I have a MSDS sheet from a manufacture of a vapour barrier sealant with a VOC content of 380 g/l. The manufacture has claimed that their product is LEED compliant. Would this product be classified as an 'architectural' or 'other' sealant under SCAQMD 1168?
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Shannon Gray
ConsultantYRG sustainability
228 thumbs up
April 1, 2010 - 12:38 pm
Hi Adolfo,
I would categorize a vapor barrier sealant as “other”. I would count caulking around trim, and applications like that, as architectural.
Shannon
RETIRED
LEEDuser Expert
623 thumbs up
April 14, 2010 - 10:18 am
Shannon -
I am very curious about your classification of this sealant as “Other.” The definition of Architectural Sealant from SCAQMD Rule 1168 is “any sealant or sealant primer applied to stationary structures, including mobile homes, and their appurtenances. Appurtenances to an architectural structure include, but are not limited to: hand railings, cabinets, bathroom and kitchen fixtures, fences, rain gutters and downspouts, and windows.”
An additional definition is given for Architectural Application as “the use of an adhesive, sealant, or adhesive or sealant primer on stationary structures, including mobile homes, and their appurtenances. Appurtenances to an architectural structure include, but are not limited to: hand railings, cabinets, bathroom and kitchen fixtures, fences, rain gutters and downspouts, and windows.” (http://www.aqmd.gov/rules/reg/reg11/r1168.pdf)
How is a vapor barrier sealant not an architectural application by this definition? It is applied to a stationary structure.
I am curious because I am working on a commercial project using SIPs and the manufacturer is telling me that they also classify their sealant (used to seal gaps between panels in the field) as “Other” also. This does not seem correct to me and with GBCI is doing reviews these days, I am not sure we can count on just saying it is in the Other category without some justification.
SMACNA went to the trouble of writing a CIR in LEED-NC v2.2 under EQc4.1 to have duct sealant classified as “Other.” (However, previously the SCAQMD had classified Duct Sealant as an Architectural Sealant – see SMACNA TRB #9-09 and #4-09 - http://www.smacna.org/technical/download.cfm?download_file=TRB9-09-Updat...).
If SCAQMD thinks a duct sealant is an architectural application, how can a vapor barrier sealant or SIPs sealant not be?
Michelle
Shannon Gray
ConsultantYRG sustainability
228 thumbs up
April 21, 2010 - 11:54 am
Correct, the vapor barrier sealant is most likely applied to a stationary structure. But, I personally would be fine categorizing a vapor barrier product as other…although it depends on the exact application of the sealant. I do think what falls into the “other” category can be somewhat subjective and confusing and really depends on the application of the product. If the GBCI doesn’t accept a product as “other” then you can always go back and use the VOC Budget Method which is really not that difficult to do.
Shannon
RETIRED
LEEDuser Expert
623 thumbs up
April 28, 2010 - 10:18 am
Shannon -
After I checked with LEEDUser on 4/14, I contacted the SCAQMD and requested they analyze a specific SIPs sealant for its classification in Rule 1168. Heather Farr, Air Quality Specialist, e-mailed me yesterday to say that the “product meets the Rule 1168 definition of an architectural sealant. The VOC limit for architectural sealants in 250g/L.”
Recently I required a contractor to complete a VOC Budget for EQc4.1 due to his alerting me very early in the finishes stage of a job of an odorous product being used, which turned out non-compliant adhesive product. I can say that it really IS a difficult endeavor. On that job we had over 42 adhesives or sealants used by a large number of trades. It was difficult because the general contractor had to go to each trade who used an adhesive or sealant and get the quantity of each product used to complete the budget. I cannot imagine trying to do that during a clarification response period of 25 business days – when the job is already completed and contractors are onto other work.
VOC Budgets for EQc4.2 (Low-Emitting Materials: Paints & Coatings) can be less of an onerous because typically there are only a few trades doing the painting. I have planned in advance for 3 of these budgets.
Yet I have to agree with the LEED Reference Guide when it says: “As the term “budget” implies, this compliance path should be a decision planned in advance.”
Michelle
Shannon Gray
ConsultantYRG sustainability
228 thumbs up
April 28, 2010 - 6:52 pm
Hi Michelle,
For the VOC budget, it is not necessary to find ALL quantities...at least this is how it has been for v2.2 and I don't see any signs of that being different in 2009. In the past it has been fine to demonstrate that low emission from a limited number of compliant low-VOC products offset excess emissions of a few non-compliant products, without calculating quantities for EVERY applicable product on the project. So, let’s say you only had one non-compliant product and you know that you used 5 liters of the non-compliant product, and say it fails by 10 grams/liter, then you only have to offset 5 x 10 = 50 grams/liter of excess VOC. In this case you just have to show that you’ve offset the excess VOCs by showing another product(s) under the allowable limit. See the VOC Budget Method: Example Calculation in the Checklists section of this credit (under the Construction section).
Shannon
RETIRED
LEEDuser Expert
623 thumbs up
February 10, 2011 - 6:21 pm
I followed Shannon’s advice regarding that the VOC Budget does not have to include ALL quantities (for a LEED for Schools v2.0 project following the LEED-NC v2.2 alternative compliance path for EQc4 credits). (I think Shannon was the guest expert last April on this credit but I could be mistaken.) I was happy to find this information and it made a lot of sense to me at the time but my reviewers just replied that I had to show ALL quantities, which had been my modus operandi prior to following the advice from LEEDUser. I found a LEED-NC v2.1 CIR Ruling (7/16/2007 for EQc4.1) that backs up Shannon’s point but I wonder if anyone else has had to face this issue or is it the case of another bad review? The clock is ticking on my clarification response request.
Finding ALL the quantities now is going to be hard as construction was completed in August 2010.
Tristan Roberts
RepresentativeVermont House of Representatives
LEEDuser Expert
11478 thumbs up
February 18, 2011 - 2:43 am
Michelle, I have been asking around about this and there has been some surprise about your reviewer comment, but so far no one I have talked to has had a recent review using this approach, so I can't corroborate if it's a bad review or a policy shift. I'll keep you posted if I learn more, and please do the same.
77 thumbs up
February 22, 2011 - 2:01 pm
I have a similar project where the product has 280g/L. It's being used as a High Performance Vapor Resistant Coating. Is that Architectural or Other? Unfortunately, we don't have a choice it appears and would have to apply the budget method if the 'Other' category is rejected. Has anyone submitted this under Other and got it rejected?
RETIRED
LEEDuser Expert
623 thumbs up
May 24, 2011 - 6:56 am
Tristan -
I wanted to provide an update to my earlier post about the VOC Budget issue. My final review came back and our clarification response narrative outlining the use of a VOC Budget that shows the non-compliant products were offset with enough (but not ALL) compliant products was accepted! It appears the reviewer was mistaken in his/her belief (see Preliminary Review comment below) that ALL products have to be included in the VOC Budget.
Our clarification response narrative included the LEED-NC v2.1 CIR mentioned above and quoted the LEED-NC v2.2 Reference Guide (“When the design (or actual) is less than the baseline, the credit requirement is satisfied.”). We also stated: “We hope that the reviewer will recognize that the request to add the rest of the compliant products to the VOC Budget would only result in improving the ratio of Total Used VOC (Design) to Allowed VOC (Baseline). This is a mathematical reality. We respectfully believe that our original VOC Budget illustrates that the design is less than the baseline. To add additional compliant products would only serve to improve the ratio and seems to us like a pointless exercise.” We illustrated this point with an excerpt from our VOC Budget.
The Final Review stated, “A response narrative has been provided to address the issues outlined in the Preliminary Review comments, and confirms that the total installed VOC level is less than the total allowable VOC level. The documentation demonstrates credit compliance.”
FYI: Here is the Preliminary Review comment: “The LEED Submittal Template has been provided stating that an alternative compliance path is being attempted requiring all indoor adhesive and sealant products to comply with the VOC limits outlined in the IEQc4 PIEACP issued 07/07/2008. A supplemental LEED-NC v2.2 template has been provided and includes the required product details. Additionally, the template states that all indoor adhesive and sealant products do not comply with the VOC limits of the referenced standards for this credit. The project is utilizing the VOC budget alternative compliance path to meet the requirements of this credit. The provided VOC budget calculations indicate that the project's total installed VOC level is less than, the total allowable VOC level.
However, the VOC budget calculations provided do not include all the adhesives and sealants listed in the template.
TECHNICAL ADVICE:
Please provide revised VOC budget calculations that include all of the adhesives and sealants listed in the template. See the Supplemental Information section for EQc4 in the LEED-NC v2.2 Reference Guide, Third Edition, for additional information and guidance.”
Tristan Roberts
RepresentativeVermont House of Representatives
LEEDuser Expert
11478 thumbs up
May 24, 2011 - 10:37 am
Michelle, it's great to hear that this was resolved favorably! And it's a relief that the budget method is still viable without excess work.