LEED v5 Public Comment

We commend USGBC’s efforts in transforming buildings and communities to advance human and environmental wellbeing through LEED throughout the years. LEED v5 for Operations and Maintenance (O+M) will continue to improve the way existing buildings are operated and maintained to enable an environmentally and socially responsible, healthy, and prosperous environment that improves the quality of life. As the largest union of property service workers in the U.S. with more than 185,000 members, we are proud of  the role our members play in furthering these goals through their operations and maintenance duties. We are deeply committed to worker education and training, and are weighing in to ensure that we do not neglect the important role of building service workers.  This includes continuing to require green cleaning for all LEED certified buildings and to make sure that we encourage training and safety protocols for building service workers.

We strongly urge you to preserve the Green Cleaning Policy as a prerequisite in v5. To the extent that the proposed v5 Green Cleaning credit includes both Green Cleaning Policy and implementation, we urge you to move all of the description of Green Cleaning and make it a prerequisite in LEED v5 for Operations and Maintenance (O+M).  In addition, we strongly urge you to take what had been a pilot credit Green Training for Contractors, Trades, Operators and Service Workers and include it as a permanent available credit. We would further urge you to specify that Green Cleaning Training can be counted toward this credit.. We recommend that you take the possible 3 points that are made available as credit for Green cleaning in the proposed v5, and make all 3 points available for provision of Green Training for Contractors, Trades, Operators and Service Workers. Furthermore, the Credit: Equity within Operations and Maintenance Staff Option 1. Worker Safety should not be limited to specific areas in the building but cover ALL operations and maintenance procedures so there is an inclusion of ALL building service workers.

Prerequisite – It is required. One of the minimum requirements to earn LEED certification.

Credit – It is optional. Completing a credit earns the project a points/s. Projects must earn at least 40 points and fulfill all prerequisites in order to get certified.

Before and After Details:

Green Cleaning Policy

  • Before (v4.1) - Green Cleaning Policy was a prerequisite
  • LEED v5 Public Comment – Completely removed Green Cleaning Policy (not a prerequisite or credit)
  • What we are suggesting – Preserving Green Cleaning Policy as a prerequisite

Green Cleaning (Implementation)

  • Before (v4.1) - Green Cleaning was a credit. Projects can earn up to 3 points
  • LEED v5 Public Comment – No change. Stays as a credit with 3 points.
  • What we are suggesting - Make Green Cleaning a prerequisite and shift the 3 points to Green Training

Green Training

  • Before (v4.1) – Pilot credit for 1 point
  • LEED v5 Public Comment – No indication if it will be continued on as a pilot credit
  • What we are suggesting – Make Green Training a credit with 3 points. The 3 points will come from Green Cleaning

Equity within O&M: Worker Safety

  • Before (v4.1) – None
  • LEED v5 Public Comment – Only covers certain building systems (divided by area/systems in the building). Only O&M mentioned is the recycling procedures.
  • What we are suggesting – Rephrase so includes ALL building service workers

[SPECIFIC CHANGES SUGGESTED:]

[END of SPECIFIC CHANGES SUGGESTED FOR THIS SECTION]

EQ PREREQUISITE: GREEN CLEANING POLICY AND IMPLEMENTATION

Intent

To foster a healthy building interior and site, and to reduce the potential negative impact of cleaning, disinfecting and maintenance products and processes on the cleaning personnel, building occupants, and the environment.

Requirements

Operate the project using green cleaning best practices.

Option 1. Certified Cleaning Service

Clean the project with a cleaning service certified and in good standing under one of the following:

  • Green Seal’s Environmental Standard for Commercial Cleaning Services (GS-42); or
  • International Sanitary Supply Association (ISSA) Cleaning Industry Management Standard for Green Buildings (CIMS-GB); or
  • Local equivalent for projects outside the U.S.

In addition, work with the cleaning contractor to create goals and strategies for conserving energy, water, and chemicals during cleaning.

Option 2. In-House Green Cleaning Policy and Implementation

Have in place a green cleaning policy for the green cleaning procedures, materials, and services that are within the project and site management’s control, [SUGGESTED ADDITION: and implement one chosen path]. Include the following elements in the policy:

Performance Targets

  • Use of cleaning products and materials that meet the green cleaning criteria of the chosen path below.
  • Use of cleaning equipment that meets the criteria of the chosen path below.

Goals and Strategies

  • Standard operating procedures for effective cleaning of hard floors and carpets that will be consistently used, managed, and audited.
  • Provisions for addressing protection of building occupants during cleaning, including vulnerable populations.
  • Guidelines for selection and appropriate use of disinfectants and sanitizers.
  • Guidelines for safe handling and storage of cleaning chemicals used in the building, including a plan for managing hazardous spills and mishandling incidents.
  • Strategies for reducing the toxicity of the chemicals used for laundry, ware washing, and other cleaning activities.
  • Strategies for conserving energy, water, and chemicals during cleaning.
  • Strategies for promoting and improving hand hygiene.

Personnel

  • Requirements for maintenance personnel including contingency planning to manage staffing shortages under a variety of conditions to ensure that basic cleaning services are met and critical cleaning needs are addressed. Include a process to obtain occupant and custodial staff input and feedback after contingency plans are implemented.
  • Timing and frequency of training for maintenance personnel in the hazards of use, disposal, and recycling of cleaning chemicals, dispensing equipment, and packaging.

Path 1. Measuring Cleaning Performance

Perform routine inspection and monitoring of the facility’s green cleaning policy to verify that the specified strategies are being used and to identify areas in need of improvement.

            AND

Surface Testing Protocol          

Develop and implement a protocol for routinely measuring of surface contamination using an ATP meter (or equivalent device). Randomly sample all space classes prioritizing those used by multiple people throughout the day and the high-touch surfaces within those space classes. Create reports to verify testing was completed and identify cleaning performance of the surfaces tested and corrective actions as warranted.

                  OR

APPA Audit

Conduct an annual audit in accordance with APPA Leadership in Educational Facilities’ Custodial Staffing Guidelines, or a local equivalent, to determine the appearance level of the facility. The facility must score 1.5 or better.

OR

Path 2. Powered janitorial equipment

At least 40%, by cost, of all powered janitorial equipment (purchased, leased, or used by contractors) used to clean the project meets all the following criteria for emissions, vibration, noise, and user fatigue.

The equipment must have the following features:

• Safeguards, such as rollers or rubber bumpers, to avoid damage to building surfaces.

• Ergonomic design to minimize vibration, noise, and user fatigue, as reported in the user manual in accordance with ISO 5349-1 for arm vibrations, and ISO 11201 for sound pressure at operator’s ear.

• Vacuum cleaners must be certified by the Carpet and Rug Institute Seal of Approval Vacuum Program (or equivalent) and operate with a maximum sound level of 70 dBA or less in accordance with ISO 11201.

• Carpet extraction equipment, for restorative deep cleaning, must be certified by the Carpet and Rug Institute's Seal of Approval Deep Cleaning Extractors and/or Seal of Approval Deep Cleaning Systems program as applicable.

• Propane-powered floor equipment must have high-efficiency, low-emissions engines with catalytic converters and mufflers that meet the California Air Resources Board or EPA standards for the specific engine size and operate with a sound level of 90 dBA or less, in accordance with ISO 11201.

OR

Path 3. Cleaning products and materials

At least 75% (for one point, 90% for two points) of all cleaning products and materials, by cost must meet at least one of the following standards. For projects outside the U.S., any Type 1 eco-labeling program as defined by ISO 14024: 1999 or later developed by a member of the Global Ecolabelling Network is acceptable as a 56 local equivalent to the standards below. Compliance may be demonstrated from a minimum of 90 days of purchases.

Cleaning and degreasing products

• EPA Safer Choice Standard;

• Green Seal (GS-37, for general-purpose, bathroom, glass and carpet cleaners used for industrial and institutional purposes; GS-40, for industrial and institutional floor care products, GS-52/53, for specialty cleaning products)

• UL EcoLogo 2700 (UL 2792 for cleaning and degreasing compounds; UL 2759 for hard-surface cleaners; 2795, for carpet and upholstery care; UL 2777 for hard-floor care; UL 2796 for odor control additives; UL 2791 for drain or grease trap additives; UL 2798 for digestion additives for cleaning and odor control)

• Cleaning product produced on site via a cleaning device that produce only ionized water, stabilized aqueous ozone, or electrolyzed water and if it complies with one of the above standards. The device can be included regardless of when purchased. For cost, use prorated over life of the device.

Hand soaps and hand sanitizers

• EPA Safer Choice Standard.

• Green Seal (GS-41, hand cleaners and hand sanitizers for industrial and institutional hand cleaners)

• UL EcoLogo 2700 (previously UL 2784 for hand cleaners and hand soaps; UL 2783 for hand sanitizers;

• No antimicrobial agents (other than as a preservative) except where required by health codes and other regulations (e.g., food service and health care requirements);

Disinfectants

• EPA registered disinfectant product formulated with only the active ingredients identified by EPA’s Design for the Environment Logo for Antimicrobial Pesticide Products. (As of June 2021, the active

ingredient list includes: Hydrogen Peroxide, Citric Acid, L-lactic Acid, Ethanol, Isopropanol,

Peroxyacetic acid, Sodium Bisulfate, and Chitosan)

• Ultraviolet-C (UVC) disinfecting device manufactured in an EPA registered establishment. These

devices can be included regardless of when purchased, for cost, use prorated over life of the device.

• For projects outside of the U.S.: in lieu of EPA registration, the product and devices must follow local regulations for disinfectant claims.

Janitorial paper

• 30% post-consumer recycled content or recycled content levels per EPA comprehensive procurement guidelines, for janitorial paper;

• Green Seal (GS-01, for sanitary paper products);

• UL EcoLogo (UL 175, for sanitary paper products);

• Janitorial paper products derived from agricultural waste and/or tree-free fibers and certified by Roundtable for Sustainable Biomaterials (RSB) standard for Advanced Products or under ANSI/LEO4000 American National Standard for Sustainable Agriculture;

• FSC certification, for fiber procurement;

Trash can liners

• 30% post-consumer recycled content or recycled content levels per EPA comprehensive procurement guidelines, for plastic trash can liners;

• ASTM D6400 and EN 13432 standard specifications for compostable plastics

• Green Seal (GS-60 Plastic Trash Bags and Can Liners)

• 30% resin (by weight) composed of inorganic minerals

[SPECIFIC CHANGES SUGGESTED:]

  • Green Training for Contractors, Trades, Operators and Service Workers credit to be inserted after Credit: Equity within Operations and Maintenance Staff (page 9)
  • Green Training for Contractors, Trades, Operators and Service Workers credit to have possible 3 points derived from the Green Cleaning credit.
  • In terms of verbiage or language, keep most of v4.1 language for v5. Minor changes suggested highlighted in green font to keep it updated and internationally applicable..
  • See v4.1 Green Training for Contractors, Trades, Operators and Service Workers pilot credit: https://www.usgbc.org/credits/existing-buildings-interiors-existing-buildings/v41/ippc81?return=/credits/Existing%20Buildings/v4.1

[END of SPECIFIC CHANGES SUGGESTED FOR THIS SECTION]

Credit: Green Training for Contractors, Trades, Operators and Service Workers

3 points

Intent

To support and encourage the knowledge and understanding of green maintenance and operations practices by those servicing buildings daily. The benefits and goals of green building will be clearer as a result, and benefit the health and well-being of building occupants and building operators and service professionals.

Requirements

To meet the requirements of this pilot credit, project teams must use a qualifying training program. To qualify a training program, complete the application here. Qualifying programs and program requirements are listed below:

Qualifying Programs

Program

Organization

Website

GPRO

Urban Green Council

www.gpro.org

Green Janitor Health Education Program

Building Skills Partnership

www.buildingskills.org/programs/greenjanitor

Curso LEED® para contratistas

Revitaliza Consultores

http://www.revitalizaconsultores.com/cursos/curso-leed-para-contratistas

Building in Nature's Image, Inc.

Contractor & Trades Training for the Doers

https://www.ngbc.us/

Green Building Training for Cleaners

32BJ Training Fund

training.32bjfunds.org

Check LEED Credit Library for the updated the list of qualifying programs. Have a program you think might qualify? Click here to apply.

Green Building Training Program

Green Building Training Program must meet the following requirements:

  1. The program is developed and maintained by a not-for-profit organization with significant expertise and at least 5 years of experience in green building education, with input from a range of building professionals, including trades, contractors, operators, and designers.
  2. The program complies with the following criteria:
    1. Subject matter meets the purpose and scope of this credit and includes at least four hours of instruction on the basics of sustainability, green building, LEED, green job sites, and the role of the relevant building systems and building professional within the “whole building” framework of sustainability
      • For contractors, subcontractors and trades, the curricula includes a minimum of six additional hours of instruction including: differences between green and conventional materials, installation, and work practices, documentation issues that are unique to LEED; opportunities for improved building performance through the retrofitting of existing buildings; new green technologies; and the role that commissioning plays in green building.
      • For building operators, the curricula includes a minimum of 8 additional hours of instruction in introductory sustainable operations including: measuring building performance, increasing efficiency in the building envelope, plumbing, heating & cooling and lighting systems, improving indoor air quality, reducing building waste, implementing green cleaning and understanding, commissioning & energy audits.
      • For building maintenance service personnel, the curricula includes a minimum of 3 additional hours of instruction including: how to improve building efficiency through improved work practices & reporting; improving indoor air quality, reducing building waste & green cleaning practices.
    2. The targeted audience is a contractor, subcontractor, trade, or building operations and service professional that is listed in this document.
    3. The courses are taught by instructors who are qualified as subject matter experts.
    4. Materials must be objective in nature and cannot contain any content that could be interpreted as a promotion or endorsement of a certain product, service, certification/accreditation or organization. As an exception to this rule, products or organizations can be presented in the context of illustrative examples of the current concerns, issues and regulations of the topic(s) being addressed. Qualified training programs may include their company name or logo only on the first and/or last slide of any presentations.
    5. The program provides the following:

Complete the application here.

[SPECIFIC CHANGES SUGGESTED:]

  • Letter of support from a local USGBC chapter attesting to the quality of the green building content or documentation showing that it is a government accredited training program.
  • Letter of support from at least two USGBC member organizations, silver level or above, who have used the training program and can attest to its quality relative to other trainings the organization has used, or letter of support from at least two accredited postsecondary education institutions that can attest to its quality.  [END of SPECIFIC CHANGES SUGGESTED FOR THIS SECTION]
  • Evaluation report showing feedback from at least [SUGGESTED CHANGE: 175] students taught within the last 12 months
  • List of contributors to the curriculum, including their profession, industry and affiliations
  1. The program provides an assessment showing the student has achieved the course’s learning objectives OR the program is accredited or seeking accreditation under ANSI/ASTM E2659-09.
  2. The program must provide course evaluations to attendees for ongoing feedback on the quality of the course.
  3. To qualify, a green building training program must submit documentation for the above requirements along with: a) learning objectives for each training or course, b) at least 6 sample exam questions, c) a description of what is being tested, and d) the pass/fail rate for the past 12 months.

Employ building operations and direct or contracted maintenance services personnel who are certificate holders under a qualified green building training program prior to LEED submittal. The minimum percentage of certificate holders for each point threshold is as follows:

  • Option 1: 75% Operations Staff. At least 75% of building operations personnel are certificate holders. OR Option 2: 50% of Operations Staff AND 30% of Building Maintenance Service Personnel. At least 50% of Operations Staff and at least 30% of building service workers (direct or contracted employees) are certificate holders.

Qualifying Building Operations and Services Personnel

Only personnel working the following minimum hours per week in the building are qualifying building operations and service personnel who may count towards achievement of this credit:

  • For buildings under 50,000 square feet, work a minimum of 8 hours per week
  • For buildings 50,000 square feet and over, work a minimum of 20 hours per week

Building Operations Personnel:

  • Operator
  • Engineer
  • Superintendent
  • Facilities or Assistant Facilities Manager
  • Handyperson
  • Chief or Assistant Chief Engineer

Building Maintenance Services Personnel:

  • Cleaner
  • Utility Porter
  • Porter
  • Janitor
  • Custodian
  • Maintenance Worker

Process

  1. Identify the Green Building Training Program(s) OR apply to qualify Green Building Training Program(s) here (please review qualifying training program requirements above before applying).
  2. Identify whether the project is under 50,000 square feet or 50,000 feet and larger, demonstrated by construction drawings, tax records, deed or government-issued documentation.
  3. Complete this template. Identify all qualifying building operations personnel. Indicate which of those personnel are also certificate holders and identify their certificate(s). The titles of the building operations personnel listed in the template (for example, “Operator” or “Engineer” should correspond with those identified in the list of qualifying Building Operations Personnel in the credit.
  4. Provide a notarized payroll report from the building owner or management company that identifies all qualifying building operations personnel.
  5. Provide verification of any claimed training through copies of certificates or wallet cards or a report from the training body.

[SPECIFIC CHANGES SUGGESTED:]

  • Option 1. Worker Safety (1 point) under Equity within Operations and Maintenance Staff credit to cover ALL operations and maintenance procedures so there is an inclusion of ALL building service workers. It should not be limited to specific areas in the building. [END of SPECIFIC CHANGES SUGGESTED FOR THIS SECTION]

Credit: Equity within Operations and Maintenance Staff

2 points

Intent

To promote and further social equity by addressing needs and disparities among those working to operate and maintain the project by supporting skills development, personal well-being, and encouraging corporate social responsibility among involved firms.

Requirements

Option 1. Worker Safety (1 point)

Develop an operations safety plan to ensure worker safety for all workers onsite for a minimum of 15 hours a week. The plan should include recommendations, where applicable, for the use of personal protective equipment (PPE) such as foot, head, eye and face, ear, respiratory, or fall protection.

Perform safety reviews to inform the operations safety plan. Assess each of the following systems, where applicable, for access, confined space, and fall exposures. Incorporate at least one protective measure for each system into the operations safety plan and/or renovation decisions:

• Roof systems: Assess personnel access, equipment location, and fall protection needs.

• Equipment rooms and systems: Evaluate personnel access, confined spaces, and safety features such as fall protection and eye wash stations.

• Building exterior enclosure and daylighting systems: Assess access for cleaning and maintenance.

• [SPECIFIC CHANGES SUGGESTED:] Daily operations and maintenance procedures:

  • Regular inspection of various areas
  • Assessment of security measures and potential fall, trip,and slip risk areas
  • Evaluate handling and reporting measures for recyclables and hazardous waste
  • Evaluate proper handling of tools and materials needed for regular inspection and repair
  • Evaluate handling of oil spills and other potential toxic substances present in the building [END of SPECIFIC CHANGES SUGGESTED FOR THIS SECTION]

• Green infrastructure features: Assess confined space hazards and access for specific systems.

The operations safety plan must exceed established U.S. Occupational Safety and Health Administration (OSHA) standards, or local equivalent.

AND/OR

Option 2. Social Responsibility Report (1 point)

Achieve certification or develop a report addressing social responsibility aspects. At least one member of the project team (i.e. owner/, owner’s representative, or facility manager) must achieve certification.

The certification or report must be publicly accessible and awarded no more than two years prior to submittal for project certification. The certification or report must address the following issues at a minimum:

  • Fair working hours and compensation
  • Human rights
  • No child / forced labor / bonded labor
  • Health and safety procedures and training
  • Right of freedom of association
  • Non-discrimination
  • Diversity and equal opportunity
  • Discipline / harassment and grievance procedures
  • Anti-corruption and bribery

AND/OR

Option 3. Partner with Existing Community Service and Advocacy Organizations (1 point)

Collaborate with a partnering community organization to support the implementation of a strategy/strategies that improve social equity within the operations and maintenance staff. Strategies should focus on issues such as:

  • Jobs (local employment, living wages and benefits, job training)
  • Housing (affordable housing, homeownership, housing quality)
  • Education and training (mentoring, daycare, GED, literacy, ESL, computer skills, other employment skills)
  • Small business support for women or minority owned businesses (mentoring, incubation, hiring, etc.)
  • Public health and safety (traffic safety, access to open space and recreation areas, etc.)
  • Mental health (mental illness, alcoholism, veterans/ PTSD, etc.)
  • Food (fresh food access, nutrition education, community gardens, etc.)

The strategy must include at least two of the following:

  • Provision or improvement of space
  • Provision of equipment or services
  • On-going local hiring, training and benefits for workers (A program is in place and continuous)
  • Sponsorship of regular ongoing programming or events (minimum of two events per year)

Laws: LEED Requirements

Why are we supporting this?

Green Cleaning Policy

The requirement of a Green Cleaning Policy should be stated in LEED v5 as a third EQ Prerequisite. LEED v3-2009, v4 and v4.1 stated Green Cleaning Policy as a prerequisite and significantly transformed the market’s awareness and consideration for using healthier and sustainable alternatives compared to potentially hazardous chemical, biological and particulate contaminants.

  • It cannot be assumed that existing building projects applying for LEED O+M will have a green cleaning policy in place, and even if the projects do have a policy, it may not fulfill LEED requirements. It is imperative for LEED projects to have a policy because it affirms that projects understand:

  • One of the most basic sustainable practices in the industry.

  • Building projects applying for recertification may submit the same policy and may have Green Cleaning practices in place. It may be an easier prerequisite to achieve compared to other prerequisites but having this prerequisite will require projects to review what is currently in place which should be a practice given that the building industry is quickly progressing in green technology and products compared to previous years.

Green Cleaning Implementation

The implementation of the Green Cleaning Policy as a prerequisite continues to express the importance of controlling indoor sources that affect the building project’s indoor air and surface quality, which affects the quality of life of all building occupants, especially sensitive populations, and the building’s longevity and impact. This is as crucial to the intent and outcomes of EQ Prerequisite: No Smoking.

  • LEED is the world's most widely used green building rating system and is a globally recognized symbol of sustainability achievement because it shows a realistic way for the industry to be in the vanguard in the built environment rather than just complying to regular building standards. States, federal government agencies, and national organizations require and/or have green cleaning policies, usually focused on educational settings, to promote the adoption of effective green cleaning practices, leading to healthier indoor environments. There are 11 states that require public schools to use green products, and LEED certified school projects that publicly post their use of green cleaning materials. LEED should make Green Cleaning Policy and Implementation as a prerequisite to be on par for school building projects and to continue being innovative leaders for other project types.

  • LEED is a holistic system. It doesn’t simply focus on one building element, such as energy. It is why LEED has transformed the market to define a green building not only as a project that meets excellent water and energy efficiency, but also as one that uses sustainable materials and implements sustainable building O+M practices such as green cleaning. It is one of the invaluable benefits of a LEED project and compared to other requirements, cleaning is already part of a building’s O+M procedures. Transitioning to green cleaning strategies is not a capital improvement. It does not require major installation or changes to a building’s structure or procedures. At this point in time, it is very challenging to say that a building is LEED certified or green but its cleaning practices have negative impacts on cleaning personnel, building occupants, and the environment.

Green Training

The addition of training as a credit, not just as a pilot credit, ensures safety and productivity, and reduces liability in the workplace. It also engenders community engagement through discussion that, in turn, develops innovative approaches to growing a greener economy.

The impacts of climate change affect everyone. Globally and within the United States, the building sector accounts for a significant amount of all energy-related carbon dioxide emissions. Building service workers play a vital role in the fight against climate change. Through enhancing their building’s operations and maintenance, not only can they reduce carbon emissions, but they can also save their building between 5% and 20% on energy costs.

The building industry now has the policy, technology, funding, and expertise available to drastically reduce building-related carbon emissions and make a lasting impact in our communities. This requires everyone in the field to stay supported and updated through training and various forms of continuing professional education to ensure that the impacts of LEED projects are maximized and continued throughout its lifetime and not just at the beginning of the certification/recertification. If LEED and other building industry certified professionals are required continuing education hours, then it would be prudent to encourage training for operations and maintenance professionals as well. 

This credit directly and indirectly addresses all three central areas of LEED v5 - from the quality of life (equity and health) to decarbonization and conservation because it is an investment in the people that operate and maintain the building, or the frontline workers of the building industry. It strengthens retention as workers become more invested in their workplace.

Green Training supports other prerequisites and credits in v5 and ultimately leads to the 3Ps - People, Planet, and Profit. A LEED building is a “step up” from non-certified buildings. It would be challenging if the community of workers who ran the building were not given the opportunity and skills to be able to “step up” as well and fulfill the requirements of running the LEED building properly.  It is through training that LEED is able to educate contractors, trades, operators and service workers to help them create the LEED space where we all want to live and work.