As mentioned above in November the USGBC began a public comment period on an updated version of the LEED Rating system and EQc4.0 is updated within it.
According to the USGBC, it is expected that this comment period will lead to substantial changes and improvements to the proposed draft credit revisions. As someone who works with LEED on an ongoing basis you want it to not only represent the best in sustainable building, but also be understandable and easily implemented.
Unfortunately there are some problems with the draft credit language for IEQ Credit 4.0 (and therefore the above Pilot Credit) and if not fixed they could have a negative effect on the indoor environment in these high-performance green buildings. These issues include:
• The proposed low-emissions credit fails to make product emissions requirements more stringent. They still only look at 35 individual chemicals and then only certain products do that many chemicals. Some product types look at the total chemicals emitting from a product and others don't. Yet there are 10,000 individual chemicals that can come off man-made products. Only 10 of the top 100 that are most commonly seen coming off of products are in the 35 individual limits. This is not protective enough for a sustainable building.
• At a time when pollutant source control is desperately needed to protect human health, the proposed credit introduces a layer of complexity that will likely discourage project teams from pursuing it. Instead of simply telling you what standard a product should follow it is asking you to do complex calculations. We have been told by numerous LEED professionals that due to this complexity they are likely to skip this point altogether.
• Differing product emissions requirements within the proposed credit mean that LEED Certified buildings in North America could have worse indoor air quality than those constructed outside of North America. There are different standards allowed for buildings outside North America - standards that look at hundreds of individual chemicals for many products, yet within North America the limit is only 35 individual chemicals.
• Poorly defined and inconsistent product emissions criteria and test methods within the proposed IEQc4 mean that some qualifying products could emit higher levels of chemicals than others, posing a significant exposure risk. Different products are held to different chemical emission criteria - this would be like having different chain of custody rules for wood used on the floor and wood used on the wall. All products in our indoor environment should have to meet the same chemical emission criteria.
• A lack of direction, appropriate reference methods, and verification requirements in IEQc4 will lead to confusion, misapplication, and abuse of the credit, which will have a detrimental effect on indoor air quality. Some of the current reference methods have 6 different pathways to show compliance. These different pathways will likely lead to completely different outcomes – leaving the system easy to manipulate, as manufacturers can simply pick the path that shows their product is low-emitting when in actuality it may not be.
All comments must be submitted to the USGBC by January 14th!
Please help protect the health of LEED building occupants by submitting your comments today. For more information on the proposed language, sample comment language and instructions on how to submit comments to the USGBC, please visit www.greenguard.org/pledge
Thank you again for your commitment to good indoor air quality in green buildings .
Tristan Roberts
RepresentativeVermont House of Representatives
LEEDuser Expert
11477 thumbs up
December 16, 2010 - 1:16 pm
Josh, what is your suggestion on how the credit should be written?I noticed you're with Greenguard, which would be directly impacted by the proposed revisions. We appreciate it when people on our forum disclose connections like this when posting. It will help us focus on the principles of your suggestions rather than be concerned about potential biases. Can you comment on how this affects Greenguard and your thoughts on that?
Josh Jacobs
Technical Information & Public Affairs ManagerUL Environment
515 thumbs up
December 16, 2010 - 1:25 pm
Sorry - thought my title came through with my name. I am Technical Information & Public Affairs Manager with GREENGUARD Environmental Institute. Actually we are working on our full comments right now, but we have posted some initial comments that people can look at on our website.
Also, as currently written GREENGUARD Children & Schools would still qualify any product certified to it to comply with the credit - so our concern is not about whether GREENGUARD will be impacted or not.
We are very concerned with the impact that the credit could have on sustainably certified building . This credit will get used even less then it does now; it gives different criteria to different products (under the same credit) and it opens up the possibility that people could be exposed to more chemicals - which shouldn't happen in any circumstance, but especially not in a sustainably certified building.
Tristan Roberts
RepresentativeVermont House of Representatives
LEEDuser Expert
11477 thumbs up
December 16, 2010 - 1:28 pm
Thanks for the additional background. You can edit your profile with a title and company so that that info appears, under "my account" in the top right of the screen.
Josh Jacobs
Technical Information & Public Affairs ManagerUL Environment
515 thumbs up
December 16, 2010 - 1:35 pm
Thanks Tristan - as soon as we have our suggested credit language I will post here.
Randal Carter
Director, Global Product Safety and ComplianceSteelcase Inc.
91 thumbs up
December 16, 2010 - 10:57 pm
I am writing this from Beijing, where I am one of two U.S. advisors to a government research team developing a low-emitting furniture standard and certification program. Therefore I unfortunately have little time to respond in detail just yet.
The technical issues raised in Josh's comments are complex, and include some valid concerns worthy of legitimate debate. However, these comments also reiterate and expand on the inflammatory and inaccurate claims available at www.greenguard.org/pledge that may unnecessarily instill fear and confusion.
These claims include:
“The proposed IEQc4 fails to make product emissions requirements more stringent.” And “…the proposed changes—if accepted—could result in the creation of unhealthy interiors in all LEED Certified buildings, including schools.” And “Rather than raising the bar on indoor air quality and requiring rigorous, comprehensive chemical emissions limits, the proposed IEQc4 encourages adherence to weak product emissions criteria and insufficient test methods. This is alarming, given that the intent of IEQc4 is to safeguard against poor indoor environmental quality. Moreover, the proposed revisions to IEQc4 all but ignore the serious concerns with indoor air quality that were raised in the April 2010 report, LEED Certification: Where Energy Efficiency Collides with Human Health." And now ”...manufacturers can simply pick the path that shows their product is low-emitting when in actuality it may not be."
These claims are categorically false.
The proposed IEQc4 credit significantly strengthens the USGBC requirements for indoor environmental quality. Notably, it adds VOC emissions requirements from the California Department of Public Health (CDPH) to paints, coatings, adhesives, and sealants where only VOC content was previously addressed. It expands the scope to address more VOC sources within a building (thermal and acoustic insulation, all individual furniture items, all layers of ceilings, floors, and walls, and built-in cabinetry). Previously ceilings were not addressed in all rating systems and emissions from insulation, individual furniture items, and built-in cabinetry were not addressed at all. It adds CDPH Chronic Reference Exposure Level (CREL) based requirements for furniture. If you are not aware, CDPH requirements include one of the toughest formaldehyde emissions criteria in the world.
Continued legitimate debate about the credit content is vital to this process. The good news here is that the proposed credit is stimulating this debate, even if some participants may be motivated in part by keeping their proprietary programs written into the credit language. I encourage others, especially members of the USGBC IEQ TAG and the USGBC IEQ working group who participated in the 1.5 year effort to draft the proposed credit, to participate in this discussion.
Josh has posted his comments on two forums; this one focused on all LEED 2012 proposed revisions, and the one focused on Pilot Credit 21 Low-Emitting Interiors. I will post my initial response on both, but I suggest we shift the detailed commentary to the Pilot Credit 21 page, as it focuses specifically on the credit under discussion.
I plan to post additional responses to the specific concerns as I can make time available while traveling. A detailed FAQ document that addresses many of these issues is available on the LEEDuser.com pilot credit 21 page, or at this link: http://www.leeduser.com/system/files/sites/default/files/EQc4-PC21_FAQ_3....
These issues are not simple nor easy. Good people are struggling with these all over the world, and there is certainly room for improvement in the proposed credit. I am confident that this debate will help us to make the LEED program even better.
Tristan Roberts
RepresentativeVermont House of Representatives
LEEDuser Expert
11477 thumbs up
December 17, 2010 - 7:48 am
Further discussion of this credit will be limited to the PIlot Credit 21 forum on LEEDuser. Please read and discuss there.