IAQ Testing - Maximum Concentrations

Donald,
If you have read some of my posts in the past you would know I have been discussing the inappropriateness of the contaminants in Credit 3.2 Option 2 and their maximum levels for quite a while. I have been commenting on LEED for a decade in this regard and have been ignored along with my peers who are experts in indoor air quality (professional or certified industrial hygienists).

Some history on this explains some of the problems. In the mid-1980s I was doing my Master’s Thesis on new carpet odor (4-phenylcyclohexene [4-PC] – note its presence in LEED). After my work was done and my thesis was published (mid-1986) the EPA Headquarters building in Washington D.C. was experiencing indoor air quality problems (1988), which had been ongoing but worsened due to a renovation project. After some initial testing, which didn’t reveal significant problems, the union for federal employees found my research and presented it to management. Suddenly 4-PC, as a byproduct of the latex backing manufacturing process for carpets, was the smoking gun. In my opinion, it played a minor role because there were many problems with ventilation and other renovation activities that likely outweighed the new carpet issue. However, one of EPA management’s decisions in response to this episode was to require the hiring of an “indoor air quality (IAQ) oriented” architect (whatever that meant in the late 1980s). This architect was to draft a “major IAQ component” to be included in “technical facility requirements” for the future construction of EPA headquarters buildings. If you wish to read a summary of this event EPA document EPA/400/1-89/001B titled “Report to Congress on Indoor Air Quality Volume 1: Federal Programs Addressing Indoor Air Quality” has a 3 page summary starting on page 23.

On with the story – I believe the document that was developed by the “IAQ oriented” architect resulted is a document called “EPA Protocol for Environmental Requirements, Baseline IAQ and Materials, for the Research Triangle Park Campus, Section 01445”. I believe this was developed in the early 1990s. It had a variety of requirements for air testing including testing at 16 locations over three consecutive days. It included testing for carbon monoxide, formaldehyde, total volatile organic compounds, total particulates and 4-PC (sound familiar?). However the allowable levels were somewhat different than the currently are in LEED. For example, formaldehyde was 20 micrograms per cubic meter (ug/M3) above outside air concentrations compared to 27 ppm (different units) in LEED 2009, TVOCs were 200 ug/M3 above outdoor air compared to 500 ug/M3 in LEED 2009, and particulates were 20 ug/M3 compared to 50 ug/M3. In addition to these parameters, the 01445 document required sampling for carbon dioxide in an empty building, which is useless, and sampling for microbial materials and EPA primary air pollutants such as sulfur dioxide, nitrous oxides, lead, and ozone. This document still exists with some minor changes. For example, carbon dioxide monitoring is no longer required and there are not as many samples required. The document is now called “Testing for Indoor Air Quality Section 01 81 09” dated December 2007. It is referenced in Green Globes as the means to do IAQ testing and I have seen it incorporated into federal building project specifications. It basically costs about ten times to do that sampling compared to LEED 2009 sampling.

In my opinion, the “IAQ oriented” architect was not the most appropriate professional to develop this document and likely did not get the input of professionals who investigate IAQ problems for a living (i.e., professional or certified industrial hygienists). The parameters identified in the EPA specification are not health based and in many ways where pulled out of a hat.

You may ask what does this have to do with LEED 2009 EQ Credit 3.2 Option 2. Well guess what document was specified in LEED version 2.0 for baseline IAQ testing. That’s right – good old 01445. I can just see the creators of LEED contemplating what they should adopt for IAQ testing. Voila – there it is, a specification (architects know specifications) created by the “Environmental” Protection Agency - perfect. As we went through LEED versions 2.1 and 2.2 and then 2009 the requirements morphed a little bit with a new source being referenced as the State of Washington’s IAQ standard which no longer exists. I commented each time a new version was up for adoption but I was ignored each time including LEED version 4.

You may infer from my tone that I am a bit bitter about the whole thing and you are correct. As you can see in a small way my Master’s Thesis research led to where we are now with LEED IAQ testing. If you look at the IAQ testing parameters in LEED version 4 you will see that 4-PC has finally been removed. However, most of the other questionable parameters remain with the addition of the California target chemicals which come from a document for product emissions and not IAQ. Also note that the EPA IP Compendium Methods are still recommended. IAQ professionals don’t use those methods and most labs won’t analyze per those methods. It would be nice if the people at USGBC would listen to the experts. The American Industrial Hygiene Association is currently working on recommendations for testing and other approaches to help assure good IAQ in a Green building. I hope this long winded explanation answers your question.

Dale Walsh, MS, CIH, LEED-AP BD+C

Hi Dale, do you know where 27 ppb of maximum allowable concentration came from? In LEED v4, maximum allowable concentrations from target chemicals were half of their chronic reference exposure levels except formaldehyde. Why is formaldehyde a exception? Thank you.

Dale (or anyone) if you post a reply to the v4 question, please do it over on the v4 forum. Thanks!