Technical Information & Public Affairs Manager
UL Environment
LEEDuser Basic Member
356 thumbs up
Director, Global Product Safety and Compliance
Steelcase Inc.
LEEDuser Basic Member
82 thumbs up
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 Pilot Credit 21 Low-Emitting Interiors, and the one focused on all LEED 2012 proposed revisions. I will post my initial response on both, but I suggest we shift the detailed commentary to this 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. Please see the detailed FAQ document that addresses many of these issues (the linke is posted under the Birds Eye View page for this credit).
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 ultimately help us to make the LEED program even better.
