Recycled Content for differnet plants from the same manufacturer

Elena, unfortunately that will not be acceoted. There is a credit interpretation that prevents using s national (or companywdie) average for a product. The recycled content data must be plant and product specific. Sorry I don't have the credit interpretation number handy.

This is info from the FAQ section above:

The manufacturer can't give me product-specific recycled content data, but they say that they fall within the national industry average. Can I use that?

No. Per LEED Interpretation #10246, recycled content claims must be specific to installed product. Average regional and national claims do not meet the credit requirements.

This Interpretation has been misinterpreted, however, to mean that recycled content figures must come from specific plants. That is not what USGBC intended. It is allowable to use a company- and product-specific national average, as long as the company has performed the necessary tracking to assure that that average is accurate at the product SKU level.

Renee, then the interpretation is still being confused. We have some of the most specific documentation in the market and we routinely have to provide plant specific information.

What happens is the LEED AP would grab our general statement on our recycled content from our website and submit it as documentation. Soon after the review will ask for plant specific, product specific, project specific verification. I which we reply with our detailed project specific letter. The primary reason for rejection initially from the reviewer is the rolled up national average for our company.

If you are able to use a company wide average I'd like to know how.

Keith, I am not sure what the LEED APs have submitted, or how they framed it, but I have been able to successfully use the Nucor corporate letter for recycling content without the plant being identified. However, it may be because the material had the same recycling content from all the plants (rebar from the bar Mill Group).

If the Nucor corporate letter added a corporate average below each Product Group ( such as total scrap steel/total alloy/post-consumer/pre-consumer for the Sheet Mill Group), then the LEED AP can claim that rate and the reviewer should accept it. Without confirmation from the manufacturer on which plant sourced the product, the LEED AP is forced to use the lowest recycle rate since there is no proof that it came from a different plant, and no way to calculate the corporate average for the Sheet Mill Group. Based upon the current documentation form Nucor, we have no way of knowing if one plant produces significantly more product than another - which would drastically change the corporate average since each plant has a significantly different recycle rate.

Even with this average documented in place, you might still get some requests for a letter if the material supposedly came from a plant with a really high recycle rate (such as Sheet Mill Group in Crawfordsville IN) vs. whatever the corporate average would be.

Where the plant location really becomes essential is if they are going for regional material credit too - they absolutely need to know where that recycled material came from if they want to claim it as regionally sourced and want to submit the info as backup. I tend to submit your info as backup for recycling content, but then use concrete and masonry products for regional material backup, since a lot of those materials can easily be regionally sourced and documented as such where my projects are located.

I will say that steel can be one of the more difficult materials to document, if the right info isn't presented in the "right" way. I hope this helps. Sorry for the novel!

Elena, Unless the manufacturer can either 1) provide a letter identifying the specific plant for the product, or 2) provide a letter identifying the corporate average for all three plants for the specific product, you will have to 3) use the lowest recycle rating.

You cannot average the three plants recycle rates together because you don't know the percentage of the product that comes from each plant. One plant may product 75% of the product, another one 20% and the last one only 5%. This would definitely alter the corporate average, depending on which plant produces the most product.

Hello Renee,

Your comment addresses an issue of concern I have for a project I am working on seeking LEED v2009 Gold certification. For recycled content of steel, we have the corporate mill spreadsheets with all of the contents listed by mill and then an averaged content. I have the invoices of all steel products which I am claiming recycled content for, but not sure that I can obtain the mill certificates for those orders. I need regional content as well but can sacrifice the regional content for better recycled content. If I can claim the average OR lowest listed recycled values for steel (basically the lowest value mill) that would greatly improve my recycled content numbers from just using the default 25% postconsumer. In your experience, doe the LEED reviewer typically request mill certificates for the steel products?

We have been successful submitting invoices that identify the specific mills, and including the mill spreadsheets showing typical recycled content. We completed this for a number of projects with different contractors, so it can (and has!) been done.

Andrew, we are happy to provide you with mill specific data from any of our mills.   Likewise, we track all incoming material by zip code and therefore we can provide you with regional material data for any project and any mill.  The same of data can be provided for our downstream product divisions as well.  Feel free to contact me for more help  

Keith Lindemulder, Nucor