Has anyone use a report mor than 3 years old to show compliance with LEED v4.1 VOC Emissions evaluation requirements? In an addenda from November of 2020 the following change was made:
Under VOC emissions evaluation, replace the third paragraph with "The statement of product compliance must include the exposure scenario(s) used, the range of total VOCs, and must follow the product declaration guidelines in CDPH Standard Method v1.2-2017, Section 8. Manufacturer statements must also include a summary report from the laboratory that is less than 3 years old and the amount of wet-applied product applied in mass per surface area (if applicable). Organizations that certify manufacturers’ claims must be accredited under ISO/IEC Guide 17065. "
Lately I see more and more materials that have reports greater than 3 years old for UL and Berkeley Analytical since nothing about the material has changed and manufactures do not want to spend money to run another report on the same material that already meet the emissions standards.
Deborah Lucking
Director of SustainabilityFentress Architects
LEEDuser Expert
258 thumbs up
October 7, 2022 - 10:51 am
I believe the requirement is that the certificates/reports are valid at the time of product data submittal. Does anyone have any different experience/insights?
Emily Purcell
Sustainable Design LeadCannonDesign
LEEDuser Expert
371 thumbs up
October 7, 2022 - 11:55 am
I think the sticking point is how to know whether the lab reports are still "valid" since they do not expire the way a 3rd party certification does. GBCI added that 3 years old requirement in the addenda, but that can often be the time between design and construction on many projects. I'm getting submittals on current construction projects where the lab report was recent during design but is >3 years old now, so I'm just hoping that will be good enough for GBCI.
Allen Cornett
Sustainable ConsultantINSPEC Sustainability Group LLC
50 thumbs up
October 9, 2022 - 9:22 pm
Thank you for the insight. I will be sure to include this as part of my discussion during the pre-submittal conference call I will have early next month.
Susan Di Giulio
Senior Project ManagerZinner Consultants
153 thumbs up
October 10, 2022 - 1:57 pm
With EPDs and HPDs, I heard in various Greenbuild workshops that the docs are supposed to be valid at the time of manufacture.
Atlas Turner
Project AssociateO'Brien360
5 thumbs up
August 21, 2023 - 1:34 pm
Hi All,
Are there any updates on how GBCI manages Berkely Analytical emissions evaluations that exceed the three year timeline, but the product formulation has remained the same?
One strategy we have been considering is to reach out to the manufacturer for a statement that confirms the product has not changed formulations if the emissions evaluation date exceeds the three year timeline for certificates that do not have an expiration date. We have not yet submitted using this strategy, but I wondered if anyone else has.
Dave Hubka
Practice Leader - SustainabilityEUA
LEEDuser Expert
532 thumbs up
August 21, 2023 - 3:25 pm
Susan, the July 2023 v4.1 reference guide requires EPD's and HPD's to be current at the time the product was purchased for the project.
Atlas, I am not aware of GBCI accepting a letter from the manufacturer stating that the product has not changed formulations - in leiu of a new test. Please post updates if you learn otherwise. Thank you.
Allen Cornett
Sustainable ConsultantINSPEC Sustainability Group LLC
50 thumbs up
August 21, 2023 - 5:38 pm
When it comes to VOC Emissions documents, our office received the following information during a pre-submittal call with the GBCI Review Team assigned to the project:
Typically, manufacturer’s claims do not have expiration dates. However, for LEED v4.1 projects registered after the November 2020 addenda, the claims must be less than 3 years old in order to be accepted; a letter from the manufacturer confirming that the product has not changed since testing and that the test is still applicable is not sufficient to demonstrate compliance with the credit requirements.
On another project when we explained that the project was registered under LEED v4 and was substituting the LEED v4.1 requirements for Low-Emitting Materials we received the following information:
If substituting a credit using the LEED v4.1 language, project teams must clearly identify and adhere to all information outlined in the referenced addenda version, including the requirement regarding the test date within the report summary. Therefore, the test date must be less than three years old if applying the November 2020 addenda; otherwise, the test date must be less than five years old.
On still another project our office asked LEED Coach: For LEED v4 projects registered before 4/21/23 that are substituting LEED v4.1 criteria on an item-by-item bases does the same addendum have to be use for each prerequisite/credit the LEED v4.1 criteria is being substituted for, or can different addenda be used for different credits? For example can LEED v4.1 criteria using the 4/9/2019 addendum be used for IEQc2 Low-Emitting Materials and LEED v4.1 criteria using the 4/21/2023 addendum be used for EAc5 Renewable Energy in the same project? Similarly when substituting with the LEED v4.1 criteria using the 4/9/2019 addendum would LTc8 Electric Vehicles require electric vehicle charging stations for 2% of the parking capacity as opposed to 5% that was changed in an addendum issued afterwards? LEED Coach provided the following response:
For LEED v4 projects registered prior to 4/21/23, projects may use a different version of LEED v4.1 credit substitutions for each credit using a substitution; it is not required for the team to select one version for all credits using a substitution. If the LEED v4 project was registered prior to 4/21/23, and the project is using the April 2019 version of LTc Electric Vehicles, then the team only needs to demonstrate that the 2% threshold has been met. Whenever the project is not using the current version, the team should be sure to provide a brief statement that clearly indicates which version of the LEED v4.1 credit is being used so that the reviewer knows which version to review against.