Thank you for the opportunity to provide feedback on the current draft of LEED v5.  Green Seal is a global nonprofit organization with a mission to protect human health and the environment by accelerating the adoption of products that are safer and more sustainable. We are proud that our health and environmental leadership standards for cleaning, personal care, sanitary paper, trash can liners, and building restoration products, as well our standard for effective green cleaning practices, have long been referenced as a simple path toward earning LEED points.    

We are pleased that the LEED O+M: Existing Buildings v5 draft proposes to allow projects to earn up to 2 points for using certified cleaning products and materials.  Amid growing recognition that everyday products such as cleaners, floor care products and other facility care products can have a marked effect on  indoor environmental quality, it is heartening to see the increased point value for cleaning products and materials that meet a leadership standard for safety and sustainability.

We also note that the draft proposes to eliminate LEED v4 IEQ Green Cleaning Policy Prerequisite, instead offering optional points for measuring cleaning performance, using specified powered janitorial equipment, and using specified cleaning products and materials. We believe that each of these three categories is important to foster a healthy building interior and site.  However, they are insufficient to ensure a high-performing green cleaning program that delivers the greatest benefit to indoor environmental quality.  We have learned from cleaning industry experts that the most effective green cleaning is accomplished by the combined benefits of green products and effective green cleaning practices.  One without the other is not sufficient to ensure maximum impact.

The proposed point structure misses critical green cleaning practices and procedures that formerly were addressed through the Green Cleaning Policy Prerequisite. These include:

  • The development of building-specific cleaning plans and associated employee training, management and oversight
  • Guidelines for selection and appropriate use of disinfectants and sanitizers
  • Procedures for safe handling and storage of chemicals
  • Provisions to protect vulnerable populations
  • Protocols to ensure effective communication between cleaning providers and building tenants, as well as opportunities for custodial staff input.

Annual cleaning performance audits cannot adequately replace these measures, which are intended to ensure ongoing cleaning performance and protection of human health. Performance audits also fail to minimize hazardous chemical exposure, as without the Green Cleaning Policy Prerequisite there is no requirement to use certified green cleaning products, rendering it possible to earn the Measure Cleaning Performance credit using conventional products. 

LEED historically has played a powerful role as a rating system of rating systems, rather than re-inventing leadership standards for categories where strong ones already exist. Incorporating existing credible third-party standards into LEED promotes a consistent definition of leadership that simplifies compliance with the LEED standard and supports existing mission-aligned organizations instead of undercutting them.

Green cleaning is a category where leadership is already defined through credible standards such as Green Seal’s GS-42 Cleaning Services Certification  and ISSA’s CIMS-GB. These standards recognize that, to be fully effective, green cleaning products and equipment must go hand in hand with green cleaning practices and procedures.  Allowing participants to pick and choose elements that are most effective when they are combined undermines the longstanding definition of green cleaning leadership. Therefore, we suggest amending the proposal with one of the following changes:

  • Reinstate the IEQ Green Cleaning Policy Prerequisite, or
  • Create a single, 4-point credit that incorporates all the components of an effective green cleaning program, including the practices and procedures outlined in the IEQ Green Cleaning Policy Prerequisite, with an option to meet the criteria through use of a certified cleaning service.

Combining the options into a single credit ensures the twin pillars of effective green cleaning – products and practices – remain intact.  We understand that it is important for LEED to avoid placing additional cost or implementation burdens on its participants. Providing an option for participants to meet the green cleaning criteria themselves instead of through a third-party certification offers them flexibility without watering down the definition of green cleaning leadership.

While the evidence is clear that the best cleaning programs include both green cleaning practices and green cleaning products, for the sake of supporting the market for green products, we also could support breaking the credit into two groups: a single 2-point credit for use of green cleaning products and a single 2-point credit for use of green cleaning best-practices.

Finally, a clarification is needed for the green cleaning credit in the current public comment version: it is misidentified as 3 points instead of 4.

We are grateful for the U.S. Green Building Council’s work to advance human and environmental wellbeing through the built environment. Thank you for your consideration of our comments, and we look forward to continued collaboration.

Sincerely,

Green Seal