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. 

Dave,  Hi.  

I understand the addtional info provided in the July 2023 v4.1 edtion of the Ref. Guide, but I am unclear as to how I can confirm the chemical inventory listed in (for example) an HPD demonstrates inherently non-emitting status.  Does the list need to name one of the LEED stated Inherenly Non-emitting" materials such as  "anodized aluminum" or "stone" and then show the breakdown of that material to at least 1000 ppm?  

I am asking specifically because our project has a paper joint tape that is claiming "self-delclared" VOC emissions compliance in their HPD (which is Not third party verified) and I would like to understand how I can verify this claim.

I don't know of any 'joint tapes' that would be considered inherently nonemitting. 

Here is a forum discussion that may help:

Joint Compound and Joint Tape - GREENGUARD Gold requirements | LEEDuser (buildinggreen.com)

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?

The coloring on a ceramic tile is applied before the tile is fired, it is part of the non-emitting product as you note. 

As Dave quoted from the v4.1 reference guice, ""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."

So you are correct to submit ceramic / porcelain tiles without additional documentation, however, as you can see, some of us have still gotten comments asking for additional information on these products. It is a known issue with review consistency and overly stringent comments.

Ceramic tile is usually considered inherently nonemitting.  However, there could be cases where it is not.  This is how Inherently Nonemitting is defined in LEED V4.1: 

Product is an inherently nonemitting source of VOCs (stone, ceramic, powder-coated metals, plated or anodized metal, glass, concrete, clay brick, and unfinished or untreated solid wood) and has no binders, surface coatings, or sealants that include organic chemicals.

The part of this statement that could make ceramic tiles emitting is,"..and has no binders, surface coatings, or sealants that include organic chemicals." If the product information, or letter from the manufaturer, shows there are non of these that include organic chemicals then that would suffice.  Otherwise a VOC Emissions Evaluation would be needed.  

I would like to ammend my previous statement on this. As Emily Purcell correvtly pointed out the LEED BD+C v4.1 Reference guide makes it clear (pg. 241, under Required Documentation) that stone, ceramic, powder-coated metals, plated or anodized metal, glass, concrete, clay brick, and unfinished or untreated solid wood are considered inherently nonemitting.  No further documentation is required.  However, mortar, adhesive and grout for ceramic systems are not incuded in the inherently nonemitting products designation.  

Hi. 
So if we have windows with plastic frames -do we need to request a VOC certificate for the whole product? Can we put it under non-emitting material? or should I put glass and then a plastic frame? 

Also for steel doors - they are prepainted outside of the site- Does it mean I have to request a VOC certificate for the whole product? or put steel doors in wall sections and paint in the paints and coatings section in the calculator?

Becuase they have a plastic frame, they can't be considered non-emitting. I've had GBCI confirm to me that even a metal framed glass door with a vinyl gasket or sweep is still ineligible for non-emitting - if there are any organic components at all, it can't go in that category.

Ideally, the manufacturer can provide a VOC emissions certificate for the whole product.

If they can't, you could break it out by "glass" (non-emitting) and "plastic" (non-compliant) and enter the square footages into the budget calculator. 

I believe a factory-painted door would be considered a Walls product and you would need a VOC certificate for the finished product but nothing in the Paints category.

I realize the odds of either manufacturer having a VOC certificate for these finished products is low, hopefully you are able to offset the non-compliant areas with compliant glass, drywall, wood doors, etc...

I agree with all of that

Hey all, I need to correct myself after receiving my most recent review back. In my earlier comment I said:

Ideally, the manufacturer can provide a VOC emissions certificate for the whole product.

If they can't, you could break it out by "glass" (non-emitting) and "plastic" (non-compliant) and enter the square footages into the budget calculator. 

I attempted the Walls category on a recent project and included some doors and windows using this approach, which I had successfully done with exterior windows in the past. I got the comment:

 The proposed methodology of separating interior windows, etc. into component parts is not acceptable. As noted in the Preliminary Review Comments, the entire product and the fabrication must be considered as a whole. Note that when an inherently nonemitting material is joined with binders/resins, other materials (e.g. gaskets, core/internal components), has a surface coating, treatment, or adhesives/sealants, etc., the resultant product is subject to the VOC emissions evaluation criteria.

So, seems like GBCI is stricter about this these days. Not really sure where to go from there except to not attempt the Walls category any longer. If exterior assemblies must be included, and manufacturers aren't getting those evaluated for emissions (why would they?), AND they can only be considered as whole products, there's no viable path.