Draft LEED Material Credit needs your comment by Dec 10 midnight PST

Tom Lent | December 02, 2012

(updated 12/09/12)

The USGBC has taken a huge step forward to address toxics in building materials in the most recent draft LEED standard that is now in public comment. The credit called “MRc4 - Building product disclosure and optimization - material ingredients” rewards product  transparency to inform product selection and encourages avoidance of toxics in building materials.

The credit rewards use of the Health Product Declaration (HPD) for product disclosure and avoidance of products containing GreenScreen Benchmark 1 chemicals. It also allows an alternative path that utilizes the Cradle to Cradle program. This credit is part of a suite of three new materials credits. The other two address use of EPDs and responsible sourcing.

DEADLINE: Comments must be submitted to the USGBC by Monday, Dec 10th. The full credit text for MRc4 and the place for submitting comments is at https://new.usgbc.org/node/2616399?return=/credits/new-construction/v4-draft . You do not need to be a USGBC member to comment

The credit is not perfect. The devil is in the details and there is plenty that needs to be focused to make it doable and a few loopholes to be closed, but this a good start. The USGBC needs encouragement to go forward with this credit and a firm push to continue down this path beyond this credit. This is particularly important in the light of recent ACC attacks aimed at trying to stop US federal government use of LEED for its buildings primarily because of this proposed credit.

HBN COMMENTS:

We strongly support this approach to product improvement through encouraging product content transparency to inform product selection and avoidance of high hazard chemicals. This is just a first step to ridding our buildings of all toxic chemicals. 

There are a few serious loopholes to be closed:

  • International projects should be subject to the same requirements as US projects. While US projects are required to avoid all GreenScreen List Translator Benchmark 1 chemicals for products to get credit, international products can get credit for products that only avoid the REACH SVHC list – a small subset of the requirements for GreenScreen Benchmark 1.
  • The Cradle to Cradle path should be restricted to products certified under the new more transparent and rigorous Version 3 and only with a published scorecard. Cradle to Cradle's just released Version 3 is big step forward in transparency from Version 2. Regardless of version, design teams need more information about the status of hazard reduction efforts in products at low and intermediate levels of C2C.
  • Do not allow compliance for a fraction of a product. This makes sense for recycled content, but not for toxic content. A product with 10% toxic flame retardants should not get 90% credit.

The credit also has some significant implementation challenges and as currently drafted appears unnecessarily complex and daunting. The compliance paths can be organized in a more straightforward and simplified way that will facilitate design team understanding & simple documentation.

  • Simplify the pathways to two different documentation options:  Complete Health Product Declaration/GreenScreen or Cradle to Cradle certification. The HPD template accommodates all the requirements for the ‘Manufacturer Inventory’, ‘GreenScreen’, and ‘REACH’ options. Focus the second point to build on the first, with option either to use a higher number of HPD documented products or to screen the HPD documented products from the first point to use only those which do not include high hazard (GreenScreen Benchmark 1) chemicals.

We've prepared further comments aimed at streamlining implementation to make it practical for design teams. For a more full discussion of our comments on this credit and the other two material credits go to LEEDUser at  http://www.leeduser.com/blogs/leed-v4-public-comment-forum-leed-takes-new-direction. Look for my more detailed assessment and proposals under the comments section at “Assessing the new MR credits - MRC4 - material ingredients”.