20-1008 CDPH Alternative Compliance for South Africa
Question
INTENT
To improve occupant health by reducing or eliminating indoor pollutants.
REQUIREMENTS
•Compliance with the California Department of Public Health (CDPH) Standard Method v1.1-2010 (or international equivalent) for all interior building products that have the potential to emit Volatile Organic Compounds.
DOCUMENTATION REQUIREMENTS
1.Provide CDPH v1.1-2010 Documents
Describe how the documentation requirements will be met by:
2. Providing a list of all interior building products that have the potential to emit Volatile Organic Compounds (VOCs)
3. Provide supporting documentation for the above demonstrating each product’s compliance with CDPH v1.1-2010 or equivalent standard.
Alternative Compliance Motivation
Currently in South Africa, CDPH v1.1-2010 is not applicable to the local context and we motivate the use of standards already in place. Currently in South Africa, there has been an adoption of the standards for VOCs found in the Green Star SA Requirements. The Green Building Council SA has developed the Green Star SA rating tools (which has been adopted from Australia Green Star Standard) to provide an objective measurement for green buildings in South Africa and Africa. These tools recognise and reward environmental leadership in the property industry.
Green Star rates a building or fitout’s overall environmental impact, Green Star rating tools award points across nine categories. Each category has several credits within it that each address specific green building aspects and actions. Under the Category Indoor Environment Quality (IEQ) which targets the well being of the occupants the credits address how the heating, cooling, lighting and indoor air pollutants contribute to a healthier indoor environmental quality. More specifically under this Category is the Credit IEQ-13 Volatile Organic Compounds, which lays out the VOC requirements to be met by a project. The requirements are laid out in an extensive Green Star SA Technical Manual which stipulates the requirements across all categories and credits.
The credit (IEQ-13) holds the following intent:
To encourage and recognise specification of interior finishes that minimise the contribution and levels of Volatile Organic Compounds in buildings.
The credit lays out the requirements of VOC limits for the following – paints, adhesives and sealants and floor coverings. For each of these, Green Star stipulates the following requirements.
Paints
VOCs are to comply with the grams per litre (g/L) content limits set out in the table below which have been adopted using a combination of the Good Environmental Choice Australia (GECA) standard number GECA-23-2005 version 1.0 Australian Voluntary Environmental Labelling Standard Architectural and Protective Coatings and The Maximum TVOC Content Limits Values for Paints and Varnishes as stated in Annex II, Table A of Directive 2004/42/CE of the European Parliament and Council of 21 April 2004.
Adhesives and Sealants
VOCs are to be in conformance with the grams per litre (g/L) content limits set out in the table which have been adopted from South Coast Air Quality Management District (California, U.S.) – Rule 1168.
Floor Coverings
Compliance Testing Carpets: - Refer to Carpet and Rug Institute Green Label (USA), OR American Society for Testing and Materials (ASTM) D5116 Guide for Small-Scale Environmental Chamber Determinations of Organic Emissions from Indoor Materials/Products (24 hour test). Compliance Testing Flooring (other than carpet): - Refer to the American Society for Testing and Materials (ASTM) D5116 Guide for Small Scale Environmental Chamber Determinations of Organic Emissions from Indoor Materials/Products (24 hour test), OR the ISO 16000 – part 9, 10 and 11 test protocol, also known as the EN 13419 test protocol.
For paints, adhesives and sealants and floor coverings the Green Star Technical Manual requirements for IEQ-13 Volatile Organic Compounds are clearly laid out and VOC limits are clearly shown in detailed tables. Please find IEQ-13 – Volatile Organic Compounds Requirements attached for review. Please note for the purpose of this clarification we have used IEQ-13-Volatile Organic Compounds from the Public and Education Technical Manual, however IEQ-13-Volatile Organic Compounds is the same across all the Green Star SA tools (Interiors, Existing Building Performance, Office and Retail).
Given the above, we would like to motivate that the requirements laid out in IEQ-13 - Volatile Organic Compounds are used as the standard for our project, in terms of VOCs and replacing those standards laid out in CDPH v1.1-2010. In South Africa Green Star is considered ‘best practice’ and Green Star has played a major role in changing the building industry for the better and as a result of Green Star many practices, in this case VOC limits, have been changed to coincide with the limits laid out in Green Star.
Additionally, given the above and its applicability we would further like to motivate that the requirements laid out in IEQ-13 - Volatile Organic Compounds are used as the standard for our project, in terms of VOCs and replacing those standards laid out in Materials - 10- Red List - Specifically the South Coast Air Quality Management District (SCAQMD) Rule 1168 for Adhesives and Sealants or the CARB 2007 Suggested Control Measure (SCM) for Architectural Coatings for ‘Wet applied Products’ and Air Resources Board (CARB) Regulation for Reducing Emissions from Consumer Products for ‘Small Containers of Sealants and Adhesives.’. In South Africa Green Star is considered ‘best practice’ and Green Star has played a major role in changing the building industry for the better and as a result of Green Star many practices, in this case VOC limits, have been changed to coincide with the limits laid out in Green Star.
Answer
The Institute is issuing a project-specific exception which provides for compliance with CDPH through documentation via Green Star South Africa or WELL per the following:
1) For Carpets and Floor Coverings, Adhesives and Sealants, and Paints that are manufactured within South Africa, compliance with the VOC emissions and content limits established in Green Star South Africa - Public & Education Building v1 IEQ-13 Volatile Organic Compounds (Green Star SA).
Documentation must contain either:
- evidence of approval issued by the Green Building Council South Africa or Green Star South Africa (for example by certificate or logo or manufacturer statement used per GBCSA guidelines), or
- a data sheet showing the relevant VOC contents or emissions rate accompanied by the Green Star SA limits for the applicable category. These must be provided together in a single document for the auditor.
2) For all other interior products with the potential to emit, and Carpets and Floor Coverings, Paints, and Adhesives and Sealants, not manufactured in South Africa, compliance with Equivalencies approved in the WELL Standard Feature 4, VOC Reduction: https://standard.wellcertified.com/air/voc-reduction, (see the Equivalencies tab). The strategies are also listed in table: https://resources.wellcertified.com/tools/strategies-table; refer to the V1 tab. Note that the list includes some strategies that are Not Approved, and these may not be used.
Parts 1 and 2 of Feature 4 address interior paints and coatings, interior sealants and adhesives. Parts 3, 4, and 5 of Feature 4 address flooring, insulation and furniture and furnishings, respectively. ANSI/BIFMA e3 and M.1 for furniture and furnishings may also be used, which are adherence pathways to CDPH within the WELL standard.
Documentation of compliance via WELL equivalencies or pathways for each product must contain both the numeric standard being applied and a data sheet or other documentation from the manufacturer showing compliance (including authorized approval logos, certificates, etc). These must be provided together in a single document for the auditor.
3) For product categories not covered by either Green Star South Africa or WELL, the team may propose an alternative standard in advance through the Dialogue, or consider the General CDPH Compliance exception. The team is also referred to the LEED definition of inherently non-emitting materials, which was approved in Dialogue post 15-0515 v 3.X Imperative 8 Clarification.
4) For all products that are permitted under this ruling, but that do not have emissions data showing compliance with CDPH Standard Method v1.1-2010, the team must also advocate to the manufacturer of the selected product that it attain CPH compliance for the product.
The Institute is exploring a regionally applicable pathway. Until that pathway is confirmed, other projects in South Africa that want to use this exception must submit a request through the Dialogue.
