The reference guide is clear that special or unique water closets can be excluded from the credit calculations, my query is does this expand to special or unique fixtures? Our client requires anti-ligature fixtures in each resident room which are then classified as a private faucet but we are unable to find a watersense labelled antiligature faucet to use. Can I exclude all anti-ligature fixtures from the indoor water use credit?
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emily reese moody
Sustainability Director, Certifications & ComplianceJacobs
LEEDuser Expert
476 thumbs up
June 5, 2018 - 12:16 pm
Hi Leanne,
I recommend contacting GBCI with your question, since it's specific to your project type. I've had those fixtures in v3 projects, which met the flow requirements for the prereq, but have not yet had to address them for the Watersense aspect. http://www.gbci.org/contact
I'm hoping their response will be to make sure the fixtures meet the flow requirements and give a pass to the Watersense portion based on the project type requirements since it's a safety concern.
Please let us know if you do this and what the response is, as I'm sure it will come up for other projects.
Megan Leslie
Sustainability ConsultantStantec
25 thumbs up
July 20, 2018 - 12:51 pm
Leanne - did you get a response from GBCI about this yet?
Stewart Whitcomb
Sr. Sustinability ArchitectUSGBC-in Volunteer (L.f.G)
5 thumbs up
December 9, 2019 - 8:18 am
I've just submitted an CIR on this same topic, The design and construction teams have been unable to identify any anti-ligature or ligature resistant lavatory or sink which carries the water sense label. The water-use and internal functionality of these lavatories is not specialized, and we have found a number of models with compliant/low 0.5 to 0.25 gpm flow-rates. The manufacturers simply appear to have forgone submission and testing with the EPA. The specialized ligature resistant lavatory housing/shape and attachment are required by the Project to protect the life and safety of our patrons.
The market has provided a pre-assemble bathroom kit/drop-in unit that has a lavatory and carries a water sense label. However, that pre-assemble bathrooms manufacturer' Willoughby indicated they do not make a water sense and ligature-resistant lavatories. The water sense label on this unit applies to the toilet/water closet only. The Willoughby ligature resistant lavatories are not water sense labeled.
The proposed solutions are an exemption be allowed for anti-ligature lavatories as an alternate compliance for Water Sense labeling until the market provides water sense labeled fixtures. This is not an exemption from water efficiency or responsibility from the water consumed. We'll use the manufacturer's flow rate in our calculations for the indoor WE Credit.
Alternatively the commissioning and construction teams maybe able to field verify the water-flow rate and water pressure measure for this fixture (Max 0.5 gpm, but manufacturer's provided rate at 60 psi) within the commissioning process to meet the intent of the credit, in replacement for the EPA water-sense certification of the lavatory in the private anti-ligature restrooms. This will require a specific process, equipment and follow-up calculations to confirm the pressure and flow-rates are suitable.
Megan Leslie
Sustainability ConsultantStantec
25 thumbs up
December 9, 2019 - 7:28 pm
FYI - I ended up submitting a CIR in 2018:
Formal Inquiry:
The Indoor Water Use Reduction prerequisite and credit require that the following fixture types must be WaterSense labeled:
- Tank-type toilet (water closet)
- Water-using urinals
- Private lavatory faucets
- Showerheads
Our project includes a 75-bed mental health substance use facility. As such, anti-ligature fixtures are required in areas that are accessible to patients. However, our project team has not been able to find water closets, lavatory faucets, or showerheads that meet the anti-ligature requirement, as well as the LEED WaterSense label requirement.
The LEED v4 BD+C Reference Guide says that "fixtures whose flow rates are regulated by health codes may be excluded from the calculation".
Please confirm that anti-ligature fixtures are exempt from the WaterSense label requirement for this project.
---------------End of Formal Inquiry---------------
Project CIR: Ruling
Returned on 10/02/2018 The applicant is asking if in their health care project where anti-ligature fixtures are required in areas accessible to patients, that anti-ligature fixtures be exempt from the WaterSense label requirements. This request is because it appears there is no availability of WaterSense labelled fixtures that meet the anti-ligature requirement.
Yes, the project may use alternative anti-ligature fixtures as long as those fixtures meet WaterSense flush and flow rates.
There currently appears to be one manufacturer of anti-ligature fixtures that bear the WaterSense label. However, due to the very limited availability (single manufacturer) of anti-ligature fixtures in the current market that offer the WaterSense label, the project is allowed to use alternative fixtures in areas accessible to patients. ---------------End of Initial Ruling ---------------
Stewart Whitcomb
Sr. Sustinability ArchitectUSGBC-in Volunteer (L.f.G)
5 thumbs up
January 8, 2020 - 5:02 pm
We've just had our ruling returned... Its both better than I hoped, and worse at the same time. 0.8 GPM minimum on Private use faucets! News to us.
The project team is requesting an exemption for anti-ligature lavatories that are not WaterSense labeled due to special circumstances related to limited product availability and functional safety requirements in the client/patron bathrooms for temporary residents with addiction, mental or behavioral challenges.
Yes, the project may use anti-ligature fixtures that are not labeled by WaterSense in the resident client/patron bathrooms, as long as the fixtures meet WaterSense flow rates. The project should use the flow rate stated in the manufacturer’s product literature in the water use calculations.
For private lavatories, note that WaterSense requires a maximum flow rate of 1.5 gpm at 60 psi and a minimum flow rate of 0.8 gpm at 20 psi. The proposed 0.5 gpm flow rate would therefore not comply with WaterSense private lavatory requirements. Private is defined as fixtures in residences, hotel or motel guest rooms, and private rooms in hospitals. Fixtures used by residential occupants and fixtures used by residential-type occupants who use the building for sleeping accommodations fall into the private classification. All other applications are deemed to be public. Public lavatories have a 0.5 gpm baseline and are not subject to the WaterSense label requirement.
Stewart Whitcomb
Sr. Sustinability ArchitectUSGBC-in Volunteer (L.f.G)
5 thumbs up
January 8, 2020 - 5:07 pm
Thanks Megan, I didn't want to use the healthcare exemptions because our project is new construction (Residential occupancy) for short-term (30 day) rehab and behavioral treatment. Although, it may apply to the intake exam rooms, not the private restrooms that are for the occupants.
Erica Downs
Sustainability ConsultantThe Green Engineer
5 thumbs up
November 22, 2021 - 2:05 pm
@Megan Leslie - Thank you for sharing your LI response. Any chance you have an LI number to search by? I am unable to locate the official response you posted anywhere in the LI database. Thank you!
Susan Di Giulio
Senior Project ManagerZinner Consultants
153 thumbs up
November 22, 2021 - 3:00 pm
FYI that 0.8 GPM minimum on residential bathroom faucets is plumbing code. Residential applies to the use type - this is a place where people sleep and do all thier personal hygene. Applies to hotel guestroom baths as well.
Michelle Bombeck
Associate PrincipalO'Brien360
34 thumbs up
November 23, 2021 - 11:13 am
Hi all - Just a note that we recieved project specific approval to exempt anti-lig fixtures from the WaterSense certification requirement, with the caveat that the fixtures still met the WS flow rates. We didn't go through formal CIR process, so nothing official to share, but encouragement to reach out to LEED Coach if you have this situation on your project.
Clive Lacey
Managing PartnerCrossey Engineering Ltd.
October 5, 2023 - 11:19 am
Hi all,
We are following to the CSA Z317.1 standard in the design of the hospital. This standard requires that all lavatories must be equipped with faucets featuring a minimum flow rate of 1.5 gpm, whereas the baseline for public lavatory faucets (for visitors) is set at 0.5 gpm.
Can we modify the baseline flow rate to 1.5 gpm? Or Can we exclude the Lavatory faucets from the calculation as stated by LEED: "Fixtures whose flow rates are regulated by health codes may be excluded from the calculation" ?
emily reese moody
Sustainability Director, Certifications & ComplianceJacobs
LEEDuser Expert
476 thumbs up
October 5, 2023 - 12:27 pm
Hi Clive,
In the "Further Explanation" section of the Reference Guide, it points out that patient room sinks are considered private with a 2.2 gpm baseline. Also, these fixtures in healthcare settings are exempt from the requirements/calcs:
- Surgical scrub sinks
- Exam or procedure room sinks for clinical use
- Medication room sinks
You may still have an issue with the regular non-patient restrooms, though, in which case you'd likely need to ask LEED Coach directly with your project-specific question.