EBOM 2009 IEQc3.3: Green Cleaning—Purchase of Sustainable Cleaning Products and Materials

Robin, I don't think the credit requirements anticipate products in the categories you mention. I would stick with the major four categories.

I agree with Tristan on this - there are all kinds of cleaning-related items that don't fit into either the 'product' or 'equipment' headings. Mops, brooms, dustpans, etc... are fine examples. I think the reality is that most EBOMEBOM is an acronym for Existing Buildings: Operations & Maintenance, one of the LEED 2009 rating sytems. purchasing categories have to be viewed as establishing a relatively narrow group of products defined by the relevant sustainability criteria. Where the criteria don't apply, the product probably shouldn't be included. Thats my take, anyway.

Dan

Not according to the credit language. What's the product?

Many of the Staples Brand "Sustainable Earth" products have an EPA Design for the Environment Logo, but are not specifically Green Seal Certified.

Sustainable Earth by Staples® Graffiti Remover #99 is one of the products I am looking at.

For what it's worth, my toxicologist sister thinks the DfE program makes a lot more sense for minimizing toxicity in cleaning product formulas than a lot of the programs that are cited in the credit language.

I'm not sure that DfE existed prior to the establishment of the current requirements, but I think it is in the proposed language for the next version of LEED. In any event, you can either try in the submittal process to present this as an alternative compliance project (with fingers crossed), or use a CIRCredit Interpretation Ruling. Used by design team members experiencing difficulties in the application of a LEED prerequisite or credit to a project. Typically, difficulties arise when specific issues are not directly addressed by LEED information/guide to get official advance clearance for the approach. The latter is recommended if your are really depending on the credit.

I would suggest working with your vendor to get them to estimate the cost associated with the volume of product used at your building. Be sure to include a narrative describing which purchases are actually products brought on-site by third-party vendors and explaining how they derived the pro-rated costs that you're using in your calculations.

Ben, GS-40 is the standard for Floor Care products for Industrial and Institutional Use. You can learn more about it at Green Seal's website at http://www.greenseal.org/GreenBusiness/Standards.aspx?vid=ViewStandardDe...

Jason, I was more confused because you are forced to select from drop downs on the online templates and GS-40 isn't an option in those drop downs. If I could just write "GS-40" that would be ok but I can't find it as an option.

Ah, I see, sorry about that. It seems you've hit on one of the many bugs in the current rounds of Credit Forms on LEED-Online. I'd suggest that you use the Feedback Form in LEED-Online to report the issue to GBCI and request that they provide you with a new version of the form that allows you to make your GS-40 claims.

I haven't seen one on biodegradable specifically, but how thick are the bags in use at the project building? There's a CIRCredit Interpretation Ruling. Used by design team members experiencing difficulties in the application of a LEED prerequisite or credit to a project. Typically, difficulties arise when specific issues are not directly addressed by LEED information/guide that is more or less viewed as standard review criteria that allows you to exclude trash can liners that have a thickness of 0.7 mil or less. That may allow you to sidestep the issue entirely.

Well, that works. Ours are 16 microns (.016 mil) thick.

If you are including those tenant spaces in your overall gross floor areaGross floor area (based on ASHRAE definition) is the sum of the floor areas of the spaces within the building, including basements, mezzanine and intermediate‐floored tiers, and penthouses wi th headroom height of 7.5 ft (2.2 meters) or greater. Measurements m ust be taken from the exterior 39 faces of exterior walls OR from the centerline of walls separating buildings, OR (for LEED CI certifying spaces) from the centerline of walls separating spaces. Excludes non‐en closed (or non‐enclosable) roofed‐over areas such as exterior covered walkways, porches, terraces or steps, roof overhangs, and similar features. Excludes air shafts, pipe trenches, and chimneys. Excludes floor area dedicated to the parking and circulation of motor vehicles. ( Note that while excluded features may not be part of the gross floor area, and therefore technically not a part of the LEED project building, they may still be required to be a part of the overall LEED project and subject to MPRs, prerequisites, and credits.) addressed by your LEED application, then those spaces must comply with any relevant credit requirements. Now, there are some caveats to that statement:
1) for IEQc3.3 - if you can reach the compliance threshold despite the fact that some of the cleaning products used in those areas do not currently comply, that is acceptable.
2) for IEQp3 and IEQc3.1 - if those restaurant tenants are unwilling to participate in the LEED process, and make up less than 10% of the gross floor area of the project building, you are allowed to exclude them from your LEED application. You'll need to provide documentation upon request to describe the size and nature of excluded spaces, and you must be consistent (meaning you can't exclude them only for certain credits where they'll hurt the overall effort).

That being said, the majority of conventional cleaners that customers are used to using now have green counterparts on the market that perform just as well. It may be worthwhile for your restaurant tenants to make a call to the Green Seal headquarters or their custodial vendor to see if they can suggest sustainable alternatives.

While microfiber rags are considered an environmentally preferable cleaning product, they are not currently recognized in the credit criteria and should be completely excluded from your calculations.

While the sample document shows an 8 month performance period, the minimum required performance period for all EBOMEBOM is an acronym for Existing Buildings: Operations & Maintenance, one of the LEED 2009 rating sytems. credits is 3 months. For any of the procurement credits, you can track for the minimum 3-month period or extend the performance period back to include the 24 months prior to the end of your performance period. If you have good purchasing history that you want to capture to boost your compliance level, you may want to consider having a longer performance period.

The product has to meet the GS-37 standard, but to do so it does not necessarily have to be certified by Green Seal. However, I'm not sure if there are other organizations certifying to Green Seal's standards. Being able to meet it isn't enough—it has to actually be certified to meet it, by someone.

HI Tristan,

thanks for the comment, the reason i asked is because my pass experience told me that, a product carrier eco labe (in this case is Green Seal) need to be audited by accredited body (might be Green Seal themselves or any accredited body by Green Seal).
there is a lot of document need to be audited (both product itself , it's manufacturing site, relevant manufactured department, testing result, etc) if a product want to get carry a eco label logo.

we have internal discussion and because of the "unclear" meaning of the sentences, we really unsure what we need to do.

I believed, logically , a product carrying an Green Seal label Only could contribute weight towards this credit, do you agree?

In practice I agree it's probably true that the only GS-37 certified products carry a Green Seal label.

In theory, a group other than Green Seal could provide a certification and label to the GS-37 standard.

Per page 444 of the LEED for Green Building Operations and Maintenance Reference Guide (2009 edition), compliant plastic trash can liners must meet the recycled-content requirements of the EPA's "Comprehensive Procurement Guidelines for Janitorial Paper and Plastic Trash Can Liners". The compliance threshold for these Guidelines is a minimum of 10% post-consumerWaste material generated by households or by commercial, industrial and institutional facilities in their role as end-users of the product, which can no longer be used for its intended purpose. This includes returns of materials from the distribution chain (source: ISO 14021). Examples of this category include construction and demolition debris, materials collected through curbside and drop-off recycling programs, broken pallets (if from a pallet refurbishing company, not a pallet-making company), discarded products (e.g., furniture, cabinetry and decking) and urban maintenance waste (e.g., leaves, grass clippings, tree trimmings, etc.). recycled content. We don't have specific product endorsement information, but most suppliers currently carry a number of products that meet these requirements.

This is a common reviewer comment. You should provide the manufacturer cut sheets for at least 20% of the products that you are claiming meet the IEQc3.3 sustainability criteria. Make sure that the documentation clearly shows that the product meets the sustainability criteria. There is a column in the Credit Form tracking table labeled "Check if documentation provided". When you resubmit, make sure that this portion of the table is completed accurately; if so, the Credit Form will automatically calculate whether you have provided documentation for the appropriate percentage of your purchases.

Is it enough to include a print out of the Green Seal website that lists the certified products?

You can use screenshots of the Green Seal website as long as you somehow indicate the products that are actually being used at the project building by highlighting, underlining, circling, etc. Also, please make sure that the product name that you include in the LEED Credit Form precisely matches the information listed on the Green Seal website so that the LEED Reviewer can easily cross-check both lists.

How does CCD-170 stack up against the existing hand cleaner requirements in the credit language? Is it contradictory or redundant with them?

If not, I would guess that it would be accepted, though I haven't seen anything
specific so I don't know for sure.

Since the credit threshold is low (30%), I might include the compliant hand sanitizers but not count on them for compliance (i.e., have some cushion).

This is an interesting issue that I had not heard about, but I did find this helpful document on the Green Seal website about the relationship between FIFRA and certification.

The representative you spoke with is partially correct. Products registered under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) cannot display a certification logo such as Green Seal's. However, they can be certified.

For some reason I can not get grasp a clear difference between Green Seal and EcoLogo (Environmental Choice). They both use science based methods to compare products ad services in the same category with green products across their life cycles.

Thanks

Green Seal and EcoLogo are very similar programs. The main difference is not the scope or method used, it is that they are run by completely different organizations. EcoLogo is based in Canada, while Green Seal is based in the U.S.

Dan, the product certifications allowed by this credit are shown in the IEQc3.3 credit language, and how to find them is discussed in more detail in our guide to IEQc3.3 products.

I don't think Greenguard is among the certifications here. I think Greenguard is more focused on product off-gassing, whereas this credit is more general sustainability standards for cleaning products.

Tristan,

Thank you, your comment is how I read the credit.
Sometimes you need double check yourself.

Susan,

We don't have tons of experience with projects attempting this credit using European green cleaning products. However, we do know of several projects in the pipeline that will be testing the validity of using sustainable, certified European products.

I'd recommend submitting with the European products, providing tons of supporting documentation verifying the sustainable characteristics of the products and demonstrating the rigorous testing required for products to earn the European eco labels. Also, submit any documentation available illustrating how these labeling systems are comparable to or more rigorous than the accepted American standards.

Please let us know how this alternative compliance path is received in the review process!

I would also add that one way to show that you are meeting the credit with European certifications is to draw on the resources of the Global Ecolabeling Network (GEN). Environmental Choice is a member, as are several European labels, and I believe that they all play by the same ISO rules.

Thanks a lot for your help. I did look into it a little and yes all these European labels comply with ISO Standards. The problem is that looking at the specifications for instance for Green Seal and European Eco-Label the testing procedures are different for the same chemicals or level of impact. So we would need an analytical chemist to figure out the comparability of these labels. Besides that the European union and countries have already established many laws and regulations with environmental minimum standards for these products. So just because the European Green Labels are not testing for something does not necessarily mean the products do not comply, because it might be required by law anyhow. If anyone came across a comparison of US and European Green Label, please let me know. I would very much appreciate any hints or links.

Generally, I scrap these credits for my projects (outside the USA) because of the difficalties (which defeats the goals of the program). What I have found is for Germany:

Schauen Sie http://www.finett.de/
Green Label Plus – Bodenbeläge

http://www.fsc-deutschland.de/db/
Zertifizierte-Holz

Beanträgung der Prüfung von eingesetzte harten Fußbödenbeläge Testing to various labeling certification standards for example Floorscore:
http://www.eurofins.de/unser-angebot/produktprufungen.aspx

Shira's first suggestion is the best way to proceed currently, until the application practicalities for international projects gets ironed out. Frau Geithner's comments are spot on and apply to a broad spectrum of required ratings in LEED and ASHRAE.

I think the system will have to slowly build up an official rating comparison data base...maybe starting with rough equivalence, for certification purposes, such as those for Filters (e.g. MERVMinimum efficiency reporting value. 13 = F7) and have it slowly sharpen up on accuracy as the experts contribute more and more.

Forcing international projects to buy American products OR discouraging projects to imploy certain credit stradigies defeats sustainability goals.

Thanks for your help. I very much agree with you and I'm hoping the USGBC is reading your suggestion. I work on a couple of European projects and I always come across Credits, where we comply with the intent, but can't proof it, because the products don't have that particular label or we would have to hire a specialist to write a 100 pages explanation to compare the testing or even maximum allowable levels. So credits in regards to low VOC products, which are easy in the US, are very very hard or impossible in Europe, because Europe measures VOC different than the US. Beside that a US label clearly favors US products, discouraging the use of regional products. This is a big burden on projects and we always have an even harder time to explain to our clients, why they should spend money for that.

How have you handled this in the prerequisite for a Green Cleaning Policy? While the prerequisite doesn't require us to purchase anything, it does require us to establish a goal for the use of products outlined in IEQc3.3 which are largely unavailable. We would really like to pursue the credits calling for plans, programs and policies associated with these products but it seems somewhat deceptive to say we plan to purchase something which we know is not available.

Diversey has a number of offices in Europe and they provide many of the companies where I am with "green" cleaning supplies and training. I would think they would be able to identify any differences between the products they sell in North America and Europe and could provide the documentation to show they are the same (or not).

A representative from a cleaning company in south america told me that although their products are certified by green seal and environmental choice in the US, it doesn't mean that they are in other countries, since the certification is valid only where it is manufactured.
The question is: a certified product in the US made under the same standards but in a different country, by the same company, is also assumed to be? If the company provides a statment showing compliance with green seal and environmental choice standards, would it be ok for LEED?

Diane, it's 30% of all purchases as a group, not 30% of all purchases within each category.

Brittany,

Homemade cleaning chemicals definitely comply with the sustainability criteria. These household products are obviously much more sustainable than manufactured cleaing products. In order to demonstrate compliance, make sure you submit supporting documentation from legitimate sources that explains the environmental benefits of using vinegar, baking soda, lemon, etc.

It would be interesting to know who is doing this. It would be worth a conversation to see how it works.

April, Brittany or Robin,

Have any of you attempted to submit documentation supporting homemade cleaning products? I am currently working on a project where our cleaning staff is interested in pursuing the credit with homemade cleaning solutions made from lemon juice, vinegar & baking soda. Have any of you heard back from reviewers on this issue, or had other related experiences? I am open to any advice, recommendations or guidance on the topic.

We have not yet tried to submit this. We decided to make it easy on ourselves and go with pre-made products. (Did you know Seventh Generation doesn't have the labeling requirements?) Right now we are using Method cleaners.

We are still interested in submitting our home-made cleaners, but have not found good research or actual data on why they are healthier. Most of what we've found seems anecdotal or expected, rather than verified, which I believe is the reason for requiring third party verification and labeling.

Hi Jana -

For multitenant buildings, up to 10% of the floor area may be exempted from almost any credit, if the area is not under management control. You can read more about this on page xxiii of the LEED Reference Guide for Green Building Operations and Maintenance. In your case, if you do not control the cleaning in more than 10% of your building, you will have to work closely with your tenants in order to achieve the relevant green cleaning credits.

For IEQp3, on the other hand, the scope of the green cleaning policy can be limited to the areas directly controlled by building management. This applies to the IEQp3 policy only, and not to the IEQc3 credits.