I'm confused about primers. Though addenda changes to the requirements have placed primers in the GS-11 standard category with interior/exterior paints, they also exist in SCAQMD Rule 1113 in multiple categories. The only difference that I can infer about when to use which category is primers used on walls and ceilings vs. primers used on " interior elements".
What I am seeing most often is primers that are by definition flat but exceed 50 g/l. The primer definitions in SCAQMD don't preclude a primer that is being used on a wall, don't distinguish between flat and non-flat, and offer a higher g/l limit. Why wouldn't we use Primer/Sealer/Undercoater?
There are also Primer/Sealer products that are flats and exceed the 50 g/l limit but do comply with the SCAQMD sealer limit.
If there are no substrate specific distinctions, like floor vs. wall or metal vs wall, how do we know which primer category we are able to use?
Susan Walter
HDRLEEDuser Expert
1299 thumbs up
November 8, 2012 - 2:41 pm
From a specification point of view, you always marry your primer to your substrate and then to the finish item. So you should be able to understand what the substrate is. Are you documenting the work of the contractor or are you vetting product for specifications?
Michelle Rosenberger
PartnerArchEcology
519 thumbs up
November 8, 2012 - 2:53 pm
Hi Susan,
I'm documenting the work of the contractor. When the primer is being applied to steel doors for example (and is a flat that exceeds 50 g/l), I am inferring I can use the SCAQMD limit because it's not being used on a wall or ceiling.
However, I also have a masonry wall primer that is also a flat and doesn't meet the 50 g/l limit. So is it no good because it's being used on a wall and doesn't meet the flat limit? Or can I somehow still resort to the SCAQMD primer because the substrate is masonry and not drywall?
Michelle Rosenberger
PartnerArchEcology
519 thumbs up
November 20, 2012 - 12:38 pm
For anyone interested in the answer on Primers from the USGBC:
"A primer is an architectural coating, therefore it must apply GS-11. It is not an undercoater because it is not used to create a smooth surface (see definitions of primer and undercoater in Rule 1113). Specialty primers and floor coatings may still use Rule 1113 as applicable. But the table from the 4/14/10 addenda calls primers to use GS-11 (using the flat, non-flat classifications).
If a project registered after the 4/14/10 addenda, then primers must use the 50/150 g/L VOC limits. The only exception to using this flat/non-flat classification would be when it can be demonstrated that the product meets the definition of specialty primers as per Rule 1113.
Bottomline, projects must always use the flat/non-flat classification for primers and meet GS-11; and only under special circumstances based on the purpose of the primer and supporting manufacturer data which confirms this – they may be classified as specialty primers and use the SCAQMD rule 1113."
Tristan Roberts
RepresentativeVermont House of Representatives
LEEDuser Expert
11474 thumbs up
January 29, 2013 - 5:32 pm
Michelle, what is the source of this quote from USGBC? It's very helpful guidance on primers! I have been asked to clarify this recently and I would just point to this quote.
Michelle Rosenberger
PartnerArchEcology
519 thumbs up
January 29, 2013 - 6:40 pm
Hi Tristan, I'm not surprised based on the difficulties we're having. The quote is from an email from a reviewer. We asked the question at Greenbuild and subsequenty were encouraged to have an email exchange.with one of our reviewers who provided the clarification. A VOC issue is basically impossible to recover from if you don't find out until review time that the product won't fly, so we spent some extra effort trying to understand the requirement correctly. Please note that it is my belief many manufacturers do not view the requirements in this way and many seem to be using the Undercoater and Sealer category of SCAQMD for their primers. I have seen Sherwin Williams and BASF products that say in writing they comply with LEED 2009 that actually don't unless they are using that category.
Lindsey Evans
Architectural DesignerPGAV, Inc.
19 thumbs up
February 11, 2013 - 2:35 pm
Michelle, as a side note if you use a lot of Sherwin Williams products, they have a really helpful VOC Reference Guide which lists the VOC category that each product complies with. You can find it here:
http://www.sherwin-williams.com/wcm/idc/groups/public/@swpublic/@sherwin-williams/@content/documents/webcontent/mdaw/mday/~edisp/sw-leed_voc_referenceguide.pdf
There is a note on page 11 which references the Addenda.
Michelle Rosenberger
PartnerArchEcology
519 thumbs up
February 11, 2013 - 3:13 pm
Hi Lindsey,
This is an awesome resource, thanks. And it also perfectly shows the problem I'm having. Look at the Loxon Masonry Primer product at the bottom of page 12 for example. It's called a primer. It's a flat. Our GS-11 requirement for primers is a 50 g/l limit as they show in the first couple of rows of these tables.
However, they note they are using the Sealer category to comply with their product which is more than 50 g/l but less than 100 g/l. If there is nothing in the product data that indicates the word "sealer" or defines the product as preventing bleed thru from the substrate, then it's a flat primer and doesn't comply, per USGBC.
Sealer and Undercoater is in the SCAQMD standard not the GS-11 standard. That is the problem precisely. Many of these products noted as using the Sealer or Sealer and Undercoater category may not actually comply with LEED 2009 depending on their VOC content and product data language.
Lindsey Evans
Architectural DesignerPGAV, Inc.
19 thumbs up
February 11, 2013 - 3:57 pm
Michelle, I agree that the details and nuances of these definitions are very complicated and important to point out and discuss. It can be frustrating at the very least. Because of this, it becomes necessary to constantly double check product data and compliance documentation.
As for the Loxon Masonry Primer you reference, it does have the word "primer" in the name, but the website for the product (http://www.sherwin-williams.com/architects-specifiers-designers/products...) describes it as, "Loxon Concrete & Masonry Primer is perfect for sealing and conditioning porous above-grade masonry surfaces." The MSDS and PDS also use the word "sealer." This might just be a case of them modifying their compliance path and product description post LEED Addenda, but I would say there is enough documentation to support considering this product in the Sealer category.
Again, I agree with you that there are many products where the definitions get extremely sticky. So thank you very much for posting your information.
Susan Walter
HDRLEEDuser Expert
1299 thumbs up
February 14, 2013 - 3:22 pm
Oh Loxon, you're such a good product but you aren't a low emitting primer. You tease.
Lindsey and Michelle, I'm in the same boat but I think my application has a reasonable sealer story since this is going on new concrete with has properties that we don't want passing through to the finished surface. This would define sealer over primer (which is there to bond) per Rule 1113. I think if we had this going on over CMU, it really would be just a primer. What do you think?
Michelle Rosenberger
PartnerArchEcology
519 thumbs up
February 14, 2013 - 4:16 pm
Hi Susan,
I just had my reply all typed up and lost it in the submit. I hate that.
I agree with you that application should govern, but the reviewers have been clear that the manufacturer data is the key. So if the product says "sealer" or alludes to preventing pass through from the substrate somewhere in the attributes, I think you'll be okay.
Since this issue is so hard to recover from, I have been rejecting them to be safe. As a result I don't have any questionables back from review to be sure. Hopefully, the LI to come will clarify this for us.
Dwayne Fuhlhage
Sustainability and Environment DirectorPROSOCO, Inc.
168 thumbs up
February 14, 2013 - 4:43 pm
Third try: Tristan, what's up with LEEDUser today?
As I understand it, the original credit language called for primers and sealers to be compliant with Rule 1113 as it existed on January 1, 2004. The addenda predates my tenure on the LEED IEQ TAG, but in Rule 1113 primers and sealers are part of the same regulatory category (Primers, Sealers and Undercoaters) with a limit of 200 g/L. Each type of product is specifically defined in that version of Rule 1113:
PRIMERS are coatings applied to a surface to provide a firm bond between the substrate and subsequent coats.
SEALERS are coatings applied to either block materials from penetrating into of leaching out of a substrate, to prevent subsequent coatings from being absorbed by the substrate, or to prevent harm to subsequent coatings by materials in the substrate.
The 1993 edition of GS-11 incorporated by reference does not specifically define primers or mandate any of the performance requirements typical to this type of product. It only calls out Scrubbability, Hiding and Washability. I can't say what they intended to have in the scope of the GS-11 at the time as it has been updated several times.
Without knowing or picking apart intent of the 1993 GS-11 standard, Susan provides a good argument for the manufacturer being correct in their classification as a "Sealer". Either way, if they are claiming it is a sealer in any form of marketing collateral it is regulated in that category in Rule 1113. Manufacturers are required to do annual reporting to SCAQMD for any coating shipped into the District and enforcement is particularly aggressive there.
The GS-11 1993 and Rule 1113 2004 editions are hard to find online. I have copies and would be happy to email them on request.
Susan Walter
HDRLEEDuser Expert
1299 thumbs up
February 14, 2013 - 4:57 pm
Funny how some topics hit at the right time. I have 2 sets of painting shops hit my desk this week. Dwayne, I think the issue is one of the reviewers being better informed but not fully aware. They are in a tough spot and it is really my job to make it clear to them that the product in question is really being used as a sealer. Their product data claims are heavier on the primer claim than on the sealer claim.
I've reached out to my local product rep on this and urged him to discuss the topic with others at his company. He has sent back a note that said he has already done this and he'll keep me informed. So we'll see. I've asked him for a letter stating my particular use of the product is functioning primarily as a sealer.
Dwayne Fuhlhage
Sustainability and Environment DirectorPROSOCO, Inc.
168 thumbs up
February 14, 2013 - 5:09 pm
Susan:
On the bright side, GBCI has been sitting in on LEED IEQ TAG calls. I'm hopeful that interpretation on their end gets more consistent as more 2009 projects pass through.
This is a technically complicated credit. From my perspective, it's partly because manufacturers don't speak design and LEED language very well. We live inside a Byzantine regulatory system that is our fundamental path to market. I'll probably encourage our primary trade association to create some guidance on "building the perfect coatings LEED submittal".
I think it would be useful if the design side had one common submittal form to pass downstream. I can't tell you how many different formats come to PROSOCO's Customer Care department or on to me.
Your thoughts? Would a USGBC submittal form template be useful?
I'm glad these inquiries are showing up on LEEDUser. It helps inform the process of smoothing out the system.
Tristan Roberts
RepresentativeVermont House of Representatives
LEEDuser Expert
11474 thumbs up
February 14, 2013 - 7:01 pm
If anyone's having trouble commenting, please contact me off-list, or look for an email from me seeking detail.Please also let me know how LEEDuser can help clarify things here. Whether it's developing specific submittal guidelines (for LEED teams, or companies), facilitating dialogue with GBCI, or synthesizing the collective knowledge here into our FAQs (see above), I'd like to harness this excellent dialogue.