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									LEED for Healthcare 1st Public Comment Period Comments & Responses
Environmental Quality Prerequisite 1

Requirement Number          CreditDescription
Prereq 1                    Minimum IAQ Performance
Prereq 1   Minimum IAQ Performance




Prereq 1   Minimum IAQ Performance




Prereq 1   Minimum IAQ Performance
Prereq 1   Minimum IAQ Performance
ment Period Comments & Responses


        Comments
        Do you believe that the requirements presented are
        appropriate for high performance healthcare facility
        construction? Please explain.
        No this prerequisite only addresses minimum ventilation
        requirements that every stgructure should be required to
        meet, which to me is not sufficient for healthcare facility
        requirements for health and infection control, therefore
        should not be called "high performance"


        Will the changes in this credit (if any) affect your ability to
        help transform the healthcare facility market? If so, please
        explain how and why.
        No

        Do you have any suggestions on how to improve the technical
        requirements of this credit? Please explain, providing
        citations to data and research where possible.
        EQc1 requirements for CO2 Monitoring are insufficient and
        inappropriate for healthcare facilities. DCV is defined by the
        need to reset outdoor air requirements based on variable or
        intermitent occupancies. Reset of control set points is
        accomplished when a change of population is sensed or
        scheduled. Base requirement eliminates more reliable and
        accurate methods of population determination by using only
        CO2. CO2 can be used to estimate populations together with
        outdoor airflow rate inputs, therefore would not be
        eliminated, only redefined by function. Detailed proposal
        revision will be forthcoming and details are dependent upon
        status of pending addendum "g" to ASHRAE 62.1-2007
        addressing Dynamic Reset (DCV).


        Do you have any general comments?
        universal search and replace "ASHRAE 62.1-2004" with current
        and more correct reference "ASHRAE 62.1-2007"
Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
Indoor Environmental Quality Prerequisite 1: Minimum IAQ
Performance AEI Comment: This prerequisite should include
the ventilation requirements prescribed by the 2006 AIA
Guidelines for Design and Construction of Health Care Facilities.


Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
The ambiguity as to what 'design minimum outdoor air rate'
means versus setpoint is confusing, and the reason for this
change is not clear. The increased stringency in relating to
airflow monitoring makes sense in a healthcare environment.
The clarification that it is only interior spaces that require co2
monitoring could be helpful.


Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
It seems that monitoring air rates as a way of assessing
pollutant concentrations is unnecessarily complicated when
alarms could instead be tied directly to pollutant levels. This
system is required in the GGHC.

Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
The requirements outlined in the GGHCshould be adopted.




Do you have any general comments?
No

Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
Minimum IAQ performance is certainly a requirement of any
healthcare facility, and is a key part of the infection control
program.
Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
While the requirements of ASHRAE 62.1-2004 are generally
adequate for office buildings, they do not adequately address
the ventilation needs of a healthcare facility, especially
regarding the needs of isolation, protective environment, and
laboratories. Both the 2006 AIA Guidelines and the ASHRAE
HVAC Design Manual for Hospitals and Clinics provide a more
detailed description of the ventilation requirements for
specific locations within the healthcare facility. JM
recommends the following revised text in the Requirements
section: Meet the minimum requirements of Sections 4
through 7 of ASHRAE 62.1-2004, Ventilation for Acceptable
Indoor Air Quality. Mechanical ventilation systems shall be
designed using the Ventilation Rate Procedure AND the
requirements of the 2006 AIA Guidelines for Design and
Construction of Healthcare Facilities Table 2.1-2, or the
applicable local code, whichever is more stringent.




Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
Minimum IAQ performance is certainly a requirement of any
healthcare facility, and is a key part of the infection control
program.

Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
No, the standards proposed ASHRAE 62.1-2004 on pagi 91 are
not specific to health care facilities that demand higher
standards, including increased air renovation


Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
Yes, the health care facilities have special demands to protect
the user who can be in a state of suppressed from normal
immunological functions. There is increasing evidence of the
role of indoor air quality in facilitating the transmission of
infective diseases. In addition the ever increasing number of
immunosupressed patients due to acquired or primary
immunological disorders, organ transplantation, and other
immune suppressive therapy ensures the responsibility and
increases the challenge of fulfilling the goals to promote
sustainable hospitals


Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
It would be better to adopt the requirements guidelines
established by the American Institute of Architects and the
American Society of Heating, Refrigerating and Air
Conditioning Engineers for health care construction.
LEED for Healthcare Committee Response




Thank you for your comments. At this time, LEED for Healthcare will maintain the
referenced standards as presented. However, this comment will be valuable during
the next LEED revision process




Thank you for your comments.




Thank you for your comments. At this time, LEED for Healthcare will maintain the
referenced standards as presented. EQ c1 is a means for ensuring effective delivery
of fresh air to occupied spaces, not a demand control ventilation strategy.




Thank you for your comment. However, with the publication of ASHRAE 170, the
refernece standard has been changed, and references to ASHRAE 62.1 have been for
the most part removed from this rating system. The one place where it remains, the
reference has been updated to 62.1-2007.
Thank you for your comment. The AIA Guidelines have been added as a reference
standard as you have suggested. Also, with the publication of ASHRAE 170, this
standard has been added as a refernece standard as well.




Thank you for your comments. At this time, LEED for Healthcare will maintain the
referenced standards as presented. However, this comment will be valuable during
the next LEED revision process.




Thank you for your comments. There is no monitoring of air rates required to meet
this prerequisite. In addition the reference standards have been chnaged to include
ASHRAE 170 and the AIA Gudielines for the Design and Construction of Helath Care
Facilities.




Thank you for your comment. However, with the recent publication of ASHRAE 170,
the refernece standard has been changed, and references to ASHRAE 62.1 have been
for the most part removed from this rating system.


Thank you for your comments.




Thank you for your comments.
Thank you for your comment. The AIA Guidelines have been added as a reference
standard as you have suggested. Also, with the publication of ASHRAE 170, this
standard has referneced in lieu of ASHRAE 62.1




Thank you for your comments.




Thank you for your comments. The reference standards have been chnaged to
include ASHRAE 170 and the AIA Gudielines for the Design and Construction of Helath
Care Facilities, in order to more directly address the ventilation issues that are
relevant to healthcare facilties.
Thank you for your comments. The reference standards have been chnaged to
include ASHRAE 170 and the AIA Gudielines for the Design and Construction of Helath
Care Facilities, in order to more directly address the ventilation issues that are
relevant to healthcare facilties.




Thank you for your comments. The reference standards have been chnaged to
include ASHRAE 170 and the AIA Gudielines for the Design and Construction of Helath
Care Facilities, in order to more directly address the ventilation issues that are
relevant to healthcare facilties.
LEED for Healthcare 1st Public Comment Period Comments & Responses
Environmental Quality Prerequisite 2

Requirement Number          CreditDescription
Prereq 2                    Environmental Tobacco
                            Smoke (ETS) Control




Prereq 2                    Environmental Tobacco
                            Smoke (ETS) Control
Prereq 2   Environmental Tobacco
           Smoke (ETS) Control
Prereq 2   Environmental Tobacco
           Smoke (ETS) Control
Prereq 2   Environmental Tobacco
           Smoke (ETS) Control




Prereq 2   Environmental Tobacco
           Smoke (ETS) Control




Prereq 2   Environmental Tobacco
           Smoke (ETS) Control
Prereq 2   Environmental Tobacco
           Smoke (ETS) Control




Prereq 2   Environmental Tobacco
           Smoke (ETS) Control
ment Period Comments & Responses


        Comments
        Do you have any suggestions on how to improve the technical
        requirements of this credit? Please explain, providing
        citations to data and research where possible.
        The requirement should make it clear that a designated
        smokers area outdoors should be separated from outdoor
        commons. In California one unintended side effect of ETS
        control is the potential for domination of outdoor commons
        areas by smokers.

        Do you have any general comments?
        Personally, I support smoke free campuses with a small
        concrete picnic table under a rain canopy for smokers away
        from entries and public open spaces.

        Do you believe that the requirements presented are
        appropriate for high performance healthcare facility
        construction? Please explain.
        Yes with the addition of protection for outdoor areas.

        Will the changes in this credit (if any) affect your ability to
        help transform the healthcare facility market? If so, please
        explain how and why.
        No, because this is already required in California.

        Do you believe that the requirements presented are
        appropriate for high performance healthcare facility
        construction? Please explain.
        I do not believe that smoking is appropriate anywhere in a
        health care facility. We should be using our buildings as
        educational tools as well as shelters. We are not sending the
        appropriate message by building smoking rooms in our health
        care facilities.

        Will the changes in this credit (if any) affect your ability to
        help transform the healthcare facility market? If so, please
        explain how and why.
I believe that Option 2 should be removed from EQ
Prerequisite 2: ETS Control. Many buildings and even entire
states are requiring complete smoking bans in buildings.
Implementing a totally non-smoking policy in hospitals should
be general practice, and a lot of facilities already do it. It will
affect our ability to transform the industry by discouraging
smoking (one of the biggest killers in the US) and by making
our buildings more efficient. Building dedicated smoking rooms
require more energy use and use more resources during
construction.


Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Remove Option 2




Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
With modifications as recommended below.

Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
Prerequisistes need to be achievable in order to avoid the
possibility that project teams will abandon LEED because they
believe it is impossible to achieve a prerequisite. Changes will
make this pr easier to understand and achieve.


Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Option 2 The term "impermeable deck-to-deck partition" is an
oxymoron. The term "fire-stopped deck-to-deck partition" or
"draft resistant deck-to-deck partition" or something else that
adequately reflects readily achievable good practice could
work. Taking 90 measurements of differential pressure in
fifteen minutes is overkill. The technician may be mildly
winded afterward! The requirement already contains a
threshold for deviation that establishes pass/fail performance,
e.g "minimum of 1Pa . . ." If the room has three adjacent
spaces and a corridor with a chase on two walls, the
performance verification will take one worker with an
instrument 90 minutes to complete. Observation for ten
minutes is more than adequate. A higher threshold - say 2.5Pa
(0.01 inch w.g.) would be more practical since reliable
measurement of 0.004 inches w.g. is not easily accomplished
without precision instruments. A partition that is properly
constructed should be able to achieve this level of
performance since that is a common standard for performance
of isolation rooms and infection control in remodeling of
hospitals. Option 3 The term "weather-stripped" is not the
appropriate language for an interior door. If there is "weather"
in the "hallway" we have bigger problems than fugitive
Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
Smoking should not be allowed anywhere in or around a
healthcare facility except in facilities where treatment requires
a designated smoking area. This area should maintain a
negative pressure relative to the surrounding area and should
be aggressively ventilated directly to the outside. This
requirement is outlined in the Green Guide for Health Care.


Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
No Changes

Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
The requirements outlined in the GGHC (outlined above)
should be adopted.




Do you have any general comments?
Smoking has no place in a healthcare facility except for when it
is required for treatment.

Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
Yes

Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
No

Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Suggest that Option 1 should be only option. In the US,
hospitals and health centers do not allow smoking. Also,
smoking contributes to particulates in the atmosphere.

Do you have any general comments?
No

Do you have any general comments?

Why are the requirements relaxed over what is in the GGHC?
Why allow smoking in a hospital at all?



Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
No, the requirements are not appropriate for high
performance healthcare facility construction. Infection control
should be a significant concern for material selection in
healthcare facilities. Durable products that meet healthcare
developed specifications have considered this and other
important criteria. Building codes include provisions to ensure
minimum requirements for new construction in order to
prevent safety and other hazards. In the United States the
demand for vinyl products is influenced by building code
requirements designed to prevent the spread of fire and
smoke. The building code requirements related to fire safety
are developed by the National Fire Protection Association
(NFPA), a private group that researches fire safety matters and
develops requirements to meet fire safety standards. An
alternative method to handle concerns regarding halogenated
compounds is on a compound and end-use specific basis,
taking into consideration the full end-use functionality, the
value in use, the overall societal value, any valid health
concerns, and comparing these against the same factors for
the proposed alternatives. In this manner a balanced,
defensible, scientific, cost-benefit assessment and free choice
can be made.
Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
The current language of this credit will negatively affect the
ability to help transform the healthcare facility market. USGBC
and GGHC have changed the language in the TSAC report from
chlorine to halogenated compound in an apparent effort to
dismiss the use of vinyl applications in the healthcare
environment. "Vinyl is the leading medical plastic used today.
It is a primary component in 25 percent of all medical products
and about 5 percent of all hospital wastes. It is the only
material that meets the criteria for flexibility, strength,
sterilization, resistance to kinking, optical clarity and cost-
effectiveness required for widespread use in medical settings"
(16). This LEED product is inconsistent with the USGBC TSAC
report, where even in its draft version clearly concluded "the
available evidence does not support a conclusion that PVC is
consistently worse than alternative materials on a life cycle
environmental and health basis" and ".does not support a
credit in the LEED rating system supporting the elimination of
PVC or any particular material." The USGBC does not seem to
recognize that a true market transition requires uniform
cooperation from all business sectors, and not just from a
select portion of the market that USGBC has slanted its
Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
In drafting a materials-avoidance credit, the USGBC has failed
to take into account sound science which includes USGBC's
assumption that all halogenated materials behave the same
which goes against established scientific principles. The
requirement that the various components "shall not be
manufactured with added halogenated materials" is a way to
ban fluoropolymers. The mention of PBT and dioxins appears
to imply that this negative credit is linked to the formation of
dioxins and furans during the various life-cycle phases of
fluoropolymer products. This assumption goes against
scientific findings. We recommend replacing the proposal that
various components "shall not be manufactured with added
halogenated compounds" by a recommendation to avoid using
hazardous substances based on proper risk assessments.
Material alternatives based on life-cycle analysis provide
designers with a more complete understanding of trade-offs
associated with material choice. In summary, the technical
requirements of this credit must be changed to ensure
consistency with sound scientific practices.




Do you have any general comments?
Credit 4.1 is contradictory to USGBC's February 2007 report
("Assessment of the Technical Basis for a PVC-Related
Materials Credit for LEED") issued by the USGBC Technical
Scientific and Advisory Committee (TSAC) which concluded
that: "no single material shows up as the best across all the
human health and environmental impact categories, nor as the
worst;" and, recommended "avoiding the 'blunt instrument' of
a materials-based credit so as to avoid steering designers to
choose materials with more negative impacts. This Association
strongly objects to consideration of a proposal that clearly
represents an attempted end-run around the TSAC review. This
credit is clearly not supported by the finding of the TSAC
report, unless you focus specifically on human health impacts
and leave out the broader environmental impacts. It is illogical
and counter-productive to eliminate a category of materials
about which we know the most, in favor of materials for which
the life-cycle impacts are less clear. In addition, Credit 4.1 is a
materials avoidance credit and does not meet the USGBC
Foundations document credit development criteria. Included
in the LEED Product Development and Maintenance Manual,
(see
http://www.usgbc.org/Docs/LEEDdocs/LEED%20Product%20De
Do you have any general comments?

I believe an additional option should be offered for eliminating
smoking on campus (property). This is a significant trend in
healthcare right now and could use more support.




Do you have any general comments?

EQ Prerequisite 2, Option 2 There should be no Option 2 for
hospitals.
LEED for Healthcare Committee Response




Thank you for your comments and clarification. This will be incorporated in the
revisions included in the second public comment draft.




Thank you for your comment.




Thank you for your comment.




Thank you for your comment.




Thank you for your comments and clarification. This will be incorporated in the
revisions included in the second public comment draft.
Thank you for your comments and clarification. This will be incorporated in the
revisions included in the second public comment draft.




Thank you for your comments and clarification. This will be incorporated in the
revisions included in the second public comment draft.




Thank you for your comment.




Thank you for your comment.
Thank you for your comments and clarification. This will be incorporated in the
revisions included in the second public comment draft.




Thank you for your comments and clarification. This will be incorporated in the
revisions included in the second public comment draft.
Thank you for your comments and clarification. This will be incorporated in the
revisions included in the second public comment draft.




Thank you for your comment.




Thank you for your comment.




Thank you for your comment.




Thank you for your comments.. Please review the revised credit included in the
second public comment draft.




Thank you for your comments and clarification. This will be incorporated in the
revisions included in the second public comment draft.
Thank you for your comments. This credit does not include any requirement
language related to vinyl products.
Thank you for your comments. This credit does not include any requirement
language related to vinyl products.




DEON: Do these responses adequately address the commenter?
Thank you for your comments. This credit does not include any requirement
language related to vinyl products.




Thank you for your comments. This credit does not include any requirement
language related to vinyl products.
Thank you for your comments and clarification. This prerequisite will be revised and
reissued for a second public comment period. This comment regarding rewarding
campus-wide no smoking will be valuable during the next LEED revision process.




Thank you for your comments. This will be incorporated in the revisions included in
the second public comment draft.
LEED for Healthcare 1st Public Comment Period Comments & Responses
Environmental Quality Prerequisite 3

Requirement Number          CreditDescription
Prereq 3                    Hazardous Material
                            Removal or Encapsulation
                            (Major Renovations Only)
Prereq 3   Hazardous Material
           Removal or Encapsulation
           (Major Renovations Only)
Prereq 3   Hazardous Material
           Removal or Encapsulation
           (Major Renovations Only)




Prereq 3   Hazardous Material
           Removal or Encapsulation
           (Major Renovations Only)
Prereq 3   Hazardous Material
           Removal or Encapsulation
           (Major Renovations Only)
Prereq 3   Hazardous Material
           Removal or Encapsulation
           (Major Renovations Only)
ment Period Comments & Responses


        Comments
        Do you believe that the requirements presented are
        appropriate for high performance healthcare facility
        construction? Please explain.
        Yes, occupants of a healthcare building should expect that they
        will not be exposed to any hazardous material outside of the
        specific hazards of their treatment. And - no I don't think this
        should be an EB credit. Many healthcare projects involve
        renovation and this should be a prerequisite whether the
        renovation is within the LEED® project boundary or not.
        Responsible owners are doing this as a normal practice for
        their own peace of mind and to avoid liability. It does not
        represent an unreasonable barrier to achievement.



        Will the changes in this credit (if any) affect your ability to
        help transform the healthcare facility market? If so, please
        explain how and why.
        This should be a prerequisite for any renovation of any size.
        How can there be justification for leaving hzardous material in
        place anywherre in a healthcare building?

        Do you have any suggestions on how to improve the technical
        requirements of this credit? Please explain, providing
        citations to data and research where possible.
There is no criteria to establish what a "major renovation" is.
Eliminate this limitation in the credit title. When would it be
acceptable to leave hazardous material unabated in a
renovation? Establishing a limit such as 10ft beyond the
confines of the renovated area sounds like a good idea from an
environmental point of view but could be difficult to achieve if
the renovated area is bounded by hard walls. The renovation
could go on idefinitely! Perhaps language like "within safe
reach of workers in the renovation area" could work. Revise
the 2nd sentence of the fourth bullet to read, "Remediate
contaminated materials with recognized procedures
performed by licensed abatement contractors to protect
workers, building occupants and the public." Revise the fifth
bullet to read "Identify and remedy the source of water and/or
moisture to prevent future mold development. The term
"mildew" is inappropriate in the context of indoor air quality
discussion since it refers to a white fungus that grows on
improperly stored lumber in outdoor timber mills. Eliminate its
use in this credit.

Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
No changes

Do you have any general comments?
No

Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
This credit seems sufficient as is.

Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
Healthcare facilities should have little trouble meeting this
credit given the focus on high ventilation rates.

Do you have any general comments?
No

Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
This credit seems sufficient as is.

Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
1. Is there a best practice regulatory standard that can be
referenced in here? 2. Letter from abatement contractor - This
should include decontamination of biological pathogens.

Do you have any general comments?
Not listed in Project Checklist on page 11.

Do you believe that the requirements presented are
appropriate for high performance healthcare facility
Yes. Lead based paint still exist in buildings built prior to 1979,
including hospitals. Lead based paint will be released into the
air as particles as part of any major renovation or demolition.
It is important to contain the lead based paint during these
activities.

Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
Yes. EPA is responsible for regulating lead based paint - related
hazards

Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Lead: On January 10, 2006 EPA proposed requirements to
minimize the introduction of lead hazards resulting from the
disturbance of lead-based paint during renovation, repair, and
painting activities in most housing built before 1978 (71 FR
1588). The USEAP Lead Repair and Renovation Rule will
address concerns about lead exposure during building
renovations and repairs. However, it does not address
concerns for lead contamination in neighborhoods where
buildings are being demolished. A concern is that lead from
buildings being demolished will be released into the air, and
that dust particles will contaminate the soil in surrounding
areas. Using lead containment methodologies in existing
building demolitions could be included as a LEED credit to
reduce lead exposures.




Do you have any general comments?
See above.
Do you have any general comments?
Add need for Certified Letter of Destruction for materials
removed from site, to be provided to the owner.
LEED for Healthcare Committee Response




Thank you for your support for this pre-requisite.




Thank you for your clarification request. We will remove the word "Major". See the
revised credit language in the second public comment draft.
Thank you for your comments. This will be incorporated in the revisions included in
the second public comment draft.




Thank you for your comments.


Thank you for your comments.




Thank you for your comments.




Thank you for your comments.




Thank you for your comments.
Thank you for your comments.




Thank you for your comments. Pathogens will be included in the second public
comment draft and will be further defined in the reference guide.




Thank you for your comments. This will be incorporated in the revisions included in
the second public comment draft.


Thank you for your comments.




Thank you for your comments.
Thank you for your comment. It is not clear whether you are requesting a change to
the present language or suggesting a reference standard for a future revision of the
rating system.




Thank you for your comment.

Thank you for your comment. This will be incorporated in the Documentation
section of the credit language as part of the revisions included in the 2nd public
comment period draft.
LEED for Healthcare 1st Public Comment Period Comments & Responses
Environmental Quality Credit 1

Requirement Number          CreditDescription
Credit 1                    Outdoor Air Delivery
                            Monitoring
Credit 1   Outdoor Air Delivery
           Monitoring
Credit 1   Outdoor Air Delivery
           Monitoring




Credit 1   Outdoor Air Delivery
           Monitoring




Credit 1   Outdoor Air Delivery
           Monitoring
Credit 1   Outdoor Air Delivery
           Monitoring
ment Period Comments & Responses


        Comments
        Do you believe that the requirements presented are
        appropriate for high performance healthcare facility
        construction? Please explain.
        No. Does not go far enough to promote increased ventilaiton /
        air change rates for healthcare and pressurization
        requirements. To avoid control problems, variable and highly
        dense spaces should be on seperate systems from those
        serving treatment and patient spaces.



        Will the changes in this credit (if any) affect your ability to
        help transform the healthcare facility market? If so, please
        explain how and why.
        Yes It would help demonstrate to heathcare operators the
        importance of more precise control can offer both the security
        of reliable infection control, together with reductions in
        operating/energy costs.

        Do you have any suggestions on how to improve the technical
        requirements of this credit? Please explain, providing
        citations to data and research where possible.
        Redefine control objective for densely occupied spaces as to
        "reset outdoor air intake set points based on changes in space
        population, as determined by any counting method, schedules
        with timers, or CO2 counting methods." This would help avoid
        failures or errors in control that potentially could put occupant
        health at risk, due to imprecise control of air used to maintain
        pressure flows and air change rates for infection control.
        Intake control using interior CO2 concentrations as the sole
        dynamic input should be specifically excluded for multizone
        systems and at least discouraged for large single zones. The
        health risk is too great for negative errors and excessive
        operating costs with positive errors.



        Do you have any general comments?
EQc1 requirements for CO2 Monitoring in densely occupied
spaces are insufficient and inappropriate for healthcare
facilities. DCV is defined by the need to reset outdoor air
requirements based on variable or intermitent occupancies.
Reset of control set points is accomplished when a change of
population is sensed or scheduled. Base requirement
eliminates more reliable and accurate methods of population
determination by referencing CO2 only. CO2 is not a
contaminent to be controlled, but can be used to estimate
populations together with outdoor airflow rate inputs,
therefore would not be eliminated as a possible technology,
only redefined by function. Detailed proposal revision will be
forthcoming in January. Details are dependent upon status of
pending addendum "g" to ASHRAE 62.1-2007 addressing
changes to section 6.2.7 Dynamic Reset (DCV).


Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
No, I think CO2 monitoring is overprescribed for air quality
control particularly in healthcare buildings where ventilation
typically exceeds ASHRAE Standard 62 requirements.
Eliminating this requirement could allow for another
"Healthcare" credit.

Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
Align the expression of intent with the requirements. the
requirements start with the word "install." The intent begins
"Provide capacity." Capacity can be provided with a BAS
system that is large enough for monitoring to be added in the
future. That does not appear to be the intent.


Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
The title of the credit is "Outdor Air Delivery Monitoring."
Revise the expression of Intent as follows: "Monitor outdoor
air delivery for compliance with design requirements." The
requirement is to monitor the system not make provision for it
at some point in the future.


Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
See Part 3

Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
See Part 3

Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
This credit will require complete reconfiguration of the
outdoor air intakes to accommodate the required air flow
measuring stations. This will impact space planning for the
facility. The outdoor air intakes will require more space. The air
flow measuring stations need a determined fixed straight
length of duct to be effective in their measurement. This
straight length of duct will have to be fitted upstream of any
mixed air plenums. The credit has high cost implications.
Airflow measuring stations are costly and can be difficult to
maintain and to keep calibrated.


Do you have any general comments?
See part 3

Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Lori Sutton. It is recommended that this requirement be
revised so that CO2 monitoring does not apply to patient care
areas. Additional outside air and supply air rates are required
Do you have any general comments?
The direct measurement of outside air is not necessary since
most systems use a tracking system that measures total supply
air and return air flow to maintain the differential that is
outside air.
LEED for Healthcare Committee Response




Thank you for your comments. At this time, LEED for Healthcare will maintain the
referenced standards as presented as the requirements are aligned with LEED 2009.
However, this comment will be valuable during the next LEED revision process.




Thank you for your comments. At this time, LEED for Healthcare will maintain the
referenced standards as presented as the requirements are aligned with LEED 2009.
However, this comment will be valuable during the next LEED revision process.




Thank you for your comments. At this time, LEED for Healthcare will maintain the
referenced standards as presented as the requirements are aligned with LEED 2009.
However, this comment will be valuable during the next LEED revision process.
Thank you for your comments. At this time, LEED for Healthcare will maintain the
referenced standards as presented as the requirements are aligned with LEED 2009.
However, this comment will be valuable during the next LEED revision process.




Thank you for your comments. At this time, LEED for Healthcare will maintain the
referenced standards as presented as the requirements are aligned with LEED 2009.
However, this comment will be valuable during the next LEED revision process.




Thank you for your comments. At this time, LEED for Healthcare will maintain the
referenced standards as presented as the requirements are aligned with LEED 2009.
However, this comment will be valuable during the next LEED revision process.
Thank you for your comments. At this time, LEED for Healthcare will maintain the
referenced standards as presented as the requirements are aligned with LEED 2009.
However, this comment will be valuable during the next LEED revision process.




Thank you for your comments.




Thank you for your comments.




Thank you for your comments. At this time, LEED for Healthcare will maintain the
referenced standards as presented as the requirements are aligned with LEED 2009.
However, this comment will be valuable during the next LEED revision process.




Thank you for your comments.




Thank you for your comments. At this time, LEED for Healthcare will maintain the
referenced standards as presented as the requirements are aligned with LEED 2009.
However, this comment will be valuable during the next LEED revision process.
Thank you for your comments. At this time, LEED for Healthcare will maintain the
referenced standards as presented as the requirements are aligned with LEED 2009.
However, this comment will be valuable during the next LEED revision process.
LEED for Healthcare 1st Public Comment Period Comments & Responses
Environmental Quality Credit 2

Requirement Number          CreditDescription
Credit 2                    Acoustic Environment:
                            Exterior Noise, Acoustical
                            Finishes & Room Noise
                            Levels




Credit 2                    Acoustic Environment:
                            Exterior Noise, Acoustical
                            Finishes & Room Noise
                            Levels
Credit 2   Acoustic Environment:
           Exterior Noise, Acoustical
           Finishes & Room Noise
           Levels




Credit 2   Acoustic Environment:
           Exterior Noise, Acoustical
           Finishes & Room Noise
           Levels
Credit 2   Acoustic Environment:
           Exterior Noise, Acoustical
           Finishes & Room Noise
           Levels




Credit 2   Acoustic Environment:
           Exterior Noise, Acoustical
           Finishes & Room Noise
           Levels
Credit 2   Acoustic Environment:
           Exterior Noise, Acoustical
           Finishes & Room Noise
           Levels


Credit 2   Acoustic Environment:
           Exterior Noise, Acoustical
           Finishes & Room Noise
           Levels




Credit 2   Acoustic Environment:
           Exterior Noise, Acoustical
           Finishes & Room Noise
           Levels
Credit 2   Acoustic Environment:
           Exterior Noise, Acoustical
           Finishes & Room Noise
           Levels


Credit 2   Acoustic Environment:
           Exterior Noise, Acoustical
           Finishes & Room Noise
           Levels

Credit 2   Acoustic Environment:
           Exterior Noise, Acoustical
           Finishes & Room Noise
           Levels
Credit 2   Acoustic Environment:
           Exterior Noise, Acoustical
           Finishes & Room Noise
           Levels
Credit 2   Acoustic Environment:
           Exterior Noise, Acoustical
           Finishes & Room Noise
           Levels
Credit 2   Acoustic Environment:
           Exterior Noise, Acoustical
           Finishes & Room Noise
           Levels
Credit 2   Acoustic Environment:
           Exterior Noise, Acoustical
           Finishes & Room Noise
           Levels




Credit 2   Acoustic Environment:
           Exterior Noise, Acoustical
           Finishes & Room Noise
           Levels
Credit 2   Acoustic Environment:
           Exterior Noise, Acoustical
           Finishes & Room Noise
           Levels




Credit 2   Acoustic Environment:
           Exterior Noise, Acoustical
           Finishes & Room Noise
           Levels




Credit 2   Acoustic Environment:
           Exterior Noise, Acoustical
           Finishes & Room Noise
           Levels
           Levels




Credit 2   Acoustic Environment:
           Exterior Noise, Acoustical
           Finishes & Room Noise
           Levels
Credit 2   Acoustic Environment:
           Exterior Noise, Acoustical
           Finishes & Room Noise
           Levels
Credit 2   Acoustic Environment:
           Exterior Noise, Acoustical
           Finishes & Room Noise
           Levels
Credit 2   Acoustic Environment:
           Exterior Noise, Acoustical
           Finishes & Room Noise
           Levels




Credit 2   Acoustic Environment:
           Exterior Noise, Acoustical
           Finishes & Room Noise
           Levels
Credit 2   Acoustic Environment:
           Exterior Noise, Acoustical
           Finishes & Room Noise
           Levels
ment Period Comments & Responses


        Comments
        Do you believe that the requirements presented are
        appropriate for high performance healthcare facility
        construction? Please explain.

        Yes, except for "acoutical commissioning". Any acoustical
        testing would necessarily be performed at the end of the
        construction period, after all interior finishes and furnishings
        were in place. Correcting any acoustical problems or
        deficiencies would be extremely costly and distuptive after the
        completion of construction. This is not a workable approach.


        Will the changes in this credit (if any) affect your ability to
        help transform the healthcare facility market? If so, please
        explain how and why.
        The credit mentions "acoustical commissioning" 4 times.
        "Acoustical commissioning" is not referenced in the Enhanced
        Commissioning credit, or an any other credit or prerequisite,
        nor is it found in the "FGI Draft Interim Sound & Vibrations
        Guidelines for Hospital and Healthcare Facilities" reference
        standard. An ill-defined and open-ended testing requirement
        will make compliance technically unfeasable.


        Do you have any suggestions on how to improve the technical
        requirements of this credit? Please explain, providing
        citations to data and research where possible.
        Follow the approach taken in the FGI refernce standard -
        provide a prescriptive path to compliance, rather than an "end-
        stage" testing path to compliance. Delete all requirements for
        "acoustical commissioning". Instead, include a Potential
        Techniologies & Strategies statement: "Engage a qualifed
        acoustical testing agency to perform acoustical commissioning
        of the interior spaces and building enclosure. Develop an
        acoustical commissioning plan to provide design phase review
        Do you have any suggestions on how to improve the technical
        requirements of this credit? Please explain, providing
        citations to data and research where possible.
        the use of computer screens that are hard to overlook helps.
Do you have any general comments?
This issue is controversial. HIPAA has been used to create
unsafe separations: uncreased privacy sometimes makes it
more difficult to create a safe patient environment.


Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
No, see above.

Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
Enclosing nursing and chart stations in IPU areas may create a
peaceful place for charting, but staff in a nursing station
typically need to be accessible and aware of what is happening
in the IPU. Electronic communications will never fully replace
hearing and seeing things directly on an IPU. I vote for an open
nursing station.

Do you believe that the requirements presented are
appropriate for high performance healthcare facility
Yes, again, patient outcomes, staff stress and error.

Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
Yes, this will have a huge impact on the healthcare market.
While some of these are a matter of practice, clearly reducing
noise levels in a facility will affect patient outcomes along with
reduced staff error and stress.


Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
No suggestions

Do you have any general comments?
No comments.
Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
Yes, again, patient outcomes, staff stress and error.

Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
Is the term "healing environment" in the Intent paragraph
used to delineate areas in the project where the credit
requirements are not applicable? That is a good idea and could
be strengthened by defining the spaces/areas where the
requirements apply. As written it seems to apply everywhere
and may introduce costs with no "healing" benefit. Does one
have to digest the reference standard to understand the
impact of the credit - probably not a good idea. Add language
to point the user in the right direction, e.g "patient occupied
areas, of nursing units, diagnostic and treatment areas and
staff occupied areas adjacent to public traffic areas."



Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Revise the second paragraph of the Requirements as folows:
"Design the facility's acoustic environment in patient occupied
areas of nursing units, diagnostic and treatment areas and staff
occupied areas adjacent to public traffic areas in accordance
with the following four sections of the 2006 FGI Draft Interim
Sound and Vibration Design Guidelines for Hospital and
Healthcare Facilities:


Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
If applied to patient care areas. There should be many areas
that would be exempt but the credit langauge does not offer
guidance.




Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Under exterior noise, reference noise from traffic, trains etc.


Do you believe that the requirements presented are
appropriate for high performance healthcare facility
Yes

Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
No, this is a nice addition to the LEED standards

Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.


1. Clarify whether emergency generators must comply with
table 1.4 during emergencies. It is normal to do testing during
daylight hours, however emergencies cannot be scheduled.
This makes a 5 dBA difference in the requirement. My
recommendation is to not require them to comply with
nighttime levels, but the most important thing is that it should
be clarified. 2. Clarify whether the design goals in 1.4 are for
peak noise levels or are averaged over some time. This mainly
affects emergency generators, which are typically tested
periodically for approximately 30 minutes. My
recommendation is to make these peak noise levels, or to
average them over a short enough time that emergency
generators would be prevented from creating major spikes in
the noise levels. The technology to make generators quiet is
readily available from multiple vendors.




Do you have any general comments?




The acoustical requirements are a wonderful addition to LEED.
Requirements of this type have long been needed in
healthcare.
Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
Yes

Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
I don't understand this question.
Do you have any general comments?
This credit should be about healing, not just privacy. There is
plenty of data about how quiet environments aid the healing
process. Also, why aren't paging and call systems addressed in
this credit?

Do you have any general comments?
Consider remote monitoring of patients so patient room door
could remain closed at all times for certain types of acuity.
Consider adding acoustic rating for verification.

Do you believe that the requirements presented are
appropriate for high performance healthcare facility
Yes, the requirements presented are generally appropriate
though some improvements could and should be made in the
interim guidelines document on which they are based.


Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
Good and feasible acoustical requirements will cause people
trying for LEED credits to consider improving the acoustical
environment and give qualified acousticians an opportunity to
contribute. We are already seeing results from the inclusion of
acoustics in LEED for Schools. Without these credits, one of the
problems we find is that the acoustics of LEED projects turn
out bad as people ignore acoustics in order to invest in other
areas that get credits.
Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
My main concern is that the cost of testing could cause some
to decide simply not to try to achieve one of these credits and
thus not do what should be done. Some of the testing such as
measurement of sound levels is simple. However,
measurement of facade performance by the cited ASTM guide
966 can be very difficult and expensive. It would be much
easier to measure sound levels inside with normal sources
outside to see whether the targets for inside levels are met.
Recognize that some parts of the US would not have local
qualified people to do the testing that would further increase
costs.


Do you have any general comments?
I am glad to see acoustics included in the LEED program. I am
not familiar with exactly how the rules are created and
modified, but hope the program has some flexibility for
adjustment based on experience after a few years if we see
that something is not working right.
Do you believe that the requirements presented are
appropriate for high performance healthcare facility
Yes. They do not repesent the best designs goals possible given
the state of the science, but they do improve healthcare design
in the right direction.

Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
The proposed changes will clarify the goals of the credit and
accelerate its adoption.

Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
The language associated with the credit is confusing. After the
heading "option 1" there should be the text: "(1 point)". This
would bring the creditinto typical LEED rating system language
and clarify for designers how two total credits are awarded.


Do you have any general comments?
I fully support the inclusion and promotion of acoustical design
metrics into green building standards. As evidenced by the
Center for the Built Environment (UC Berkley, 2005) surveys of
occupant satisfaction consistently rate the category of
acoustical comfort the lowest of all surveyed categories. In
fact, the studies shaow that acoustics is the only category that
has an unacceptable rating. It has further been shown that
acoustics directly impact worker productivity (ASID 200 and
2007). I look at productivity as the 'effieiceny' of the building
as a machine to enable tasks for the occupants. For a
healthcare facility, productivity is seen as accurate diagnosis
and increased recovery rates. I think that the proper acoustic
environment can improve both of those aims. Thanks for the
excellent work in this regard.


Do you believe that the requirements presented are
appropriate for high performance healthcare facility
The FGI draft interim sound and vibration design guidelins for
hospital and healthcare facilities provides reference to quality
criteria for facility construction.

Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
Including acoustics in LEED for Healthcare is a large step in
improving the quality of all healthcare facilities and also
pushing manufacturers to create quieter equipment.


Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Option 2 of the credit says "...design features to meet criteria
for sound and vibration..." but there are no guidelines
provided for vibration. These guidelines exist in the FGI draft.
Why aren't they included here? Noise from structureborne
vibration could easily negate all efforts in option 1 if not
addressed. This should be another point in my opinion.


Do you have any general comments?
The requirements for these points are pretty siginificant and
certainly the require the help of an acoustic consultant. I
would push that this credit is given more points and/or made a
pre-requisite point. Noise is becoming more and more of an
issue as we continue to develop our world and promote the
use of less materials, more energy efficient equipment, etc. As
a word of caution, the FGI draft includes sound masking
system. While this may be appropriate to use, it does not meet
the requirements of all facilities and the suggested masking
noise level is too high. I think it's appropriate that this has been
left out of this credit.

Do you believe that the requirements presented are
appropriate for high performance healthcare facility
In general,yes, but they need to be 1) more clearly stated,
2)directly related to the 3 factors described in the intent
statement above,and 3) additional requirements/metrics
needed for intelligibility, and modifications to metrics for
speech privacy. As it currently stands the 'Requirements' is
really focused on the HIPAA and even then it states 'HIPAA
guidelines should be followed'... manadatory language would
be "shall be followed". Then it refers to the 2006 FGI draft
interim guidelines, which are a draft and interim which means
they are still a work in progress. So yes, mostly appropriate,
but not entirely sufficient.


Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
We have an opportunity with this Acoustic Credit to ensure
that the indoor acoustic environment will be acceptable for all
speech/hearing issues. So I would like to restate the 'Intent' as
"to provide building occupants with an indoor acoustic
environment that supports 1) speech intelligibility in spaces
where precise oral communications are necessary to provide
proper medical care, 2) speech privacy between spaces where
private medical/financial conversations may be overheard by
unintended listeners, and 3) quiet restful spaces, free of
disruptive sounds, that are conducive to good health and
healing. Having this intent, we can then follow through with
Requirements that address each of these 3 goals, thereby
ensuring that the entire facility will meet with occupant
satisfaction with the indoor acoustic environment.




Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Option 1 (1 point) Speech Privacy Goal: 1st issue is criteria
Table 4-3 Closed Rms... there is an unresolved issue with the
meaning of 'Normal Privacy' as this was developed in ASTM E
1130 as a metric for distractions for the purpose of office
worker performance, and thus needs to be further investigated
for Healthcare issues. There is also an issue with the use of
these metrics in closed spaces, and this is currently being
researched at ASTM in WK8777 which is working on an
alternate approach. 2nd issue is the use of Table 4-4 Open plan
... this table specifically refers again to office workers which is
ok in the offices, but no reference is made to criteria for
Healthcare specific spaces such as reception, waiting,
pharmacy - where confidential information is exchanged - this
needs to be further research in terms of the user's perception
of need. Room Noise Levels: there should probably be a
reference to the ASHRAE Handbook 2007 Fundamental Chap
47 for the design guidelines, and a reference that for spaces
intended primarily for intelligibility that the low end of range
preferred, whereas for areas of privacy and healing
environments the high end is preferred. Acoustical Finishes:
Table 2-2 is entirely inadequate - it would be preferred to use
Do you have any general comments?
It's on the right track but needs better organization and more
current information in some places, but a really good start. I
would be willing to work on this with others.

Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Potential Strategies and Technologies · Select equipment,
movable and fixed, that only generates low sound energies. ·
In inpatient floor planning, avoid locating patient rooms
adjacent to elevators, stairwells, and visitor/public spaces.
(Sources of noise that cannot be easily controlled) · Locate
televisions in public and staff areas only where there is
adequate space for patients and staff to be out of hearing
range if they so choose. Consider remote speakers directional
speakers to minimize sound spillage from TV viewing areas.
Provide headsets and/or pillow speakers for televisions and
radios located in semi-private rooms or other locations where
sound can carry to other patients. · Specify and install sound-
absorptive wall treatment with an NRC of 0.7 or higher that
does not compromise cleaning or infection control.


Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
The credit requirements for acoustical comfort would be more
easily understood and implemented if the following changes
are made: - For each "Option", add the text: "Achieve all
requirements listed below" - Option 1, bullet point 2, change
to: "Design the facility to meet or exceed the "Confidential"
criteria from Table 4-3 Speech Privacy Goals for Enclosed
Rooms and the "Normal" criteria from Table 4-4 Speech
Privacy Goals for Open Plan Spaces." - Option 2, acoustical
commissioning, add the following text related to testing for
reverberation times: ". generally in accordance with the field
test method described in Appendix X2 of the current edition of
ASTM C423." - Exterior site noise, 2nd bullet refers to the
Tables in the AIA Guidelinies incorrectly. The text should read:
"Design the building envelope composite STC rating based on
Table 1.3-1 and Table A1.3-2, to meet the design goals in Table
1.3-1 for the Exterior Site Exposure Category that applies. - In
the Potential strategies section, a sentence should be included
recommending acoustical treatments for nurse stations. These
areas are a key source of noise, and acoustical treatments are
needed to reduce noise and increase speech privacy: "At nurse
stations and open staff areas, carefully integrate sound
Do you believe that the requirements presented are
appropriate for high performance healthcare facility
I believe the requirements are appropriate. Privacy between
two individuals in discussion or on the telephone are everyday
issues in buildings and health centers. Types of systems
installed, especially mechanical, affect daily work.


Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
This credit should be a prerequisite.




Do you believe that the requirements presented are
appropriate for high performance healthcare facility
The acoustic environment is an integral component of
environmental quality. Any measurement in LEED system is
better than none.

Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
This credit will improve the healthcare environment. Thank
you!

Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Separate this credit into two credits: EQcr2.1 Acoustic Indoor
Environment: Exterior Noises, and EQcr2.2 Acoustic Indoor
Environment: Interior Noises. The use of OPTIONS is confusing.
In LEED, an option is usually an alternate path for compliance.
By breaking the acoustic credit into sub-points, it will make it
easier to intuitively understand the difference between the
two(2)credits.

Do you have any general comments?
Accoustic credits need to be brought into other LEED
accreditation systems! Schools, Work environments (NC, CI) ...
Good work!
Do you believe that the requirements presented are
appropriate for high performance healthcare facility
The proposed credit is strong from a technical perspective, but
ommits completely the behavioural component to noise. You
can acoustically insulate out the ying-yang, but if the
occupants are not informed and consequently do not actively
participate in the reduction of noise in their environment, then
the results from these technical measures will be less effective.
Both technical AND behavioural aspects must be addressed in
this credit.


Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
see below

Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Include a component in the credit ensuring that the healthcare
organization has in place a "Quiet Environment" program. This
program would inform the occupants that this healthcare
center has put into place guidelines to reduce noise and thus
promotes a healing environment. For example, this can include
a work environment quiet policy, such as reducing the use of
speaker phones in an open space, or not talking loudly in
hallways, etc. Visitors should also be informed of this policy.
When the people are informed that this new healthcare center
is making every effort to have a quiet environment, their
behaviour should follow. Physical modifications alone will be
helpful, but will not provide a complete solution.




Do you have any general comments?
no.




Do you believe that the requirements presented are
appropriate for high performance healthcare facility
Yes.




Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
No.

Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Yes. They are as follows: Option 1, first major bullet, first minor
bullet, change Table 4-1 to 4.3-1. This is to conform to the AIA
Interim Guideline. Option 1, second major bullet, first minor
bullet, change Table 3-1 to 3.3-1. This is to conform to the AIA
Interim Guideline. Potential Technologies & Strategies, last
bullet: "Intall noise level sensor systems, which provide visual
feedback when acoustic thresholds are exceeded." This
statement is unclear. Where is the noise level to be sensed?
Visual feedback for what? What acoustic thresholds? The
intention of this statement must be better described.




Do you have any general comments?
Generally in conformance with the intention and format of the
AIA Interim Acoustical Guidelines for Healthcare Facilities.

Do you have any general comments?
Anthony Bernheim, HDR: Third bullet under Option 1: Sections
4.4 / 4.5 - What is being referred to here?


Do you have any general comments?
The requirements reference the 2006 FGI Draft Interim Sound
and Vibration Design Guidelines -AHA was not involved in
issuing this draft. Please remove the reference to AHA.


Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Specify and install flooring products to reduce footfall and cart
rolling noise. We are concerned that this requirement will gain
higher priority then other key flooring characteristics such as
durability, maintainability, slip resistance, and low drag
resistance for rolling objects (carts, gurneys, and portable
medical equipment). We believe this requirement should be
withdrawn or modified to identify that these are
characteristics to consider in specifying flooring products but
are secondary to other performance issues.

Do you believe that the requirements presented are
appropriate for high performance healthcare facility
This comment is a general support for inclusion of acoutical
requirements (see comments below). ASA's members will
submit detailed suggestions.

Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
The attached comment is a for general support for inclusion of
acoustical requirements by the Acoustical Society of America
(see comments below). ASA's members and sutaining member
corporations will submit detailed suggestions separately from
this comment. The important aspect of including design to
create quality acoutical spaces will be for the benefit of
patients at the healthcare facilities and the doctors and nurses
who are caring for them.


Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
No - This is a general support for inclusion of acoutical
requirements (see comments below). ASA's members will
submit detailed suggestions.

Do you have any general comments?
BACKGROUND In an important step towards proper building
design and use, the LEED for Healthcare rating system
recognizes speech privacy and an appropriate noise level as an
aspect of a facility's environmental quality (EQ). "EQ Credit 2
Speech Privacy" has the intent of designing for adequate sound
isolation will result in speech privacy, acoustic comfort, and a
reduction in noise-produced annoyance. It notes that the
Health Information Portability and Accountability Act (HIPAA)
mandates that all individually identifiable health information
communicated orally is kept private. The intent set out in the
HIPAA guidelines should be followed, providing adequate
speech privacy to patients while ensuring acoustic comfort,
and a reduction in noise-produced annoyance. Under this
credit, two points are possible towards LEED certification.
(Reference pgs. 97-99 of draft) ASA SUPPORT FOR LEED
PROPOSAL The Acoustical Society of America (ASA) takes the
position, in agreement with the LEED for Healthcare rating
system, that setting goals for acoustic privacy and comfort are
necessary elements in the best practices of healthcare
facilities. The ASA supports the proposal that the design of new
and existing healthcare facilities should meet certain acoustical
requirements to earn green building certification, and hence
endorses the inclusion of acoustic credits in LEED for
Healthcare ratings. ACOUSTICAL SOCIETY OF AMERICA The
Acoustical Society of America (ASA) began in 1929 and has
presently has 7,500 members who are engaged in various
aspects of acoustics, including helping to make the world a
quieter place to live. The ASA has organized many technical
LEED for Healthcare Committee Response




Thank you for your comment. Agreed. Our intent was not to limit commissioning to
after completion of construction. Your suggestion below to address the problem is a
good one. The rating system has been revised to reflect the changes suggested as
part of the revisions included in the 2nd public comment period draft.




Thank you for your comment. Agreed. Our intent was not to limit commissioning to
after completion of construction. Your suggestion below to address the problem is a
good one. The rating system has been revised to reflect the changes suggested as
part of the revisions included in the 2nd public comment period draft.




Thank you for your comment. Agreed. Our intent was not to limit commissioning to
after completion of construction. Your suggestion below to address the problem is a
good one. The rating system has been revised to reflect the changes suggested as
part of the revisions included in the 2nd public comment period draft.




Thank you for your comment. Good design still does matter. The Rating system is not
a substitute for good design,
Thank you for your comment. Pls see the ASA comment below. Also, standards
should have a vote, but not a veto, over good design.




Thank you for your comment. Pls see above.




Thank you for your comment. Hopefully, this credit will become a driver for a
technological or a design solution that can meet those needs as well as privacy
considerations.




Thank you for your supportive comment.




Thank you for your supportive comment.
Thank you for your supportive comment.



Thank you for your comment. To clarify, the intent was meant to cover the entire
facility. This will be further clarified in the Reference Guide. While raising the bar, the
objective here is to support market transformation, even though its applicability to
all spaces makes the achievement more difficult.




Thank you for your comment. To clarify, the intent was meant to cover the entire
facility. This will be further clarified in the Reference Guide.While raising the bar, the
objective here is to support market transformation, even though its applicability to
all spaces makes the achievement more difficult.




Thank you for your comment. To clarify, the intent was meant to cover the entire
facility. While raising the bar, the objective here is to support market transformation,
even though its applicability to all spaces makes the achievement more difficult.
Thank you for your comment. The reference Guide will clarify this point.




Thank you for your comment and your support.




Thank you for your comment and your support.




Thank you for your comment. The rating system is revised so that emergency power
generators during maintenance testing are covered. The Reference Guide will clarify
that the guidelines apply to maximum noise levels.




Thank you for your comment and support.
Thank you for your comment and support.




Thank you for your comments. Only the principal items referenced in the FGI
Guidelines have been included in this credit. Additional strategies, including paging
and call systems, can be submitted for consideration as exemplary performance
points. These will be detailed further in the Reference Guide.


Thank you for your comment. It has been added to Potential Technologies and
Strategies section.




Thank you for your supportive comments.




Thank you for your supportive comments.
Thank you for your comments. However testing is a small cost compared to the
design costs. We have made changes to the credit language to include "as necessary"
or "test sample rooms" as much as possible in order to address such concerns.




Thank you for your comments. The LEED tools are continuously updated and revised,
and this credit may absolutely be tracked and modified in the future.




Thank you for your supportive comments.




Thank you for your supportive comments.




Thank you for your comments. The current text has clarified the intent.
Thank you for your comments and support.




Thank you for your comments.




Thank you for your support.




Thank you for your comments. The HCC felt that vibration control was part of
standard practice today, It is referenced in the FGI draft. In terms of numbers of
points, this credit will remain at 2 points. However, your comment may be valuable
in future revisions of the credit language.
Thank you for your comments and support. It is important not to construct pre-
requisites that become barriers to the LEED program; hence, the LEED-HC committee
included Acoustics in the credit program.




Thank you for your comments. We recognize that the FGI document is interim, and
will update this credit to comply as that document is solidified. At the same time, it
seems unneccesary to reinvent the good work of that document that is approved by
FGI. Clarification language included in the second public comment draft.
Thank you for your comments. They are good guidelines at the detailed level that
can be incorporated into the The Reference Guide.




Thank you for your comments. This level of detail is best pursued by following the
interim guidelines as they are developed to address future standards developed by
the ASTM.
Thank you for your comment. We encourage you to contact the FGI task force.




Thank you for your comments. All such suggestions to the Potential Technologies
and Strategies section cannot be included in their entirety due to space limitiations
and will be forwarded on to the authors of the Reference Guide..
Thank you for your comments. The second public comment draft has included
changes meant to address your recommendations.




Thank you for your comments and support.




Thank you for your comments. At this time, LEED for Healthcare will maintain the
referenced standards as presented. However, this comment will be valuable during
the next LEED revision process.



Thank you for your comments and support.
Thank you for your comments and support.




Thank you for your comments. We have clarified the issue in the second draft.




Thank you for your comments and support. This comment will be valuable during
the next LEED revision process.



Thank you for your comments and support. We will add statements in the Refrence
Guide to address. Refer to the Green Guide for Health Care Operations, which is
preparing an Acoustics Operation credit.




Thank you for your comments.
Thank you for your comments and support. We will add statements in the Reference
Guide to address. Refer to the Green Guide for Health Care Operations, which is
preparing an Acoustics Operation credit.




Thank you for your comments.




Thank you for your comments and support.




Thank you for your comments.
Thank you for your comments. Sorry for the oversight. We will correct the editing as
requested for the first 2 bullets. With respect to your last column, The HCC will
address in the Reference Guide.




Thank you for your comments and support.




Thank you for your comments. Will clarify.




Thank you for your comment. It is the AIA/AAH (Academy on Architecture for
Health). This will be corrected in the second public comment draft.




Thank you for your comments. This is not a requirement, but is instead a potential
technology and strategy. A Rating System by its nature hyperfocuses on a limited
number of design charateristics. It is up to the designers themselves to consider all
characterisitcs and strike a balance between them.
Thank you for your comments and support.




Thank you for your comments and support.




Thank you for your comments and support.
Thank you for your comments and support.
LEED for Healthcare 1st Public Comment Period Comments & Responses
Environmental Quality Credit 3.1

Requirement Number          CreditDescription         Comments                                                          LEED for Healthcare Committee Response
Credit 3.1                  Environmental Quality     Do you believe that the requirements presented are
                            Management Plan: During   appropriate for high performance healthcare facility
                            Construction              The requirement to minimize noise pollution is not within the     Thank youfor your comment. We have incorporated many of these suggestions into
                                                      scope of the credit intent. Noise and vibration is addressed      what will be our next public comment review period and have specifically taken out
                                                      properly by GGHC MR c2.4 and those requirements have not          much of the detail as you have suggested. Some of this information will be included
                                                      been retained in this credit. The use of standardized ICRA        in the reference guide.
                                                      materials is the responsibility of the owner. The available
                                                      materials referenced in this credit may not be consistent with
                                                      the owner's infection control requirements and are deficient in
                                                      that they do not list all hospital departments and may classify
                                                      some departments in a different risk category than the owner
                                                      my dictate. The USGBC should not accept the responsibility to
                                                      determine what infection control measures are the medical
                                                      standard for all possible conditions. The paragraph on mold
                                                      and mildew is actually about moisture control. Air quality
                                                      professionals will be amused by the reference to mildew which
                                                      is a white fungus resembling frost that occurs on improperly
                                                      stored wood in unconditioned lumber mills - hence the name
                                                      "mill-dew." This fungus is not a variety of interest in modern
                                                      construction. The paragraph on ventilation system protection
                                                      has ambiguous language relating to the application of
                                                      temporary filters. If the intent is to address active systems
                                                      rather than all systems then modifications may avoid
                                                      questions and unnecessary expense. The informational
                                                      statement on VOC accumulation in soft materials is
                                                      unnecessary justification for the requirement that is
                                                      inconsistent with other statements of requirements. An
                                                      internet search did not return any sources for the text of
                                                      reference standard BS 5228. Local regulations that reference
                                                      BS 5228 available from internet sources require community
                                                      Will the changes in this credit (if any) affect your ability to
                                                      help transform the healthcare facility market? If so, please
                                                      explain how and why.
                                                      GGHC EQ c3.1 was developed prior to general understanding        Thank you for your comment. The rating system will be incorporated to reflect the
                                                      of 2006 AIA Guidelines and therefore includes information that changes suggested as part of the revisions included in the 2nd public comment
                                                      can be at cross purposes. This is an important credit for        period draft
                                                      transforming the market but has many flaws that should be
                                                      addressed before it is ready for the market. The credit is based
                                                      upon GGHC EQ c3.1. That credit was not coordinated with
                                                      2006 AIA Guidelines for Construction of . . . Requirements in
                                                      the Guidelines now clarify the owner/operator's responsibility
                                                      for infection control planning and mitigation requirements.
                                                      Changes in this credit will better align the credit with the
                                                      Guidelines. The paragraph on Noise and Vibration is difficult
                                                      for US project teams to use effectively. That may discourage
                                                      project teams from attempting the credit and any of its
                                                      environmental quality requirements. That would be
                                                      counterproductive.




                                                      Do you have any general comments?
                                                      Sorry to beat this credit up so hard but there are two              Thank you for your comment. We have broadened the narrative and have removed
                                                      constituencies to look out for here. 1. The construction            some of the information as you have suggested as part of the revisions included in
                                                      industry can implement specific measurable performance              the 2nd public comment period draft
                                                      standards. Experience indicates that if it isn't crystal clear or
                                                      there isn't a clear pathway to compliance, achieving the credit
                                                      will suddenly become "very expensive" which is code for "I
                                                      can't be bothered with it. Get your credits on your own dime."
                                                      For something as simple as construction waste diversion there
                                                      can be tremendous resistance to something as intuitive as on-
                                                      site segregation. Just try to achieve the credit in a market
                                                      where it takes more than two phone calls to find a hauler who
                                                      has perfected the process and reporting and suddenly it's a big
                                                      problem. 2. The "environment" meaning the physical world
                                                      and the people that directly and indirectly share the planet
                                                      temporarily with a construction project. When there are
                                                      aspects of a credit that are perceived as difficult to attain, then
                                                      other elements of that credit may not be attempted and the
                                                      "environment" suffers as a result. I hope you will find the input
                                                      valuable.




                                                      Do you have any suggestions on how to improve the
                                                      technical requirements of this credit? Please explain,
                                                      providing citations to data and research where possible.
                                       Modify bullet 1 as follows: For major renovations, additions       Thank you for your comment. The rating system will be incorporated to reflect the
                                       adjacent to occupied facilities or phased occupancy in new         changes suggested as part of the revisions included in the 2nd public comment
                                       construction, follow 2006 AIA Guidelines to establish an           period draft
                                       integrated Infection Control Team, comprised of the Owner,
                                       Designer and Contractor to evaluate infection control risk and
                                       document the required precautions in a project-specific plan.
                                       Utilize the Infection Control Risk Assessment (ICRA) standard
                                       published by ASHE and the CDC as a guideline for construction
                                       activities to assess the risk and to select mitigation procedures.
                                       This will apply to renovation projects and new construction
                                       projects where occupancy of the building is phased in during
                                       the construction process. Modify bullet 2 as follows: Moisture
                                       control - develop a moisture control plan to address measures
                                       that will maintain dry conditions to protect stored material and
                                       installed work from damage due to spills, line breaks, severe
                                       weather and other causes within areas under construction.
                                       Implement spill control measures to clean-up spills before they
                                       spread to other parts of the work. Address removal and
                                       disposal of water damaged materials susceptible to microbial
                                       growth. Revise the language of bullet 3 for clarity as follows: If
                                       permanently installed air handlers are used during
                                       construction, use filtration media on those air handlers with a

Credit 3.1   Environmental Quality     Do you believe that the requirements presented are
             Management Plan: During   appropriate for high performance healthcare facility
             Construction              The requirements are appropriate, but lack specificity with       Thank you for your comment. We broadened the narrative as you suggested as part
                                       respect to mold and mildew management. This may make it           of the revisions included in the 2nd public comment period draft. Some of this
                                       difficult to determine if the EQMP employed on a project will     information will be included in the reference guide.
                                       meet the requirements.

                                       Will the changes in this credit (if any) affect your ability to
                                       help transform the healthcare facility market? If so, please
                                       explain how and why.
                                       Yes, in preventing mold and moisture intrusion that is can lead Thank you for your comments.
                                       to mold exposure to occupants and sensitive populations.


                                       Do you have any suggestions on how to improve the
                                       technical requirements of this credit? Please explain,
                                       providing citations to data and research where possible.
                                       To add more specificity for mold and mildew requirements,        Thank you for your comment. We broadened the narrative as you suggested as part
                                       the committee should consider including similar language to      of the revisions included in the 2nd public comment period draft. Some of this
                                       LEED for Schools EQ Credit 10: Mold Prevention in the            information will be included in the reference guide.
                                       "Potential Technologies and Strategies" section of this credit.
                                       "A complete guide to preventing mold and reducing the
                                       probability of it recurring can be found in the Humidity Control
                                       Design Guide for Commercial and Institutional Buildings,
                                       available from ASHRAE and The GREENGUARD Environmental
                                       Institute offers its GREENGUARD for Building Construction
                                       Program. These documents contain a comprehensive overview
                                       of the principles and practices stated here and serve as
                                       valuable resources in constructing commissioning plans and
                                       operation and maintenance guides."




                                       Do you have any general comments?
                                       It would be good to have the mold and mildew requirements         Thank you for your comment. The rating system will be incorporated to reflect some
                                       for this credit as consistent as possible with LEED for Schools   of the changes suggested as part of the revisions included in the 2nd public comment
                                       EQ Credit 10.                                                     period draft. The credit won't align exactly with LEED for schools as you suggested
                                                                                                         as the needs related to healthcare facilities are somewhat unique.

Credit 3.1   Environmental Quality     Do you have any general comments?
             Management Plan: During   Note that fume is a technical term referring to metal vapors.     Thank you for your comment. The rating system will be incorporated to reflect the
             Construction                                                                                changes suggested as part of the revisions included in the 2nd public comment
                                                                                                         period draft

                                       Do you have any suggestions on how to improve the
                                       technical requirements of this credit? Please explain,
                                       providing citations to data and research where possible.
                                       include a no smoking policy for contractors                       Thank you for your comment. That is a good suggestion. The rating system will be
                                                                                                         incorporated to reflect the changes suggested as part of the revisions included in the
                                                                                                         2nd public comment period draft


Credit 3.1   Environmental Quality     Do you have any general comments?
             Management Plan: During   see technical comments                                            Thank you for your comments.
             Construction
                                       Do you have any suggestions on how to improve the
                                       technical requirements of this credit? Please explain,
                                       providing citations to data and research where possible.
Credit 3.1   Environmental Quality
             Management Plan: During
             Construction




                                       An excellent reference for this area is CAN/CSA Z317.13-03        Thank you for your comment. At this time we are going to hold off in referencing
                                       Infection control during construction or renovation of health     Z317.13-03. The HCC will consider including CAN/CSA Z317.13-03 in the next major
                                       care facilities. It provides a much more thorough and             LEED revision.
                                       systematic approach and includes documentation.

                                       Do you believe that the requirements presented are
                                       appropriate for high performance healthcare facility
                                       construction? Please explain.
                                       see technical comments                                            Thank you for your comments.

                                       Will the changes in this credit (if any) affect your ability to
                                       help transform the healthcare facility market? If so, please
                                       explain how and why.
                                       See technical comments                                            Thank you for your comments.
Credit 3.1   Environmental Quality     Do you have any suggestions on how to improve the
             Management Plan: During   technical requirements of this credit? Please explain,
             Construction              providing citations to data and research where possible.
                                       Smoking and Eating by construction workers in clinical areas      Thank you for your comment. We have incorporated the non-smoking requirement
                                       under construction contribute to potentially lingering debris     as part of the revisions in the 2nd public comment period draft. At this time
                                       that harbor bacteria and mold. Credit should require that         however, we have not excluded food products within the construction area.
                                       smoking and eating be prohibited in future clinical areas
                                       during construction.

Credit 3.1   Environmental Quality     Do you believe that the requirements presented are
             Management Plan: During   appropriate for high performance healthcare facility
             Construction              A comprehensive Environmental Quality Management Plan             Thank you for your comment. We broadened the narrative as you suggested as part
                                       should include strategies for protecting the building from        of the revisions included in the 2nd public comment period draft. This information
                                       moisture intrusion and consequently exposing occupants to         will be further developed in the reference guide.
                                       dangerous mold.

                                       Will the changes in this credit (if any) affect your ability to
                                       help transform the healthcare facility market? If so, please
                                       explain how and why.
                                       Yes. Moisture management should be included as a                Thank you for your comments.
                                       fundamental component of the standard construction practice
                                       for all projects, especially healthcare facilities.

                                       Do you have any general comments?
                                       LEED for Schools includes a separate credit within the EQ         Thank you for your comment. We have added some of the LEED for Schools
                                       section for Mold Prevention (EQ Credit 10). I am curious why      language to the Potential Technologies and Strategies section of the credit. In
                                       LEED for Healthcare does not include the same credit,             addition, EQ c3.1 includes the requirement to develop a moisture control plan to
                                       considering indoor air quality is such an important aspect of     address measures that will maintain dry conditions to protect stored on-site and
                                       the healing environment.                                          installed absorptive materials from moisture damage. Immediately remove from site
                                                                                                         and properly dispose of any materials susceptible to microbial growth and replace
                                                                                                         with new, undamaged materials. Also include strategies for protecting the building
                                                                                                         from moisture intrusion and exposing occupants to dangerous mold spores. EQ p3
                                                                                                         requires that you provide contract requirements for reporting and investigating
                                                                                                         suspect mold encountered in demolition. Remediate contaminated materials with
                                                                                                         recognized procedures performed by licensed abatement contractors to protect
                                                                                                         workers, building occupants and the public. Decontamination of biological
                                                                                                         pathogens should also be addressed if required. It also requires you to identify and
                                                                                                         remedy the source of water and/or moisture to prevent future mold development.

                                       Do you have any suggestions on how to improve the
                                       technical requirements of this credit? Please explain,
                                       providing citations to data and research where possible.
                                       Under Potential Technologies & Strategies, include language       Thank you for your comment. The rating system will be incorporated to reflect the
                                       that addresses mold prevention strategies, such as those          changes suggested as part of the revisions included in the 2nd public comment
                                       included in LEED for Schools EQ Credit 10: Mold Prevention. "A    period draft. This will be further developed in the forthcoming reference guide but
                                       complete guide to preventing mold and reducing the                did not specifically address GREENGUARD with the exception of listing as a Potential
                                       probability of it recurring can be found in the GREENGUARD        Technologies and Strategy.
                                       for Building Construction Program (formerly GREENGUARD
                                       Mold Protection Program), which offers comprehensive steps
                                       for preventing mold during the design, construction and
                                       operation phases of the project, including principles and best
                                       practices that serve as valuable resources."

Credit 3.1   Environmental Quality     Do you have any suggestions on how to improve the
             Management Plan: During   technical requirements of this credit? Please explain,
             Construction              providing citations to data and research where possible.
                                       Consider using the EPA language or cite it as a reference        Thank you for your comment. The rating system will include a refernce to CA DHS
                                       (http://www.epa.gov/iaq/schooldesign/controlling.html#Install under Potential Technologies and Strategies as part of the revisions included in the
                                       ation%20Sequencing). The language on page 100 is stronger        2nd public comment period draft
                                       and different than that used by the EPA in their sequencing
                                       guidelines. In addition, the list of items that are "wet" and
                                       "dry" is significantly shorter and may unfairly target those few
                                       items listed in the LEED document. Also, more detailed
                                       information concerning the complex phenomenon of VOC
                                       release and possible absorption by other materials is
                                       addressed in "REDUCING OCCUPANT EXPOSURE TO VOLATILE
                                       ORGANIC COMPOUNDS (VOCs) FROM OFFICE BUILDING
                                       CONSTRUCTION MATERIALS: NON-BINDING GUIDELINES,"
                                       issued the CA DHS. (See: http://www.cal-
                                       iaq.org/VOC/VOC.html)
Credit 3.1   Environmental Quality     Do you believe that the requirements presented are
             Management Plan: During   appropriate for high performance healthcare facility
             Construction              A comprehensive Environmental Quality Management Plan       Thank you for your comment. The rating system will be incorporated to reflect the
                                       should include strategies for protecting the building from  changes suggested as part of the revisions included in the 2nd public comment
                                       moisture intrusion and exposing occupants to dangerous mold period draft. This will be further developed in the forthcoming reference guide
                                       spores.

                                       Will the changes in this credit (if any) affect your ability to
                                       help transform the healthcare facility market? If so, please
                                       explain how and why.
                                       Yes. Moisture management should be included as a                Thank you for your comments.
                                       fundamental component of the standard construction practice
                                       for all projects, especially healthcare facilities.

                                       Do you have any general comments?
                                       LEED for Schools included a separate credit within the EQ          Thank you for your comment. We have added some of the LEED for Schools
                                       section for Mold Prevention (EQ Credit 10). We are curious         language to the Potential Technologies and Strategies section of the credit. In
                                       why LEED for Healthcare does not include the same credit.          addition, EQ c3.1 includes the requirement to develop a moisture control plan to
                                                                                                          address measures that will maintain dry conditions to protect stored on-site and
                                                                                                          installed absorptive materials from moisture damage. Immediately remove from site
                                                                                                          and properly dispose of any materials susceptible to microbial growth and replace
                                                                                                          with new, undamaged materials. Also include strategies for protecting the building
                                                                                                          from moisture intrusion and exposing occupants to dangerous mold spores. EQ p3
                                                                                                          requires that you provide contract requirements for reporting and investigating
                                                                                                          suspect mold encountered in demolition. Remediate contaminated materials with
                                                                                                          recognized procedures performed by licensed abatement contractors to protect
                                                                                                          workers, building occupants and the public. Decontamination of biological
                                                                                                          pathogens should also be addressed if required. It also requires you to identify and
                                                                                                          remedy the source of water and/or moisture to prevent future mold development.




                                       Do you have any suggestions on how to improve the
                                       technical requirements of this credit? Please explain,
                                       providing citations to data and research where possible.
                                       Under Potential Technologies & Strategies, include language        Thank you for your comment. The rating system will be incorporated to reflect the
                                       that addresses mold prevention strategies, such as those           changes suggested as part of the revisions included in the 2nd public comment
                                       included in LEED for Schools EQ Credit 10: Mold Prevention. "A     period draft. This will be further developed in the forthcoming reference guide but
                                       complete guide to preventing mold and reducing the                 did not specifically address GREENGUARD with the exception of listing as a Potential
                                       probability of it recurring can be found in the GREENGUARD         Technologies and Strategy.
                                       for Building Construction Program (formerly GREENGUARD
                                       Mold Protection Program), which offers comprehensive steps
                                       for preventing mold during the design, construction and
                                       operation phases of the project, including principles and best
                                       practices that serve as valuable resources.

Credit 3.1   Environmental Quality     Do you believe that the requirements presented are
             Management Plan: During   appropriate for high performance healthcare facility
             Construction              This credit is intended to minimize air pollution from fossil      Thank you for your comment. The HCC will consider including the fuel emission
                                       fueled vehicles and construction equipment during the              discussion in the rating system during the next revision.
                                       construction process. One of the existing Potential Strategies
                                       listed addresses practices to reduce diesel emissions from
                                       construction vehicles: it calls for reduced air emissions from
                                       construction equipment and non-road diesel engines by
                                       utilizing low sulfur fuel or biodiesel, or converting to natural
                                       gas powered engines. The credit does not specifically envision
                                       reduced emissions through the use of retrofits or new clean
                                       engines which can be equally if not more effective than the
                                       fuels noted. Nor does the credit envision reduced emissions
                                       through implementation of construction site anti-idling
                                       initiatives.


                                       Will the changes in this credit (if any) affect your ability to
                                       help transform the healthcare facility market? If so, please
                                       explain how and why.
                                       --

                                       Do you have any suggestions on how to improve the
                                       technical requirements of this credit? Please explain,
                                       providing citations to data and research where possible.
                                       The proposed modifications to the Requirements and Potential          Thank you for your comment. The HCC will consider including the fuel emission
                                       Technologies and Strategies section would clearly identify such       discussion in the rating system during the next revision.
                                       retrofits and cleaner engines as activities warranted credit
                                       under EQ Credit 3.1 (and also GGHC MR Credit 2.4)
                                       Requirements: Add language to identify retrofits and/or
                                       cleaner engines that exceed current regulatory standards as
                                       reduced emissions vehicles. Implement a plan to minimize
                                       vehicle and equipment idling when machines are not moving
                                       or working Develop a plan to reduce air emissions from
                                       construction equipment and other non-road diesel engines by
                                       utilizing ultra-low sulfur diesel fuel or biodiesel, and/or
                                       equipping such vehicles with EPA or California Air Resources
                                       Board verified emissions control technology, or (when
                                       available) requiring construction vehicles to utilize Tier 4
                                       engines. A list of EPA and CARB verified emissions control
                                       technologies can be found at:
                                       http://www.epa.gov/otaq/retrofit/nonroad-list.htm.
                                       Technologies and Strategies: Add the below language to
                                       provide more detailed guidance on anti idling and retrofits. 1.
                                       Adopt strictest local, state, or regional anti idling regulation as
                                       facility policy. If no policy exists, adopt an idle reduction plan
                                       that reduces nuisance odors and unnecessary idling associated
                                       with diesel emissions from construction equipment. The plan
                                       Do you have any general comments?
                                       On behalf of the Greater Boston Breathes Better (GB3)                 Thank you for your comment. The HCC will consider including the fuel emission
                                       partnership (for a list of partners see                               discussion in the rating system during the next revision.
                                       http://www.epa.gov/NE/eco/gb3/partners.html), the
                                       Consensus Building Institute is pleased to comment on the
                                       LEED Healthcare Rating System. We support EPA's suggestion
                                       for an EA Credit: Clean Diesel in LEED Green Building Rating
                                       System for New Construction version 3.0. We also support the
                                       incorporation of Green Guide to Health Care (GGHC)
                                       approaches to hospital construction into LEED for Healthcare,
                                       which we've understood to be a health sector-focused rating
                                       system that helps hospital's voluntary efforts to achieve credits
                                       under LEED New Construction version 3.0.

Credit 3.1   Environmental Quality     Do you have any general comments?
             Management Plan: During   Requirements Many states REQUIRE that all air handling units          Thank you for your comment. The rating system will be incorporated to reflect the
             Construction              have final filters installed for operation at ANY time. Minimum       changes suggested as part of the revisions included in the 2nd public comment
                                       would be approximately MERV 14.                                       period draft

                                       Do you have any suggestions on how to improve the
                                       technical requirements of this credit? Please explain,
                                       providing citations to data and research where possible.
                                       Add check and replace media filter as necessary during                Thank you for your comment. The rating system will be incorporated to reflect the
                                       construction.                                                         changes suggested as part of the revisions included in the 2nd public comment draft.
LEED for Healthcare 1st Public Comment Period Comments & Responses
Environmental Quality Credit 3.2

Requirement Number          CreditDescription
Credit 3.2                  Indoor Air Quality
                            Management Plan: Before
                            Occupancy




Credit 3.2                  Indoor Air Quality
                            Management Plan: Before
                            Occupancy
Credit 3.2   Indoor Air Quality
             Management Plan: Before
             Occupancy




Credit 3.2   Indoor Air Quality
             Management Plan: Before
             Occupancy
Credit 3.2   Indoor Air Quality
             Management Plan: Before
             Occupancy




Credit 3.2   Indoor Air Quality
             Management Plan: Before
             Occupancy
ment Period Comments & Responses


        Comments
        Do you believe that the requirements presented are
        appropriate for high performance healthcare facility
        construction? Please explain.
        The requirement OPTION 2 is most appropriate for healthcare
        facilities. While OPTION 1 may help to dilute chemical levels
        from new construction materials and processes, it does
        nothing to ensure that the indoor environment has an
        acceptable chemical load for occupancy. Therefore, OPTION 2
        should be mandatory for healthcare facilities.


        Will the changes in this credit (if any) affect your ability to
        help transform the healthcare facility market? If so, please
        explain how and why.
        Yes, in protection of sensitive populations.

        Do you have any suggestions on how to improve the technical
        requirements of this credit? Please explain, providing
        citations to data and research where possible.
        Furnishings have the ability to add chemicals to the indoor
        environment. Furnishings should be required to be in place
        prior to clearance sampling (not just suggested).


        Do you have any general comments?
        For healthcare environments, maximum concentrations should
        be established for more individual chemicals in addition to the
        current criteria. These additional criteria could reference
        nationally recognized lists or regional lists such as CA CRELs
        and OSHA PELs and TVL's.




        Do you have any general comments?
        the note for 4-PCH under the chart should have an asterisk
        instead of a bullet
Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Under Option on air testing, credit is proposed for meeting a
formaldehyde concentration of 27 parts per billion (ppb) and a
particulates (PM10) concentration of 50 micrograms per cubic
meter (?g/M3). The formaldehyde concentration should be
updated to a concentration that is considered more health
protective. Thus, US EPA has established a net formaldehyde
standard for a new RTP facility of < 16ppb -
http://www.epa.gov/rtp/new-
bldg/environmental/s_01445.htm . Given that healthcare
facilities will be occupied by sensitive populations (e.g.,
children, elderly, persons with compromised pulmonary
function such as asthmatics) the credit should be awarded only
for achieving a level of formaldehyde concentration below that
required for US EPA employees. A more appropriate
formaldehyde concentration would protect against both
irritation and asthma-like respiratory symptoms. Recently,
California Office of Environmental Health Hazard Assessment
(OEHHA) proposed both an 8-hour Reference Exposure Level
as well as a Chronic Reference Exposure Level (CREL) of 9
?g/M3 or 7 ppb -
http://www.oehha.ca.gov/air/hot_spots/crnr110207.html#rel2
007 and
http://www.oehha.ca.gov/air/hot_spots/pdf/FormaldehydePR.
pdf . This concentration is aligned with the 8 ppb chronic
minimal risk level established by the US Agency for Toxic
Substances and Disease Registry -
http://www.atsdr.cdc.gov/mrls/index.html . Since sensitive
populations are always present in a healthcare setting, perhaps
Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Lori Sutton. The USGBC should note that flush out has not
been proven effective upon analysis. Option 2 is a better
approach in conjunction with selection of low VOC materials. It
is recommended that Option 1 be deleted as a possibility for
compliance with this credit. Anthony Bernheim, HDR: As it is
written, one will not get valuable information. The Flush is out
is done first and the testing follows the flush out to find out if
there are any chemicals of concern being emitted (this after
trying to select all the correct materials that will not emit
chemicals of concern or chemicals in concentration of concern.
Here is how it should work: 1. get all the test data. 2. All mtls
have been tested to meet CA 013050. 3. Flush out bldg (floor
by floor or whatever works). 4. If testing is done accurately and
mtls selected corrrectly, then the job is done. 5. Flush out
really should not be needed if mtls selected correctly and have
already been tested by 01305. If flush is done would only need
one week or less. NOTE: Flush out will vary by season, time of
day, temperature, humidity, quality of outside air. Need to test
both outside and inside air. Example: a bad ozone day outside
will influence inside air. Lastlly, rather than have Marilyn
Black's list - this should be a chart for CA Section 01350 - an
expanded list of chemicals of concern. Also: the second OR
should be an AND (before Option 2).



Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
The main protective measures are not clearly stated on either
the clean form or the marked changes.


Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
Yes, the main concern here is due to evidence of extremely
serious adverse events in immunosupressed patients during
major renovations in hospitals.

Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Provide Barrier Systems : small projects with minimal dust
generation should use plastic sheeting, sealed sealed at full
ceiling height. Any projects that generates moderate to high
level of dust requires rigid, dust proof barrier walls with calked
seams. Large dusty projects need an entry vestibulate for
clothing changes with gasketed doors and tight seals along the
entire perimeter of the walls and at all walls penetration.
Debris should be removed in containers with tightly fitted
covers to circulate in restricted and predetermined circulation
areas. If chutes are used to conduct debris outside, HEPA filters
should be used in fans with negative pressure and chute
openings should be sealed not in use. Ventilation control: Air
handling systems in areas under construction or major
renovation should be turned of, and all supply and return
openings in construction area should be sealed. If this is not
feasible, provide filters not less than 95% efficient according to
ANSI/ASHRAE Standards 52.1 1992, section Gravimetric and
Dust Spot Procedures for Removing Particulate Matter. Heavy
dusty work may require dampering off or other forms of
blocking systems including: Negative pressure: Spaces under
construction should be maintained under negative pressure
compared to the adjacent areas not under construction, using
exhaust fans ducted to the outside or to be recirculated with at
least 95% filtration.
LEED for Healthcare Committee Response




Thank you for your comment. We discussed internally whether or not to make both
OPTION 1 and OPTION 2 mandatory. However, in the end, we needed to satisfy
humid climates where the building flushout would introduce humidity levels above
the recommended levels which may in turn may facilitate mold growth.




Thank you for your comment.




Thank you for your comment. We have revised the statement to clarify that; "all
finishes and furnishings" must be installed prior to flush out.




Thank you for your comment. In addition to lowering the tolerances for the VOC
emission levels, we have added the following to the PT&S section of the credit. "For
additional chemical testing criteria that is not required as part of this credit, you may
reference nationally recognized lists or regional lists such as the California Office of
Environmental Health Hazard Assessment (OEHHA) Chronic Reference Exposure
Levels (CREL), the Occupational Safety and Health Administration – (OSHA)
Permissible Exposure Limits (PEL) and American Conference of Governmental
Industrial Hygienists (ACGIH) Threshold Limit Values (TLV)."



Thank you for your comment. The rating system will be incorporated to reflect the
changes suggested as part of the revisions included in the 2nd public comment
period draft.
Thank you for your comment. The rating system will be incorporated to include
additional information and clarified threshold limits as part of the revisions included
in the 2nd public comment period draft.
Thank you for your comment. We discussed internally whether or not to make both
OPTION 1 and OPTION 2 mandatory. However, in the end, it was determined that we
needed to provide a selection for either OPTION 1 or OPTION 2. OPTION 1 would be
allowed where materials containing higher levels of VOC are installed and OPTION 2
would be allowed in humid climates.




Thank you for your comment. Most of this will be covered under EQ c3.1 which will
also be further developed in the upcoming reference guide.




Thank you for your comment.
Thank you for your comment. Most of this will be covered under EQ c3.1 which will
also be further developed in the upcoming reference guide.
LEED for Healthcare 1st Public Comment Period Comments & Responses
Environmental Quality Credit 4
The LEED for Healthcare Committee has requested that the language in EQc4 restricting the use of materials containing phth
developed and pilot through the LEED Credit Pilot Library that address the EPA Chemical Action Plan. All credits in the pilot l
become part of the LEED rating system. For more information on the Pilot Library, or to participate, please visit www.usgbc.


Requirement Number           CreditDescription
Credit 4




Credit 4
Credit 4
Credit 4
Credit 4
Credit 4
Credit 4




Credit 4




Credit 4
Credit 4
Credit 4
Credit 4
Credit 4
Credit 4
Credit 4




Credit 4




Credit 4




Credit 4
Credit 4
Credit 4




Credit 4




Credit 4
Credit 4
Credit 4
Credit 4
Credit 4
Credit 4
Credit 4




Credit 4
Credit 4
Credit 4
Credit 4
Credit 4
Credit 4
Credit 4
 ment Period Comments & Responses

ested that the language in EQc4 restricting the use of materials containing phthalates be removed from the credit to become the basis for
Pilot Library that address the EPA Chemical Action Plan. All credits in the pilot library must go through public comment and USGBC memb
more information on the Pilot Library, or to participate, please visit www.usgbc.org/pilotcreditlibrary.


             Comments
             Do you have any suggestions on how to improve the technical
             requirements of this credit? Please explain, providing
             citations to data and research where possible.
             Credit could be given for products that can be effectively
             maintained with non-toxic, low VOC products. Low VOC
             building materials may sometimes require (or staff may tend
             to use) high VOC waxes and cleaning products.


             Do you have any general comments?
             While difficult to enforce, the preferred cleaning products for
             each material should be part of our evaluation for choice.


             Do you believe that the requirements presented are
             appropriate for high performance healthcare facility
             construction? Please explain.
             Yes, if cleaning is included.

             Will the changes in this credit (if any) affect your ability to
             help transform the healthcare facility market? If so, please
             explain how and why.
             In general yes.

             Do you believe that the requirements presented are
             appropriate for high performance healthcare facility
             Many of the requirements are appropriate; some are not &
             need to be changed.




             Will the changes in this credit (if any) affect your ability to
             help transform the healthcare facility market? If so, please
The intent to optimize IAQ is obviously an important &
appropriate focal point for healthcare & other buildings. These
following comments pertain to Group 3:Flooring Systems


Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
*Current description under first bullet says "carpet & resilient
systems shall meet CHPS 01350." Why just carpet & resilient?
All other flooring systems should undergo the same scrutiny,
right? *The 3rd bullet is confusing. Is it referring to flooring
systems or adhesives? *The reference to 'no phthalates' in
flooring systems should be removed. This is another example
of a biased, unfounded preference being inappropriately
included as a requirement. It's inconsistent with all other LEED
systems & not of sound science. First, it's important to
recognize that "phthalates" is a very broad category of
materials with a wide-variety of characteristics. Examples: -PET
(polyethylene terephthalate) is safely used to make drink
bottles & then often used as a recycled filler -Glycolated PET
(i.e., PETG) is made by recycling PET bottles and would be
prohibited if all phthalates are excluded. -Polyester phthalates
are widely used as coating materials and have never been
implicated in any health issue -Phthalate plasticizers - likely the
material being (inappropriately) focused on in this draft,
though that detail is uncertain & unjustified. Secondly, it's
another example of the "same wolf in different sheep clothing"
mentioned earlier It continues to be obvious there are folks
developing this system who choose to disagree and ignore
Do you have any general comments?
*There are many different types of "phthalate" plasticizers
with varying compositions, properties and toxicology. It
appears the LEED-Healthcare team (& thus USGBC) is
attempting to preempt a variety of governmental and
regulatory agencies by directing away from phthalates
currently not subject to any regulation. This is an inappropriate
action to be taken. Statements regarding phthalate plasticizers
as a general class should not be made especially since
individual plasticizers vary so widely. Vinyl backed carpet
products containing low levels of phthalate plasticizers and
meeting the Green Label Plus criteria also comply with CHPS
01350 emission requirements. Similarly, hard surface flooring
products containing low level phthalate plasticizers and
meeting the FloorScore criteria also comply with CHPS 01350.
CHPS 01350 is an accepted protocol within multiple LEED
systems and a unique "no phthalate" preference should not be
inconsistently interjected into this system, especially since safe
product performance has been demonstrated by many flooring

Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
No, the requirements should be based on a scientific approach,
IAQ standards, and testing methods currently available to
evaluate the indoor air performance of products. As outlined in
Question 1 response above, performance requirements need
to be utilized in lieu of two proprietary statements being
inserted into the list of standards being recommended for
utilization. Note that several flooring and wallcovering
products that include phthlates are Green Guard Certified.
(http://www.greenguard.org/Default.aspx?tabid=12 ) In
addition, it is assumed that phthlates are being de-selected in
the proposed credit, because of phthlates being in vinyl tubing
(in relation to male neonates). Note that the LEED HC is a
building standard, NOT a medical device standard. There is no
evidence that supports deselection of phthlates from building
materials. Products with phthlates utilized in healthcare
environments have a strong history of providing safe,
maintainable, durable, and cost effective solutions within a
demanding environment.


Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
Yes, as design professionals look to truly change the healthcare
marketplace, we need to have consistent guidelines to follow.
Throughout the credit, there are references to standards that
are based in performance. This makes sense and is easily
understood and followed by a design professional. There is a
huge inconsistency in that there is a proprietary 'deselection'
bullet points added into the listing, which are totally
inappropriate: "Ceiling tiles (including suspended acoustical
tiles) and wall coverings shall contain no polybrominated
diphenyl ethers (PBDE - a flame retardant) or phthalates."
"Flooring systems shall contain no polybrominated diphenyl
ethers (PBDE) or phthalates." Both of these statements are
proprietary and not directly relevant to environmental quality.
There is no evidence that states there is an environmental or
human risk factor using phthlates in building materials. This is
consistent with comments for MR Credit 4 and deselection of
product versus selecting the appropriate product through life
cycle analysis for the appropriate application. In addition, most
design professionals will not know the meanings of phthlates.
If a user of the guideline asks for clarification, this clearly
becomes a deselection criterion for PVC, which is not
appropriate according to the USGBC PVC improve the findings.
Do you have any suggestions on how to TSAC report technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
See response to Question #1 above.

Do you have any general comments?
See response to Question #1 above.
Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
No. Please see our comments in question #1 for explanation.


Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
Yes. Our PVC-backed carpet products contain Diisononyl
phthalate (DINP), and therefore this proposed credit would
exclude our PVC-backed carpet products from healthcare
facilities. In 2006, after an extensive life cycle study, the
European Commission Joint Research Centre found no human
health risk to workers, consumers, or humans exposed via the
environment to DINP used as a PVC plasticizer. (Official Journal
of the European Union, C 90/4, April 13, 2006, Part 5. Available
at (last accessed on October 22, 2007):
http://eurlex.europa.eu/LexUriServ/site/en/oj/2006/c_090/c_
09020060413en00040028.pdf) The study also found no risk to
the atmosphere, aquatic ecosystem or terrestrial ecosystem
from such use of DINP. For this reason, we believe the
categorical exclusion of all phthalates is overly broad, and that
the use of the specific phthalate DINP as a plasticizer in PVC
should be permitted. Without a provision allowing such use of
DINP, the benefits of our PVC-backed carpet products, from
improved acoustics to ergonomic advantages, will not be
realized in healthcare facilities. In addition, after a thorough
and detailed study of PVC, the USGBC's TSAC concluded that
PVC was not consistently better or worse than alternative
materials. By excluding all flooring systems that contain
Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Yes. The use of the specific phthalate DINP as a plasticizer in
PVC-backed carpet should be permitted. Please see our other
comments in questions #1 and #2 for further explanation.


Do you have any general comments?
We believe the suggestion to "Avoid paints with added
antimicrobials" is unrealistic, as nearly all paints, to our
knowledge, contain antimicrobial preservatives. In addition, to
the extent these requirements exceed those imposed by the
EPA, which evaluates and approves antimicrobials for
particular uses, the USGBC should provide a scientific rationale
for the more stringent treatment.
Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
I do not. The Technical and Scientific and Advisory Committee
of the USGBC advised in their report against material-
avoidance credits that architects and builders would be
directed toward materials that have greater negative impact
over their lifetimes than the products being avoided. The last
bullet point of Group 2 Wall and Ceiling Finishes eliminates the
use of phthalates in wallcoverings. This Credit is not based on
scientific data. The following are some of the things that
should be taken into consideration: ·Phthalate plasticizers
have been used successfully used in flexible vinyl compounds
for over half a century. ·There are numerous phthalates with
varying properties. The credit is broad and eliminates all
phthalates. ·Indoor Air Emissions Testing of our wall
coverings has not shown any emissions of phthalate plasticizer
by California 01350 or Greenguard testing protocol. ·The
credit already has indoor air emissions testing requirements
Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
This credit should not be adopted as written. It would
eliminate many wallcovering products that achieve their
flexibility, hand and properties using phthalate plasticizers.
These products offer safety, aesthetics and performance to the
healthcare industry and help to control the costs of healthcare.




Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
The last bullet point of Group 2 Wall and Ceiling Finishes that
states "Ceiling tiles and wall coverings shall contain no
polybrominated diphenyl ethers(PBDE-a flame retardant) or
phthalates" should be changed to delete the "or phthalates".

Do you have any general comments?
Our company produces both vinyl wallcoverings as well as
other wallcoverings. We take great pride in the products we
produce and the aesthetics and performance they bring to our
customers. We also take very seriously our commitment to the
environment both with the products we produce and also at
our manufacturing locations. We were one of the first
companies to develop water base print technology. We have
received the Ohio Governor's Award for plant emissions
reduction of over 90%. None of our wallcoverings are
produced using lead, cadmium, or mercury compounds. We
produce GREENGUARDâ certified wallcoverings for low
emissions and comply with the Collaborative for High
Performance Schools based on California 01350. We offer
wallcoverings containing recycled content. We have initiated a
take back program for wallcoverings removed from
installations where our wallcovering will be installed. We have
developed products not only using our own fabric backed
wallcovering but also those of other wallcovering
manufacturers. All of our vinyl wallcoverings are UL labeled.




Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
Emission requirements of this credit are appropriate for
healthcare facilities. However, it is inappropriate to assume
that the content-based requirements for adhesives, paints,
wood products, and insulation will serve the intent of this
credit. Further it should be noted that the referenced Section
01350 criteria does not require compliance with the emissions
levels until 14-days after installation. Thus, the reference to
installers should likely be removed from the Intent section of
this credit.
Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
Manufacturers in many industries are proactively addressing
emissions issues associated with their products. The best way
to determine IAQ issues associated with a product is to
measure chemical emissions. For product types where this
credit only requires content-based emissions, this credit fails
to recognize manufacturers that are proactively measuring and

Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
General Recommended that emissions requirement for all
products should read: "products installed in the building
interior should meet the indoor air quality requirements of
CA's Special Environmental Requirements Specifications
Section 01350 (as specified in CA DHS Practice
CA/DHA/EHLB/R-174). An independent laboratory should
conduct testing and modeling should use the standard office
building protocol parameters. The following programs
currently use the 01350 requirements for compliance: ·
Carpet and Rug Institutes' Green Label Plus Program (for
carpet and carpet related products only) · Collaborative for
High Performance School low-emitting Materials Table ·
GREENGUARD Product Emission Standard for Children &
Schools · Scientific Certification Systems Indoor Advantage
Gold Certification Program Note that the programs are listed in
alphabetical order. ADHESIVES and PAINTS The requirements
for adhesives, sealants, paints, and coatings only include
content based VOC limits. These VOC content limits were
developed to reduce smog formation in outdoor air. VOC
content does not provide a surrogate for the amount or type
of chemicals that will be emitted into the indoor environment
during use. The methods used to determine VOC content are

Do you have any general comments?
The emissions requirements of MR Credit 5 for Furniture and
Furnishings should be moved under this credit as OPTION 5,
and the available credits for low-emitting products should be
increased from 4 to 5. We submitted separate comments
related to this credit. Section 01350 includes requirements for
a very limited list of chemicals based on the CA OEHHA CRELs
and does not include criteria for TVOC. This is inconsistent with
other requirements of the standard that include more robust
requirements based on nationally recognized toxicology lists.
For example, EQ Credit 5 requires comparison of outside air
intake contaminant concentrations against more complete,
nationally recognized lists including OSHA PELs, ACGIH TLVs,
and NIOSH RELs. Also note that while Section 01350 does not
include TVOC criteria, EQ Credit 3.2 requires the building to
meet specific TVOC criteria for clearance. For the overall IAQ
management plan of the building to work, it will be necessary
to align the product specific emissions goals with the building
IAQ clearance goals. Since GREENGUARD Children and Schools
program includes TVOC criteria that will help ensure that
building clearance goals are met, this program should be
referenced for all general comments?
Do you have any emissions based requirements.
Group 5 should be an EA credit and not fall under IEQ.




Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
1. This is a good format that can be used for MR credit 3.1 - 3.4
& MR credit 4.1 2. Under potential strategies -' use
formaldehyde free' - Call out 'no added formaldehyde'. Wood
has some natural formaldehyde in it.

Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
This response is submitted by the Resilient Floor Covering
Institute (RFCI). RFCI, the products of its members, and its
environmental programs are described in detail in our
response to Question 4 for MR Credit 4.1. By requiring the
elimination of ingredients in a flooring system which
contribute to the overall durability of a key building
component will only result in added environmental impact as
these flooring systems will need to be replaced more often.




Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
This response is submitted by the Resilient Floor Covering
Institute (RFCI). RFCI, the products of its members, and its
environmental programs are described in detail in our
response to Question 4 for MR Credit 4.1. Current flooring
adhesive systems use phthalates as a coalescing agent as well
as providing improved adhesion to the subfloor. These
performance characteristics are important for the successful
installation of flooring materials in healthcare facilities. The
intent of this credit is to "reduce the quantity of air
contaminants that are odorous, irritating and/or harmful to
the comfort and well-being of installers and occupants."
Because of the high molecular weight of phthalates ( low vapor
pressure), results of emissions tests conducted for FloorScore
and other IAQ programs normally produce no emissions - thus
eliminating the use of phthalates does not accomplish the
stated intent of this credit and only reduces the performance
of flooring installations.
Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
This response is submitted by the Resilient Floor Covering
Institute (RFCI). RFCI, the products of its members, and its
environmental programs are described in detail in our
response to Question 4 for MR Credit 4.1. This credit should
follow the stated intent of the credit in reducing the quantity
of air contaminants. The correct approach is outlined under
the first section under Group 3: Flooring Systems where the
requirements for low-emitting materials are based on
California Section 1350. Section 1350 is based on emissions
limits on specific chemicals based on actual health risk
assessments developed by state of California health officials
Do you have any general comments?
The Resilient Floor Covering Institute (RFCI) submits the
following general comments regarding Draft EQ Credit 4: Low-
Emitting Materials. Reducing air contaminants is a worthy goal
and is being accomplished by the various voc emissions
programs for adhesives which have been introduced in recent
years. However, there is no scientific basis for eliminating the
very broad category of phthalates based on the objective of
reducing emissions. There are many types of phthalates used
for a variety of purposes of which there is no evidence that
they are harmful and that phthalates contribute to an increase
in air contaminants.

Do you have any general comments?
We encourage the use of GREENGUARD Children & Schools
emissions standards as the default in these documents, rather
than CA 01350. The GREENGUARD Children & Schools criteria
requires products meet the CREL's in 01350, but also require
no measurable levels of phthalates and no chemical greater
than 1/100th available TLVs, which have been established to
product workplace workers including installers. The
GREENGUARD test method and standards are publicly
available at www.greenguard.org. Under Potential
Technologies & Strategies, suggest the following addition:
Specify products that meet GREENGUARD Children & Schools
standard, which requires products meet not only the chronic
RELs of CA 01350, but also require no measurable emissions
levels of phthalates, total aldehydes, and 1/100th listed VOCs
with Threshold Limit Values. Products are screened and
controlled for hundreds of VOCs not covered by the minimum
CA 01350.




Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
Yes, to some extent. However, we have concerns about some
of the specific language contained in these credits, as outlined
below. We believe that sustainability programs such as LEED-
Healthcare should recognize both product formulation criteria
and those products that, when used, minimize the risk of
harmful acute and chronic inhalation exposures in building
occupants. We urge the USGBC to embrace limits on chemical
emissions rather than bans on ingredients.




Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
Yes. We applaud the LEED-Healthcare Committee for
expanding the breadth of products for which chemical
emissions criteria should be applied. We also support the
committee's desire to expand chemical emissions criteria to
product types that may affect outdoor air (GROUP 5).
Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
GROUP 1: INTERIOR ADHESIVES & SEALANTS While measuring
VOC content may assist in minimizing chemicals in the indoor
environment, this credit, as written, does not address chemical
emissions and indoor inhalation exposures, which would be
protective of installers and building occupants. Chemical
content analysis is not sensitive or specific enough to limit
inhalation exposure to the low levels of exposure being
required for indoor air. As such, we recommend the following
language be added: "Interior adhesives and sealants installed
in the building interior should meet the indoor air quality
requirements of CA's Special Environmental Requirements
Specifications Section 01350 (as specified in CA DHS Practice
CA/DHA/EHLB/R-174) or the GREENGUARD Test method
TM.P066 (www.greenguard.org). Testing should be conducted
by an independent laboratory and modeling use should be the
Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
No, just because a product does not have the chemical du jour,
does not mean it is safe. Building science is just that....a
science, therefore use science to select materials. Please use
performance based metrics to specify products. Greenguard
for instance is an extremely rigorous standard for products to
adhere to. It requires auditing and looks at all chemical
emissions in each product category not just a few. In the case
of fiber glass insulation for instance, there are many reasons
why all manufacturers have not embraced the so-called
formaldehyde free technology. First of all, the amount of
formaldehyde emitted by insulation is very low to begin with.
Secondly, the rate of formaldehyde decay is very rapid. Half of
the available formaldehyde is gone within 5 days. And finally
the risk associated with worker exposure PF based fiber glass is

Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
No, the credit available for formaldehyde free is
counterintuitive to the objective of this document. Arbitraray
de-selection based on opinion causes controversy and does
not safeguard public health. This document as well as all LEED
documents should move to a scientific-based selection of
materials. Performance based metrics should be used rather
than the arbitrary de-selection of specific chemicals.


Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Please use metrics like those used for Greenguard or CA 01350
and eliminated the wholesale de-selection of technologies that
do not protect nor ensure adequate indoor environmental
quality. Formaldedhye-resin based fiberglass products are
routinely comprehensiely audited for emission levels and most
manufacturers are certified by Greenguard. Certified products
should form the basis of this credit


Do you have any general comments?
In general, focusing on the prohibition of adding formaldehyde
has several significant problems. Attempting to ban
formaldehyde in this credit potentially encourages the use of
product formulations that generate significant emissions of
other volatile organic compounds (VOCs) to the detriment of
building occupants. The is evidence that no added
formaldehyde products can very high in other VOCs, many of
which have significant health effects. The committee is urged
to set clear, scientifically based limits on all VOCs, including
formaldehyde, and not to arbitrarily ban one additive.
GREENGUARD Indoor Air Quality Certification is but one of
several programs that test for all VOCs -- there are other
programs in the market that can also be leveraged. Most
concerning, the language of this provision has the effect of
driving the batt insulation market to one major product
manufacturer - this is neither good public policy nor is it a
advisable legal position for the USGBC to take. The well
documented epidemiology studies of PF resin based fiber glass
for 75 years is reiterated. The degree of safety and
understanding afforded by this does not exist for alternatives.
We urge the USGBC embrace limits rather than bans.
Do you have any general comments?
Why not include medical furnishings and exterior applied
products as the "fifth group?"

Do you have any general comments?
The materials should meet these requirements without the
reduction of performance.




Do you have any general comments?
The materials should meet these requirements without the
reduction of performance.
Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Recommend under Group 2 (page 105) changing "use the
standard office building protocol parameter" to "use building
protocol parameters that are consistent with ASHRAE 62.1
standards for ventilation rates". Change "Avoid paints with
added antimicrobials (page 108)" to "Avoid paints with added
chemical antimicrobial treatments". There are a number of
materials that are inherently anti-microbial. These include
bamboo, silver, copper and certain clays, some of which could
be incorporated into a paint to give it antimicrobial properties.
Amend the bullet -"Avoid all halogenated organic flame
retardants." (page 108) -to be consistent with MR Credit 4.1
(pg 82). The list of chemicals in EQ 4 is significantly longer than
that given in MR Credit 4.1. Recommend removing the bullet
Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
VOC content limits have no scientific relationship to human
health concerns and are not sufficient in and of themselves to
limit inhalation exposure. The only emission criteria
incorporating human health concerns is the CA Section 01350
Specification. While CA 01350 has limitations in the range of

Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
Yes. The effort to broaden the scope of products evaluated by
chemical emission criteria is noteworthy.
Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Group 1: Interior Adhesives and Sealants Add the following
requirement applicable to the entire group, "Adhesives and
sealands shall or meet or exceed the indoor air quality
requirements of California's Special Environmental
Requirements, Specifications Section 01350, as specified in the
California Department of Health Services Standard Practice
CA/DHS/EHLB/R-174 (2004). Testing should be conducted by
an independent laboratory and modeling should use the
standard office building protocol parameters. The following
programs currently utilize CA 01350 requirements for
compliance: - Scientific Certification Systems (SCS) Indoor
Advantage Gold Environmental Certification Program -
Scientific Certification Systems FloorScore program (for
flooring adhesives) - Greenguard Product Emissions Standard
for Children and Schools - Collaborative for High Performance
Schools Low-Emitting Materials Table Group 2: Wall and
Ceiling Finishes Paints and Coatings - Add the following
requirement, "Adhesives and sealands shall or meet or exceed
the indoor air quality requirements of California's Special
Environmental Requirements, Specifications Section 01350, as
specified in the California Department of Health Services
Standard Practice CA/DHS/EHLB/R-174 (2004). Testing should
Do you have any general comments?
a) The inclusion of furniture emission credit in MR Credit 5 is
odd. See specific comments in that credit. b) We encourage
the use of publicly-available, peer-reviewed standards as the
stated requirements for these credits (e.g. CA Section 01350)
and only referencing proprietary certification programs (e.g.
SCS Indoor Advantage Gold) as potential solutions. LEED has
historically suffered from reference to proprietary programs
(e.g. LEED-NC v2.0 Credit EQ 4.5, prior to acceptance of the
ANSI / BIFMA Furniture Emissions Standards in 2006).




Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Group 4 of this proposal admonishes that, "Fiberglass batt
insulation products shall contain no added formaldehyde."
Johns Manville supports this limitation as the no added
formaldehyde fiber glass batt has been a best industry practice
even before 2002 when Johns Manville switched its full line of
thermal and acoustic insulation to a no added formaldehyde
formulation. The Potential Technologies and Strategies section
of this credit notes the following: Specify wood, agrifiber and
fiberglass products (including thermal and acoustical insulation
and acoustical and other suspended ceiling tiles) that contain
no added urea-formaldehyde resins. Consider formaldehyde-
free composite wood, agrifiber, and fiberglass products that
are free of all formaldehyde chemicals, including phenol
formaldehyde. This language should be changed to make clear
that the credit for fiber glass batt insulation is limited to only
those products that have no added formaldehyde of any kind,
Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Group 2- Wall & Ceiling Finishes Group 2 Wall and Ceiling
Finishes: Consider redrafting as it is written in LEED for
Schools; EQ 4 Low Emitting Materials, Option 6: Ceiling and
Wall Systems. All gypsum board, insulation, acoustical ceiling
systems and wall coverings installed in the building interior
shall meet the testing and product requirements of the CA
Dept of Health Services Standard Practice for the Testing of
Volatile Organic Emissions from Various Sources Using Small
Scale Environmental Chambers, including 2004 Addenda.
Group 4- Composite Wood Agrifiber, Fiberglass Bat Insulation
Products (includes particleboard, MDF, plywood, among
others) Georgia-Pacific recommends that this group be divided
into two separate groups, one for composite wood and
agrifiber, and another one for fiberglass bat insulation
products. This separation would be consistent with other LEED

Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
No, the requirements should be based on a scientific approach
and use IAQ standards and testing methods currently available
to evaluate the indoor air performance of products. The term
phthalates cover a family of chemicals, with different chemical,
physical, and toxicological properties Avoiding products that
contain phthalates without analysis of exposure brings
questions to the scientific rigor of the approach. Indoor Air
Quality testing of vinyl products typically do not find
detectable levels of phthalates using standard test methods
that would be protective for human health with a reasonable
margin of safety. As example, the GREENGUARD Emission
Criteria For Children & Schools T This guideline suggests that
children are more susceptible to toxins, and set limits for total
phthalates at




Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
Throughout the credit, there are references to standards that
are based in performance. This makes sense and is easily
understood and followed by a design professional. There is a
huge inconsistency in that there is a proprietary 'deselection'
bullet points added into the listing, which are totally
inappropriate: "Ceiling tiles (including suspended acoustical
tiles) and wall coverings shall contain no polybrominated
diphenyl ethers (PBDE - a flame retardant) or phthalates."
"Flooring systems shall contain no polybrominated diphenyl
ethers (PBDE) or phthalates." Both of these statements are
proprietary and not directly relevant to environmental quality.
It is unclear if the requirement "Flooring system shall contain
no polybrominated diphenyl ethers (PBDE) or phthalates"
applies to flooring systems or to adhesives in flooring system.
However, this credit requirement that flooring systems shall
contain no phthalates is a way to avoid PVC flooring products.
Avoiding PVC flooring products would affect the ability to
maintain the cleanliness of heath care facilities and increase
the potential for the spread of disease and infection. . Forcing
the substitution of PVC with alternative (often more
expensive) materials, would also hamper the objective of
affordable health care.
Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
LEED-HC should delete proprietary' deselection' bullet points
mentioned above from LEED EQc4 . The technical
requirements of the credit should promote the evaluate of
products for Indoor Air Quality using standard testing and
modeling methods and risk based assessment tool like
California's Special Environmental Specification Section 01350
and/or adherence to product certification programs listed in
the guideline.




Do you have any general comments?
The low emitting material credits should integrate
performance criteria for the important indoor air quality issues
of limiting the spread of infection and maintaining a clean,
sterile environment in health care facilities.

Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
Many of the requirements are inappropriate. While we
generally support adoption of science-based regulatory
requirements for EQc4, default prescriptive approaches do not
take into account performance, safety testing, or other science-
based and measurable factors. EQc4 should adopt a
performance based approach, evaluate products using risk
based IAQ testing, use an assessment tool like California's
Special Environmental Specification Section 01350
(http://www.ciwmb.ca.gov/greenbuilding/Specs/Section01350)
, adhere to the product certification programs listed in the
standard, and complete risk based analysis. Any and all
Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
This question is not applicable to the responder (the American
Chemistry Council). As our comments to this section note, we
believe that certain of the changes suggested will not improve
the performance, quality, or safety of healthcare institutions
for installers or occupants, and will fail to "reduce the quantity
of air contaminants that are odorous, irritating and/or harmful
to the comfort and well-being of installers and occupants," the
stated intention of this credit.


Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
The technical requirements of the credit should be based on
sound scientific principles and informed by life cycle analysis.
For phthalates used in construction materials, there is ample
data to show that they are safe as currently used (see
aforementioned risk assessments, references). Based on the
physical/chemical properties, phthalates have very low vapor
pressure and thus there is negligible exposure to workers in an
occupational setting. As described above, there are risk
assessments showing that the risk to workers is very low and
that risk reduction measures above those already in place are
not needed. The technical requirements of the credit could be
improved by applying a similar standard of scientific rigor to
alternate materials. We suggest evaluation of all products
using risk based IAQ testing and an assessment tool such as

Do you have any general comments?
With respect to the Potential Technologies & Strategies
discussion, we urge that this section be deleted outright. Many
of the recommendations noted here are prescriptive, and do
not provide the scientific basis for the recommendation. By
way of example, this section suggests specification of "low
VOC" materials in construction documents. It is important to
understand that solvents are a critical component essential to
the performance of paints, finishes, adhesives, and sealants.
Different products often have performance attributes, such as
Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
The requirements are not appropriate for high performance
healthcare facility construction as they do not take all factors
into consideration. For example "formaldehyde-free"
insulation products are often high in other volatile organic
compounds, many of which have considerable health effects;
the enactment of this requirement would work against the
goals that these proposed requirements are based on.


Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
While the Formaldehyde Council, Inc. (FCI) supports high
performance healthcare facility construction it is clear that the
changes in this credit would greatly affect the ability of the
companies that use urea-formaldehyde (UF) resins in their
products to help transform the healthcare facility market or
even participate in such a market. As it stands there are
existing industry and consensus standards governing the use of
UF resins in wood products such as the Composite Panel
Association's (CPA) industry-wide Environmentally Preferable
Product (EPP) Certification Program for composite panels. All
EPP-certified products must meet American National
Standards Institute (ANSI) standards for formaldehyde
emissions. Formaldehyde emissions from unfinished
particleboard, medium density fiberboard and hardboard must

Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
FCI would advise setting performance based criteria tied to
accepted national and international standards limits rather
than banning products that are made with formaldehyde. We
feel that material de-selection should be avoided and the
reference to "no added formaldehyde" for fiberglass batt
insulation should be omitted. Continuous studies have been
made and found that fiberglass insulation, regardless of the

Do you have any general comments?
Formaldehyde is both a naturally produced and an important
component of various metabolic processes. As a result, it is a
constituent of living systems, from bacteria and fish to rodents
and humans. Because there are naturally evolved, highly
efficient detoxification pathways to manage formaldehyde, it
should be assessed differently than an agent that has no role in
normal metabolism and physiology. The use of formaldehyde
is regulated in the U.S. by a number of federal agencies
including the Department of Housing and Urban Development
(HUD). Formaldehyde emissions from UF resins have
drastically decreased due to the great strides that the industry
has made since the mid-1980's, when levels of formaldehyde
in consumer products were much higher than today. The odor
threshold of formaldehyde ranges from .5 to 1 ppm. This range
is also where individuals begin to sense eye irritation with
greater certainty for irritation occurring at 1 ppm and above.
The Industrial Health Foundation has reviewed over 150
published studies to determine an appropriate occupational
exposure level for formaldehyde and found that eye irritation
does not become significant until around, 1 ppm, and
moderate to severe eye, nose, and throat irritation occurs at 2
to 3 ppm. However formaldehyde emissions from the technical
Do you have any suggestions on how to improve today's
requirements of this credit? Please explain, providing
citations to data and research where possible.
Anthony Bernheim, HDR: SQAQMD only tests for content (not
emissions as in Title of Credit). Why not use CA Section 01305,
too, for each Option? Group 2: Use 01305 in addition to
content. NOTE: also mention to use low VOC tint(s). Ref Table
107: This is for content, only, also need concentration limits.
Do not use grams per liter. Use micrograms (same language as
01305 so that the comparisons will be equal). Group 3: should
include adhesives so the carpet and the adhesives are tested
as an assembly. Carpet cushion should have to meet CRI Green
Label Plus not just CRI Green Label. Under Potential Strategies:
the first two bullets should say: Specifiy low-VOC emitting
Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
EQ Credit 4 Low Emitting Materials (Specifically Group 5
Exterior Applied Products) Volatile Organic Compound (VOC)
Limitations relating to the South Coast Air Quality
Management District (SCAQMD). There are weather and
climatic differences that have not been taken into account. The
US Green Building Council has randomly adopted the SCAQMD
standards for VOC emissions without taking into account the
significant climatic conditions of various regions of the country.
Recently, California Air Resources Board staff acknowledged
that climate differences have the ability to impact the
application of water based emulsion roof coatings because of
low to freezing temperatures, high relative humidity, and
frequency of rain, dew, and/or snowfall. During the adoption
of the 2007 Suggested Control Measure for Architectural and
Industrial Maintenance Coatings in Chapter 5 Technical
Assessment of Categories, Section 3 Bituminous Roof Coatings,
Subsection 3 Coating Description: .other parts of the country
(e.g. Northeast and Midwest) are subject to colder or less
temperate climates that may not permit the use of waterborne
emulsions. Emulsion Bituminous Roof coatings can be
adversely impacted by unexpected rain, heavy dew, thick fog,
and extremely cold temperatures due to slower cure times
Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
This significantly impacts the asphalt roofing industry and
there are significant incorrect conclusions drawn about hot
applied asphalt and lacks the ability to substitue other low
emittance products that fall with the asphalt roofing arean.
Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Cold-process adhesive application and low-fume asphalt
virtually eliminate fumes and odors and technological
advances include peel-and-stick self adhesive products which
eliminate the need for high solvent based primers, sealers, and
adhesives. Asphalt roof coatings both water based (particularly
in dry arid climates) and solvent borne bituminous (in moist,
wet, and volatile climates) service a particular niche market for
increasing the energy efficiency and savings of a building by
increasing the reflectivity and emissivity of a built-up low slope
roofs. In addition, there are successful application on high
density, fume-sensitive occupancy type building including
health care facilities, schools, and college campuses, food
preparation centers, airports, fashion malls, fine hotels, and
financial/office center. There are cold-process adhesive
applications and low-fume asphalt built up roofs benefits the
end users by providing the following: Aspahlt Roofs add multi-
layer protection and decrease the need to use single ply
roofing membranes, which in general uses a high VOC content
solvent for their installation and repair Asphalt can increase
the thermal performance and can address the needs of energy
savings by adding additional insulation against climatic shifts
and reducing the heating and cooling needs of the building
Do you have any general comments?
In General ARMA feels that asphalt roofing has been
stigmatized by the LEED Healthcare Rating System with little to
no evidence to support is position. ARMA would gladly meet
with LEED to discuss these points brought forward above.

Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
We believe that the restrictions presented in EQ Credit 4 as
they relate to phthalates, are quite inappropriate for high
performance health care facility construction. A) Credit EQ 4 is
inappropriate as it would eliminate the use of a very useful,
cost effective and high performing application of phthalates in
vinyl ceiling materials and wall coverings. Additionally, it would
eliminate the use of phthalates as a coalescing agent in
adhesive systems use in flooring. Polymers and adhesives
which use phthalates are well characterized. The vapor
pressure of phthalates is very low which means they are very
low emitting materials. It is well documented that worker
exposure is very low and well within established guidelines. B)
High performance healthcare facility construction materials
should be manufactured with materials which have a strong
Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
We are addressing the November 2007 draft of the LEED HC
Proposal, without reference to earlier drafts or other versions
of LEED, so cannot comment on 'changes', as we have no
different version against which to compare the November
2007 draft. We are concerned that the required absence of
phthalates to achieve EQ Credit 4 does not have a scientific
basis and cover those concerns in our subsequent responses.




Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
The technical requirements should be based on sound
scientific principles. For the phthalates used in construction
materials, there is ample data to show that they are safe as
currently used. Based on the physical/chemical properties they
have a very low vapor pressure and thus there is very little
exposure to workers in an occupational setting. Additionally,
there are risk assessments showing that the risk to workers is
very low and that risk reduction measures above those already
in place are not needed. European Commission (2003a). Risk-
Assessment Report Vol. 36, 2003 on:1,2-Benzenedicarboxylic
acid, di-C9-11-branched alkyl esters, C10-rich, CAS#: 68515-49-
1, EINECS#: 271-091-4.and:di-"isodecyl" phthalate (DIDP),
CAS#: 26761-40-0, EINECS#: 247-977-1.Publication: EUR 20785
EN. European Commission (2003b). Risk-Assessment Report
Vol. 35, 2003 on:1,2-Benzenedicarboxylic acid, di-C8-10-
branched alkyl esters, C9-rich, CAS#: 68515-48-0, EINECS#: 271-
090-9.and:di-"isononyl" phthalate (DINP), CAS#: 28553-12-0,
EINECS#: 249-079-5.Publication: EUR 20784 EN. Kavlock et al.
(2002). NTP center for the evaluation of risks to human
reproduction: phthalates expert panel report on the
reproductive and developmental toxicity of butyl benzyl
phthalate. Repro Toxicol 16, 453-487. Kavlock et al. (2002).
Do you have any general comments?
No
Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Under the Flooring Systems (group 3) we recommend that the
key sections of the documents be reprinted in the LEED-HC
document in a reference section and made available for public
review and/or a website link be provided in the LEED
documents to direct readers where they may download these
references at no charge. Under the Exterior Applied Products
Systems (group 5) - the same issue and request as noted above
to provide direct reference to our free internet access to the
South Coast Air Quality Management District rule


Do you have any general comments?
Under the section Interior Adhesives & Sealants the standard
for total mass of product references California documents, we
recommend that the key sections of the documents be
reprinted in the LEED-HC document in a reference section and
made available for public review and/or a website link be
provided in the LEED documents to direct readers where they
may download these references at no charge. We make this
same recommendation for the section on wall and ceiling
finishes (group 2) in reference to the South Coast Air Quality
Management District rule and California Dept of Health
Services standard.

Do you have any general comments?
For five years the USGBC's appointed Task Group conducted a
thorough, in-depth evaluation of the scientific literature
related to human health/safety and environmental concerns
about the use of polyvinyl chloride (PVC) as a component in
building materials. No other building material has undergone a
more thorough review. Based on the scientific data, the Task
Group recommended against a credit for excluding vinyl in the
LEED rating system, going so far as saying such a credit could
encourage the use of worse materials. We recognize the
obsession of the anti-PVC activists, but if USGBC allows an
obsession to become a substitute for science, the organization
will and should lose credibility. Since a science-based
evaluation failed to support the agenda of the activists, they
are resorting to under-the-table manipulation and political
maneuvering to produce a result that due process could not.
The approach of discrediting PVC products under the guise of
singling out its building block components is an unfair attempt
to "game the system" after the evaluation of PVC products has
been completed. This attempt should be rebuked not only
because it is contrary to the scientific findings but equally so
because of the lack of fair play demonstrated.

Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
No. Specifying products that do not contain phthalates in EQ
Credit 4.3 Low Emitting Materials: Flooring Systems is illogical,
since phthalates as used in carpet have no potential to impact
air quality. In the case of PVC flooring, phthalate plasticizers
are not off-gassed or ingested nor do they come into intimate
contact with humans. No scientific studies have demonstrated
that phthalates contained in PVC building products contribute
negatively to indoor air quality or cause ill health effects.
Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
Yes. This credit is contrary to USGBC's commitment to using
comparative life-cycle analysis in its LEED program. It uses a
single attribute approach to indirectly deselect PVC building
materials rather than comparative life cycle analysis.




Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Yes. We agree with the intent of the credit that flooring
products should meet applicable Indoor Air Quality testing
criteria, such as the CRI Green Label Plus program, however,
we recommend removing the requirement that "flooring
Systems shall not contain phthalates."


Do you have any general comments?
Dear USGBC, My name is John Sager and I work for the USEPA,
Office of Solid Waste. We just learned in the past several days
of the proposed guideline for the use of coal fly as a
supplementary cementitious material that would limit use of
this fly ash if the mercury concentration is more than than
2ppb. The Office of Solid Waste actively supports the use of
coal fly ash as a supplementary cementitious material, because
we believe this use is highly beneficial for the environment.
We would like to discuss this proposed guideline with you. In
particular, we would like to know if there is any scientific or
engineering basis upon which you propose this limit on the
concentration of mercury in fly ash used as a supplementary
cementitious material. I hope that I am submitting this
comment in the proper comment area. If not, I would
appreciate it if you would forward it to the appropriate
reviewer. We hope that you will contact us in this regard. We
have extensive information that we can share on this topic,
and we would benefit from learning if there is any scientific or
engineering basis for your proposal. Respectfully submitted,
John Sager USEPA Office of Solid Waste 703-308-7256
sager.john@epa.gov
ontaining phthalates be removed from the credit to become the basis for a broader credit to be
ts in the pilot library must go through public comment and USGBC member ballot before they
it www.usgbc.org/pilotcreditlibrary.


             LEED for Healthcare Committee Response




             Thank you for your comments. Your recommendation will be considered during the
             next overall LEED upgrade.




             Thank you for your comment. The language in EQc4 restricting the use of phthalate-
             containing materials has been removed from the credit and will become the basis for
             a broader credit to be developed and pilot through the LEED Credit Pilot Library that
             address the EPA Chemical Action Plan. These comments will be reviewed and
             considered during the piloting of this credit, and revisions may be made as a result of
             your comment. For more information on the LEED Pilot Credit Library, please visit
             www.usgbc.org/pilotcreditlibrary.
a broader credit to be developed and pilot through the LEED Credit Pilot Library that
address the EPA Chemical Action Plan. These comments will be reviewed and
considered during the piloting of this credit, and revisions may be made as a result of
your comment. For more information on the LEED Pilot Credit Library, please visit
www.usgbc.org/pilotcreditlibrary.




Thank you for your comment. The language in EQc4 restricting the use of phthalate-
containing materials has been removed from the credit and will become the basis for
a broader credit to be developed and pilot through the LEED Credit Pilot Library that
address the EPA Chemical Action Plan. These comments will be reviewed and
considered during the piloting of this credit, and revisions may be made as a result of
your comment. For more information on the LEED Pilot Credit Library, please visit
www.usgbc.org/pilotcreditlibrary.
Thank you for your comment. The language in EQc4 restricting the use of phthalate-
containing materials has been removed from the credit and will become the basis for
a broader credit to be developed and pilot through the LEED Credit Pilot Library that
address the EPA Chemical Action Plan. These comments will be reviewed and
considered during the piloting of this credit, and revisions may be made as a result of
your comment. For more information on the LEED Pilot Credit Library, please visit
www.usgbc.org/pilotcreditlibrary.




Thank you for your comment. The language in EQc4 restricting the use of phthalate-
containing materials has been removed from the credit and will become the basis for
a broader credit to be developed and pilot through the LEED Credit Pilot Library that
address the EPA Chemical Action Plan. These comments will be reviewed and
considered during the piloting of this credit, and revisions may be made as a result of
your comment. For more information on the LEED Pilot Credit Library, please visit
www.usgbc.org/pilotcreditlibrary.
Thank you for your comment. The language in EQc4 restricting the use of phthalate-
containing materials has been removed from the credit and will become the basis for
a broader credit to be developed and pilot through the LEED Credit Pilot Library that
address the EPA Chemical Action Plan. These comments will be reviewed and
considered during the piloting of this credit, and revisions may be made as a result of
your comment. For more information on the LEED Pilot Credit Library, please visit
www.usgbc.org/pilotcreditlibrary.




 The HCC recognizes that in can preservatives are used in many acrylic paints to
provide acceptable shelf life. The recommendation to avoid antimicrobials in paint
has been clarified in the new draft to target added chemicals and metals that are
targeted at use phase antimicrobial activity, due to concerns reflected in studies by
the CDC, Kaiser and others that these products are not effective and instead may
increase resistance. REF: Centers for Disease Control and Prevention (CDC),
Guidelines for Environmental Infection Control in Health-Care Facilities
Recommendations of CDC and the Healthcare Infection Control Practices Advisory
Committee (HICPAC), U.S. Department of Health and Human Services, 2003, Kaiser
Permanente, “Evaluation of Antimicrobial Property Claims in Finishes and Fabrics "
2007, Tristan Roberts, Antimicrobial Chemicals in Buildings: Hygiene or Harm?
Environmental Building News, August 2007
Thank you for your comment. The language in EQc4 restricting the use of phthalate-
containing materials has been removed from the credit and will become the basis for
a broader credit to be developed and pilot through the LEED Credit Pilot Library that
address the EPA Chemical Action Plan. These comments will be reviewed and
considered during the piloting of this credit, and revisions may be made as a result of
your comment. For more information on the LEED Pilot Credit Library, please visit
www.usgbc.org/pilotcreditlibrary.
Thank you for your comment. The language in EQc4 restricting the use of phthalate-
containing materials has been removed from the credit and will become the basis for
a broader credit to be developed and pilot through the LEED Credit Pilot Library that
address the EPA Chemical Action Plan. These comments will be reviewed and
considered during the piloting of this credit, and revisions may be made as a result of
your comment. For more information on the LEED Pilot Credit Library, please visit
www.usgbc.org/pilotcreditlibrary.




Thank you for your comments. The HHC agrees that VOC content based standards
are not ideal predictors of actual exposure from emissions. However, the HHC does
not feel that there is sufficient agreement in the industry on protocols to
meaningfully measure emissions from wet applied products and establish standards.
The HCC is monitoring the discussions on these issues will consider using improved
emissions based standards for wet applied products during the next revision.
The USGBC has determined that it is important to utilize the Precautionary Principle
in evaluating cases where scientific uncertainty exists but potential for harm is
significant and alternatives are available. The LEED system is designed to encourage
best practices and facilitate market transformation. Hence it is appropriate that LEED
credits set thresholds which are beyond regulatory baselines and beyond industry
consensus standards which represent current standard practice.
The USGBC has determined that it is important to utilize the Precautionary Principle
in evaluating cases where scientific uncertainty exists but potential for harm is
significant and alternatives are available. The LEED system is designed to encourage
best practices and facilitate market transformation. Hence it is appropriate that LEED
credits set thresholds which are beyond regulatory baselines and beyond industry
consensus standards which represent current standard practice.




Formaldehyde is classified as a known carcinogen by the World Health Organization
(International Agency for Research on Cancer) and was listed by the California Air
Resources Board as a Toxic Air Contaminant with no safe level of exposure and so
warrants action even beyond the ACTM. The USGBC has determined that it is
important to utilize the Precautionary Principle in evaluating cases where scientific
uncertainty exists but potential for harm such as this is significant and alternatives
are available. The LEED system is designed to encourage best practices and facilitate
market transformation. Hence it is appropriate that LEED credits set thresholds which
are beyond regulatory baselines and beyond industry consensus standards which
represent current standard practice.

HHC is concerned about other emissions from these products in addition to
formaldehyde and will consider including emissions criteria in the rating system
during the next revision
GREENGUARD may be used for compliance for both this credit and MR credit 5 at the
team's discretion.




Thank you for your comments. The issues of concern in Group 5 are of concern for
indoor environmental quality as well as outdoor atmospheric issues due to the
frequency of this work occurring proximate to occupied healthcare facilities.




Thank you for your comment noting the ambiguity of the "formaldehyde-free"
phrase. The Potential Technologies & Strategies language in the rating system will be
changed to use the "no added formaldehyde" phrase as suggested as part of the
revisions included in the 2nd public comment period draft.
Thank you for your comment. The language in EQc4 restricting the use of phthalate-
containing materials has been removed from the credit and will become the basis for
a broader credit to be developed and pilot through the LEED Credit Pilot Library that
address the EPA Chemical Action Plan. These comments will be reviewed and
considered during the piloting of this credit, and revisions may be made as a result of
your comment. For more information on the LEED Pilot Credit Library, please visit
www.usgbc.org/pilotcreditlibrary.
Thank you for your comment. The language in EQc4 restricting the use of phthalate-
containing materials has been removed from the credit and will become the basis for
a broader credit to be developed and pilot through the LEED Credit Pilot Library that
address the EPA Chemical Action Plan. These comments will be reviewed and
considered during the piloting of this credit, and revisions may be made as a result of
your comment. For more information on the LEED Pilot Credit Library, please visit
www.usgbc.org/pilotcreditlibrary.
Thank you for your comment. The language in EQc4 restricting the use of phthalate-
containing materials has been removed from the credit and will become the basis for
a broader credit to be developed and pilot through the LEED Credit Pilot Library that
address the EPA Chemical Action Plan. These comments will be reviewed and
considered during the piloting of this credit, and revisions may be made as a result of
your comment. For more information on the LEED Pilot Credit Library, please visit
www.usgbc.org/pilotcreditlibrary.




Thank you for your support.
The HHC agrees that VOC content based standards are not ideal predictors of actual
exposure from emissions. However, the HHC does not feel that there is sufficient
agreement in the industry on protocols to meaningfully measure emissions from wet
applied products and establish standards. The HCC is monitoring the discussions on
these issues will consider using improved emissions based standards for wet applied
products during the next revision. The HCC complements the California 01350
requirements in this credit with chemical screening criteria because California 01350
only addresses emissions of a specific list of volatile organic compounds (VOCs) from
building materials. 01350 does not provide a comprehensive analysis of all
hazardous chemical exposure issues with building materials. For example, it does not
cover releases of semivolatile organic compounds (SVOCs) and other compounds
that are released through pathways other than immediate volatilization, such as dust
transport. The credit guidelines are intended to supplement 01350 based standards
by addressing other compounds that are also contained in and released from some
building materials for which there are indications of potential harm to occupants.



Thank you for your comments. Formaldehyde is classified as a known carcinogen by
the World Health Organization (International Agency for Research on Cancer) and
was listed by the California Air Resources Board as a Toxic Air Contaminant with no
safe level of exposure. Most indoor environments now exceed recommended
exposure levels both for irritant effects and for cancer risk. Studies by Axten for the
Formaldehyde Product Stewardship Committee have shown that PF based insulation
binders do continue to offgas significant levels of formaldehyde long after
installation.

The HCC also notes the concern that there may be other emissions of concern from
insulation and will consider your comments in future revisions.
We agree that selection of materials should be science based and are basing the
deselection of formaldehyde on good science.




see above




The HCC also notes the concern that there may be other emissions of concern from
insulation and will consider your comments in future revisions.
The HCC does not expect a problem with market availability or monopoly in the batt
insulation market, noting that there are a variety of non fiberglass batt insulation
options on the market, and now two manufacturers producing fiberglass batt
fiberglass with no added formaldehyde and at least one other manufacturer has
previously produced a no added formaldehyde fiberglass batt product which was
discontinued solely because of low demand.
Thank you for your comments. Because of some of furniture's unique characteristics
we are keeping it separate at this time. We will consider your comment in future
revisions

Thank you for your comments. HHC agrees that materials should meet these
requirements without reductions of performance. Performance assessment,
however, is not a part of LEED criteria at this time. Your recommendation will be
considered during the next overall LEED upgrade.




Thank you for your comments. The HCC recognizes that in can preservatives are used
in many acrylic paints to provide acceptable shelf life. The recommendation to avoid
antimicrobials in paint has been clarified in the new draft to target added chemicals
and metals that are targeted at use phase antimicrobial activity, due to concerns
reflected in studies by the CDC, Kaiser and others that these products are not
effective and instead may increase resistance. REF: Centers for Disease Control and
Prevention (CDC), Guidelines for Environmental Infection Control in Health-Care
Facilities Recommendations of CDC and the Healthcare Infection Control Practices
Advisory Committee (HICPAC), U.S. Department of Health and Human Services, 2003,
Kaiser Permanente, “Evaluation of Antimicrobial Property Claims in Finishes and
Fabrics " 2007, Tristan Roberts, Antimicrobial Chemicals in Buildings: Hygiene or
Harm? Environmental Building News, August 2007.




Thank you for your comments. The HHC agrees that VOC content based standards
are not ideal predictors of actual exposure from emissions. However, the HHC does
not feel that there is sufficient agreement in the industry on protocols to
meaningfully measure emissions from wet applied products and establish standards.
The HCC is monitoring the discussions on these issues will consider using improved
emissions based standards for wet applied products during the next revision. The
HCC complements the California 01350 requirements in this credit with chemical
screening criteria because the California 01350 requirements only address emissions
of a specific list of volatile organic compounds (VOCs) from building materials. 01350
does not provide a comprehensive analysis of all hazardous chemical exposure issues
with building materials. It does not cover releases of semivolatile organic compounds
(SVOCs) and other compounds that are released through pathways other than
immediate volatilization, such as dust transport. The credit guidelines are intended
to supplement 01350 based standards by addressing other compounds that are also
contained in and released from some building materials for which there are
indications of potential harm to occupants.
screening criteria because the California 01350 requirements only address emissions
of a specific list of volatile organic compounds (VOCs) from building materials. 01350
does not provide a comprehensive analysis of all hazardous chemical exposure issues
with building materials. It does not cover releases of semivolatile organic compounds
(SVOCs) and other compounds that are released through pathways other than
immediate volatilization, such as dust transport. The credit guidelines are intended
to supplement 01350 based standards by addressing other compounds that are also
contained in and released from some building materials for which there are
indications of potential harm to occupants.




A) Because of some of furniture's unique characteristics we are keeping it separate at
this time. We will consider your comment in future revisions. B) we agree and have
specified CA Section 01350 as the reference standard and proprietary certification
programs only as ways of meeting that standard.
Thank you for your comments. In the 2nd draft of LEED-HC we have included
language to clarify that the restriction includes urea formaldehyde, phenol
formaldehyde, and urea-extended phenol formaldehyde.
The intention of the HCC was to eliminate the use of tankers and kettles as well as
the need to lay swaths of molten asphalt on the roof prior to membrane application
due to NIOSH findings of long term potential carcinogenicity and short term acute
respiratory irritation from asphalt and coal tar fumes. Human epidemiological studies
have reported an increased risk in lung cancer among workers exposed to asphalt
fumes and asphalt fumes caused skin tumors in experimental animals. Additionally,
known human carcinogens (PAHs) have been found in asphalt fumes. The language
will be changed as part of the revisions included in the 2nd draft to clarify that the
requirement is only to not use hot-mopped asphalt installation techniques and that
self-adhering, cold adhesive, torch-applied, or heat weldable membranes and
installation techniques are permissible. REF: NIOSH Pocket Guide to Chemical
Hazards, NIOSH, 2008, and Hazard Review: Health Effects Of Occupational Exposure
To Asphalt, NIOSH, 2000.



Thank you for your comments. The USGBC has determined that it is important to
utilize the Precautionary Principle in evaluating cases where scientific uncertainty
exists but potential for harm is significant and alternatives are available. The LEED
system is designed to encourage best practices and facilitate market transformation.
Hence it is appropriate that LEED credits set thresholds which are beyond regulatory
baselines and beyond industry consensus standards which represent current
standard practice. In this case the complling issues are that formaldehyde is classified
as a known carcinogen by the World Health Organization (International Agency for
Research on Cancer) and was listed by the California Air Resources Board as a Toxic
Air Contaminant with no safe level of exposure and so warrants action even beyond
the ACTM.

The HCC will list relevant CAS numbers in the Reference Guide.
Thank you for your comment. The language in EQc4 restricting the use of phthalate-
containing materials has been removed from the credit and will become the basis for
a broader credit to be developed and pilot through the LEED Credit Pilot Library that
address the EPA Chemical Action Plan. These comments will be reviewed and
considered during the piloting of this credit, and revisions may be made as a result of
your comment. For more information on the LEED Pilot Credit Library, please visit
www.usgbc.org/pilotcreditlibrary.




Thank you for your comment. The language in EQc4 restricting the use of phthalate-
containing materials has been removed from the credit and will become the basis for
a broader credit to be developed and pilot through the LEED Credit Pilot Library that
address the EPA Chemical Action Plan. These comments will be reviewed and
considered during the piloting of this credit, and revisions may be made as a result of
your comment. For more information on the LEED Pilot Credit Library, please visit
www.usgbc.org/pilotcreditlibrary.
The California 01350 requirements only address emissions of a specific list of volatile
organic compounds (VOCs) from building materials. 01350 does not provide a
comprehensive analysis of all hazardous chemical exposure issues with building
materials. It does not cover releases of semivolatile organic compounds (SVOCs) and
other compounds that are released through pathways other than immediate
volatilization, such as dust transport. The credit guidelines are intended to
supplement 01350 based standards by addressing other compounds that are also
contained in and released from some building materials for which there are
indications of potential harm to occupants.




Infection control is already very carefully addressed in healthcare environments and
beyond the scope of LEED.




Thank you for your comment. The language in EQc4 restricting the use of phthalate-
containing materials has been removed from the credit and will become the basis for
a broader credit to be developed and pilot through the LEED Credit Pilot Library that
address the EPA Chemical Action Plan. These comments will be reviewed and
considered during the piloting of this credit, and revisions may be made as a result of
your comment. For more information on the LEED Pilot Credit Library, please visit
www.usgbc.org/pilotcreditlibrary.
The suggestion regarding the use of Life Cycle Assessment tools to inform this credit
is not specific to LEED for Healthcare but is a more overarching issue with relevance
to all LEED rating systems. LEED for Healthcare uses LEED for New Construction v3 as
its primary point of reference. Within the v3 structure, LCA is not currently used as a
basis for credit formulation. USGBC’s LCA into LEED initiative is exploring how to use
LCA to inform credit structure and associated values in future versions of LEED and
will inform all LEED tools upon its conclusion.




Thank you for your comment. The language in EQc4 restricting the use of phthalate-
containing materials has been removed from the credit and will become the basis for
a broader credit to be developed and pilot through the LEED Credit Pilot Library that
address the EPA Chemical Action Plan. These comments will be reviewed and
considered during the piloting of this credit, and revisions may be made as a result of
your comment. For more information on the LEED Pilot Credit Library, please visit
www.usgbc.org/pilotcreditlibrary.




On antimicrobials: The HCC recognizes that in can preservatives are used in many
acrylic paints to provide acceptable shelf life. The recommendation to avoid
antimicrobials in paint has been clarified in the new draft to target added chemicals
and metals that are targeted at use phase antimicrobial activity, due to concerns
reflected in studies by the CDC, Kaiser and others that these products are not
effective and instead may increase resistance. REF: Centers for Disease Control and
Prevention (CDC), Guidelines for Environmental Infection Control in Health-Care
Facilities Recommendations of CDC and the Healthcare Infection Control Practices
Advisory Committee (HICPAC), U.S. Department of Health and Human Services, 2003,
Kaiser Permanente, “Evaluation of Antimicrobial Property Claims in Finishes and
Fabrics " 2007, Tristan Roberts, Antimicrobial Chemicals in Buildings: Hygiene or
Thank you for your comments. Formaldehyde is classified as a known carcinogen by
the World Health Organization (International Agency for Research on Cancer) and
was listed by the California Air Resources Board as a Toxic Air Contaminant with no
safe level of exposure.

HHC is concerned about other emissions from these products and will consider
including emissions criteria in the rating system during the next revision


The HCC does not expect a problem with market availability or monopoly in the batt
insulation market, noting that there are a variety of non fiberglass batt insulation
options on the market, and now two manufacturers producing fiberglass batt
fiberglass with no added formaldehyde and at least one other manufacturer has
previously produced a no added formaldehyde fiberglass batt product which was
discontinued solely because of low demand. It is certainly the case that more
assessment is needed for formaldehdye alternaiteves and more development is
needed of even safer alternatives. However, reducing exposure to formaldehyde - a
known carcinogen with no safe level of exposure - is important to the sustainable
environment movement and it is important that LEED provide clear market signals to
raise the bar, encouarge development of more safer alterantieves and transform the
market. The USGBC has determined that it is important to utilize the Precautionary
Principle in evaluating cases where scientific uncertainty exists but potential for harm
is significant and alternatives are available. The LEED system is designed to
encourage best practices and facilitate market transformation. Hence it is
appropriate that LEED credits set thresholds which are beyond regulatory baselines
and beyond industry consensus standards which represent current standard practice.




Studies by Axten for the Formaldehyde Product Stewardship Committee have shown
that PF based insulation binders do continue to offgas significant levels of
formaldehyde long after installation.
see above




Thank you for your comments. ] The HHC agrees that VOC content based standards
are not ideal predictors of actual exposure from emissions. However, the HHC does
not feel that there is sufficient agreement in the industry on protocols to
meaningfully measure emissions from wet applied products and establish standards.
The HCC is monitoring the discussions on these issues will consider using improved
emissions based standards for wet applied products during the next revision          A
sentence to encourage the use of low VOC tints will be added to the Potential
Technologies & Strategies language in the rating system as part of the revisions
included in the 2nd public comment period draft.                    Grams per liter is a
standard measure of VOC content and is consistent with the SCAQMD regulations
and GreenSeal thresholds which are the source for the requirement. Micrograms will
be the appropriate measure when an emissions standard can be utilized for this
credit in the future.
 HHC agrees that flooring systems should be tested as a system with the
recommended adhesive. The requirement states: “Systems shall be tested including
backer and adhesive” The committee is concerned that some of the programs
utilizing the 01350 protocol may not be testing whole systems and encourages users
to insist on system emissions testing.          HCC agrees that carpet cushion
should meet Green Label Plus requirements, however there does not appear to be a
Green Label Plus program for cushion products at this time.        The HCC agrees
that the phrase "no added formaldehyde" is preferable to "formaldehyde-free". The
Potential Technologies & Strategies language in the rating system will be changed to
use the "no added formaldehyde" phrase as suggested as part of the revisions
included in the 2nd public comment period draft.




Thank you for your comments. The HHC acknowledges that performance issues may
preclude the use of water based emulsions that meet the VOC requirements in
certain climatic conditions. The use of mechanically attached roofing system or a
heat welded system to may be necessary to meet the requirements while assuring a
high performance installation. This will be discussed in the reference guide.




The intention of the HCC was to eliminate the use of tankers and kettles as well as
the need to lay swaths of molten asphalt on the roof prior to membrane application
due to NIOSH findings of long term potential carcinogenicity and short term acute
respiratory irritation from asphalt and coal tar fumes. Human epidemiological studies
have reported an increased risk in lung cancer among workers exposed to asphalt
fumes and asphalt fumes caused skin tumors in experimental animals. Additionally,
known human carcinogens (PAHs) have been found in asphalt fumes. The language
will be changed as part of the revisions included in the 2nd public comment period
draft to clarify that the requirement is only to not use hot-mopped asphalt
installation techniques and that self-adhering, cold adhesive, torch-applied, or heat
The intention of the HCC was to eliminate the use of tankers and kettles as well as
the need to lay swaths of molten asphalt on the roof prior to membrane application
due to NIOSH findings of long term potential carcinogenicity and short term acute
respiratory irritation from asphalt and coal tar fumes. Human epidemiological studies
have reported an increased risk in lung cancer among workers exposed to asphalt
fumes and asphalt fumes caused skin tumors in experimental animals. Additionally,
known human carcinogens (PAHs) have been found in asphalt fumes. The language
will be changed as part of the revisions included in the 2nd public comment period
draft to clarify that the requirement is only to not use hot-mopped asphalt
installation techniques and that self-adhering, cold adhesive, torch-applied, or heat
weldable membranes and installation techniques are permissible." REF: NIOSH
Pocket Guide to Chemical Hazards, NIOSH, 2008, and Hazard Review: Health Effects
Of Occupational Exposure To Asphalt, NIOSH, 2000.            Like the GGHC, the LEED-
HC also allows repair of asphalt roofs as long as practices are in compliance with
procedures established by NIOSH Publication No. 2003-112
Thank you for your comment. The language in EQc4 restricting the use of phthalate-
containing materials has been removed from the credit and will become the basis for
a broader credit to be developed and pilot through the LEED Credit Pilot Library that
address the EPA Chemical Action Plan. These comments will be reviewed and
considered during the piloting of this credit, and revisions may be made as a result of
your comment. For more information on the LEED Pilot Credit Library, please visit
www.usgbc.org/pilotcreditlibrary.




Thank you for your comment. The language in EQc4 restricting the use of phthalate-
containing materials has been removed from the credit and will become the basis for
a broader credit to be developed and pilot through the LEED Credit Pilot Library that
address the EPA Chemical Action Plan. These comments will be reviewed and
considered during the piloting of this credit, and revisions may be made as a result of
your comment. For more information on the LEED Pilot Credit Library, please visit
www.usgbc.org/pilotcreditlibrary.




Thank you for your comment. The language in EQc4 restricting the use of phthalate-
containing materials has been removed from the credit and will become the basis for
a broader credit to be developed and pilot through the LEED Credit Pilot Library that
address the EPA Chemical Action Plan. These comments will be reviewed and
considered during the piloting of this credit, and revisions may be made as a result of
your comment. For more information on the LEED Pilot Credit Library, please visit
www.usgbc.org/pilotcreditlibrary.
Thank you for your comment. The language in EQc4 restricting the use of phthalate-
containing materials has been removed from the credit and will become the basis for
a broader credit to be developed and pilot through the LEED Credit Pilot Library that
address the EPA Chemical Action Plan. These comments will be reviewed and
considered during the piloting of this credit, and revisions may be made as a result of
your comment. For more information on the LEED Pilot Credit Library, please visit
www.usgbc.org/pilotcreditlibrary.




 Thank you for your comments. As suggested, the HCC will incorporate web links in
the Reference Guide to where the relevant reference documents can be downloaded.
Thank you for your comment. The language in EQc4 restricting the use of phthalate-
containing materials has been removed from the credit and will become the basis for
a broader credit to be developed and pilot through the LEED Credit Pilot Library that
address the EPA Chemical Action Plan. These comments will be reviewed and
considered during the piloting of this credit, and revisions may be made as a result of
your comment. For more information on the LEED Pilot Credit Library, please visit
www.usgbc.org/pilotcreditlibrary.




Thank you for your comment. The language in EQc4 restricting the use of phthalate-
containing materials has been removed from the credit and will become the basis for
a broader credit to be developed and pilot through the LEED Credit Pilot Library that
address the EPA Chemical Action Plan. These comments will be reviewed and
considered during the piloting of this credit, and revisions may be made as a result of
your comment. For more information on the LEED Pilot Credit Library, please visit
www.usgbc.org/pilotcreditlibrary.
Thank you for your comment. The language in EQc4 restricting the use of phthalate-
containing materials has been removed from the credit and will become the basis for
a broader credit to be developed and pilot through the LEED Credit Pilot Library that
address the EPA Chemical Action Plan. These comments will be reviewed and
considered during the piloting of this credit, and revisions may be made as a result of
your comment. For more information on the LEED Pilot Credit Library, please visit
www.usgbc.org/pilotcreditlibrary.




Thank you for your comments. The suggestion regarding the use of Life Cycle
Assessment tools to inform this credit is not specific to LEED for Healthcare but is a
more overarching issue with relevance to all LEED rating systems. LEED for
Healthcare uses LEED for New Construction v3 as its primary point of reference.
Within the v3 structure, LCA is not currently used as a basis for credit formulation.
USGBC’s LCA into LEED initiative is exploring how to use LCA to inform credit
structure and associated values in future versions of LEED and will inform all LEED
tools upon its conclusion.




Thank you for your comment. The language in EQc4 restricting the use of phthalate-
containing materials has been removed from the credit and will become the basis for
a broader credit to be developed and pilot through the LEED Credit Pilot Library that
address the EPA Chemical Action Plan. These comments will be reviewed and
considered during the piloting of this credit, and revisions may be made as a result of
your comment. For more information on the LEED Pilot Credit Library, please visit
www.usgbc.org/pilotcreditlibrary.
 Thank you for your comments. We appreciate the information provided by USEPA in
investigatin gthis issue. Please refer to the MR category credit 3 responses for further
detail.
LEED for Healthcare 1st Public Comment Period Comments & Responses
Environmental Quality Credit 5

Requirement Number          CreditDescription
Credit 5                    Indoor Chemical &
                            Pollutant Source Control




Credit 5                    Indoor Chemical &
                            Pollutant Source Control
Credit 5   Indoor Chemical &
           Pollutant Source Control
Credit 5   Indoor Chemical &
           Pollutant Source Control
Credit 5   Indoor Chemical &
           Pollutant Source Control




Credit 5   Indoor Chemical &
           Pollutant Source Control
Credit 5   Indoor Chemical &
           Pollutant Source Control




Credit 5   Indoor Chemical &
           Pollutant Source Control




Credit 5   Indoor Chemical &
           Pollutant Source Control
Credit 5   Indoor Chemical &
           Pollutant Source Control
Credit 5   Indoor Chemical &
           Pollutant Source Control




Credit 5   Indoor Chemical &
           Pollutant Source Control
ment Period Comments & Responses


        Comments
        Do you believe that the requirements presented are
        appropriate for high performance healthcare facility
        construction? Please explain.
        In general yes, although we believe they can be improved upon
        by requiring the use of interior finishes like floor coverings
        which can be maintained without potentially hazardous
        chemicals.

        Will the changes in this credit (if any) affect your ability to
        help transform the healthcare facility market? If so, please
        explain how and why.
        Yes, regular maintenance of some interior finishes - in
        particular floor coverings which constitute a large portion of
        the building - requires the use of potentially hazardous
        chemical pollutants that substantially contribute to unhealthy
        indoor air. The use of floor coverings that can be maintained
        with minimal maintenance and without the use of potentially
        hazardous chemicals - i.e. floor coverings which do not require
        artificial coatings which eventually need to be stripped with
        potentially hazardous chemicals and then re-coated - should
        be included as a requirement or as an option to receive
        additional points.

        Do you have any suggestions on how to improve the technical
        requirements of this credit? Please explain, providing
        citations to data and research where possible.
        Again, requiring the use of floor coverings that can be
        maintained with minimal maintenance and without the use of
        potentially hazardous chemicals - i.e. floor coverings which do
        not require artificial coatings which eventually need to be
        stripped with potentially hazardous chemicals and then re-
        coated - should be included as a requirement or as an option
        to receive additional points

        Will the changes in this credit (if any) affect your ability to
        help transform the healthcare facility market? If so, please
        explain how and why.
What is the threshold? It should be National Ambient Air
Quality Standard according to ASHRAE Standard 62. EQ pr1
already requires outdoor air including local sources of
contamination to be analyzed and, if necessary, treated to
meet NAAQS and requires the designer to provide
documentation - which is seldom provided. EQ pr1 should
require documentation of the analysis.


Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Eliminate the bullet "To minimize contamination from exhaust
contaminants at outside air intakes:" The paragraph has no
meaning taken independently and repeats information
previously expressed. Bullets 5 and 6 seem to overlap. The
pollutants in the NAAQS have already been addressed in EQ
pr1 so eliminate references to CO, NO2, SO2, O3, PM10 and
PM25. Modify bullet 5 as follows: Other contaminants specific
to the conditions of the project shall be included in the
analyses (i.e. considering such sources as fume hood exhausts,
sterilizer exhausts, housekeeping area exhausts, smoking
areas, etc.). Modify bullet 6 as follows: For other air
contaminants, the outside air intake concentrations shall be no
higher than 2.5% of the 8-hour and short term/ceiling limits
prescribed by the Permissible Exposure Limits (PELs)
established by the Occupational Safety and Health
Administration (OSHA), or the Threshold Limit Values (TLVs)
established by the American Council of Governmental
Industrial Hygienists (ACGIH), or the Recommended Exposure
Limits (RELs) established by the National Institute of
Occupational Health and Safety (NIOSH), whichever is lower.
Where the concentrations of air contaminants at the outdoor
air intake cannot be achieved for how to improve the technical
Do you have any suggestions on specific pollutants,
requirements of this credit? Please explain, providing
citations to data and research where possible.
The Item 1 requirements and Item 2 requirements are
mutually exclusive. It is inappropriate to have an either/or
approach to these items. Due to the emissions issues
associated with numerous materials in the furniture industry,
emissions testing requirements cannot be fully addressed by
banning certain materials. Requiring emissions testing will
ensure that problems do not occur from materials used to
substitute for the various resin types and chemistries banned
in Item 1. Also, there is some inconsistency in the emissions
requirements for Item 2. The office model employed in the SCS
IA Gold program for furniture is not consistent with the Section
01350 criteria. Therefore, some products certified under that
program may not meet the requirements of this credit. Only
the GREENGUARD Children and Schools program and the CRI
Green Label Plus programs have been evaluated for
equivalency to the 01350 requirements. Until the SCS IA Gold
program has undertaken this review process, the program
should not be referenced for compliance to this credit.




Do you have any general comments?
The chemical bans should be kept in the MR section but
moved to MR Credit 4.3. The emissions requirements included
in this credit should be moved under EQ Credit 4 as OPTION 5.
Section 01350 includes requirements for a very limited list of
chemicals based on the CA OEHHA CRELs and does not include
criteria for TVOC. This is inconsistent with other requirements
of the standard that include more robust requirements based
on nationally recognized toxicology lists. For example, EQ
Credit 5 requires comparison of outside air intake contaminant
concentrations against more complete, nationally recognized
lists including OSHA PELs, ACGIH TLVs, and NIOSH RELs. Also
note that while Section 01350 does not include TVOC criteria,
EQ Credit 3.2 requires the building to meet specific TVOC
criteria for clearance. For the overall IAQ management plan of
the building to work, it will be necessary to align the product
specific emissions goals with the building IAQ clearance goals.
Since GREENGUARD Children and Schools program includes
TVOC criteria that will help ensure that building clearance
goals are met, this program should be referenced for all
emissions based requirements.
Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
The requirements are generally appropriate for high
performance healthcare. However, Part 1 and Part 2 are not
necessarily linked and should be separated. Item 1 (chemical
bans) should be moved to MR Credit 4.3 and the emissions
requirements should be a separate credit under EQ Credit 4 as
OPTION 5.

Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
Many responsible furniture manufacturers have been
addressing the materials and emissions issues included in the
requirements of this credit. By requiring either material bans
or emissions measurement (and not requiring both), LEED for
Healthcare may not be appropriately rewarding manufacturers
that have taken a holistic path toward sustainability.

Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
LEED-NC took out the drains requirement I think because it
was confusing what the specific requirement was. Either define
clearly how this type of plumbing is different than
conventional plumbing or remove the requirement.




Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
see technical comments

Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
see technical comments

Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Modelling to achieve compliance "under worst case
meterological conditions" is not a practical or scientific
approach. Is it necessary to undertake modelling in every
instance? Suggest that there should be some conditions. A

Do you have any general comments?
see technical comments
Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
1. Define 'high volume' under definition section.


Do you have any general comments?
1. Credit does not adequately address naturally ventilated
spaces.
Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Define "worst case meteorological condition." Define NAAQS.




Do you have any general comments?
Improved over GGHC credit requirements.
Do you believe that the requirements presented are
appropriate for high performance healthcare facility
A

Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
A

Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
- Suggest adding ETO to the list of regulated emissions either in
this credit or in EA Credit 8.

Do you have any general comments?
COMMENT FROM LEED FOR HEALTHCARE WORKSHOP AT
GREENBUILD 2007.
Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
I would like to see more emphasis on chemicals related to
worker safety. I feel that this is a very important issue and
should not be dropped from the LEED for Healthcare guide.


Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
Having more credits and information regarding environmental
quality - indoor Chemical and pollution source will help shape
our workplace to be safer. I would like to see more points for
greener options in this category.

Do you have any general comments?
We need to make this safer for workers. We need more
governmental regulations for chemical safety.
Do you have any general comments?
Need to define who and what the NAAQS is and what they
regulate. Is the term "containment drains" referring to holding
tanks?
LEED for Healthcare Committee Response




Thank you for your comment. The HCC will consider adding reference to this issue to
the reference guide.




Thank you for your comment. The HCC will consider adding reference to this issue to
the reference guide.




Thank you for your comment. The HCC will consider adding reference to this issue to
technologies and strategies in this credit.
Thank you for your comment. The NAAQS thresholds are stated in the credit
requirement language.




Thank you for your comment. We apologize for the formatting of this credit
language. The credit language will be revised and included in the second public
comment draft.
Thank you for your comment. However, this is not a commnent for EQ Credit 5 .




Thank you for your comment. However, this is not a commnent for EQ Credit 5 .
Please see the MR section for comments and responses.
Thank you for your comment. However, this is not a commnent for EQ Credit 5 .




Thank you for your comments.




Thank you for your comment. We have removed the reference to containment
drains from the credit language in the second public comment draft.




Thank you for your comment.




Thank you for your comment.
Thank you for your comments. "worst case meterological conditions" will be
defined in the reference guide




Thank you for your comment.




Thank you for your comment. The term "high volume" is used in multiple LEED 2009
and will be defined in the reference guide.


Thank you for your comment.




Thank you for your comment. These will be defined in the reference guide.




Thank you for your comment


Thank you for your comment




Thank you for your comment




Thank you for your comment. ETO sterilants would be included in the broader
definition of sterilants already in the language.


Thank you for your comment.
Thank you for your comment.




thank you for your comment. Your recommendation will be valuable during the next
LEED for Healthcare version devlopment.




Thank you for your comment.


Thank you for your comment. NAAQS will be defined in the final version. We have
also removed the reference to containment drains from the credit language in the
second public comment draft.
LEED for Healthcare 1st Public Comment Period Comments & Responses
Environmental Quality Credit 6.1

Requirement Number          CreditDescription
Credit 6.1                  Controllability of Systems:
                            Lighting




Credit 6.1                  Controllability of Systems:
                            Lighting
Credit 6.1   Controllability of Systems:
             Lighting
Credit 6.1   Controllability of Systems:
             Lighting




Credit 6.1   Controllability of Systems:
             Lighting
             Lighting




Credit 6.1   Controllability of Systems:
             Lighting




Credit 6.1   Controllability of Systems:
             Lighting
Credit 6.1   Controllability of Systems:
             Lighting
Credit 6.1   Controllability of Systems:
             Lighting
ment Period Comments & Responses


        Comments
        Do you have any general comments?
        Clarify that window shades that require occupant control are
        not the windows which allow the nurses to see in the room,
        but the exterior windows.




        Do you believe that the requirements presented are
        appropriate for high performance healthcare facility
        construction? Please explain.
        It seem that the credit requirements dictate automatic window
        treatments in patient rooms - if so, this is a costly and
        prohibitive requirement.


        Will the changes in this credit (if any) affect your ability to
        help transform the healthcare facility market? If so, please
        explain how and why.
        If I understand this vaguely worded credit, the window
        treatment requirement will be extremely difficult and costly to
        meet, and would seriously constrain the design of patient
        rooms. Patient room design should remain as flexible and non-
        prescriptive as possible.

        Do you have any general comments?
        The window shade control requirement is vaguely worded -
        "Provide occupant controls over window shades, blinds,
        and/or curtains that are readily accessible from the patient
        bed." Is the intent of the credit that: a) all window treatments
        shall have occupant controls "readily accessible from the
        patient bed", or b) that only such windows as are "readily
        accessible from the patient bed" are required to have
        occupant controls? If the intent is a) this is a serious drawback.
        Most windows in patient rooms are not readily accessible from
        patient beds - behind a patient bed is a headwall with medical
        gasses, nurse call systems and other services. Patient beds are
        almost never located on exterior walls, and requrie staff and
        visitor circulation on each side and the foot of the bed.
        Patients cannot physically reach windows, window treatment
        rods or cords. If occupant controls for all patient room window
Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Delete the requirement "Provide occupant controls over
window shades, blinds, and/or curtains that are readily
accessible from the patient bed." Add a Potential Technologies
& Strategies statement,"Provide automatically operated
patient room window shades, blinds and/or curtains with
controls that are readily accessible from the patient bed, or
arrange window treatment controls so that they are within
easy reach of a bed-ridden patient."


Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
Is something missing from the paragraph that begins "In staff
areas . . ." It seems like the remainder of the paragraph could
stand on its own and has no relation to "staff areas." If the
intent is to three-way switch the lighting from both the patient
zone and the staff area then this requirement lacks merit. The
language about multi-occupant spaces doesn't seem to relate
to "specific groups." The only time you encounter specific
groups in a classroom is when the instructor dreams up one of
those dopey "break into small groups" events. The language in
LEED® NC seems to be more flexible. "In multi occupant
spaces provide controls to allow the lighting to be adjusted to
meet group needs and preferences." I have always looked at
that as multi-occupant work spaces rather than classrooms
and conference rooms. Classrooms and conference rooms
usually get lighting controls without the benefit of a LEED®
incentive. The medical records transcription or accounting
function is where the incentive of a LEED® credit is needed.




Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
The requirement to include control of window shading from
the patient bed may discourage many projects from pursuing
the credit. Is the risk of losing all lighting controllability worth
the benefit of the few projects that can afford motorized
window shading?

Do you have any general comments?
no

Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Revise the intent language as follows: Provide a high level of
lighting system control by individual occupants and in multi-
occupant spaces (i.e. classrooms or conference areas) to
promote the productivity, comfort and well-being of building
occupants. Revise the first requirement as follows: Provide
lighting controls for 90% (minimum) of the building occupants
to enable adjustments to suit task needs and preferences of
individuals and work groups. Revise the third requirement as
follows: Provide individual lighting controls for each bed in
multi-occupant spaces, such as recovery rooms, emergency
departments, infusion areas, and similar open areas.




Do you believe that the requirements presented are
appropriate for high performance healthcare facility
Indoor Environmental Quality 6.1: Controllability of Systems:
Lighting AEI Comment: Consider further defining what it means
to be "readily accessible from the patient bed". In many cases,
in-patient critical care, pediatric, and psychiatric patient rooms
practitioners insist in full control of lighting devices in these
spaces.




Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Install thermal comfort controls in patient areas that are
readily accessible from the patient bed.
Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
1. Define 'Occupants' under definitions section.




Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
Yes, but with some suggestions below. They requirements
empower the patient and family to control their environment,
reducing stressand enhancing the healing process. They also
reduce the energy consumption of the lighting systems
effected, creducing the overall impact the facility will have on
the evnironment over its life cycle.


Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
Yes. The proposed changes will help a project design team
create a built environment that will enhance the experience
for the patient and family, and improve the quality of the work
environment and experience for the hospital staff. Overall this
will promote healing for the patient, shorten hospital stays,
and reduce the risk acquired infections and medical errors.


Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
My suggestions focus on enhancing lighting control for the
patient, family, and staff in the patient room and other critical
spaces in the hospital. I recommend that requirements for
enhanced lighting control be established for specific critical
spaces in the hospital as defined below. This will enhance
patient comfort and well being, reduce stress, create an
enhanced healing environment, improve the productivity of
the care-giving staff, and reduce staff fatigue and resulting
medical errors. Patient rooms: Lighting controls should be
located for the patient as well as the nursing staff. Multi-
location dimmers or multiple light level switching controls
should be positioned at the door of the patients' rooms to
allow the nursing staff the ability to create a comfortable
lighting environment without disrupting the patient. Additional
control should be provided at the patient bed so that calls to
the nursing staff might be reduced. In patient rooms, lights and
dimmer or switch controls used for charting purposes or to
read instruments should be selected and located as to not
disturb the patient at night (Reference ANSI/IESNA RP-29-06,
Lighting for Hospitals and Healthcare Facilities, Section 4.3.2.)
Dialysis unit: Provide lighting controls and window shade
controls that are readily accessible to the patient . (Reference
ANSI/IESNA RP-29-06, Lighting for Hospitals and Healthcare
Facilities, Section 4.1.8) Radiation Therapy, CAT scan and MRI
units: Provide adjustable lighting via dimmers or multi-level
switching to relax patient, reduce stress, and minimize
claustrophobia. (Reference ANSI/IESNA RP-29-06, Lighting for
Hospitals and Healthcare Facilities, Section 4.17.3) Nurseries:
Do you believe that the requirements presented are
appropriate for high performance healthcare facility
Yes, to an extent. Some of the requirements seem a bit
extravagant and costly for most owners.




Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
No

Do you have any general comments?
No
Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Remove requirement to have control of window shades from
the bed. This drives an expensive solution. Operable shades at
the window should suffice. Reconsider requirement to provide
individual lighting control in each bay of recovery rooms, etc.
Consider reducing the requirement to providing individual
lighting control in each recovery bay, etc. Consider permitting
banks of rooms to be switched together. If switching in
recovery areas, etc. is included there should be a written
clarification that occupancy sensors should not be employed in
areas where patient safety could be impacted.


Do you have any general comments?
Is there an example of the specification for remote window
shades from patient beds?
LEED for Healthcare Committee Response

Thank you for your comment. The window shades will be defined in the reference
guide as exterior window shades to control light and vision to the exterior of the
building.




Thank you for your comment. The HCC discussed the cost impact of automatic
shades and determined that the costs were within reason for obtaining this credit as
many new facilities are already implementing automatic shades in patient rooms.




Thank you for your comment. The HCC discussed the cost impact of automatic
shades and determined that the costs were within reason for obtaining this credit as
many new facilities are already implementing automatic shades in patient rooms.




Thank you for your comment. The intent of the credit is to have the window
treatment controls readily accessible from the patient bed for control of exterior
window treatments. This allows the patient to control the view or amount of
daylight into the room from the patient bed without having to call the nursing staff
to assist.
Thank you for your comment. At this time, LEED for Healthcare will maintain the
requirements as presented. However, please review the revised credit in the second
comment period.




Thank you for your comments. We apologize for the formatting issues in the first
version of the credit. We have corrected this to align with LEED 2009.
Thank you for your comment. We hope that project teams will provide lighting
controls in all spaces regardless of their achievement of the window treatment
provision. Individual lighting control is standard operating procedure.




Thank you for your comment.




Thank you for your comments. We apologize for the formatting issues in the first
version of the credit. Please note that your suggested revision to the third
requirement is not changed from the original language of the credit.




Thank you for your comment. This language will be further clarified in the credit.




Thank you for our comment. Please note that this credit covers lighting control
rather than thermal control.
Thank you for your comments. We apologize for the formatting issues in the first
version of the credit. We believe this issue will addressed in the second public
comment version of the credit.




Thank you for your comment.




Thank you for your comment.
Thank you for your comment. Your recommendation will be incorporated in the LEED
Reference Guide.




                                                                                       reference guide



Thank you for your comment. The HCC discussed the cost impact of automatic
shades and determined that the costs were within reason for obtaining this credit as
many new facilities are already implementing automatic shades in patient rooms.




Thank you for your comment.


Thank you for your comment.
Thank you for your comment. At this time, LEED for Healthcare will maintain the
requirements as presented. However, please review the revised credit in the second
comment period.




Thank you for your comment. There are examples of automatic control of window
treatment from patient beds.
reference guide
LEED for Healthcare 1st Public Comment Period Comments & Responses
Environmental Quality Credit 6.2

Requirement Number          CreditDescription
Credit 6.2                  Controllability of Systems:
                            Thermal Comfort


Credit 6.2                  Controllability of Systems:
                            Thermal Comfort




Credit 6.2                  Controllability of Systems:
                            Thermal Comfort




Credit 6.2                  Controllability of Systems:
                            Thermal Comfort
Credit 6.2   Controllability of Systems:
             Thermal Comfort
ment Period Comments & Responses


        Comments
        Do you have any general comments?
        - Must patient be able to reach thermal controls?


        Will the changes in this credit (if any) affect your ability to
        help transform the healthcare facility market? If so, please
        explain how and why.
        The stipulation that patients have access to comfort controls
        largely makes sense in a healthcare context.

        Do you have any suggestions on how to improve the technical
        requirements of this credit? Please explain, providing
        citations to data and research where possible.
        The ability to selectively disable patient control over
        immediate environmental conditions, or at least to limit the
        range of values they can select, might make sense for impaired
        patients.

        Do you have any general comments?
        No

        Do you believe that the requirements presented are
        appropriate for high performance healthcare facility
        construction? Please explain.
        The requirements make sense.

        Do you have any suggestions on how to improve the technical
        requirements of this credit? Please explain, providing
        citations to data and research where possible.
        1. Define 'occupants' under definitions section. 2. Potential
        strategies - UFAD not preferable in a hospital due to infection
        control issues.

        Do you have any suggestions on how to improve the technical
        requirements of this credit? Please explain, providing
        citations to data and research where possible.
        The provisions for operable windows appears to conflict with
        the requirement for a VAV system in EA credit 1.
Do you have any general comments?
Improvement over GGHC not to require the controls be
accessible from the patient bed.
LEED for Healthcare Committee Response

Thank you for your comment. No, there is no requirement that the thermal control
be located within reach of the patient.




Thank you for your comment and support.




Thank you for your comment. This "override" capability is not inconsistent with the
credit intent. As long as the controls are provided for individual control, the credit
intent is met.


Thank you for your comment.




Thank you for your comment.




Thank you for your comment. We will provide a definition for "occupants" in the
Reference Guide. There may be areas of a hospital (administrative areas) that are
appropriate for UFAD), though we concur that its use is not universally appropriate.




Thank you for your comment. The use of operable windows does not preclude or
conflict with the use of VAV. Please note that VAV is only a requirement if the
prescriptive path option of EA c1 is followed.
Thank you for your comment.
LEED for Healthcare 1st Public Comment Period Comments & Responses
Environmental Quality Credit 7

Requirement Number          CreditDescription
Credit 7                    Thermal Comfort




Credit 7                    Thermal Comfort




Credit 7                    Thermal Comfort
Credit 7   Thermal Comfort




Credit 7   Thermal Comfort




Credit 7   Thermal Comfort
Credit 7   Thermal Comfort
ment Period Comments & Responses


        Comments
        Do you have any general comments?
        No

        Do you believe that the requirements presented are
        appropriate for high performance healthcare facility
        construction? Please explain.
        As a thermal satisfaction survey only the credit should be a
        freebie. Add ventilation quality to assessment and give it some
        Healthcare "gravitas."

        Will the changes in this credit (if any) affect your ability to
        help transform the healthcare facility market? If so, please
        explain how and why.
        Add ventilation to the assessment and retitle the credit Air
        Quality and Thermal Comfort Assessment. LEED HC is about
        health right?


        Do you have any suggestions on how to improve the technical
        requirements of this credit? Please explain, providing
        citations to data and research where possible.
        Add the words "air quality" to the description of the
        assessment.

        Do you have any general comments?
        The requirement says occupants, which I interpret to include
        patients and visitors. Is that what you want?

        Do you believe that the requirements presented are
        appropriate for high performance healthcare facility
        construction? Please explain.
        The requirements make sense.

        Will the changes in this credit (if any) affect your ability to
        help transform the healthcare facility market? If so, please
        explain how and why.
The integration of LEED NC's EQ7.2 credit for thermal comfort
verification makes sense in a healthcare setting where patient
comfort is critical. The addition of requirements for
compliance with Guidelines for the Design and Construction of
Healthcare Facilities presumably makes sense as well.


Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Perhaps decrease the acceptable proportion of occupants who
are dissatisfied from 20% to 5% or lower.




Do you have any general comments?
No

Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
1. Suggest adding another requirement - Group spaces with
similar thermal comfort criteria. The programming & zoning
could accomodate for that.
Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
The credit requirements may be more easily achieved if the
user is directed to the specific section of the AIA Guidelines
that is relevant. We suggest the following change to make this
clearer. "Design HVAC systems and the building envelope to
meet the requirements of ASHRAE 55-2004 and local codes or
current AIA Guidelines for the Design and Construction of
Healthcare Facilities, Table 2.1-2 requirements for design
temperature and relative humidity, where local codes do not
apply. Demonstrate design compliance in accordance with
ASHRAE 55-2004, Section 6.1, Documentation."




Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
No
Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
No

Do you have any general comments?
No

Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Clarify whether or not patients and visitors are included in the
occupants to be included in the survey. Suggest that survey be
limited to full time staff. Patient and visitors are transient and
do not provide an accurate baseline to gauge whether changes
are necessary and if changes address the complaints as the
patients/visitors will likely be gone before the changes are
implemented. Staff should be the focus of the survey.
LEED for Healthcare Committee Response

Thank you for your comment.




Thank you for your comment. This credit combines the requirements of LEED-NC
Credit 7.1 and 7.2 into a single credit, which we believe addresses your comment.




Thank you for your comment. This credit combines the requirements of LEED-NC
Credit 7.1 and 7.2 into a single credit, and the ventilation quality dictated under the
prereqsuisite address your concerns for both ventilation and thermal comfort.




Thank you for your comment. The HCC has elected to retain the wording of the
credit in its current form.


Thank you for your comment. We will define occupant in the Reference Guide. We
agree that the term includes patients and visitors as well as staff.




Thank you for your comment.
Thank you for your comment.




Thank you for your comments. At this time, LEED for Healthcare will maintain the
referenced threshold to maintain consistency with LEED products. However, this
comment will be valuable during the next LEED revision process.




Thank you for your comment.




Thank you for your comment. The control of multi-occupant spaces is covered in EQ
credit 6.2.




Thank you for your comment. Your comments have been incorporated into the
revised credit language. Please review the revised credit language in the second
round of public comment.




Thank you for your comment.
Thank you for your comment.


Thank you for your comment.




Thank you for your comment. This clarification will be included in the revision of the
credit language in the second comment period draft.
LEED for Healthcare 1st Public Comment Period Comments & Responses
Environmental Quality Credit 8

Requirement Number          CreditDescription
Credit 8                    Views and Daylight




Credit 8                    Views and Daylight
Credit 8   Views and Daylight
Credit 8   Views and Daylight




Credit 8   Views and Daylight




Credit 8   Views and Daylight
Credit 8   Views and Daylight




Credit 8   Views and Daylight




Credit 8   Views and Daylight
Credit 8   Views and Daylight




Credit 8   Views and Daylight
Credit 8   Views and Daylight




Credit 8   Views and Daylight




Credit 8   Views and Daylight
Credit 8   Views and Daylight
Credit 8   Views and Daylight




Credit 8   Views and Daylight




Credit 8   Views and Daylight
Credit 8   Views and Daylight




Credit 8   Views and Daylight
ment Period Comments & Responses


        Comments
        Do you believe that the requirements presented are
        appropriate for high performance healthcare facility
        construction? Please explain.
        I think that for 8.1, in a true Diagnostic and Treatment area for
        inpatient care, the expectations for 3 points and likely 2 points
        are unrealistic, particulary for tertiary care facilities. That does
        not mean I will not try to acheive the points, I just believe that
        patient safety & efficiency advocates and patient care models
        will prevail over the evidence based design studies.


        Will the changes in this credit (if any) affect your ability to
        help transform the healthcare facility market? If so, please
        explain how and why.
        Generally I am very pleased with the intent of this credit.


        Do you have any suggestions on how to improve the technical
        requirements of this credit? Please explain, providing
        citations to data and research where possible.
        Site the latest evidence based design studies for patients and
        staff health.

        Do you have any general comments?
        I think 8.1 should refer to all spaces other than inpatient units
        and not specifically to Diagnostic and Treatment Areas. Or
        maybe to Occupiable Spaces other than Inptatient Units and
        define what that means.

        Do you believe that the requirements presented are
        appropriate for high performance healthcare facility
        construction? Please explain.
        Yes.

        Will the changes in this credit (if any) affect your ability to
        help transform the healthcare facility market? If so, please
        explain how and why.
This is an important credit for helping to improve the indoor
spaces by requiring the exposure to the outdoor environment.
I feel this makes a great improvement on basic code
requirements

Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Please be more definitive as to what constitutes a 'View'. A
view could be of mountains, or of a city, or of a parking lot.
Views to the open sky are great, and sometimes shared with a
view of a rooftop. Please try to somehow more definitively
describe these aspects.

Do you have any general comments?
None.

Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
Yes, except as noted below

Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
Unknown

Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
EQ 8.1: Views and Daylight: Diagnostic & Treatment Areas ***
The "11 degree angle" and "90%" requirement must be
defined much more clearly. Is this required from any and every
location within a "perimeter room"? What height is the view
from? A seated position, standing position, or all vertical points
from floor to ceiling? Does "90% of the perimeter rooms"
mean 90% of the total area of all of the perimeter rooms, or
each room either complies or not and then 90% of the total
number of rooms must comply? ---EQ 8.2: Views and Daylight:
Inpatient Units ***Why are "inpatient bedrooms" excluded
from this requirement? ***--EQ 8.3: Views and Daylight:
Daylight Quantity ***This credit should be titled "Daylight
Quantity and Quality" because it restricts maximum da




Do you have any general comments?
No

Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Require glare control under 8.3




Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
Indoor Environmental Quality 8.1/8.2 Views and Daylight AEI
Comment: LEED for Healthcare makes an important
augmentation to the existing daylighting credits with the
requirement to have a minimum of 11 degrees of
unobstructed view. This disallows previous uses of "Zen Views"
and thus places a higher importance on meaningful
contribution of daylight and views to patient and staff health.


Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
Provide diagram showing how to take 11 degree angle of
unobstructed view in the vertical and horizontal direction will
help to clarify the calculation for this credit.


Do you have any general comments?
1. Daylight and views are different issues and often require
different strategies. There should be separate credits for
daylighting and for views.




Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
1. Credit EQ 8.2 - Exclusion of patient rooms from this credit is
troubling. Perhaps a certain level of daylighting in patient
rooms should be a prerequisite. 2. Credit EQ 8.3 - Is the intent
of this credit to provide for energy savings or to improve the
health of patients & staff. Does this include patient rooms?
Again, daylight and view should be looked at separately.
Provide an option to combine both option 1 & 2 Each of the
options for demonstrating compliance has advantages for
different types and orientation of buildings, but it would be
very difficult to get this credit using just one of the options.
Because it makes sense to design a building envelope
differently depending upon which direction it faces (by
responding to sun orientation), it also makes sense to vary the
expected daylight levels depending on orientation. The
possibility of using a blending of Option 1 and Option 2 to
achieve this credit would allow for more flexibility in design
and would address the differences created by sun orientation.
Option 1 - This credit requires quantity of light, but not
necessarily quality of light. The requirement of 25 footcandles
at 9am and 3pm on September 21 favors penetration of direct
sun from the east and west. I would like to see much more
flexibility in the requirements for daylighting and in how it is
defined and more incentives for designing for quality of light
rather than quantity


Do you have any general comments?
Credit needs to explain how to interpolate perimeter area
chart for D&T floor plates that are bigger than 50,000sf. Do
you interpolate based on the 50,000 sf : 15516 ratio?




Do you have any general comments?
Since 8.1 addresses D&T spaces and 8.2 addresses inpatient, is
it the intent that other areas such as administrative areas
would be addressed through Innovation in Design?




Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
8.1: Provide the basis for the 11 degree angle of unobstructed
view and explain how it is to be measured. Provide the basis
for the ratios of perimeter area to floor plate area. These
ratios will be very difficult to achieve and seem
counterintuitive to other areas of consideration including
minimizing footprint and energy consumption. Please clarify
the following: Is it the intention that 1) the building footprint
be designed so that areas of the table fall within the 15'
perimeter strip, and 2) 90% of this area must have compliant
windows? Whether the answer is yes or no, I believe the
language requires much clarification. 8.2: Please clarify what
types of spaces are to be considered by the first point. It is not
clear if staff and public areas are included as it would seem
these are to be covered by the second point. Or is the second
point simply intended to increase compliance from 75% to
90%? 8.3: OPTION 1 and 2: Define "these areas." Is it the 15'
perimeter strip in 8.1, 90% of the 15' perimeter strip in 8.1, the
20' perimeter strip in 8.2, and/or 90% of the perimeter strip in
8.2? OPTION 2: Define daylight factors and how to calculate it.
LEED-NC 8.1 uses the term "glazing factor." Is this the same
thing? Even if so, this document should stand on its own and
include all information necessary to achieve certification.
Do you have any general comments?
Not sure how the requirement for 75% of occupied spaces
(excluding the patient rooms) be within 20 ft of the exterior
wall could be met. I think this credit needs to be written
specifically considering the limitations in the planning of a
nusing unit. Right now it is unrealistic.


Do you have any general comments?
See Green Guide for HC for stronger language with lighting and
circadian rhythm strategies.




Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
Yes

Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
No

Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
It would be helpful to have some definition of what spaces are
considered D&T and Inpatient Areas for the purposes of credit
achievement--i.e. should support offices or storage areas that
serve D&T be included? In addition, the phrasing of the
following section is unclear: "For 1 point, a minimum of 75% of
the occupied areas (excluding inpatient bedrooms) shall be
within 20 feet (or twice the window head height, whichever is
smaller) of the perimeter. All such perimeter areas must have
windows that provide at least an 11 degree angle of
unobstructed view in the vertical and horizontal direction."
Suggest changing the phrasing to specify that *occupants of
qualifying inpatient areas must have access to* an 11 degree
angle of unobstructed view, rather than somewhat
ambiguously stating that the perimeter areas "provide" that
view (i.e., to whom?). The current phrasing leaves open the
possibility that, for instance, a nurse's station located in a
corridor within 20 feet of a perimeter window in a patient
room with a qualifying 11 degree angle of unobstructed view
for the patient, but without a view through that window for
the nurses, qualifies for inclusion.


Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
- Options #1 and #2 should really be regionally specific based
on the prevailing climate of a given region. if the area has a
predominance of sunny days (Southern California), then option
#1 should be used. If the reverse is true, the option #2 should
be used. - - Why are credits 8.1 and 8.2 prerequisites for credit
8.3? Isn't bringing daylight into a health care space a good
thing regardless? Why discourage the practice?




Do you have any general comments?
- Why are inpatient bedrooms excluded from credit 8.2? - The
description of the requirements for viewing angles and
percentages of views really need to be clarified. What is the
vantage point from which these measurements are to be
taken?
Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
"Strategies to consider include building orientation, shallow
floor plates, increased window head and ceiling heights, glazed
partitions, increased building perimeter, courtyards, and atria."
Comments: the addition of hard surface and increased room
volume via increasing the ceiling height will have an adverse
affect on the acoustical comfort of the space. Add the
following bullet on page 116 "Use high light reflectance
surfaces to enhance the lighting, per the recommendations of
IESNA". Add the following bullet to page 116 "Use high light
reflectance surfaces to enhance the penetration of
daylighting." Studies by the Weidt group have shown that the
use of high light reflectance ceilings can increase by 15-20%
the amount of daylight penetrating a space 12'-22' from a
window. Strategies for harvesting daylight and extending it
into interior spaces should be added to this section. (See:
http://www.iesbc.org/content/publications/lightnews/LightNe
ws%20Fall%202003.pdf) Add the following bullet to page 117
"Use high light reflectance surfaces to enhance the penetration
of daylighting." Studies by the Weidt group have shown that
the use of high light reflectance ceilings can increase by 15-
20% the amount of daylight penetrating a space 12'-22' from a
window. Strategies for harvesting daylight and extending it
into interior spaces should be added to this section. (See:
http://www.iesbc.org/content/publications/lightnews/LightNe
ws%20Fall%202003.pdf) Add the following bullet to page 118
"Use high light reflectance surfaces to enhance the penetration
of daylighting." Studies by the Weidt group have shown that
Do use of high light reflectance ceilings
the you have any general comments? can increase by 15-
This credit may favor non-urban sites as there is less flexibility
in the foorplate shape on a dense urban site. Daylight and
views are highly desirable in waiting areas but not desirable in
imaging areas.




Do you believe that the requirements presented are
appropriate for high performance healthcare facility
construction? Please explain.
n/a
Will the changes in this credit (if any) affect your ability to
help transform the healthcare facility market? If so, please
explain how and why.
n/a

Do you have any suggestions on how to improve the technical
requirements of this credit? Please explain, providing
citations to data and research where possible.
n/a

Do you have any general comments?
Wayfinding is an environmental stress. Why does LEED for
Healthcare not include a credit to ensure adequate wayfinding
is provided in a healthcare center? Contact the Center for
Health Design for more empirical research on the detrimental
physiological and psychological effects due to poor wayfinding
in hospitals. Also see Romedi Passini's work. Susan Rowley
former board member of the Environmental Design Research
Association

Do you have any general comments?
This is a great credit but more consideration/focus should be
given to staff who tend to work longer shifts compared to
counterparts in other professions. The longer the shift, the
more important window/view access becomes. Windows at
the ends of corridors (corridors terminating at exterior
window)allow connection to outdoors throughout the day.
What is good for the health of the staff is good for the health
of the patient. Staff lounges should not only have window but
the best views. GS/LS3P
LEED for Healthcare Committee Response




Thank you for your comment. The HCC promotes the importance of views and
daylighting in tertiary care facilities. Neverthelss, the points under the EQc8 credits
have been revised downward as part of the next Public Comments Draft.




Thank you for your comment.




Thank you for your comment. It is anticipated that the Reference Guide will
incorporate such references.


Thank you for your comment. We apologize for this oversight. This clarification will
be included in the second public comment draft of the rating system. Please note
that 8.1 has been moved to be 8.3 in order to better align with LEED 2009.




Thank you for your comment.
Thank you for your comment.




Thank you for your comment. View criteria language is included in the Green Guide
but didn’t' make it to the LEED credit language. View criteria will be incorporated in
the reference guide.




Thank you for your comment.




Thank you for your comment.




Thank you for your comment.
Thank you for your comment. Clearly, the 11 degree angle calculation needs
clarification; in LEED-NC, this calculation is explained in the Reference Guide. The
intent of the '90% of perimeter rooms' is 90% of the spaces - not by area. The
Inpatient Unit areas no longer have a dedicated "view" credit, and are now simply
covered by the Daylight Quantity calculations required to achive a point under
EQc8.1.




Thank you for your comment. See the revised credit language for inclusion of glare
control.




Thank you for your comment and support.
Thank you for your comment. This calculation will be fully explained in the Reference
Guide. It is currently covered in the LEED-NC Reference Guide.




Thank you for your comment. We concur that daylight and views are different
strategies. The form credits are based upon providing views: daylight quantity credit
8.3 (now 8.1 under the Second Public Comment Draft) focuses on daylighting. The
credit prioritizes views because the research supports views as the primary driver of
health and productivity benefit. Under the Second Public Comment Draft, daylight,
views and energy use for lighting have been linked, as they are mutually supportive
strategies.




Thank you for your comment. The intent is to improve the health of paitents and
staff. Removal of patient rooms is because there is no evidence that engineered
daylighting levels enhance healing in hospital settings - the evidence is based on
view. Moreover, experience shows that daylit patient rooms often have window
treatment to lower levels of daylight for patients to sleep.
These credits are intended to achieve what you suggest: 8.1 and 8.2 prioritize views
throughout the building (now 8.2 in the Second Public Comment Draft); 8.3 (now 8.1
under the Second Public Comment Draft) rewards daylight quantity either in
Inpatient Units or in the other part of the hospital (ie, in any area of the hospital that
you can achieve two view points, you can further choose to daylight).
In terms of your comment on focusing on quality rather than quantity, it may be
useful in future development of the rating system.
Thank you for your comment. We debated whether to insert the chart with
interpolation methodology, or also include the formula for direct calculation based
on floor area of your building. Please see the revised credit language in the second
public comment draft. Calculation methodology, interpolation instructions and
instructions for floor plates above 50,000 sf will be forthcoming in the reference
guide.




Thannk you for your comment. The intent was for all areas of the hospital other
than Inpatient Units to be covered by 8.1 (now 8.2 under the Second Public
Comment Draft). Please refer to the revised credit language in the second public
comment draft.Please note that 8.3 has been moved to be 8.1 in order to better align
with LEED 2009.




Thank you for your comment. The 11 degree angle calculation methodology will be
covered by the Reference Guide.
In terms of specific answers to your questions, they are as follows 1) yes; 2) yes, 90%
of the perimeter rooms require windows (not area); though credit achievement only
relies on the existence of the window meeting the 11 degree requirement- if you
provide windows that achieve the daylight quantities outlined in 8.3 (now 8.1 in the
Second Public COmment Draft), you get an additional point.
Again, we will rename the first credit to make it clear that all other spaces than IPU's
are intended to be covered. The 20' perimeter strip is an error in 8.2. Please refer to
the revised credit language in the second public comment draft. Please note that 8.3
has been moved to be 8.1 in order to better align with LEED 2009
Thank you for your comments. Credit language should be within 15'. It is true that
this requirement cannot be met through standard racetrack nursing unit design,
where occupied staff space is locked in the center of the racetrack.




Thank you for your comment. While the committee supports the GGHC Circadian
Rhythm credit and encourage the GGHC to work with project teams devleoping an
innovation credit for healthcare teams, the credit has not been moved into this
document.




Thank you for your comment.




Thank you for your comment.
thank you for your comment. Please refer to the revised credit language in the
second public comment draft.




Thank you for your comment, which we presume is meant for Credit 8.3. The OR
between Option 1 and 2 allows for regional variation in approach, as you suggest.
The current practice of providing windows in corridor circulation (even if those
windows achieve daylighting levels outlined in 8.3) do not address the important
issue of connecting building occupants to nature through views. The only
justification for increasing the total number of points allocated to Views and
Daylighting is to drive market transformation toward buildings that fundamentally
increase the amount of view opportunity for occupants.




Thank you for your comment. The 11 degree angle calculation methodology will be
covered by the Reference Guide and will follow the methodology outlined in LEED-
NC.
The Inpatient Unit areas no longer have a dedicated "view" credit, and are now
simply covered by the Daylight Quantity calculations required to achive a point under
EQc8.1.
thank you for your comment and support. Please see the revised language in the
second public comment draft for inclusion of the suggested language.




Thank you for your comment. While daylight may not be desirable in diagnostic
imaging rooms or reading areas, daylight in shared work areas, offices, and
associated diagnostic imaging workspaces would be welcomed by staff. It is true that
urban hospitals have evolved to be the least daylit of any regularly inhabited building
typology - but that does not mean that such design is encouraged or should be
rewarded in a sustainable building rating system.




Thank you for your comment.
Thank you for your comment.




Thank you for your comment.


Thank you for your comment. This comment will be valuable in future revisions of
the LEED tool.




Thank you for your comment and support. Credit 8.2 was directly aimed at your
comment - as the design of inpatient units begin to move staff space to the
perimeter, it is not only possible but likely that Staff Lounges may get the best views!
However, 8.2 has been removed from the Second Public Comment Draft, and
daylight, views and energy use have been linked in the revised credits 8.1 and 8.2.

								
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