As currently written, the proposed low-emitting interiors credit fails takes some small steps forward and, in my opinion, takes some steps back on protecting building occupants from indoor air pollution associated with product emissions. Rather than simplifying the credit (which would align with the USGBC’s publicly stated goal of simplifying the entire LEED rating system) and increasing stringency, the revised credit adds a thick layer of complexity and fails to raise the bar on indoor air quality across the board. This is somewhat alarming, given that the intent of the low-emitting interiors credit is to help protect the health of LEED certified building occupants.

Additionally, the proposed revisions all but ignore the serious concerns with indoor air quality raised in the report, LEED Certification: Where Energy Efficiency Collides with Human Health. Compiled by Environment and Human Health, Inc. (EHHI), the report concludes that LEED fails to protect human health because it allows and, in fact, rewards the use of high-emitting products during the construction, build-out, and furnishing of LEED certified buildings.

The primary problems within the proposed revisions to the low-emitting interiors credit are as follows:
• The new credit requires LEED users to analyze complex data and sift through eight pages of complicated mathematical formulas just to calculate a product’s eligibility to satisfy the credit. Additionally, the number of awardable points has been reduced from four to three. As a result, LEED users will likely skip the credit altogether in favor of pursuing credits that involve less work and reward a greater number of points. This will hurt the indoor air quality of LEED buildings.

• Furniture is held to different and less stringent emissions standards than other products.

• The industry-backed BIFMA test method is the only test method specifically cited in the credit for furniture, which may cause LEED users to believe—mistakenly—that this is the only qualified furniture test method in LEED. Particularly an issue because the test method uses a less stringent and less restrictive test model than other credible testing methods in the marketplace.

• The GREENGUARD Test Method (GGTM), the most widely-used and referenced product emissions testing method in North America, uses a much stricter modeling scenario and has adopted the new lower formaldehyde emissions level, as established by the California Department of Public Health for use in CA 01350. It is also what is currently used, alongside the BIFMA test method, in the current LEED Rating Systems for furniture.

To remediate these problems, the USGBC should:

• Make LEED simpler and easier to use, not more complex. The USGBC should make the low-emitting interiors credit easier to achieve by recognizing—by name— the third-party certifications that are known to comply with the testing requirements specified in the credit as they have done in other credits the rating systems.

• Reference and recognize the GREENGUARD Test Method by name, as well as other, stringent emissions test methods.

• Restore the maximum number of awardable points to four instead of three.