I feel like broken record on this topic, because I know I've been through this before. I received review comments on a project that have the potential to reduce the steel contribution significantly and I'm looking for some consistent information to help answer the questions.
Moving backwards through the process from the site, the fabricator cut, formed, welded, and prepared the components for final assembly and installation on site. That is the location the reported as the manufacturing location.
In reporting the extraction/harvest location, the report uses the next entity back in the chain which is typically a mill. For many of the larger steel shapes, the mill melts the scrap and can document where that scrap came from. The tube companies, however, receive coil from a different mill who actually melted the scrap. The tube company can tell me where they purchased their coil, but to find the scrap location for the mill that produced the coil is a much bigger task.
The fabricator has successfully achieved points by reporting the mill location as the extraction point on several projects in multiple rating systems, but the exact same documentation was rejected on the project I am currently working on.
Does anyone have insight on this aspect? If the steel has recycled content, are you required to go back to the scrap yard even if that is three layers away from the project? Can the coil used to make the tube ever be considered the "raw material"?
Jon Clifford
LEED-AP BD+CGREENSQUARE
LEEDuser Expert
327 thumbs up
March 21, 2015 - 3:05 pm
Tiffany – I understand your frustration. Thanks to its convoluted supply chain, getting reliable recycled regional and recycled content data for steel tube has been hard. I have had similar issues with sheet steel fabrications and other products manufactured from materials pre-processed by others using goods originally milled by yet another set of companies. It takes an extraordinary effort (and cooperation from the entire supply chain) for a manufacturer to track so many variables through so many layers and report valid percentages. For such items, I have had to settle, using the steel default for MRc4 and 0% regional for MRc5.
To your question, “Can the coil used to make the tube ever be considered the ‘raw material?’” No, not any more. Addenda issued July 2010 “clarified” when & how to count recycled as regional (see http://www.usgbc.org/leed-interpretations?keys=100000379). Before July 2010, the interpretation was a bit looser. An ancient CIR was often cited to allow just what you have asked to do. USGBC even issued addenda that seemed to support this interpretation, but they rescinded the guidance just three months later when they issued the addenda above.
This “about-face” may explain the inconsistencies that you have seen—why the fabricator’s data that worked in the past is no longer accepted by reviewers.