Lessons Learned for Achieving a Materials Petal

The Living Building Challenge (LBC) is a rigorous certification governed by the International Living Future Institute (ILFI), an organization setting stretch goals that exceed all existing third-party certifications. To earn ILFI’s Petal certification, a building must meet the requirements for three of the seven petals—one of which must be Materials, Energy, or Water. The Materials petal is said to be the most challenging: it requires intensive due diligence to ensure no Red List materials are utilized on the project. HITT promotes transparency during construction, and as a general contractor, using healthy materials not only benefits the building occupants, but is also safer for the subcontractors that install them.

Living Building projects represent our responsibility to build for the highest level of regeneration. At Co|Lab, we are sharing our lessons learned throughout the process of seeking certification.

“The time investment required is nearly a full-time job, so it is crucial to allocate adequate resources for overseeing the certification.”

Below are a few best practices we learned during construction as we seek our Materials petal:

• Proceed with Eyes Wide Open: If this is your first endeavor in managing a project seeking Petal certification, it is overwhelming to decide where to begin and how to create a plan. Although ILFI offers resources on their website, there is a learning curve for all project participants. The time investment required is nearly a full-time job, so it is crucial to allocate adequate resources for overseeing the certification.
• Demonstrate Transparency: Research as many products as possible for compliance early in the process. Collaborate with the entire project team to identify all the materials you think you’ll need to use. This is a laborious but critical process; project teams must perform due diligence to document communication investigating each material’s ingredients. The research must include a full ingredient list for every single material. Save all correspondence in writing (e.g., emails, letters, and narratives) and documentation showing how many manufacturers, suppliers, vendors, subcontractors, etc. you contacted and who at each company you talked to. It’s difficult to track down this information; this documentation proves you gave your best effort to find complete ingredient lists and verify the ingredients’ compliance.
• Trust Yet Verify: Even when a manufacturer claims a product is Red List free, push for backup if you suspect they may be not be informed or clear on the requirements. For example, hollow metal doors have non-compliant fire retardants in them, but the manufacturer may forget to add those chemicals to the ingredient list.
• Proprietary Ingredients: Some manufacturers will be unwilling to share complete ingredient lists because they may include proprietary components. ILFI allows proprietary ingredients to be unlisted if the manufacturer confirms they are Red List free. In this case, you don’t have to provide due diligence, however, you must ensure that your ingredient lists still add up to 100 percent of the materials when the proprietary ingredients are included.
• General Red List Exceptions: If there’s a Red List chemical in one of your desired products, you must demonstrate a good-faith effort to investigate two alternative products. If you can confirm they also cannot provide a compliant product, ILFI may grant an exception (e.g., they also have a Red List chemical in them, have an extremely long lead time, or require an order of double the amount of the product you need). Because the market for compliant products is still growing, project teams will likely not be able to be 100 percent Red List free, but conducting this type of research that demands transparency from manufacturers will lead to market growth in the future.
• Miscellaneous Materials Exceptions: ILFI allows for certain pieces of “miscellaneous hardware” to be excluded from the materials requirements. Search the ILFI dialogue and confirm what constitutes this exception; make sure you utilize the exceptions list when reviewing specified and non-specified materials. For Co|Lab, we found that toilet paper holders, cabinet pulls, screws and nails, etc. tended to qualify for this exception, saving us time.
• Manufacturer Locations: Be sure to account for where the product is manufactured when specifying materials. You don’t want to get to completion and realize you haven’t met the location sourcing requirement:
  • At least 20 percent of materials must come from within 500 km of the construction site
  • An additional 30 percent of the materials must come from within 1,000km or closer
  • An additional  25 percent must come from within 5,000 km
• Remember Your Coatings: Don’t forget to ask about coatings. Many products have a coating or glaze, and the VOC content and ingredients must be tracked to this level of detail. This includes both indoor and outdoor products. Double check each product that is not the natural color of the material that has a coating on it (e.g., orange fire protection coating or another color to help a material blend into the surroundings). An item commonly overlooked are pipe elbows.
• Salvaged Materials: A salvaged material must be a product that was previously used, not just ordered. For example, the material counts as salvaged if it was previously installed in a building, but not if it’s extra material that was never used. The definition of salvaged materials expands past materials installed in the building. For example, a project can also reuse landscaping materials.
• Be a Team: Encourage a positive, team-oriented attitude with your subcontractors and don’t push the burden on them. Make sure the subcontractors truly understand the requirements and the difficulty of the process, as most subcontractors are unaware of Red List chemicals or the LBC certification. Be patient and willing to partner and team. A great example of this is the Certified 3.x Projects Materials Table. Create a Red List free template letter for subcontractors to ask manufacturers to sign, including the Red List CAS# list.
• Third Party Product Certifications: ILFI can fast-track approvals for certain product certifications. ILFI’s Declare certification has three distinct labels: Declared, Living Building Challenge Compliant, or Declared Red List Free. If a Declared Red List Free product is selected, it is automatically approved for use without any due diligence requirements. Living Building Challenge Compliant products are also accepted without due diligence. Try to incorporate these materials whenever possible as they have already been vetted on the Declare Database or in the Certified 3.x Projects Materials Table. (It’s important to note that the materials table has some errors. A few products have not been vetted for compliance, but the database is still a good resource for manufacturers.) A Declared product requires due diligence to find an alternative product, as these include a Red List chemical, although they have disclosed 100% of the ingredient list. Logic says that Cradle to Cradle, another product certification path, would also align with the Materials petal; however, this product certification earns no credit and full due diligence is still required for all of these products.

As of this posting, Co|Lab is still undergoing material due diligence and working towards earning this stringent petal certification.