I’d personally like to hear input from architects and project teams on some fundamental questions regarding coatings and sealants.
I’ll share my perspectives as a starting point for you to either build up or tear down. Either way, we collectively need some real world perspectives on the subject and that shouldn’t always be from NGOs, laboratories, certifiers and manufacturers (that’s me). Questions:
Is the proposed Low-Emitting Interiors credit system workable?
If you don’t think it is workable, what changes could you suggest?
Would you use the credit system as it exists and to what level of credit attainment?
The credit language is designed with specific goals in mind, but as a specialty product manufacturer I am concerned about attainability with regards to coatings and sealants since the credit is based on having conformant product on every layer in a given interior surface.
Being new to the IEQ TAG, I talked with someone who helped write the draft to better understand how the layer approach works. I’ll use a school floor as an example (and hope I get it right). Many schools contain a mixture of finished and decorative concrete and various coverings such as carpet and resilient materials. Throw in a locker room, a wood floored gymnasium and swimming pool and the materials list gets quite a bit longer. Our theoretical school has the following materials: carpet, linoleum, recycled rubber tiles, concrete curing compound, concrete stain, concrete hardener, concrete finish, epoxy in the locker rooms and laboratories, control joint sealants, a swimming pool coating and high-durability wood coating and line striping for the gym. That’s just for the floors.
In order to contribute to credit, every one of these materials would require testing. Any area with multiple layers where any one layer is not tested would not be eligible for credit. To put that in perspective, a concrete floor might have a general application of a curing compound and a hardener with carpet and adhesive applied over it. Even if every other material is tested, an adhesive that was not CDPH tested would cause that entire area to not count towards the credit percentage thresholds. That concerns me both for the ability of a project team to actually attain the credit and for my tested products to actually be counted should another layer not make it.
I’ve been monitoring comments and questions on related NC2.2, LEED for Schools and LEED 2009 LEEDUser forum areas. Many of the project team questions are related to proper VOC category assignments for specialty coatings. I have to assume this means the product’s manufacturers haven’t figured out how the LEED credit works to the point of assisting the project team with credit attainment.
If specialty product manufacturers are having trouble with assisting on credit attainment now based on straight regulatory compliance, what indicates the situation will improve with added layers of complexity?
I’m not an architect, but have heard frustration with the complexity of the regulatory VOC management systems in the context of LEED. I share your pain as the person responsible for figuring out how to make sure my employer keeps on the right side of the regulations and with personal legal liabilities should I fudge the numbers. However, as frustrating as that is, regulatory compliance is a basic requirement for market access in our rapidly multiplying area and state jurisdictions. I wish VOC compliance was like the IPC where all pipes are created equal in every state.
I agree that from an architect’s perspective a simple pass/fail based on CDPH emissions testing must appear less complex than the byzantine VOC regulatory system.
I’ll present a manufacturer’s perspective. Figuring out how to play in the CDPH emissions testing world is complex and foreign to the vast majority of coatings manufacturers compared to the VOC regulations we already have to follow. It adds staff and monetary overhead to products we opt to have tested. This includes opportunity cost for small formulators where we have to choose between R&D and customer support or navigating CDPH product and substrate prep, shipping, chain of custody forms, Certificates of Conformance and report management. Over 60% of coatings manufacturers have fewer than 100 employees to design, make, promote and distribute products. Around 50% have fewer than 50 employees. Even large manufacturers have to consider overhead costs for their individual SKUs. I know of one major coatings manufacturer with over 40,000 SKUs.
Like it or not, we live in a cost/benefit world. I support PROSOCO’s testing and certification requirements for concrete flatwork coatings. If we sell a near zero VOC anti-graffiti coating that would work for the interior CMU walls in a school, but only get a few random specifications, is that worth the companies’ resources to support CDPH testing? I’ve already had to answer that one for real life LEED for Schools projects. No, we did not spend the $2,800 for testing. As it turns out, what mattered a few years ago doesn’t matter today.
This brings me to the elephant in the room. LEED for Schools was the test bed for an all emissions testing approach. Based on the USGBC issuance of a PIEACP allowing substitution of regulatory VOC compliance for CDPH testing and personal experience with desperate project team members, it would appear the experiment has not been entirely successful. Take a look at the LEEDUser forum where the vast majority of questions relate to regulatory VOC categorization instead of the original CDPH testing requirement.
http://leeduser.com/credit/Schools-2009/IEQc4.2
I look forward to your comments and criticisms.
Julie Hendricks
PresidentSage Building Revival
163 thumbs up
September 10, 2011 - 7:52 pm
For reasons mostly different than what Dwayne has stated above, I think this credit is clumsy and virtually unworkable. I hope there will be an active debate about this!
First, I'd like to note that the Low-Emitting Materials credits as they are now are already pretty time consuming. They take much more time proportional to the LEED credit we get for them (about 4% of points for something that takes maybe 10% of the total time). This change is going to make that equation even more lopsided.
Specifically, I'm referring to the requirement that all materials applied to floors, walls, and ceilings as well as insulation be calculated by surface area. What this means (as far as I can tell) is that for every applicable material submitted, we will have to figure out what surfaces it is being applied to, calculate the areas and add them all up. Moreover, we are asked to calculate based on manufacturer data about how to apply it. Finding these surface areas, and studying the manufacturer data about how fluids are applied, is an entirely new level of complexity.
I don't see the benefit over merely listing the products and their compliance as we do now. If amounts must be provided, how about using the product cost (as is allowed in the current draft for furniture) or the number of gallons for fluids.
In my estimation, the extra work in this credit will add cost to LEED projects without adding any extra IAQ benefit.
Mary Crozier
PrincipalCrozier Architecture
1 thumbs up
September 14, 2011 - 10:00 pm
As an architect, former facilities manager, and LEED project administrator since 2000 I believe this credit group revision moves beyond feasible for many manufacturers, architects and contractors. Current IEQ4 credit requirements have greatly improved indoor air quality. At what point do we risk credit compliance or even projects abandoning LEED to achieve the next few percentage points of gain? If hospitals need the added protection then use LEED Health Care as the next test market and evolution catalyst. Added documentation, testing and calculations will a work against the credit group.
Dwayne noted the problems with the LEED for Schools version of the credit citing frustration shared by "desperate team members." I also use the PIEACP (alternative credit compliance approach) on my projects which deferred to LEEDv2.2. Please use this new version of LEED to clarify the process and apply lessons learned from past versions of LEED, not repeating the same problems or creating new ones.
A general comment for LEED 2012- When ASHRAE approves a directive they give manufacturers 3+ years to design, test and implement the new products to meet the more stringent requirements yet USGBC credit committees appear to believe this proposed major shift can happen in 10 months or less across many more diverse product lines. Many organizations and governments have adopted LEED compliance similar to a building code therefore I believe the ASHRAE comparison applies. Most of my past projects are LEED silver and gold certified, yet few could achieve enough credits, even with a 10% budget increase, to achieve basic certification under comment period v2012. One proposed v2012 credit could not be achieved because an independent certification process had yet to be created at the time of this comment period!