Hello,
I would like to make sure about International Alternative Compliance Path for Option 2 of the credit. In reference guide we can find the information that, if the material doesn’t contain any substances that meet REACH criteria for substances of very high concern or ingredients listed on the SVHC - it meets the requirements. That is the reason why I had found manufacturer declarations sufficient to document compliance until I bumped into ID#100002163. Does it state that manufacturer declaration alone is not suitable, and the manufacturer have to provide fully inventoried chemical ingredients to 100 ppm and assess each substance?
I would be very grateful for the professional guidance.
Calie Gihl
Design EngineerLEEDuser Expert
19 thumbs up
November 26, 2017 - 6:15 pm
Hi Agata,
My interpretation of the new text is that the manufacturer must now provide fully inventoried chemical ingredients to 100 ppm for compliance. Although the reference guide is not up to date without the ID addenda, LEED User's credit language section reflects the change in requirements.
If the manufacturer has a declaration but not the additional inventory of ingredients, it wouldn't hurt to reach out to them to request this information, or see if they can produce it.
Nadav Malin
CEOBuildingGreen, Inc.
LEEDuser Moderator
844 thumbs up
December 4, 2017 - 3:32 pm
Yes, I'm with you, Calie. But I think the language is still unclear about whether or not that full inventory down to 100 ppm has to be published or delivered with the product documentation. It might be sufficient for the manufacturer to document that they've done the inventory down to that level--especially if that claim is backed up by a reputable independent auditor.
If GBCI does require the inventory down to 100 ppm be available, I'm pretty sure that they would still allow for some of the product contents to be listed as "proprietary," like they do for the manufacturer's inventory in Option 1. Those proprietary substances would still have to show their function in the product, what % of the product they represent, and indicate that they don't contain any REACH list substances, I expect.
Does anyone else have experience with this recently? Or a ruling from GBCI to share?