REACH compliance

Can someone please answer this?

The LEED requirement goes above and beyond REACH, in specifying a 100 ppm threshold, which is higher than a 1,000 ppm threshold. 

I would qualify the following by saying that I am not an expert in REACH specifically, but based on the language you have shared, the REACH documentation referenced by Charline is not sufficient at only 1,000 ppm.

Please search the LEEDuser forum for more on this. I think this question may have been a duplicate which was answered previously.

It seems that the best source for ingredients are the material safety datasheets (MSDS).

Do you know what the requirement of material safety datasheets in the European Union is? I mean, the requested threshold (ppm) for the declaration of the ingredients?

Best Regards

Francesco, this BuildingGreen article is a good starting point for understanding SDSes (no longer MSDS), and their usefulness, and limits, in material ingredient reporting:

https://www.buildinggreen.com/primer/safety-sheets-getting-new-format%E2%80%94and-some-new-data

The SDS is a globally harmonized standard.

Read up on it and draw your own conclusions, but SDSes are only "best" in that they are most common. But they lack many ingredients, don't usually hit the thresholds needed for LEED credit, and are not verified, which hurts LEED contribution.

If you are a manufacturer, they can be a useful tool in developing your HPD or Declare label; as a building project team, they don't do you much good for this credit.

Thanks, Tristan.

This sentence is clear: "In addition to carcinogens, the most toxic mutagens, reproductive toxicants, and skin and respiratory sensitizers must be reported on the new SDS if they are present at concentrations of 0.1% or Greater.", i.e. 1000 ppm

While LEED requires that substances are declared also at lower concentration, i.e. 100ppm.

I believe for us as LEED specialists, the issue is done once we receive the manufacture written confirmation related to their material (either under the technical data or the material safety data sheet). 

Since I work in LEED projects out of USA, I face a situation where manufacturers do not have any written document confirming the compliant to REACH (and also no C2C), so I have made my own draft declaration letter confirming the compliant with all REACH requirements stated in MRc4 and I send it to manufactures to sign it off 

Hello everyone, 

Here is a brief overview of the REACh rules. 

The declarable threshold for Substances of Very High Concern (SVHC) is 1000 ppm, component level. However, the REACH Annex XVII refers to restrictions at different thresholds. They can be lower than 1000 and even 100 ppm. 

Nevertheless, it looks like the guide exceeds the REACH expectations. It may be the case for at least some chemicals. 

I hope this helps. Thanks!