ASC Submits Questions on LEED Revision
BETHESDA, MD – The Adhesive and Sealant Council (ASC) has again submitted questions to the United States Green Building Council (USGBC) regarding its LEED 2012 V.4 building rating system revision, including comments focused on process, material credits screening tools and a new verification process added to the most recent draft.
In this round of comments, ASC has asked direct questions related to how LEED credit options are developed. These included requesting information about who is reading and developing responses to industry questions and comments addressed to the latest USGBC proposal and why it has chosen not to use an ANSI-accredited process for developing the latest LEED proposal despite the fact that USGBC is an ANSI-accredited organization.
“Since 2006, USGBC has been an approved ANSI-accredited Standards Development Organization (SDO) with an approved ANSI process that allows for a broad, consensus-oriented development process that requires formal responses to all comments submitted,” noted Mark Collatz, ASC’s Director of Regulatory Affairs. “Yet, despite being accredited and using the power of the ANSI brand to gain credibility when the LEED program was new, the USGBC has never followed the ANSI process. USGBC’s responses to ASC’s earlier comments and questions lacked specificity and exhibited a cookie-cutter approach that ignored legitimate questions, because the draft is incredibly complex and introduces tools that were never developed for use by a SDO.”
As with responses to earlier LEED V.4 proposals, ASC questioned USGBC’s reliance on Cradle to Cradle and the GreenScreen tool to assess hazards in finished building material products.
“USGBC continues to include GreenScreen as a tool that can be used by industry in order to gain a credit, despite the fact that GreenScreen was only developed to evaluate product ingredients and evaluate alternatives in an R&D setting,” said Collatz. “To try to utilize it as a way to characterize finished goods, and therefore gain a credit, is a complete misrepresentation of a legitimate research instrument. The fact that it continues to remain within the drafts is indicative of the USGBC either not understanding how the tool works, or not caring to entertain the concept that the process they follow simply doesn’t work, as the question ASC has with this tool remains – the tool does not adequately address how anyone should use the tool to evaluate finished goods.”
Finally, ASC acknowledged that it was encouraged by a new third option that appears to offer product manufacturers the opportunity to demonstrate efforts toward product improvement through some of the same approaches they are presently using to optimize and verify stronger health and safety-based programs.
The council did suggest that phasing in the percentage of ingredients validated by these verification programs would be a better approach than the present proposal that would require 99 percent of the ingredients to have undergone the verification process to qualify.