"Everything within the waterproofing membrane"

Partially True.  True: The membrane itself is not included.  Technically, only a percentage of the materials for the credits you are seeking must meet low emitting critera (v4.1).  IE: If you are pursuing ceilings, 90% of the materials must comply to contribute, and with walls only 75% must comply - though it's certainly a lot easier to calculate if you don't have to use the budget method AND you can get a bonus point for tracking at 90% for a min. of three categories.  If your project is v4 and you're substituting v4.1 credits, your materials can utilize v4 testing standards (CDPH Standard Method v1.2-2010 rather than 2017).  The v4 guidebook has some pretty helpful diagrams that really help visualize where they draw the line.  

We also got a response comment that you have to get the actual testing lab data/certificates from the manufacturers. The product data sheets that reference VOC content (distributed by the manufacturers) is not accepted. 

This is making this credit very difficult to collect paperwork at the end of the project, and slows down product approval processes during construction phases, as the contractors and the manufacturers have no clue what you are asking for. We were advised to not pursue adhesives & sealants as well as paints & coatings, and it was great advice as most of those products do not qualify or have proper documentation to support their claims of VOC content.  

Lab results for VOC Content? I get the VOC Emissions testing report, that makes sense, but VOC content? VOC content standards were originially developed to respond to ground level smog concerns. It seems very odd that reviewers would reverse a long practice of accepting VOC content claims from manufacturer's cut sheets.

They have to be talking about the CDPH emissions test report which should report TVOC Emisisons after 14-days. The VOC content listed on a Product Data Sheet is different from this. The manufactuer should be able to report this and provide you documentation if they actually have had their product tested. 

this one has been a bit of struggle for us as well. 

Laboratory's that conduct the tests must be accredited under ISO/IEC 17025 ... and/or ... organizations that certify manufacturer's claims must be accredited under ISO Guide 17065.

This is what the LEED reviewer is looking for. Statements and product data from manufacturers is no longer accepted by GBCI when documenting VOC compliance. 

This is a LEED Coach's response: "A wet-applied product (Adhesives and Sealants / Paints and Coatings categories) must have two documents provided: VOC content and VOC emissions evaluations (or General Emissions Evaluations, if you are looking at v4 instead of v4.1). The product data sheets that reference VOC content (distributed by the manufacturers) are accepted for VOC content documentation, but not for VOC emissions evaluations. For the VOC emissions evaluations, the third-party certificates or lab reports must be provided. If a third-party certificate is provided, and the certification body is not listed on the Third-Party Table, then the certification body must be accredited under ISO Guide 17065. If a lab report is provided, the laboratory that conducts the test must be accredited under ISO/IEC 17025. "

So in short - for VOC content, the manufacturer's product data is acceptable; for VOC emissions the lab report is required. 

If you have access to a project through LEED Online it has some useful graphics to help clarify what is within the weather barrier.  Under a LEEDv4 project go to the Low-emitting Materials credit click on the "Credit Library" tab, then click on the "Guide" tab and select "Further Explanation" on the left menu.  There is a section on "Definition of Building Interior and Exterior" with 6 Figures (4 wall sections with different claddings, and 2 roof sections.) It is not crystal clear where the weather barrier is in all those details but generally we interpret them to mean that the weather barrier is outside, and components from the inside surface of the weather barrier are inside.  LEED v4.1 would be the same but apparently since it is in pilot there are no guides for v4.1 shown.

Hi Chyanne, where can we find the guidance / info that states that "If your project is v4 and you're substituting v4.1 credits, your materials can utilize v4 testing standards (CDPH Standard Method v1.2-2010 rather than 2017)." It would be helpful to know that it still applies, and I'd like to make sure before I go ahead with v4.1. Thank you! 

EDIT. Found the LEED interpretation : https://www.usgbc.org/leedaddenda/10495

Regarding whether the weather barrier is "interior" or "exterior" - this below is from the v4 Reference Manual: "The building interior is defined as everything within the waterproofing membrane. The building exterior is defined as everything outside and inclusive of the primary and secondary weatherproofing system, such as waterproofing membranes and air- and water-resistive barrier materials."

Cold climate building are frequently equipped with a robust vapor barrier located on the  inboard side of framing and insulation, vapor permieable weather barrier and siding.  TYhis vapor barrier it typicly a 6-10mils polyetylene plastic and is sealed at all laps and edges, effectivly isolating those wall components ourboard of that layer  from the interior environment.  In htese design cases, is that what woudl be considered the waterproof membrane?  I am not seeing any depeer explantionin v4.

Deborah:

We are also wondering if the vapor barrier can be the same as the “waterproofing membrane”? I would have thought they mean where rain hits the façade, but reading “Further explanation” on LEED Credit Library as Ralph refers to above, it seems that they have an imaginary border inside the wall, and not where the rain hits the façade. Can anyone tell us if we can use the vapor barrier as the border? As Sean says, that is what we have on cool climates, I don’t know how common that is in the rest of the world, but in Sweden a building has to be airtight. The vapor barrier is located on the warm side, sometimes about 7 cm into the wall to allow for electrics etc to run in those 7 cm.

My 2 cents is to make a choice based on the credit intent of "To reduce concentrations of chemical contaminants that can damage air quality and the environment, and to protect the health, productivity, and comfort of installers and building occupants." The requirement of inside the weatherproofing assumes there is an air barrier inside of which product emissions may affect indoor air quality.

I agree with Michelle's statement to consider the intent to proptect human health and reduce the harmful VOC's in the interior environment.  That requires some subjective judgement. What it takes to do that effectively or specificly is not entirely clear-cut in terms of the layers in an exterior assembly that will reduce the passage of VOCs.  The answer to your "yes and no" is not an absolute based on intent.

Fortunately LEED Online provides graphics of different wall assemblies and where the divide is (for LEED purposes).  The guide is available in LEED BD+C V4, Low-Emitting Materials under the "Guide" tab. Scroll down to the heading "Definition of Building Interior and Exterior". Six illustrations are shown. Note, for instance, on the example for a Metal Stud Wall Assembly the dividing line is shown on the interior-side surface of the exterior sheathing, NOT on the interior-side surface of the felt (supposed weather barrier). 

I agree with the comments above, as this is an "Indoor Environmental Quality" credit. Deborah I also agree with you that the air/vapour barrier is the dividing plane between interior and exterior in a cold climate.  The LEED definitition of "weather barrier" (and even their diagrams) are vague and confusing to try apply universally across a wide range of climates even within the USA.

The "requirements" paragraph of the v4 reference guide states "The building interior is defined as everything within the waterproofing
membrane.The building exterior is defined as everything outside and inclusive of the primary and secondary weatherproofing system, such as waterproofing membranes and air- and water-resistive barrier materials."

Those two sentence are a bit contradictory, but logically everything inside the air/vapour barrier would be the interior.

Help! The project is located in a cold climate. Does the roof insulation, which is sandwhiched between the waterproofing membrane and the air barrier, need to comply with the EQc Low-Emitting Material requirements? After reading through all of the comments above, I am still confused.

Per the v4 and v4.1 Reference Manuals: "The building interior is defined as everything within the "waterproofing" membrane. The building exterior is defined as everything outside and inclusive of the primary and secondary weatherproofing system, such as waterproofing membranes and air- and water-resistive barrier materials."

There is a big difference between "waterproofing membrane," which would be the EPDM membrane, and the "air barrier." An air barrier reduces the flow of air, a vapor barrier reduces the flow of water vapor, and a waterproof membrane reduces the flow of liquid water. Each function is completely different.

Again, the insulation is sandwhiched between these two layers.

Theresa
pg 671 of the v4 Reference Manual shows similar conditions: EPDM membrane and vapor retarder sandwiching the insulation. Everything inboard of the vapor retarder is considered interior.

I agree with Deborah - I have found these EPDM and TPO diagrams to be very helpful, except they are on page 673 in my v4 Reference Guide.  

Heads up that we recently received a reviewer comment that refered to the April 2023 LEED v4.1 LEED BD+C: New Construction beta guide (pg 238) stating we now need to include the air barrier membrane itself and vapor barrier (if inside air barrier) in the low emitting materials calculations: 

Follow the language in the rating system  for each product category to identify materials to include.  Some materials installed in the project are excluded from this credit entirely. For example, the following products are not applicable to the product categories, or they are considered exterior products: equipment related to fire suppression, HVAC, plumbing, electrical, conveying and communications systems, poured concrete, Structural insulated panels (SIPs), and water-resistive barriers (material installed on a substrate to prevent bulk water intrusion). For this credit, the following products should be considered within the building interior: the air barrier membrane itself, the vapor barrier/vapor retarder membrane (if used inside the air barrier), and non-structural prefabricated building envelope products that are in contact with the building interior such as sandwich panels,  

This credit continues to creep into more and more building compontents.
And now, testing must be renewed every three years whether or not you've changed manufacturing. Testing isn't free. What is the point if your product hasn't changed? 
There is a line between promoting improved environmental conditions and becoming an unjustifiable burden. With this April 2023 "clarification" I feel it's now crossed over to the zone of undue burden. Convice me otherwise. 
I'm serious. Please do convicne me otherwise. I would like to know. 

Seconding Martha's comment, as the scope of this credit continues to grow - specifically, growing to include materials that are installed before the building is enclosed so the IAQ risks to installers and occupants are much less of a concern! 

And a question re: Laura's review comment - if the air / vapor barrier membrane is included, what category is it in? None of the product categories in the v4.1 credit seem to address it. Walls?? (I already gave up on achieving walls...)

thumbs up to Martha and Emily,,,,unless you are Dan Campbell, I think you are punting on this one :)

Nerding out on this....so depending on whether the VB is a membrane or-fluid applied, we follow either SCAQMD rule 1168 (for the adhesive) or 1113? 

I apologize for not being clear. What makes this confusing is the interchanging terms of "waterproofing membrane" and "weatherproofing membrane" as refered to in the diagrams in the LEED v4 Reference Guide. These terms are different. Again, as I mentioned earlier, there is a BIG difference between waterproofing membrane, vapor barrier and air barrier. I'm not the architect that specifies the material, I'm simply the contractor that has to collect the information and upload it to LEED Online and respond to the reviewer's comments. But, I also am trying to review submittals on other projects and don't want to get burned by the current review comments. The roof details are the same. They always are the same for flat EPDM roofs in this climate. There is the roof deck, then the air barrier, which is the "weatherproofing membrane." There is NOT a vapor barrier. Then, a layer of insulation and a cover board. The top layer is the EPDM, the "waterproofing membrane." The review comment is the "waterproofing membrane," not the "weatherproofing membrane" that is referenced in the LEED Reference Guide, which also refers to the air and/or vapor barrier. Is it the "waterproofing" or "weatherproofing" membrane that is the plane? If it is the "weatherproofing membrane" then the roof insulation and cover board would NOT be included. If it is the "waterproofing membrane, then the roof insulation and cover board are included. Or is it is just the roof insulation? Frustrating...

Theresa,

RE the April 2023 LEED v4.1 LEED BD+C: New Construction beta guide (pg 238)
"For this credit, the following products should be considered within the building interior: the air barrier membrane itself, the vapor barrier/vapor retarder membrane (if used inside the air barrier), and non-structural prefabricated building envelope products that are in contact with the building interior such as sandwich panels".

Sounds like your confusion stems from your LEED reviewer's comment? If so, get them to clarify.

The USGBC issued an updated 4.1 Refernce Guide in February 2024. I was hoping it would clarify the seemingly new requirement that testing to CDPH standards had to be updated every 3 years. Unfortunatley, I am still confused. Like the addenda, it requires that "Manufacturer statements must include a summary report from the laboratory that is less than three years old" and adds inclusion of "the amount of wet-applied product applied in mass per surface area (if applicable)". Often we submit the lab report, not a manufacturer's statement. Are they saying that the three year criteria only applies when relying on manufacturers statements, or is this just wishful thinking?  That said, testing companies such as SCS Global Services appear to be stating the dates of certificate validity (one year in their case!), and I would assume are alerting manufacturers to impending expiry dates. I'm OK with that, as long as they take on that burden - I definitley don't want to find the architectural community in that position!

Kristi…I have had the exact same thought for a long time now and have been frustrated with the way it’s worded in the beta guide. If the reviewers require the lab report to be less than three years old then it should state such in the second paragraph under VOC emissions evaluation.

It should read something like the following if the certificates / lab reports are required to be less than three years old.

Laboratories that conduct the tests must be accredited under ISO/IEC 17025 for the test methods they use. The laboratory reports are to be included and must be less than three years old…etc. etc..

Otherwise, right now the beta guide is asking about Manufacture statements…which we don’t collect or submit as our supporting documentation nor are we asked for manufacturer statements during the review process to document compliance.

Feeling the confusion and seeking the same clarification as you, Kristi!