LEED Report 0510

8/4/2019 LEED Report 0510

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The Green Building Debate

LEEDCERTIFICATIONWhere Energy Efficiency

Collides with Human Health

E NVIRONMENT & H UMAN H EALTH , I NC


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ENVIRONMENT & H UMAN H EALTH , I NC .1191 Ridge Road North Haven, CT 06473

Phone: (203) 248-6582 Fax: (203) 288-7571www.ehhi.org

Research and publication of this report was made possible by

The Forrest &Frances Lattner Foundation, The Tortuga

Foundation and The William C. Bullitt Foundation.

LEEDCERTIFICATION

Where Energy EfficiencyCollides with Human Health


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SUSAN S. ADDISS, MPH, MURS. Past Commissioner of Health for the State of Connecticut; Past President of the American Public Health Association; Director of Health Education for Environment andHuman Health, Inc.

NANCYO. ALDERMAN, MES. President of Environment andHuman Health, Inc.; Recipient of theConnecticutBar Association, Environmental LawSections, Clyde Fisher Award; and theNew England Public Health Associations Robert C. Huestis/Eric Mood Awardforoutstandingcontributions to public health in the environmental healtharea.

D. BARRYBOYD, M.D. Oncologist and Director of Integrative Medicine at Greenwich Hospital, Affiliate member of the Yale Cancer Center, Assistant Clinical Professor of Medicine and Curriculum Director for Nutrition and Integrative Medicine, Yale University School of Medicine.

RUSSELLL. BRENNEMAN, ESQ. Connecticut Environmental Lawyer;Co-Chairof the Connecticut League of Conservation; Former Chair of the ConnecticutEnergyAdvisory Board;Past President of the ConnecticutForest andPark Association.

DAVID R. BROWN, SC.D. Public Health Toxicologist; Past Chief of Environmental Epidemiology andOccupational Health at the ConnecticutDepartment of Health; Past Deputy Director of ThePublic Health Practice Group of ATSDRat the National Centers forDisease Control andPrevention

(CDC) in Atlanta, Georgia.

ROBERT G. LACAMERA, M.D. Clinical Professor of Pediatrics, Yale UniversitySchool of Medicine;PrimaryCarePediatrician in New Haven, Connecticut from 1956 to 1996, with a sub-specialty inchildren with disabilities.

Peter M. Rabinowitz, M.D., MPH. Associate Professor of Occupationaland Environmental Medicine, YaleUniversitySchool of Medicine. Director of clinical services at Yale's Department of Occupational andEnvironmental Medicine. Principal investigatoron theCanary DatabaseProject, which looks at animals as sentinels of environmental health hazards.

HUGH S. TAYLOR, M.D. Professorof Obstetrics, Gynecology andReproductive Sciences and Department of Molecular,Cellular andDevelopmental Biology; Chief of theDivision of Reproductive Endocrinology andInfertility, Yale UniversitySchool of Medicine.

JOHN P. WARGO, PH.D. Professorof RiskAnalysis andEnvironmental Policy at Yale UniversitysSchool of Forestry andEnvironmental Studies, andProfessorof PoliticalScience.

Environment and Human Health, Inc.

B oa rd M em be rs


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John Wargo, Ph.D.YALEUNIVERSITY

RESEARCH& EDITINGLinda Wargo, MES

Nancy Alderman, MESPresident

ENVIRONMENT ANDHUMAN HEALTH, INC.

ADDITIONALEDITINGSusan Addiss, MPH, MUrSDirector of Health Education


EDITING ANDGRAPHICDESIGN Jane Manola Bradley, MALS

Medical/Science Writer


Copyright 2010 Environment & Human Health, Inc.

Printed on recycled paper with soy-based inks

Environment and Human Health, Inc.This project was developed and managedby Environment and Human Health, Inc.


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C r e d i t s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1E HH I B oa rd M em be rs . . . . . . . . . . . . . . . . .2 Ta b le s a n d A p pe nd ic es . . . . . . . . . . . . . .5

I. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .6P ro b l em S t a te m e nt . . . . . . . . . . . . . . . . . .6

II. LEED Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11

III. Health Threats Neglected by the LEEDRating System . . . . . . . . . . . . . . . . . . . . . . . . . . . . .15

I nd oo r A ir Q ua li ty . . . . . . . . . . . . . . . . . . . . .17F o r m a l d e h y d e . . . . . . . . . . . . . . . . .19 To b a c c o S m o k e . . . . . . . . . . . . . . . .20P a r t i c u l a t e s . . . . . . . . . . . . . . . . . . .21P e s t i c i d e s . . . . . . . . . . . . . . . . . . . . .23F la m e R et a rd a nt s . . . . . . . . . . . . .26

Drinking Water . . . . . . . . . . . . . . . . . . . . . . .27

P l a s t i c s . . . . . . . . . . . . . . . . . . . . . . .29

B i s p h e n o l - A. . . . . . . . . . . . . . . . . . .2 9

P VC a nd P h th al at es . . . . . . . . . . . 31Per f l uo rooc t ano ic Ac id (PFO A) . . . 34

Ar t i f i cia l Tur f . . . . . . . . . . . . . . . . . . . . . . . .37

IV. Government Adoption of LEED Standards . . . . . 42

L oc al a n d M u ni c ip a l A do p ti o ns . . . . . . . . 4 2Sta te Adopt ions . . . . . . . . . . . . . . . . . . . . . .43

V. False Sense of Security . . . . . . . . . . . . . . . . . . . . .46

H az ar do us C he mi ca ls i n H um anTi ss u e a nd I n do o r E nv i ro n me n ts . . . . . . . 47

S um ma r y o f F in d i ng s . . . . . . . . . . . . . . . . . . . . . .49

R e c o m m e n d a t i o n s . . . . . . . . . . . . . . . . . . . . . . . . .53

E n d n o t e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .65

Table of Contents


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Tables and Appendices


Table 1. Different Types of LEEDBuilding Rating Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12

Table 2. Rating System Categories for New Constructionand Renovations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .14

Table 3. LEED 2009 for New Construction and Major Renovations:Credits Available for Artificial Turf . . . . . . . . . . . . . . . . . . . .41

Table 4. State Efforts to Green Buildings . . . . . . . . . . . . . . . . . .4 4 4 5Notes to Table 4 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7 0

Appendix I. LEED Categories and Point Values . . . . . . . . . . . . . . . . .5 8

Appendix II. U.S. Green Building Council Board of Directors . . . . . . 5 9

Appendix III. Chemicals Often Found in Buildings and Their Health Effects Not Necessarily in LEED Buildings . . . . . . . . . . . . . . . . . . . . . . . . . . . . .6 0 6 3

Notes to Appendix III . . . . . . . . . . . . . . . . . . . . . . . . . . . .7 2

Appendix IV. LEED Minimum Project Requirements . . . . . . . . . . . . . .6 4

LEED Indoor Environmental Quality Standards . . . . . . 6 4

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ew federal, stateand local laws tied toGreen BuildingStandards areon the rise in theUnited States andthroughout theworld. As a growingnumber of governmental regulations are linked to green buildingstandards, certication criteria that insufficiently account for threats tohuman health are becoming deeply embedded in U.S. law.

The U.S. Environmental Protection Agency (EPA) denes green buildingas the practice of creating structures and using processes that areenvironmentally responsible and resource-efficient throughout abuildings life-cycle, from site selection to design, construction,operation, maintenance, renovation and deconstruction. 1

The green building movement is now thriving in many wealthiernations. The building industry began to establish voluntary programsand standards for energy-efficient development following the rapidsurge in energy prices in 1974 after the Mideast oil embargo.

This research report presents a thorough evaluation of the Leadershipin Energy and Environmental Design (LEED) programs consideration of human health within the built environment, as a basis for proposingchanges that would more fully value human health.

Many building programs now exist to encourage energy efficiencyand environmental responsibility. The most prominent and successfulinclude the LEED program sponsored by the U.S. Green Building Council(USGBC), the United Kingdoms Building Research EstablishmentEnvironmental Assessment Method (BREEAM) program, Australias

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The purpose of this report is to evaluate the LEED programs standards that many assume protect humanhealth from environmental hazards within the built environment.

I. I n t r o d u c t i o nProblem Statement

N



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Green Star program, and the U.S. EPAs ENERGY STAR for Buildings

program. All have similar objectives and employ similar criteria toevaluate building performance.

This report evaluates the LEED certication program for NewConstruction and Major Renovation. LEED has also developed othercertication categories, including commercial interiors, core and shells,schools, homes and existing buildings. New rating systems will soon beavailable for health care facilities, retail buildings and neighborhoods.

LEED for new construction evaluates projects, and assigns points orscores for categories such as energy efficiency, site renovation, innova-tive design, efficient waste management, use of recycled materials,access to public transit, and use of building materials deemed to beenvironmentally responsible.

Development projects voluntarily submit building details, and LEEDstaff award certicates according to accumulated points for platinum,gold, or silver performance.These designations are both symbolicallyimportant and economically valuable, as their award tends to increase

property resale value. Governments at all levels have adopted new lawsthat reward LEED certication, including loan guarantees, lower-interestloans, mortgage interest rate reductions, income tax credits, propertytax reductions and other public subsidies.

Green building programs also are attracting considerable investment bythe building industry. The green building market is predicted to morethan double from todays $3649 billion to $96140 billion by 2013. 2

Most corporations, government agencies, and academic institutions arenowgreening their real estate portfolios. 3

The purpose of this report is to evaluate the LEED programs standardsthat many assume protect human health from environmental hazardswithin the built environment. The LEED scoring system is weightedheavily toward energy conservation and the use of new and renewableenergy technologies.

This critique.. . is intended to sound the alarm about

the health dangers of broad adoption of LEED

standards by governments,corporations, and others

unless the LEED award system is changed

to require protectionof human health fromhazardous chemicals.


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The effect is to encourage tighter buildings, resulting in lower levels of

exchange between indoor andoutdoor air. Since indoor air is often morecontaminated than outdoor air, the effect may intensify chemicalexposures, increasing the likelihood of unintended health consequences.

Elements of the built environment that potentially affect human healthinclude the location of buildings, waste management, building materials,infrastructure to deliver air and water, furnishings, and appliances thatburn fuels indoors. All of these elements are considered in thisassessment of the growing conict between green buildingdevelopment standards and human health.

Much of this critique is devoted to the LEED programs failure to placeenough emphasis on the indoor air in the built environment. Buildingmaterials are known to include many well-recognized toxic substances,including metals, adhesives, plastics, solvents, ame retardants, sealantsand biocides.

The nal building structure comprises thousands of these chemicals,and many materials off-gasor become airborneand are inhaled

by occupants. Chemicals often employed include respiratory stressors,neurotoxins, carcinogens, reproductive hazards, hormone mimics anddevelopmental toxins.

EPA now estimates that Americans spend, on average, 90 percent of their time indoors or within vehicles. The time within vehicles isapproximately 5 percent. Time spent outdoors is declining, and thistrend is associated with a growing sedentary lifestyle and the increasinguse of electronic media. The effect is increased human exposure toindoor chemical mixtures that are not monitored or managed under

LEED requirements.

The LEED program fornew construction and renovationconsidershuman health within itsindoor environmental qualitycategory, which isallotted 15 points out of a possible total point score of 110. Thus, humanhealth concerns constitute only 13.6 percent of the total possible award.

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A building may receiveplatinum, or the highest ranking in the LEED system,without any points beingawarded in the category intended to protect human health.


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Points may be awarded in other subcategories, including daylight and

views, thermal comfort, lighting, air delivery monitoring, ventilation,chemical and pollutant source control, and material emissions.

Chemical and pollutant source control and materials emissions areperhaps most relevant to humanhealthamong all the criteria considered,yet collectively account for a very small percentage of the total scoreawarded to a project . A building may receive platinum, or the highestranking in the LEED system, without any points being awarded in thecategory intended to protect human health (Appendix I).

During the last half-century, societys growing exposure to chemicalshas been accompanied by an increase in the prevalence of manyillnesses and conditions. These include respiratory diseases, childhoodasthma, neurological impairments, declining sperm counts, fertilityfailure, increase in autoimmune disease and severe allergies, breastand prostate cancers, and developmental disorders among the young.Some of these problems have been caused or exacerbated by exposureto commercial chemicals and pollutants. 4 There is little doubt, forexample, that tobacco, lead, mercury, radionuclides, solvents, vehicle

exhaust, combustion by-products, dioxins, PCBs and many pesticideshave caused extensive human illness.

The rise in childhood asthma, beginning in the early 1980s, hasparalleled an increase in energy efficiency of buildings, and datasuggest that increased chemical exposure in indoor environments maybe the reason. Greater insulation, less ventilation, and a huge increase innew chemicals and products, within new buildings, collectively inducechemical exposures and potential health effects never previouslyexperienced in human history.

LEED building certication standards that insufficiently account forthreats to human health are being adopted or encouraged by many U.S.laws and regulations. A rapidly growing number of federal, state, andlocal laws and regulations are adopting LEED standards that affectbuilding codes and zoning and subdivision regulations.

Greater insulation, lessventilation, and a huge

increase in new chemicalsand products, within new

buildings,collectively inducechemical exposures and

threats to health never previously experienced

in human history.


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In Connecticut, for example, any new state building costing more than

$5 million must achieve LEED certication. Many corporate, govern-mental and educational institutions are now required by law or policyto meet LEED standards for future development and renovations.

As the world wrestles with climate change, nations, corporations, andindividuals are reconsidering how they produce and consume energy.Clearly, the building sector is a keystone to a sustainable energy future.

Within the United States, for example, more than 100 million buildingsconsume 76 percent of the nations electricity and emit nearly half of the

countrys greenhouse gases. Energy consumption within buildings ispredominantly used to heat and cool air, to provide light, to heat water,and to run electronic equipment.

This critique is not meant to diminish the importance of the GreenBuilding Councils efforts to encourage greater energy efficiency withinthe built environment. It is, however, intended to sound the alarm aboutthe health dangers of broad adoption of LEED standards by governments,corporations and others, unless the LEED award system is changed to

require protection of human health from hazardous chemicals.

The Green Building Council is an association of private executives fromthe elds of engineering, construction and architecture, and representa-tives of trade associations (Appendix II). Many of these individuals havelittle expertise in the chemicals used in the building industry, or thepotential effects on human health from exposure to these compounds.

The Green Building Council does not disclose the points it awardsfollowing its evaluation of individual building components and

performance. The Council also remains unaccountable to the public,and it is not subject to the Administrative Procedures Act or the Freedomof Information Act. Despite the freedom from oversight by either theCongress or state legislatures, LEED standards are being rapidlyincorporated into diverse laws, regulations and policies at all levels of government.

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The Green Building Council is an association of privateexecutives from the elds of engineering, constructionand architecture, and representatives of tradeassociations. Many of these individuals have

little expertise in thehazards associated withchemicals used in thebuilding industry, or the potential effects on humanhealth from exposure tothese compounds.


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he U.S. Green Building Council (USGBC) was formed in 1993 as a non-prot green buildingorganization. By 1994, the organization hadformed a committee composed of architects, real estate agents, abuilding owner, a lawyer, an environmentalist and industry repre-sentatives to develop a certication system for the sustainable buildingindustry, otherwise known as LEED. In 1997, the U.S. Department of

Energy agreed to fund Green Building Councils committee, whichwould launch a program ( LEEDVersion1.0) a year later. In the spring of 2009, LEEDVersion3.0was released .1

LEEDs purpose is to evaluateenvironmental performance from a wholebuilding perspective over a buildings life cycle, providing a denitivestandard for what constitutes a green building. 2 The program isintended to protect the environment, protect occupant health, promotenancial return, provide a standard for the termgreen, and promote anintegrated design process. 3

Energy and sustainable rating programs are developing rapidly andgaining wider adoption in places such as Great Britain, Europe, SouthAfrica, Australia and New Zealand. The most recognized programsoutside the United States include the U.K.s BREEAM and AustraliasGreen Star.

BREEAM, funded mainly by the U.K. government, provides research andinformation to the building industry on environmental protection and

sustainable development. It is the most widely used environmentalrating scheme in the United Kingdom. While voluntary, it adopts the U.K.Building Regulation as a benchmark to rate the level of performanceimprovement. BREEAM was the inspiration for LEED, but lacks the strongcommercial mindset, which the U.K. Green Building Council (UKGBC) isnow trying to replicate. 4

II. LEED Program

T

Despite the freedom fromoversight by either Congress

or state legislatures, LEED standards are being

rapidly incorporated intodiverse laws, regulations

and policies at alllevels of government.


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Green Star is the most popular voluntary building environmental

assessment program in Australia, and has been adopted in New Zealandand South Africa. Like LEED and BREEAM, it uses a credit rating systemand has become a national guide to evaluate the environmental designand performance of buildings. 5

Over the past decade, LEED has expanded rapidly. Rating systems arenow available for commercial interiors, core and shells, schools, homesand existing buildingsand new rating systems will soon be availablefor health care facilities, retail buildings and neighborhoods.

Since the initial rating systemfor new construction began in2000, there have been roughly35,000 LEED projects in all 50states, totaling over 4.5 billionsquare feet. 6

This report analyzes the LEEDstandards and credits for newconstruction and renovationprojects. In the category of new construction andrenovation, credits may beawarded by accumulatingpoints in seven areas, as shownin Table 2.

L EE D M i n im um P r oj ec t R e q u i re me n t s

The LEED program has adopted certain minimum requirements thatmust be met before any project may be considered for certication. These are extremely important, both for what is required, and what isneglected.

Existing Rating Systems

New Construction

Commercial Interiors

Core & Shell

Schools

Homes

Existing Buildings: Operations & MaintenancePending Rating Systems

Healthcare

Retail

Neighborhood

20002004

2006

20072007

2008

In Review

Passed Ballot Phase

Begins 2010

Year Adopted

Table 1. Di erent Types of LEED Building Rating Systems


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None of the minimum requirements explicitly addresses the need to

reduce chemical exposures or to protect human health. While LEEDrequires compliance with environmental laws, including all applicablefederal, state, and local building-related regulations, these laws restrictthe use and concentrations of very few chemicals in indoorenvironments. This is well demonstrated by the presence of manyhazardous chemicals in human tissues, as shown in the additional casestudies that follow.

L E E D I nd o o r A i r Q u a l i t y P e r f o r ma n c e

The rating category intended to encourage protection of health is titled,Indoor Environmental Quality. A building can achieve a total of 15points in the indoor environmental quality category among a possibletotal of 110 from all other rating categories. However, 8 of the 15possible points may be awarded for lighting, daylight and views (3points possible), thermal comfort (3 points possible), and air qualitymanagement planning during construction (2 points possible).

Thus, only 7 out of a possible 110 points have the primary intent

to limit hazardous chemicals within the built environment.Since the highest building rating possible onlyrequires a total score of 80 points, LEEDcertication is possible, even at thehighest platinum level, withoutearning credits in the indoorair category, the categorymost likely to protecthuman health.

Only 7 out of a possible110 points have the primary

intent to limit hazardouschemicals within the

built environment.


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Table 2. Rating System Categories for NewConstructionandRenovations

DESCRIPTIONTOTAL

POSSIBLEPOINTS

Energy and Atmosphere

Sustainable Sites

Indoor Environmental Quality

Materials and Resources

Water E ciency

Innovation inDesign

Regional Bonus Credits

CATEGORY

Includes energy use monitoring, e cient design and construction, e cient appliances and systems, and use of renewable and clean sources of energy.

35

26

15

14

10

6

4

Credits allocated to characteristics that minimizeimpact on ecosystems and waterways, encourageappropriate landscaping, utilize smart trans porta-tion choices, control stormwater runo , and reduceerosion, light pollution, heat island e ect and construction-related pollution.

Promotes strategies that enhance indoor air quality, increase natural daylight and views,and improve acoustics.

Promotes waste source reduction, reuse and recycling;acknowledges sustainably grown, produced and transported materials.

Promotes e cient appliances, xtures and ttings indoors, and rewards e cient water

use in landscaping.

Points credited for using new/innovative technologiesand strategies to improve a buildings performancebeyond LEED credits. Provides points for including aLEED Accredited Professional in the project.

Speci c credits available depending on buildingsregion of the country. For example, additional credits in the southwest available for water e ciency; credits in the northeast for sustainablesites or insulation. 7

If building projects meet the above requirements, they are assessed to determine their total allocation of credits. Four levels of certi cation are possible, depending on the number of creditsearned: Certi ed 4049 credits; Silver 5059 credits; Gold 6079 credits ; Platinum 80110 credits.

Source: USGBC. LEED 2009 for New Construction and Major Renovations.

110Total Points Possible


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he Green Building Council requires that all certied projects complywith existing environmental laws. The United States has one of themost complex bodies of environmental law in the world, and althoughmany believe that these laws and regulations provide protection forhuman health, this is not the case. Hazardous chemicals are often usedin consumer products, as well as in commonly used building materials.

Among many serious problems is the failure of the Toxic SubstancesControl Act (TSCA) that was adopted in 1976 to help EPA maintain aninventory of potentially toxic substances. The agency is not empoweredto demand pre-market testing or to regulate the production of chemicalsunless it has compelling evidence that these compounds have signi-cant environmental or health risks. Therefore, the burden on govern-ment is to conduct the testing needed to justify regulation, and this task is now impossible given the staggering number of untested chemicalsand combinations that have been released into the environment.

When TSCA went into effect, 62,000 chemicals were alreadyin commerce and were therefore listed, but immediately exempted orgrandfathered from any data submission requirements. Nearly 20,000additional chemicals have been introduced into commerce since then,yet almost half were not reported to the EPA until after companiesbegan to sell them. EPA has required companies to submit data todemonstrate product safety for only 200 of these chemicals, and it hasused TSCA authority to ban only ve compounds since 1976.

As a result of this neglect, 90 percent of U.S. chemicals produced in thehighest volumes are exempt from federal review under TSCA. Moreover,in 1998 the EPA found that basic toxicity information was available foronly seven percent of them, and no toxicity data was available for morethan 40 percent. For chemicals produced at lower volumes, the agencyhad even less information.

III. Health Threats Neglectedby the LEED Rating System

Hazardous chemicals areoften used in consumer products, as well as in

commonly used buildingmaterials. Among many

serious problems isthe failure of the Toxic

Substances Control Actthat was adopted in

1976 to help EPAmaintain an inventory

of potentially toxic substances. The agency

is not empowered todemand pre-market testing.

T


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The EPA also has reported that 95 percent of the information submitted

by manufacturers is classied as condential business information, andtherefore is not accessible to the publicor to state, local or foreigngovernments.

For the rst time in December 2009, EPA used TSCAs authority to listchemicals that may present an unreasonable risk of injury to health andthe environment. Once on the list, the chemical manufacturer canprovide information to demonstrate that the chemical does not posean unreasonable risk. 1

This EPA list, entitled Chemicals of Concern, includes four classes of chemicals widely used in the building industry and accepted under theLEED rating system. These chemicals include phthalates (used assofteners in exible vinyl products, such as oor and wall coverings);short-chain chlorinated paraffins (secondary plasticizers and ameretardants in plastics); PBDEs (used as ame retardants in textiles,plastics and wire insulation); and peruorinated chemicals, includingPFOA (used for non-stick cookware and stain resistant materials). ManyLEED-certied buildings have been constructed using some of these

compounds.

The LEED rating system does not pay sufficient attention to potentialhealth effects of chemicals and other compounds used in buildingmaterials. The rating system assigns credits for building products thatmay contaminate indoor air and the environment, such as insulationmaterials or other materials that may contain ame retardants, 2 PVCmaterials containing phthalates, and articial turf containing multiplecontaminants.

This section describes how the LEED rating system falls short of protecting human health by failing to encourage health-protectiveindoor air and drinking water quality, and overlooks the use of hazardous substances in building materials and landscaping.

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The LEED rating systemdoes not pay sufficient attention to potential health effects of chemicalsand other compounds used in building materials.


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L E E D O f f e r s L i t t l e A s s u r a n c eo f H e a l t h P r o t e c t i o n

New construction or renovation projects are eligible to receive amaximum of 110 total point credits. Only 15 credits are available formeeting LEED standards for indoor environmental quality, and seven of these credits are associated with thermal comfort and lighting. Sincenone of the eight remaining air quality credits are required, a buildingcould earn no credits for air quality assurance and still be awarded the

highest level of certicationplatinum.

The vast majority of chemicals in indoor environments remainunregulated under federal, state and local law. Moreover, if history isany guide, the situa tion will not improve soon. Without a compre-hensive new approach, these already serious threats to health from airpollution will persist.

EPAs air quality regulations do not assure air quality for many reasons. The agency has spent most of its resources attempting to regulate onlysix criteria pollutants that are common in outdoor air. To a lesserextent, some attention is given to 189 others known as hazardous airpollutants.

Thousands of additional chemicals are routinely released both outsideand inside. It takes about 10 years after EPA becomes aware of a dangerfor it to revise a standard for a single air pollutantsuch as ozone orne particlesand even when tougher stan dards are set, manu-facturers are granted a four-year period before the new rules apply.

Many factors can contribute to poor indoor air quality, includingoutdoor air pollution that ows into buildings. In addition, indoorair can contain pollutants from cleaning products, pesticides,formaldehyde in furniture and insulation, paints and other wood

Heating and cooling systems that recycle air rather than exchanging

indoor and outdoor air, aswell as windows that do

not open, especially in rest rooms, often lead to an

accumulation of chemical and biological agents that

can trigger or exacerbateasthma and lead to other

respiratory problems.

Indoor Air Quality


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nishes, cleaning agents, waxes and polishing compounds, fragrances,

plasticizers in wallpaper, rugs, components of building structures (suchas sealants, plas tics, adhesives and insulation materials), animal andinsect allergens, molds, fumes from household gas appliances andtobacco smoke.

Carbon monoxide, ne carbon particles, and polycyclic aromatichydrocarbons emitted from poorly vented replaces, wood stoves,furnaces, water heaters, kerosene heaters, and idling vehicles inattached garages also may pose a serious threat to health indoors.

By 1994, several scientists had shown that severe asthma occurs moreoften than mild asthma among children liv ing in areas that exceedfederal outdoor air quality standards. In 2000, the EPA estimated thatnine million children were living in areas where ozone stan dards werenot met; 3.5 million children were living in areas where the particulatestandards were exceeded; 2.8 million children were living in countieswhere the carbon monoxide standard was surpassed; and 1.4 millionchildren lived in counties where the air limit for lead was not met.

In 2007, about 20 million children were living in areas of the UnitedStates that failed to meet at least one of the federal standards for airquality. This is especially sobering since indoor air is often more pollutedthan the air outside.

The 1974 Energy Policy and Conservation Act encouraged buildingstandards to promote energy efficiency and reduce the exchange of indoor and outside air. Tighter, more energy-efficient structures oftenhave one-tenth the air exchange rates of older structures with win dows,doors and walls that are less well-insulated and sealed.

Heating and cooling systems that recycle air rather than exchangingindoor and outdoor air, as well as windows that do not open, especiallyin rest rooms, often lead to an accumulation of chemical and biologicalagents that can trigger or exacerbate asthma and lead to otherrespiratory problems.

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Tighter, more energy-efficient structures oftenhave one-tenth the air exchange rates of older structures with win dows,doors and walls that are lesswell-insulated and sealed.


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F o r m a l d e h y d e

Formaldehyde, a volatile organic compound (VOC) often used inbuilding materials, is identied as a human carcinogen and is a seriousairway irritant. It is designated a toxic air contaminant in California withno safe level of exposure. A signicant association has been demon-strated between nasopharyngeal cancer and having lived 10 or moreyears in a mobile home, especially for mobile homes built in the 1950sto 1970s, when formaldehyde resin use increased.

Numerous studies indicate that leukemia and neoplasms of the brainand colon may be associated with formaldehyde exposure. There is asignicant positive association between formaldehyde exposure andchildhood asthma. Associations between residential or school exposureto formaldehyde and respiratory symptoms have been reported, andphysician-diagnosed asthma and bronchitis are associated withincreasing concentrations of formaldehyde. 3

Inside buildings, formaldehyde can off-gas from pressed woodproducts, such as plywood, particleboard and berboard.

Formaldehyde is also found in insulation, durable press drapes, othertextiles and glues. One of the major sources of exposure is frominhalation of formaldehyde emitted from composite wood productscontaining urea-formaldehyde resins. Greater concentrations of formaldehyde have been associated with lower fresh air exchange, aswell as painting, varnishing and acquiring new wooden or melaminefurniture in the previous 12 months. 4

LEED grants one point for documenting that composite wood andagriber products used on the interior of the building (dened as insideof the weather-proong system) do not contain urea-formaldehyderesins (EQ Credit 4.4, Low-Emitting Materials: Composite Wood & Agri ber Products). Points are not awarded for using formaldehyde-freeinsulation, due to an assumption that the phenol-based formaldehydebinders used in batt berglass insulation do not emit formaldehyde at

Inside buildingsformaldehyde can

off-gas from pressedwood products, such as

plywood, particleboard and fiberboard. Formaldehydeis also found in insulation,

durable press drapes,

other textiles and glues.


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levels of concern, and that drywall between the insulation and the

indoor space protects building occupants from exposure to signicantemissions. However, a memo from the Healthy Building Network recommends avoiding this material, noting that berglass insulationcontaining phenol-based formaldehyde binders may expose occupantsto potentially hazardous levels of formaldehyde. 5

To b a c c o S m o k e

The LEED rating systems for new construction and existing buildingsallow smoking within designated rooms that exhaust the smokeoutdoorsprovided that a separate heating and ventilation systemprevents smoke from entering other parts of the building.

This requirement implies that ventilation and air ltration techniquescan remove secondhand smoke from the air, and protect people insidethe building from secondhand smoke. But according to the U.S. SurgeonGeneral and the American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE), ventilation systems cannot eliminatesecondhand smoke, also called environmental tobacco smoke (ETS).

Secondhand smoke is a known human carcinogen. It contains over4,000 chemical compounds, more than 60 of which are known to orsuspected to cause cancer. The dangers of secondhand smoke are wellknown, but each year it is responsible for an estimated 46,000 deathsfrom heart disease in non-smokers who live with smokers; about 3,400lung cancer deaths in non-smoking adults; breathing problems innon-smokers; up to 300,000 lung infections in children younger than18 months of age, as well as increases in the number and severity of asthma attacks in children who have asthma. 6

The workplace is a major source of secondhand smoke exposure foradults. Secondhand smoke exposure in the workplace has been linkedto an increased risk for heart disease and lung cancer among adultnon-smokers. 7 In 2006, Surgeon General Richard Carmona concluded,separating smokers from nonsmokers, air cleaning technologies, and

20


The LEED rating systemsfor new construction and existing buildings permit smoking within designated rooms that exhaust the smoke outdoors.... A report from the U.S.Surgeon General concluded,

even sophisticated ventilation approachescannot completely remove secondhand smoke froman indoor space.


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21


ventilating buildings cannot eliminate secondhand smoke exposure,

since conventional air cleaning systems cannot remove all toxic particlesand gases found in secondhand smoke. A report from the U.S. SurgeonGeneral concluded, even sophisticated ventilation approaches cannotcompletely remove secondhand smoke from an indoor space. Becausethere is no risk-free level of secondhand smoke exposure, anything lesscannot ensure that nonsmokers are fully protected from the dangers of exposure to secondhand smoke. 8

The American Society of Heating, Refrigerating, and Air-ConditioningEngineers (ASHRAE), the international indoor air quality standard-setting body, unanimously adopted a position document onsecondhand smoke, which states, A total ban on indoor smoking is theonly effective means of controlling the health risks associated with ETSexposure. The organization notes that selective location of supplyexhaust vents and air cleaning and ltration may reduce exposure toETS, but limited evidence is available on their effectiveness. 9

P a r t i c u l a t e s

Particulate matter (PM) is a complex mixture of extremely small particlesand liquid droplets. The potential to cause health problems is linked toparticle size. Particles that are 10 micrometers in diameter (PM 10 ) orsmaller can pass through the throat and nose and enter the lungs,harming the heart and lungs, and causing serious health effects. Fineparticles 2.5 micrometers in diameter (PM 2.5) and smaller, are associatedwith an excess risk of both lung cancer and cardiopulmonary disease. 10

Fine particles can penetrate most deeply into the lungs of children, whohave small airways, acting as a nucleus and attracting other hazardous

particles and gases, including carbon monoxide, formaldehyde, sulfurand nitrogen oxides, and PAHs (polycyclic aromatic hydrocarbons)that can be inhaled. These smaller particles may be capable of deliv-ering a higher dose of toxic gases to the lung than coarser particles.Formal dehyde is noteworthy among toxins that can stick to these verysmall particles.

Particulate matter (PM) isa complex mixture of

extremely small particlesand liquid droplets. The

potential to cause health problems is linked to

particle size. Particlesthat are 10 micrometers

in diameter or smaller can pass through thethroat and nose and

enter the lungs, harmingthe heart and lungs,and causing serious

health effects


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Scientists are increasingly concerned about the health effects of such

tiny particles, as they are even found indoors. LEED standards requiretesting for only large-diameter particles (PM 10), providing a credit if itcan be demonstrated that the contaminant maximum concentration forPM10 does not exceed 50 mcg/m

3 following construction (but onlybefore occupation).

Research suggests that this limited testing may not reect the actualPM10 levels inside a building once it is occupied. Researchers sampledthe air in 142 new buildings seeking LEED certication afterconstruction. The four-hour averages (the recommendation) were all

within the LEED limit, but when the investigators ran a vacuum cleanerto simulate the effects of human activity, the PM 10 readings spiked to ashigh as 60 mcg/m 3. Larger surges were seen when indoor samplingcoincided with nearby outdoor construction activity.

Indoor PM 10 readings spiked to 200 mcg/m3 for about 15 minutes, and

dropped back to less than 30 mcg/m 3 at the end of the workday. Spikesin the 200 mcg/m 3 range for PM 10 are considered a potential healththreat. The PM 10 levels increased beyond the LEED limit in occupied

schools, apartments, and offices, when people were inside behavingnormally. 11

Diesel exhaust particles, another example of ne particulate matter, aredetected in most indoor environmentsand their indoor concentrationsare highest in buildings closest to intensely used traffic corridors. Nearly90 percent of particles emitted as diesel exhaust are considered to beultrane, less than 1 micrometer in diameter.

The limited testing required by LEED for PM 10 may not adequately

reect the PM 10 present in a building, once it is occupied. Furthermore,LEED neglects to test particles less than 10 micrometers in size,although these are considered more dangerous to health than largerparticulates, particularly if people are exposed to them repeatedly.

22

The limited testingrequired by LEED for PM 10may not adequately reflect the PM 10 present in abuilding once it is occupied.



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23


P e s t i c i d e s

The LEED certication for the existing building rating system does notrequire pesticide use reduction. Instead it offers 1 possible credit withinthe LEED Sustainable Sites category for developing an Integrated PestManagement (IPM), Erosion Control and Landscape Management Plan;and 1 additional possible credit in its Green Cleaning-Integrated PestManagement category. Thus, only 2 credits are possible in categoriesthat have multiple additional objectives. It is possible to neglect pesti-cides totally and still receive the highest platinum level of certication.

Pesticides are deliberately toxic substances and more than 100 millionpounds are released indoors in the United States each year. EPA haslicensed nearly 107 separate pesticides for use in indoor settings. Theagency has rarely requested experimental data on indoor chemicalpersistence, movement, or human exposures, before issuing permits tomanufacturers. Rather than requiring these studies, EPA scientistsinferred risks from data developed and submitted by manufacturers tosupport licenses for outdoor uses.

Pesti cides are intentional additives to many consumer products, such ascloth ing, carpets, plastics, paints, stains, building materials, playequipment, furniture, some detergents, fuels, shampoos, pet products,cosmetics and pharmaceuticalsall of which end up within indoorenvironments.

Americans spend more than 90 percent of their time inside build ings.Pesticides released indoors can produce extended exposures, especiallyif indoor areas are poorly ventilated. There is no legal requirement toinform occupants about the chemicals that have been applied, theirpotential health effects, or their rate of dissipation, all of which arenecessary to know in order to determine when it is safe to re-enter thestructure following treatment.

It is possible to neglect pesticides totally and

still receive the highestplatinum level of

certification... . There is nolegal requirement to inform

occupants about thechemicals that have been

applied, their potential health effects, or their rate of dissipation.


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Children are especially susceptible to pesticides applied indoors.

Young children spend more time indoors within residential settingsthan adults, and this time is usually spent on or near oors, where dust,molds, pesticide residues and other contaminants settle.

Young children touch surfaces that may be treated with pesticides morefrequently than adults do, and they tend to put their hands and objectsin their mouths, crawl on oors and wear fewer clothes than adults,especially in warmer climates. More than half of the nearly 96,000pesticide exposures reported to American Poison Control Centers in2007 concerned children less than six years in age.

The allowed interval between spraying and building reentry has asignicant effect on exposure levels. Farm worker exposure, forexample, is normally managed by government required reentryintervals, but most products registered for homeowner applicationare not. In fact, many products may legally be sprayed whenroomsincluding classroomsare inhabited.

In the absence of evidence to the contrary, the EPA has long assumed

that indoor residues dissipate and pose no signicant health threat.Recent experiments, however, have shown that residues may persist formonths and years following application. Resi due levels are inuencedby structural characteristics, such as the design and location of theheating and ventilation system (especially fresh-air exchange rates) andits quality of ltration, the location of windows and doors, and thetendency of homeowners to ventilate using open windows and doors.For some chemicals, residue levels in the air continue to rise for daysfollowing applicationand are highest near the oor.

Several thousand pesticide products are available for outdoor lawn andgarden uses, or to control termites near building foundations. Thesechemicals present a risk of well water contamination, and those whoapply them face potential exposure while mixing, applying, cleaning upand storing the pesticides, as well as when reentering treated areas.

24


Americans spend morethan 90 percent of their time inside build ings....Young children spend more time indoors withinresidential settings thanadults, and this time isusually spent on or near

floors, where dust, molds, pesticide residues and other contaminants settle.


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25


Each step carries additional risks if label warnings and direc tions are not

followed perfectly or if other mistakes occur. In addition, childrensexposure to pesticides applied outdoors may be much greater thanthose of adults: they love to roll, play and sit in the grass, and they enjoytouching and smelling colorful ornamental shrubs and owers, whichare sprayed more often than other plants.

A recent EPA survey found that 75 percent of U.S. households used atleast one pesticide product indoors during the past year. Another studysuggests that 80 percent of most peoples exposure to pesticides occursindoors and that measurable levels of up to a dozen pesticides havebeen found in the air inside homes. 12

The Green Building Councils commitment to pesticide reduction inbuildings is weak at best, relying on Integrated Pest Management (IPM),a pest management approach that means different things to differ entpeople . When the Government Accounting Office examined the statusof IPM adoption in the United States, it discovered that the implemen-tation rate is a misleading indicator of the progress made toward anoriginal purpose of IPMreducing chemical pesticide use.

IPM includes a wide variety of pest management practices, withoutdistinguishing between those that tend to reduce chemical pesticideuse and those that may not. The Green Building Councils currentreliance on IPM provides little assurance of health protection frompesticides used indoors. 13 There is little necessary governmentoversight to assure compliance with performance standards.

IPM originated with chemical manufacturers, formulators andapplicators who hoped the standard would be accepted by EPA as an

alternative to stricter federal regulations that might limit pesticide useand residues in air, water and food. Thus LEEDs offer of 2 credits foremploying IPM standards provides little assurance of pesticide exposurereduction.

The U.S. Green BuildinCouncils commitment to

pesticide reduction inbuildings is weak at best,

relying on Integrated Pest Management (IPM), a pest

management approachthat means different things

to different people.


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F l a m e R e t a r d a n t s

Brominated ame retardants (BFRs) are a large chemical group thatincludes tetrabromobisphenol A (TBBPA), polybrominated diphenylethers (PBDEs), polybrominated biphenyls (PBBs) and hexabromo-cyclododecane (HBCD or HBCDD). Data demonstrate that ameretardants are in most peoples bodies, are ubiquitous in theenvironment, and that low-level exposures may cause liver toxicity,thyroid toxicity, neurodevelopmental toxicity and fertility problems. 14,15

Articles often treated with the ame retardant PBDE include carpets,

upholstery fabric, cushions, and plastics used as components in electricalappliances and equipment. Three commercial PBDE mixtures have beenproduced and used in the US and abroad: (1) commercial pentabromo-diphenyl ether (c-pentaBDE), used in foam for furniture and mattresses;(2) commercial octabromodiphenyl ether (c-octaBDE) used in electric andelectronic devices); and (3) commercial decabromodiphenyl ether(c-decaBDE), whose primary use is in high-impact polystyrene.

Manufacture and import of c-pentaBDE and c-octaBDE were phased outin 2004, but articles treated with c-pentaBDE and c-octaBDE may still beimported. In the United States, c-decaBDE is still manufactured andused as an additive ame retardant in textiles, electronic equipment,and building and construction materials. Its primary use is in high-impact polystyrene (HIPS) based products. 16

Concerns about PBDEs led to the use of HBCD, used as a ame retardantprimarily in polystyrene insulation foam, as well as in upholstery textiles,video or audio equipment housings and high-impact polystyrene. Morethan 85 percent of HBCD is used in polystyrene insulation, which is likelythe primary source of global contamination. 17, 18

Like its predecessor, HBCD is not chemically bound to the material itprotects, and the compound has been detected in both the environ-ment and in people. Human health data suggest thyroid effects, whichmay present potential concerns for developmental neurotoxicity.Potential reproductive effects have only begun to be studied. 19

26


Articles often treated with the flame retardant polybrominated diphenyl ether (PBDE) include carpets, upholstery fabric,cushions, and plasticsused as components inelectrical appliances

and equipment.


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27


Environmental monitoring programs have found traces of PBDEs and

HBCD not only in wildlife, but also in human breast milk and body uids.For both children and adults, dust is the primary source of exposure toame retardants. Young children come into contact with higher levels of ame retardants because they are closer to the oor, where chemicalspersist in carpets and furniture. 20,21

Despite concerns about the use of HBCD and other flame retardants inpolystyrene insulation, such insulation can earn multiple points underthe LEED rating system. Dow Chemical Co. claims in its advertising thatits STYROFOAM brand extruded polystyrene insulation, spray

polyurethane foam insulation and similar products can potentiallycontribute 25 to 51 points to LEED for Homes certication, particularlyin the area of energy and atmosphere. 22

The Green Building Councils Green Home Guide states, Polystyrenefoams contain brominated ame retardants that raise serious health andenvironmental concerns. 23

The LEED program for new construction neglects drinking water quality.LEEDs water credits are predominantly allocated to encourage reduceduse of water and the energy necessary to acquire, distribute and sanitizeit. LEED assigns no credit for drinking water quality assurance, andestablishes no minimum requirements or goals for testing or ltration. The Green Building Council relies on the federal Safe Drinking Water Act(SDWA) to provide sufficient health protection.

Many buildings deliver water to taps via plastic piping that can leachchemical components into water supplies. Subtle variations in waterchemistry, such as a change in acidity or alkalinity, can affect the rate of chemical leaching, as can water temperature and the time that waterremains stagnant within the piping before being used. Furthermore,

Despite concerns about the use of hexabromo-cyclododecane (HBCDor HBCDD) and othe

flame retardants in polystyrene insulation,

such insulation can earnmultiple points under

the LEED rating systemDrinking Water


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many studies demonstrate that some water supplies contain residues

of synthetic chemicals, including pesticides, fuels, pharmaceuticals andmetals.

Other studies have shown that the piping that delivers water is oftencracked, leading to both water loss and potential intake of contam-inants. Older supply lines, water mains, solders used to join metal pipes,and even some brass faucets contain lead, a well recognized toxin thathas often been found to leach into tap water. 24

National responsibility for dening acceptable levels of drinking water

contamination lies with EPA, which derives its authority from SDWA.When EPA sets a new contaminant limit for a maximum contaminant level(MCL) for drinking water, municipalities around the country must rou-tinely demonstrate that their water is not contaminated beyond the MCL.

The statute requires that EPA set MCLs for a number of toxic substances. The legal strategy of listing contaminants has caused water suppliersand potential polluters to resist addition of new chemicals to the list,due to the costs of monitoring, ltration and liability. Congress was

dissatised by EPAs slow progress in regulating contaminants, and in1988 amended the statute, demanding that 83 chemicals be regulatedwithin three years.

Water deemed clean as it leaves a water ltration plantaccording toSDWA standardsmay become contaminated after treatment, sincechemicals are tested only when water leaves a treatment plant. Somechemicals, such as bromates, can be formed when water containingcertain contaminants is combined with cleaning chemicals and exposedto sunlight.

Other chemicals may leach into water supplies. Tap water sampleshave been found to contain not just one contaminant, but dozens.More than half of the water systems in a recent study had at leastseven contaminants in their water, yet the SDWA does not regulatemixtures of pollutants in drinking water. 25

28


The LEED program for new construction neglectsdrinking water quality....LEEDs water credits are predominantly allocated to encourage reduced useof water and the energy necessary to acquire,distribute and sanitize it.LEED assigns no credit for drinking water quality assurance, and establishesno minimum requirementsor goals for testing or filtration.


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29


EPA has understood the extent of pesticide contamination of drinking

water supplies for decades, but has neglected to regulate chemical use,or to warn consumers about effective ltration technologies.

No law in the United States requires labeling of chemical ingredientsin plastics, and their use is not restricted in LEED-certied buildings.Plastics now comprise nearly 70 percent of the synthetic chemical

industry in the U.S., where each year more than 100 billion poundsof resins are formed into build ing materials, window and doorcasings, furnishings, electrical wiring, piping, insulation, water andwaste conduits, oor coverings, wood sealants, wallpaper, paints,packaging materials, appliances, countertops, lighting xtures andelectronics.

The chemical contents of plastics have always been a mystery toconsumers. Ingredients are not labeled under federal law, and mostmanufacturers are unwilling or unable to disclose these contents ortheir sources. Some products are labeled to facilitate recycling but notto identify chemicals used in their manufac ture.

There are many chemicals used to manufacture plastics, some of whichare harmless and others toxic. Several well-researched compounds mayharm human health and the environment, including bisphenol-A (BPA),polyvinyl chloride (PVC), phthalates, peruorooctanoic acid (PFOA) orchemicals in the rubber inll in articial turf. Use of these chemicals inbuilding materials is not restricted by LEED, nor are credits awarded for

avoiding these products.

B i s p h e n o l - A ( B PA )

Each year several billion pounds of BPA are produced in the U.S. TheCenters for Disease Control and Prevention (CDC) found that over 90

Plastics

Other chemicals may leachinto water after traveling

through plastic pipes.... Nolaw in the United Statesrequires labeling of thechemical ingredients in

plastics, and their use isnot restricted in LEED

certified buildings


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percent of human urine samples tested have measurable BPA levels. BPA

has also been detected in human serum, breast milk, maternal and fetalplasma, amniotic uid and placental tissue at birth.

BPA, a primary component of hard and clear polycarbon ate plastics andepoxy resins, is used in a wide range of building materials, includingpaints, sealants, adhesives and llers (caulk, grout, mortar, and putty). The resins are used as lacquers to coat metal products and watersupply pipes. Substantial migration of BPA from PVC hoses intoroom-temperature water has been documented, yet PVC pipe isapproved for use in residential water supply lines in many cities.

In addition to exposure to BPA via PVC pipes in buildings, BPA has alsobeen measured in dust and air. It is difficult to identify BPA in buildingmaterials since the epoxy resins used in these materials may be listed ona material safety data sheet as a proprietary mixture, with no disclosurethat the resin is made from BPA. 26

BPA is suspected of affecting nor mal human hormonal activity.Scientists growing interest in hormone disruption coincided with aconsensus within the National Academy of Sciences that children areoften at greater risk of health effects than adults because of their rapidlygrowing but immature organ systems, hormone pathways andmetabolic systems. In addition, young children breathe more air,consume more food, and drink more water per pound of body weightthan adults, and thus have greater exposure to any chemicals present intheir environments.

Since 1995, scientists have reported that BPA caused health effects inanimals similar to numerous illnesses growing in prevalence in the

United States. These conditions include breast and prostate can cer,declines in sperm counts, abnormal penile or urethra develop ment inmales, early sexual maturation in females, neurobehavioral problems,obesity and type 2 diabetes, and immune system disorders. Many of thestudies link low-dose BPA exposure to health effects. BPA can bind withestrogen recep tors in cell membranes following low doses measured in

30


BPA is found in buildingconduits that distributewater and air, and bothare plausible routes of human exposure. Theabsence of federal regulation, together with the growing trend

of governments to adopt LEEDs standards, foretellsa long future of exposureto chemicals such as BPAin the built environment.


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31


parts per trillionthat is, at exposures nearly 1,000 times lower than the

EPAs recommended acceptable limit.27

In 2007, the U.S. National Institutes of Health issued a strong warningabout the chemicals hazards: There is chronic, low level exposure of virtually everyone in developed countries to BPA. The publishedscientic literature on human and animal exposure to low doses of BPAin relation to in vitro mechanistic studies reveals that human exposureto BPA is within the range that is predicted to be biologically active inover 95 percent of people sampled. The wide range of adverse effects of low doses of BPA in laboratory animals exposed both during develop-ment and in adulthood is a great cause for concern with regard to thepotential for similar adverse effects in humans. 28

Use of BPA is so widespread that it is difficult to identify the mostimportant sources of exposure. BPA is found in building conduits thatdistribute water and air, and both are plausible routes of humanexposure. The absence of federal regulation, together with the growingtrend of governments to adopt LEEDs standards foretells a long futureof exposure to chemicals such as BPA in the built environment.

P V C a n d P h t h a l a t e s

PVC plastics pose a problem at least as serious as BPA, but they are alsoneglected by LEED standards. Products that contain PVC can be used inLEED-certied buildingsand no credits are available for avoiding them.

More than 300 different types of plasticizers have been identied inPVC, with phthalates among the most common. Phthalates, added tosoften and make PVC more pliable, are recognized as global pollutants

and major constituents of indoor air. Di(2-ethylhexyl) phthalate (DEHP)constitutes roughly 50 percent of global consumption of phthalates,and about 95 percent of the current production of DEHP is used in PVC.Another phthalate, DnBP, is used in latex adhesives, and is also aplasticizer in PVC. BBzP is a plasticizer for vinyl tile, carpet tiles andarticial leather and is also used in certain adhesives. 29

Several well-researched compounds may harmhuman health and the

environment, includingbisphenol-A, polyviny

chloride, phthalates, perfluorooctanoic acid or

chemicals in the rubber

infill in artificial turfUse of these chemicals inbuilding materials is not

restricted by LEED, noare credits awarded for

avoiding these products.


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Many of the chemicals used to make PVC are toxic, while other

chemicals are created during the production and manufacturingprocess. One of the most toxic chemicals created during the productionand manufacturing process is dioxin, a persistent bioaccumulativetoxicant targeted for elimination by the Stockholm Convention of Persistent Organic Pollutants.

Vinyl chloride is classied as a human carcinogen by numerous scienticand regulatory bodies. Non-cancerous adverse effects are documentedon the nervous system, liver, lungs, blood, immune system, cardio-vascular system, skin, bones and reproductive organs. Occupational

exposure to PVC is a risk factor for scleroderma, a widespreadconnective tissue disease, and testicular cancer. Additives to PVC, suchas phthalates and BPA, may contribute to these health effects. 30

The building industry is responsible for 75 percent of the PVC used inthe United States. Pipes and ttings compose the largest por tion (44percent) of PVC used for building and construction. It is the mostpopular material for large diameter buried pipelines installed by bothwater and wastewater utilities, as well as for smaller-diameter drain

waste and vent piping and indoor water plumbing. PVC is the leadingpipe material in the United States today, accounting for more than 70percent of all the water and sewer pipe currently being installed. 31

Phthalates may affect development and reproduction, increase the risk of infertility, and lead to testicular damage, reduced sperm count andsuppressed ovulation. Studies in children note associations betweenindicators of phthalate exposure in the home and risk of asthma andallergies. Some phthalates (BBzP and DEHP) found in indoor dust havebeen associated with allergies and asthma. Studies suggest a link

between asthma and the concentration of phthalates in indoor dustassociated with the use of plasticized products such as PVC ooring andwall material. 32

Plastic wall materials in homes have been associated with lower respira-tory tract symptoms and asthma in children, while use of plastic wall

32


The building industry isresponsible for 75 percent of the polyvinyl chloride(PVC) used in the United States.... PVC is the leading pipe material in the United States today, accountingfor more than 70 percent

of all the water and sewer pipe currently beinginstalled. 31


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33


material in the workplace is associated with asthma in adults. A clinical

diagnosis of bronchial obstruction has been shown to be more commonamong children living in homes with PVC ooring than in homes withwood ooring, and more common among children in homes with textilewallpaper than with painted walls. If the PVC ooring gets wet, it can leadto elevated indoor air concentrations of 2-ethyl-1-hexanol (2E1H), avolatile organic compound (VOC) that is a hydrolysis product of DEHP. 33

A growing list of companies has committed to a PVC phase-out, and theAmerican Public Health Association has called for an industrial chlorinephase-out. Other nations have also taken action: Denmark has called forthe minimization of PVC use in public buildings; Norways secondlargest city, Bergen, made the decision in 1991 to phase out PVC; and inthe United Kingdom, numerous local authorities have policies banningvinyl windows in public buildings. 34

Some groups advocate for vinyl-free alternative purchasing policies inconstruction. Several U.S. municipalitiesincluding Portland, Seattle,New York and San Franciscoare also developing policies to reducethe use of vinyl. These movements are not without challenges from the

vinyl industry. When New York State began offering a green buildingtax-credit program designed to encourage sustainable building materials,and excluded vinyl ooring, the vinyl ooring industry led a lawsuitcontesting the States refusal to recognize vinyl ooring as a greenbuilding material. 35

In 2000, a LEED credit was proposed to award the avoidance of PVC inbuilding products used in new construction to Eliminate the use of virgin PVC and any chemical listed in the OSHA Toxic & HazardousSubstances. 36

In response to criticism from industry groups, the Green BuildingCouncil appointed a committee to evaluate whether PVC-basedmaterials are consistently among the worst of the alternative materialsstudied in terms of environmental and health impacts. The committeeconcluded that the credit should not be offered, noting that alternative

Studies in children noteassociations between

indicators of phthalateexposure in the home

and risk of asthmaand allergies...


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building products carry other risks to the environment and human

health, missing an opportunity to encourage demand for less toxicalternatives to PVC. 37

The PVC controversy demonstrates the inuence industry has over theLEED decision-making process and, ultimately, the denition of greenbuilding. Does the Green Building Council have the expertise to judgecomparative environmental and human health threats among chemi-cals employed in building materials? A review of the credentials of itsboard and staff suggests that the organization does not. Should theGreen Building Council's standards then be adopted as law or be usedby governments to guide tax policy? 38

P e r f l u o r o o c t a n o i c A c i d ( P F O A )

Peruorooctanoic acid (PFOA) is a synthetic chemical that does notoccur in nature. PFOA is most commonly known for its use in Teoncookware, and is also used in the manufacture of uoropolymershigh-performance plastic and synthetic rubber materials used in themanufacture of fabric and carpet treatment products, such as

Scotchgard, Stainmaster and other nonstick and stain-resistantproducts.

Upholstery, stone, rock and tile sealants, carpet treatments, oor waxesand water-repellent fabrics are likely to be the most signicant sourcesof human exposure to PFOAs. The federal Agency for Toxic Substancesand Disease Registry (ATSDR) notes that carpets treated with PFOAs arean important source of exposure for children, and that workers infacilities that make PFOA or similar molecules called uorotelomershave increased levels of these chemicals in their blood. 39

PFOA never breaks down in humans or in the environment, whichexplains its widespread presence in humans and wildlife. It has beendetected in 95 percent of Americans tested and in breast milk andbabies. PFOA has also been found in the blood of people in fourconti nents, and in workers who make uorotelomers.

34


PVC plastics pose a problem at least as serious as BPA, but they are also neglected by LEED standards. Productsthat contain PVC can beused in LEED-certified buildingsand no

credits are availablefor avoiding them.


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35


As regulators continue to review the chemical, scientists continue to

publish reports of disturbing health risks: PFOA has been associatedwith testicular, pancreatic, mammary and liver tumors in male andfemale mice, as well as developmental toxicity in rodent models. Studiesin workers have shown changes in sex hormones and cholesterolassociated with the levels of PFOA in blood, as well as increases inprostate and bladder cancer.

The discovery that arctic animals double the amount of PFOA in theirblood every four years demonstrates the persistence of this ubiquitouschemical. The discovery of PFOA in dogsanimals tested had PFOAlevels 2.4 times higher than those found in humansdemonstrates thepossibility that frequent contact with household wall-to-wall carpeting,furniture and other PFOA-treated items may also have implications forhuman exposures. 40

Newborn babies exposed to low levels of PFOA in utero had lower birthweights. Pregnant women with high levels of PFOA report a higherincidence of preeclampsia and birth defects, while women with highPFOA levels may be twice as likely to be diagnosed with infertility. More

than 10 percent of all women are estimated to exceed a 1 in 1000 excesslifetime cancer risk from their exposures to PFOA, and nearly 7 percentof all women exceed a safe dose for ovarian effects.

In a preliminary risk assessment of the developmental toxicity associatedwith exposure to PFOA, EPA estimated that health risks to young girls andwomen of childbearing age are higher than levels considered accept-able. No studies are available on health effects in babies exposed toPFOA-contaminated breast milk. 41

Potential health effects associated with PFOAs have been researched fordecades. DuPont scientists issued internal warnings in 1961 about thehealth risks of PFOA, which led to further studies demonstrating thatPFOA accumulates in human blood, does not break down in theenvironment and may cause liver damage. Elevated levels of thechemical in DuPont workers were documented by 1980. DuPonts

Perfluorooctanoic acid (PFOA) never break

down in humans or in theenvironment.... Newborn

babies exposed to low levels of PFOA in uter

had lower birth weights.


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secrecy led to civil administrative actions by EPA against DuPont in 2004

and 2005, leading to a settlement with DuPont for the largest civiladministrative penalty EPA has ever obtained under any federalenvironmental statute. 42

Despite decades of research and global concern about health risksassociated with PFOA, and its widespread presence in both humans andanimals, no enforceable health standards exist. The only federalregulation governing PFOA exposure is a provisional drinking wateradvisory. Hundreds of PFOA-related chemicals that may degrade toPFOA are also not regulated in the United States. 43

Although EPA has released several draft hazard assessments and risk assessments for PFOA in the last nine years, none of them have beennalized. The Agency for Toxic Substances and Disease Registry (ATSDR)publicly stated years ago that it was working on an evaluation of healthrisksincluding risks associated with PFOA contamination of humanbreast milk, arising from PFOA-contaminated drinking waterbut noreport has been released. 44

The EPAs PFOA Stewardship Program proscribes PFOAs from emissionsand products by 2015. While DuPont announced its intent to end theproduction and use of PFOA by 2015, it has not declared an intent toend the production or use of uorotelomers.

The companys reports to EPA on current production are kept secret ascondential business information, so current production is a mystery tocurious consumers. Fluorotelomer-based carpet coating products arereported to be widely used in Dalton, Georgia, the carpet productioncapital of the United States. Carpets are dipped in vats of stain repel-

lents containing chemicals that may contain or break down into PFOA. 4

Buildings that use carpets that do not contain PFOAs receive no bonuspoints from LEED, and the Green Building Council has published no

36


Despite decades of research and global concern about healthrisks associated withPFOA, and its widespread presence in both humansand animals, noenforceable health

standards exist.


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statements concerning the potential risks of PFOAs or recommenda-

tions regarding avoidance of the chemical. There is no certicationprogram that guarantees that PFOAs are not used.

The Carpet and Rug Institute (CRI) has launched a Green Label program totest carpeting and certify that it meets stringent criteria for low chemicalemissions. The Green Label Plus testing program, adopted by LEED,does not test carpet for PFOA. CRI claims that the carpet industry hasceased using the chemistry that produced the PFOA found in carpettreatments and notes that even when the industry did utilize theprocess that produced these very small traces of PFOA, based on all the

information available, there was never any health or safety risk. 46

Both DuPont and 3M have produced PFOAsand are members of CRI.DuPont has claimed that exposures to PFOA do not present a humanhealth risk. Three years ago DuPont committed to no longer make, useor buy PFOA by 2015, or earlier if possible. 47

Articial turf is manufactured from synthetic bers made to resemblenatural grass. The material is used in sports arenas, residential land-scaping and commercial applications. Most synthetic turf systemsinclude a drainage layer, a multi-layered backing system, and plasticor nylon grass blades that are inlled with a granular ller to resemblenatural turf. This inll is often granulated recycled rubber tires.

Despite debate over whether plastic grass is safe or a health risk,

articial turf can earn multiple points toward LEED certication.Hazardous chemicals contained in the crumb rubber can volatilize, andbe tracked into buildings and homes on clothes and gear.

Buildings that use carpetsthat do not contain PFOAs

receive no bonus pointsfrom LEED, and th

USGBC has not published statements concerning the

potential risks of PFOAsor recommendationsregarding avoidance

of the chemical

Artificial Turf


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EHHI analyzed the ground-up rubber tire inll and found it to contain a

number of toxic compounds, including benzothiazole (a skin and eyeirritant and harmful if swallowed); butylated hydroxyanisole (a recog-nized carcinogen, suspected endocrine toxicant, gastrointestinaltoxicant, immunotoxicant and neurotoxicant); n-hexadecane (a severeirritant based on human and animal studies); and 4-(t-octyl) phenol (corrosive and destructive to mucous membranes). The full extent of the health effects associated with these chemicals is not known, anddata are lacking on the health effects from human exposure to thesechemicals. 48

The Norwegian Institute of Public Health showed that volatile organiccompounds (VOCs) from rubber inll can be aerosolized into respirableform during sports play, but little or no toxicological information isavailable for many of the VOCs that are found in articial turf. Studiesare lacking on the potential for the development of asthma and airwayallergies in response to exposure to the latex in the tires used insynthetic turf. 49

Recently, scientists found harmful chemicals in every sample of arti-

cial turf tested, including polycyclic aromatic hydrocarbons (PAHs),chromium and lead. Arsenic and cadmium were detected in mostsamples. Levels of many PAHs exceeded health-based standards forsoil, especially in newer articial turf elds.

Exposure to PAHs can cause cancer, while studies have shown thatmetals can damage the brain, kidney, liver, skin and bladder. Even moreimportant, tests showed that some of the contaminants were biologicallyavailable, which means that they can be absorbed by the body. 50

Lead has been detected in some synthetic turf made of nylon or nylon-

polyethylene blend bers. Lead is added to the turf to keep the colorvibrant. In 2008, the CDC noted that some turf contains levels of leadthat pose a potential public health concern and warned, As the turf ages and weathers, lead is released in dust that could then be ingestedor inhaled, and the risk for harmful exposure increases. 51

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Despite debate over whether plastic grass is safe or a health risk,artificial turf can earnmultiple points toward LEED certification.


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Lead can cause irreversible neurological damage, renal (kidney) disease,

cardiovascular effects and reproductive toxicity. Blood lead levels oncebelieved to be safe are now considered hazardous, with no knownthreshold.

In addition to concerns about exposures to chemicals in the crumbrubber, some synthetic turf contains antimicrobial agents used tominimize bacterial growth. 52

Additional health and environmental concerns surrounding articialturf include:

I Worker Exposure: Health data from workers in rubberfabrication and reclamation industries indicate the presenceof VOCs, semi-volatile hydrocarbons and harmful particulatesin the air. Occupational studies reveal health effects rangingfrom severe skin, eye and respiratory irritation to threekinds of cancer. Companies that manufacture and supplysynthetic turf are responsible for assessing the risks tohumans. The previous case study about PFOAs demonstrates

that it may be decades before these data are revealed andreviewed.

I Disposal: Most synthetic turf needs to be replaced after about10 years, yet the turf is not biodegradable. Most synthetic turf elds are composed of crumb rubber inll made from recycledtires. Used tires have been banned by landlls in all but eightstates, partly because of concerns about the risk of tire res,which release toxicants such as arsenic, cadmium, lead, nickel,PAHs and VOCs.53

I Heat Island E ect: Replacing natural turf with articial turf contributes to the urban heat island effect by absorbingsunlight and emitting heat. Urban heat islands increasedemand for energy (particularly air conditioning), intensify air

Most synthetic turf needsto be replaced after

about 10 years, yet the turf is no

biodegradable. Most synthetic turf fields are

composed of crumbrubber infill made from

recycled tires. Used tireshave been banned by landfills in a

but eight states....


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The LEED rating systemawards points for using synthetic turf, as many as 4 points for water efficiency alone. Pointsmay also be available for materials selection and innovation in design.

pollution, and increase heat-related health problems. Summer

temperatures in New York City are about seven degrees higherthan in surrounding areas because of this effect. Researchers atPennsylvania State University note that the difference betweensurface and air temperatures on articial turf can be as muchas 37 degrees. 54

I Habitat Loss: Natural turf offers habitats for insects, plants,and animals and provides food for birds. Synthetic elds do notcontain microorganisms that can break down pollutants, anddo not absorb rainwater it simply drains through the eldand runs into storm sewers.

The LEED rating system awards points for using synthetic turf, as manyas 4 points for water efficiency alone. Points may also be available formaterials selection and innovation in design, as shown in Table 3(opposite).

For example, the rst LEED Platinum-certied aviation facilityHangar 25 at the Bob Hope Airport in Burbank, Californiawas

landscaped with 6,500 square feet of articial grass. The synthetic turf was manufactured by SYNLawn.

Californias Attorney General led suit against SYNLawn and other turf companies, under Californias Proposition 65, for excessive lead levelsafter testing showed high amounts in articial turf products. Anagreement was subsequently reached to limit the amount of lead in turf products sold in California. 55

40



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Source: Based on LEED 2009 for New Construction and Major Renovations. Adapted from LEED and Credits for Arti cial Turf Projects. http://blog.arti cialturfsupply.com/leed-certi cation-and-credits-for-arti cial-turf-projects/

Table 3. LEED 2009 for New Construction: Credits Available for Artificial Turf

WE Credit 1.1: Water Efficiency Landscaping 50% Reduction

WE Credit 1.2: Water Efficiency LandscapingNo Potable Water Use or No Irrigation

Water Use Reduction: 20%

Water Use Reduction: 30%

Wa t e r E f f i c i e n c y

1 point

1 pointin addition to

point from above

1 point


point from above

Description LEED New Construction/Major Renovation Point Value

M a t e r i a l s a n d R e s o u r c e s

1 point


point from above

1 point

1 point

1 point

1 point

I n n o v a t i o n i n D e s i g n

1 point

1 point

Credit 1-1-4of Innovationin Design:

Products of a recyclable nature + water saving benefits 4 points

MR Credit 2.1: Construction Waste ManagementDivert 50% From Disposal

MR Credit 2.2: Construction Waste ManagementDivert 75% From Disposal

MR Credit 3.1: Materials Reuse 5%

MR Credit 3.2: Materials Reuse 10%

MR Credit 4.1: Recycled Content 10% (post-consumer + pre-consumer)

MR Credit 4.2: Recycled Content 20% (post-consumer + pre-consumer)

MR Credit 5.1: Regional Materials 10% Extracted, Processed & Manufactured

MR Credit 5.2: Regional Materials 20% Extracted, Processed & Manufactured


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IV. Government Adoption of LEED Standards

LEED is now the most widely accepted national standard for defininggreen development and architecture.

Green Building Councilstandards have been incorporatedinto federal, state and local lawthrough legislation, executive orders,resolutions, policies, loan-grantingcriteria and tax credits. LEED isnow the most widely acceptednational standard for deninggreen development and architecture.LEED performance requirements have been adopted as laws orregulations at various governmental levels in 44 states, including198 localities (132 cities, 33 counties and 33 towns), 33 stategovernments, 12 federal agencies or departments, 16 public schooldistricts and 39 institutions of higher education. 1

Hundreds of cities and towns have adopted incentives to encouragegreen building, some of them specically tied to the LEED system. The city council of Alexandria, Virginia, adopted a Green Building policythat requires all new development needing a development site plan orspecial use permit to achieve a LEED Silver or equivalent rating fornon-residential development, and a LEED-certied or equivalent ratingfor residential development. 2

All new municipal buildings must either follow LEED guidelines orbe certied under the LEED Rating System in Anchorage, Alaska;Providence, Rhode Island; and Cambridge, Massachusetts. Smallertowns, such as Greenwich, Connecticut, require all new and renovatedtown buildings to achieve LEED Silver certication.

Local and Municipal Adoptions



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Other cities require buildings of a certain size or cost to meet LEED

certication standards. Atlanta, Georgia, and Berkeley, California,require buildings over 5,000 square feet to achieve minimum LEEDcertication; Washington, DC, and Boston codes require buildings over50,000 square feet to be LEED-certied; and New York city requires allmunicipal construction costing more than $2 million to earn a minimumLEED Silver certication.2

Many colleges and universities, as well as schools ranging fromkindergarten to twelfth grade, ha

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