Finding Products for LEED v4: A Guide
That complicated new Materials and Resources section of LEED v4 that we debated for years? It’s here. Are you ready?
By Paula Melton, Nadav Malin, Tristan Roberts, and Candace Pearson
If you’re accustomed to looking for products that earn LEED points by checking boxes for recycled content, regional materials, and other single attributes used in previous versions of LEED, the MR category in LEED v4 can be pretty disorienting. To get into the right mindset, it helps to step back and see the big picture—where the building industry is now and where the U.S. Green Building Council (USGBC) hopes to move it over the next few years.
As it has made particularly clear in energy and water categories, USGBC (with some nudging from its critics) is pushing LEED toward a focus on building performance. And just as USGBC wants to see LEED stand for energy-efficient building performance, it also wants to make sure that we are truly improving the environmental and health performance of our building material selections. That’s a longer-term trajectory, however, and USGBC sees the need for stepping stones, which it has carefully placed within LEED v4’s materials-related credits.
Life-cycle assessment, or, looks at the impact of a building product, a material, or a whole building over its entire life cycle. This is potentially a more sophisticated and results-oriented approach when contrasted with the pursuit of single attributes like recycled content.
Disclosure and transparency: While LCA appears in LEED v4, there isn’t enough data about our building products and materials to rely on LCA for design decisions. Other design decisions and design tools that could be driven by building product data, such as hazard avoidance, are also hobbled by a lack of data. Therefore, by encouraging disclosure of impacts and ingredients, USGBC hopes to fuel more sophisticated use of data in future design activities and in future versions of LEED. In the meantime, disclosure advocates argue that simplywill lead to cleaner products.
Higher standards: “Higher” because LEED v4’s requirements are tighter than they used to be. Biobased materials must now adhere to the Sustainable Agriculture Network standard, for example. “Standards” because LEED v4’s MR section is referencing a number of standards and programs not previously seen in LEED, such as the European REACH program, GreenScreen, and more (see below). It’s likely that some of these standards will be more widely adopted by the industry and lead to change while others won’t gain the same traction. But in referencing outside programs and creating multiple options for compliance, USGBC hopes to spur market development and, ultimately, better performance.
Now, let’s take a look at how these big-picture concepts are unfolding within the credit requirements—and how you can get on board. This article will focus on LEED Building Design & Construction (LEED BD&C), and particularly LEED for New Construction (LEED-NC), but the concepts and programs discussed here are relevant for all LEED v4 rating systems.
Building Life-Cycle Impact Reduction (MRc1)
In MRc1,, LEED v4 has combined two credits that probably never should have been separate: building and material reuse (MRc1 and MRc3 in LEED 2009). Neither credit has been very accessible, with only 3% of LEED-NC 2009 projects having earned MRc3 to date. And while reclaimed hardwoods are easy to find, it’s not clear that LEED has spurred any useful transformation in this area of building materials. Meanwhile, MRc1 has been earned by only 17% of LEED-NC 2009 projects, and preservationists have complained that it doesn’t emphasize historic value.
In LEED v4, MRc1 is more focused on changing the way we look at whole buildings—to give them more credit as resources. Projects that use appropriate rehabilitation standards on historic buildings can earn points, as can restoration projects in areas labeled as blighted. Credit can be awarded for onsite or off-site material reuse, but instead of being calculated by cost (which remains an option under the Material Sourcing credit, MRc3—see below), this credit calculates the contribution of those materials as a percentage of building surface area.
The added twist to MRc1 is an option for(LCA). The scope of the LCA option covers the complete building envelope and all structural elements, including the wall assembly from cladding to interior finishes as well as structural roofs, floors, and ceilings, but not finishes in those areas.
Where to find products
Prominent green buildings that have engaged in whole-building LCA have shown a, displacing some use of steel and concrete. A variety of engineered lumber products are becoming more available, including products with Forest Stewardship Council (FSC) content. These aren’t off-the-shelf products, though; integrating them requires lead time and collaboration among architect, engineer, and manufacturer.
Tips & field notes
On a per-product basis, materials reuse will probably remain easier to do under MRc3, and the thousands of products that offer reclaimed content will continue to vie for attention there. However, with more points available under MRc1 for buildings that manage large swaths of reuse, look for greater promotion of products and services that, for example, facilitate reuse and polishing of an existing concrete slab.
With whole-building LCA still relatively nascent, its influence on product and material selection remains unclear. However, Keith Lindemulder of Nucor Corporation, a steel supplier, thinks that the selection of six specific impact categories in LEED v4’s LCA option will tilt the playing field toward timber products. Those categories include global warming potential and eutrophication, for example, but not impact on habitat. Lindemulder also worries that USGBC has “regulated out innovation until the calculators can catch up,” contending that LCA data is mostly available for generic structural systems, which could create a higher documentation burden for project teams pursuing this credit with proprietary and possibly innovative engineered systems.
The approach of MRc2,, along with ongoing pressure from across the pond, has stimulated a flurry of activity around environmental product declarations (EPDs) in the U.S. over the last couple of years, and the pace appears to be accelerating. (See “ .”)
EPDs, called “Type III Environmental Product Declarations” by ISO, are independently verified reports based on life-cycle assessment (LCA) studies that have been conducted according to a set of common rules (product category rules, or PCRs) for each product category and then peer-reviewed. At the heart of the EPD process are “program operators”—organizations that ensure that the EPDs meet the various requirements.
UL Environment is responsible for the majority of EPDs that have been published to date. These include generic, industry-wide EPDs for the American and Canadian Wood Councils as well as product-specific EPDs for several carpet companies and other major manufacturers. Other organizations vying in the program operator role include NSF International, ASTM International, and ICC Environmental Services (ICC-ES), a subsidiary of the International Code Council, which has published a series of EPDs for Armstrong ceiling panels.
These program operators don’t do the actual LCA studies behind the EPDs. They just ensure that the studies follow the appropriate product category rules and that they’ve been translated properly into the EPD format. Because EPDs are relatively new in the U.S., the program operators have been busy sorting out the product category rules while trying to meet ISO’s stipulation to avoid creating duplicate PCRs within a product category. When program operators attempt to produce the first U.S.-based EPDs in a category, they can either create a PCR from scratch—as ICC-ES has done for pressure-treated wood—or adapt one from Europe, which is UL Environment’s preferred approach.
Option 2 of the EPD credit seeks to reward products that have been certified as preferable by programs with an LCA-based approach. No specific programs have been approved yet, so it is too soon to say what products might comply, butis a likely harbinger of things to come.
Where to find products
Currently, the most extensive list of EPDs openly available is in UL’s, which lists products with EPDs along with many other certified claims. Others can be found on the ICC-ES website and scattered around the Internet.
Subscription-based services like GreenWizard and GreenSpec (published by BuildingGreen) are providing more-user-friendly platforms that allow LEED projects to find EPDs (as well as other relevant documentation, like HPDs—see below) quickly for relevant products, rather than searching various databases. With GreenWizard, manufacturers are encouraged to upload relevant product data to its database, where subscribers have access to it and can apply various search filters to find both relevant products and products that have needed LEED documentation. GreenWizard also provides a substitute for the oft-maligned LEED Online interface. According to Brent Trenga of GreenWizard, the tool has information from more than 1,200 manufacturers, although the number providing EPDs or other transparency-related information is more on the order of 15 to 20.
GreenSpec links to manufacturer EPDs, HPDs, and other relevant information for products that meet GreenSpec criteria for listing—which currently includes products from more than 1,900 manufacturers.
Tips & field notes
Given the rapidly evolving field of EPDs in the U.S., it is perhaps not surprising that a number of organizations are introducing alternative approaches. Each of these has its own rationale, but the inconsistency with standard practice in Europe and among leading U.S. program operators is problematic.
One example of a different approach is that of the National Ready-Mixed Concrete Association (NRMCA), which has chosen to be the program operator for concrete EPDs produced under. It’s not clear that a trade association will count as an independent third-party program operator as required by ISO, so that role may be moving to a different organization before long.
Similarly, FPInnovations from Vancouver, British Columbia, is hedging the guidelines in the governing ISO documents by doing the LCA and EPD work and also serving the role of program operator. USGBC has not yet established its own rules for the level of independence it requires between these functions for the EPD to be acceptable for LEED v4, but such rulings are likely forthcoming.
It also won’t be easy to align the so-called EPDs that the Institute for Market Transformation to Sustainability (MTS) is now producing based on its own proprietary PCR, which it claims covers all products. According to the organization’s May 2012 SMaRT Environmental Product Declaration Policy & Product Criteria Rule, the existing SMaRT product certification program already meets the requirements of an EPD, so MTS decided to include an EPD Summary as part of the SMaRT Summary in order to faciliate SMaRT’s acceptance in Europe. MTS justifies its single-PCR approach based on the efficiency gained by not having to create a separate PCR for each product category. Also, unlike other EPDs, which are designed to be neutral reports on the impacts of a product, MTS touts its EPDs as only appearing on products that have been certified to the SMaRT standard. (For more on SMaRT, see “.”)
Not as far along is the emerging Standard for Type III Life-Cycle Impact Profile Declarations for Products, Services and Systems (LEO-SCS-002) from Leonardo Academy and SCS Global Services, which seeks to introduce a more comprehensive LCA method, including health and other impact categories not included in mainstream EPDs. This standard, once approved, could lead to PCRs and EPDs produced according to a structure that can’t be aligned with others on the market. It’s worth acknowledging, however, that the comparability of EPDs—even when they’re produced under the same PCR but by different entities—has yet to be proven.
Generic industry EPDs
The LEED credit includes an option for products to contribute, albeit at a lesser value, by being covered by a generic EPD for their industry, not one specific to a single company’s product. Currently, generic EPDs from UL Environment do not list which manufacturers are considered “participants,” so it would be tricky to find products that can contribute in this way, but participant lists might become available as a supplement to the EPD once enough project teams start asking for them.
Just as UL Environment is strong in the program operator market, PE International, based in Europe, is the leading provider of LCA services in support of EPDs. (PE principal consultant Steve Baer also served as chair of the LEED materials & resources technical advisory committee.)
Not only is PE International leading the field in doing the LCA studies itself, but the company also has a software platform that major manufacturers can use to produce custom EPDs for each product variation, or SKU (stock-keeping unit), according to Heather Gadonniex, who recently left UL to join PE as director of business development.
By integrating with its bill-of-materials tracking system, Gadonniex says, “There are already a host of manufacturers starting to produce EPDs at scale.” By the time LEED v4 fully replaces LEED 2009 in 2015, she predicts, there will be numerous companies with that capability. At that point, the question of how many individual EPDs are available will become meaningless.
PE is not the only LCA provider working on EPDs. There are many smaller organizations active in this arena, such as Sustainable Solutions of Royersford, Pennsylvania.
Sourcing of Raw Materials (MRc3)
is where LEED v4 carries those familiar LEED attributes like recycled content and certified wood, but there’s a twist.
Rather than focusing on attributes like recycled content as inherently good, the intent for this new credit calls into focus “environmentally, economically, and socially preferable life-cycle impacts.” In other words, USGBC wants to see, where possible, true benefits. Some requirements here are basically unchanged, like those for recycled content—but with new options and new standards to reference, there are several wrinkles. This area, which has traditionally been ripe for picking up several points through various MR credits, has also been condensed to one or two points.
• MRc3 Option 1 focuses on corporate sustainability reporting—a well established, voluntary system common among large corporations. The credit lists several frameworks to choose from, but the Global Reporting Initiative (GRI) offers the most common one. The credit requirements are vague as to whether the corporate sustainability report, or CSR, must come from the product manufacturer itself or from the raw-material supplier to the manufacturer. USGBC is likely to accept either option as long as it includes specifics on environmental impacts of raw materials extraction. In practice, for most products this will likely mean that product manufacturers have to either pass along CSRs from their supplier or begin incorporating content from those reports into their own CSRs.
• MRc3 Option 2 references FSC certification, materials reuse, and recycled content without notable changes from past versions of LEED. The biggest change is in biobased materials: the credit newly sanctions the Sustainable Agriculture Network (SAN) to certify biobased materials that may not fall under the wood or bamboo category, such as cotton, wool, straw, soy, or corn-based polymers. As an extension of the Rainforest Alliance, the SAN standard ensures that crops are responsibly sourced according to ten categories, including everything from wildlife protection to occupational health.
• Another addition is extended producer responsibility, or EPR. Better known as “product take-back,” EPR means that a manufacturer has established measures to reclaim its products at the end of their useful life and to recycle them into the same product in a “closed loop.” It has become common to see building products advertised as “recyclable,” but some manufacturers have stretched that term to the limit, using it as a label for new product lines for which established, closed-loop recycling processes haven’t made it out of research and development. LEED v4 requires compliant EPR products to be have established programs that include program literature and contact information.
According to Mikhail Davis, director of restorative enterprise for Interface, “There are no corporate social responsibility reports that actually meet the requirements.” He explained: “A lot of manufacturers think, ‘Oh we have a CSR report!’ But even if you and all your suppliers have a CSR, they probably don’t meet the requirements of that credit” because a typical CSR does not include the data on extraction operations and activities required by MRc3. Says Davis, “We've begun to have conversations with our suppliers about how we can meet the requirements.”
Projects should have more luck finding products that meet EPR criteria. More than half of the states in the U.S. have some laws requiring EPR for certain categories—often for products with concentrated toxic content like cell phones and fluorescent lamps. For building projects, carpeting is the most commonly applicable area that might amount to significant dollar value. Carpet companies have worked to establish ways to take back the large, uniform quantities of product that are discarded, with some carpet companies taking back any kind of carpet and recycling it into backing, for example.
The SAN certification could bring more rigor to an area in whichHowever, SAN isn’t ready for LEED v4 because it has its hands full targeting sugar-cane tracts and other food-focused farms in developing countries (the sole certified U.S. operation is a Hawaii coffee plantation).
Dave Bubser, the U.S. regional manger of the Rainforest Alliance, told EBN,“The current focus is on places with high biodiversity and little management standards. All of our crops fall into the food-and-beverage category, and we don’t anticipate drifting into North America.” According to Bubser, there is talk about looking to U.S. and Canadian growers to certify a wheat board, but that is still in “wait-and-see mode.” Unless we’ve overlooked a flooring product made from chocolate, there are currently no SAN-certified building products that would qualify for LEED v4—let alone products that would qualify in the U.S. for the multiplier of being sourcing locally or domestically.
Tips & field notes
SAN may simply need time to evaluate the demand and target new suppliers in order to meet LEED project teams’ needs. A working partnership could bring the SAN standard to widespread use, just as recognition under LEED did for FSC. In fact, the recently appointed executive director of SAN, Andre de Freitas, last worked as the director-general of FSC, leveraging LEED to expand its reach.
In the meantime, according to USGBC, the LEED v4 reference guide will likely state that manufacturer-declared conformance to the standard will work for now. Product manufacturers must supply a letter from all raw material suppliers with information that delineates how their practices conform to the ten categories of the SAN standard.
Competing standards could also meet demand. Already, Leonardo Academy is developing a separate standard under the same name—the Sustainable Agriculture Standard, or LEO-4000—which is still in its drafting phase but will be seeking LEED recognition once launched, according to Michael Arny, the organization’s president. This international standard will focus on “anything produced on a farm,” meaning both plant and animal products, he says. Arny envisions the standard being applicable to LEED for Existing Buildings (LEED-EBOM) purchasing credits, which include food, but there is room to accommodate building-sector manufacturers looking for raw biobased materials too. “We will just have to see what the market does,” Arny told EBN.
may comprise the two most controversial points in all of LEED v4.
The credit has no precedent in prior versions of LEED. It offers three very different options for addressing chemicals of concern, with a strong focus on inherently hazardous substances rather than on considerations like occupant exposure (the latter would be addressed by so-called risk-assessment or risk-management methodology, discussed below).
The credit offers one point for material ingredient reporting. The presence of potentially hazardous materials does not disqualify a product from being counted toward the total—a source of consternation to some critics.
But don’t underestimate the power of disclosure, says Mikhail Davis of Interface, who sees transparency as “the single most important piece of all the material credits.” Just the act of writing up an inventory of product ingredients can be transformational for manufacturers, he told EBN, because it “triggers a feedback loop that is stronger than any outside advocate can create” and also “tips people away from materials they kind-of know they shouldn’t be using.”
Option 1 allows for a “manufacturer inventory” of ingredients and introduces two new reference standards to the rating system.
• The manufacturer inventory involves publishing Chemical Abstract Service Registration Numbers (CASRN) for all ingredients in the product; some ingredients may be kept proprietary, but their hazard potential based on the GreenScreen benchmarking system must be disclosed (see below under “Optimization”). This inventory is very similar to the Health Product Declaration program.
• Theis a standardized format for disclosure by manufacturers of product contents, emissions, and health information. It has been likened to a nutrition label for building products focused on health-based issues not addressed by EPDs. Because the HPD is an open standard for reporting product ingredients and associated health hazards, it’s up to individual manufacturers to choose to use the HPD and to choose the level of detail to provide. To qualify for LEED, however, the HPD must include all ingredients down to 0.1% (1,000 ppm) and full disclosure of health hazards from ingredients, based on the GreenScreen assessment criteria. Companies can choose to leave some proprietary ingredients unnamed as long as they still report health hazards for those chemicals. An HPD is several pages long; the summary page on front indicates the level of disclosure and checkboxes for the manufacturer to indicate “Full Disclosure of Known Hazards” for every ingredient.
• Cradle to Cradle (C2C) is a multi-attribute sustainability certification that does not require manufacturers to publish product ingredients, making it an odd choice for a “disclosure” option. Products certified at least Basic under version 2 or Bronze under version 3 of C2C have had their ingredients disclosed to a third-party assessor, who vets the list for accuracy. C2C also rates products based on energy, water, carbon, waste, and indoor air quality targets. There is a chance that only the product’s material health certification level will need to be documented for this credit path, but that’s an evolving conversation at USGBC.
Where to find products
C2C-certified products are listed in anrun by the Cradle to Cradle Product Innovation Institute (C2CPII). C2CPII told EBN that it will be optimized to aid project teams searching for v4-eligible products. Products you already intend to specify will sport a prominent C2C logo if they are certified. There are roughly 100 certified building products listed, including some from major manufacturers—enough to contribute to many LEED v4 projects but not all.
Manufacturer inventories and HPDs will most likely only be available on individual manufacturers’ websites—at least at first. “We have been approached by several organizations that have expressed curiosity about serving as a central repository,” said Eden Brukman, technical director at the Health Product Declaration Collaborative. “There are a few paths that we are currently evaluating in this regard.” UL Environment has also expressed interest in providing HPDs and possibly even providing a combined EPD and HPD declaration, according to Paul Firth, product manager at UL.
Tips & field notes
Watch your Vs and 2s! The C2C options for this credit are weighted differently depending on the version of C2C the product is certified under; according to Stacy Glass of C2CPII, manufacturers have a two-year grace period before they must start using version 3 of C2C.
Few manufacturers have published HPDs so far, but HPDs could scale up quickly. They are fairly unique among the standards and programs newly referenced in LEED in that major environmentally progressive architectural firms have vocally endorsed them—creating demand on the project side that could translate to results from manufacturers. (Disclosure: BuildingGreen’s Nadav Malin sits on the HPDC board and helped develop the standard.)
Following the lead of several pioneering architectural firms, the Health Product Declaration Collaborative (HPDC), the organization that manages the “HPD Open Standard” reporting format, is encouraging a letter-writing campaign to ask manufacturers to complete HPDs. The template for the letter provided by HPDC reads, “We urge you to complete, and make publicly available, an HPD for each of your products.” Some firms, including Cannon Design, have included due dates, a step that Rand Ekman, AIA, director of sustainability, claims hasn’t been met with any “hue and cry.” He says, “I think most manufacturers are supportive of the HPD and are not too freaked out by the timeframe,” which for Cannon includes a 2015 deadline to provide HPDs or not be included in projects. “Some products that have more complex supply chains will have a harder time,” he explains. Ekman says he has encouraged those manufacturers to keep the lines of communication open.
If you’re confused by all the options, you’re not alone. USGBC has brought together a task group to help clarify the relationships among the referenced standards in this credit and how they can streamline the data so both manufacturers and project teams can find and use it more readily. USGBC will be publishing the findings of this group periodically.
Still, argues Interface’s Davis, although he’s concerned about the complexity of the credit, having multiple compliance paths is a good thing initially. “That will make it easier for manufacturers to get in the game,” he said. “If there’s no route to get in, people will start to resist it. This creates a way for manufacturers who are not as far along to be able to play in LEED v4.”
Here’s another area where LEED’s long-term goal of performance-based accountability begins to take shape. Option 2 of MRc4 offers an incentive for manufacturers to go beyond awareness and disclosure of product formulations and to begin eliminating potentially hazardous chemicals from their supply chains.
This option also references C2C, but in a different way, and introduces new reference standards to the rating system.
v3 Silver or v2 Gold certification means that a manufacturer has reached the final stages of replacing hazardous materials. The C2C methodology for chemical assessment includes a list of(products on this “black list” can’t enter the system even at the Basic level), as well as a tiered watch list (called an “ABC-X” system, with X identifying hazards that eventually must be phased out). A v3 Silver product has had an ABC-X assessment on 95% of its ingredients and contains no known or suspected carcinogens or reproductive toxicants. (The v2 system is a bit different, with a Gold product being optimized under a less stringent framework.)
• The GreenScreen List Translator, developed by the nonprofit Clean Production Action, is essentially a mega-red-list—a collection of chemicals that are considered hazardous by a number of regulatory bodies around the world. The List Translator includes both “authoritative” and “screening” lists—but to qualify for credit, products only need to come up clean when compared against the authoritative lists. This means that none of the ingredients in the product can be flagged as the equivalent of “Benchmark 1,” which in theincludes the most chemicals—including known human carcinogens, mutagens, and reproductive and developmental toxicants.
• For a full GreenScreen hazard assessment, the List Translator is just the beginning. “The List Translator is very useful as a quick-and-dirty step for identifying things that are known to be chemicals of concern, but it tells you nothing about chemicals that are not well characterized or tested,” says Lauren Heine, Ph.D., director of the GreenScreen program. With manufacturers routinely introducing new chemicals (typically in an effort to make safer formulas), all the red lists in the world can’t keep track of every potential hazard. A full assessment involves a wide-ranging review of published data about the material’s entire life cycle and the life cycles of similar chemicals. To qualify for credit, each ingredient of a product must be assessed by a licensed GreenScreen profiler and must include no Benchmark 1 chemicals throughout its life cycle.
• REACH (short for Registration, Evaluation, Authorisation and Restriction of Chemical Substances) is a European Union regulation that aims to identify the most potent hazards used in European industry. The program is gradually assessing more than 30,000 chemicals and has begun creating its; the list contained 22 chemicals as of September 2013, and European manufacturers must get special permission to use these substances. To qualify for LEED v4, products must contain no chemicals from this authorization list and none from the —which includes more than 100 chemicals still being assessed for possible inclusion on the authorization list.
Where to find products
Finding C2C-certified products is easy in theand by looking for the C2C logo—which with v3 newly includes certification level—on preferred manufacturers’ websites.
GreenScreen assessments could be trickier, especially at first. A product with an HPD or manufacturer inventory that meets the criteria for MRc4 Option 1 is probably eligible if the listed ingredients include no Benchmark 1 hazards from the GreenScreen List Translator—but be sure to verify before you spec.
A few sites may soon provide a centralized database of products and materials that have undergone a full GreenScreen assessment. According to Heine, potential locations include—a database of both chemicals and building products where manufacturers or even project teams can check their products against the List Translator by performing a “QuickScreen”—and a website proposed by MIQ Logistics, which provides supply-chain management services for manufacturers.
All companies that produce building materials for European markets should have information about their European products’ status relative to REACH. The REACH option may apply to North American products if the formulations are identical.
Tips & field notes
Not all international manufacturers will formulate their products the same way in Europe and North America, though, points out Chris Mundell, AIA, sustainable design coordinator at HKS. The firm is working on two v4 beta projects, and Mundell is finding out just how much the weight has shifted in the rating system. For one of the projects, “I’ve created a spreadsheet that has every product or material,” he told EBN. “In my spreadsheet, I’m trying to put both version 3 and version 4 attributes to see what products are going to help.” He notes that in LEED 2009, recycled content, regional content, and FSC wood could add up to six points, but “in version 4, these are all pulled together into one credit.” (The tables accompanying this article offer our own take on this spreadsheet, with fictitious products for illustrative purposes.)
The firm is looking into products that count in multiple categories, including MRc4, but that is harder now as well. “The carpet has no-PVC backing and is coming out of Europe,” he said, “which helps with the chemicals” but not with regional sourcing. The carpet complies with the REACH option but doesn’t contribute to other MR credits.
The third way
Many manufacturers of chemicals and plastics have objected to the new MR credits (see “A Ban on PVC?”), prompting USGBC to develop a third compliance path for MRc4. Details are still quite hazy.
In April 2013, “we opened up a call for volunteers to start a working group to work on implementing the details,” said Sara Cederberg, LEED manager at USGBC. “We got a good number of applicants; right now, we are really focusing on making sure that the group is balanced.” Once the final group is formed, members will have a year to figure out how projects can comply, she told EBN.
These are uncharted waters for LEED. The credit language encourages manufacturers to seek third-party verification of supply-chain optimization regarding material health. It appears to favor “risk-assessment” methods.
A hazard assessment characterizes the inherent health and environmental dangers of a material without taking exposure into account; hence it typically focuses on the most toxic substances—chemicals for which, some would argue, there is really no “safe” amount.
A risk assessment goes beyond identifying hazards and analyzes the level of risk involved in using a particular chemical in a particular way. A hazard assessment might identify a halogenated flame retardant as a persistent, bioaccumulative toxic chemical. A risk assessment would then focus on how much of the chemical could be considered safe for humans and ecosystems; this information is usually used to seek ways to limit exposure through environmental regulations.
Although these methodologies are complementary, they have in the past few years come to be seen as opposing, with consumer and environmental advocates tending to argue for more hazard screenings and outright bans of certain chemicals, and industry advocates tending to argue for more risk assessments and exposure controls. As Dick Doyle of the Vinyl Institute told EBN in discussing LEED v4, “we see a leaning toward a hazard-based approach—we feel it has to go toward risk-based and exposure.”
Option 3 of MRc4 appears to fall more toward the risk-assessment end of the spectrum, but there is currently no third-party standard to verify the credit criteria.
Putting transparency together with hazard-assessment and risk-assessment methodologies in one LEED credit is a bit like tying three roosters up in a sack. The feathers are already flying.
First, there are tensions between those who promote transparency and those who prefer the C2C methodology, which protects proprietary information while helping manufacturers optimize their products in five different areas—looking not just at toxic ingredients but also at recycling, carbon, water use, and social justice.
Although disclosure can be good, that’s not even part of the C2C continuum. “In Cradle to Cradle, while we encourage transparency, it is not required,” said Stacy Glass, executive in residence at C2CPII. “To get the supply chain information that they need, manufacturers have to enter into non-disclosure agreements.”
Glass expressed hope that that would change in the long term, but some C2C advocates don’t feel the same way. “I can say that personally and professionally I’m not a big fan of public disclosure of ingredients,” says Jay Bolus, vice president of technical operations at McDonough Braungart Design Chemistry (MBDC), original developer of the C2C standard. “I have counseled clients not to fill out the HPD,” he told EBN. “They have spent so much money on developing innovative stuff; why make it available?”
Rus Perry, FAIA, vice president at SmithGroupJJR, gave a reason why as a designer he would advise companies to disclose: “If you tell us what’s in it, you have a head start,” he said, arguing that it’s better to get any bad news about a product out on the table: “Once you've told me what it is, my assumption is that everyone else”—meaning manufacturers of comparable products—“is doing worse.” Perry predicts that as disclosure catches on, “we’ll start to get competition, and the forward-looking folks will go deep into educational mode.”
Dow Building Solutions, which has certified its Styrofoam and Thermax insulation products under C2C, isn’t a fan of material transparency and doesn’t plan to provide an HPD; it will participate in the credit through its C2C certification only. “For our insulation products, Dow considers the most important attribute to be its insulating effectiveness over the life of the product versus life-cycle impacts,” said Elena Enache-Pommer, Ph.D., a lead researcher at Dow Building Solutions. The company participates in C2C because the program “aligns with our 2015 sustainability goals, especially in the areas of renewable energy, water stewardship, and social responsibility”—not primarily to optimize its chemical formula.
Enache-Pommer is concerned that LEED is the wrong venue for making health evaluations about building products—especially because of the heavy focus on inherent hazard rather than actual exposure risk. “Dow is very committed to thorough evaluation of the health-risk potential of all of our building products and technologies,” she said, while arguing that government regulation was the best way to ensure safety. (At the same time, Dow and other large chemical companies have.) Dow will be participating, however, in the technical advisory group developing Option 3 of the material ingredient credit.
The chemical industry has long argued that it doesn’t make sense to assess hazards without also looking at exposure risk. But there’s room for both, says Lauren Heine of Clean Production Action. “Risk assessment answers the question, ‘Is it safe enough?’” she said. “Hazard assessment allows you to ask certain questions like, ‘Which one is inherently safer?’” Both approaches are necessary, argues Heine, but she adds that certain substances are so dangerous that we should simply be seeking alternatives. “Exposure controls can fail,” she said. “Why spend time and money controlling exposure to things when it may be possible to find something inherently safer?”
No one is likely to resolve these ongoing arguments definitively in the near future, but the credit has certainly started a lot of conversations, and conversations about materials are a positive thing, according to Interface’s Davis.
“One of the interesting things about the HPD is the notes section,” he says. “There you can explain why you don’t feel like this hazard flag is problematic in the way this ingredient is used, or you can explain what is the source of the recycled content—or any number of other things.” By providing this section, the HPD “is creating a platform for some dialogue,” he said. “Before, the red list was the end of the conversation as opposed to the beginning of one.”
No longer given their own credit, as has been the case in LEED 2009 and earlier, locally sourced building materials are recognized in LEED v4 as a multiplier. In MRc2, MRc3, and MRc4, products sourced within 100 miles (160 km) of the project site are valued at 200% of their cost in credit calculations.
In addition to receiving reduced emphasis under LEED v4, the reduction in radius from 500 to 100 miles is dramatic. A circle around a project with a radius of 500 miles allows 785,000 square miles from which to gather materials. Reduce that radius to 100 miles, and you haven’t divided that area by five: you’ve divided it by 25, down to 31,400 square miles.
Tips & field notes
Product manufacturers have commonly touted their contributions to LEED’s Regional Materials credit. Those manufacturers will now be pressed to offer more detailed information to show that their products come from within a tight radius, while some manufacturers, particularly those making complex assemblies of products with plastics whose origin can’t be traced, might get out of the game.
“I think concrete ends up being the material of choice to get that credit, and everything else gets ignored,” Nucor’s Keith Lindemulder told EBN. There will undoubtedly be many exceptions to that trend (especially since structural and enclosure materials can’t constitute more than 30% of eligible products in the three credits where the multiplier can be used), but it’s a fair point: local sourcing is much more stringent now, and many fewer materials will be eligible.
Another obstacle is the fact that the regional multiplier only kicks in when a product meets the basic credit requirements, such as FSC certification or recycled content. That closes a loophole that had arguably been a convenient counterpoint for LEED in the “wood wars.” When faced with the argument that, which has a strong presence in the U.S., USGBC had been able to point out that wood from any local sawmill can at least qualify for the Regional Materials credit. That’s no longer the case if that wood has to be FSC-certified to qualify for the regional multiplier.
Low-Emitting Materials (EQc2)
The product-by-product requirements forhaven’t changed significantly, but project teams may find that the new calculations take some time to learn, especially when using the “budget” path, which introduces a level of complexity not seen in this credit before.
The most substantive change to this credit from LEED 2009 centers around the definition of “interior.” The credit now accounts for virtually everything inside the waterproofing membrane—including ceiling products, cavity-fill and acoustic insulation, and even furnishings if they are part of the scope of work.
And instead of being broken up into four distinct one-point options by product type, all these categories are combined, with roughly one point allocated per two product categories. Other big changes:
• Inherently low-emitting materials, like natural stone, powder-coated metals, and unfinished wood flooring, automatically qualify for this credit. (This is consistent with a 2010 update to LEED 2009.)
• Total VOC (TVOC) testing and reporting are required from manufacturers in addition to individual VOC emissions testing and reporting.
• Wet-applied products must have both VOC content and VOC emissions testing.
• Referenced standards may look new to some LEED users. Composite wood products must now meet one of the most stringent standards for formaldehyde emissions testing—the CARB ULEF standard. And the testing protocol formerly known as California 01350 is now being referred to more accurately as CDPH Standard Method v1.1. The ANSI/BIFMA emissions testing standard for furniture has also been added, along with a variety of international standards.
The old standbys for low-emitting materials—certifications that test according to the(now the 2010 update)—may still be a way to screen products, but tests from accredited labs are also acceptable now. Ask preferred manufacturers if they have appropriate test results. If seeking products to specify for this credit, you can search on the websites of many third-party certifications that reference the 2010 update of the CDPH Standard Method, but ensure that manufacturers have had their testing done recently enough to qualify under the 2010 version of the CDPH protocol.
Tips & field notes
Although it has not always been common to report TVOC emissions, manufacturers will no doubt begin doing so once the new requirement becomes clear. “Depending on how people are marketing zero-VOC, there could be a little more reality there,” says Dwayne Fuhlhage, sustainability and environment director at coatings manufacturer Prosoco. Fuhlhage, who also serves on the EQ technical advisory group for LEED, explains that, like acetone, aren’t included in usual content reporting, but emissions do appear in TVOC numbers. “If TVOC shows up, I suppose the designer is going to take a second look and probably ask questions,” he says.
Finding wet-applied products that have both VOC content and emissions testing may be tricky at first, since many manufacturers of adhesives, sealants, and coatings haven’t often pursued emissions testing until now. These products “were the latecomers for more than one reason,” says Fuhlhage. Even “once you subtract out wall paint and primers associated with wall paint, you’ve still got hundreds of regulatory categories,” not to mention multiple formulations of similar products. The complexity and expense of testing hundreds of chemical formulations according to hundreds of different air quality standards increases the expense and complexity of the task for manufacturers—especially on top of requirements for these materials that include regional, statewide, and national laws that sometimes conflict. Fuhlhage acknowledges that “change is never easy” but anticipates that “the chaos will resolve” eventually.
It may also take time for insulation manufacturers to pursue indoor emissions testing, although some fiberglass and mineral wool makers have already sought indoor-air-quality certifications due to concerns about formaldehyde emissions.
EBN did not find any project teams that had started using the budget calculation method yet. Although the prescriptive method, requiring 90% or 100% adherence to the critera for each category, appears to be easier to document, the budget method is likely easier to achieve because there is more wiggle room if stray high-VOC products make it into the project.
Can It Be Done?
Finding LEED v4-compliant products should be easy in some areas and will be impossible in others. Project teams are understandably nervous about taking on this task, but the many MR options could be a blessing in disguise as the most accessible, transformative standards and programs rise to the top.
On the other hand, USGBC will be on guard against weaker programs or pathways short-circuiting credit intents without providing significant environmental benefit. With feedback coming in from the 107 projects currently beta-testing LEED v4, USGBC claims that it is striking the right balance of rigor and ease of documentation, and EBN has already observed manufacturers and other service providers working to provide compliant documentation—based, we hope, on greener products.
Chip Henderson, AIA, principal at Contects Consultants & Architects and a LEED v4 beta project team participant, is “totally excited about it,” as he told EBN. With more experience on residential projects, “I was always reluctant to do LEED commercial,” he says, “because I felt like I was going to be a green bookkeeper, figuring out what percentage of recycled materials or local materials—knowing just a little bit about a whole lot of information. I like the fact that we’re sort of setting that aside—diving in deeply and meaningfully” to a more focused set of issues.