GREENGUARD Environmental Institue

Comment: The USGBC should reinstate the GREENGUARD Test Method as an option for furniture evaluation and explicitly reference the GREENGUARD Test Method by name in the credit language. The GREENGUARD Test Method has served as the basis for product emissions testing by furniture manufacturers for over a decade.  The GREENGUARD Certification Program has been specifically referenced in LEED since the introduction of LEED for Commercial Interiors in 2004, and the GREENGUARD Test Method has been used to support the program the entire time. The GREENGUARD Test Method and GREENGUARD Certification Program have helped transform the emissions profiles of entire product categories, including furniture, flooring, adhesives, sealants, paints, coatings, and more. This has resulted in healthier products and healthier indoor environments. In fact, test data show that furniture manufacturers who have tested their products according to the GREENGUARD method over the past decade have effectively evaluated their products’ IAQ performance and significantly lowered their formaldehyde emissions levels. This transformation, made possible by accurate and replicable test data, has made a significant contribution to the protection of human health in the built environment.

The GREENGUARD Test Method is the leading test method in the market today. More than 150 furniture manufacturers around the world have relied on it to test over 8,400 individual furniture lines, and these same manufacturers continue to use the method to support their product performance on a periodic basis. This is far more than the number of product lines tested to BIFMA M7.1, which has replaced GREENGUARD as the baseline test method for furniture emissions in the current draft of LEED 2012.  The GREENGUARD Test Method has been updated and modified over the years with input from many stakeholders, including the USGBC, manufacturers, and public health experts.

Originally developed through the EPA ETV program, a public and transparent process, as well as the State of Washington’s East Campus Plus Program, the GREENGUARD Test Method  represents a consolidation of many current national and international programs and test methods. It is recognized, referenced, and used by hundreds of sustainable building programs, specifications, guidelines, codes, and laws around the world and is included in multiple laboratories' ISO 17025 scopes of accreditation. In fact, the GREENGUARD Test Method is currently the most stringent test method in the North American market. It requires not only that products be evaluated and held to criteria for TVOC and over 450 VOCs, but also that all VOCs be identified and reported so that any chemical of concern can be addressed by the manufacturer.

It has been argued that the GREENGUARD Test Method should not be included in LEED because it is the basis for the “proprietary” GREENGUARD Certification Program. This argument is deeply flawed.  LEED itself is a proprietary program, not an ANSI standard.  LEED also directly references other non-ANSI proprietary programs and standards in other credits.  These programs, including GREENGUARD, have made valuable contributions to the continuing development of sustainable, healthier building products for LEED buildings. No explanation or rationale has been given for excluding GREENGUARD while including other proprietary programs or methods, and to do so would be both unfair and anti-competitive.  In addition, the California Standard Method and the BIFMA standards—each of which is referenced explicitly in LEED 2012—are used as the basis for other proprietary certification programs. These programs were founded, at least in part, to compete with GREENGUARD. Furthermore, the basic classroom model used in the GREENGUARD Test Method is the same as that used by the CA Standard Method, and the office models in GREENGUARD (when used for furniture) result in equivalent or higher predicted room concentrations. And, unlike BIFMA M7.1, the GREENGUARD Test Method is publicly available, free of charge, and allows other programs to employ it.

Finally, the GREENGUARD Test Method serves as the foundation for the world’s largest product emissions database. As such, it is a lynchpin for global product emissions testing and should be included in LEED for this reason alone. The large body of test data that have been collected using the GREENGUARD Test Method guides manufacturers, formulators, and  public health organizations in identifying key sources of pollution across multiple industries, as well as thepollution levels, leading to solutions for reducing public health risks.

Recommendations, suggestions, or other ideas for improvement:
Revise the Furniture Evaluation section as follows:

New furniture and furnishing items shall be tested following ANSI/BIFMA Standard Method M7.1-2011 or the GREENGUARD Environmental Institute’s “Standard Method for Measuring and Evaluating Chemical Emissions from Building Materials, Finishes and Furnishings using Dynamic Environmental Chambers” (GGTM.P066). Comply with ANSI/BIFMA e3-2011 Furniture Sustainability Standard, Sections 7.6.1 and 7.6.2 or the emissions requirements in the GREENGUARD IAQ Standard for Building Materials, Finishes and Furnishings (GGPS.001) and the GREENGUARD Children & Schools Standard (GGPS.002), using either the concentration modeling approach or the emission factor approach. Model the test results using the open plan, private office, or seating scenario in ANSI/BIFMA M7.1 or equivalent, as appropriate. USGBC-approved equivalent testing methodologies and contaminant thresholds are also acceptable. For classroom furniture, use the standard school classroom model in CDPH Standard Method v1.1. Documentation submitted for furniture shall state which modeling scenarios were used to determine compliance.