There are currently two routes through which this point can be earned, either through a two-week flush-out period, or via a testing procedure. In principle the latter method is preferable, both from a technical and logistic standpoint. A performance-based testing method provides hard data on levels of indoor contaminants in the finished building, and does not rely on the assumption that the two-week flush out period will be adequate to reduce pollutant levels to acceptable concentrations. Moreover, in most commercial building projects, a flush-out period of this length will prove to be expensive and impractical. However, we have closely evaluated Section 01445 of the EPA RTP Protocol for Environmental Requirements, Baseline IAQ and Materials, and we believe that this method is also too expensive and impractical for routine use as a compliance assessment tool by LEED applicants. Moreover, many of the regulated pollutant levels could be higher than the allowable EPA maximums in the outside air, especially in Southern California, let alone inside a newly constructed building. As an example, the allowable maximum level of total particulates in this EPA protocol is just 20 mg/m3. We regularly see that figure exceeded in outdoor air locally, especially when the Santa Ana winds are blowing. The following footnote clearly demonstrates that this value of 20 mg/m3 is far more stringent than internationally accepted standards for particulates in indoor air. [Begin Footnote: Currently there are no defined standards in the USA for RSP levels in the indoor air of non-industrial environments. However, in 1984 a World Health Organization (WHO) working group identified that concentrations of less than 100 micrograms per cubic meter (mg/m3) of air were of limited or of no concern. Only when the values exceed 150 mg/m3 they are considered to be concentrations of concern. We suggest LEED adopts the value of 100 mg/m3, eight hour Time Weighted Average (TWA), of total RSP as a recommended standard for commercial office areas, using the estimated occupancy levels recommended by ASHRAE for design purposes in Standard 62-1999 of one person per 150 sq. ft of floor space. Airborne Particle Weights ù Pertinent Standards - ASHRAE Std 62-1999 75 mg/m3, annual average* 260 mg/m3, 24 hr. average - ACGIH TLV 10,000 mg/m3, 8 hr. TWA - OSHA PEL 5,000 mg/m3, 8 hr. TWA - NAAQS 50 mg/m3 (annual average*), 150 mg/m3 (24- hour average) - WHO (ETS Particulate) <100 mg/m3, of limited or no concern *Annual averaging regulates cumulative exposures over a one year period and says little about day to day exposures. It is entirely possible to exceed a 150 mg/m3 (24 hr) average on several occasions and still achieve a 50 mg/m3 annual average. Thus, for regulating day to day exposures the 150 mg/m3 (24 hr) standard is more appropriate and, in some circumstances, may be more stringent. End Footnote] The language in the EPA protocol is also contradictory. There is a requirement that the tests be conducted during working hours, presumably to ensure the building is operating under its normal working heat and pollutant load. This is a sensible requirement. But, there is also a requirement that all the pollutant limits must be achieved "prior to acceptance of the building," and that the pollutant levels do not account for contributions from office furniture, occupants, and occupant activities. It is impossible to back out these contributions when measuring these parameters, unless the intent is to measure twice, before and after occupancy. Finally, there is a requirement to measure mold and mildew, but no information in the protocol on what acceptable levels are. MATERIALS TESTING The EPA protocol has a requirement that all paints, carpets, ceiling tiles and fireproofing, all attached to a sample of their appropriate substrate (except for ceiling tiles) must be submitted to a laboratory that is specially equipped with chambers to test the emissions from the materials. The EPA protocol also requires that actual samples intended for use in the project be submitted. Moreover, any past testing that may have been conducted by the manufacturer in all good faith is no longer valid, because the samples have to be tested actually attached to their intended substrates. For instance, the carpet would have to be submitted attached to a sample of concrete used in the building; each paint (including primers) must be submitted attached to each wall, window frame, floor, beam, fitting, and so on. Following completion, the results of all this testing need to be submitted to the EPA for them to input the data into a computer model (also to be made available to the contractors) in order to calculate the maximum indoor air concentrations. This requirement is prohibitively expensive as well as completely impractical. Nor is there any way for a contractor to predict ahead of time if any of the hundreds of assemblies required for chamber testing would ôfailö when inserted into the EPA model. We believe that the intent of this credit, which is the development of a Construction IAQ Management plan, could be demonstrated to the LEED adjudicators without leaving the building empty for two weeks OR going through this impractical EPA protocol. It would be achieved by developing and providing prescriptive instructions regarding ventilation regimes during the construction and finishing process, specifying paints, adhesives and composite wood products below specified VOC contents, and using carpets, ceiling tiles and fireproofing that have already been tested for VOC emissions. These steps are given credits in the first point of Credit Three (EQ.C3.1 - Construction IAQ Management Plan During Construction) and in Credit Four (EQ.C4.1 û 4.4 - Low Emitting Materials). This would be followed by an IAQ inspection and testing procedure shortly before occupancy. PROPOSED ALTERNATIVE To overcome the problems identified above with the prescribed compliance methods, we propose an alternative option of an IAQ inspection and testing procedure prior to occupancy using nationally accepted air quality standards taking into account outdoor air levels. A comprehensive inspection document, which reflects the net IAQ results of all construction activities and materials installations in the building, could then be submitted to the LEED reviewers to claim this credit. We therefore submit for USGBC consideration the following proposed alternate procedure: EQ Credit 3.2: Construction IAQ Management Plan, After Construction û PROPOSED ALTERNATE Intent: Prevent indoor air quality problems resulting from the construction or renovation process, to sustain long term installer and occupant health and comfort. Requirements: Develop and implement an Indoor Air Quality (IAQ) Management Plan for the construction and pre-occupancy phases of the building as follows: After construction ends and prior to occupancy, conduct a minimum two-week building flushout with new filtration media at 100% outside air, OR conduct a baseline indoor air quality testing procedure consistent with current EPA protocol for Environmental Requirements, Baseline IAQ and Materials, for the Research Triangle Park Campus, Section 01445, OR conduct a baseline indoor air quality testing procedure that randomly selects sampling points for every 25,000 square feet, or for each contiguous floor area, whichever is larger, to measure the maximum concentration levels for the chemical contaminates listed below: Chemical Contaminant Maximum Concentration Reference Standard Carbon Dioxide (CO2) 530 parts per million* ASHRAE 62-1999 Formaldehyde 50 parts per billion State of Washington IAQ Standard Particulates 150 micrograms per cubic meter EPA National Ambient Air Quality Standard TVOC 500 micrograms per cubic meter State of Washington IAQ Standard 4-PCH 6.5 micrograms per cubic meter State of Washington IAQ Standard (* This measurement is required only if the building is regularly occupied during the testing. Measured differential between indoor and outdoor conditions is based on occupancy type as defined by ASHRAE 62-1999. Maximum concentration differential in parts per million = 10,300 / ventilation rate in cubic feet per minute.) For each building area where the maximum concentration limits are exceeded conduct a partial building flushout, for a maximum of two weeks, then retest the indoor air quality levels to indicate the requirements are achieved. (1 point) Submittals Provide a letter from the architect or engineer describing building flushout procedures including actual dates of building flushout. OR, Provide specifications and documentation demonstrating conformance with IAQ testing procedures and requirements as described in the referenced standard. OR, Provide a copy of the IAQ testing results indicating that the maximum chemical contaminate concentration requirements are not exceeded. Please state if this alternate method of testing will be acceptable to meet the intent of the credit.
Two edits must first be made to your CIR text. In your first footnote, the estimated OCCUPANCY LEVELS for design purposes should be 7 persons per 1000 sq. ft.of floor space (for consistency with ASHRAE 62-1999 text).áThe maximum carbon dioxide concentration differential in parts per million should read: 10,300/ventilation rate PER OCCUPANT, in cubic feet per minute (again, for consistency with ASHRAE 62-1999 text). As amended, the proposed testing protocol represents a reasonable alternative to the referenced standard and will be accepted if it is properly documented. That said, LEED practitioners must reference and satisfy the original document on which this CIR was undoubtedly based. It can be found on page 34 of the LEED for Commercial Interiors (LEED-CI) draft for the Pilot Program, titled "Alternate EQc3.2 Requirement and Submittal" (available on the USGBC Web site). Please note that this Credit Ruling's special provision applies to LEED Versions 2.0 and 2.1 (for new buildings and major renovations). Its permanence will be tested via membership vote in the next balloted version of LEED (Version 2.2, most likely).
Related Addenda (Corrections & Interpretations)