GREENGUARD Environmental Institue

The U.S. Green Building Council (USGBC) recently released proposed changes to the LEED Indoor Environmental Quality (IEQ) Credit for low-emitting interiors. Unfortunately, the proposed changes—if accepted—could lead to less healthy conditions in LEED certified buildings across the globe, including some of the most sensitive indoor environments, such as schools. 

As currently written, the proposed low-emitting interiors credit fails to improve upon measures to protect building occupants from indoor air pollution associated with product emissions.  Rather than simplifying the credit (which would align with the USGBC’s publicly stated goal of simplifying the entire LEED rating system) and increasing stringency, the revised credit adds a thick layer of complexity and fails to raise the bar on indoor air quality. This is somewhat alarming, given that the intent of the low-emitting interiors credit is to help protect the health of LEED certified building occupants. 

Additionally, the proposed revisions all but ignore the serious concerns with indoor air quality raised in the report, LEED Certification: Where Energy Efficiency Collides with Human Health. Compiled by Environment and Human Health, Inc. (EHHI), the report concludes that LEED fails to protect human health because it allows and, in fact, rewards the use of high-emitting products during the construction, build-out, and furnishing of LEED certified buildings.

The primary problems within the proposed revisions to the low-emitting interiors credit are as follows:

  • Furniture is held to different and less stringent emissions standards than other products. 
  • The industry-backed BIFMA test method is the only test method specifically cited in the credit, which may cause LEED users to believe—mistakenly—that this is the only qualified furniture test method in LEED.
  • BIFMA has not publicly announced its intention to adopt California’s more stringent formaldehyde emissions levels, which all other products in LEED 2012 will be required to meet. This issue is even more problematic when you consider that BIFMA uses a less stringent and less restrictive test model than other credible testing methods in the marketplace.
  • The GREENGUARD Test Method (GGTM), the most widely-used and referenced product emissions testing method in North America, uses a much stricter modeling scenario and has adopted the new lower formaldehyde emissions level, as established by the California Department of Public Health for use in CA 01350.
  • The new credit requires LEED users to analyze complex data and sift through eight pages of complicated mathematical formulas just to calculate a product’s eligibility to satisfy the credit. Additionally, the number of awardable points has been reduced from four to three. As a result, LEED users will likely skip the credit altogether in favor of pursuing credits that involve less work and reward a greater number of points. This will hurt the indoor air quality of LEED buildings.

To remediate these problems, the USGBC should:

  • Reference and recognize the GREENGUARD Test Method by name, as well as other, more stringent emissions test methods.
  • Make LEED simpler and easier to use, not more complex.  The USGBC should make the low-emitting interiors credit easier to achieve by recognizing—by name— the third-party certifications that are known to comply with the testing requirements specified in the credit. This includes GREENGUARD Certification, among others.
  • Restore the maximum number of awardable points to four instead of three.

You can help! Submit comments to the USGBC today!

  • Voice your concern over the proposed low-emitting interiors credit by submitting public comments to the USGBC before March 20, 2012.
  • Tell the USGBC that green buildings aren’t healthy buildings unless they require low-emitting materials.
  • Urge the USGBC to strengthen this credit to help protect your health.
  • Demand that the USGBC make human health a priority—not an option!

Don’t know what to write? Click here to see the comments submitted by GREENGUARD.

Then, click here to submit your comments to the USGBC.

But you have to hurry!

You only have until Tuesday, March 20, 2012 to share your comments!


After all, what could be more important than the air you breathe?