PROSOCO’s Director of Regulatory Affairs Dwayne Fuhlhage offers this perspective on proposed revisions to Indoor Environmental Quality requirements in the draft version of LEED 2012.
LEED 2012 Second Public Comment Period
by Dwayne Fuhlhage, CHMM; Regulatory Affairs Director
With final adoption of the International Green Construction Code (IGCC) on the horizon and the Living Building Challenge nipping at its heels, the USGBC is focused on taking green building to the next level.
The proposed revision substantially increases Indoor Environmental Quality (IEQ) requirements for coatings, sealants and adhesives by moving from proof of regulatory VOC compliance to passing emissions testing.
If you found this blog entry after the comment deadline, keep reading.
USGBC will be listening to stakeholders well past the deadline. GREENBUILD will feature a LEED 2012 lounge where attendees can talk with USGBC staff and Technical Advisory Groups (TAG) members directly. Each TAG, including the IEQ TAG, will have scheduled times to discuss specific credit areas.
The USGBC was among the first to reward use of small-chamber VOC emissions testing by providing an EQ credit path in LEED for Schools. This was PROSOCO’s primary reason for being an early adopter (in the coatings industry) with our SCS Indoor Advantage Gold certified Consolideck products.
By contrast, LEED 2009 for New Construction and Major Renovation calls out compliance with the 2004 version of SCAQMD Rule 1113 as the path to credit.
The LEED 2012 approach includes a substantive revision and realignment of the EQ credit system, including the EQ Credit for Low-Emitting Interiors as summarized:
• The only path to credit is through independent small chamber emissions testing of products utilized in building interiors. The cited method is the California Department of Public Health’s Standard Method for the Testing and Evaluation of Volatile Organic Chemical Emissions for Indoor Sources Using Environmental Chambers, Version 1.1.
• The credit rolls all interior products into one systems approach.
• The credit provides 1-3 points based on the percentage of combined interior surface area that is tested and demonstrated to be conformant (50% = 1 point, 70% = 2 points, 90% = 3 points).
• Conformance determination includes every layer in the system.
I talked with someone who helped write the draft to better understand how the layer approach works. I’ll use a school floor as an example.
Many schools contain a mixture of finished and decorative concrete and various coverings such as carpet and resilient materials. Throw in a locker room, a wood floored gymnasium and swimming pool and the materials list gets quite a bit longer.
Our theoretical school then has the following materials: carpet, linoleum, recycled rubber tiles, concrete curing compound, concrete stain, concrete hardener, concrete finish, epoxy in the locker rooms and laboratories, control joint sealants, a swimming pool coating, and high-durability wood coating and line striping for the gym.
In order to contribute to credit, every one of these materials would require testing. Any area with multiple layers where any one layer is not tested would not be eligible for credit.
To put that in perspective, a floor might have a general application of a curing compound and a hardener with carpet and adhesive applied over it. Even if every other material is tested, an adhesive that was not CDPH tested would cause that entire area to not count towards the credit thresholds.
Some non-conformant products allowed
The credit’s tiered point approach does allow for some non-conformant products. That’s a good thing from my perspective. I’ve received multiple inquiries from LEED project team members looking for miscellaneous specialty coatings for LEED for Schools projects.
Sometimes we can help; sometimes we can’t. PROSOCO has concrete flatwork pretty well covered, but the volume of anti-graffiti coatings we could sell for the occasional interior CMU specification doesn’t merit the $2,800 outlay for CDPH chamber testing.
From a general perspective, LEED for Schools has proved to be an interesting proving ground for the CDPH emissions approach. Apparently, enough project teams were having problems finding products that the USGBC Executive Committee approved an alternative approach allowing compliance with South Coast Rule 1113 to gain credit (LEED for Schools PIEACP dated July 7, 2008).
Many of the questions posted on the LEEDUser forum on this topic relate to proper regulatory categorization of coatings as opposed to finding conformant CDPH tested products. See LEEDUser Schools IEQc4.2
This leads to fundamental questions: Is the existing LEED for Schools IEQ Credit 4.2 working as intended? Is it a good model for all new construction and major renovations certifying or specifying to LEED standards?
I think conformant specialty coatings will remain difficult to find. Some manufacturers will get out ahead and have the testing done, but for small-volume niche products or formulations adjusted often based on raw materials availability or regulatory drivers, the economics may not work out.
What do you think?
I’d like to hear from readers and USGBC wants to hear from stakeholders. You have two avenues for formal comments. The traditional route is through the USGBC website at LEED Rating System Development
The new, interactive route is through the LEEDUser forums. USGBC will consider substantive comments from the forums. Here’s an overview.
In a recent member’s only webinar on the new MR credit system, USGBC staff reiterated their desire to get LEED 2012 right. There may or may not be a third comment period.
In addition to the LEED 2012 lounge, they are encouraging hallway conversations at GREENBUILD in Toronto to help gain insights in to what moves the bar without breaking it. Assuming my Passport comes in time, maybe I’ll see you there.
I can be contacted at firstname.lastname@example.org or by toll-free phone at PROSOCO’s corporate office – 800-255-4255.
About the Author: Dwayne Fuhlhage is the corporate regulatory manager for PROSOCO. Dwayne is a member of the USGBC LEED IEQ Technical Advisory Group, ASTM E60 Committee on Sustainability and the ASTM D22.05Committee on Indoor Air Quality. Dwayne serves as PROSOCO’s representative to the American Coatings Association and the Consumer Specialty Products Association where he participates in various VOC, environmental marketing and chemicals management policy committees.
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