As described in our Healthy Building Network newsletter today, one of the most positively transformative could be the "Avoidance of Chemicals of Concern in Building Materials" which rewards disclosure of ingredients and avoidance of chemicals on a red list, proposed to be the California Prop 65 list in the draft. HBN strongly endorses the intent of the credit and welcomes the USGBC effort which we expect to reinforce the advances we have been making with the Pharos Project to encourage full disclosure.
The devil is in the details, however, and it will be critical to get the details right in this credit to avoid it becoming a vehicle for greenwash. There are a number of issues we see as important to the effectiveness of the credit including:
- defining disclosure and picking the right red list of chemicals to avoid;
- focusing on interior products;
- rewarding verification; and
- providing sufficient points to encourage engagement and improvement.
This credit is a good first step in a progression, and we call on the USGBC to signal where it is going with this measure. Future versions (2014) should both address health impacts elsewhere in the life cycle and should make disclosure of product content a prerequisite.
Iâ€™ve described HBN's suggestions for refining the Chemicals of Concern credit in more detail in LEEDuser. We encourage you to read our proposals and add your comments there. According to the LEEDuser website, "substantive comments posted here during USGBC's second public comment period will be submitted to USGBC and considered 'official' public comment." Of course you are also encouraged to comment on the LEED Public Comment page.
Other Key Issues in LEED 2012
While you are in LEEDuser, participate in some of the other important discussions of material issues in the LEED 2012 draft. The Non-Structural Materials Transparency credit is also aimed at increasing transparency but through Environmental Product Declarations (EPDs). This one warrants engagement as well with significant issues addressing forestry impacts and substantial questions about the proposal to credit generic industry average EPDs. Join the discussions in LEEDuser here and here and help focus this credit to be most useful. EPDs should become very useful tools as their use increases but they have serious limits in some areas of health and resource extraction and are not at this time a replacement for rigorous third party standards such as FSC.
Speaking of wood, the FSC-SFI debate that has wracked the USGBC for years has taken a new twist in LEED 2012 with the advancement of the LCA/EPD issue and addition of several credits that reward products simply for being biobased. Knowing from ours and others' assessments that being biobased is no guarantee of sustainability, reduced climate impact or improved health, we recommend seriously considering the issues being raised in LEEDuser here and in this statement endorsed by a variety of NGOs. We agree that the new Responsible Sourcing of Raw Materials credit, while still needing some adjustments, represents a major step forward in addressing the environmental and social impacts of the extraction of non-wood materials.
Finally, there are good materials developments in the EQ section to reinforce as well. Some important criteria developed in LEED for Healthcare are ready to move into the rest of LEED (see LEEDuser discussion here). We are concerned about the proposal to drop VOC content restrictions from indoor wet applied materials (see discussion here), but we are very pleased to see LEED 2012 is following the path first blazed by the GGHC and then LEED for Healthcare to extend VOC emissions testing to all interior finish materials.
All in all, the draft LEED 2012 proposes some major shifts in how manufacturers are encouraged to assess, disclose and formulate the products with which we build. This is an important comment period in which to engage with some very important elements to support and many needing your input to reshape to be effective and avoid greenwash. Join the discussion and provide your comments by next Wednesday, September 14, 2011.