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Guideline I.1: Low Emitting Materials

Intent

To minimize occupant exposure to volatile organic compounds.

Required Performance Criteria

  1. All newly installed interior materials must comply with California Department of Public Health (CDPH) Standard Method v1.1–2010 or v1.2-2017. Interior materials are defined as all materials and finishes interior to the enclosure’s least vapor-permeable and continually air-sealed barrier system. This includes but is not limited to flooring adhesives, sealants, carpets, resilient flooring, paints, acoustical insulation products, gypsum board, acoustical ceilings, acoustic wall panels, casework, composite wood subflooring, and furnishings.1
    1. Exceptions:
      1. Inherently non-emitting sources: Products that are inherently non-emitting sources of volatile organic compounds (VOCs) (stone, ceramic, powder-coated metals, plated or anodized metal, glass, concrete, clay brick, and unfinished or untreated solid wood flooring) are considered fully compliant without any VOC emissions testing if they do not include integral organic-based surface coatings, binders, or sealants.
      2. Salvaged and reused architectural millwork more than one year old at the time of occupancy is considered compliant, provided it meets the requirements for any site-applied paints, coatings, adhesives, and sealants. Newly installed finishes and components are not exempt from I.2A or I.2B.
      3. Product types with two or fewer compliant manufacturers available from the combination of all databases listed below at the point of product selection are exempt from this requirement.2
      4. Structural building products as excluded from CDPH Standard Method v1.1 under part 1.1.4.
      5. Composite wood products covered under Guideline I.2C.
      6. Furnishings covered under Guideline I.2D. Onsite applied furniture coatings are not exempt from the requirements of I.2A.
    2. Approved databases of materials recognized as compliant with the most current CDHP standard:
      1. Collaborative for High Performance Schools (CHPS) Low Emitting Materials (which includes several of the other third-party certifications below).
      2. Carpet and Rug Institute (CRI) Green Label Plus™ Certification (for carpet, cushion, and adhesive products).
      3. Scientific Certification Systems (SCS) Indoor Advantage Gold™ Certification.
      4. Resilient Flooring Institute (RFI) FloorScore™ Certification.
      5. Underwriters Laboratory (UL) GREENGUARD Gold™.
      6. Intertek ETL Environmental™ VOC+.
      7. Materials Analytical Services, LLC (MAS) Certified Green™ (for Building Materials).
      8. NSF/ANSI 332 (for Resilient Floor Coverings).
      9. Berkeley Analytical Associates ClearChem (for Interior Building Products).
      10. Coatings Research Group, Incorporated (CRGI) Green Wise Gold (for Paints).
  2. Wet-applied materials: All onsite wet-applied materials must meet the applicable requirements below. Interior onsite wet-applied materials also must meet the general requirements for VOC emissions under I2A.
    1. All paints and coatings wet-applied onsite must meet the applicable VOC limits of the California Air Resources Board (CARB) 2007, Suggested Control Measure (SCM) for Architectural Coatings, or the South Coast Air Quality Management District (SCAQMD) Rule 1113, effective June 3, 2011.
    2. All adhesives and sealants wet-applied onsite must meet the applicable chemical content requirements of SCAQMD Rule 1168, July 1, 2005, Adhesive and Sealant Applications, as analyzed by the methods specified in Rule 1168.
    3. Paints, coatings, adhesives and sealants wet-applied onsite may not include any intentionally added methylene chloride or perchloroethylene.
  3. Composite Wood Products: Newly installed composite wood must meet the California Air Resources Board ATCM for formaldehyde requirements for ultra-low-emitting formaldehyde (ULEF) resins or no added formaldehyde resins.
  4. New furniture and furnishing items not tested under I.2A must be tested in accordance with ANSI/BIFMA Standard Method M7.1–2014. Comply with ANSI/BIFMA e3-2014 Furniture Sustainability Standard, Section 7.6.1 or 7.6.2
    1. Furniture listed in the following databases or providing the following certifications are considered compliant with this guideline:2
      1. Scientific Certification Systems (SCS) Indoor Advantage (furniture)
      2. Scientific Certification Systems (SCS) Indoor Advantage Gold (furniture)
      3. Underwriter Laboratories (UL) Greenguard Certified
      4. Underwriter Laboratories (UL) Greenguard Gold Certified
      5. Intertek ETL Environmental VOC (furniture)
      6. Intertek ETL Environmental VOC+ (furniture)
      7. Materials Analytical Services, LLC (MAS) Certified Green

[1] This guideline is aligned with the USGBC, “Indoor Environmental Quality Credit: Low-Emitting Materials,” LEED Building Design and Construction v.4, though with a different definition of interior materials and a different threshold for compliance.

[2] Allowable exclusions differs from LEED v.4.

[3] Allowed furnishings differ from LEED v.4.

Recommended Performance Criteria

  1. After construction and before occupancy, conduct air-testing to ensure that the contaminant levels listed in the USGBC document “Maximum Concentration Levels, by Contaminant and Testing Method” are not exceeded using the test methods listed in that document. If excessive levels of contaminants are found in the building, develop a mitigation plan to reduce these and retest until acceptable thresholds are reached. Conduct testing in spaces representing typical airflow conditions and interior finishes.

During Predesign and early design, identify all applicable product types to be used in the project. All interior materials on interior assemblies must be included (though some materials in these may be subject to the listed exclusions). For exterior assemblies this is done by determining which continuously sealed material or set of materials is least vapor-permeable and including all materials interior of that boundary. Note that there may be materials (such as metal cladding) that are the least vapor-permeable layer but which are not continually sealed, and should not be considered as the boundary of interior materials.

The recommended method for tracking this guideline is for an assigned team member or members to keep a running list of products and their VOC content compliance information, complete with manufacturer’s documentation. If a product category has been identified but a complaint product has not yet been selected, products may be found in the list of approved databases in the guideline requirements. Communication with manufacturers and product representatives may aid in the discovery of compliant products.

Through the design process, compile required documentation and maintain and update the list of materials. Review project documents to identify all applicable products and specify them as low- or non-emitting. Track and report all interior materials in the B3 Guidelines Tracking Tool, even those that are excluded from VOC content requirements.

For bid and construction documents preparation, verify continued selection of compliant interior materials and products to reflect guideline requirements. Provide contractor with detailed specifications to ensure that the team has the information needed to meet the B3 Guideline requirements. The design team should specifically call out compliant products and only specify allowable substitutions that also meet the guideline requirements.

Input compliant products into the B3 Tracking Tool by uploading a list of all interior materials used in the product and their method of achieving compliance or qualifying for an exemption. Note that compliance with I.2B may be documented through a Certificate of CARB Compliance from the Hardwood Plywood and Veneer Association or the Composite Panel Association. The absence of added methylene chloride and perchloroethylene may be determined from the MSDS for a material.

Coordinate reviews of the construction submittals to ensure that selected products meet the guideline requirements and do not exceed the allocated VOC emissions limits. All review submittals, substitution requests and changes to the construction contract should be carefully reviewed by the design team and contractor for compliance with guideline requirements.

Because meeting these guideline requirements is not typical for all construction teams and suppliers, conducting a B3 Guideline-specific preconstruction meeting to review the requirements in detail and stress their importance will aid in successful product procurement.

A Note for Suppliers, Contractors, and Subcontractors:

During construction, interior paints and coatings applied onsite represent the largest source of VOC emissions. Awareness of VOC levels in paints and coatings is a key step in ensuring the building project is sustainable, and selecting an approved paint, primer or stain is as easy as finding a compliant certification mark as listed in the guideline text. Similarly, awareness of interior adhesives and sealants applied onsite (including flooring adhesives) is also a key factor in compliance.

Carpet installation requires that the carpet, carpet cushion, and carpet adhesive all be compliant with this guideline. Installation of other floorings such as tile, masonry, cut stone, concrete, and wood require that any the flooring product and any finishes or sealers meet the same requirements as paints.

During closeout, monitor submittals and construction site to ensure that materials, products, and systems are being correctly installed to preserve project goals and objectives. Review substitutions based on performance criteria to ensure consistency and compliance with goals as represented in the drawings and specifications.

Document changes to requirements for construction that occur that may impact the provision or installation of materials, products, or components that were intended to ensure indoor air quality standards are achieved.

It is also recommended to use low- or noVOC emitting materials for products including cleaning supplies, pest management applications, minor remodeling, and maintenance associated with “churn” or standard product replacement of furnishings and finishes and to see the full benefit of lowered VOC emissions.

Retain final product compliance documentation as part of the B3 records.

Design:

  • I.1A: List the material categories needed to meet the guideline.

Final Design:

  • I.1A: List all interior materials specified to meet the guideline in the required material categories, including method of compliance, compliant specifications.
  • I.1B: List all wet-applied products specified in the project including method of compliance and relevant specifications.
  • I.1C: List all composite wood products specified including method of compliance, compliant specifications, and product documentation.
  • I.1D: List all furniture specified including method of compliance, compliant specifications, and product documentation.

Closeout:

  • I.1A: List all interior materials installed in the required material categories, including method of compliance.
  • I.1B: List all wet-applied products installed in the project including method of compliance.
  • I.1C: List all composite wood products installed in the project including method of compliance.
  • I.1D: List all furniture installed including method of compliance.
  • I.1E: List testing protocols used in the project and results of testing, including levels of listed contaminants and locations tested.

Occupancy – Submitted annually for ten years:

  • I.1E: Submit any testing results, whether remediation was necessary and performed remediation methods (if any).

California Department of Public Health (CDPH), “Standard Method for the Testing and Evaluation of Volatile Organic Chemical Emissions from Indoor Sources Using Environmental Chambers,” Version 1.1, February 2010: https://archive.cdph.ca.gov/programs/IAQ/Pages/VolatileOrganicCompounds.aspx updated method available here: https://archive.cdph.ca.gov/programs/IAQ/Documents/CDPH-IAQ_StandardMethod_V1_2_2017.pdf

AQMD Rule 1113: http://www.aqmd.gov/home/regulations/compliance/architectural-coatings/tos

OEHHA Acute, 8-hour and Chronic Reference Exposure Level (REL) Summary: https://oehha.ca.gov/air/general-info/oehha-acute-8-hour-and-chronic-reference-exposure-level-rel-summary and chRELs as of June 2016: http://oehha.ca.gov/air/allrels.html

Collaborative for High Performance Schools (CHPS) High Performance Products Database: https://chps.net/products

Carpet and Rug Institute (CRI) Green Label Plus Certification for carpet, cushion, and adhesive products: https://carpet-rug.org/testing/green-label-plus/

EPA Indoor air PLUS: https://www.epa.gov/indoorairplus

UL SPOT: https://spot.ulprospector.com/en/na/BuiltEnvironment

LEED v.4 EQ Credit Low-Emitting Materials Third Party Certification and Labels: http://www.usgbc.org/resources/low-emitting-materials-third-party-certification-table

Low-Emitting Materials Calculator LEED v.4: http://www.usgbc.org/resources/low-emitting-materials-calculator

South Coast Air Quality Management District Rule 1168 – Adhesive and Sealant Applications: http://www.aqmd.gov/docs/default-source/rule-book/reg-xi/rule-1168.pdf

Glossary

Interior Materials

Interior materials and finishes are defined as all materials interior to the enclosure’s least vapor-permeable and continually air-sealed barrier system. For most enclosure systems this definition will encompass all materials interior and exclusive of the vapor barrier/retarder, though for some assemblies with several systems providing vapor impermeability a further determination will need to be made.

Continually Air-Sealed Barrier System

A continually air-sealed barrier system refers to the set of air-sealed building materials that is intended to prevent air-flow through a wall assembly. This may consist of a continually sealed vapor barrier or a set of materials that when combined provide the least vapor-permeable system. Note that some materials have low vapor permeability but may not be part of a continually sealed system and should not be considered as the boundary of the building’s interior.

Volatile Organic Compounds (VOCs)

Volatile organic compounds (VOC) refers to any compound of carbon, excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, and ammonium carbonate, that participates in atmospheric photochemical reactions, except those designated by EPA as having negligible photochemical reactivity. VOCs are organic chemical compounds the composition of which makes it possible for them to evaporate under normal indoor atmospheric conditions of temperature and pressure.[1]

Sealants

A sealant has adhesive properties and is formulated primarily to fill, seal, or waterproof gaps or joints between two surfaces. Sealants include sealant primers and caulks.[2] Sealants are used on wood, fabric paper, corrugated paperboard, plastic foam, and other materials with tiny openings, often microscopic, that may absorb or discharge gas or fluid.

Composite Wood Products:

Composite wood products includes hardwood plywood, particleboard, and medium density fiberboard. Composite wood excludes hardboard, structural plywood, structural composite, oriented strand board, glued laminated timber, prefabricated wood I-joists, and finger-jointed lumber.[3]

[1] United States Environmental Protection Agency, “Technical Overview of Volatile Organic Compounds,” March 17, 2016.

[2] South Coast Air Quality Management District Rule 1168.

[3] Definition based on California Air Resource Board rules, www.arb.ca.gov.

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