Fundamental material safety

Fundamental material safety

Intent: 

To reduce or eliminate occupant exposure to lead, asbestos, and polychlorinated biphenyls (PCBs) from building materials.

No, batteries fall outside of what would be considered building materials in Feature 11.

A team member only needs to sign and submit the Letter of Assurance (LoA). The signee of the LoA may wish to confirm that the product meets WELL materials requirements by reviewing relevant ecolabels, applicable regulations and / or ingredient disclosure mechanisms. However, these documents should not be submitted with documentation.

For Parts 2, 3 and 4, a project is exempt if the building was constructed after any applicable laws were passed banning or restricting the hazardous material. Parts 2, 3 and 4 are applicable when additional work is undertaken by the project (renovation, demo, repair or painting). Note, projects must be sure to adhere to Parts 2 and 3 for any construction occurring after certification to be prepared to comply with this feature at recertification.

Part 3, however, is not contingent on additional work and mandates ""in place"" management of asbestos. This includes inspection and the application of an asbestos management plan (including re-inspection every 3 years). Note, a project can be exempt from Part 3 if asbestos is identified and fully removed.

For Parts 2, 3 and 4, projects should draft a short narrative explaining why they are exempt from any or all parts, outlining the rationale for the exemption. This explanation should be submitted as a part of the project documentation.

For Parts 2, 3 and 4, a project is exempt if the building was constructed after any applicable laws were passed banning or restricting the hazardous material. Parts 2, 3 and 4 are applicable when additional work is undertaken by the project (renovation, demo, repair or painting). Note, projects must be sure to adhere to Parts 2, 3, 4 for any construction occurring after certification to be prepared to comply with this feature at recertification.

Part 3, however, is not contingent on additional work and mandates ""in place"" management of asbestos. This includes inspection and the application of an asbestos management plan (including re-inspection every 3 years). Note, a project can be exempt from Part 3 if asbestos is identified and fully removed.

For Parts 2, 3 and 4, projects should draft a short narrative explaining why they are exempt from any or all parts, outlining the rationale for the exemption. This explanation should be submitted as a part of the project documentation.

Re-inspection of all friable and non-friable known or assumed asbestos containing building material must be conducted at minimum once every three years. If all asbestos containing material has been removed, evidence reflecting this can be submitted and the requirement for re-inspection waived.

The investigation for lead based paint hazards requires an inspection of areas subject to abrasion (friction surfaces, impact surfaces and chewable surfaces, or any surface with deteriorated paint), and wipe samples of the nearest horizontal surface to determine whether dust-lead level concentrations exceed hazard levels (40 µg/ft² on floors or 250 µg/ft² on interior window sills). To determine dust-lead hazards, wipe samples are taken of dust on floors and window sills to determine the mass-per-area concentration of lead and compare to the same hazard levels.

Lastly, a soil-lead hazard is bare soil containing total lead ≥ 400 ppm (µg/g) in a commonly used outdoor area or an average of 1,200 ppm in remaining areas, based on soil samples.

Part 3b requires sampling for asbestos in accordance with the Asbestos-Containing Materials in Schools Rule (40 CFR part 763.86) prior to abatement.

The air test is a preliminary screen to determine risk of exposure: whether PCBs are present in the air at levels exceeding EPA exposure thresholds. There may be PCB-containing materials that are not captured through an air test. In the case of renovation, repair or demolition, where PCB-containing materials (if present) are likely to be disturbed, the project will need to characterize and determine the extent of PCB contamination prior to abatement through sample testing. Suspect building materials must be tested to determine PCB sources, and sample results evaluated to determine if surrounding areas warrant testing.

Guidelines and further details can be found at the EPA’s site on PCBs; “How to Test for PCBs and Characterize Suspect Materials” under “Building Characterization and Sampling Plan.”

If the features (as written) are required by law, the project just needs to submit the remediation report or an LoA per protocol. However, if the French law requires something different to the features as written, then the project would have to submit an equivalency proposal (EP) and documentation required as per the equivalency.

The term “attempt” in this context means the ways in which a project team has tried to procure an appropriate product, which typically involves outreach to manufacturers.

This feature is applicable only to the WELL project boundary. For Core and Shell projects, review the Core & Shell Scope Matrix for more information.

For Parts 2, 3 and 4, a project is exempt if the building was constructed after any applicable laws were passed banning or restricting the hazardous material. Parts 2 and 4 are applicable when additional work is undertaken by the project (renovation, demo, repair or painting). Note, projects must be sure to adhere to Parts 2, 4 for any construction occurring after certification to be prepared to comply with this feature at recertification.
Part 3, however, is not contingent on additional work and mandates "in place" management of asbestos. This includes inspection and the application of an asbestos management plan (including re-inspection every 3 years). Note, a project can be exempt from Part 3 if asbestos is identified and fully removed.