For full disclosure I am the Technical Information and Public Affairs Manager for GREENGUARD Environmental Institute.
As mentioned above the LEED Pilot Credit 21 is being proposed as the new EQc 4.0 for ID+C and BD+C. In November the USGBC began a public comment period on an updated version of the LEED Rating (http://www.usgbc.org/DisplayPage.aspx?CMSPageID=2360) system and this credit is within it.
According to the USGBC, it is expected that this comment period will lead to substantial changes and improvements to the proposed draft credit revisions. As someone who works with LEED on an ongoing basis you want it to not only represent the best in sustainable building, but also be understandable and easily implemented.
Unfortunately there are some problems with the draft credit language for IEQ Credit 4.0 (and therefore the above Pilot Credit) and if not fixed they could have a negative effect on the indoor environment in these high-performance green buildings. These issues include:
• The proposed low-emissions credit fails to make product emissions requirements more stringent. They still only look at 35 individual chemicals and then only certain products do that many chemicals. Some product types look at the total chemicals emitting from a product and others don't. Yet there are 10,000 individual chemicals that can come off man-made products. Only 10 of the top 100 that are most commonly seen coming off of products are in the 35 individual limits. This is not protective enough for a sustainable building.
• At a time when pollutant source control is desperately needed to protect human health, the proposed credit introduces a layer of complexity that will likely discourage project teams from pursuing it. Instead of simply telling you what standard a product should follow it is asking you to do complex calculations. We have been told by numerous LEED professionals that due to this complexity they are likely to skip this point altogether.
• Differing product emissions requirements within the proposed credit mean that LEED Certified buildings in North America could have worse indoor air quality than those constructed outside of North America. There are different standards allowed for buildings outside North America - standards that look at hundreds of individual chemicals for many products, yet within North America the limit is only 35 individual chemicals.
• Poorly defined and inconsistent product emissions criteria and test methods within the proposed IEQc4 mean that some qualifying products could emit higher levels of chemicals than others, posing a significant exposure risk. Different products are held to different chemical emission criteria - this would be like having different chain of custody rules for wood used on the floor and wood used on the wall. All products in our indoor environment should have to meet the same chemical emission criteria.
• A lack of direction, appropriate reference methods, and verification requirements in IEQc4 will lead to confusion, misapplication, and abuse of the credit, which will have a detrimental effect on indoor air quality. Some of the current reference methods have 6 different pathways to show compliance. These different pathways will likely lead to completely different outcomes – leaving the system easy to manipulate, as manufacturers can simply pick the path that shows their product is low-emitting when in actuality it may not be.
All comments must be submitted to the USGBC by January 14th!
GREENGUARD Children & Schools Certification would still currently qualify any product certified to the new language, so our concern is not how it effects us, but how it effects sustainably certified buildings and their IAQ. Please help protect the health of LEED building occupants by submitting your comments today. For more information on the proposed language, sample comment language and instructions on how to submit comments to the USGBC, please visit www.greenguard.org/pledge
Thank you again for your commitment to good indoor air quality in green buildings .
Randal Carter
Director, Global Product Safety and ComplianceSteelcase Inc.
91 thumbs up
December 16, 2010 - 11:04 pm
I am writing this from Beijing, where I am one of two U.S. advisors to a government research team developing a low-emitting furniture standard and certification program. Therefore I unfortunately have little time to respond in detail just yet.
The technical issues raised in Josh's comments are complex, and include some valid concerns worthy of legitimate debate. However, these comments also reiterate and expand on the inflammatory and inaccurate claims available at www.greenguard.org/pledge that may unnecessarily instill fear and confusion.
These claims include:
“The proposed IEQc4 fails to make product emissions requirements more stringent.” And “…the proposed changes—if accepted—could result in the creation of unhealthy interiors in all LEED Certified buildings, including schools.” And “Rather than raising the bar on indoor air quality and requiring rigorous, comprehensive chemical emissions limits, the proposed IEQc4 encourages adherence to weak product emissions criteria and insufficient test methods. This is alarming, given that the intent of IEQc4 is to safeguard against poor indoor environmental quality. Moreover, the proposed revisions to IEQc4 all but ignore the serious concerns with indoor air quality that were raised in the April 2010 report, LEED Certification: Where Energy Efficiency Collides with Human Health." And now ”...manufacturers can simply pick the path that shows their product is low-emitting when in actuality it may not be."
These claims are categorically false.
The proposed IEQc4 credit significantly strengthens the USGBC requirements for indoor environmental quality. Notably, it adds VOC emissions requirements from the California Department of Public Health (CDPH) to paints, coatings, adhesives, and sealants where only VOC content was previously addressed. It expands the scope to address more VOC sources within a building (thermal and acoustic insulation, all individual furniture items, all layers of ceilings, floors, and walls, and built-in cabinetry). Previously ceilings were not addressed in all rating systems and emissions from insulation, individual furniture items, and built-in cabinetry were not addressed at all. It adds CDPH Chronic Reference Exposure Level (CREL) based requirements for furniture. If you are not aware, CDPH requirements include one of the toughest formaldehyde emissions criteria in the world.
Continued legitimate debate about the credit content is vital to this process. The good news here is that the proposed credit is stimulating this debate, even if some participants may be motivated in part by keeping their proprietary programs written into the credit language. I encourage others, especially members of the USGBC IEQ TAG and the USGBC IEQ working group who participated in the 1.5 year effort to draft the proposed credit, to participate in this discussion.
Josh has posted his comments on two forums; this one focused on Pilot Credit 21 Low-Emitting Interiors, and the one focused on all LEED 2012 proposed revisions. I will post my initial response on both, but I suggest we shift the detailed commentary to this Pilot Credit 21 page, as it focuses specifically on the credit under discussion.
I plan to post additional responses to the specific concerns as I can make time available while traveling. Please see the detailed FAQ document that addresses many of these issues (the linke is posted under the Birds Eye View page for this credit).
These issues are not simple nor easy. Good people are struggling with these all over the world, and there is certainly room for improvement in the proposed credit. I am confident that this debate will ultimately help us to make the LEED program even better.
Tristan Roberts
RepresentativeVermont House of Representatives
LEEDuser Expert
11477 thumbs up
December 17, 2010 - 7:56 am
Due to some of the strong opinions associated with this topic I'm going to set some ground rules as LEEDuser forum moderator:1) Be as concise and clear as possible—everyone wants to follow along. (For those less familiar with the proposed credit language, I recommend reading USGBC's FAQ on it, which is posted in the Bird's Eye View tab above.)2) Understand that everyone has the same goal of healthy buildings.3) Support opinion with facts and concrete suggestions.Anything else?
Josh Jacobs
Technical Information & Public Affairs ManagerUL Environment
515 thumbs up
December 17, 2010 - 4:24 pm
I agree a technical and scientifically driven debate about the credit is vital to the process and will lead to improvements in the proposed credit, but your comments don’t address the issues I bring up and underscore one of my main concerns, the proposed language is too complicated and confusing and will likely lead to people just skipping the credit altogether, an outcome none of us want. If someone who is not only paid by a large furniture manufacturer to work on and understand this issue, but also is one of the primary authors of the proposed revisions doesn’t see the technically relevant scientific issues, then how can we expect a green building practitioner who has not been so involved in the development process to understand how to comply with this credit. The credit needs simplification – comply with X, not another table that has to be filled out. So I will spell our concerns with our post and the credit:
1) When GEI stated that the product emissions requirements were not made more stringent, we meant three things:
a) While we applaud the USGBC for making actual emissions rather than just content part of the rating system for adhesives and paint mandatory (something we have long advocated for), we don’t feel this is more stringent as the proposed emission requirements were already required in LEED for Schools. Including this is simply updating the language to ensure consistency among the LEED suite of tools;
b) It has been widely reported that some sustainable buildings are having problems with their indoor air quality, using low-emitting materials, or just requiring an air clearance test to ensure a healthier indoor environment were not made prerequisites;
c) Composite wood still only requires a single chemical to be minimized and most products only require 35 chemicals to be minimized. This was already being done in LEED for Schools, so again the revisions are merely bringing the credit in-line with what is already being done in other versions of LEED.
Some may call that an improvement, but when studies are consistently showing that humans are being exposed to more and more chemicals every day, more is needed to protect the health of building occupants. Our suggestion is ensure that low-emitting products are utilized by making them a prerequisite or even better require indoor air quality clearance testing (EQc3.2) be passed before occupancy (make it a prerequisite) – this would add stringency.
2) BIFMA M7.1-201X, which has been included in the draft credit (even though it is not yet finalized and we do not know what the final product will be) as currently written allows for 6 different paths to prove compliance, all of which can result in greatly different outcomes. Some of those actually don’t even require a final full product to be tested for its chemical emissions. So we would suggest the removal of a test methodology that isn’t finalized and make sure that any methodology used requires a full final product is tested to show that it is low-emitting. Also, include a single test method and criteria for all products, not different test methods and criteria for different products.
3) Combining more products into this credit is a step forward; unfortunately the language is written in such a way that most practitioners will not understand how to use it. Additionally, all low-emitting material credits have been given points in other rating systems where they weren’t specifically called out. This was done using the compliance criteria in LEED for Schools, so again the proposed credit is just updating the language to ensure consistency across the LEED Rating Systems.
4) The CDPH Chronic Reference Exposure Levels (CRELs) have been a requirement in LEED for Schools specified furniture. So again, while we applaud it being brought over to some other rating systems, it isn’t something ‘new’ – it is just holding all furniture to the same standard.
One thing I think we can agree on (and as evidenced by the discussion here) is that this credit needs some work if the ultimate goal of improving the indoor air quality and providing a safer environment for building occupants is going to be realized. Too often the health of building occupants has been an overlooked area of green building, and we are hopeful that the interest shown here, and elsewhere, will lead to a more robust and rigorous credit for low-emitting interiors within LEED buildings.