Pilot Credit 21 Criteria in the EU

Good points. VOC content limits are in this credit only by history. Some VOC will evaporate within very short time, other VOCs will be emitted into indoor air continuously over a long time. Only if there are no small traces at all of any VOC then there will be no emissions - there is no further correlation between VOC content and indoor air quality. Both US and EU regulations on VOC content were established for protection of outdoor air against smog and ozone formation. They came into LEED at an earlier time because there was no other low VOC regulation available for coatings, adhesives etc.at that time. Test methods behind US VOC content limit values are old-fashioned and not applicable to most advanced coatings and adhesives (water-borne, 2-component and other reactive ones). And subtraction of exempt compounds without ozone depletion potential - as done in the USA - is meaningless in the context of indoor air quality. At least outside the USA we need alternative pathways. Therefore GBC Italy now requires low VOC emissions of adhesives and sealants (referring to EMICODE EC1 product requirements) and low VOC content of paints and coatings referring to EU Decopaint Directive. Proposed PC 21 language includes EU Decopaint limits as alternative pathway, for including products tested for EU without having to repeat testing these for US limits with partly improper test methods. Reference is made to European Directive only, not to national interpretations. Yes there are differences between EU Decopaint VOC limits and US VOC limits, and some products passing Decopaint will fail US VOC limits, but also the other way round. Texanol is a good example of the difficulties with EU Decopaint Directive: Pure Texanol will not be considered as VOC in EU (boiling point just higher than 250°C), but technical Texanol has slightly different boiling point and will be inside VOC definition - this can lead to different interpretation, for sure. The proposed credit language is nothing else than adding a non-perfect European solution to a non-perfect US solution in order to gain more international applicability of LEED. An environmental leadership solution for IEQ credits would be no longer to require low VOC content but only VOC emissions, as PC 21 does for other products.

As to why VOC content limits were retained for wet-applied products on site, everyone working on the proposed credit agreed VOC chamber emissions requirements were better for improving air quality. However, some felt the VOC content requirements were evolving to provide protection against compounds of concern that may not be readily measured by VOC emissions chamber testing. Thus, the credit was structured to retain content requirements in part for this reason, and in part to allow partial credit for VOC content compliance of wet-applied products while the market transitioned to VOC chamber emissions requirements. Also, for adhesives and sealants that are not applied "full-spread" or across the entire surface of a wall, floor, or ceiling, there was a concern that the current emissions chamber test method does not address how much adhesive or sealant must be applied when determining compliance.

UL Environment has been following comments on the IEQ section over the last few weeks and we appreciate being able to hear all of the points and counterpoints which have been expressed. As many of you know, Underwriters Laboratories has been in the standards development business for over 100 years, and as a company that frequently organizes and moderates these types of discussions, we believe that this open and candid dialogue is healthy and helpful in reaching sound and supportable solutions. We have reviewed the formal changes being proposed in LEED IEQc4, in addition to the comments being posted on the LEED User Forum, and would like to provide our perspective as well. Before we get into the specifics, it might be helpful for us to share our overall philosophy, which is the basis for many of these comments: UL Environment supports and will continue to support any changes that will encourage, promote, maintain and ultimately, result in healthier products and indoor environments; especially, when such changes are driven by sound science and data. In making this statement, we do realize that this may not always be possible given that the science may not yet exist or if it does exist, it may not fully align with the outcomes desired, but we still believe we should strive to make this vision into reality, as we all work together to solve this global problem. Here are UL Environment’s comments about the changes being proposed in LEED IEQc4: • We believe that an expanded scope for LEED beyond the US is necessary since improving indoor air quality is a global issue that requires a global solution. As such we support the continued use of the CDPH Standard Method v1.1 until a better method becomes available. We think its practicality, reproducibility and technical foundation is relevant on a global basis and so far has achieved good market acceptance. This is further supported by the fact that The International Construction Council and ASHRAE have referenced only the CDPH Standard Method. In addition, some recent comments from G. Miller, President of the AIA, suggest that the new International green Construction Code, which prescribes CDPH, may be legally enforceable. This is another datapoint that we believe should be considered in this discussion. Attached is the URL of these comments if you are interested: http://featured.matternetwork.com/2010/11/international-green-construction-code-game.cfm. We do understand there are some concerns with CDPH; mainly the number of CREL values currently available (35). However, we also believe that this hurdle can be overcome in a relatively short order with the collective efforts of this group by increasing the number of CRELs. • At this time, we do not believe that adding more methods, protocols, and approaches to the LEED standard would be productive unless these additions materially improve indoor air quality and human health. There are several reasons for our position. First, we believe that adding more methods at this time would simply increase confusion and complexity for consumers, LEED users (i.e., Architects, Builders, etc.), manufacturers and other key stakeholders. The increased confusion and complexity likely would discourage pursuing the IEQ credit at all. This outcome would be opposite of what we are all trying to achieve, and as such we think keeping things stable until harmonization of methods can occur is the better path. We support harmonization, but think this is a discussion that should occur outside this process and be adopted once agreement is reached. The second reason we would not support these additions at this point relates to the science. As Dwayne Fuhlhage and several others have pointed out, none of the European standards being proposed for inclusion as alternatives are accepted as written by all the member states of the EU. Different EU member states have adopted these standards with material differences. In addition, the EU standards are missing important elements. For example, a volatile chemical emission like formaldehyde, clearly recognized as a concern based on its classification as a carcinogen, is addressed by the AgBB Testing and Evaluation Scheme only through reference to the AFFSET criteria. Similarly, the EU Decopaint Directive lacks equivalency in scope and criteria to the available standards, which in our opinion doesn’t lead us to better human health. • Outside of what is being proposed, we would also like to offer some suggestions that we believe could advance IAQ in the marketplace. We believe individual speciation and analysis (IVOC) is a good tool and would like to see these continue to be a significant component of how measurements are done. We also support TVOC as a broad monitoring mechanism, but not necessarily as the sole pass-fail determinant for product certification decisions. We think the science has advanced beyond TVOC as a single approach for product emissions evaluation, which is good for human health. Lastly, we believe that chemical listings by product category could offer some unrealized benefit. Logically, there are so many combinations of chemicals and products and processes that contribute to making products, it only points to the fact that there may be some value in characterizing product categories and their emissions characteristics. It’s important, and worth the discussion as we work towards a healthy indoor environment. We hope you find these comments helpful. We appreciate your time and attention, and look forward to any feedback you have. Respectfully submitted, UL Environment, Inc.

I appreciate your thoughtful comments. You raise the issue of whether the European AgBB emissions test method and requirements should be adopted within LEED. This is an issue worthy of discussion that has so far not received much attention in this forum. Many have noted (under this credit and others) the strong requests for LEED to give credit for international standards, programs and criteria. Inclusion of international criteria will likely expand international use and make it easier to find local materials and products that comply. These benefits are very appealing and in the absence of harmonized requirements, it is very tempting to include multiple optional requirements that are similar, yet also different. The danger here is that different requirements yield different results. One of the primary reasons people support standards development is to enable harmonization on valid methods and meaningful criteria. When multiple, competing criteria on something like VOC emissions exist, manufacturers and purchasers are often confused. The playing field is not level nor fair, as it is difficult to make meaningful comparisons between products. Considering the entire market, compliance often becomes required for all cited programs. Manufacturers and ultimately customers must pay for multiple tests and evaluations that are similar, yet not identical. Precious time and resources are wasted. This practice is inherently not sustainable. As markets and standards mature, harmonization ultimately ensues because it is essential for market efficiency. It is important to balance the need for harmonization with the need for easing use internationally. The LEED rating systems have a role to play in market harmonization, and not surprisingly have led to the use of some North American requirements (like CA 01350) in other countries. The German AgBB program is a well-respected program and while it does not represent a European consensus, it does share common attributes with several other European counterparts. It was included in the proposed credit as a compromise in an effort to facilitate international use of the LEED rating systems. It contains more individual VOC requirements than the CDPH Std Method (as has been discussed in this forum), but it does not always ensure lower VOC emissions from products. The AgBB requirements use different exposure scenario conditions than the CDPH Standard Method v1.1. VOC emissions from building materials generally decrease over time, thus the time point for determining compliance is critical. Longer times allow for additional off-gassing to occur and are generally easier to meet. The CA Standard Method v1.1 requires compliance at 14 days, while the full AgBB requirements apply at three or 28 days, which the proposed credit does not take into account. Converting the required emissions limits for the AgBB and CDPH Standard Method into common units (to correct for variations in exposure scenarios), my initial calculations (unchecked by others) show that 10 of the CDPH emissions limits are lower (tougher) than their AgBB counterparts. This is ignoring the difference between 14 and 28 days. Of course the AgBB program includes requirements that the CDPH Std Method does not. If we are going to include an international program like the AgBB within LEED, shouldn't we require that products using this option must also meet the CDPH Standard Method requirements (where they are tougher) as a consistent baseline? This could be accomplished by requiring additional calculations on AgBB results and/or limiting compliance claims using the AgBB to time points at 14 days or earlier.

Randy If you require compliance with both programs (e.g. CA 01350 and AgBB), then you will continue to need increased volume of testing, and then there will be even less products available in the market than before. Most low VOC products have been tested against either CA 01350 or against AgBB. Requiring compliance with both programs would look good for testing labs like our one, by increasing market demand for VOC emissions testing, but it does not really help in making available a larger number of compliant products to LEED projects.

One more remark on European low VOC programs. Like Section 01350 in the USA, AgBB can be considered the most widely accepted low VOC program in Europe. Several other low VOC programs are using the AgBB approach, but working with more stringent limit values or shorter testing duration, such as EMICODE, PRODIS/GUT, AFSSET and Blue Angel. Several contributors stated that there are still a lot of differences between EU member states, but you may see more light in this jungle during next year. Harmonization of test method foregoes in CEN TC 351 WG2 and is expected to lead to a published testing standard during 2012. A draft document is already available. Harmonization of performance classes, meaning different levels each with specified limit values, is worked on between European Commission and national regulators. Timeline is not as clear but they make good progress and this could be published also in 2012 as basis for future CE marking. This would even include EU-wide harmonized LCI values.