Entry Type ID Date Applicable Rating System Primary Credit Inquiry (LIs) Ruling (LIs) Related Addenda/LIs Related Resources Campus Applicable Internationally Applicable Country Applicability Reference Guide (Addenda) Page (Addenda) Location (Addenda) Description of Change (Addenda) "LEED Interpretation" "1340" "2006-01-24" "New Construction, Schools - New Construction, Commercial Interiors, Core and Shell" "EQc4.1 - Low-emitting materials - adhesives and sealants" "Our Project team has noted variations between the VOC limits published in the LEED NC Version 2.1 Reference Guide and the current South Coast Air Quality Management District Rule #1168. The SCAQMD rule has been updated several times since the Reference Guide was published. To meet the requirements of this credit, which VOC limits should we be striving for, those published in the LEED NC version 2.1Reference Guide or the current SCAQMD rule #1168?" "Projects will not be penalized for following any erroneous information listed in the Reference Guide. The correct VOC limits are those in effect as of March 2000 (the release date of LEED-NC) within SCAQMD rule #1168. The latter clarification has previously been published within errata sheets for the Rating System and Reference Guide. Applicable Internationally. " "None" "None" "X" "LEED Interpretation" "1767" "2007-04-20" "New Construction, Commercial Interiors, Core and Shell, Schools - New Construction" "EQc4.1 - Low-emitting materials - adhesives and sealants" "USGBC has previously stated that if a product is inside the exterior moisture protection, it is a controlled product (it must comply with the credit requirement). Our question concerns the adhesive used to adhere to the concrete the ""stick pins"" that hold up the insulation to the underside of the concrete slab that forms the garage ceiling. Technically, this area is inside the exterior moisture protection envelope, but garage is not a regularly occupied space, and the concrete slab provides an impenetrable barrier between the stick pins/adhesive and the occupied spaces above. The garage is below and adjacent to occupied space. At the adjacent condition, the garage is separated from the occupied space either by solid wall, intervening utility spaces or a vestibule. The garage has variable active ventilation by two exhaust shafts with fans that are controlled via CO2 detectors. These shafts are located in the southwest and northwest corners of the garage. Distribution fans are also located in opposite corners, etc to move air towards the exhaust fans. Fresh air is brought into the garage via numerous openings along the full length of the east wall and a centrally located fresh air shaft. The adhesive used for this purpose has a VOC content of 420 gm/L, and we have not been able to find an acceptable substitute with a VOC content within the maximum 250 g/L assigned to the ""All Others"" category of Table 1 of the LEED-NC version 2.1 Reference Guide. (No other category of Table 1 applies.) Given that the product will be used in a non-conditioned, non-regularly occupied space; that there is no acceptable alternative for this application; the presence of the impenetrable concrete stab, and the long duration between application and occupancy of this multi-story project, we request that this application/product be exempted from the requirements of EQ 4.1." "The project is inquiring if an adhesive used within the exterior moisture protection, but above an impenetrable concrete deck in an unconditioned, non-regularly occupied space, is exempt from EQc4.1. The project may exclude the adhesive in question since 1) the garage is open to the outdoors at all times and thus is not technically an interior space and 2) the occupied areas of the building are separated from the garage by solid, impenetrable walls. Applicable Internationally. " "None" "None" "X" "LEED Interpretation" "1822" "2007-07-16" "New Construction, Commercial Interiors, Core and Shell, Schools - New Construction" "EQc4.1 - Low-emitting materials - adhesives and sealants" "Our Project, registered under NCv2.1, incorporates newer SCAQMD VOC limits based on NCv2.2 wherever those limits are more stringent than older SCAQMD and BAAQMD Rules cited for NCv2.1. Some category definitions in South Coast and Bay Area District Rules are ambiguous. When we cannot determine which VOC limit applies, we rely on manufacturer\'s claims that South Coast and Bay Area Districts allow a product\'s sale for the intended use. However, products sold only in small containers qualify for Rule exemptions allowing use despite excess VOC\'s. LEED Reference Guide does not address exemptions. EXAMPLE: NCv2.1 and NCv2.2 require the same VOC limits for Architectural Sealant Primers, allowing much higher VOC\'s for sealant primers at ""Porous"" substrates. BAAQMD and SCAQMD Rules define ""Porous Material"" similarly, but delineate no absolute threshold between ""Porous"" and ""Nonporous"". As examples, the definitions list wood, fabric, paper, cardboard, and foam, suggesting that less absorptive materials like concrete may not qualify as ""Porous"". We had not anticipated that at least two of the many approved low-VOC joint sealants on our Project might require sealant primer when applied to concrete. These primers fall between the two specified VOC limits. Ambiguous definitions force us to apply the more restrictive limit, disallowing the primers in question. In response, the sealant manufacturer contends that BAAQMD permits the proposed sealant primers, so they should be acceptable under EQc4.1. However, it is unclear whether the products qualify under the less restrictive ""Porous"" category, or if the District allows them under the small container exemption. We fear that approving products allowed under Rule exemptions may force us to demonstrate overall low-VOC performance for the entire Project using VOC Budget calculations. The method described in the Reference Guide appears to require quantity tracking for ALL products governed by the LEED Credit in jeopardy. At this point, many months into construction, such after-the-fact quantity tracking could excessively burden the dozens of contractors and subcontractors who have used VOC-compliant adhesives and sealants in hundreds of applications. As an alternative, a VOC Budget averaging emissions ONLY of the two sealants and primers in question would demonstrate that the low-VOC sealant negates the primer (based on much higher sealant application rates). Tallying emissions for a hundred more low-VOC products becomes superfluous. We do not want to impose arbitrary restrictions or require excessive documentation simply because referenced standards are unclear. Therefore, we have the following related questions: 1. What distinguishes ""Porous"" from ""Nonporous"" under BAAQMD and SCAQMD definitions for sealant primer? [We suspect that the distinguishing characteristic may be whether the primer acts simply as a bond enhancer (at slick, Nonporous Substrates), or as a sealer as well (at Porous Substrates, to prevent migrating fluids from damaging the substrate or the seal). Designation may depend as much on primer and sealant composition as on the substrate\'s absorptiveness.] 2. Is it sufficient to demonstrate that the District whose Rule is cited in Credit requirements permits the product\'s use, or does a VOC Budget calculation become necessary to offset excess VOC\'s from products allowed under BAAQMD and SCAQMD Rule exemptions. 3. If a VOC Budget calculation becomes necessary, is it sufficient to demonstrate that low emissions from a limited number of low-VOC products offset excess emissions of a few non-compliant products, without calculating emissions for EVERY applicable product on the Project. Similar issues with ambiguities, exemptions, and VOC Budget exist in NCv2.1 and NCv2.2, Credits EQc4.1 and EQc4.2." "The request poses the three following questions. The first question is a request for clarification between sealant primers classified for porous vs. non-porous use. The distinction described in your question between porous vs. non-porous sealant primers is correct. Porous sealant primers are those that act as sealant as well as bond enhancer. Since the criteria applicable to non-porous sealant primers (250 g/L) under SCAQMD is more restrictive, the project team is correct in applying the more restrictive criteria to a product that can be classified under both porous and non-porous sealant primer classifications. The second question is requiring whether exemptions under SCAQMD and BAAQMD rules can be used to show exemptions under LEED EQc4.1. These exemptions will be evaluated on a per case basis. Not all exemptions within SCAQMD Rule #1168 and BAAQMD Regulation 8 Rule 51 can be extended to LEED EQc4.1 requirements. Because this credit ruling cannot assess each exemption within SCAQMD and BAAQMD rules, this ruling assumes that the exemption rule cited in the credit interpretation request, whereby application of non-compliant products sold in small containers is acceptable, is paragraph (J) (4) of the SCAQMD rule 1168 amended January 2005. The exemption rule cited only applies to products purchased prior to September 15, 2000. The project is therefore required to go through the VOC budget calculation method to show compliance with EQc4.1 if a non-compliant product has been used. The third question is requiring whether all adhesive and sealant products are required for the VOC budget calculation. In this case, if VOC emissions from a few products can be offset through VOC budget calculation with VOC emissions from a different set of products due to the scale of application, the project is not required to include all other adhesives and sealants used in the project in the VOC budget calculation. Applicable Internationally. " "None" "None" "X" "LEED Interpretation" "1862" "2007-09-10" "New Construction, Commercial Interiors, Core and Shell, Schools - New Construction" "EQc4 - Low-emitting materials" "Our project is located in South Korea which uses VOC emission rate as the standard for low VOC products based on the laboratory test method ISO 16000-9. The low VOC Korean Standard (KS) is implemented by the Korea Air Cleaning Association. Our issue is that the KS measures VOC emission rate in mg/(m^2)hr in contrast to the Green Seal (g/l). Will the USGBC accept the VOC measurement in emission rate in lieu of g/l? If this is acceptable, please advise us on how the emission rate in mg/(m^2)hr will be converted to g/l for comparison." "The referenced standards for EQc4.1 are South Coast Air Quality Management District (SCAQMD) Rule #1168 for adhesives, sealants and sealant primers and Green Seal Standard for Commercial Adhesives GS-36 for aerosol adhesives. The VOC limits set by SCAQMD are in g/L and those set by Green Seal in percent VOCs by weight, not rate of emission. The process for testing emissions is different from how VOC content (in g/L) is determined, and therefore a direct conversion is not possible. As such, the project team has two options in order to demonstrate credit compliance. 1. Verify the VOC content of the products used with the product manufacturers, per the credit requirements. 2. If the project team wishes to use rate of emission, please reference the testing and product requirements of the California Department of Health Services Standard Practice for The Testing Of Volatile Organic Emissions From Various Sources Using Small-Scale Environmental Chambers, including 2004 Addenda. Applicable Internationally; South Korea. " "None" "None" "X" "South Korea" "LEED Interpretation" "2503" "2009-02-24" "New Construction, Schools - New Construction, Commercial Interiors, Core and Shell" "EQc4.1 - Low-emitting materials - adhesives and sealants" "LEED CI version 2.0 credit EQ4.1 requires all adhesives and sealant used on the interior of buildings not to exceed limits listed in tables 1 and 2 of the reference guide. All adhesives, sealants on our project were specified, submitted and approved by the project team to comply with these guidelines. However, during the construction process a previously approved low VOC compliant wood flooring adhesive (VOC limit 100 g/l) was accidentally substituted for a non compliant adhesive (388g/l). The non compliant adhesive was used in a very limited area of the 15 floor build out. It occurred at the installation of (20) stair treads from floor 10 to floor 11. The building has since been occupied but the project team wants to make every effort to rectify the situation and ensure the air quality of the space is not negatively impacted by this adhesive. As a solution, all treads will be removed and new treads will be re-installed using mechanical fasteners in lieu of adhesive. During the removal of the treads and the adhesive we will use a visqueen dust curtain to isolate the work area to prevent dust and adhesive entering the occupied space. In addition we will provide a negative air machine and will refrain from using any solvents to remove the adhesive. To further ensure that the air quality has not been negatively impacted we will perform an IAQ test for TVOC once the new stair tread installation has been completed. For this test we propose two test locations, one at the top of the stair on floor 11 and one at the bottom of stair on floor 10 where contaminate levels should be expected to be highest. Testing procedures will comply with EPA testing methods to demonstrate that contaminate concentration levels are not exceeded as listed in table 1 of credit EQ3.2. The IAQ test report will be provided as part of our submittal for credit EQ4.1. In addition we will submit a VOC budget calculation as outlined in Credit EQ4.1 to show that our design VOC is well below the budget VOC. In summary, we will show that the quantity of indoor air contaminants that are odorous, potentially irritating and/or harmful to the comfort and well being of the occupants have been successfully reduced and that any VOCs that would have emanated from the adhesive in question are no longer present. We feel that the outlined measures satisfy the intent of credit EQ4.1 If the above procedures and documentation are satisfied, will USGBC approve credit EQ4.1?" "The USGBC acknowledges that a mistake can be made even on a diligent LEED project. Therefore, the LEED-CI reference guide allows projects which use an adhesive or sealant that exceeds the VOC limit, to demonstrate credit compliance through a VOC budget, rather than the traditional compliance path. In addition to the VOC budget, the project should also provide documentation about the non-compliant product. Please see the LEED-CI Reference Guide for further guidance on calculating the VOC budget. The project has also proposed removing the stair tread which was adhered with the non-compliant adhesive, and reinstalled with mechanical fasteners. Since the building is already occupied, building occupants have already been exposed to the VOCs given off from the adhesive. Removing and replacing the stair treads would cause an unnecessary use of additional materials and further expose building occupants to VOCs during the removal. Projects should keep in mind the intent of the credit as well as the requirements. Applicable Internationally. " "None" "None" "X" "LEED Interpretation" "758" "2004-04-19" "New Construction, Commercial Interiors, Core and Shell, Schools - New Construction" "EQc4.1 - Low-emitting materials - adhesives and sealants" "HVAC duct work is generally installed once the building has walls and a roof, but before windows are installed. It is our project team\'s understanding that the building would not be considered to have indoor air at this time, but since this inquiry deals with the indoor air distribution system, we want to be certain that we will comply with the credit requirements. In climates with freezing temperatures over the winter months, water based duct sealants (which comply with VOC limits) are not acceptable for use due to the fact that they will crack when frozen. Oil-based sealants (which do not comply with VOC limits) are required in freezing weather until the building is enclosed and thermally controlled. It is not clear to this project team whether or not SSc4.1 would apply to sealing the duct work. When, during the construction process, does SSc4.1 start to apply, and does SSc4.1 apply to duct sealants?" "Duct sealants must be included under this credit. The VOC limit requirements of EQc4.1 for adhesives and sealants apply to all phases of construction. The LEED-NC v2.1 Reference Guide states on page 276 that this credit applies to products and installation processes that have the ability to adversely affect indoor air quality on site: and those that are exposed in interior spaces accessible by occupants (meaning all space within the weatherproofing layer of the building envelope). The VOCs from this product will offgas long enough to effect the building\'s indoor air quality. In addition, installers are immediately exposed to the product\'s emissions. Applicable Internationally. " "None" "None" "X" "LEED Interpretation" "809" "2004-06-21" "New Construction, Commercial Interiors, Core and Shell, Schools - New Construction" "EQc4.1 - Low-emitting materials - adhesives and sealants" "This is a USGBC administrative CIR to define the term indoor in the credits Intent section, thus clarifying the scope of the credit." "Essentially, if a product is inside the exterior moisture protection it is a controlled product (it must comply with the credit requirement). To elaborate: all materials that emit contaminants that have the potential to enter the indoor air will be considered as indoor sources of contaminants. Materials which have the potential to communicate their emissions to the indoor air include all indoor surfaces in contact with the indoor air including flooring; walls; ceilings; interior furnishings; suspended ceiling systems and the materials above those suspended ceilings; all ventilation system components in communication with the ventilation supply or return air; and all materials inside of wall cavities, ceiling cavities, floor cavities, or horizontal or vertical chases. As an example these materials include the caulking materials for windows, and insulation in ceilings or walls. Examples of materials that have little or no potential for communicating with the indoor air are those siding and roofing materials that are on the exterior side of the waterproofing membrane. Applicable Internationally. " "None" "None" "X"