In September of 2018 our office asked two sources (created a case number with USGBC, and submitted questions to our GBCI Review Team related to preliminary review comments) about VOC Content documentation. In summary both responses stated VOC Content must be tested and calculated/theoretical values were not acceptable.
Our office substitutes the LEED v4.1 Low-Emitting Materials criteria for all our LEED v4 projects. The LEED v4.1 reference standard states, “Statement of product compliance must be made by the manufacturer or a USGBC-approved third-party. Any testing must follow the test method specified in the applicable regulation.” The applicable regulation for Paints & Coatings is SCAQMD rule 1113, which states, “VOC content displayed may be calculated using product formulation data, or may be determined using the test method in subdivision (e).”
Have calculated/theoretical VOC Content in g/L be accepted on projects, or have they been rejected and only tested values been accepted?
Dave Hubka
Practice Leader - SustainabilityEUA
LEEDuser Expert
530 thumbs up
April 18, 2023 - 7:02 am
Hello Allen,
I don't believe GBCI will accept calculated/theoretical values of VOC content.
They will most likely provide the following comment: "Product must demonstrate compliance with the VOC emissions evaluation which requires that the product has been tested according to California Department of Public Health (CDPH) Standard Method v1.2–2017"
The summary report from the lab must also be less than three years old. I believe this is three years from the time of product application, not time of product selection OR time of LEED submission.
If anyone has learned otherwise, please post.
thanks!
Allen Cornett
Sustainable ConsultantINSPEC Sustainability Group LLC
50 thumbs up
April 18, 2023 - 8:24 am
California Department of Public Health (CDPH) Standard Method v1.2–2017 is associated with the VOC Emissions criteria. I am asking about the VOC Content criteria. VOC Emissions and VOC Content are two separate requirements that need to be met when attempting the Adhesives & Sealants or Paints & Coatings categories. Thank you for your time.
Dave Hubka
Practice Leader - SustainabilityEUA
LEEDuser Expert
530 thumbs up
April 18, 2023 - 8:47 am
Hello Allen,
I believe that GBCI will require testing and not allow calculated/theoretical VOC content limits.
as an example, in the LEED for Existing Buildings rating system the existing ventilation system must meet the requirements of ASHRAE 62.1. This Standard specifically states that it should not be used retro-actively on existing buildings.
Hope you find this helpful.
kind regards.
Gretchen Krumm
Project ArchitectMosaic Architecture
April 24, 2023 - 10:08 am
I'd like to hear additional responses to this question as well as I'm currently reviewing an environmental data sheet from a manufacturer which states the data given are "MAXIMUM THEORETICAL VALUES based on the product AS CURRENTLY FORMULATED. Variations may occur on individual batches due to adjustments made during production". Is this way of sharing VOC content going to be acceptable to LEED?
Allen Cornett
Sustainable ConsultantINSPEC Sustainability Group LLC
50 thumbs up
April 25, 2023 - 12:04 pm
Below is my question (copy and pasted information from the reference guide and SCAQMD rule 1113 is not displaying below) and the response from LEED Coach:
Thank you for the information and your time. I do have a follow up question regarding guidance received in 2018 that came up as I was talking with the manufacture about the ASTM 6886 test method and then talking with the environmental , health, and safety manager for another manufacturer.
LEED v4 and v4.1 include similar verbiage that manufacturers must make statements of compliance and any testing must be per the test method in the applicable regulation. While the applicable regulation for Paints & Coatings SCAQMD rule 1113 includes information on acceptable methods to calculate or test for VOC Content, the attached VOC Content Email states only testing is acceptable. Additionally some manufacturers list their VOC Content as “Theoretical”. “Theoretical” is included in the EPA definition for "Maximum theoretical emissions" (page 5 of the Chapter-1200-3-18 attachment) and is one of the terms that is said to be “This value represents the true mass of VOC in one gallon of coating.” (Page 4 of the VOC-Calculation attachment). Below is the information one manufacture sent me regarding calculations used to determine VOC Content per SCAQMD rule 1113 (starting with item 2):
LEED v4’s Low Emitting Materials (Indoor Environmental Quality) which deals with VOC content is broken down into two parts:
Therefore, the product is USGBC compliant in providing the 3rd party VOC certificate from Berkeley Analytical to indicate VOC Emissions compliance and in using Rule 1113 mathematical formula to determine VOC Content in the product based on formula ingredients.
It is understandable that there is potential confusion due to the use of “test” and “test method” in reference to VOC Content to mean an actual test, but the explanation within SCAQMD’s Rule 1113 for a manufacturer reported content to be “calculated from formulation data…by the manufacturer” makes it clear that the VOC content displayed on a product’s PDS or label (the same PDS which is used to prove VOC Content Declaration for a LEED credit) can be from a mathematical calculation/formula not an actual test like that performed by Berkeley Analytical.
Are calculations per the applicable regulation acceptable to show compliance with LEED v4.1 VOC Content requirements? Also would a VOC Content value that included the term ”Theoretical” be acceptable since it is in reference to an EPA definition.
LEED Coach Response
Typically, Berkeley Analytical ClearChem certificates are accepted documentation of the VOC content and VOC emissions evaluation for the LEED v4/v4.1 Low-Emitting Materials Credit. This is indicated in the v4.1 Guide. It would be acceptable for the VOC content to be calculated per the referenced standard.