Robert F. Kennedy Community Schools, Los Angeles. Photo courtesy Flexco.

With the success of the U.S. Green Building Council’s (USGBC) LEED Green Building Rating System, the terms low-emitting products and volatile organic compounds (VOCs) have become part of the construction industry professionals’ vocabulary. And with an increase of the knowledge of these terms, the demand for low-emitting flooring products continues to rise.

In the face of ever-evolving credit requirements and compliance paths, flooring manufacturers, installers, and distributors need to master LEED flooring emissions requirements in order to satisfy the needs of specifiers and LEED project teams.

The Importance of Indoor Air Quality Requirements
Various flooring products have the potential to off-gas hundreds of VOCs-from irritants to carcinogens to reproductive toxins-into indoor air, jeopardizing the health of people who live, work, or play where the products are installed. This is true of many other types of products, but it is a particularly critical issue for flooring because it covers such a significant portion of the surface area of a typical building interior. 

LEED addresses flooring emissions in Indoor Environmental Quality (IEQ) Credit 4.3 – Low Emitting Materials, Flooring Systems. The intent of the credit: “To reduce the quantity of indoor contaminates [sic] that are odorous, irritating and/or harmful to the comfort and well-being of installers and occupants.” The goal is to ensure that LEED certified buildings are not only greener than traditional construction, but also healthier.

Fulfilling the requirements of this IEQ c4.3 is not always straightforward; thus, there can be a lot of confusion among LEED project teams as they try to select flooring products that make the greatest contribution to the achievement of their indoor air quality goals. 

Why the Disconnect?
The LEED Rating System attempts to take a holistic approach to sustainability by incorporating multiple criteria to address different environmental issues. While this is vital in the pursuit of more sustainable buildings, it also means that it can be very difficult, if not impossible, for project team members and LEED Accredited Professionals (LEED APs) to gain comprehensive expertise on requirements across the entire rating system.

In addition, credit requirements sometimes differ in rating systems designed for different types of construction. To complicate matters further, the LEED Rating System is constantly evolving to include new requirements.

A new version of each rating system comes out every few years, and several processes designed to ensure that LEED remains technically relevant are in place to facilitate the adoption of new compliance strategies between published revisions. This is enabled by the Credit Interpretation Ruling (CIR) process, which allows project teams to request technical assistance and/or suggest alternate compliance paths to address credit intents for an individual project. 

If a CIR suggests a legitimate strategy outside the prescribed requirements, it can undergo the Performance/Intent Equivalent Alternative Compliance Path (PIEACP) process, which formalizes the creation of alternative compliance pathways that can be used on all future projects.

Unfortunately, this constant development means that even those who once had a solid understanding of credit requirements can quickly lose their expertise. While it may not be possible to know everything about the LEED Rating System, it is possible to become an expert on one of the credits that matters most for flooring products: IEQ Credit 4.3.  

De-Mystifying LEED Flooring Emissions Requirements
The good news is that specifiers are depending on flooring manufacturers and contractors to answer how products contribute to LEED credits and to demonstrate compliance through third-party certification. They are looking for hassle-free solutions, and manufacturers who understand the requirements and know how to provide appropriate documentation have a competitive edge. It is no longer enough just to have a vague awareness of flooring certification programs. Manufacturers and flooring contractors need to understand the requirements behind flooring certification programs and how they compare to the requirements of the LEED Rating System itself.  

The key to decoding LEED flooring emissions requirements is to understand that they are based on California Section 01350 (California Department of Public Health Standard Practice For The Testing of Volatile Organic Emissions from Various Sources Using Small-Scale Environmental Chambers). This emissions test method defines acceptable emissions limits for 35 VOCs that are known to be harmful to human health.

CA 01350 is also the basis of the Resilient Floor Covering Institute’s FloorScore certification and the Carpet & Rug Institute’s Green Label Plus certification. Therefore, products certified under either FloorScore or Green Label Plus can help fulfill LEED IEQ Credit 4.3 requirements. In fact, as the development of the credit progressed and became more stringent and comprehensive, both certifications were written into the credit language.

The latest version of IEQ Credit 4.3 has also evolved through the PIEACP process to include GREENGUARD Children & Schools Certification as a compliance path. When the GREENGUARD Children & Schools standard is compared against CA 01350, it is easy to understand why.

The GREENGUARD Children & Schools Certification not only includes limits for the 35 chemicals defined by CA 01350, but also imposes limits on over 320 additional chemicals, requires that products meet a total volatile organic compound (TVOC) limit, and incorporates other requirements that make it more protective of human health.   

Flooring Adhesive Requirements: Content vs. Emissions
IEQ Credit 4.3 requirements for flooring adhesives reference CA 01350, as well. Accordingly, adhesives that are certified under GREENGUARD Children & Schools, FloorScore, Green Label Plus, or those that can document CA 01350 testing would comply.

The requirements also provide an option to use content criteria from the South Coast Air Quality Management District (SCAQMD). (See SCAQMD rule 1168.)  

Using the content option, Green Seal certification (GS-36) or a material safety data sheet (MSDS) showing that a product meets SCAQMD rule 1168 would also be a strategy to show compliance. Note that LEED for Schools does not allow for content-based criteria, as it acknowledges only emissions criteria, which are more protective. (Chart 1)

All Compliance Paths Are Not Created Equal
The various compliance paths often raises questions about which criteria are more protective from an indoor air quality perspective. A recent report from the U.S. Environmental Protection Agency (EPA), entitled Criteria for Evaluating Programs that Assess Materials/Products to Determine Impacts on Indoor Air Quality, suggests that relying on MSDS sheets and VOC content requirements to predict indoor air quality impacts can be problematic.

The report states, “First, because MSDS only deal with known hazards, many VOCs will not be listed. Second, some pollutants not contained in the product may be in the emissions. Third, this method of determining emissions will almost always be incomplete, because identification of emitted compounds will be uncertain, and information on emission rates is lacking. Fourth, VOC content information provides no data on individual compounds, many of which may be toxic or carcinogenic.”

When it comes to emissions-based programs, comprehensive criteria that address the most VOCs and other pollutants are key to ensuring that the finished space will have the best possible indoor air quality.

Helping LEED the Way to Healthier Flooring Options
Regardless of whether a project seeks LEED certification, understanding LEED product emissions requirements and being able to provide the lowest emitting product options gives floor covering industry professionals a clear competitive edge. When it comes to something as important as indoor air quality, fulfilling credit requirements is good, but exceeding them is better, helping create a truly healthier space is best of all.

- By Henning Bloech, LEED AP, executive director, GREENGUARD Environmental Institute; and Maria Rutland, LEED AP ID +C, marketing specialist, GREENGUARD Environmental Institute

About the authors:

Maria Rutland, LEED AP ID+C is marketing specialist for the GREENGUARD Environmental Institute (GEI). Maria works to help educate the commercial building industry about the importance of indoor air quality and its impact on human health. She is an active member of the U.S. Green Building Council Georgia Chapter, helping develop educational events and curricula that contribute to LEED AP credential maintenance. 

Henning Bloech, LEED AP is the executive director of the GREENGUARD Environmental Institute. He is responsible for the strategy and positioning of GREENGUARD in the global market, leading strategic development and growth initiatives. Previously, Henning was the Global Sustainability Director for INVISTA. He has published numerous articles and business cases on sustainable product selection, indoor air quality, source control and green procurement. He is an established speaker and has held training seminars and presentations on green design, indoor air quality and healthy buildings at conferences and symposia around the world. Henning is an active member of the Green Products Roundtable and the TFM Green Buildings Advisory Board.