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NC-2009 IEQc3.2:Construction IAQ Management Plan—Before Occupancy

Comment on Value and Purpose of IEQc3.2

As a Certified Industrial Hygienist with 28 years of experience conducting IAQ assessments and a Masters Degree in Toxicology/Industrial Hygiene with a thesis on new carpet emissions I want to state my disagreement with the description of the value and purpose of the subject credit at the beginning of this list. The introduction to this credit above states "IEQc3.2 ensures that the building ends up with the intended result (i.e., good IAQ for occupancy)...The credit has a direct impact on occupant health and comfort..." - In my expert opinion these claims are false. First of all flush out has little impact on future IAQ as many past studies have shown. Second of all the air testing is simply a snap shot that often evaluates things other than building emissions (e.g., cleaning products used for final cleaning, outdoor air pollutants, etc.). It may be considered a screen to identify whether low emitting materials were properly used but it will NOT "ensure that the building ends up with good indoor air quality for occupancy". In my experience IAQ complaints from building occupants are and have been seldom related to new building emissions. The biggest indoor pollutant source is humans. These tests are done before occupancy so the effect of humans "polluting" the indoor environment and how the building handles that is not evaluated. LEED does not address maintenance or housekeeping which are many times more influential on IAQ than new building emissions. Prevention of fungal contamination after occupancy is not addressed by LEED (i.e., use building materials that don't support fungal growth in water use areas). Intake of pollutants from sources like sewer vents, combustion sources (oven, boilers, etc.), bathrooms, etc. are not addressed in LEED. I can give numerous other issues that are built into "Green" buildings that contribute to poor IAQ and have a much greater negative impact on IAQ than new building materials off-gassing. At best, IEQc3.2 either blows out a small amount of VOCs and small dust particles or helps evaluate whether the use of low emitting building materials was not totally botched. At worst, it gives the false impression that the new "Green" building will have good IAQ. The smell of "Green" may very well be fungal growth (mold) or the money going down the drain to respond to IAQ problems.

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Wed, 09/17/2014 - 20:12

Dale, I disagree with your reasoning and understanding of the benefits of this credit. I also have years of experience in IAQ testing and started my career in that field. Imagine if you purged a car before it was sold and used by its new owner. That initial VOC smell really lingers when purging is not performed. If the testing and purging are well coordinated, particularly with regard to the installed furnishings, then there is a significant difference in the initial period of IAQ for the occupant. The credit of course does not address long term IAQ. This is addressed in LEED EBOM instead. Using your logic, you could also claim that commissioning is a waste of time since the parameters of operation and operator adjustments will eventually degrade performance over time, thus why do it. However, in best practice commissioning, a systems manual must be supplied that includes how to recommission the building. If I was to fault the IEQc3.2 credit, I would say that it should supply the owner with information on how to maintain IAQ and to conduct IAQ surveys on certain regular basis and provide names of consultants who can assist in performing tests when required.

Wed, 09/24/2014 - 01:45

Ian, First of all, thank you for your response. Opposing points of view are always of value because they help point out weaknesses in an argument and can sometimes lead to learning new things. With that being said I would agree that flush out may have a minimal value to improved new building IAQ. With that being said are the extra energy (causing increased outdoor air pollution), air filter waste (causing waste of resources and landfill space), schedule delays, etc. worth a debatable minor improvement in IAQ at the beginning of occupancy? I say no. As I have stated previously, the intent statement for LEED 2009 IEQ Credit 3.2 Credit is "To reduce indoor air quality (IAQ) problems resulting from construction or renovation to promote the comfort and well-being of construction workers and building occupants." In my opinion flush out or air testing do not accomplish this intent and, as such, this intent statement is misleading and incorrect. First of all, how does flushing out a building or doing air testing "after" construction do anything for construction workers? Secondly, bringing in a little extra outdoor air into a building after it has been ventilated throughout the construction process is not going to do a whole lot to "promote" occupant well-being. In my experience the outdoor air and other non-construction related issues such as cleaning products used before occupancy or occupant associated issues such as dusty furniture from another location or off-gassing from new equipment packing materials are often a problem and cause of air testing failure (per arbitrary LEED requirements). Your example of comparing purging a car to building flush out is comparing apples to oranges. A car is not constantly ventilated during or after construction as is the case with a building. Of course blowing out a car is going to reduce interior VOCs until you stop and then they will just build up again until the car is old enough to stop having significant off-gassing. A building with the proper amount of "clean" outdoor air provided on a constant basis (unlike a car) both during construction use of VOCs (paints, adhesives, etc.) and after construction will take care of removing most of the VOCs. Pushing through a little extra outdoor air before occupancy (flush out) is going to pale in comparison regarding the value to good IAQ of continuous outdoor air intake. Your commissioning comment is simply off base. The main function of commissioning is to assure that the building systems operate the way they were designed to operate once installed (hopefully the design was good in the first place). Flushing out a building has nothing to do with the proper operations of building systems. I would never argue that building commissioning is a waste of time. In fact it is a very valuable aspect of LEED. It would be nice if it was applied to IAQ related issues more. One of my main arguments has been that many things get designed into a building that cause IAQ problems (sewer vents too close to outdoor air intakes, air handling units hard to access and maintain, supply vents next to return vents causing airflow short circuits, air filters not fitting properly, cellulose [paper] in drywall used in high water use areas such as bathrooms, kitchens, janitors closets, etc. etc. etc.). It would be nice to prevent these issues from being designed and installed in the first place. Lastly, the comment that long term IAQ is addressed in LEED EBOM is false, in my opinion. I have done numerous presentations on LEED EBOM (2009) and, as such, am very familiar with its contents. LEED EBOM as it applies to IAQ basically has the same requirements as are found in LEED for New Construction with the addition of a bunch of written policies and the use of "Green" cleaning. Sometimes the "Green" stuff is just as or more hazardous than the traditional cleaning products. The idea often put forward is that the chemical is OK because it is "natural". Poison Ivy is natural too. The only truly different aspect of LEED EBOM from LEED for New Construction is IEQ Credit 1.1 which is worth 1 credit and requires the building owner/operator to "Develop and implement on an ongoing basis an IAQ management program based on the EPA Indoor Air Quality Building Education and Assessment Model (I-BEAM)". When I talk to architects that do LEED EBOM they say that Credit IEQ 1.1 is an easy credit because all they have to do is complete an I-BEAM checklist. Perhaps if an I-BEAM program was actually developed and thoroughly implemented by an IAQ Professional and maintained by the building owner/operator it might actually improve IAQ. Apparently that is not how it is implemented if it is implemented at all. In conclusion, I stick by my previous posts regarding the value of LEED Credit 3.2 (or lack thereof) as it pertains to its claimed intent. There are many other things that could be done to help assure good IAQ in a "Green" building that are not even in the discussion at USGBC or in other related rating systems or codes. USGBC has shown over and over again a lack of interest in hearing from IAQ experts such as Certified Industrial Hygienists with IAQ experience. I know this from personal experience as someone with the knowledge and experience I have presented in previous posts who has been denied participation on the IEQ Technical Advisory Group for LEED on several occasions and has had his comments on new versions of LEED ignored for more than a decade. It is a shame that real science does not prevail with the USGBC and other similar organizations. Our world could be improved tremendously if it did. Ian, if you have some peer reviewed, science-based studies on the value of building flush out as it relates to measureable improvement in indoor air quality in a new building I would be very interested in having those references. The following reference suggests a lack of value for flush out: Applied Occupational and Environmental Hygiene Volume 11, Issue 6, 1996 Effects of Ventilation Flushout on Indoor Air Quality in a Newly Constructed Office Building. Also, the 2012 International Green Construction Code has eliminated building flush out as a way of assuring good IAQ.

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