WELL v2 Materials: Hazardous Substance Limits and Transparency Requirements (2024)

1,000 ppm. That’s the asbestos ceiling for every newly installed product in a WELL v2 project, set by precondition X01 across 9 product categories. Missing one precondition blocks certification entirely. WELL v2’s Materials concept has three preconditions (X01 to X03) and, in features X05 to X08, up to 11 optimization points, addressing hazardous substance limits, outdoor contamination, VOC emissions, and ingredient transparency. The concept also contains further optimizations (X04 and X09 to X12) that this article does not cover.

What are the WELL v2 materials numbers at a glance?

WELL v2 Materials is the certification concept that restricts hazardous substances and drives ingredient transparency across all project types, governed by preconditions X01 through X03 and optimizations X05 through X08.

Preconditions are mandatory for all WELL v2 certification types. Failing one precondition blocks certification regardless of optimization points accumulated.

What does X01 restrict in newly installed products?

X01 Material Restrictions is the precondition that bans asbestos, mercury, and lead above defined thresholds in every newly installed product, per WELL v2. The restriction applies the moment a product enters the project boundary during construction or renovation.

Asbestos above 1,000 ppm is prohibited across 9 product categories: thermal protection, acoustic treatments, sheathing, roofing and siding, fire and smoke protection, joint protection, plaster and gypsum board, ceilings, and resilient flooring.

Newly installed fluorescent and sodium lamps must either meet RoHS restrictions or stay within these mercury limits, which vary by lamp type:

Newly installed paints must meet one of four criteria: lead at 100 ppm by weight or below, no added lead carbonates or sulfates, a lead-free ecolabel or recognized certification, or X08 compliance. Drinking water pipes, fittings, and solder must be approved for drinking water by a government authority or certification body, or have a weighted wetted average of 0.25% lead or less (verified by a third party or labeled ANSI/NSF 372-compliant). Fire alarms, meters, sensors, relays, thermostats and load break switches must contain no more than 0.1% (1,000 ppm) mercury and 0.01% (100 ppm) lead by weight, or meet RoHS. X01 applies only to newly installed products; a project with no newly installed relevant materials achieves automatic compliance.

How does X02 manage hazardous materials in existing buildings?

X02 Interior Hazardous Materials Management is the precondition requiring existing buildings to assess, document, and act on asbestos, lead paint, and polychlorinated biphenyls (PCBs), per WELL v2 Materials.

Asbestos: any material containing more than 1% asbestos qualifies as asbestos-containing material (ACM). Identification requires polarized light microscopy (PLM) or transmission electron microscopy (TEM) testing. When ACM is managed by methods other than removal, the follow-up inspection date must be stated and cannot exceed three years from the last inspection.

Lead paint: floor dust loading above 10 µg/ft² is a hazard. Window sill dust above 100 µg/ft² is a hazard. Paint exceeding 0.5% lead by weight or 930 µg/ft² (10,000 mg/m²) of applied area is a hazard. Bare soil above 400 ppm lead is a hazard. Stabilized or enclosed lead paint also triggers the 3-year re-inspection cycle.

PCBs: buildings constructed or renovated before PCB bans require a written assessment and action plan. Materials containing PCBs must be disposed of under applicable environmental law.

X02 does not require removal of hazardous materials before certification: an investigation by a qualified inspector plus an implemented action plan satisfies each part.

What outdoor hazards does X03 cover?

X03 CCA and Lead Management is the precondition that addresses outdoor hazards from chromated copper arsenate (CCA) wood, contaminated soil, and lead-containing recreational surfaces, per WELL v2 Materials.

CCA-treated wood in outdoor structures installed before applicable bans requires identification through purchase records or testing. Confirmed CCA wood must be disposed of under applicable laws (without incineration or wood chipping) or treated regularly with penetrating, oil-based, semi-transparent stains that prevent arsenic leaching.

Outdoor bare soil requires testing the top 1.5 cm (0.6 in) for lead. If lead exceeds 400 ppm by weight, a second set of samples is taken at 6, 12, 18 and 24 inches (15, 30, 45 and 60 cm). Soil above 400 ppm is replaced to the depth of the deepest sample above the threshold.

Artificial turf fibers with lead concentrations above 300 mg/kg require wipe testing. If wipe test results exceed 430 µg/m² (40 µg/ft²), the turf must be replaced. Loose-fill recycled rubber with lead above 300 mg/kg also requires replacement.

Playground equipment painted before lead bans: if the paint is cracked, peeled or chipped and a sample contains more than 90 ppm lead, the paint must be removed or encapsulated. X03 applies to all outdoor areas within the project boundary.

What chemical restrictions does X05 add beyond the preconditions?

X05 is the 2-point optimization that limits halogenated flame retardants (HFR), per- and polyfluoroalkyl substances (PFAS), heavy metals, and, in architectural and interior products only, orthophthalates, per WELL v2 Materials.

Part 1 (1 point) targets furniture, millwork, and fixtures. At least 50% by cost, covering a minimum of 10 distinct products, must have textiles and plastics containing 100 ppm (0.01%) or less of HFR, PFAS, lead, cadmium, and mercury. Products with no textiles or plastics are automatically compliant.

Part 2 (1 point) targets flooring, insulation, ceiling and wall panels, and plastic plumbing. At least 50% by cost, minimum 10 distinct products, must meet the following limits:

Each part requires a minimum of 10 distinct products.

How do X06 VOC restrictions work?

X06 VOC Restrictions is the 4-point optimization that limits VOC content and emissions in wet-applied products and installed furnishings, per WELL v2 Materials.

Part 1 (2 points) covers paints, coatings, adhesives, sealants, and poured floorings installed inside the building envelope. Projects qualify with at least 10 distinct products or coverage of 10% of project area. All products must be VOC-content-tested per SCAQMD Rule 1168, CARB 2019 Suggested Control Measures, EU Ecolabel, or equivalent. At least 75% by surface area or volume must also pass emissions testing per CDPH Standard Method v1.2, AgBB, or EU LCI VOC thresholds under EN 16516-1:2018.

Part 2 (2 points) covers installed products. Flooring: 90% compliance by cost or surface area. Furniture, millwork, and fixtures: 75% by cost. Insulation and ceiling or wall panels: 75% by cost or surface area. Accepted standards include CDPH v1.2, AgBB, and ANSI/BIFMA e3-2014. One compliant product category earns 1 point; two or more categories earns 2 points.

Composite wood panels in custom or refurbished furniture must additionally meet the LEED v4.1 formaldehyde emissions criteria, or US EPA TSCA Title VI, Europe E1, or Japan Four-star.

How does ingredient transparency work under X07 and X08?

X07 Materials Transparency is the 3-point optimization that rewards chemical ingredient disclosure in permanently installed products, per WELL v2. X08 Materials Optimization adds 2 points: 1 for products with inventoried ingredients that meet one of four chemical-restriction routes (Living Building Challenge Red List v4.0, the Cradle to Cradle Basic Level Restricted Substances List, REACH lists, or a LEED v4.1 optimization path) and 1 for Cradle to Cradle or Living Product certified products.

X07 runs three tiers. Part 1 (1 point): at least 25 distinct products or 50% by count, with ingredients disclosed via Declare label, Health Product Declaration (HPD) in the HPD Public Repository, Cradle to Cradle (C2C) Gold or Platinum, UL Product Lens, Global Green Tag Product Health Declaration, or manufacturer inventory to 1,000 ppm. Part 2 (1 point): at least 15 distinct products with all ingredients publicly disclosed to 100 ppm. Part 3 (1 point): at least 15 distinct products with ingredients independently verified by a third party.

X08 (2 points) has two parts. Part 1 (1 point) requires 25 distinct products with ingredients inventoried to 100 ppm that meet one restriction: free of the LBC Red List v4.0, within the Cradle to Cradle Basic Level Restricted Substances List version 4, free of REACH Restriction, Authorization and SVHC-list compounds, or a LEED v4.1 optimization path. Projects with fewer than 25 such products can instead commit to buying compliant products for future repair, renovation or replacement. Part 2 (1 point) requires 15 distinct products certified Cradle to Cradle Silver, Gold or Platinum in Material Health, or under Living Product Challenge or Living Product Certification.

Why do these numbers exist?

WELL v2 states its own rationale for each Materials feature. For X02 it notes that asbestos-containing dusts are the main cause of mesothelioma and are responsible for over 200,000 deaths annually, and that lead accumulates in blood, tissues and bones and can impair the intellectual development of children. For X05 it cites the research gap on orthophthalates, halogenated flame retardants and PFAS, and the vulnerability of unborn and young children. For X06 it notes that newly installed furniture, flooring, insulation and wet-applied products can emit VOCs for roughly one to two years.

The numeric limits are WELL’s own values, so cite them to the standard and not to another body. Two values show why: the X01 paint limit is 100 ppm of lead, while the X03 playground-equipment trigger is 90 ppm, and the soil trigger in X02 and X03 is 400 ppm of lead by weight.

What do teams most often get wrong about WELL v2 Materials?

Six points recur in documentation.

1. X01 applies to newly installed products only. Existing materials are covered instead by X02 and X03. Confusing the two produces unnecessary compliance work on legacy materials.

2. X05 counts products, not just chemistry. Each part needs at least 50% by cost of the newly installed products in the listed classes and a minimum of 10 distinct products. A project with fewer than 10 distinct products in the classes cannot meet the part, regardless of chemical compliance.

3. X07 Part 1 and Part 2 are different disclosure depths. Part 1 accepts disclosure down to 1,000 ppm (0.1%) for 25 products or 50% by count; Part 2 requires disclosure of all ingredients down to 100 ppm for 15 products, made public. Check the depth of each declaration before claiming Part 2.

4. The X02 follow-up inspection is not a one-time event. When asbestos is managed by methods other than removal, the month and year of the follow-up inspection must be stated and cannot exceed three years from the last inspection. The same three-year limit applies to re-inspection of stabilized or enclosed lead paint.

5. Composite wood in custom or refurbished furniture needs separate verification. X06 Part 2 requires composite wood panels in custom or refurbished furniture to meet the LEED v4.1 formaldehyde emissions criteria, or US EPA TSCA Title VI, Europe E1 or Japan Four-star. Standard furniture spec sheets rarely confirm this for refurbished pieces.

6. WELL Core projects are not exempt from material preconditions. The Core guidance for X01 through X03 is to meet the requirements for the extent of developer buildout.