Don’t allow the use of products that merely claim to be “low VOC.” Everyone specifying and purchasing products must actually find the products’ VOC content in grams per liter (g/L), which is usually found on the product’s technical data sheet or material safety data sheet, and compare that number with VOC limits listed for different uses determined by the South Coast Air Quality Management District (SCAQMD) Rule #1113 and Green Seal GS-11 and GS-03.
Only 20% of product cut sheets selected at random need to be uploaded to LEED Online to document this credit although it is best to keep all product cut sheets on file in case the credit is audited.
Yes. If you have just one non-compliant product, then you can balance it out with just one really good, low-VOC product, as long as all your other products meet the requirement. For example, if you have two gallons of non-compliant paint that is 100 g/L over its required threshold, then you can balance it out with another product you’re using. You would have to be using two gallons that are 100g/L under the required threshold, or four gallons that are 50 g/L under, or 20 gallons that are 10 g/L under, etc.
GBCI has issued a clarification that the actual barrier does not need to comply with this credit. Any applied products that are 'touched by the indoor air' would need to be considered for IEQc4.2, but if they fall outside of this they can be excluded.
Check out the Resources tab for the Green Seal Standard and SCAQMD Rules for more information. These documents can be helpful in determining where and how your product should be categorized to determine corresponding VOC thresholds.
Graphic Arts (Sign) Coating is found in SCAQMD 1113, Table 1 - VOC Limits, with 500 g/l as the current limit.
Projects should comply with the editions in the reference guide or applicable LEED addenda issued before the project's registration date.
Handheld aerosol spray paints are not covered by Green Seal GS-11 or SCAQMD Rule 1113, the relevant standards under this credit. 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 under LEED-NC v2.2 was issued that excluded spray paints from this credit, and there have been no rulings reversing this for LEED 2009 projects, although there is not officially a ruling one way or another that applies to LEED 2009. See LEED InterpretationLEED Interpretations are official answers to technical inquiries about implementing LEED on a project. They help people understand how their projects can meet LEED requirements and provide clarity on existing options. LEED Interpretations are to be used by any project certifying under an applicable rating system. All project teams are required to adhere to all LEED Interpretations posted before their registration date. This also applies to other addenda. Adherence to rulings posted after a project registers is optional, but strongly encouraged. LEED Interpretations are published in a searchable database at usgbc.org. #2486 2/10/2009.
As stated in the credit language, architectural paints and coatings applied to interior walls and ceilings are subject to GS-11.
If a project registered after the 4/14/10 addendum, then primers must use the 50 g/L and 150 g/L VOC limits for flat and non-flat paints, respectively. The only exception would be when it can be demonstrated, based on the purpose of the primer and supporting manufacturer data, that the product meets the definition of specialty primers per SCAQMD Rule 1113.
Like the similar credit, IEQc4.1: Low-Emitting Materials: Adhesives and Sealants, it shouldn’t cost you anything extra to earn this credit—it will just take some work. Your first priority should be to specify only paints and coatings that comply with the credit’s VOC limits, and enforce those specifications on the jobsite. Research low-VOC paints and coatings before construction begins and provide lists of acceptable materials to contractors to help ensure that the right products are used.
Major manufacturers offer paints and coatings that are just as durable and perform just as well as their higher-VOC counterparts. Performance of low-VOC products has sometimes been an issue in the past, but the market has largely moved beyond this point.
Low-VOC acrylic paint is readily available. While it may be more difficult, it is not impossible to find low-VOC oil-based and high-gloss paints. Darker shades of paints also tend to have higher VOC levels. Rust proofing coatings also tend to have higher VOC content, but several name brand providers have low-VOC alternatives.
Low-VOC paint like this 0-VOC Acrylic from Sherwin-Williams does not have to sacrifice performance or cost. Photo – Sherwin-Williams
Making sure that VOC limits are observed demands proactive communication between the designer, contractor, and all subcontractors who do work inside the building. Subcontractors have to be educated about the requirements, and their contracts should require that they document their compliance.
Unlike some LEED credits where only a certain percentage of the materials have to comply, this credit is all-or-nothing—all paints and coatings must comply. If a non-compliant paint or coating gets used by mistake, or if you need to bend the VOC limits to meet the requirements of a warranty or fire code, you can still earn the credit following the “VOC budget process.” You’ll simply have to do some calculations to show that your extra use of VOCsA volatile organic compounds (VOCs) is a carbon compound that vaporizes (becomes a gas) at normal room temperatures. VOCs contribute to air pollution directly and through atmospheric photochemical reactions (excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides and carbonates, and ammonium carbonate) to produce secondary air pollutants, principally ozone and peroxyacetyl nitrate. was offset by very low use of VOCs elsewhere. You have to meet the budget for paints and coatings separately from adhesives and sealants (for IEQc4.1), though—you’re not allowed to create a combined VOC budget covering multiple IEQc4 credits.
Earning this credit is a key part of a construction indoor-air-quality management plan, and will help you earn another LEED point via IEQc3.1: Construction Indoor Air Quality Management Plan—During Construction.
Earning this credit can also help teams pass air quality tests needed to earn IEQc3.2: Construction Indoor Air Quality Management Plan—Before Occupancy.
Using low-VOC paints and coatings is not only beneficial to occupants, but can improve air quality and the health of construction workers who are constantly exposed to construction pollution.
First check the allowable VOC levels for each product type you are using – see the summary of VOC limits in the Low-Emitting Material Limits document (see Documentation Toolkit) and then make sure the products specified do not exceed those limits.
Select paint colors and sheen levels.
Many "zero-VOC" paints contain colorants with as much as 150 g/L of VOCs. Natura from Benjamin Moore uses zero-VOC colorants. Photo – Benjamin MooreIt’s easier to find low-VOC paints if you choose lighter paint colors. Darker colors tend to use more pigment and binders, where VOCs are concentrated. When compiling VOC numbers for paints, make sure that the numbers you get include pigment, not just the base paint.
Light colors also make spaces brighter, reducing electric lighting needs.
Major manufacturers offer paints and coatings that are just as durable and perform just as well as their higher-VOC counterparts. Poor performance of low-VOC paints and coatings has been an issue in the past, but is no longer a problem for any but the most demanding applications. Interior wall and ceiling paints (in flat and semi-gloss sheens) are readily available. Some specialty coatings such as rust-proofing finishes can be more challenging.
Make sure low-emitting requirements have been integrated in construction specifications. Products must be at or below the recommended VOC limits. VOC levels can be found on a product’s MSDS or technical data sheet and are measured in grams per liter (g/L).
Guidance on incorporating LEED specifications into construction documents, along with samples, is available from MasterSpec and from the Whole Building Design Guide (see Resources).
Identifying VOC requirements directly on the drawings as well as in the specs is a good way to remind the contractor and subcontractors of the requirements, but be careful to make sure the information is consistent between the drawings and the specs.
It is best to require subcontractors to supply all LEED-required VOC information on the products they purchase at the time they are submitting products for approval. This way contractors do not wait until the end of construction to supply information, and you have the opportunity to review products for LEED compliance before products are purchased.
Specify compliant products by brand name whenever possible. It is best to distribute a list of acceptable products and the VOC limit chart from the LEED rating system at the contractor and subcontractor orientation meetings.
Low-emitting products can be part of a more comprehensive IAQ management plan, as required for IEQc3.1: Construction Indoor Air Quality Plan—During Construction. A comprehensive IAQ plan covers all adhesives, sealants, paint, coatings, composite materials, and overall construction best practices protecting air quality.
Achieving this credit can also help achieve IEQc3.2: Construction IAQ Management Plan—Before Occupancy, if your project pursues the air-testing option for this credit. Using low-VOC products improves your odds of passing the air quality tests.
Only paints and coatings installed within the weather barrier need to comply with this credit. If paints and coatings are part of the weather barrier, err on the side of caution and use low VOC paints and coatings.
Products assembled off-site or factory-finished are exempt from this credit, because it is assumed that VOCs have off gassed before arriving at the site.
Using low-emitting paints and coatings should be a no-added-cost measure.
Some contractors might charge a premium for implementing and documenting this credit but, in general, costs should be minor or nonexistent as more firms start incorporating these as standard best practices.
Hiring construction teams with LEED experience is helpful, as is reviewing LEED requirements and responsibilities with the contractor during the bidding process. Construction teams without LEED experience can be successful with this credit, but will require more training and a closer eye on quality control to make sure compliant materials are used and that items are documented correctly.
Implementing an IAQ plan and use of low-emitting materials demands accountability. It is best if subcontractors are contractually required to implement their parts of the IAQ plan.
The general contractor (GC) should be oriented to all LEED-related issues, including IAQ management, low-emitting materials, environmental material tracking tools, construction waste management, and so on. A list of acceptable products for each use type, and the list of VOC limits, should be provided to aid subcontractors in product selection.
The GC should hold orientation meetings with the subcontractors to review the LEED responsibilities related specifically to their trades. This exercise helps to build trust and is crucial for obtaining buy-in from all participants in the process.
Coordination and communication among the GC, subcontractors and design team early in the process can minimize scheduling delays and pushback from subcontractors.
Give the GC and subcontractors the following tools to help them track materials data for all MR and IEQ credits. (See the Documentation Toolkit for access.)
Research compliant, low-emitting products before construction begins. If product decisions are made after construction begins, with less time to carefully review data sheets, there is a much greater risk of using a non-compliant product.
When researching low-emitting products, double-check that the manufacturer’s information does not use misleading language. A common example is a product cut sheet that uses the term “low-emitting” without providing a specific VOC g/L value. Many cut sheets give a maximum value of, for example, VOC < 100g/L. That’s fine as long as 100 g/L meets the criteria for that product—just enter 100 g/L VOC amount for LEED documentation.
It is common for an MSDS to list the chemical contents of a product without giving an overall VOC g/L number. You’ll need to contact the manufacturer or check cut sheets to get the total VOC number. (See the Documentation Toolkit for a sample cut sheet.)
Obtain VOC levels, in writing, from the manufacturer, for the actual products used on the project—don’t rely on VOC quotes given over the phone.
The VOC value on an MSDS can be unreliable when several different products are listed on one sheet. Get clarification from the manufacturer on the actual VOC content of the product you are using.
The GC should be aware of any warranty issues that may exist if alternative paints or coatings are used. For example, a flooring company’s warranty may require a specific coating that does not meet the VOC requirements. To keep the warranty valid, use the coating specified and use the VOC budget method to show a weighted average VOC compliance (see below).
If noncompliant materials are used onsite accidentally, or due to a warranty or other issue, you can use the VOC budget method. This method compares the total amount of VOCs (in grams per liter) used in the design case to the total amount of VOCs that would have been used if every product exactly met LEED VOC allowances. The calculation must be determined for adhesives and sealants separately from paints and coatings. For example, it won’t necessarily help your case to use low-VOC paints but also some high-VOC sealants. (See the compliance example below for paints and coatings.)
Using the VOC budget method is usually successful, but can be time-consuming to document.
Throughout construction, the GC should collect material safety data sheets (MSDS) from subcontractors and completed VOC tracking forms for all products used onsite associated with this credit.
Assign someone to be responsible for inputting the subcontractors’ tracking forms into the master spreadsheet. A LEED consultant or an administrative assistant in the GC’s office may be the best choice for this role.
Review subcontractor product suggestions ahead of time to avoid the purchase of inappropriate materials and eliminate the need for costly change orders.
Streamline documentation and research by keeping a master spreadsheet of all the items being tracked for each material across MR and IEQ credits. For example, you may need to ask the millworker for regional information for MRc5, certified wood information for MRc7, and information about coatings installed on-site for IEQc4.1. If one spreadsheet collects all the data, it can streamline your documentation, associated research, and help with quality control. (See the Materials Calculator in the Documentation Toolkit.)
A master spreadsheet helps ease information collection for subcontractors, giving them a road map of exactly what types of information to collect for each product.
The GC functions as the overall quality assurance provider for this credit. Responsibilities include conducting weekly reviews of subcontractor product safety data sheets and tracking forms, as well as spot checks in dumpsters to determine which products are actually being used.
Post signs at the construction site that reminds subcontractors to follow LEED requirements for low-VOC products. (See Documentation Toolkit for sample signs.)
Schedule the application of paints and coatings so that off-gassing does not contaminate other absorptive materials. This is required if projects are attempting IEQc3.1: Construction Indoor Air Quality Plan—During Construction. For example, do not store or install acoustic ceiling tile before flooring and wall paints are put down, because ceiling tiles will absorb the off-gassing of paint and contaminate the air over a longer time period.
It is usually a good idea to do a “mini air flush” (if your project is not attempting IEQc3.2) before occupancy to help remove any lingering VOCs from the construction process. This can be as simple as putting industrial sized fans in the window and pumping in fresh air overnight or running the HVAC exhaust on high for a few days. (See IEQc3.2: Construction Indoor Air Quality Plan—Before Occupancy if the team wants to do a full flush-out for an additional LEED point.)
Transfer all the data collected in the master material tracking spreadsheet to the LEED Online form and upload the product cut sheets.
Keep a list of compliant, low-emitting paints and coatings used on the project so that O&M staff can use these products for future renovations.
Excerpted from LEED 2009 for New Construction and Major Renovations
To reduce the quantity of indoor air contaminants that are odorous, irritating and/or harmful to the comfort and well-being of installers and occupants.
Paints and coatings used on the interior of the building (i.e., inside of the weatherproofing system and applied onsite) must comply with the following criteria as applicable to the project scope1:
You may use the LEED v4 version of this credit on v2009 projects. For more information check out this article.
Specify low-VOC paints and coatings in construction documents. Ensure that VOC limits are clearly stated in each section of the specifications where paints and coatings are addressed. Track the VOC content of all interior paints and coatings during construction.
Green Seal is an independent, nonprofit organization that strives to achieve a healthier and cleaner environment by identifying and promoting products and services that cause less toxic pollution and waste, conserve resources and habitats, and minimize global warming and ozone depletion. GS–36 sets VOC limits for commercial adhesives.
SCAQMD is the air pollution control agency for all of Orange County and the urban portions of Los Angeles, Riverside and San Bernardino counties, the smoggiest region of the U.S. The organization is committed to protecting the health of residents, while remaining sensitive to businesses.
Support on incorporating LEED requirements into specifications.
Green Seal is an independent, nonprofit organization that strives to achieve a healthier and cleaner environment by identifying and promoting products and services that cause less toxic pollution and waste, conserve resources and habitats, and minimize global warming and ozone depletion. This document outlines criteria for anti-corrosive paints and can be helpful in defining application type for products.
SCAQMD is the air pollution control agency for all of Orange County and the urban portions of Los Angeles, Riverside and San Bernardino counties, the smoggiest region of the U.S. The organization is committed to protecting the health of residents, while remaining sensitive to businesses. This document outlines criteria for clear wood finishes, floor coatings, stains, primers, sealersSealers are coatings applied to either block materials from penetrating into or leaching out of a substrate, to prevent subsequent coatings from being absorbed by the substrate, or to prevent harm to subsequent coatings by materials in the substrate. and shellacs, and can be helpful in defining application type for products.
Guidance and sample language on incorporating VOC limits into Specifications.
Teams can use this tool to track all materials across various MR and IEQ credits. It helps teams develop a roadmap of what information needs to be tracked for different products. It can also be used early on to create the baseline budget and ensure the products that are being used will apply to the various credit thresholds.
This is a materials tracking form that helps subcontractors record the environmental values of products they purchase. This can be distributed to each trade subcontractor and submitted to the GC for filing.
Use a letter like this sample to orient the contractor to their responsibilities for all MR and IEQ credits. This letter is an introduction that can be customized for the credits your project is pursuing.
This is a VOC tracking sheet that helps subcontractors record the low-emitting qualities of the products they purchase and can be distributed to each trade subcontractor and submitted to the GC for filing. Use it specifically for earning low-emitting materials credits, but in conjunction with documentation for MR credits.
Products with VOC content not meeting credit requirements for VOC levels can inadvertently get used on the jobsite. A sign like this sample helps remind subcontractors and construction workers of their responsibilities.
Look to product cut sheets for information on the VOC content of paints and coatings. The example here clearly displays information needed for documentation, as well as an instance where more information is needed from the manufacturer.
You can use the VOC budget method to earn this credit by offsetting materials that go over the VOC limit with materials that are under it. The spreadsheet shown here, along with tips in the Getting It Done tab, demonstrates how to perform the budget method. This spreadsheet was completed by Mary Kay, LEED AP BD+C, a LEEDuser reader, and was approved by GBCI on a LEED-NC v2.2 project.
The following links take you to the public, informational versions of the dynamic LEED Online forms for each NC-2009 IEQ credit. You'll need to fill out the live versions of these forms on LEED Online for each credit you hope to earn.
Version 4 forms (newest):
Version 3 forms:
These links are posted by LEEDuser with USGBC's permission. USGBC has certain usage restrictions for these forms; for more information, visit LEED Online and click "Sample Forms Download."
Documentation for this credit is part of the Construction Phase submittal.
I'm currently reviewing a submittal for Fire-stopping Intrumescents and Mortar Products, applied on the interior of the building Envelope on a Project we are working on.
Beleive it should be considered as an 'Anti-Corrosive' Product Type under the VOC Classifications?. Can someone offer a second opinion?.
Ish—Intumescent fire-stopping, used to seal off floor & wall penetrations, qualifies under IEQc4.1 as an Architectural Sealant. However, intumescent paint falls under IEQc4.2.
Intumescent paint is usually applied to steel as fireproofing. When exposed to extreme heat, the paint expands, puffing up like popcorn, to form a protective insulating jacket around the steel. Since it is applied to steel, it may also have anti-corrosive properties. If it does, the Green Seal GC-03 VOC limit applies. Otherwise, use the GS-11 limits for “flat” or “non-flat.”
Jon - if the Firestopping Product is a mortar, a fire resistive
microsilica compound which may be applied as a fire-stopping/thermal insulation layer across an area, does it not make sense to qualify this product under IEQc4.2, assuming a coating?
Ish—If the mortar is a mineral-based, cementitious product, with no organic binders, polymers, or additives, neither IEQc4.1 nor IEQc4.2 applies to it. Check material safety data or ingredient lists to verify the mortar’s composition. If it contains only inert mineral components such as gypsum, Portland cement, or microsilica, VOCsA volatile organic compounds (VOCs) is a carbon compound that vaporizes (becomes a gas) at normal room temperatures. VOCs contribute to air pollution directly and through atmospheric photochemical reactions (excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides and carbonates, and ammonium carbonate) to produce secondary air pollutants, principally ozone and peroxyacetyl nitrate. should not be a concern.
If the mortar does include organic components, it may qualify as a “Pigmented Fire-Retardant Coating” if it meets that definition in SCAQMD-1113-2004.
The SCAQMD has sometimes baffled me with their categories, and in this case, the lack thereof. In 2007 the fire-retardant coating category was eliminated. It appears that sometime between then and 2014 it was reinstated as "fire-proof coatings", into which intumescent paint would seem to fit. The 2014 limit for fire-proof coatings is 150 g/l. Prior to that it was 350 g/l. I haven't delved into when it was re-instated. If the product you are reviewing is under 150, you are OK either under the current SCAQMD category or the non-flat paint category. If you are above that , you may need to have discussion with the USGBC about if and how you could use the 350 g/l limit.
Keith—For LEED NC-2009, refer only to the versions of SCAQMD and Green Seal Standards referenced by credit requirements (GS-11-1993, GC-03-1997, & SCAQMD-1113-2004). Definitions and requirements have changed in newer versions of these standards. Ignore them. They are not relevant to LEED NC-2009.
Ish—How is the mortar applied? Is it spread across a surface like paint, or is it troweled in to fill a wall or floor opening. If it is used as a fill gaps, it is not a coating governed by IEQc4.2. It may fall under IEQc4.1, but only if it contains organic binders, polymers, or additive. If it is entirely mineral-based, it is just mortar, and neither IEQc4.1 nor IEQc4.2 applies.
What category would whiteboard paint fall under? Plan to use IdeaPaint which has a COC of 325 g/L, don't want to calculate the VOC budget method if not necessary. Thanks!
Hi Craig – I’m not sure that I’ve heard from you since I worked with your brother on the Airport.
Whiteboard (Dry-Erase) paint probably qualifies as a non-flat with a VOC limit of 150g/L. The brand that you mention offers various lines of marker board paint. As you noted, one line reports having over 300g/L VOC, but the same company offers other lines of whiteboard paint that DO comply with LEED VOC limits. So do several other manufacturers.
If you DO have to use the VOC budget, and if you only use small quantities of non-compliant paint, you can use an abbreviated version of the budget that does not require you to quantify every such product used on the project. We pioneered this short-cut approach on the Airport project. See Part 3 of the Response to LI#1822: http://www.usgbc.org/leed-interpretations?keys=1822
If VOC content is mentioned as per ISO EU standard, is it acceptable for LEED?
Nowfal – I presume you mean ISO 11890-2, as cited in EU Decopaint Directive 2004/42/CE.
Apparently, the EU Directive’s methodologies for measuring VOC content differ considerably from those used in the SCAQMD & CARBThe California Air Resources Board, part of the state government, is charged with maintaining clean air. This agency is unique at the state level: California was the only state that had such an agency before the passage of the federal Clean Air Act, and was allowed to keep it. Standards referenced in LEED-2009. Therefore, measurements using the European standard may not be valid to show compliance with SCAQMD or CARB VOC limits. See Dwayne Fuhlhage's June 19 post on the LEED-2009 Core & Shell IEQc4.2 page:
On the other hand, under LEEDv4, 2004/42/CE is listed as an alternative to SCAQMD-1113 outside the US. LEEDv4 provides additional guidance for evaluating VOC content internationally. However, the LEED-2009 Global Alternative Compliance Path Guide does not include these alternatives (see http://www.usgbc.org/resources/leed-reference-guide-green-building-desig...).
Global VOC requirements appear to be the hot topic of recent LEEDuser posts. Since USGBC has not addressed this issue under LEED-2009, it may be wise to submit a formal inquiry. We can hope that USGBC will soon issue LEED Interpretations or Addenda that clarify this issue.
I am confused how to identify if this products should be considered as Adhesives and SealantsA sealant has adhesive properties and is formulated primarily to fill, seal, or waterproof gaps or joints between 2 surfaces. Sealants include sealant primers and caulks. (SCAQMD Rule 1168. )Sealants are used on wood, fabric, paper, corrugated paperboard, plastic foam and other materials with tiny openings, often microscopic, that may absorb or discharge gas or fluid. or Paints and Coatings. Need your advise please. Thank you.
“Dry Pre-Mix Mineral Based Bonding Coat” appears to refer to a plaster product applied over smooth concrete to provide a roughened (keyed) substrate for subsequent layers of plaster. As such, the product probably does not qualify as a coating under IEQc4.2. However, if the plaster base contains organic binders, polymers, or additives, adhesive VOC limits specified under IEQc4.1 could apply. Check material safety data or ingredient lists to verify the composition of the plaster. If the plaster contains only inert mineral components such as gypsum & Portland cement, VOCsA volatile organic compounds (VOCs) is a carbon compound that vaporizes (becomes a gas) at normal room temperatures. VOCs contribute to air pollution directly and through atmospheric photochemical reactions (excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides and carbonates, and ammonium carbonate) to produce secondary air pollutants, principally ozone and peroxyacetyl nitrate. should not be a concern.
However, to be safe, you could enter this product into the IEQc4.2 template as a "Primer" with a VOC limit of 200 g/L or a "Mastic" (300 g/L, max.) if it meets either definition under SCAQMD Rule 1113.
If the product forms a substrate for materials other than plaster, it might qualify under IEQc4.1 as a "Ceramic Tile," “Drywall”, “Panel,” or "Structural Glazing" adhesive if it meets any of these definitions under SCAQMD Rule 1168.
I am working on a project that specified a paint for a covered car park pavements that is an epoxy covering using for pavement's signals. In which category of IEQc4.2 Applicable VOC Limits, should this paints be considered?
Thanks in advance
IEQc4 VOC limits only apply to products used within a building’s weatherproof enclosure. Therefore, if your covered parking area is open to the outside air, IEQc4 VOC limits do not apply to these pavement-marking paints.
On the other hand, if your parking area is totally enclosed and protected from the elements, you must follow VOC regulations set forth in SCAQMD Rule 1113-2004. This rule sets a VOC limit of 150 g/L for “Traffic Coatings” that are “formulated for or applied to public streets, highways, and other surfaces including, but not limited to, curbs, berms, driveways, and parking lots.”
The problem is that in Europe there is a regulation that legislate VOC content limit for paints and varnishes. This directive defines for each product subcategory a maximum VOC content limit for water-based (WB) and for solvent-based (SB) products.
In this case, the subcategory is "two-pack reactive performance coatings for specific end use such as floors" and the VOC limit is respectively 140 g/L (WB) and 500 g/L (SB). Being this kind of products (epoxi coatings) always solvent based there is no way that a product like that is fabricated in Europe will fulfill LEED requirements.
You can find the EU Directive here: http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32004L0042&...
For LEED IEQc4.2, VOC content must be calculated using methods defined in the SCAQMD Rule 1113-2004 definition for “Grams of VOC per Liter of Coating, Less Water and Less Exempt Compounds.” In particular, read the special method for coatings that contain “Reactive Diluents,” products, such as epoxies, that contain VOCsA volatile organic compounds (VOCs) is a carbon compound that vaporizes (becomes a gas) at normal room temperatures. VOCs contribute to air pollution directly and through atmospheric photochemical reactions (excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides and carbonates, and ammonium carbonate) to produce secondary air pollutants, principally ozone and peroxyacetyl nitrate. “which, through chemical and/or physical reaction, such as polymerization, becomes an integral part of the coating.” This method calculates the VOC content of the product AFTER the components have been mixed and catalyzed. Contact coating manufacturers. Their chemists should be able to perform VOC calculations according to SCAQMD methods. EU methods appear to differ from SCAQMD.
Finally, as stated previously, LEED-2009 VOC restrictions do not apply to products applied outside the building’s weatherproof enclosure.
Also note that the EU Directive’s definition of VOC appears to differ from SCAQMD’s definition (“Any volatile compound of carbon, excluding methane, carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, ammonium carbonate, and exempt compounds”). Since the two standards appear to use differing definitions of VOC and differing methods of measuring g/L VOC content, it is unlikely that EU’s g/L VOC designations correspond to SCAQMD’s.
For SCAQMD definitions of “VOC” & “Exempt Compounds,” see SQAQMD Rule 102:
See Dwayne Fuhlhage's excellent June 19 post on the Core & Shell IEQc4.2 page:
Your underground parking lot is not heated or air-conditioned, is it? If you only provide ventilation and the garage is open to the outdoors at all times, your garage may be exempt from IEQc4. Underground parking garages that are “inside the exterior moisture protection envelope,” but “not technically interior space,” are exempt from IEQc4 because they are “unconditioned, non-regularly occupied space.” See LEED InterpretationLEED Interpretations are official answers to technical inquiries about implementing LEED on a project. They help people understand how their projects can meet LEED requirements and provide clarity on existing options. LEED Interpretations are to be used by any project certifying under an applicable rating system. All project teams are required to adhere to all LEED Interpretations posted before their registration date. This also applies to other addenda. Adherence to rulings posted after a project registers is optional, but strongly encouraged. LEED Interpretations are published in a searchable database at usgbc.org. #1767:
If you have issues inside your building reconciling differences between EU & SCAQMD VOC standards & limits, you might heed Dwayne’s recommendation to submit an official inquiry asking GBCI how to address the conflicts.
We are using projected perlite on the inside of the building as a fire-resitance. Would this be considered a coating and if so under what category would it fall as far as VOC content is concerned?
“Projected Perlite” appears to refer to sprayed-on perlite plaster. If so, the product probably does not qualify as a coating under IEQc4.2. However, if the plaster base contains organic binders or additives, adhesive VOC limits specified under IEQc4.1 could apply. Check material safety data to verify the composition of the plaster. If the plaster contains only inert, mineral, components such as gypsum & Portland cement, VOCsA volatile organic compounds (VOCs) is a carbon compound that vaporizes (becomes a gas) at normal room temperatures. VOCs contribute to air pollution directly and through atmospheric photochemical reactions (excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides and carbonates, and ammonium carbonate) to produce secondary air pollutants, principally ozone and peroxyacetyl nitrate. should not be a concern.
However, to be safe, you could enter this product into the IEQc4.2 template as a "Pigmented Fire-Retardant Coating" with a VOC limit of 350 g/L if it meets this definition under SCAQMD Rule 1113.
The table on LEED online does not provide with the option for fire-retardant coatings. What other category should be used and what is the VOC limit for fire-retardant coatings?
As per SCAQMD "The Fire-Retardant Coating category will be eliminated on January 1, 2007 and subsumed by the coating category for which they are formulated."
What is the product you are using?
LEED 2009 references the 2004 version of SCAQMD Rule 1113 posted below. It lists 650g/L for clear fire-retardant coatings and 350 for pigmented. More recent versions of Rule 1113 have eliminated these categories.
John and Jon,
Thanks for this.
Jon, so do we need to include it on the form?
John, it is an intumescent coating. If we do need to include it, which category should we use from the dropdown menu?
MM: Because your product is paint, you do need to include the intumescent paint in your IEQc4.2 documentation.
If the product qualifies as a flat or non-flat paint and complies with GS-11 VOC limits, you can enter it as such. Likewise, if it has anti-rust properties and less than 250g/L VOC, you can enter it as a GC-03 Anti-Corrosive.
If it does not meet any of these GreenSeal standards, the LEED-Online form offers an “Other” category. If you pick "Other," the Product Type field allows you to type in “Pigmented Fire-Retardant Coating.” The "VOC Allowable" field is editable too, so can enter “350” in that field. I hear that reviewers will accept this.
See the comment thread on “Dry-Fog Coatings” below started by Lile on March 26.
The link to Rule 1113 in the Resources tab above is broken. By searching the SCAQMD website (and Google), I can only find the most current version of Rule 1113. Can someone please provide a link to the version of Rule 1113 that is applicable to this credit? Thank you very much.
Thank you very much, Jon. I forgot to check usgbc.
The version provided through the above web address was amended July 9, 2004, but the Ref Guide referenced the Rules in effect January 1, 2004. So, is USGBC linking to the wrong version, or has there been an addenda updating the SCAQMD reference? Thanks
See pages 9 & 10 of the Rule posted by USGBC. They have highlighted the column showing the VOC limits that came into effect January 1, 2004.
You are correct that USGBC's post is the July 9, 2004, amendment instead of the December 5, 2003, amendment that would have been in affect in January 2004. However, the July 9 amendment included only minor technical changes that do not appear to include substantive changes to coating definitions or VOC limits.
I have not been able to find a link to the Dec. 2003 amendment, but the link below outlines the changes introduced in the July 2004 amendment (see pages 15-40 of the pdf):
This is about as close as I have been able to find.
Thanks, Jon. I did find the 2003 "Staff Report for Amended Rule" document here:
This seems to have the "rules in effect 1/1/2004" within the document. I just wanted to confirm I have the final correct version. Thanks for your help.
In my opinion, LEED 2009 incorrectly categorizes primers. I know that the table issued with the 4/14/10 addendum clearly lumps primers into the GS-11 requirements. This I don’t understand. In fact GS-11 makes no reference to primers at all. The only place that regulates primers in the LEED-referred material is SCAQMD Rule 1113.
Clearly primers are formulated for a different purpose than topcoats, which is abundantly clear in GS-11 topcoat requirements. R-1113 defines primers quite adequately as “coatings applied to a surface to provide a firm bond between the substrate and subsequent coats”.
So why has LEED removed it from the R1113 "primers, sealersSealers are coatings applied to either block materials from penetrating into or leaching out of a substrate, to prevent subsequent coatings from being absorbed by the substrate, or to prevent harm to subsequent coatings by materials in the substrate., and undercoaters" category and forced it into the GS-11? This also then bases their VOC limit on whether they flat or non-flat, which has nothing to do with the function of a primer.
Has anyone challenged the USGBC about this?
USGBC agrees with you.
In their October 1, 2013, Addendum, USGBC adjusted primers “from the GS-11 VOC limits to the SCAQMD Rule 1113 limit for consistency with the original balloted version of LEED 2009. General purpose primers for wall and ceiling paint are widely available at lower VOC concentrations than the specified limit. Content will vary for certain substrates and in high-performance applications.”
See Reference Guide Correction ID#100001815 in the Addenda Database in the LEED Credit Library.
The entire Addenda is available at:
, and the revised Table 1 VOC chart is at:
USGBC has not yet posted this most current version of Table 1 on the IEQ Resources Tab in the LEED Credit Library. (Has anybody else noticed that current Addenda are often nearly impossible to find in the LEED Credit Library and Addenda Database? Improvements to these databases could eliminate much confusion. )
Incidentally, primers had been lumped into GS-11 ever since a 2003 LEEDv2.0 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 (LI# 5910). Change sometimes happens slowly.
Bless you Jonathan. We have been struggling with this on several projects for the past year or two. And yes, it is incredibly difficult to find Addenda and many other resources on the USGBC website since they "upgraded" it. I have more luck searching through Google to find things than I ever do trying to navigate the site. Very frustrating. Thank you.
Jonathan. Huge thank you!
Many thanks also to the numerous excellent posts below by LEEDuser contributors.
I had run across those links in previous posts.
It also helps that I had downloaded the entire library of old CIRs several years ago just before a previous USGBC database upgrade.
Hi. If you have a project that is utilizing LEED NC 2009, Do products have to comply with the latest Rule 1113 that was updated in September 2013 or if it was registered prior to it, just have to comply with what's in the reference guide?
For LEED 2009, Rule 1113 is essentially a fly in amber locked into the limits in effect on January 1, 2004. An interpretation last year allows substitution of the CARBThe California Air Resources Board, part of the state government, is charged with maintaining clean air. This agency is unique at the state level: California was the only state that had such an agency before the passage of the federal Clean Air Act, and was allowed to keep it. 2007 Suggested Control Measure for architectural coating VOC for any of the coating categories. The reference standards are now posted on the USGBC website:
The original, printed Reference Guide should be used as a first glance due to the later Credit Interpretations. The 2013 interpretations is intended to smooth out potential conflicts with green building codes.
I am starting to see a specification for
3. Dry-Fog Coatings: VOC not more than 400 g/L.
in MasterSpec and some projects' LEED specs. After consulting with a paint rep, I discovered these include dry-fall paints, and some metals coatings. However I do not find anything about dry-fog coatings in LEED. Has there been any ruling or loophole in the LEED standards to include dry-fog coatings?
SCAQMD #1113: DRY-FOG COATINGS are coatings which are formulated only for spray application so that when sprayed, overspray droplets dry before falling on floors and other surfaces.
I have always reported Dry Fall under this category.
To play it safe, specify Dry-Fog to comply with Green Seal Standard GS-11 (for “architectural paints & coatings applied to interior walls & ceilings”) or GC-03 if the coating has anti-corrosive properties.
MasterSpec probably includes Dry-Fog because early editions of the LEED-2009 Reference Guide listed this coating type. Originally, Table 1 of Chapter IEQc4.2 was a complete list VOC limits for over 40 coating categories defined under SCAQMD 1113. USGBC issued Addenda in April & November 2010 that shortened Table 1 to include only the 3 paint types covered by Green Seal, plus just 17 SCAQMD coating categories. Dry-Fog Coating does not appear in the current Table.
At least one paint manufacturer’s interpretation is that, since the Addenda omitted coating types from Table 1, “those coatings shall be considered other categories within that table, e.g. flat/nonflat/floor/etc.”
SCAQMD 1113-2004 is an old standard. Whatever the coating type, lower-VOC products are usually readily available to comply with current, more restrictive, regional VOC regulations. Using the lowest VOC products available protects IAQIndoor air quality: The quality and attributes of indoor air affecting the health and comfort building occupants. IAQ encompasses available fresh air, contaminant levels, acoustics and noise levels, lighting quality, and other factors. during construction and after occupancy.
These answers are very informative, however still leave me in a quandry. I have a project where some 400 g/L Dry Fog Coatings were used, and if I can't find a hole to jam this square peg into, the project loses the low VOC paint credit. USGBC's attempts at clarifying the issue have just made more confusion as several of the applicable documents aren't consistent.
The LEEDONLINE template lists the standard types of paints shown in the reference guide. It does not list Dry Fog Coatings as an option. It does have a category for "Other". If I pick "Other" then the Product type field is blank, which allows me to type in "Dry Fog Coatings". The VOC Allowable field is editable (unlike all other cases) so I could put "400" in that field. Would this be rejected by a LEED reviewer because it does not fit the categories in this addendum http://www.usgbc.org/Docs/Archive/General/Docs9498.pdf, or would it have to be accepted because it was included in SCAQMD 1113-2004? Since these two documents are inconsistent, the answer does not seem clear.
If it were me, I'd probably stop fighting the system and do a VOC budget method approach to not lose the credit. It shouldn't be that hard as it doesn't sound like there is much dry fall paint and your painting contractor can (and should) give you the volumes used and the volumes on the wall paint for the offset. If you make a reasonable case, write a short narrative on their conflicting guidelines and submit the budget, it shouldn't be a problem.
A little bird told me the following:
The requirement is to be compliant with SCAQMD, and the list in the reference guide is for typical products but is not the comprehensive list. Using the applicable limit for dry fog as indicated in your inquiry is acceptable.
This is for cleaning pipes prior actual coating and painting application. I understand that this solvent does emit strong odor and as such application after hours is preferred.
Any VOC limit?
And other thoughts?
Did you find out any VOC limit for cleaning pipes, I have the same question as you do. Thank you.
Cleaning agents aren't coatings or paints.
I have a subcontractor proposing to use a Form Releasing Agent with a VOC level of 445 g/L. I have yet to find a hard-fast requirement for a VOC max. content for this LEED Credit. Does anyone have any input? Does a Form releasing agent even need to meet the credit requirements since it isn't a finish material anyways?
Thanks for your help!
Would form work coatings fall into this LEED credit? What would their VOC limit be? Thanks!
No, they aren't permanently installed. There is discussion below about this topic with more flushed out answers. There are also low voc form oil that you can specify.
VOC emission for formwork application should be considered even though 2009 VOC table doesn't include formwork release agent VOC. The 2011 shows as 250 g/l but again the 2009 referenced 2004.
1) For Table 1 Satndard VOC limits, there are different values falling under Ceiling limit, Current limit and Effective date. Which value to be used from these for VOC calculation and if its Effective date then which date the final one?
2) Also for HVAC and Fire Protection ducts and piping is VOC needed for them also? If so what is the limit for them?
Saud: I am posting a reply below from an earlier discussion. The Ceiling Limit is not relevant to LEED 2009. The version of SCAQMD Rule 1113 in effect on January 1, 2004 is on the USGBC website in the credit resources section. Use the 2004 column. An October, 2013 interpretation also allows substitution of the categories and limits from the CARBThe California Air Resources Board, part of the state government, is charged with maintaining clean air. This agency is unique at the state level: California was the only state that had such an agency before the passage of the federal Clean Air Act, and was allowed to keep it. 2007 Suggested Control Measure.
I'll let others chime in on the HVAC and Fire Protection question.
"Be sure you are looking at the credit referenced version of Rule 1113 in effect on January 1, 2004. It is available at
http://www.usgbc.org/node/1732511?view=resources The credit is essentially a fly in amber in that it references a long outdated version of Rule 1113 with all of its definitions and limits.
I may be wrong, but suspect you are reading the most current version of Rule 1113 dated September 6, 2013.
As a point of clarification, the 'ceiling limit' is part of the newest version of the regulation. That defines a secondary cap for manufacturers using an exemption system known as corporate averaging. For manufacturers not using averaging (including my employer), the limit is simply the limit. But it is only relevant if you are specifying products to be used in the Los Angeles basin. The rest of the densely populated U.S. states, Canada and several countries use variations of the CARB Suggested Control Measure for architectural coatings."
Thank you so much. I have another thing to ask, in case of water tanks when painting them from inside will it also require VOC data? If so what will be this limit?
I would argue that a water tank is not habitable space, and therefore exempt from LEED VOC requirements. It is not the weather barrier of a building occupied by people. I assume the water tank is outdoors somewhere?
You're right, the water tank is not a habitable space but I am not sure it will be exempt or not. It can be outdoors as well as it can be in the building underground or on the roof may be.
We have the water cistern right in the parkade space part of the building....yes voc limits apply.
We are submitting for IEQ credits 4.1, 4.2, and 4.3 and there are several materials that overlap all three of these categories, primarily carpet adhesive (which would fall under 4.1 and 4.3) and concrete sealant (which would fall under 4.1, 4.2, and 4.3). My question is, do I report these materials in each credit form, or do I choose one credit and only submit that material once? Thank you for any and all insight. K
I would suggest reporting each product into each relevant category; I have been directed to this on a past review.
Ideally you would want everyone to use low VOC whether the product is applied on site or off site. However, if for some reason, a high VOC primer was applied in a shop off-site to steel columns which were then propertly dried and cured and installed on site. Would it have any adverse effect during the air testing? What if a touch-up (maybe sanding?) was necessary in the future, would it cause any harm?
The letter of the law is that if it is applied off site, it is not a concern. In addition, i assume that the steel would be either in the inside of drywall or, if exposed, painted? There should not be any impact on IAQIndoor air quality: The quality and attributes of indoor air affecting the health and comfort building occupants. IAQ encompasses available fresh air, contaminant levels, acoustics and noise levels, lighting quality, and other factors. testing.
What is the VOC limit for this ?
Rule 1113 Industrial Maintenance (IM) Coatings Max 420 g/lQuick question - is this product being applied on the interior of the building?
yes - both interior and exterior of the building.
As John-David stated, durable anti-graffiti coatings live in the IM category. IM has performance requirements such as chemical resistance and surviving repeated scrubbing or abrasion - both typical for non-sacrificial anti-graffiti coatings. Some manufacturers bend the curve a bit by selling multiple layer systems where each layer is sacrificial, but still call the product an IM coating.
Sacrificial coatings designed to be removed by pressure washing or stripping materials and replaced after each tagLEED Technical Advisory Group (TAG): Subcommittees that consist of industry experts who assist in developing credit interpretations and technical improvements to the LEED system. would not typically be classified as IM coatings. These would live under other categories such as Low Solids if it is less than 1-pound per gallon solids content or Waterproofing Concrete/Masonry Sealer if marketed for use on brick, block or stone and it has additional water repellent characteristics.
I have a specification for a clear concrete sealer that is used to seal an existing concrete floor. (Ben Moore - SuperSpec 100% Acrylic Masonry Sealer' = 165 g/L VOC)
According to product info it
'Reduces the porosity of masonry surfaces' (sounds like a masonry sealer)
'Provides excellent surface adhesion' (sounds like a primer)
'Tintable' (sounds like a stain)
and of course - it'll go on the floor - as a 'coating' and therefore would not meet the 100 g/L VOC requirement.
the Rule 1113 definitions don't help much - any guidance on this would be appreciated.
I would call this a "sealer and undercoater" for 200 g/L.
It is up to the manufacturer to properly categorize the coating in compliance with SCAQMD Rule 1113. Unfortunately, manufacturers are living in the current iteration and there are some disconnects with credit referenced version which is now five rulemakings behind.
'Floor Coating' can be eliminated from the list as the definition covers opaque coatings and those generally not having concrete protection characteristics.
Absent definitive feedback from the manufacturer, I'd say Mara is on the right track.
As an FYI, the text of the Rule 1113 as it existed on January 1, 2004 is now in the credit resource section on USGBC's website. The CARBThe California Air Resources Board, part of the state government, is charged with maintaining clean air. This agency is unique at the state level: California was the only state that had such an agency before the passage of the federal Clean Air Act, and was allowed to keep it. 2007 SCM can be used as a substitute as allowed in the October 1, 2013 interpretation utilizing its category definitions and limits. The SCM is more universal with manufacturers and is incorporated by reference in CalGreen, the IgCC, ICC-700 and the ASHRAE 189.1 update.
We have a product that will be used on the metal piping of a power generator. The piping will become hot during use, therefore the coating needs to be resistant to the heat.
Not sure what would be the VOC ceiling limit for such product, couldn't find an appropriate category under IEQc4.1 where to fit it, since none of the categories address the "resistance to heat" function...
IEQc4.2 helps projects comply with source control methods mentioned in the SMACNA guide for IAQ plans.
Be very strict in using low-emitting products to avoid failing the air quality test, if pursuing that option.
The planning and tracking processes are the same for both of these credits.
To earn IEQc4.3, coatings used for flooring systems must comply with the IEQc4.2 VOC limits.
Do you know which LEED credits have the most LEED Interpretations and addenda, and which have none? The Missing Manual does. Check here first to see where you need to update yourself, and share the link with your team.
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