Review comment that I have never received before states the following:
"Several products include recycled content but are listed as being 100% regional. It is not clear that 100% of the recycled content and
raw content has been extracted within 500 miles. For a material with recycled content to be 100% regional the extraction location of both
the raw and regional content must be known and within 500 miles."
A good example of this would be our brick, which has a 28% preconsumer content, but is 100% regional, as the raw materials are extracted within 500 miles and the brick is manufactured in the same location. It is 100% regional.
Julie Blue
Associate, AIA, LEED APTMP Architecture, Inc.
11 thumbs up
June 17, 2013 - 11:28 am
We recieved the same exact comment on a recent project. Then the comment was followed by several examples of products the reviewer mentioned and all were metal/steel related products. Basically we took it as saying if the product is not 100% recycled content then it is questionable whether or not it can be counted as 100% regional material becuse there will be "virgin" material within the product as well. We took each item mentioned and got manufacturer letters to back up our data/explain the calculations and break out the recycled material with the location extracted and also each virgin material with their location of extraction.
Some manufacturers could not completely back-up their claim, so we used the recycled content percentage as the regional material percentage because they were able to determine the recycled content was either from the plant or a local recycling center that was within the 500 miles of the project.
This was an accepted approach from our review team.
Julie Blue
Associate, AIA, LEED APTMP Architecture, Inc.
11 thumbs up
June 17, 2013 - 11:32 am
I think they are looking closely at regional material claims now and want more manufacturer's letters over and above the 20% they require to be uploaded.
Valerie Molinski
Environmental Stewardship ManagerTarkett North America
102 thumbs up
June 17, 2013 - 11:40 am
Thanks for the feedback. I figured it might be related to steel, but I was wondering what this meant for documentation..... as in, are they asking me to go back more steps to trace the raw materials as it relates to where the recycled portion came from? I thought, as a general rule, we only had to go back so many steps as far as a raw material to document.
It's interesting that you say that they want more for back up docs these days...I don't like to hear 'they want more than 20% uploaded." I generally do end up with more than 20%, but at the same time, I do not think that is fair of a reviewer to request if that is not the current rule. USGBC/GBCI needs to make it 30/40/50% or whatever they want so it's a recognized threshold instead of some reviewers asking for more and some not. I hate when it's arbitrarily requested or enforced. Not saying this is happening, but I am sure they can understand our frustrations when rules are changed in the middle of the game- especially when they are not published rules but at the whim of the reviewer on your project.
Julie Blue
Associate, AIA, LEED APTMP Architecture, Inc.
11 thumbs up
June 17, 2013 - 11:47 am
Agreed on the threshold. Only (1) of our claims actually was changed due to the review comment all others were confirmed through further manufacturer letters. That is what makes me think reviewers want more data uploads than the 20% (or particular product data).
We were not required to trace back the recyled content material.
Susan Walter
HDRLEEDuser Expert
1299 thumbs up
June 17, 2013 - 12:54 pm
This same comment came up on a recent review for us as well. Seems a new trend.
Perhaps one solution is to upload all of the steel claims and 20% of the rest. (Not that I'm agreeing with the upscaling of the 20% requirement.)