v4 drafts?Now it's referred to as CDPH Standard Method v1.1, which is more accurate.My understanding is that this is the a fairly stringent test and products are now commonly tested against it, so it's ready for "prime time."

For companies that manufacturer a wide range of adhesive and sealant product this testing is incredibly expensive. There are simply too many products to test and pass through 01350.

Paints, flooring, composite wood you can get. They are manufactured in large enough quantities to spread the cost around.

CDPH Standard Method v1.1 still refers to itself as 01350.

These are the 01350 (CDPH Standard Method v1.1) problems:

- Expensive testing
- Annual product restesting unless onerous Quality Control Management is proven by documentation. "
- Retesting after any reformulation of a product

The above are why you will continue to see a limited range of adhesives and sealants meeting the 01350 standard.

Tristan,

This is something you should know about CDPH Standard Method v1.1 (01350).

The chemical component data that is collected is analyzed by a limited number of experts. The experts take each chemical and analyze the decay curve, meaning how long does take the chemical to dissipate to an acceptable level where the contaminates below a threshold deemed acceptable to California's Prop 65.

I have seem many of these decay curves. What was obvious was that the experts were figuring out if it was safe to use a building after a certain number of days following installation of a material. Usually, it took less than two weeks for the emissions to be acceptable. If not two weeks, then usually not long afterward.

In other words, with time nearly every product installed would decay to acceptable emissions limits well before occupancy occurred.

Does compliance with CA 01350 = Compliance with Prop 65?

What is the best form of documentation to show that a product complies with Prop 65?

CA 1350 has not been known as such since February, 2010 - It has been revised and re-titled. It is now the Standard Method for the "Testing and Evaluation of Volatile Organic Chemical Emissions from Indoor Sources Using Environmental Chambers, Version 1.1." It is a chamber testing methodology for determining VOC emissions for construction materials.
http://www.cal-iaq.org/phocadownload/cdph-iaq_standardmethod_v1_1_2010%2...

Proposition 65 is the California list of carcinogenic chemicals/materials:
http://oehha.ca.gov/prop65/prop65_list/Newlist.html

They are used for different purposes - one for testing for emissions, and one for identifying harmful chemicals in construction materials. Not equal, though they are distant cousins!

For testing, you may be able to find confirmation that testing has already been done via 3rd Party Certifiers, or you can require the materials to be tested. For Prop 65, You can ask your manufacturer to provide certification that their product does not contain any Prop 65 Chemicals.

What is the testing standard for Prop 65?

Do you know which 3rd party certifiers provide testing for Prop 65?

My office does not review MSDS, but it seems to be the only way to determine if a product complies as in many case Prop 65 is listed under the Regulatory Requirements section. If Prop 65 is listed under the Regulatory Requirements section, and no chemicals are listed is this sufficient documentation that the product complies with Prop 65?

I've also seen MSDS with chemicals listed and percentage. If the listed amount is at or under 0.01%, or 100 ppm, does that constitute compliance with Prop 65.

If the manufacturer's environmental documentation (on Manf. letterhead) for a product states that it complies with Prop 65, is that sufficient documentation?

I've also read that the Standard Method for the "Testing and Evaluation of Volatile Organic Chemical Emissions from Indoor Sources Using Environmental Chambers, Version 1.1 is used to determine the point at which the chemical levels of a product fall below the set thresholds of Prop 65.

We have been collecting MSDS as part of the submittals for O&M manuals so they come across my desk on a regular basis as part of the 'LEED check'. Here's what is frustrating to me, well let me clarify, one thing that is frustrating is that the MSDS in Section 15 will list chemicals and usually a percentage but wimps out on the CA Prop 65 report. They usually say that the product contains a chemical known to the state of CA to be a carcinogen. But there isn't much in the MSDS to help a building professional determine compliance with LEED HC. Yes, I have been assuming that the percentages listed in Section 15 are accurate but I still have to cross reference the Section 15 listed chemical with the Cali Prop 65 list. It is a little too time consuming.

Another issue I see is the broad brush approach of Cali Prop 65 lists. There is little information on how or form the product causes an issue. For example, consider the issue of crystilline silica or pulverized sand which is in a lot of building products, usually over 1%. The reason that is listed for silica is the danger of cancer due to inhaling fine particles of the siilica. OK. But if the product arrives at the project site already incorporated into a form that is not going to allow the silica to be released AND it come from a manufacturing process where the workers at that locations are protected from inhaling the silica during manufacture BUT the silica is over 1%, is this still a dangerous product? Personally, I think not.

I think we're going to have to take this conversation back to LEED HC and join together. The GBCI folks are likely waiting for a project team to start asking for official clarification. Perhaps we can all cooperate.

For LEED HC the value of "proving" Prop 65 is complied with is not worth the effort, meaning owners are not willing to pay the cost of time to properly document a credit like this.

The LEED HC simply put too many requirements into the credits. Credits that earned two separate points in other LEED systems, were merged into a single point. That increase the documentation level of effort.

In the end, unless the product is emitting something, whether by off-gassing, decaying, or being ground/sanded into dust, that a body comes into contact with and absorbs, most chemicals in products are not hazardous in their final form.

A good case in point is the long time error in LEED regarding ceramic flooring--they should be excluded from LEED consideration. The physical act of fabricating the ceramic kills off any organic materials. Prop O banned chemicals might still be in the products, but they will do no harm unless they are turned into a toxic form. Any silica in the product is harmless unless the product is sanded or ground.

This is a link with some good basic information about toxic chemicals.
http://www.ccohs.ca/oshanswers/chemicals/poisonou.html

One reason many building owners have turned away from LEED is because of issues like this. Some know silica is toxic in dust form, and otherwise not. They don't understand why they have to spend money to document something that isn't really an issue.

I will just refer to the first reply where I did understand that ceramic is exempt from the Floorscore certificate requirements; based on that should I apply for "Alternative compliance" path, and if so; do I need to upload any document other than the MSDS?

Thanks,

All, 

I am confused about ceramic or non emitting sources materials that would have a colour coating or similar. Does this means that we need to verify compliance for the coating only? Note that they are not wet applied on site, already manufacturer. 

For instance we have materials such us pool mosaic tiles (turquoise), and porcelain tiles with "colour" finishes, I would consider them accepted by LEED as non imitting source... What has been your experience with these type of materials?

I ask the manufacturer’s to provide the following on their company letterhead for those materials:

To whom it may concern,

The manufacturing of our [insert product here] does not include integral organic-based surface coatings, binders, or sealants.

Sincerely,

Since even the LEED handbook states ceramic materials are inherently non-emitting.  So do we even still need to provide a letter from the manufacturer or any other form of documentation to confirm this even if USGBC already recognizes that ceramic anything is already inherently non-emitting?

You do not need to provide documentation stating that an inherently non-emitting product is non-emitting. 

However, as discussed in this thread and others, some of us have gotten comments asking for that documentation. There's a lot of gray areas in LEED, multiple sources of guidance, reviewers are dealing with the same confusion many of us are, and sometimes they are...let's say overly enthusiastic about asking for proof of something like this. 

If you get comments like that, you can write to LEED coach / GBCI support asking for a re-review of the comment, since it contradicts what's in the reference guide. But Allen's recommendation of getting a brief manufacturer statement might be faster & simpler! 

Thanks