Overall: I like the simplified point & percentage threshold structure! Much easier to communicate to a contractor than the v4.1 version.
Paints & coatings:
“specialized finishes (dyes, sealers, hardeners and toppings for concrete floors)” Are these products only included if the concrete floor is otherwise unfinished? I.e. does hardener/topping need to comply if a carpet is installed. In addition, please provide language clarifying that concrete admixtures are not required to comply. I see that poured concrete is not required to comply with the Flooring category so I would assume that includes any admixtures that do not serve as a separate finish.
“Include at a minimum the following types of paints and coatings, as defined in SCAQMD Rule 1113” I’m confused by the “at a minimum” language. If the product is not defined within Rule 1113, how do we know this category applies and what defines VOC content compliance?
Insulation:
“Exclude insulation for HVAC ducts and plumbing piping from the credit. Insulation for HVAC ducts may be included at the project team's discretion.” Please clarify whether duct insulation is excluded or optional
Formaldehyde emissions eval:
“This applies to a finish or treatment applied less than one before installation to a salvaged or reused composite wood product.” The time period is missing.
Walls:
“The walls product category includes all finish wall treatments (wall coverings, wall paneling, wall tile), gypsum or curtain walls, retail slatwall, trim, interior and exterior doors, non-structural wall framing, interior and exterior windows, window treatments, countertops, laminate/veneer used for built-in cabinetry, non-structural sandwich panels, and CMU.”
Curtain wall: This term should be clarified, unclear whether it refers to a building enclosure or an interior fabric partition. If it’s a building enclosure, see below…
Framing, windows, exterior doors, CMU: These should not be included. Framing and CMU are non-emitting, except for any coatings that would fall under the coatings category. Framing also does not have a “surface area” to be easily measured. Windows and doors are made primarily of non-emitting materials, are installed (by definition) before the building is enclosed, and are often custom-fabricated such that product testing is not practical. Manufacturers are not going to start testing window gaskets and insulation because the risk of emissions to installers or occupants is so minimal. So far in my experience the inclusion of these items just means the project team is going through unnecessary product logging and surface area calculation exercises to demonstrate that these materials don’t affect overall VOC emissions compliance. Effectively it is hours of work to demonstrate that a primarily metal and glass product is in compliance, which is not an exercise that drives better product standards or design.
In order to reduce the documentation burden, the credit requirements should be limited to products that have a risk of emitting VOCs during construction or occupancy (i.e. wall finishes). At this point, project teams are simply skipping the Walls category altogether because one noncompliant countertop or door means having to do an area takeoff of *all* materials that fall under this category to demonstrate that the % threshold is met. It has become so difficult to document this category as a whole that the wall finish products that most affect IAQ are not being tracked for compliance.
If these items are to remain in the credit requirements, I would urge the credit authors to go through the exercise of quantifying 90% compliance for a sample bill of materials to understand the feasibility and workload issues involved in determining their surface area and percentage compliant, before finalizing the language. Any kind of tool or workaround to simplify the process would be a huge help if we need to account for such difficult to document materials.
Emily Purcell
Sustainable Design LeadCannonDesign
LEEDuser Expert
367 thumbs up
May 9, 2024 - 3:27 pm
Adding some follow up comments after participating in a few LEEDv4.1 LEEDUser threads about this credit...
Overall this credit has felt to many LEED users like a huge investment of time in admin/paperwork for very little gain in better material performance. Getting compliant products for major product categories isn't the hard part, but the following are current pain points:
The above lead to a lot of work for project teams but they have very little impact on the performance of products and indoor spaces. If there is room to rework this credit, I'd recommend:
I recognize that some of these might be more review approach issues than credit language issues. but the forums here are full of project teams doing 95% of this credit right and having to expend a lot of time working with manufacturers to respond to review comments calling out the last 5%.
Harry Flamm
Senior Sustainability ConsultantStantec Architecture
20 thumbs up
May 20, 2024 - 12:37 pm
I agree with everything Emily stated above. The credit has become onerous and confusing to GC's, and should be easily grabbing the low-hanging fruit of VOC's and compliance.
Speaking of "low-hanging" items -- there is absolutely no health, cost, or availability reason to "exclude (interior) insulations for hvac duct and piping, and plumbing piping" from the insulation category -- and to state that "Insulation for HVAC ducts may be included at the project team’s discretion". (BTW, no other credit talks about "discretion" of adding optional items). Why give it a pass? It smells of industry-lobbying. Add duct and piping to the credit -- it is so easy to comply and makes the intent of the credit consistent.
Lona Rerick
Associate PrincipalZGF Architects LLP
2 thumbs up
May 24, 2024 - 4:58 pm