LEED v4 Low-Emitting Materials Requirements: Categories, CDPH Testing, and Points (v4, 2019 addenda)

LEED v4 BD+C EQ Credit Low-Emitting Materials is worth 1-3 points. It limits VOC emissions and VOC content for products inside the waterproofing membrane. Points follow the number of compliant product categories (Option 1) or the percentage of compliant materials (Option 2). Emissions testing to CDPH Standard Method v1.1-2010 is part of LEED v4 already, not an addition of LEED v4.1. Source: LEED v4 BD+C rating system, July 2019 addenda, pp. 117-121. This article covers LEED v4 BD+C; LEED v4.1 is not covered. LEED v5 has also been released (USGBC) and is not covered.

Key numbers at a glance

The credit divides the building into categories with different compliance thresholds, and each product must pass an emissions test and, if wet-applied on site, a VOC content limit. Option 1 awards points by the number of compliant categories (Table 2 of the credit). Option 2, the budget calculation method, awards 1 point at 50% to under 70% compliance, 2 points at 70% to under 90%, and 3 points at 90% or more.

The VOC content limits (grams per liter) are not set by the credit itself. They come from the regulations it names: CARB 2007 Suggested Control Measure for Architectural Coatings or SCAQMD Rule 1113 (effective June 3, 2011) for paints and coatings, and SCAQMD Rule 1168 (July 1, 2005) for adhesives and sealants. Read the limit for each product type from the current text of those rules.

Why were these limits established?

The credit’s intent is to reduce concentrations of chemical contaminants that can damage air quality, human health, productivity and the environment. It covers two things: VOC emissions into indoor air (tested in a chamber) and the VOC content of materials, which protects installers and other tradespeople working with wet-applied products. Emissions are tested to CDPH Standard Method v1.1-2010 using a stated exposure scenario (the private office scenario by default), and manufacturers’ claims must also state the total VOC range after 14 days (336 hours): 0.5 mg/m3 or less, between 0.5 and 5.0 mg/m3, or 5.0 mg/m3 or more. The content rules are separate from emissions testing because content can be checked from the manufacturer’s disclosure before a product is installed.

What are the product categories covered?

For New Construction the credit evaluates six categories inside the waterproofing membrane. Schools and Healthcare projects have a seventh, exterior applied products. Each category has its own threshold:

Furniture is optional in BD+C: include it in the calculation if it is in the project’s scope of work, which raises the number of categories needed for each point level (see the table above). Inherently nonemitting sources (stone, ceramic, powder-coated metals, plated or anodized metal, glass, concrete, clay brick, and unfinished or untreated solid wood) are considered fully compliant without emissions testing, provided they have no integral organic-based surface coatings, binders or sealants.

How does CDPH Standard Method v1.1 emissions testing work?

Building products must be tested and determined compliant under California Department of Public Health (CDPH) Standard Method v1.1-2010, using the applicable exposure scenario; the default is the private office scenario. The manufacturer’s or third-party certification must state the scenario used, and compliance claims for wet-applied products must state the amount applied in mass per surface area. Both first-party and third-party statements of compliance must follow CDPH Standard Method v1.1-2010 Section 8, and organizations that certify manufacturers’ claims must be accredited under ISO Guide 65. Laboratories must be accredited under ISO/IEC 17025 for the test methods used. For projects outside the U.S., products tested under the German AgBB scheme (2010) and certain ISO 16000 and DIBt methods are also accepted. U.S. projects must follow the CDPH method. The credit does not name specific certification programs; check that a product’s certification states the CDPH v1.1 scenario and the manufacturer’s claim meets the Section 8 rules.

What composite wood formaldehyde requirements apply?

Composite wood, as defined in the California Air Resources Board (CARB) Airborne Toxic Control Measure for formaldehyde emissions from composite wood products, must be documented to meet the CARB ATCM requirements for ultra-low-emitting formaldehyde (ULEF) resins or no-added-formaldehyde resins. The composite wood category threshold is 100% of the composite wood not covered by other categories. Salvaged and reused architectural millwork more than one year old at the time of occupancy is considered compliant, provided any site-applied paints, coatings, adhesives and sealants meet their requirements. Whether other formaldehyde standards such as EPA TSCA Title VI are accepted is not stated in the credit text; ask USGBC if a project relies on one.

What compliance failures should teams avoid?

Four failure patterns to avoid on this credit.

1. Treating all categories as 100% tests. Interior paints and adhesives are assessed at 90% by volume for emissions and 100% for VOC content; flooring, composite wood and ceilings, walls and insulation are assessed at 100%. A single non-compliant flooring product therefore makes the flooring category non-compliant, but a small share of non-compliant paint or adhesive does not necessarily do so. Specify adhesives by product name, not only the flooring.

2. Substituting products during construction. A compliant flooring system installed with a substitute adhesive that fails the VOC content rule or lacks emissions data can cost the adhesives and sealants category. Review every substitution before installation.

3. Missing the VOC content track for wet-applied products. Emissions testing alone is not enough; on-site wet-applied paints, coatings, adhesives and sealants must also meet the content limits of the named regulations, and in North America methylene chloride and perchloroethylene may not be intentionally added.

4. Counting categories the project does not need. Exterior applied products are scored only for Schools and Healthcare. Furniture counts only if it is in the project scope, and then raises the category count needed for each point.

Frequently asked questions

What is the LEED v4 EQ Low-Emitting Materials credit worth?

1 to 3 points. For New Construction without furniture: 2 compliant categories earn 1 point, 4 earn 2 and 5 earn 3. With furniture in scope: 3, 5 and 6 categories. The budget calculation method (Option 2) awards 1, 2 and 3 points at 50%, 70% and 90% compliance.

When does a single non-compliant product cause a category to fail?

For flooring, composite wood, and ceilings, walls and insulation the threshold is 100%, so a non-compliant product fails the category. Interior paints and adhesives are assessed at 90% by volume for emissions, but 100% for VOC content of wet-applied products. Under the budget method, if 90% of an assembly meets the criteria it counts as 100% compliant, and if fewer than 50% meet them it counts as 0%.

Which products are outside the scope of this credit for New Construction?

The credit applies to the building interior, defined as everything within the waterproofing membrane. Exterior applied products are scored only for Schools and Healthcare. Inherently nonemitting sources such as stone, ceramic, glass, concrete, clay brick and unfinished solid wood are compliant without emissions testing.

Did LEED v4.1 add CDPH testing?

No, not as a first requirement: LEED v4 BD+C already requires emissions testing to CDPH Standard Method v1.1-2010 together with VOC content limits for wet-applied products. This article does not cover the v4.1 credit text; check the v4.1 rating system if the project is registered under it.