NC 2009 IEQp2: Environmental Tobacco Smoke (ETS) Control

Meike, here are two other LEEDuser forum discussions on air curtains.

I don't know if GBCI has ever allowed this, but I doubt it. I don't see air curtains as the kind of dependable, permanent block to smoking that the credit is looking for.

Jutta, you could try in a narrative to justify not doing the blower door tests, but I doubt it would work. That construction method sounds fine, but it can be surprising how details can be overlooked during construction and not turn out as expected. That's what the testing is all about.

Thanks Tristan, and do agree with you.

prior to constructing the actual building we are building a couple of 'mock-up' rooms to test a number of design and construction components plus interior fit-out and will be 'test-driving' some of the LEED requirements and plans as well. We will have blower-door testing carried out on these rooms to gauge performance and then take a decision from there. my hunch is, though, that we will recommend to test all the smoking rooms regardless, to - as you say - meet the actual intent of the test!

Jutta,
I submitted 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 on this matter. I have VST walls, cement-bound particle boards, which are like formwork that remain in the building. The prefabricated elements are filled on-site with self-compacting concrete. One of the advantages with VST walls is that the construction becomes extremely airtight. There are no gaps in between walls or apartments. I had proposed testing six out of 224 apartments, providing the results were indeed well under the limit. Results are so far ten times better than required. But my CIR was denied. I have to do all the Blower Door testings, one out of seven apartments (at least). This will be a large cost for my project that will not improve air tightness. I also considered arguing that all apartments in my country, according to law, have to withstand fire for at least 60 minutes (EI60) without any smoke leaking between apartments, but have not tried this.

Maria, thanks very much for this post! this is very valuable information. luckily we only have a limited number of smoking rooms in the project, which is otherwise a non-smoking building, and we will budget for blower-door testing for all smoking rooms.

What strikes me again, however, how critical it is that USGBC is beginning to look at differing approaches to LEED prereq/credit compliance and i am glad that considerable attention is being paid to international projects and ACPs. Deon Glaser from USGBC just yesterday commented on a discussion in LEEDuser on the international projects page (referenced in Susann Geithner's post above), where she says "We are currently working on creating a feedback form so that we get input from practitioners like you on what is working with these ACPs and what we need to improve going forward." So this will be worth watching and contributing to!

An ante room is not required but recommended. If you can achieve the pressure difference without that and meet the other requirements than you are fine.

Veronika, this is a long shot, but I'm wondering if the balcony is within 25 feet of any other openings, besides the door holding cell?

Veronika,
You'll want to read the LEED HC guidelines on this and ask to be compliant with Option 2. This states that for resident smoking (inpatient psych qualify) where the regulations say you can't take smoking away from the patient, locate smoking balconies 50 feet from entries. The door out there is gasketed and there are other requirements.

We did this before and submitted in design phase. The reviewer however does not approve it until you have the results. In our case it stated that our approach is ok, but we should submit the prerequ in construction review, which we do.

Thank you Susann!
We will have recieved a few results before we submit, but from all. So we will submit what we have and send in the rest at Construction Submittal. Apartments will be finished and moved in at different times (about once a month), during more than a year. It's a large building, a whole block.

Since an building that allows smoking can meet the prerequisite by restricting smoking to designated smoking rooms that meet the ventilation and air tightness requirements, it sounds reasonable to designate specific units as smoking units. You might consider zoning the smoking units to a discreet part of the building - I imagine a reviewer would want to see that the exhaust from these units is suficiently far from any non-smoking unit windows and air intakes to prevent re-circulation. In addition to the tenant agreements, you might also want permanent signage that identifies the smoking and non-smoking areas. Since this is a pre-req, you might want to do a CIR to know for sure.

Hi Brian,
Check the 2010 AGMBC. We have documented several campus credits, and they routinely have basically the same requirements just using the campus-wide boundary in lieu of your LEED project boundary.

This credit is listed as viable for Option 1. Documentation required is noted as evidence of signage communicating the exterior smoking policy for entire campus. And yes, you would have to use a campus boundary rather than your project's LEED boundary.

Please note there is a new wrinkle on that credit form that seems to indicate with a required upload that you need to provide designated smoking areas if you are not prohibiting smoking entirely on your site. I am currently querying that issue with GBCI and don't have a response yet.

Michelle, have you heard back from the GBCI regarding the "wrinkle" you mentioned? I seem to be ecountering the same thing. Our project has no operable windows (for reasons of security) and no air intakes within 25' of the exterior ground plane, so we saw no need to designate any smoking areas on the site. And yet.
Thanks!

Veronika, the word is "hospitality," which refers not to healthcare hospitals, but to hotels.

Great, thank you!
We consider our inpatients as residential, does these requirements apply on our project in that case?

/Veronika

Re: 1) Unless smoking is prohibited in the whole building, which some rental properties have done, each unit is considered a "smoking room" and has to meet the credit requirements for door sweeps, sealing of plumbing, HVAC, and electrical penetrations in the walls, dedicated direct exhaust for each unit and verification with blower door testing.

Yes, prohibiting smoking in all common areas will comply if smoking is also prohibited on any exterior balconies or decks that are w/in 25' of an operable window or intake vent, which is probably true of most exterior decks.

2) The blower door test is to verify that smoke will not migrate from unit to unit -which can certainly happen. This can be challenging to prevent, especially in metal stud framed construction. For party walls between units, make sure electrical outlets and other penetrations don't share a stud cavity or other chase that allows air to move between units. Extra effort may be needed to instruct and supervise that sub contractors and installers are providing adequate air sealing at all penetrations, fixtures, etc. Pocket doors can be problematic; gaskets may be needed on fixture, outlet and switch covers, etc.

In our experience, the blower door has usually been set up at the unit entry door. I believe it's acceptable to cover with plastic & tape the exterior windows and kitchen & bath vent fans since these are connected to the outside and not to other units, but you'll want to verify that. The test is thus determining the air leakage in and out of the unit through the boundary it shares with other units, which is a good indicator of ETS transmission between units.
Hope that helps!

I had asked about this in the NCv2.2 prereq. There it was possible but with v2009 and the MPR's it is no longer possible. The building has to be complete and whole and any tenants for a C&S project would have to comply with this prereq.

Here is some further reading. And look up definitions for entirety and physically distinct in the glossary at the end. http://www.usgbc.org/ShowFile.aspx?DocumentID=6473

Annette, I don't see that the LEED Online form asks for that. Can you describe more specifically where you are seeing that? (Sample forms can be downloaded directly from our Doc Toolkit above, btw.)

The online template asks for the following info: "A site plan/map showing the location of the designated outdoor smoking/nonsmoking areas is required to document
compliance."

If you'd like to allow people to smoke anywhere on the site, as long as it is 25 feet away from the building, this will meet the intent of the prerequisite. This area "anywhere on site except within 25 feet from the building" is also defined as a "designated smoking area" even though it not a nice little smoking box. Be sure to communicate this area to building occupants through signage.

Also, speaking from experience, the 25 feet is not a magic number. . . Environmental Tobacco Smoke may still find it's way into the building.

Hope this helps.

Hi Tristan, It only appears when you click on the option for "Smoking is prohibited within 25 feet..." then after owner signature the next line states: "A site plan/map showing the location of the designated outdoor smoking areas is required to document compliance." We got a comment from the reviewers that we didn't indicate where the designated smoking areas are and I'm not quite sure what they want.

David, seems we replied at the same time. Are you saying that we should have signage stating, "smoking allowed beyond this point" or something to that effect to indicate where the smoking area is? I can't say I've ever seen that.

Annette, thanks for clarifying, I somehow missed that. Ideally you'd prohibit smoking onsite and that would make thing simpler, but as David says either the boundary or a designated area should meet the documentation requirements here.

I've seen project teams spray paint "no smoking within 25 feet of building" on the pavement 25 feet away from every building entrance. This strategy has been approved by LEED project reviewers.

As a bonus this paint is not used on the inside of the building so it is not required to comply with IEC Credit 4.2, however we suggest project teams meet the VOC content requirements for all items. . . "transform the market" type attitude.

We are having the same issue with review comments asking for designated smoking areas. My newest project is in the early stages for a municipality. They do not believe they can prohibit smoking on the property as a legal issue, though WA state already prohibits smoking within 25' of openings by law. You would think State law would be more than adequate.

However, since this is a prerequisite, we need to be sure. Your comment, David, is the first that I have seen indicating that a boundary radius will work for this purpose. Have you been through review successfully with this approach? And if so, using standard non-smoking signage?

Has anyone had a successful solution to this? We're running into the same comment now.

I think that signage will still be required regardless of the local code to (1) prohibit smoking on the entire property and (2) to communicate that smoking is prohibited within 25ft of the entryways. If the owner feels strongly that signage is not necessary, you could submit for the preliminary review with an explanation of the special circumstances and see what comes back. The signage could always be added prior to the submission for the final review.

To clarify, we do have the proper pressurization to prevent smoke from entering our building. It is just a matter of how do we measure, since the reference guide stipulates the doors must be closed. It assumes there are doors to close.

I don't think there is a protocol for this, no. I think you would need to come up with something on your own (with technical support) that seems as rigorous as possible, and propose it to GBCI. Since this is a prerequisite, 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 might be a worthwhile investment.

Jean, as far as LEED goes I would say you have quite a bit of discretion to pick a number of signs that seems appropriate. So I would focus on what seems needed for the project and your intended audience of smokers.

I would be interested to know if you provided the signs only at the vehicle entrances, or if you included them at pedestrian "entrances" - such as a sidewalk at a corner of the site, not close to a vehicle entrance.

There is no on-site parking within the project boundry on this project. Parents must park on the public road by the curb. I have signs at enterances onto the property and at building entrances.

Josie, one or the other would suffice in this case. If the common hallways are pressurized with respect to the residential units, then weather-stripping of the doors of residential units leading to common hallways is not required. Alternatively, if you weather-strip all doors of residential units leading to common hallways, you do not need to prove positive pressure of the common hallways.

Patrik, the sampling methodology is described in the California Residential Manual that is referenced in this prerequisite. You would be required to test 1 per every 7 "like" units. I.e., At a minimum and if all 90 units are identical, you'd have to perform testing of 13 units. It is up to the project team and testing agent to identify the variations in unit types and ultimately how many tests are required, based on the sampling methodology described above.

I hadn't thought about it from this perspective, but now that I do, I agree with you that something obvious is going unstated.

It does seem like the point is fairly academic, though—IF you're right and there's no isolation requirement, who would do that?

Hopefully nobody would actually do that, but a barracks lawyer might use that omission to make a case for cheaper HVAC in a residential building. The implementation section doesn't seem to differentiate between residential and non-residential projects, so I'm thinking it was either an oversight in the requirements section, or left "flexible" on purpose. Some situations won't meet the intent even if they meet the letter anyway. Take a hotel, for example, where rooms on the second floor are designated smoking, and rooms on the third floor are not. The rooms in my example (typical worker bee hotel) each have their own PTAC which pulls in and exhausts air. The second and third floor units are within less than 25 feet of each other, so someone can effectively smoke within 25 feet of an air intake. While the smoke is being exhausted to the outside, in accordance with the requirements of case 1, option 2, it can be pulled right back in. There's no requirement to exhaust the smoke anywhere in particular, the requirement just says "to the outdoors". Since the people smoking are inside the building, the restriction on exterior smoking areas being at least 25 feet away from entries, outdoor air intakes, and operable windows doesn't provide any protection.

Residential buildings typically do not have return air systems that are shared between separate living units.

We have talked this through for a project including a hotel with a central air conditioning system. The advise we got from the GBCI is to also have these systems separate from "non-smoking" systems. But also we have a mixed use building with hotel, office, retail. So we are required to do that overall for the building.

Yes, USGBC doesn't stipulate who can do the blower door testA blower door test gives an overall value for airtightness of a space, and can help identify air leaks. The testing unit consists of a calibrated fan that is sealed onto the unit entrance. The fan creates a continuous flow of pressure into the unit (or out of the unit when using theatrical fog to locate leaks). Devices detect the rate of pressure retention and loss due to possible air leaks in the construction., only the standard that's used to do it.

Gabriel, as far as I know LEED does not allow you to establish a smoker's program according to local laws. Is that specific to a Mexican version of LEED?

In Mexico there is a law of no smoking inside the buildings, the solution is to comply the project to distance the 25 ft by LEED, in addition we are considering a ante room with a double access and a negative pressure to block the entry of contaminated air into retail areas.

Is this a correct solution?

Yes, although I'm not sure what the purpose of the anteroom is, if you are enforcing no smoking in the buildings and within 25 feet of all entrances.

The ante room are applied to that outdoor spaces (balconies) do not meet distance of 25 ft.

Technical solution is correct?

So, you'd basically be following Option 2, Case 1, and have designated smoking areas on balconies.

I would anticipate that this would work, if ALL openings to the indoors get this negative pressure treatment, and if these outdoor areas are treated like designated smoking areas that occupants aren't compelled to use. For example, they are not main entrances that people must go through to get in. This situation is not anticipated by the credit language, so I would be prepared to document very well that it meets the credit intent.

By prohibiting smoking on the entire property, you are in compliance with the credit requirements, regardless of whether or not an adjacent property is within 25' of a building opening. You do not have control of what happens on another property and therefore cannot be penalized for it, hence why the credit language specifies prohibiting "on-property" smoking within 25 feet.