There are currently two routes through which this point can be earned, either through a two-week flush-out period, or via a testing procedure. In principle the latter method is preferable, both from a technical and logistic standpoint. A performance-based testing method provides hard data on levels of indoor contaminants in the finished building, and does not rely on the assumption that the two-week flush out period will be adequate to reduce pollutant levels to acceptable concentrations. Moreover, in most commercial building projects, a flush-out period of this length will prove to be expensive and impractical. However, we have closely evaluated Section 01445 of the EPA RTP Protocol for Environmental Requirements, Baseline IAQ and Materials, and we believe that this method is also too expensive and impractical for routine use as a compliance assessment tool by LEED applicants. Moreover, many of the regulated pollutant levels could be higher than the allowable EPA maximums in the outside air, especially in Southern California, let alone inside a newly constructed building. As an example, the allowable maximum level of total particulates in this EPA protocol is just 20 mg/m3. We regularly see that figure exceeded in outdoor air locally, especially when the Santa Ana winds are blowing. The following footnote clearly demonstrates that this value of 20 mg/m3 is far more stringent than internationally accepted standards for particulates in indoor air. [Begin Footnote: Currently there are no defined standards in the USA for RSP levels in the indoor air of non-industrial environments. However, in 1984 a World Health Organization (WHO) working group identified that concentrations of less than 100 micrograms per cubic meter (mg/m3) of air were of limited or of no concern. Only when the values exceed 150 mg/m3 they are considered to be concentrations of concern. We suggest LEED adopts the value of 100 mg/m3, eight hour Time Weighted Average (TWA), of total RSP as a recommended standard for commercial office areas, using the estimated occupancy levels recommended by ASHRAE for design purposes in Standard 62-1999 of one person per 150 sq. ft of floor space. Airborne Particle Weights ù Pertinent Standards - ASHRAE Std 62-1999 75 mg/m3, annual average* 260 mg/m3, 24 hr. average - ACGIH TLV 10,000 mg/m3, 8 hr. TWA - OSHA PEL 5,000 mg/m3, 8 hr. TWA - NAAQS 50 mg/m3 (annual average*), 150 mg/m3 (24- hour average) - WHO (ETS Particulate)
Two edits must first be made to your CIR text. In your first footnote, the estimated OCCUPANCY LEVELS for design purposes should be 7 persons per 1000 sq. ft.of floor space (for consistency with ASHRAE 62-1999 text).áThe maximum carbon dioxide concentration differential in parts per million should read: 10,300/ventilation rate PER OCCUPANT, in cubic feet per minute (again, for consistency with ASHRAE 62-1999 text). As amended, the proposed testing protocol represents a reasonable alternative to the referenced standard and will be accepted if it is properly documented. That said, LEED practitioners must reference and satisfy the original document on which this CIR was undoubtedly based. It can be found on page 34 of the LEED for Commercial Interiors (LEED-CI) draft for the Pilot Program, titled "Alternate EQc3.2 Requirement and Submittal" (available on the USGBC Web site). Please note that this Credit Ruling's special provision applies to LEED Versions 2.0 and 2.1 (for new buildings and major renovations). Its permanence will be tested via membership vote in the next balloted version of LEED (Version 2.2, most likely).