For full disclosure I am the Technical Information and Public Affairs Manager for GREENGUARD Environmental Institute.

As mentioned above the LEED Pilot Credit 21 is being proposed as the new EQc 4.0 for ID+C and BD+C. In November the USGBC began a public comment period on an updated version of the LEED Rating ( system and this credit is 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!

GREENGUARD Children & Schools Certification would still currently qualify any product certified to the new language, so our concern is not how it effects us, but how it effects sustainably certified buildings and their IAQ. 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

Thank you again for your commitment to good indoor air quality in green buildings .