I give a big thumbs up to the USGBC for the progress they are making in defining a set of Chemicals of Concern credits to incentivize both disclosure and tiered avoidance performance. Disclosure and performance may still be highly contentious issues in relation to the LCA and wood related MR credits (as note other threads above here in LEEDuser), but I think on this chemicals of concern credit, the USGBC is doing something that should be able to be widely supported. These two credits are very important additions to LEED, representing a big leap forward in the efforts to more substantively address material content and health that we initiated in LEED for Health Care. The new credits will be well supported by the Health Product Declaration (www.hpdworkinggroup.org) which should be ready for public use by the time that LEED 2012 hits the streets. Kudos to staff for strengthening this important credit set in this round, including residuals in the disclosure, more important chemicals in the avoidance and setting a strong 100 ppm threshold. I have a few questions, comments and suggestions about the specific language in the third public comment version to make this a fully functional credit: 20% of project materials criteria: Both credits are based upon meeting criteria for 20% of project materials by cost for at least 3 building product and material types. The USGBC will need to define what a product and material type is to meet the intention which I assume is to make sure that a diversity of materials is addressed and it is not met by just getting disclosure on three closely related big bulk structural materials. Given the importance of toxic content avoidance in the interiors where occupant exposure is greatest, I suggest that the requirements include that at least a portion of the criteria be met by interior products. Perhaps that at least 20% of interior products be included? Disclosure criteria: Disclosure of chemical compounds is only required for those that trigger Clean Production Action’s Green Screen v1.2 Benchmark 1 and disclosure appears to be defined as either CAS number or Green Screen hazard. This is a novel use of the Green Screen, which was designed as a hazard avoidance and alternatives assessment tool rather than a disclosure and hazard communications tool. I think it can be done but some clear guidance for how to communicate will be needed. We’ll be providing guidelines in the HPD based upon the originating lists that Green Screen compiles that will be useful. My preference would be to require full disclosure of CAS number, but I think disclosure of hazard is a good next step (and indeed the HPD anticipates this pathway as well). Multiple avoidance points: The avoidance credit is a two point credit, but the language is not clear whether it is an all or nothing 0 or two points or if there is a tiered step process to getting points. I suggest a stepped process to encourage engagement and continuous improvement. How about one point for each 10% and clear guidance for innovation points for going further? Avoidance criteria: I suggest that there will need to be some clarification on the chemicals covered under the avoidance criteria that probably can be mostly handled in the reference guide. I’d suggest including compounds for all of the heavy metals and that there be some weeding of some of the non CAS specified listings on Prop 65 that are primarily industrially managed occupational hazards, such as wood dust. And I’m curious as to the rationale for a couple of exclusions, namely a) site cured MDI, since all the other EPA Action Plans chemicals are included, and b) REACH SVHCs for US projects. Residuals: I note that residuals are included in the disclosure criteria but not the avoidance criteria. I expect that rationale may be that residuals are tougher to manage than intentionally added ingredients, but I’d still suggest starting to include them, even if at higher thresholds initially with a planned trajectory to bring them down. So there are still some issues to work out to make these credits work well, but the USGBC staff has taken a huge step forward in addressing a complex issue. The basic structure is in place and sound to build from now. Good work!

I am also overall very pleased about the latest updates to both the Avoidance and the Disclosure credits. This draft looks much stronger and clearer than previous versions - go USGBC! I am concerned, however, about the fact that the the Disclosure chemicals lists do not match up with the Avoidance chemical lists. I would suggest that the credits align in order ensure that the chemicals that are included in the Avoidance credit also are disclosed in the Disclosure credit, in addition to those that are already laid out. This would maintain a linkage between the two credits and make the requirements to the market more clear and consistent. Also, along the same lines, since residuals are included in the disclosure criteria, they should definitely be included in the avoidance criteria as well.

Jessica – When you choose the LEED 2012 Adventure of View Changes by Rating Systems (http://www.usgbc.org/DisplayPage.aspx?CMSPageID=2601), there are Rating System Summaries that compare Second to Third Public Comment version. Here is the direct link for BD&C - https://www.usgbc.org/ShowFile.aspx?DocumentID=18603.

My interpretation is that if a manufacturer does not have closed loop recycling, then the recycled content from their product cannot contribute to this portion of the credit. So only products with closed loop recycling programs will be able to contribute recycled content credit. Though there are no specific requirements for how much material must be actually closed loop recycled to qualify a manufacturer as having a program. Is 1,000 pounds enough? 1 million pounds? There needs to be some threshold. NSF 140 - Sustainable Carpet Assessment Standard has clear criteria for end-of-life management with specified reclamation rates. The manufacturer must document a reclamation rate of at least 1% or 40,000 lbs (whichever is smaller) where the reclamation rate = (lbs of all product reclaimed annually) divided by (lbs of annual production of product being certified)

I really like the idea of closed loop recycling, but the way I'm reading this now, it seems to ignore the tremendous number of cross-industry secondary markets for recycled content that have gained momentum over the years. I would like to see an alternative that offers credit for manufacturers with a closed loop process in combination with strong, time-tested recycling (not downcycling) opportunities between industries/product types.

PEFC started as a European forest certification system (the Pan European Forest Certification scheme), but subsequently evolved into the Programme for the Endorsement of Forest Certification, a global umbrella for timber-industry-originated-alternative-to-FSC forest certification systems around the world. These include SFI, CSA and American Tree Farm in North America. To my knowledge, none of these schemes is "life-cycle based" (nor is FSC). Given its scope and diversity, PEFC is not devoid of merit or substance, but there is great variation in the quality of PEFC-endorsed systems, some of which - including SFI - are essentially a front for status quo, business-as-usual industrial forestry. As long as this remains the case, PEFC has no place in LEED. A true leadership standard in green building should limit itself to leadership reference standards, and in forestry, that's FSC.

Thanks for the additional info Jason! Please excuse the inaccuracy of the life cycle comment as it was intended to relate to the approach to chain of custody specifically. In any case, the point is that while PEFC has indeed been led astray in its overall approach, there are many PEFC certified forests in Europe that appear to be managed at least as sustainably as their FSC brethren and in some cases this is thanks to national standards, not FSC or PEFC. So just like other products, shouldn't the approach to sustainably sourced wood be determined by the specific standards (since PEFC includes a vast range of certifications it is the specific standards endorsed by PEFC that should be evaluated, not the brand) under which the specific wood products have been forested and followed to installation rather than brand dependent? Set the bar, not the brand!

The approach you suggest makes sense in principle, and was in fact attempted by USGBC (the forest certification benchmark which failed at ballot in 2010). FSC and its supporters supported the concept of the benchmark and worked hard to try to get USGBC to set a high bar - one that we characterized as "FSC or better." Had such a benchmark been developed and instituted, and if one of PEFC's European affiliates had met it, then I don't think anyone would have objected to its being recognized by LEED provided that you can distinguish those certified products from others certified under other, less rigorous PEFC-endorsed systems. However, in the end, USGBC tried to "divide the baby," and settled on a benchmark that split the difference between FSC and SFI. Both systems and their supporters opposed the resulting benchmark, albeit for different reasons, and it failed at ballot. After all the blood, sweat and tears that went into this process, I will be surprised if USGBC resurrects it.

I agree we both of you. I want to uphold a high standard for wood products but I think there is a lot more than just FSC, which deserves to be recognized. PEFC isn't perfect but in many European countries,which have a lot more laws around forestry and environmental protection of ecosystems, it is at least as good as FSC. To Ward's point the best practice is using materials, which are extracted very close to your location. That for sure reduces the impact on the environment.

Jason, Do you have a link or can you email me a copy of the "Statement of Consensus on Driving Leadership in Performance and Transparency" you reference above? Nevermind I found it here - http://www.buildinggreen.com/live/images//Performance_Disclosure_Consensus_FINAL.pdf

The principal authors of the "Statement of Consensus on Driving Leadership in Performance and Transparency" have developed a detailed analysis of problems with -- and suggested solutions for -- key LEED 2012 MR credits. Please consider this analysis in developing and submitting your comments to USGBC: http://www.fscus.org/images/documents/LEED2012_Analysis.pdf The key recommendations are as follows: BUILDING DESIGN & CONSTRUCTION Responsible Extraction of Raw Materials credit • Separate and distinguish certification by leadership performance standards from lesser performance thresholds OR only recognize materials that are certified to a material- specific leadership performance standard. • Set minimum percent thresholds that are achievable, yet ambitious. Building Reuse and Whole Building Life Cycle Assessment credit, and Material Life Cycle Disclosure and Assessment credit • The Whole Building LCA option in the Building Reuse and Whole Building Life Cycle Assessment credit should be eliminated from the body of LEED 2012 and should remain instead in the LEED Pilot Credit library. • Require a broader range of impact categories for EPDs and require products to report environmentally relevant impacts. Material Life Cycle Disclosure and Assessment credit: Multi-Attribute Assessment • Move option 3 into a new Credit with 1 point available and work towards creating a true multi-attribute option. LEED FOR HOMES Environmentally Preferable Products credit • Increase the points available from 4 to 8. • Reinstate flooring, cabinets, doors, windows, and driveways as applications for EPPs. • Make all framing subsections available for 0.5 points: exterior walls, floors, roofs, and interior walls. LEED FOR EXISTING BUILDINGS Purchasing—Ongoing Consumption credit • Separate and distinguish certification to leadership performance standards from lesser performance thresholds OR only recognize materials certified to an industry-specific leadership performance standard. • The first bullet under the “Bio Based” subheading should be amended to read “New wood AND PAPER products are certified by Forest Stewardship Council or better.” Facility Alterations and Additions • Separate and distinguish certification to leadership performance standards from lesser performance thresholds OR only recognize materials that are certified to an industry- specific leadership performance standard.

Good point. I'm surprised that they are allowing/encouraging plumbing fixtures to be included. I would think that these should almost always be upgraded for water efficiency, much as windows have long been excluded from this credit.

I totally agree. Wouldn't it be great if in 5 or 10 years we had an FSC equivalent for all major raw material industries? However, we still need a usable, justifiable version of LEED between now and then, so I totally agree with your concerns. Giving self-declarations equal weight as rigorous third party certified standards seems very un-USGBC and un-LEED. (Disclosure: I helped to author parts of the link you referenced above, though the specific weightings were not mine.) I recently added a general comment on the main 2012 page suggesting that some credits look to be deeply laborious (e.g. costly) but without the clear promise of higher performance -- the raw materials credit is definitely one that I think has the potential to fall in that category. Of course, I can envision paths to performance that aren't laborious, but I think they would leave us with a meaningless "achievement".

The single standard reference to Sustainable Agriculture Network (http://sanstandards.org) for non-wood biobased products is problematic. It is a good standard, but unlike FSC, has virtually no certifications in the US yet (only one coffee farm in Hawaii) and not very extensive use in building product related crops elsewhere. The bioplastic and other non-wood biobased material industry is in a much earlier stage of development with no widely used clear best practices certification yet. To initiate change in bioplastics and other non-wood biobased applications, and take advantage of recent developments, we need to make use of the variety of certification programs that have been developed specifically for materials production in this country and elsewhere, such as Working Landscapes (http://www.iatp.org/working-landscapes) and the Global Organic Textile Standard (GOTS www.global-standard.org), as well as the role USDA Organic. Specific credit language should identify the principles that certifications should meet, either directly by listing them or indirectly through reference to lists of principles like those of ISEAL or iFOAM. Then a process should be set up for reviewing potential certifications and accepting them for listing in the Reference Guide. ... yes i know this sounds like the ill fated benchmarking we tried to work out on wood...

Thank you Tom for bringing up the important point above. The credit as it stands would essentially eliminate the opportunity for any rapidly renewable materials currently grown in the US. There are further issues related to biobased materials under this credit. "The credit currently reads, “Biobased products are those that meet ASTM Test Method D6866.” There are two problems with this: 1) It references an ASTM standard incorrectly 2) It does not define 'biobased' in terms of standard definitions ASTM Test Method D6866 does not define “biobased.” It is only a standard method for testing the percentage of biobased content in a product. It does not set a content level that qualifies a product to be called biobased. The USDA bio-preferred program is the most recognized program across all industry sectors for defining biobased, and references ASTM 6866 as the method for determining the percentage of content. The IgCC recently approved definition of acceptable biobased building products that establishes minimum 75% biobased content to call a product “biobased” when tested in accordance with ASTM D6866. The process of setting the IgCC definition was consensuses based. LEED should be at least as good, if not better, than IgCC and establish a level for biobased content. I'd further challenge the system to determine the biobased content not only on production but disposal of material. Serious consideration should be given to requiring materials to be biodegradable or compostable. In the case of polymers, often adding a percentage of biobased material to an otherwise recyclable compound reduces the ability to recycle materials. Creating incentive for biobased materials to be either recyclable or compostable helps achieve the goal of reducing the impacts of production throughout the life-cycle.

How could petroleum-based products contribute to this credit? Petroleum is a global commodity and therefore it is virtually impossible to trace its polymers back to their origin of extraction and to identify exactly which company is conducting the extraction. Recycled content is excluded from the calculation. Therefore for a product with high recycled content and the remainder of the raw materials derived from petroleum, it appears that there is no opportunity to contribute to this credit.

Good point Melissa. Petroleum is going to be pretty impossible to acredit. and on the other hand, shouldn't recycled content - by avoiding extraction completely - be inherently a recipient of this credit?

I was thinking the same thing. Recycled content is awarded elsewhere, and LEED generally doesn't double dip -- but this is actually a better place for it than the Material LCA credit. The latter is about disclosure, whereas recycled content is really about performance, as are reuse and local materials, also in that credit option.

Not sure if that is in the draft's language or not but how about excluding recycled content from the total material costs for that credit. It shouldn't count against you and recycling is a means of responsible sourcing, as is reuse.

Better yet, let's include recycled content in the numerator and denominator - that is let's call recycled content responsibly sourced. At least post consumer recycled content. Post industrial should probably remain responsible to its original extractive source. I think Lisa's point is also important about looking at the potential to close the loop - that is how much of the product be recyclable or compostable at the end of life. This is an important part of making the most responsible sourcing - non extractive - possible as well.

I'm going to step back from my blithe suggestion to call automatically call recycled content responsibly sourced. It can be but as we've seen with electronics recycling, it ain't necessarily so. We need standards for responsible recycling just as we need them for responsible forestry, agriculture and mineral extraction. SCS has made a very interesting start on this path with their "Responsible Recycled Source Standard" released last year. http://www.scscertified.com/docs/DRAFT_SCS_STN_ResponsibleSource_V1-0.pdf . It is only being applied to precious mineral recycling in jewelry and electronics so far but i think has great potential for helping us insure that building product recycling of metals polymers and other materials is being done well with respect to health, environment and labor practices.

I agree with you, Susann, that there should be a fixed distance for any additional weighting for the location of harvesting/extraction of raw materials. Your point regarding European countries and the U.S. also applies to large and small states in the U.S. - in California under the current credit language, you could get 200% weighting for, say, wood harvested in the northern part of the state and used in a project in San Diego, 600 or 700 miles away - but in a small state like Connecticutt, you could source wood from 100 miles away in Massachussetts and only receive 150% weighting. This is arbitrary. Also, awarding 300% weighting for "local" materials that are harvested/extracted/manufactured within 50 miles of the project is well-intended but largely meaningless since VERY few materials will qualify.

Actually the 50 miles will really be unachievable for any downtown project. 50 miles out of Chicago and you start digging in the suburbs. As much as I want to encourage local materials, maybe the USGBC should check their current projects so far and see how much could actually make that happen so far just for regional materials under the current rating system than add responsible sourcing and sources of materials down the chain.

There is no doubt that the updated goals of this credit are in conflict with the general push for location-efficient development in existing urban cores. Clearly the dissuasive nature of these requirements in terms of overall LEED market acceptance should allow a greater threshold for projects located in large urban areas--say 250 miles. Generally, the transportation portion of the overall LCA is quite small compared to the manufacturing and use phase footprint. This seems like a misapplication of a principle to me.

Don't get me wrong, I'm all for supporting the use of local products. Not so much because of life cycle costs, much more because it supports local economies, recycling and reuse. It might also make Architects like me think twice about using those fancy tiles from Italy or the stone imported from China. However I think the way this is written will impose an unfair disadvantage on a lot of projects particularly international once and projects in large urban areas.

12 hours? I thought the deadline was midnight on March 27. Where did you get 12 hours from? I can't find anytime on their website.