27 March 2013 – There’s bad news from the US again. After a huge and feisty fight from the US Green Building Council, it seems that PVC and Pals chemical industry managed to create a mess out of the LEED Material Ingredients Credit to be used in the updated USGBC’s LEED rating tool, for which submissions close 31 March.

News on Wednesday morning from Bill Walsh executive director of the Healthy Building Network said the US Green Building Council which manages LEED has taken a credit that would reward meaningful chemical disclosure and avoidance in building products and” embellished it with complex documentation pathways, opt-out options, and an inscrutable ‘supply chain’ options”.

These turn the intent of the credit on its head, by effectively rewarding the status quo, he says.

The argument that less toxic materials in our built environment cost more just doesn’t hold water, Walsh says.

He points to one of the most successful LEED chemical reduction credits, which dates back to the very beginning of LEED: the credit for composite wood products with no added urea formaldehyde.

It resulted reductions in formaldehyde emissions from manufacturing facilities of more than 80 per cent between 2005 and 2010.

“The credit helped catalyse market demand for a range of formaldehyde-free products, undermining the standard industry arguments that healthier building materials cost too much and won’t be accepted by consumers,” Walsh writes.

“The LEED formaldehyde-free credit was clear and straightforward and never diluted by poison pills from the chemical industry. This is significant because the market’s favorable response to LEED’s formaldehyde-free credit laid the groundwork for new formaldehyde regulations by the California Air Resources Board.

“Industry trade associations fought against the CARB regulations. Reinforced by the LEED-inspired market support for their products, however, one composite wood manufacturer and several cabinet makers bucked their trade associations and joined HBN…”

HBN member Tom Lent says in analysis that the worst elements of the proposed Material Ingredients Credit include:

The (very seriously) Bad: Complexity

With three options that include 10 non-parallel paths for compliance, each with several different percentages, benchmarks and languages, this credit is getting more complicated with each comment period and communicates the impression to project teams that this is a very difficult credit to achieve and confuses manufacturers trying to determine how to comply. This is not necessary. The credit must be simplified to insure that teams don’t just walk away in frustration.

 Easy out options that undermine the credit

Three of the 10 paths in the credit language are particularly dangerous, threatening to undermine the credit intent posing a serious threat to industry adoption of the HPD and more broadly to the goal of providing standardised, comparable disclosure and assessment of product contents and to rigorous improvement of product content.

  •  Option 1 Path 1 – Manufacturer inventory: This path allows products to contribute to the inventory point if the manufacturer posts an unstructured, non-standard incomplete inventory of ingredients without disclosure of hazard. It is weighted the same as the HPD and C2C while avoiding addressing hazards and hence removes all incentive to do an HPD or C2C.
  •  Option 2 Path 5 – International Alternative Compliance Path

This path allows products to contribute to the optimisation point whose manufacturers are only meeting current or coming regulatory minimums in the EU (REACH SVHC lists). Products get the same credit as GreenScreen Benchmark One and C2C paths while avoiding a list of chemicals that is only a small fraction of the GreenScreen or C2C lists and requiring neither disclosure nor any assessment of the hazard, private or public, of ingredients actually used. Standard practice will be rewarded resulting in no disclosure and no improvement in products.

  •  Option 3 – Product Manufacturer Supply Chain Optimisation

 This option allows products to contribute if their manufacturers participate in an as yet unspecified program to identify, document, communicate about and optimise health, safety and environment issues along the supply chain.

 There is no identified program yet, or standards for how the USGBC would assess such a program. It is expected, however, that the chemical industry will attempt to use this to get credit for its so-called “Responsible Care” program. There is no clear connection between the Responsible Care program or the LEED credit language and the delivery of products that are inherently safer that the rest of the credit seeks to encourage. Like the REACH path, I expect this program could be a direct threat to engagement in the HPD if it goes the path of being an industry developed program without robust building industry and environmental health NGO stakeholder engagement.

These three paths seriously threaten to undermine the industry effort underway to standardize disclosure, assessment and optimisation.

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  1. I am very much in favour of a disclosure credit for toxic substances released during a product’s lifecycle.

    However, toxicity assessment is a complex business and we need to be very careful not to take actions that have perverse outcomes and expose folk to greater toxicity risk. Such a credit needs to consider the extent of any emissions and the paths to exposure as well as the toxicity of the chemicals released.

    The assessment needs to be consistent between all product classes to avoid jumping out of the frying pan into the fire – it is not automatically true that natural, renewable or recycled materials are non-toxic or even less toxic than ones from the chemical industry (Rhubarb leaves (oxalic acid), snake venom, formaldehyde, anthrax, dust mite poo for example). I love timber products for many reasons including their sequestered CO2, but all timber products do naturally release some formaldehyde.

    Lastly I think that it is important to focus attention on the toxic emissions that expose people to harm rather than the ingredients of a production process. Often highly toxic materials can react together to produce non-toxic products some of which can help us environmentally (e.g. insulation materials).

    It is a tough job, but I hope the long-suffering LEED development volunteers and staff are able to craft a LEED credit in a way that can reduce toxic exposures from all sources without being burdensome and costly to document and assess.

    Nigel Howard – former Vice President and CTO of USGBC responsible for LEED development and implementation 2000-2005,