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.
- Certificate / lab report expiration dates relative to spec / installation dates
- Scope creep of the product categories (review comments asking for concrete admixtures and weatherproofing components, inclusion of exterior windows and doors in an otherwise interior credit, expansion in latest v4.1 addenda to add stair nosings and transition strips to Flooring...)
- Review comments asking for documentation of inherently non-emitting products
- No compliance path for products like windows that are 99% non-emitting (manufacturers are never going to pay for testing of something like that)
- Requirement to provide a full certificate or lab report for every product submitted. Or documents being rejected for details like lab accreditation.
- Requirements to include product types that are nearly always non-emitting (e.g. ceiling grid, tiles, windows, drywall compound, metal door frames...)
- Different standard for composite wood depending on application - e.g. if a wood product meets the formaldehyd standard, and is used as a wall base, it needs to meet CDPH, but it's the same product!
- Need to calculate compliance by percentage when one noncompliant product was used on a small area
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:- Clear product categories that focus on materials that are: interior, large-scale (yes to carpet, no to transition strips), likely to affect indoor air quality for installers or occupants (is there actually high-emissions drywall out there we need to worry about?). No "kitchen sink" approach to the product categories, but one that targets the most impactful materials.
- Clear (and realistic) guidelines about product certificate expiration dates that take into account the cost of testing and the length of time between specification and installation for long timeline projects
- Ability to submit documentation for XX% of materials rather than every single one. Or flexibility on documentation so that manufacturer statements of compliance with CDPH v1.2 are allowed. Anything to reduce the burden of digging up a compliant document for every single product!
- Composite wood products can meet CDPH OR formaldehyde standard
- Built-in grace for small-scale product applications, e.g. if something is less than X gallons or X square feet it doesn't need to be documented. often this is the case for custom wall/ceiling products in a lobby, or special-use adhesives.
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%.