ID#5460 made on
EQc5 - Indoor chemical and pollutant source control
LEED BD+C: New Construction
A CIR ruling from 1/18/2005 (EQc5) stated that " [i]f there is a janitorial / housekeeping room in the building then it must meet the criteria for this credit by providing the ventilation require...
A CIR ruling from 1/18/2005 (EQc5) stated that " [i]f there is a janitorial / housekeeping room in the building then it must meet the criteria for this credit by providing the ventilation requirements and deck-to-deck partitions," even if the building adhered to a green housekeeping policy that required only GreenSeal-compliant cleaning materials to be used in the building. In contrast, a CIR ruling from 6/24/2003 (also EQc5), stated that "The green housekeeping program is commendable but not directly applicable to credit achievement. However, because of this program, there does not appear to be chemical use in this building that would require a separate drainage system, and thus such a system will not be required." Logical consistency dictates that if no drainage system is required, then no ventilation and partition requirement would be required either. We presume that simply calling the room where green housekeeping chemicals are stored a 'janitorial closet' couldn't trigger the requirements -- we could simply rename the room and then our facts would be the same as the school in the 6/24/2003 ruling. Please clarify whether the 1/18/2005 ruling intended to overrule the 6/24/2003 ruling, or alternatively, please explain what would appear to be a logical inconsistency (no drains are required but ventilation and partitions are required?), or please revise the 1/18/2005 ruling to confirm that if we are using a green housekeeping policy (all GreenSeal-compliant), that this eliminates the requirement for ventilation/partitions/drainage to meet the credit intent. Also please respond to the question in the 1/18/2005 CIR whether, absent a requirement for partitions/ventilation/drains, the credit could be achieved simply with walkoff mats and entryway systems.
The 1/18/2005 ruling is NOT intended to overrule the 6/24/2003 ruling. Two separate issues are being addressed by these two CIRs. The first one is dealing with the need for chemical mixing areas to have segregated areas with deck to deck partitions and separate outside exhaust. The second one is to do with appropriate disposal of liquid waste in spaces where water and chemical concentrate mixing occurs. In both cases, the CIRs are consistent with the Rating System and Reference Guide requirements. Green housekeeping products still contain chemicals which need to be contained and dealt with per the credit requirements (albeit at lower levels). Therefore, even if the project only uses Green Seal compliant cleaning products, it would still need to meet the criteria of providing the ventilation requirements and deck-to-deck partitions. This is also noted in the CIR ruling dated 1/24/2005 which states that "Green housekeeping cleaners contain chemicals that need to be addressed." This credit does NOT differentiate between rooms that store Green-Seal-compliant cleaning products and those that store industry standard products. The need for drains plumbed for appropriate disposal of liquid waste is a separate issue from the ventilation requirements. As noted in CIR ruling dated 2/18/2002, sinks that dispose of chemicals, such as detergents, which are approved by the local water treatment facility, can be part of a conventional sanitary drainage system. If greywater is being directed to re-use for irrigation or uses or to a natural wastewater treatment system, then separate plumbing would be required for disposal of conventional cleaning agents. Projects should check with their local treatment facilities to confirm what the jurisdiction requirements are for chemical disposal. In response to the question raised in CIR ruling dated 1/18/2005, a project MAY be able to meet this requirement by only providing permanent walkoff mats and entryway systems if NO chemicals (of any type) are mixed and stored on-site. If any chemicals are mixed or stored on-site, then the criteria for containment, ventilation and plumbing will apply.
**Update October 1, 2013: Applicable credits have been updated.
Related Addenda (Corrections & Interpretations)