Inherently Nonemitting

Hi Allen,

I haven't seen this comment personally, and I would push back on it - what documentation do they expect to see, exactly? Product data sheets do not typically state what the product does NOT contain. I am not sure what a project team could provide to demonstrate that a porcelain tile is a porcelain tile without some exceptional process where they add an organic coating after firing. I'd ask GBCI what about these products made them doubt your claim of inherently non-emitting, and an example of acceptable documentation.  

I *have* included documentation of the ceiling grid products in the prelim submission to get ahead of potential comments - might have been that same Rockfon drywall grid you mention - since the product data sheet included painted and non-painted options. In that case I provided a photo of the sample that the contractor approved, to make it clear that we used the unfinished metal version. So you might check if that's the issue. 

I have just received a comment asking for proof of inherently nonemitting material:

2. It is unclear whether the Armstrong Suprafine product meets the criteria for being inherently nonemitting,
as indicated in the calculator. Note that the full product, including paints/coatings must be considered.
Examples of products that are inherently nonemitting sources of VOCs are powder-coated metals.
Provide the following:
a. Product information (e.g. MSDS, HPD, cut sheet) or a manufacturer statement demonstrating the product
qualifies as inherently nonemitting.
b. The VOC emissions evaluations for any products determined not to meet the inherently nonemitting
criteria, if available.
c. A revised Low-Emitting Materials Calculator, as necessary.

We had submitted a cut sheet showing that the materials are galvanized steel.

I have proactively done the same.  I'll include a cut sheet or a health product disclosure and highlight where it clarifies that something is glavanized, powder coated, not coated, etc.

On a couple of projects, we have been asked to provide manufacturer's documents that demonstrate that products "do not include integral organic-based surface coatings, binders, or sealants."

Sometimes the manufacturers resist because they don't understand why we request it. When that happens we do our best with a narrative (of course glazed ceramic products are inherently non-emitting...) In fact, I can't think of a product that has integral organic-based surface coatings, binders, or sealants (some stone product perhaps?) so the documentation requirement seems over-the-top to me.

We received this comment on a project last year.  We used Prelude and Suprafine Armstrong suspension systems.  They have Health Product Declarations that state they are inherently non-emitting (See Section 3 in the HPD).

"Do not let perfection be the enemy of progress."
I continue to be tremendously irritated by the irrational rigidity on this.  A factory applied paint on a ceiling grid is low emitting. Making companies do testing is a irrational hassle.  And a porcelain tile isn't going to have coatings becuase that defeats the purpose of the products. 
I hope someome from the TAG reads this and decide, gee, maybe we did get carried away. Please issue an addenda to allow factory finished painted metal products and as well as tile without supplemental documentation.  Powder-coated ceiling grids are big upcharge and do not add value for the client or air quality.  

Copy/pasting a post from earlier today to this thread:

the July 2023 edition of the v4.1 BD+C reference guide states:

"Stone, ceramic, and porcelain tiles; powder-coated metals, plated or anodized metal, glass, clay brick, and solid wood are materials which, on their own, are considered inherently nonemitting without additional information. For other materials, a manufacturer chemical inventory of the product to at least 0.1% (1,000 ppm) is required to confirm the product complies with the inherently nonemitting sources criteria."

Manufacturer chemical inventory programs (e.g. Health Product Declaration, Declare, etc) outlined within the Materials Ingredient credit are accepted by GBCI as demonstrating the product is inherently nonemitting. 

If a manufacturer chemical inventory program document is not available, then you'll need to demonstrate compliance with one of the programs listed here:

https://www.usgbc.org/resources/cdph-list-certifications-use-cdph-standa...

If you cannot demonstrate compliance with one of the programs listed in the link above, then the product is not compliant (per GBCI) and you'd need to obtain costs OR surface area OR volume in efforts to meet the category threshold."

hope this helps.