New Report Criticizes LEED on Public Health Issues

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EHHI's new report takes aim at LEED's approach to public health.

A new report from the nonprofit Environment and Human Health, Inc. (EHHI) takes aim at the U.S. Green Building Council (USGBC) and its LEED rating systems, arguing that they don’t do enough to address human health issues. While acknowledging the validity of some of EHHI's concerns and inviting collaboration, USGBC argues that the report contains fundamental misunderstandings about how LEED addresses public health.

Released in late May 2010, “LEED Certification: Where Energy Efficiency Collides With Human Health” was authored by John Wargo, Ph.D., a professor of environmental risk analysis at Yale University. Among its chief complaints is that because the Indoor Environmental Quality section in LEED for New Construction (LEED-NC) represents 15 out of 110 possible points, and because LEED’s highest, Platinum-level certification occurs at 80 points, a building could earn a Platinum certification while skipping that section. As Nancy Alderman, the president of EHHI, told, “it is possible to build a LEED building and have it not be healthy inside, and we’re saying this needs to be fixed.”

Report misunderstands LEED, says USGBC

Brendan Owens, P.E., vice president for LEED technical development at USGBC, criticized the report for “singling out the Indoor Environmental Quality section as the only place that LEED deals with public health.” Arguing that all LEED credits are built and evaluated for multiple environmental and health benefits, Owens said, “the report’s authors would have benefited from a better understanding of the philosophy that underpins the rating system.”

Pointing to the relevance of previous work by EHHI in linking diesel exhaust from school buses and childhood health, Owens noted that 17 points in the Sustainable Sites section of LEED support low-emitting, alternative transportation, walkable neighborhoods, and related issues. Thirty-five points in LEED-NC encourage energy efficiency, an issue that, as Owens noted, is linked with the worldwide public health impacts of climate change and emissions from coal-burning power plants.

Owens also objected to the idea that a LEED building could be built without attention to indoor environmental quality, saying that in practice, project teams look to earn points from across the rating system, and that some of LEED’s indoor health credits are among the most commonly attempted. One of LEED’s prerequisites calls for a minimum level of ventilation, addressing another of the report’s concerns—that tight, energy-efficient buildings can increase exposure to offgassing chemicals.

Synthetic turf earning LEED points

According to Alderman, the genesis of the report came when she saw a claim from the synthetic turf industry that use of its products can earn several LEED points. EHHI has been critical of synthetic turf and linked it to public health risks. The report devotes several pages to the connection between synthetic turf and LEED, and reprints a turf industry table showing how it can earn numerous LEED points. (The table, as with many similar efforts by building products manufacturers, is misleading, with several potential points being included that are very unlikely or impossible according to LEED’s requirements.)

Unclear line between voluntary system and code

As with other issues in the report, Owens says that its focus on the turf issue shows how EHHI misunderstands LEED. “We don’t take a regulatory mindset in the development of the LEED rating system,” he said, adding, “we encourage people to transform the way they build and operate buildings, rather than regulating for the bad actors out there.” However, the EHHI report questions whether there is a clear line between LEED as a voluntary rating system and LEED as a code, with numerous federal, state, and municipal regulations calling for implementation of LEED.

EHHI also criticizes USGBC itself, arguing that its 25-member board of directors is filled with “engineers, architects, developers, real estate executives, chemical industry officials and building product manufacturers,” with one medical doctor representing a public health perspective. “The board of directors must include more health people,” said Alderman.

Owens agrees that LEED would benefit from having more public health experts involved, but, he says “The USGBC board doesn’t make LEED.” If you look at the membership of the LEED technical advisory groups and volunteer committees, including the one devoted to indoor environmental quality, he adds, a bigger picture emerges of numerous public health experts involved in LEED.

Is LEED doing enough about toxic chemicals?

Much of the report looks at the issue of human exposure to toxic chemicals in buildings, and argues that LEED creates a “false impression of a healthy and safe building environment, even when well-recognized hazardous chemicals exist in building products.” Wargo, the author, lays most of the blame for this situation with the federal government, faulting the lack of testing of likely hazardous chemicals. At the same time, Wargo enumerates the risks of chemicals such as bisphenol-A, phthalates, and PVC, and blames USGBC for not doing more to keep these chemicals out of LEED buildings.

Here the report steps into an ongoing and emotional debate about LEED, in which it has been criticized by other environmental groups such as the Healthy Building Network for lacking leadership in addressing chemical hazards. Recently, a credit that would have encouraged reduced use of halogenated compounds such as PVC was removed from the draft version of LEED for Healthcare, and instead included in LEED’s Pilot Credit Library, where project teams are encouraged to test developing LEED credits (see “LEED for Healthcare Draft Open for Comments”).

The Indoor Environmental Quality section of LEED should be tougher, agrees Owens. “The changes that have happened over the evolution of the rating system show a pretty clear pattern of that occurring over time,” he says, “and I think you’ll see that continue in the next version of LEED.”

Tone of report questioned

Owens expressed surprise at the fairly caustic tone of the report, in which Wargo attempts to “sound the alarm” and warn of “health dangers” if LEED is more widely adopted. Owens said that USGBC was drafting an open letter in response to EHHI, and hoped to engage with the group.

Bill Walsh, executive director of the Healthy Building Network, told that in his experience, the tone of the report represents a typical response to LEED of people from the human health community. “Their first encounter with LEED is usually highly negative—they react just like this,” he said. “People just can’t believe that you get credit for using all manner of vile material in a green building. So no, they’re not really stepping back to assess the whole thing.” Walsh added that he hoped USGBC would use the report as an opportunity to build a broader constituency for developing its materials credits.

For her part, Alderman agreed that “we want to improve LEED,” and added, “we are hoping that LEED’s weight can actually make a difference with the multi-billion dollar building products industry, and the federal government.”

EHHI is a small Connecticut-based nonprofit founded in 1997. Its board of health experts and policy makers has focused over the years on issues including pressure-treated wood, vehicle exhaust and asthma, pesticides, and childhood obesity. The report is available on its website,

– Tristan Roberts

Comments (2)

1 Green Buildings should be lea posted by Cate Leger on 06/14/2010 at 12:26 pm

I would like to support EHHI's point that LEED creates a “false impression of a healthy and safe building environment, even when well-recognized hazardous chemicals exist in building products.” It seems they are pointing out the elephant in the room.

As a long time green architect, I do not believe that LEED is becoming more protective of human health but quite the opposite. With the addition of new energy efficiency standards, building siting standards, water conservation, etc., materials toxicity concerns have been watered down over the years. All of these new foci are valid and applauded. Green buildings should be more energy efficient, sited in preexisting urban areas, use water efficiently, and I agree that these strategies do tangentially reduce health impacts of the built environment. But green buildings should also minimize use of known carcinogens, suspected endocrine disruptors, etc. It is not just the health of the building's inhabitants that is at stake. Throughout their life from cradle to grave, chemicals of concern in building products effect people, plants and animals--the whole environment.

LEED standards need to be set higher. In addition, to reducing energy and water demands, a Silver, Gold or Platinum building should reflect an aggressive, precautionary approach towards protecting occupant and environmental health from exposure to chemicals of concern.

2 re: Green Buildings should be posted by Amanda Webb Nichols on 06/15/2010 at 12:35 pm

Cate - I respectfully disagree with your comments. As an architect you should understand that the onus is on you to protect the heath, safety, and welfare of building occupants - not LEED or the USGBC. Nowhere in the rating systems does it state that LEED has established the maximum requirement for design and construction. Most indefinitely LEED will expand over time and hopefully become better with age. Challenge your own design standards - not just those established by external organizations.

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June 3, 2010