-
Avoiding chemicals of concern
Note: This pilot credit was closed for new registrations as of March 1, 2012.
USGBC is planning a three step approach toward chemicals of concern. This pilot credit is intended to be the first measure. The Safer Chemistry pilot credit acknowledges and supports contemporary and accepted knowledge about specific chemicals of concern that should be avoided.
The second measure will address USGBC’s larger mission of advancing product transparency and alternatives assessment across the spectrum of industrial chemicals to support systemic redesign of building products for progressively better human and ecological health.
The third measure will focus on process transparency within building product manufacturing. It is of increasing concern to USGBC that customers and manufacturers better understand and reduce the overall life-cycle related impacts associated with green building product manufacturing.
In this three step approach USGBC shows regard for leading-edge knowledge and precautionary reason, offers guidance to help formulators and designers innovate products that drive better building performance and helps manufacturers identify their greatest opportunities for improvement across the life-cycle of impacts that matter most to the USGBC mission.
The end result should be a world of green building materials to select that have optimized their supply chains and their contents to a measurable degree which will in turn significantly mitigate our sector's overall burden on the planet.
Use this list of chemicals
The list of the chemicals in the credit language is abbreviated. Each of the chemicals listed represents multiple chemicals and very closely related chemicals so when project teams are actually applying this credit, they need this complete list.
Questions for Projects
- Were you able to determine targeted chemical content for all of the products selected? If not what were the challenges in obtaining desired data?
- How did you decide which human health parameters would be important for your team to assess in comparing products?
- Was the comprehensive evaluation of chemical ingredients, combinations and alternatives assessment useful to your product selection? How did you use it? Would you consider using it for more products beyond the scope of this credit?
- Were target chemical-free alternatives available? If not, did you choose not to evaluate them for this credit? What were those materials/products?
Credit Submittals
General
- Register for Pilot Credit(s) here.
- Register a username at LEEDuser.com, and participate in online forum
- Submit feedback survey; supply PDF of your survey/confirmation of completion with credit documentation
Credit Specific
In order to maximize the usefulness of feedback associated with this pilot credit, USGBC asks that project teams provide an analysis of alternatives to products containing targeted chemicals as well as an analysis of the industry norm products that the team would have chosen had this pilot credit not been pursued. Teams must evaluate potential human health tradeoffs resulting from replacing materials and products to comply with this credit. It is the intention that the materials chosen for evaluation be limited to CSI MasterFormat 2004 Edition Divisions 03–10 and 12. This analysis is critical for the continued evolution of this pilot credit.
- List all of the interior finishes that are included in the project team’s scope of work
- Select six interior finish products for evaluation. A product is considered a whole assembly as purchased by the project team, e.g. a chair, desk or window as opposed to an entire furniture system. Suggested building product selections are those that have high exposure to building occupants through finish surfaces or are the finish materials with the largest quantity in the project, by area. Provide a narrative of why these materials were chosen for evaluation.
- Identify products, equivalent to those identified in step 2, that are considered either industry norm or are in your firm’s standard specification AND contain at least one targeted chemical listed in the credit requirements. If the industry norm does not contain any targeted chemicals, provide documentation demonstrating as much and skip to step 5.
- Perform a comprehensive evaluation of the similar products identified in steps 2 and 3 with an overall focus on human health effects, such as VOC emissions or product toxic content using consistent metrics. Evaluations could be based on indemnified manufacturer’s product data, third party comparison of products, or credentialed toxicologist’s report.
- Evaluate whether or not the products identified in step 2 also meet the requirements for EQ Credit 4, as applicable, in the rating system you are pursuing.
USGBC
Excerpted from LEED 2009 for New Construction and Major Renovations
Pilot Credit 11: Chemical Avoidance in Buidlng Materials
Intent
To reduce the quantity of indoor contaminants that are harmful to the comfort and well-being of installers and occupants.
Requirements
Specify interior building materials and products that do not contain the specific targeted chemicals listed below for all applicable materials. Furniture is required to be included if it is within the project’s scope of work.
From the US Environmental Protection Agency, Pollution Prevention and Toxics, Existing Chemicals Program (US EPA PPT)
Penta, octa, and decabromodiphenyl ethers in products (PBDEs)1
- pentabromodiphenyl ether (c-pentaBDE),
- octabromodiphenyl ether (c-octaBDE)
- decabromodiphenyl ether (c-decaBDE)
Phthalates2
- Butyl Benzyl Phthalate (BBP) [CAS RN: 85-68-7]
- Di(2-Ethylhexyl)Phthalate (DEHP) [CAS RN: 117-81-7]
- Di-N-Octyl Phthalate (DNOP) [CAS RN: 117-84-0]
- Di-N-Pentyl Phthalate (DNPP) [CAS RN: 131-18-0]
- Dibutyl Phthalate (DBP) [CAS RN: 84-74-2]
- Diisobutyl Phthalate (DIBP) [CAS RN: 84-69-5]
- Diisodecyl Phthalate (DIDP) [CAS RN: 68515-49-1 & 26761-40-0]
- Diisononyl Phthalate (DINP) [CAS RN: 68515-48-0 & 28553-12-0]
From the California Office of Environmental Health Hazard Assessment (OEHHA) list of Chemicals Known to the State to Cause Cancer or Reproductive Toxicity, Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65).
Phthalates2
• Di-N-Hexylphthalate (DNHP) [CAS RN: 84-75-3]Other Targeted Chemicals:
Brominated or halogenated flame retardants (BFRs and HFRs)1- Tetrabromobisphenol-A (TBBPA)
- Tris(2-chloroisopropyl) phosphate (TCPP),
- Tris(2-chloroethyl)phosphate (TCEP)
- Dechlorane Plus
FOOTNOTES
- Penta, octa, and decabromodiphehenyl ethers, as well as Brominated or halogenated flame retardants (BFRs and HFRs) were previously included in Pilot Credit 2: PBT Source Reduction.
- Phthalates are a plasticizerChemical compound added to a material to make it more flexible or softer. The most common plasticizers used in PVC (vinyl) products such as flooring and wallcoverings are various phthalates that are suspected of causing cancer and/or endocrine disruptions. used mostly in flooring to make materials more fluid, soft, and pliable.
Potential Technologies & Strategies
Organizations
LEED Pilot Credit Library
The homepage for the LEED Pilot Credit Library. The LEED Pilot Credit Library is intended to facilitate the introduction of new prerequisites and credits to LEED. This process will allow USGBC to test and refine credits through LEED 2009 project evaluations before they are sent through the balloting process for introduction into LEED.
Articles
Foundations of LEED
Background for the LEED Pilot Credit Library is provided in this foundational document.
Full Chemical Avoidance List
This spreadsheet lists the CAS registry numbers for the substances with each chemical referenced in Pilot Credit 11. Project teams should reference the table when speaking to product manufacturers about which substances are included in their products. Also, each of the chemicals listed in the credit language represents multiple chemicals and very closely related chemicals, so when project teams are trying to avoid them, they need the full list.
LEEDuser is produced by BuildingGreen, Inc., with YR&G authoring most of the original content. LEEDuser enjoys ongoing collaboration with USGBC.
32 Comments
Webinar on Chemicals of Concern
I wanted to let you all know the webinar "LEED Innovation & Pilot Credits: Avoidance of Chemicals of Concern" is being offered March 15 2102 at 1:00pm EST . You can find more information and register on the USGBC website page: http://usgbc.peachnewmedia.com/store/seminar/seminar.php?seminar=10496
Hi Sarah, I clicked on the link you posted, but it's an Ergonomic webinar, not Chemicals of Avoidance. I don't see a Chemicals of Avoidance webinar on the master list, or am I missing something?
Thanks,
Phyllis
The programing for the webinar was recently changed to Ergonomics instead of Chemical Avoidance. I can't remove my previous post. Sorry about the confusion.
Thanks for the update. Hopefully it will be offered in the future.
Identify Indemnified
What is "indemnified manufacturers product data" and how do I know if I've got it?
"indemnified manufactures product data" basically means that the manufacturer is responsible for the content and would be legally liable if it was known to be misleading. This requirement is asking for data released directly by the manufacturer as opposed to a 3rd party.
Sarah, thanks for your response. We completed a submittal on Pilot Credit 11 a month or so ago, and most of the manufacturer-obtained data we got was in the form of an email from a company representative. In your opinion, are they legally liable if information in that email proves to be false?
Yes, that is acceptable. I have received you documentation and we are reviewing it now. Thanks for testing out the credit!
Oh great- we look forward to hearing your comments.
POLYETHYLENE TEREPHTHALATE (PET)
I'm thinking of submitting for this pilot credit with one of my products being a type 6,6 Interface carpet tile (Tectonics). Pharos tells me that it contains PET- Polyethylene Terephthalate, which is a phthalate. However, it is not listed in Tom Lent's CASRN List for Pilot 11. Is PET a chemical to avoid under this credit?
After doing some research, I believe the answer to this question is the following:
Orthophthalates are often added to plastics to make them soft and flexible (i.e., they are plasticizers). These orthophthalates are the ones denoted by the word "phthalate," and they are the ones most associated with health concerns. PET is made from terephthalic acid, which is chemically different from orthophthalic acid. This page from the NIH website helps clarify: http://www.ncbi.nlm.nih.gov/pmc/articles/PMC1367856/
Thanks for the update, Julie.
PC 54 is the new PC11?
Should we be continuing in this credit or asking for a transfer to PC 54? What would the USGBC prefer from project teams?
Hi Susan - There is quite a bit of overlap between PC11 and PC54, but we're leaving both open for the moment. By doing this, we can compare the results of each credit and see which approach works best as a credit.
As for differences, the scope of materials covered by PC54 is larger than PC11, but PC11 includes some phthalates that PC54 does not.
If you're currently registered for PC11 and would like to pursue PC54 instead, you can re-register, or email pilot@usgbc.org to have your registration transferred, but you're by no means required to switch over if you feel PC11 is a better fit for your project.
EHHI report on LEED
Susan, I'll bite... here's a thread devoted to the EHHI report, for anyone who would like to share their impressions. I can start the discussion with a link to this article on the EHHI report, which I wrote last year when it came out. (That should also serve as a good intro to the report for anyone reading this saying "what's EHHI?"
My initial reaction was that EHHI should have spent more time understanding LEED and how it works. If they had done any research they would have found how popular the IEQ credits are across project teams and where public health issues are embedded into other categories. I was especially puzzed by the section on water infrastructure. A single building project rarely has opportunity to impact that issue.
But we're discussing chemicals here and they did have a good point about the LEED HC credit being dropped into the pilot credits. What I would like to see is more understanding of chemistry in the design community. What is green chemistry and how to better access products. For example, one of my interior designers gave me a new flooring product to evaluate. The wear layer is PVC (bad) but it is no wax which is good for the application. So do we eliminate a chemical up front or eliminate chemicals in operations?
Full Chemical list
Our project is enrolled in this pilot credit but when I attempt to get the full chemical list LEED User says I don't have permission. Do we have to be members of LEED User for this?
Susan, try the link now—I have fixed it. You can download it without being a member.
It worked just fine! That is quite a list. It appears that the form is organized by CAS number and then chemical name, correct? Is there any reason to capture and track the TSCA number or SARA number as well?
I ask about the TSCA and SARA numbers because I often see MSDS1. Material safety data sheets (MSDS) are detailed, written instructions documenting a method to achieve uniformity of performance. 2. A report that manufacturers of most products are required to make available to installers and purchasers, informing them of product information on chemicals, chemical compounds, and chemical mixtures, the existence of potentially hazardous ingredients, and providing instructions for the safe handling, storage, and disposal of products with those numbers (and OSHA) and not a CAS number.
Susan, I don't know the answer to your question, but I hope that someone at USGBC can respond.
Pilot Credits 2 & 11
Will MBDC's Cradle to Cradle Gold Certification serve as acceptable
> documentation in support of Pilot Credits 2 & 11?
> MBDC's list of banned and restricted chemicals are at this link. http://www.mbdc.com/detail.aspx?linkid=2&sublink=30
I crossed referenced the MBDC's banned list with the PC list and did not find one common chemical of concern between the two lists. I did find some overlap with the Perkins + Will list which is very general. It helps to organize the PC list by CAS number within the chemical class and sort to get them in order (mathmatically, I'm sure I'm commiting great crimes agains chemistry).
Expanding the pilot credit to include insulation
First, I want to say I am thrilled that USGBC is stepping up its focus on the chemistry of green building. While it is a complicated area, and full of proverbial rabbit holes, it is an essential part of making buildings green.
Second, I wanted to express my interest in expanding the Chemical Avoidance Pilot Credit—PC11—to include a focus on choosing insulations that do not contain HFRs. There are several on the market that come in a rigid form that can be excellent substitutes for the polystyrene boards: rigid mineral wool like Roxul and foamed glass like Foamglass by Dow Corning. There are also some new very promising products on the marketplace such as Greensulate, a rigid mycelia based insulation, and Aerogel. And of course, blown in cellulose is an excellent green substitute for urethane based spray foam insulation.
Given the environmental and human health value these alternatives can provide, I think it would be worth expanding the program to include insulations as well as interior finishes and furnishings.
Hi Cate--
Thanks for the product selections--good to know. I just looked at the scorecard for the new LEED Healthcare rating system and was pleased to insulation included, but I believe that the focus is still formaldehyde1. Formaldehyde is a naturally occurring VOC found in small amounts in animals and plants but is carcinogenic and an irritant to most people when present in high concentrations, causing headaches, dizziness, mental impairment, and other symptoms. When present in the air at levels above 0.1 ppm, it can cause watery eyes; burning sensations in the eyes, nose, and throat; nausea; coughing; chest tightness; wheezing; skin rashes; and asthmatic and allergic reactions. 2. A known carcinogen with no known safe exposure level. Formaldehyde occurs naturally, but appears in unnaturally high concentrations in many buildings because it is an ingredient in binders used in many building materials and furnishings.. When 2012 comes up for comment, we should all provide input on the chemistry/human health issues. Incidentally, did you read the report: "LEED Certification: Where Energy Efficiency Collides with Human Health?" I'd be interested in your impressions. Marian
The next version of LEED (not officially being called LEED 2012—yet) is out for public comment until Dec. 31st. You have the option of using this LEEDuser forum for public comments.
Marian, I did read the EHHI report and have mixed feelings about it. If you would like to start another thread, I'll be happy to participate in the conversation.
Susan
Bisphenol A
Any chemists out there know where Bishpenol A, a known endocrine disruptor, fits into the chemical avoidance picture? I've been told it's not a PBT but it doesn't seem to fit into this category, either. The majority of epoxy resins in adhesives, grouts, etc., on the market are BPA-based. Many also contain Tris. I've been told by one epoxy manufacturer that because there is no "free" BPA in their product the exposure concern was not an issue. At least that was the implication. Theirs is a mixture of Bisphenol A and epichlorohydrin. Thoughts?
Good points, Marian. Bisphenol A is the chemical behind the consumer revolt last year that led to massive change in the chemistry of sport water bottles and sippy cups. The National Institutes of Health cites evidence of reproductive and developmental toxicant effects. EPA has targeted BPA in an Action Plan for potential regulation citing particular concern for pregnant women, and children and potential for long-term adverse effects on growth, reproduction and development in aquatic species at concentrations similar to those found in the environment.
Biomonitoring has found BPA widespread in humans. Where is it coming from? Most of the attention to date has been focused on BPA use in water bottles, sippy cups, food can linings and register receipts, but BPA is used fairly extensively in buildings caulks, adhesives, grouts, high performance paints and floor 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. as well as various polycarbonate plastics such as glazings and wall protections.
No free BPA in epoxy? Maybe. But studies of workers applying BPA based epoxies have shown evidence that the epoxy metabolizes back into BPA and alters sex hormones.
All in all, there are plenty of reasons for a precautionary avoidance of BPA and HBN's Pharos Project identifies building products that are known to contain BPA based compounds.
For more information on BPA see “Bisphenol A in Building Materials: High Performance Paint Coatings” http://www.healthybuilding.net/healthcare/2009-07-17_BPA_memo_FINAL.pdf
Hi Tom--
Thanks for sharing all this info! Which pilot credit in LEED does BPA avoidance fit in? I've been told it is not a PBT.
Second aside: It would be great to know if the epoxy resin mfrs. are going to address this somehow. For concrete tunnels, airports, etc., this mixture of BPA and epichlorohydrin, a hazardous substance and organochlorine, apparently is the only way to create high performance adhesives and grouts.
BPA currently doesn't fit under a LEED pilot credit. I'm not familiar with how this was decided or whether it's being considered as an addition.
In addition to the really good information and dialog on Healthy Building Network's site (great context & relevance) check www.chemsec.org Their SIN list (Substitute It Now) is a fast and reliable look into various chemicals. When the site opens look to the upper right side and click "Go to SIN list database". There you can enter the name of the chemical in question, such as "bisphenol a", and learn lots in just a few minutes. Perkins+Will shares their Radical Transparency list; readily available on their website. The Living Building Challenge also has a list of materials/chemicals to avoid.
Start a new LEED comment thread