15-0515 v3.X Imperative 8 Clarification


We are seeking clarification on Imperative 8, under Requirements, that states all interior building products that have the potential to emit VOC’s must comply with CDPH Standard Method v1.1-2010.

(1) Under “CDPH Conformant Certifications”, projects outside the U.S. are allowed to use other standards that conform to CDPH SM v-1.1 2010, including FloorScore. Our project, however, is within the U.S. and is also seeking LEED v3 certification. We are attempting all IEQ credits which allow either the use of products w/ Green Label Plus, Green Label, FloorScore certification, or conformance to CDPH standards. Because these certifications were developed from CDPH v1.1-2010 standards, are products certified under these three certifications acceptable in lieu of documenting conformance to CDPHv1.1?a. Additionally, LEED states that the Greenguard Gold standard meets the CDPH standards. Is this certification acceptable in lieu of documentating conformance to CDPH v1.1?

(2) Please define “interior building products”. Does this include the waterproof membrane? (Structural steel, structural wood, SIPS, etc.) Then, please define “building products”. Does this including windows, lighting, fans, FF & E, etc.? The CDPH standard describes testing methods for “freestanding furniture”, does this mean LBC’s FF & E exception does not apply to this requirement?

(3) Please define “potential to emit VOCs”. How can projects practically make a distinction between interior building products that have this potential without a deep understanding of chemistry?a.LEED defines “inherently non-emitting sources” as: stone, ceramic, powder-coated metals, plated or anodized metal, glass, concrete, clay brick, and unfinished or untreated solid wood flooring. Does the LBC align with this definition and associated examples?

(4) We are considering using desking systems and office chairs listed on the Declare database. Do we have to document that these products also comply w/ CDPH? If they do not comply or have not completed necessary testing, and other interior Declare products do not comply either, are these Imperative 10 “approved products” actually not acceptable for use on our project? Thank you for providing clarity on these items. We hope to develop a streamlined approach to comply with both LEED and LBC VOC standards.


1. It is acceptable for projects located both within and outside of the United States to use products certified by standards that conform with CDPH 01350 requirements. Specifically, Green Label Plus, Green Label, FloorScore, and Greenguard Gold are all acceptable standards for the purposes of LBC CDPH conformance. 

2. Interior building products are all those located inside of the building envelope. The waterproof membrane does not fit within this definition, though structural steel, structural wood, or similar may be considered an interior building product depending upon their location in the project. Building products are defined as all products used in the construction of a building, with the exception of FF&E. FF&E products do not need to comply with CDPH, though the team is encouraged to use compliant products at their discretion so as to maximize chances of achieving the I-08 Healthy Interior Environment (I-08) IAQ testing requirements (see Health & Happiness Petal Handbook, p. 12-14). 

3. Teams may use LEED's definition of "inherently non-emitting sources" as a guide regarding which products are unlikely to emit VOCs. 

4. It is necessary to verify that Declare products are CDPH-compliant. Declare labels state each product's CDPH status. If the status is "compliant" or "N/A", the product meets I-08 requirements. If the product is "not compliant", it may not be used by any project pursuing I-08.

Post ID 2930

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