I'm very pleased to see the VOC emissions testing requirements extended to all interior surfaces. I’m concerned, however, to see that the VOC content restrictions have been eliminated for wet applied products on interiors. Adding 01350 type emissions testing is probably a good thing for protecting long term chronic health of occupants. Remember, however, that this test does not start benchmarking emissions until 14 days after application of the finish or adhesive. Very high levels of VOCs can outgas quickly before the 14 day mark and may represent the bulk of the VOC impact. Evidence of this potential can be seen in paints can pass the 14 day emissions standard but have very high VOC content levels, such as Behr Premium Plus Interior/Exterior High Gloss Enamel Series which apparently passes GreenGuard Children & Schools but has a Coating VOC content of 142 g/l according to its MSDS: http://www.actiocms.com/VIEW_MSDS/AuthorDisplay_V402/msdsdisplaycode_aut...
This leaves two interior health issues and one exterior environmental health issue vulnerable that the previous VOC content restrictions helped address:
1) Installation crew: Painters and installers are exposed to the pre 14 day high levels of VOCs constantly.
2) Occupants: Realistically there often end up being occupants in adjoining spaces to construction, particularly in additions and CI projects that may be exposed to the short term high VOC levels as well.
3) Smog : Most of the VOCs that offgas from coating or adhesive applications to interior surfaces will end up ventilated to the outside environment. The total surface area of interior walls, floors, and ceilings will generally end up being far larger than the exterior surface area. Hence the potential contribution of reactive VOCs to the outside environment from interior painting and adhesives could be much larger with equivalent product VOC content.
Reduction of emissions of smog forming volatiles is probably sufficient reason to warrant keeping the SCAQMD and CA ACTM VOC content limitations in place for wet applied interior products. That is an exterior air quality issue, not an IEQ issue per se, but an important health impact nonetheless and should not be lost. Then there are the direct IEQ issues for installers and occupants from the short term emissions. VOC content is a crude measure, but until the industry establishes agreed upon methods for lab measurements of short term emissions from wet applied products and benchmarks for them it is the best we have and we can’t afford to throw it out.
Anne Less
Green Team Consultant, Healthy Materials + Knowledge ManagementGoogle
18 thumbs up
September 7, 2011 - 8:21 pm
I am also quite concerned that VOC content restrictions have been eliminated for wet applied interior products.
Reinhard Oppl
Independent consultant on VOC issuesformerly with Eurofins Product Testing A/S
329 thumbs up
September 8, 2011 - 4:19 am
This is a question of what belongs where.
VOC content restrictions do not correlate at all with indoor air quality and consumer exposure, as very most VOC evaporate within the first few hours. And the VOC content limits are so high that remaining VOCs will contribute significantly to consumer exposure indoors during several weeks, if not months.
VOC content restrictions protect not indoor air but outdoor air - therefore these could become part of Materials and Resources credit, but not of the Low-Emitting Interiors credit which deals with long-term exposure indoors. And if that would happen then the test method needs to be updated - the present test method works fine only for solvent-based products, it fails technically with many modern low-emitting products. ISO 11890 would be a standard representing recent state-of-the-art.
Subtraction of exempt compounds (not being an issue for smog formation) is another reason why VOC content limits will protect neither consumer nor painter. There are products on the market where most VOC is made of acetone, because this is an exempt compound and not counted as VOC by SCAQMD or Green Seal, even though this is not a good solution for healthy indoor air.
Short-term exposure while painting is another issue. Here you are having TWA air limit values published by NIOSH and OSHA that should be respected. Also here, VOC content and painters' exposure do not show any quantitative correlation. I wonder whether we really do need additional requirements in LEED. We do not have such specifications in LEED regarding workers exposure to other hazardous substances such as dust, fibres, etc.
Dwayne Fuhlhage
Sustainability and Environment DirectorPROSOCO, Inc.
169 thumbs up
September 14, 2011 - 1:10 pm
I want to reiterate Reinhard’s comments regarding safety management during product use. At the risk of sounding callous, construction activities are inherently dangerous and require job hazard analysis, planning and training in accordance with OSHA regulations and the general duty obligations of employers. We don’t propose to eliminate metal grinding or welding due to heavy metal emissions or ban cement flatwork because it exposes workers to an alkaline corrosive; we manage risk. In the case of chemicals management, that involves hazard communication, application of engineering controls and as a last line of defense utilizing PPE based on hazard potentials.
That’s not to say I favor using high risk chemicals inside buildings. Ultimately, specifiers need to balance risk, performance and longevity with every building component and system. Sometimes that means choosing a coating with an inconveniently high published VOC content. The CARB coating regulatory limits are the result of a market study of around 950 manufacturers supplying products in California and a two year technology review and rulemaking to set technology forcing VOC standards in each and every category. I mention the CARB rule as it is referenced in the exterior LEED for Healthcare credit system. I cannot support use of Rule 1113 for numerous reasons mentioned in my LEEDUser comments on the first draft of LEED 2012.
I’m glad Tom posted an example of a product in a category with a 150 g/L regulatory VOC limit. That number sounds high, and perhaps it would be in an 85% solids product with the balance being a high risk organic solvent such as xylene. Product selection is where professional judgment must come into play. I don’t make or compete with the example product, so I can put on my corporate safety hat and look at it objectively based on one hazard communication document and pretend it will used in my production facility or corporate office.
Based on the MSDS for this product, the primary VOC is ethylene glycol at 1-5% of the formulation. This would be consistent with a published VOC content of 57 g/L with water included in the calculation. Since it is over 1 pound per gallon solids, the calculated coating regulatory VOC content must be based on subtracting a primary carrier solvent, water, yielding a label VOC content of 142 g/L. The vapor pressure of ethylene glycol is negligible at 0.06 mm Hg; it will not volatilize quickly and any initial exposure to applicators should be minimal and easily remedied with minor cross-ventilation. The product is non-flammable with a NFPA rating of 1 for flammability.
This is the type of analysis I go through with construction management and corporate safety personnel when they call to talk about potential hazards and safety management in using my products. Most of my interior products have a similar or lesser risk profile, but I do have specialized products for problem substrates and applications that have higher risk potential. I talk through those problems honestly so they can apply appropriate engineering controls and procedures. They can also go back to their specifier and look for other options – I do have competition.
This particular example points to the problem of using gross VOC or emissions TVOC as the sole means to determine whether a product is good or bad. This product is relatively low risk and yet has been pointed to as being intrinsically bad because of the 142 g/L VOC content. Yes, it would be great if they could eliminate the ethylene glycol, but would the product still flow, form a proper film and meet ASTM performance standards and owner expectations for aesthetics and performance? Can it be touched up, or does the entire wall need to be re-coated if someone relocates a towel dispenser?
The one thing we collectively neglect in the debate over VOCs is that coatings and sealants, like every other component in a sustainable building, need to meet longevity and performance objectives. We don’t suggest making glass thinner solely because of GHG emissions during production. We don’t skimp on structural welds because of weld fumes. We don’t ban earth moving due to dust and diesel emissions.
If this were an intumescent coating, we would not suggest using a lesser material at risk of allowing structural steel to melt in a fire. If it were a rust preventative coating, a building owner has every right to expect that metals near the swimming pool or locker room won’t rot away. If it were a water repellent, there should be an expectation that it will prevent degradation of the substrate as specified.
My company works closely with conservators and building forensics specialists. Degradation to historic structures is disheartening. Products like terra cotta and Indiana limestone were supposed to be maintenance free “forever” building materials.
However, I am even more concerned about the state of our new building inventory. USGBC’s LEED system has successfully transformed the commercial and institutional construction market. Every building system and subsystem has been rethought. Building exterior assemblies are often composed of products that barely existed 15 years ago. Unfortunately, many 10 year old assemblies are already leaking water and have required extensive remediation. Coatings and sealants are critical components in those systems. As we earnestly discuss the potential of using CARB SCM and Rule 1168 VOC limits for all LEED project exteriors, how should performance questions help guide the debate?