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EBOM-2009 SSc2:Building Exterior and Hardscape Management Plan

Where can I find the VOC limits for sealants used as fillers?

Our review comments has one item, "Provide a revised plan that includes sustainability criteria for sealants used as fillers based on the requirements of BayArea Air Quality Management District Regulation 8, Rule 51." I searched the standard and found nothing connected with fillers Where can I find it ? Why experts raised such problem for we didn't mention any sealants used as fillers.

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Tue, 11/13/2012 - 16:03

We are having the same problem with a recent review. We've used the same criteria on paints and sealants time and time again (GS-11 and SCAQMD) and have been approved without any problem about "sealants used as fillers". This is our first review mentioning this. Like Yan Lian, we do not apply sealants used as fillers, did not mention it, and we were also unable to find what is being referenced. Is this a new standard that needs to be included in SSc2 moving forward? Please advise! Thank you!!

Tue, 11/13/2012 - 16:22

This is strange. Neither the v2009 rating system nor the v2009 reference guide make any mention of "sealants used as fillers" and there have been no LEED Interpretations or Addenda to revise that language. This seems like yet another example of some undercurrent within the GBCI Reviewer community to "unofficially" change credit requirements without any official process or publication to support the changes. Unfortunately, this happens all too often. The only reference I can find in the BAAQMD Reg. 8, Rule 51 is the following: "8-51-218 Sealant Products: Any material with adhesive properties that is used primarily to fill, seal, waterproof, or weatherproof gaps or joints between two surfaces. Sealant products include sealant primers and caulk." This is a definition of a "Sealant Product" which suggests that the product may be used to fill a gap or joint (i.e. caulk). My suggestion would be to make the literal revisions to the SSc2 plan and indicate that sealants used as fillers will regulated in accordance with the requirements of Bay Area Air Quality Management District Regulation 8, Rule 51. It may also be worthwhile to send a mid-review clarification to your review team to see if they can provide any additional guidance before submitting your final application. Anyone else have any other thoughts?

Wed, 11/21/2012 - 05:21

We had same comment and the review team reply to our question regarding this particular question was as follows: "The review team is referring to a cross-reference within the EBO&M rating system, between SSc2 and MRc3. This cross-reference is stated on page 11 of the EBO&M reference guide - 2009 Edition, Updated April 2010. The simple clarification would be to refer to the BAAQMD regulation in your building exterior and hardscape management plan. Please refer to the MRc3 credit language (page 269 of the EBO&M reference guide)."

Thu, 02/28/2013 - 17:25

All, We've been trying to sort this out with GBCI. The VOC criteria, and definition of "sealant", are identical in both the BAAQMD Reg 8, Rule 51 and SCAQMD Rule 1168, so the listed values in the LEEDuser template cover compliance with both rules (because they have identical criteria). We should see reviewers stop asking for a citation of BAAQMD going forward, since the 1168 already covers it.

Tue, 06/25/2013 - 18:47

I just received comments from my LEED Reviewer on 6/19/13 and this same BAAQMD comment for sealants used as fillers was listed. My plan is just to literally add "sealants used as fillers will comply with BAAQMD Reg 8, Rule 51" to order to response to the comment. The actual VOC limits list that the building personnel are using is based on SCAQMD alone.

Tue, 08/20/2013 - 00:38

Jenny - we received the same review comment on 7/31/13. Just a heads up! Perhaps the LEEDuser template should be revised in some manner to resolve this?

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