Deciphering GBCI Rulings on Product Docs for LEED Projects
LEED project managers are like intrepid explorers in search of … expiration dates? A longtime traveler discusses two big rules of thumb on project timelines, product documentation, and best practices for submittals.
Dave Hubka
November 8, 2023
Even army rations expire. Declarations and certifications have a similar shelf life, so be sure check the dates, and then explain yourself to LEED reviewers.
Photo: Win Henderson, U.S. Federal Emergency Management Agency. License: Public domain. LEEDUser guest author Dave Hubka is sustainability practice leader at architecture firm EUA and has been working with sustainable design and LEED for 20+ years.
Hunting for documents when compiling a LEED application can be quite the adventure. The task requires a seasoned LEED explorer ready to battle the elements while crossing oceans, ascending mountains, and traversing deserts.
The task requires several lifelines in the form of product search engines like Ecomedes, UL Spot, Mindful Materials, Sustainable Minds, and Green Badger (my personal favorite—this ingenious platform functions as my “ruby slippers”).
Once a declaration, action plan, or testing report is found—Eureka!
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Like the French philologist who deciphered the Egyptian hieroglyphics of the Rosetta Stone, the LEED explorer must decipher this document to know whether it meets all the LEED requirements. A great deal of time may be required to ensure all the necessary information lies within – perhaps not the 20 years it took to decipher the Rosetta Stone – but it sure feels like it some days!
With bated breath, each QC checklist item is marked off until all requirements are confirmed. This ‘holy grail’ of documents is then uploaded to LEED Online and sent off for review by Green Business Certification Inc. (GBCI).
A month later, our LEED explorer receives an email that takes precedence over all other emails of the day. They have been notified that the LEED review report is ready.
Opening a LEED review report is akin to unwinding time itself. It commands a lifetime to process within just a few moments.
While it may be written in font size 4, the sentence “certification date of the test must cover the date the product was made” feels larger than life. Perhaps we will need a French philologist once again.
Next stop: the reference guide
A succinct list of pertinent dates would sure help with our journey through technical documentation. Here are four valuable dates listed within the LEED v4.1 July 2023 reference guide.
Product declarations (Environmental / Health) must be valid at the time the product was produced.
Life-Cycle Action Plans are valid for four years.
Ingredient Action Plans are valid for five years.
VOC / Emission testing reports must be less than three years old.
Environmental Product Declarations Option 2 (Life-Cycle Action Plan) and Material Ingredients Option 2 (Ingredient Action Plan)—Action plans include a date they were issued. Products that claim this action plan must be purchased before their expiration date. (Within four years for a Life-Cycle Action Plan and within five years for an Ingredient Action Plan.)
Low-Emitting Materials—Emission testing reports include a certification period that is most typically three years in length. Products that claim this report must be purchased within this certification period.
Now it gets fun!
Looking at past LEED review reports, GBCI messages can feel as tangled as a pit of asps due to the complexity of product testing, manufacturing, and shipping as they relate to project phases and timelines.
GBCI may allow a product declaration to be valid if “selection” occurred prior to the expiration date.
GBCI seems to allow claims up to five years old. Teams applying the guidance from the November 2020 addenda would probably be held to the three-year requirement. The time period is taken from when the product was selectedby the design team.
GBCI has explained to me that reviewers are checking that test report dates for Low-Emitting Materials overlap with the estimated manufacturing date of the product.
More generally, GBCI has said that reviewers should accept a certificate with a certification period that overlaps the project’s estimated design/specification phase OR up to roughly a year before construction.
The one-year rule of thumb + four examples
Based on this key, it would appear that we may have success when specifying products with current declarations, action plans, and testing reports. This is typically within the 12 months prior to the start of construction.
Here are four examples.
Declaration has a date of issue September 7, 2020 and a period of validity of five years
As long as this product is purchased by the contractor prior to Sept 7, 2025, it can still contribute to Environmental Product Declarations.
As long as September 7, 2025, is after the start of construction, then the declaration should contribute.
If construction starts after September 7, 2025, I believe GBCI would not allow the declaration to contribute.
Life-Cycle Action Plan has a creation date of September 7, 2020
GBCI appears to be lenient with product selection dates as long as they are assumed to be within the 12-month window.
As long as the design team specifies the product prior to September 7, 2024, it can still contribute to Environmental Product Declarations.
Greenguard Gold lists a certification period of September 7, 2017 to August 9, 2023
The product would need to be specified within that time period.
The VOC emission test date is September 7, 2020
The product would need to be selected before September 7, 2023 (or maybe September 7, 2025?) for this product to contribute to Low-Emitting Materials.
Second rule of thumb: explain yourself to GBCI!
Checking certifications, action plans, and testing dates during the specification phase is not enough: when you submit your application, make things easy on your team and your GBCI reviewer by providing an explanatory note within the LEED application.
The adventure of reviewing LEED documents can be daunting, even for the most seasoned LEED explorer. Understand that you are not alone and that all our missions—manufacturers, clients, consultants, designers, contractors, and GBCI reviewers—are aligned. Together we are venturing to transform how we design and construct our buildings. It takes all of us to spin this blue marble more sustainably.
Product manufacturers are at the forefront. Maintaining product certifications is key to ensuring that the built environment is a more environmentally and socially responsible, healthy, and prosperous port of call.
“So we beat on, boats against the current, borne back ceaselessly.”
Hi Dave - Yep, I too read 8.8 in the CDPH standard and was absolutely astounded to see the decision of retesting timelines delegated to certifcation bodies - Wild! I appreciate the collaboration and agree that USGBC/GBCI have great insight and expertise to offer in this arena but it still seems very strange. Regardless, I have gotten response from GBCI on my inquiries and they don't appear to be wavering. They point at 8.8 as their ticket to make the rules as they see fit. I'm still pushing but I'm not terribly optimistic. C'mon v5!
Your post got me thinking...why 3 years or 5 years for a re-test of VOC???
So I read the CDPH standard - for the very first time - and in Section 8.8 Retesting it states:
"certification/verification organization shall establish the schedule for routine laboratory retesting" AND "the minimum frequency is dictated by building rating systems that award credits for using products with low VOC emissions" AND "changes in formulation, manufacturing process, or supplier that can alter the VOC emissions characteristics of a product shall trigger additional retesting to maintain the validity of a claim".
Based on this, the retesting requirement is entirely based upon what USGBC determines it to be. (v4.1 is not a balloted rating system hence voting by members is not required when issuing the next edition of 4.1 - while not allowing teams to use previous editions of v4.1)
In response to Allison's comment, you are spot on. Long length projects can really struggle and may even fall apart if product testing / declarations are not maintained. A couple of years ago the guidance offered by GBCI: "compliant when specified" will count toward credit compliance...but now they are enforcing "compliant when purchased"....based on recent GBCI review comments.
Hooo boy, this one hits me right in the feels! I'm mad that we have to have this conversation (we have a planet to save, y'all!), sad that I seem to lose the battle with GBCI more often than not, and glad to be in good company :) I have been trying to get to the bottom of the (arbitrary?) decision to put the 3 (or maybe 5?) year deadline on the emissions testing documents for some time now. The CDPH standard does not state a re-testing timeline requirement, so where does GBCI get 3 (or maybe 5?) years from? I understand the need for retesting when product formulations or manufacturering processes change, and that scenario is covered by the standard. But what about when the manufacturer has been cranking out the same product formulation, using the same process for 30 years because they know they have the winning recipe? Why would or should they retest? When pressed for an answer from GBCI, I've been greeted by resounding silence. Good news is I'm tenacious as heck and still pushing that boulder up the mountain - I will report if/when I ever get a reasonable answer!
I laughed, I cried, I commiserated. Thanks Dave for putting it all into these well-writen words! I agree, "when in doubt, explain yourself to GBCI" is the best advice one could give.
I wonder what GBCI is going to do with one of my projects that legitimately has a 5 year construction period. We're still in the build phase now, but add this to the list of things I'm now going to be worrying about...
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