Recognizing the issues already under discussion regarding the analytical methods and the maximum contaminant levels presented in LEED v4... I was wondering if anyone else is experiencing any confusion regarding Option 2. Air Testing Step.1 "Determine Air Testing Locations"... My specific concern is that the new directive appears to increase the number of sampling stations sginificantly for many of the projects we are looking at and that the costs associated with this may make it impossible to consider Air Testing as a viable method in achieving the credit. Wording such as "all space types" and "spaces that are identical in construction" appears to increase the number of sampling locations exponentially.
Does anyone know if there are discussions regarding this topic? And/or if the USGBC has provided guidance regarding their definition of "identical spaces"?
Any thoughts would be appreciated... Thanks - Courtenay
Dale Walsh
30 thumbs up
September 4, 2014 - 4:02 pm
I was curious as to where you are getting the "all space types" and "spaces that are identical in construction" language. All I see in the LEED V4 EQ Credit for IAQ Assessment Option 2: Air Testing requirements is "all occupied spaces".
The requirement starts with "After construction ends and before occupancy", which in just about all of my air testing projects has not been a timeframe that exists in the real world.
It goes on to say ",but under ventilation conditions typical for occupancy." Again, this is an unclear requirement because the amount of outdoor air being brought in will vary depending on the time of year and outdoor temperatures. Plus, what amount of occupancy (10%, 50%, 100%)?
It then says "conduct baseline IAQ testing using protocols consistent with the methods listed in Table 1 for all occupied spaces." I won't go into the myriad of problems with Table 1, but what the heck does "all occupied spaces" mean? Does it mean the building as a whole? Does it mean every room commonly occupied? Is a large open cubicle area one space? Does it apply to any room that may be occupied (e.g., janitors closets, mechanical rooms, break rooms, etc.)? V4 seems to have taken the LEED air testing criteria from confusing and relatively useless for accomplishing the goal of good indoor air quality for occupants to utterly mind boggling, impractical, and just as useless.
This is what happens when people who don't have practical experience write procedures and criteria and don't ask or listen to the experts for their input. I was recently denied for the third time to participate on the LEED Indoor Environmental Quality Technical Advisory Group and none of my LEED public comments on this section have ever been addressed over the last 10 years of commenting. My peers have also been mostly ignored as well.
Courtenay - Though I have not been involved in any V4 projects, I will likely just continue on with what I have been doing for the previous Versions. When establishing the number of sample set locations i will try to identify areas in the building served by an air handling unit the brings in outdoor air (OA) and mixes it with return air or just supplies 100% OA. This is a common IAQ Professional's approach to identifying separate zones. At least one sample set will be collected from each floor of the building with one additional for each additional OA AHU serving the area or for each additional 25,000 square feet served by one OA AHU (i.e., 70,000 sq ft single floor served by one OA AHU would require three sample sets).
I have been doing my Total VOC sampling with a method that analyzes for individual VOCs all along because it helps identify why a space failed the criteria. That should suffice to comply with the new CDPH target chemical requirement.
The new ozone and PM2.5 requirements (if your building is in a non-attainment area for these compounds) is just another ill-considered requirement. Since the only value, limited as it might be, to this air testing credit is to provide a QA check as to whether low emitting materials were properly used in the building, making the designer/builder responsible for controlling outdoor air pollutants, which have nothing to do with the building, is impractical and cost prohibitive. Is the designed/builder now going to be responsible for removing very small outdoor particulates and a gas (ozone) from the outdoor air at the intake? Indoor air has been determined for decades (per EPA and others) to be many times more polluted than outdoor air. Controlling PM2.5 and ozone in the outdoor air we breathe is the local air quality management agency's responsibility - not architects, builders, and building operators. The PM2.5 and ozone sources are typically from vehicle and industry combustion sources - not commercial or residential buildings.
The whole issue of using EPA particle references (PM10 and PM2.5) is inappropriate for indoor air in the first place. We industrial hygienists identify particles by where in the lungs they deposit not their impact on smog/outdoor air pollution. We have total particulates that include all collectable sizes. There is inhalable which only penetrate to the upper respiratory tract (nose, throat, etc.). Thorasic penetrate to the mid lung area and respirable penetrate to the gas exchange area (alveolis). Respirable particles are measured differently than PM10 and PM2.5. Occupational exposure limits are typically either total or respirable.
When I submit my first V4 air testing report for a client to obtain the Credits I highly doubt the person reviewing it will have anywhere near the expertise or knowledge to dispute my methods. They also should not have any suggested alternatives to my approach because their criteria language is so unclear. If they want to make this Credit impractical and cost prohibitive they may come up with clarifications on their unclear language that create a monster. Until then, I intend to just keep on going the way I have in the past. If you want an idea of what I usually charge for a very comprehensive, defensible air testing job done by a Certified Industrial Hygienist with 28 years experience in IAQ contact me privately. I am not sure you can discuss pricing in a public forum. However, I will say I am very competitive and have an expedited 4 day turnaround.
I hope all this ranting helps.
Courtenay Griffin
IH Scientist/CBSTQuES&T
2 thumbs up
September 5, 2014 - 9:51 am
Dale - Thank you for your response. At this moment in time we are also continuing to select sampling locations in accordance with LEED 2009; however, some of the projects we have been asked to particpate in are not slated for completion until 2016. I am assuming/hoping that we will have some sort of clarification for LEED v4 from the USGBC by that time but...
One specific project we have been asked to submit a sampling plan and pricing for is a 3-story building with 3 AHUs, utilizing the 2009 protocols this project would require 4 sampling locations (1 AHU serves greater than 25,000 sf); however, utilizing the strict interpretation of wording in LEED v4, this same building would require 27 sampling locations. This seems a little extreme to me...
The wording I am referencing comes from LEED v4 Indoor Air Quality Assessment EQ page 689 as part of the Step-by-Step Guidance.
"Step 1. Determine air-testing locations
Select testing locations with the least ventilation but the greatest concentration of VOCs and other contaminants. Testing must be completed by an appropriately accredited professional. Use current versions of ASTM or ISO methods. The number of testing locations depends on the size of the
building and number of ventilation systems but must include all occupied spaces. If sampling is used, all space types must be represented (e.g., office and classroom). Use the following methodology to determine how many air testing locations are required.
Test at least one location per ventilation system for each occupied space type. There must be a minimum of one test per floor. The locations selected for testing must represent the worst-case zones where the highest concentrations of contaminants of concern are likely to occur.
For offices, retail, schools, hospitality, and multifamily residential projects, test areas no larger than 5,000 square feet (465 square meters). For warehouses or large open spaces in other building types (e.g., ballrooms in hospitality, gymnasiums in schools), a limit of 50,000 square feet (4 654 square meters) may be used. If there is evidence that the air in the space is well mixed and sources of contaminants of concern are uniform, project teams may test a single location in that space.
Determine whether the project includes spaces (e.g., offices, school classrooms, or multifamily residential units) that are identical in their construction, finishes, configuration, square footage, and HVAC systems. Project teams may sample identical spaces by testing one in seven. If
the sampled space fails the test, all seven must be tested."
There are other parts of the credit which are also confusing and I understand completely about the "after construction end and before occupancy", I have found that this is getting better as more contractors are aware of the fact that IAQ testing is to occur; however, construction projects and building owners do have a tendency to operate on different time frames...
It is my understanding that the LEED sampling protocols will be addressed at one of the upcomimg AIHA conferences and that the AIHA is involved in discussions with the USGBC regarding the specified methods and the applicability of certain components, specifically the fact that many of the methods referenced are from 1989 and that analytical methods have advanced since that time.
As I said, I am hoping for clarification between now and an undetermined time in the future but I figured it would be best to start the conversation... Wasn't sure if anyone was specifically speaking about sampling locations. Looking forward to your thoughts.