We have a question regarding REACH. The reference guide indicates that a product is compliant with credit requirements if “End use products and materials have fully inventoried chemical ingredients to 100 ppm and assess each substance against the Authorization list – Annex XIV, the Restriction list – Annex XVII and the SVHC candidate list, (the version in effect in June 2013), proving that no such substance is included in the product.”

However, article 7 of the “REACH legal text” states that manufacturers are bound to notify the agency that a substance meets REACH criteria for high concern or candidate list substances, if the substance is present in a product above a concentration of 0,1% (1000ppm), weight by weight.

We’ve received multiple credit support documents for different products in accordance with the REACH requirements stated above. By respecting REACH criteria, could we consider these products as compliant with credit requirements?

Thanks,

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ragesh ramadas

Sr.Architect,LEED Coordinator

Shapoorji Pallonji Mideast LLC

LEEDuser Basic Member

2 thumbs up

Sat, 12/07/2019 - 11:02

Can someone please answer this?

Tristan Roberts

Representative

Vermont House of Representatives

LEEDuser Expert

7780 thumbs up

Tue, 12/10/2019 - 00:09

The LEED requirement goes above and beyond REACH, in specifying a 100 ppm threshold, which is higher than a 1,000 ppm threshold. I would qualify the following by saying that I am not an expert in REACH specifically, but based on the language you have shared, the REACH documentation referenced by Charline is not sufficient at only 1,000 ppm. Please search the LEEDuser forum for more on this. I think this question may have been a duplicate which was answered previously.

Francesco Passerini

engineer

LEEDuser Basic Member

65 thumbs up

Mon, 01/13/2020 - 11:31

It seems that the best source for ingredients are the material safety datasheets (MSDS). Do you know what the requirement of material safety datasheets in the European Union is? I mean, the requested threshold (ppm) for the declaration of the ingredients? Best Regards

Tristan Roberts

Representative

Vermont House of Representatives

LEEDuser Expert

7780 thumbs up

Mon, 01/13/2020 - 15:42

Francesco, this BuildingGreen article is a good starting point for understanding SDSes (no longer MSDS), and their usefulness, and limits, in material ingredient reporting: https://www.buildinggreen.com/primer/safety-sheets-getting-new-format%E2%80%94and-some-new-data The SDS is a globally harmonized standard. Read up on it and draw your own conclusions, but SDSes are only "best" in that they are most common. But they lack many ingredients, don't usually hit the thresholds needed for LEED credit, and are not verified, which hurts LEED contribution. If you are a manufacturer, they can be a useful tool in developing your HPD or Declare label; as a building project team, they don't do you much good for this credit.

Francesco Passerini

engineer

LEEDuser Basic Member

65 thumbs up

Tue, 01/14/2020 - 08:35

Thanks, Tristan. This sentence is clear: "In addition to carcinogens, the most toxic mutagens, reproductive toxicants, and skin and respiratory sensitizers must be reported on the new SDS if they are present at concentrations of 0.1% or Greater.", i.e. 1000 ppm While LEED requires that substances are declared also at lower concentration, i.e. 100ppm.

Saad Al Haj

Sustainability Consultant

AESG

LEEDuser Basic Member

1 thumbs up

Wed, 02/12/2020 - 06:41

I believe for us as LEED specialists, the issue is done once we receive the manufacture written confirmation related to their material (either under the technical data or the material safety data sheet). Since I work in LEED projects out of USA, I face a situation where manufacturers do not have any written document confirming the compliant to REACH (and also no C2C), so I have made my own draft declaration letter confirming the compliant with all REACH requirements stated in MRc4 and I send it to manufactures to sign it off

Aury Hathout

Certified Environmental Auditor

Enviropass

LEEDuser Basic Member

2 thumbs up

Fri, 02/02/2024 - 19:36

Hello everyone, Here is a brief overview of the REACh rules. The declarable threshold for Substances of Very High Concern (SVHC) is 1000 ppm, component level. However, the REACH Annex XVII refers to restrictions at different thresholds. They can be lower than 1000 and even 100 ppm. Nevertheless, it looks like the guide exceeds the REACH expectations. It may be the case for at least some chemicals. I hope this helps. Thanks!

Ian McCall

Environmental Engineer

LEEDuser Basic Member

11 thumbs up

Sun, 07/07/2024 - 17:24

Hello LEED Friends, Sorry still not clear for me. Are all REACH products LEED complient evne the 1000 ppm ? or Do and REACH products need to be inventoried to 100 ppm ? Thanks

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