Hello SDL Leaders,
Over the past month, I have been working with ILFI to navigate the question of residuals in LBC compliant products vs. products reporting for a Declare label.
Through our conversations, it came to light that ILFI considers the LBC Red List threshold to be 10,000 ppm, rather than the 100 ppm written into the existing LBC standards.
They have recently generated a dialogue post to clarify this change: https://support.living-future.org/article/887-20-0109-ingredient-disclosure-threshold(I included the language below in case you don’t have access to the dialogue)
As it stands, this applies to all LBC 3.0 and 3.1 projects, and the expectation is that it will also be included in the LBC 4.0 handbook language when released in coming weeks.
While I have already written ILFI to express my concern and would encourage others to do the same, I’d be interested in hearing your thoughts on this and if you have any background as to why ILFI might be willing to give up so much ground. It seems a bit out of place to me.
Thanks, John M
"20-0109 v3.X Ingredient Disclosure Threshold
The following Clarification applies to Living Building Challenge projects under versions 3.0 and 3.1. Projects registered under LBC 4.0 should refer to the LBC 4.0 Materials Petal Handbook for superseding guidance on ingredient disclosure thresholds.
Ingredient Disclosure Threshold
Project teams are required to vet ingredients within products to a level of specificity between 10,000 ppm and 100 ppm (1%-0.01%). A disclosure level of 10,000 ppm aligns with SDS ingredient reporting thresholds. For example, if a project team collects an SDS disclosing 100% of ingredients by weight with Chemical Abstract Services Registry Numbers (CASRN), no additional ingredient information is required. Manufacturers are not required to provide an ingredient breakdown below 100 ppm, the same disclosure level required for the Declare program. If an intentionally added Red List ingredient is present below 100 ppm, the product is still considered Red List free and compliant with the LBC requirements. Ingredient disclosure provided at any level within the required 10,000 ppm to 100 ppm range is considered compliant disclosure documentation. For example, a fully disclosed HPD showing no Red List ingredients or aligning with a published exception is acceptable ingredient disclosure documentation."