ACA on May 28 submitted comments to the U.S. Green Building Council regarding LEED 2012. The U.S. Green Building Council opened this unexpected – and very short – fourth public comment period on May 11 in response to concerns regarding the drastic changes in LEED 2012 from the previous 2009 iteration. 

The new LEED 2012 draft includes a drastic change – the Avoidance of Chemicals of Concern now references the European Registration, Evaluation, Authorization and Restriction of Chemical Substances, or REACH, and requires U.S. manufacturers to comply with this system.  LEED 2012 also includes a credit for disclosing 99 percent of the ingredients in building materials, and a new credit system for Low-Emitting Interiors, which contains emissions standards for furniture, ceilings, flooring, architectural coatings, and adhesives and sealants. Under the Low-Emitting Interiors credit, at least 90 percent of interior paint and coatings applied to walls, floors, and ceilings, and 90 percent of interior adhesives and sealants applied on-site must comply with emissions testing requirements.       

With regards to the Low-Emitting Interiors credit, ACA expressed concern that requiring nearly all interior architectural coatings, adhesives, and sealants to undergo emissions testing is not practically feasible in the current marketplace, and will limit access to compliant products, ultimately decreasing the viability of the Low-Emitting Interiors credit.  ACA instead recommended incorporating an alternative compliance option that allows paint and coatings to meet the California Air Resources Board 2007 Suggested Control Measure for volatile organic compound (VOC) limits for architectural coatings.  If the Low-Emitting Interiors credit continues to require emissions testing for interior coatings, adhesives, and sealants, ACA urged the council to amend the threshold so that only 70 percent of these materials are required to meet the CDPH 01350 emissions testing limits.

In its comments ACA addressed five credits, and particularly focused on the following three:

  • Low-Emitting Interiors (which requires emissions testing for 90 percent of interior architectural paint, coatings, adhesives, and sealants)
  • Avoidance of Chemicals of Concern (which incorporates the European Union’s REACH framework – 20-30 percent of building materials must conform to REACH)
  • Material Ingredient Reporting (which requires disclosure of 99 percent of chemical compounds for 20 percent of all interior materials )


The final version of LEED 2012 was scheduled to be voted on by the U.S. Green Building Council’s membership in June.  But given all the controversy over the most recent drafts, the council pushed back the balloting for LEED 2012 to Aug. 15, 2012.

The U.S. Green Building Council intends to unveil the final version of LEED at its annual Greenbuild International Conference and Expo in November 2012. 

Read more at:
http://paint.org/news/industry-news/item/872-drastic-change-in-fourth-public-comment-period-for-leed-2012-aca-submits-comments.html

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