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WELL Addenda

WELL ADDENDA

Review the complete list of addenda changes made to the WELL Building Standard.

Feature 75: Internally generated noise

Type Description
Verification type
Type: Verification type
Post Date: 20 Oct, 2017

Remove: "Visual Inspection". Add: "Performance Test"


Amendment
Type: Amendment
Post Date: 27 Apr, 2017

Add: "spaces and potential sources of disruption" after "the following"


Amendment
Type: Amendment
Post Date: 27 Apr, 2017

Remove: "d. Teleconference rooms: maximum noise criteria (NC) of 20."


Amendment
Type: Amendment
Post Date: 27 Apr, 2017

Add: "," after "as well as occupants themselves"


Amendment
Type: Amendment
Post Date: 27 Apr, 2017

Remove: "major" after "occupants themselves can be"


Amendment
Type: Amendment
Post Date: 27 Apr, 2017

Remove: "To reduce acoustic disruptions and increase speech privacy by
creating an acoustic plan and limiting internal noise levels." Add: "To reduce acoustic disruptions from internal noise sources and increase speech privacy."


Alternative Adherence Path
Type: Alternative Adherence Path
Post Date: 09 Feb, 2017

Whereas Noise Criteria levels within a space is driven by sound produced by the HVAC and other mechanical systems which may be outside of a tenant’s control, New and Existing Interiors projects may achieve Feature 75 when achieving NC levels higher than listed, with the following conditions:
- Achieve NC levels of 5 higher, but the project is limited to Gold level of certification, no matter how many Optimization features are achieved.
- Achieve NC levels 10 higher, but the project is limited to Silver level of certification, no matter how many Optimization features are achieved.


Intent
Type: Intent
Post Date: 24 Oct, 2016

In the Feature description, remove the second paragraph. Replace with the following text:
'Intent: To reduce acoustic disruptions and increase speech privacy by creating an acoustic plan and limiting internal noise levels.'


Alternative Adherence Path
Type: Alternative Adherence Path
Post Date: 06 May, 2016

Noise Rating curve values may be used in lieu of Noise Criterion curve values for the mechanical equipment sound levels required in Part 2 of this feature using the same maximum criteria values listed for each space type. The project team must indicate in their documentation application if Noise Rating is to be used in lieu of Noise Criterion.


Amendment
Type: Amendment
Post Date: 06 May, 2016

In Part 2a, change “Open office spaces and lobbies:” to “Open office spaces and lobbies that are regularly occupied and/or contain workstations:”


Feature 76: Thermal comfort

Type Description
Equivalency
Type: Equivalency
Post Date: 11 May, 2018

Singapore Standard SS 554:2016 has not been accepted as an equivalent for ASHRAE 55-2013 of Feature 76. SS 554 does not appear to directly address metabolic rate or clothing insulation assumptions. Further, the submitted comfort analyses do not confirm that the design criteria listed in Table 1 meet ASHRAE 55-2013 requirements because the metabolic rate assumptions are inconsistent. Lastly, SS 554 does not appear to include design requirements because the limits listed in Table 1 are classified as recommended and are only referenced relative to audits of existing environments.
Please note that SS 554 Table 1 recommends using ISO 7730 as the analytical method for all thermal comfort parameters and ISO 7730 is already an approved equivalent. Please also note that it is acceptable for the project team to bring on another individual with experience using ASHRAE standards to verify design compliance and sign the LOA (e.g. as a peer review), if they wish and/or the engineer of record is unable to do so.


Amendment
Type: Amendment
Post Date: 20 Oct, 2017

In 17 Jan, 2017 AAP, remove: "Core and Shell residential" before "projects may fulfill…". Add: "Residential"


Amendment
Type: Amendment
Post Date: 20 Oct, 2017

In 09 Feb, 2017 AAP, add: "for cooling" after "…or air conditioning units"


Amendment
Type: Amendment
Post Date: 26 Jul, 2017

Add: "(including circulation areas)" after "mechanically-ventilated projects"


Amendment
Type: Amendment
Post Date: 26 Jul, 2017

Remove: "naturally-ventilated" after "All spaces in". Add: "naturally-conditioned" after "All spaces in"


Equivalency
Type: Equivalency
Post Date: 26 Jul, 2017

Previously published as AAP:
ISO 7730:2005 and/or CEN Standard EN 15251:2007 may be used in lieu of ASHRAE 55-2003 Sections 5.3 and 5.4. The requirements of these standards must be met in all spaces, rather than 75% of regularly occupied spaces in the project. When selecting either ISO 7730:2005 or CEN Standard EN 15251:2007, the most appropriate standard must be selected for the space. Note that some naturally ventilated spaces may not qualify to use CEN Standard EN 15251:2007 if certain criteria are not met.

In addition, when utilizing CEN Standard EN 15251:2007, the project must comply with either Category I or Category II as described in Table A.1 of the standard in order to be within +/- 0.5 of the PMV for the space.


Alternative Adherence Path
Type: Alternative Adherence Path
Post Date: 09 Feb, 2017

Multifamily residential projects may certify when not supplying central-system air conditioning or air conditioning units for cooling in individual dwelling units, with the following conditions:
- Outdoor air is supplied at a volume to meet Feature 3 Part 4 and is filtered to meet Feature 5 Part 2.
- The developer allocates spaces for tenant-owned, supplemental air conditioning units to be installed.
- The developer supplies all occupants with tenant guidelines for selecting a high-performance air conditioner unit to maximize comfort and optimize efficiency. The guidelines should detail the importance of local thermal comfort standards including environmental factors of air temperature, humidity, radiant temperature, air speed; and personal factors of metabolic rate and clothing insulation.
- Projects using this option are limited to Gold level certification, no matter how many optimizations are achieved.


Alternative Adherence Path
Type: Alternative Adherence Path
Post Date: 17 Jan, 2017

Residential projects may fulfill the requirements of Feature 76 by providing a narrative of how the residential units meet local thermal comfort standards (environmental factors: air temperature, humidity, radiant temperature, air speed and personal factors: metabolic rate and clothing insulation) or by providing an allowance for tenants to select an air conditioning unit of their choice from options, which would allow the unit to meet the thermal comfort requirements.


Equivalency
Type: Equivalency
Post Date: 24 Oct, 2016

The Green Star Credit 14 is an accepted equivalent to the requirements of Feature 76: Thermal Comfort. Compliance with the Green Star credit is sufficient to comply with the requirements of Feature 76.


Intent
Type: Intent
Post Date: 24 Oct, 2016

In the Feature description, remove the second paragraph. Replace with the following text:
'Intent: To promote occupant productivity and ensure a sufficient level of thermal comfort.'


Alternative Adherence Path
Type: Alternative Adherence Path
Post Date: 06 May, 2016

Inquiry: In residential units, are the requirements of Feature 76 met if individual unit controls for heating are provided?

Ruling: No, an exemption from ASHRAE 55 requirements may not be granted in residential units if individual unit controls are provided. It is typical for each unit in a multifamily residential development to have individual control over space temperatures with controls allowing occupants to adjust temperatures. In order to rely on the controllability of the systems as an alternative strategy, it must be demonstrated that the local controls allow occupants to set conditions within the unit to meet ASHRAE 55.


Feature 77: Olfactory comfort

Type Description
Amendment
Type: Amendment
Post Date: 01 Nov, 2018

For Part 1, remove:
"a. Negative pressurization.
b. Interstitial rooms.
c. Vestibules.
d. Hallways.
e. Self-closing doors.".
Add:
"a. Negative pressurization.
b. Self-closing doors.
c. Hallways, vestibules or other intermediate areas."


Alternative Adherence Path
Type: Alternative Adherence Path
Post Date: 24 Oct, 2016

Core and Shell projects pursuing WELL compliance may submit Feature 77 as an Innovation feature under Features 101-105, provided all parts of the Feature are met for the whole building scope (i.e. The building core and shell and all parts of the interior finish-out that are completed by the project owner).


Intent
Type: Intent
Post Date: 24 Oct, 2016

In the Feature description, remove the second paragraph. Replace with the following text:
'Intent: To maximize olfactory comfort by reducing the transmission of strong smells and odors within the building.'


Feature 78: Reverberation time

Type Description
Amendment
Type: Amendment
Post Date: 26 Jul, 2017

Remove: "6,000 m³". Add "570 m³"


Amendment
Type: Amendment
Post Date: 26 Jul, 2017

Remove: "3,000 m³". Add "280 m³"


Amendment
Type: Amendment
Post Date: 26 Jul, 2017

Remove: "3,000 m³". Add "280 m³"


Intent
Type: Intent
Post Date: 24 Oct, 2016

In the Feature description, remove the second paragraph. Replace with the following text:
'To help maintain comfortable sound levels by limiting reverberation times.'


Amendment
Type: Amendment
Post Date: 06 May, 2016

In Part 1b, change “Open office spaces:” to “Open workspaces:”


Feature 79: Sound masking

Type Description
Equivalency
Type: Equivalency
Post Date: 04 Dec, 2017

AS/NZS 2107:2016 has been accepted as an alternative to the sound masking level requirements in Feature 79 Part 2. Note that Private Office and Open Workspace sound masking levels must fall within the background noise criteria ranges in Table 1 of AS/NZS 2107:2016. This equivalency applies only to projects in Australia and New Zealand.


Intent
Type: Intent
Post Date: 24 Oct, 2016

In the Feature description, remove the second paragraph. Replace with the following text:
'Intent: To reduce acoustic disruptions and increase speech privacy by implementing sound masking into the building design.'


Amendment
Type: Amendment
Post Date: 06 May, 2016

In Part 2a, change “Open office spaces:” to “Open workspaces:”


Verification type
Type: Verification type
Post Date: 10 Feb, 2016

Add MEP Letter of Assurance as required documentation, remove Architect Letter of Assurance.


Feature 80: Sound reducing surfaces

Type Description
Amendment
Type: Amendment
Post Date: 07 Jun, 2018

For Part 1a and 1b, add: ", beams, joists" after "...lights, skylights, diffusers"


Equivalency
Type: Equivalency
Post Date: 16 Mar, 2018

Alpha W (αw) has been accepted as an equivalent to the Noise Reduction Coefficient (NRC) requirements of Feature 80 – Sound Reducing Surfaces, Parts 1-3.

Note that Alpha W is, like NRC, a single number metric for sound absorption that ranges from 0.00 to 1.00 and represents the average absorption coefficient of a given material across 125 Hz to 4 kHz, while NRC is a metric based on absorptive coefficients of a given material across 250 Hz to 2 kHz.


Amendment
Type: Amendment
Post Date: 05 Feb, 2018

For Part 2, remove: "walls". Add: "vertical surfaces"


Amendment
Type: Amendment
Post Date: 24 Oct, 2016

For Part 2a, add "interior" in front of "surrounding walls."


Intent
Type: Intent
Post Date: 24 Oct, 2016

In the Feature description, remove the second paragraph. Replace with the following text:
'Intent: To reduce sound reverberation and maintain comfortable sound levels though absorptive ceiling and wall surfaces.'


Amendment
Type: Amendment
Post Date: 06 May, 2016

In Part 1a, change “Open office spaces” to “Open workspaces:”


Amendment
Type: Amendment
Post Date: 06 May, 2016

In Part 2b, change “Open office spaces:” to “Open workspaces:”


Amendment
Type: Amendment
Post Date: 06 May, 2016

In Part 2c, change “Cubicle style offices:” to “Partitioned office spaces:”


Feature 81: Sound barriers

Type Description
Amendment
Type: Amendment
Post Date: 01 Nov, 2018

For Part 1a, remove: "NIC of 35 when a sound masking system is present, or minimum NIC of 40". Add: "STC of 40 when a sound masking system is present, or minimum STC of 45


Amendment
Type: Amendment
Post Date: 01 Nov, 2018

In part description, remove: "Noise Isolation Class (NIC)". Add: "Sound Transmission Class (STC)"


Amendment
Type: Amendment
Post Date: 07 Jun, 2018

For Part 1b, remove: "NIC" after "minimum". Add: "STC"


Verification type
Type: Verification type
Post Date: 11 Jan, 2018

In Verification Method, add: "Architect and Contractor" after "Letter of Assurance"


Equivalency
Type: Equivalency
Post Date: 17 Jan, 2017

The China national standard 'Code for Design of Sound Insulation of Civil Buildings' (GB50118-2010) has been approved an acceptable method to comply with Feature 81, Part 1 when Dw levels under ‘High Limits’ are achieved. Note that projects must comply with the verification method according to Appendix D.


Intent
Type: Intent
Post Date: 24 Oct, 2016

In the Feature description, remove the second paragraph. Replace with the following text:
'Intent: To reduce sound transmission and acoustic disruptions through sound barriers.'


Verification type
Type: Verification type
Post Date: 10 Feb, 2016

Add Contractor Letter of Assurance as required documentation.


Feature 82: Individual thermal control

Type Description
Alternative Adherence Path
Type: Alternative Adherence Path
Post Date: 15 Aug, 2018

To meet the requirements of Feature 82 Part 1 and 2, projects may implement the following strategies:

  • Operative temperature can be adjusted by +/- 1.5 °C per 4.05 m [13.28 ft] zone edge dimension.
  • Occupants have the ability to set their preferred zone temperature.
  • Occupants have access to personal thermal comforts devices such as fans (excluding space heaters).

Amendment
Type: Amendment
Post Date: 20 Oct, 2017

For Part 1a, add: "with more than 10 people" after "...and between rooms"


Amendment
Type: Amendment
Post Date: 26 Jul, 2017

In Part 2a, remove: "employees". Add: "occupants"


Intent
Type: Intent
Post Date: 24 Oct, 2016

In the Feature description, remove the second paragraph. Replace with the following text:
'Intent: To maximize and personalize thermal comfort among all occupants.'


Amendment
Type: Amendment
Post Date: 06 May, 2016

In Part 1a, change “The building provides a thermal gradient of at least 3 °C [5 °F] across open office spaces…” to “The building provides a thermal gradient of at least 3 °C [5 °F] across open workspaces…”


Verification type
Type: Verification type
Post Date: 10 Feb, 2016

Add owner Letter of Assurance as required documentation, add on-site spot checks as required verification, remove visual inspection.


Feature 83: Radiant thermal comfort

Type Description
Alternative Adherence Path
Type: Alternative Adherence Path
Post Date: 15 Aug, 2018

As an alternative to Feature 83 Part 1, projects may use active chilled beams that integrate outdoor air supply, so long as the following conditions are met:

  • At least 50% of the thermal effect is from radiant heat transfer.
  • The outdoor air is introduced laterally at the surface of the chilled beams.
  • There is no supplemental floor-mounted conditioning or ventilating equipment at the perimeter of the space.

Intent
Type: Intent
Post Date: 24 Oct, 2016

In the Feature description, remove the second paragraph. Replace with the following text:
'Intent: To maximize floor space, reduce dust transmission and increase thermal comfort by incorporating radiant heat and cooling systems into the building design.'


Amendment
Type: Amendment
Post Date: 06 May, 2016

In Feature introduction text, change “Additional benefits include saved floor space, lower dust transportation and increased thermal comfort through the separation of temperature controls and fresh air supply systems” to “Additional benefits include saved floor space, lower dust transportation and increased thermal comfort through the separation of temperature controls and outdoor air supply systems


Amendment
Type: Amendment
Post Date: 06 May, 2016

Change Part 1 name from “Lobbies and Other Common Public Spaces” to “Lobbies and Other Common Spaces”


Feature 84: Health and wellness awareness

Type Description
Intent
Type: Intent
Post Date: 24 Oct, 2016

In the Feature description, remove the second paragraph. Replace with the following text:
'Intent: To promote a deeper understanding of factors that impact health and wellness.'


Amendment
Type: Amendment
Post Date: 06 May, 2016

In feature introduction text, change “Health literacy, defined by the Institute of Medicine as…” to “Health literacy, defined by the National Academy of Medicine as…”


Feature 85: Integrative design

Type Description
Amendment
Type: Amendment
Post Date: 27 Apr, 2017

Remove: "Prior to the design and programming of the project, all". Add: "Project"


Intent
Type: Intent
Post Date: 24 Oct, 2016

In the Feature description, remove the second paragraph. Replace with the following text:
'Intent: To facilitate a collaborative development process and ensure adherence to collective wellness goals.'


Feature 86: Post-occupancy surveys

Type Description
Equivalency
Type: Equivalency
Post Date: 05 Feb, 2018

PeopleLOOK™ of the UK has been accepted as an equivalent for the Occupant Indoor Environmental Quality Survey of Feature 86 Part 1. Note that, in addition to the survey requirements in PeopleLOOK™, thermal comfort parameters must be surveyed twice a year.


Equivalency
Type: Equivalency
Post Date: 05 Feb, 2018

The Comfortmeter survey has been accepted as an equivalent for the Occupant Indoor Environmental Quality Survey of Feature 86 Part 1. Note that, in addition to the survey requirements in Comfortmeter, thermal comfort parameters must be surveyed twice a year.


Amendment
Type: Amendment
Post Date: 26 Jul, 2017

Remove: "employees" after "10 or more". Add: "occupants" after "10 or more".
After "at least 30% of", remove: "employees". Add: "occupants" after "at least 30% of"


Equivalency
Type: Equivalency
Post Date: 14 Jul, 2017

The Building Use Studies (BUS) methodology of Occupant Satisfaction Evaluation has been accepted as an alternative for the Occupant Indoor Environmental Quality Survey required for Feature 86 Part 1.


Amendment
Type: Amendment
Post Date: 17 Jan, 2017

Change "…is given to a representative sample of at least 30% of employees at least once per year…" to "…is completed by a representative sample of at least 30% of employees at least once per year…"


Equivalency
Type: Equivalency
Post Date: 24 Oct, 2016

The Leesman Survey is an accepted alternative to the Occupant Indoor Environmental Quality Survey required for Feature 86, Part 1: Occupant Survey Content.


Equivalency
Type: Equivalency
Post Date: 24 Oct, 2016

The BOSSA Survey is an accepted alternative to the Occupant Indoor Environmental Quality Survey required for Feature 86, Part 1: Occupant Survey Content.


Equivalency
Type: Equivalency
Post Date: 24 Oct, 2016

The Green Star Innovation Challenge: Occupant Engagement is an accepted alternative to the requirements of Feature 86: Post-Occupancy Surveys. Therefore, compliance with the Green Star credit is sufficient to comply with the WELL feature.


Intent
Type: Intent
Post Date: 24 Oct, 2016

In the Feature description, remove the second paragraph. Replace with the following text:
'Intent: To allow occupants to provide feedback to building owners and management, and help further develop the WELL Building Standard.'


Feature 87: Beauty and design I

Type Description
Intent
Type: Intent
Post Date: 24 Oct, 2016

In the Feature description, remove the second paragraph. Replace with the following text:
'Intent: To thoughtfully create unique and culturally-rich spaces.'


Verification type
Type: Verification type
Post Date: 10 Feb, 2016

Add professional narrative as required documentation, remove annotated architectural drawing, remove on-site spot checks.


Feature 88: Biophilia I - qualitative

Type Description
Intent
Type: Intent
Post Date: 24 Oct, 2016

In the Feature description, remove the second paragraph. Replace with the following text:
'Intent: To nurture the innate human-nature connection within the project.'


Verification type
Type: Verification type
Post Date: 10 Feb, 2016

Add professional narratives as required documentation, remove annotated architectural drawings, remove on-site spot checks.


Feature 89: Adaptable spaces

Type Description
Amendment
Type: Amendment
Post Date: 07 Jun, 2018

For Part 3, add: "a combination of" after "...through the provision of"


Amendment
Type: Amendment
Post Date: 20 Oct, 2017

In part description, remove: "Areas". Add: "Projects with gross floor area"


Intent
Type: Intent
Post Date: 24 Oct, 2016

In the Feature description, remove the second paragraph. Replace with the following text:
'Intent: To reduce distractions, mitigate stress and enable focused work by integrating a stimuli management program within the building.'


Feature 90: Healthy sleep policy

Type Description
Amendment
Type: Amendment
Post Date: 07 Jun, 2018

In part description, remove: "middle and high schools". Add: "primary and secondary schools"


Intent
Type: Intent
Post Date: 24 Oct, 2016

In the Feature description, remove the second paragraph. Replace with the following text:
'Intent: To support healthy sleep habits by discouraging occupants from working late at night and providing them with sleep support software.'


Verification type
Type: Verification type
Post Date: 24 Oct, 2016

Under Appendix D, change the feature type for Part 1 from "(Protocol)" to "(Organizational Protocol)"


Alternative Adherence Path
Type: Alternative Adherence Path
Post Date: 06 May, 2016

The requirements of Part 1b (provide employees with a 50% subsidy on software and/or applications that monitor daytime sleep-related behavior patterns such as activity levels, caffeine and alcohol intake, and eating habits) may be met if employees are provided free, doctor recommended software applications that meet these requirements.


Feature 91: Business travel

Type Description
Intent
Type: Intent
Post Date: 24 Oct, 2016

In the Feature description, remove the second paragraph. Replace with the following text:
'Intent: To minimize disruptions to occupants' sleep and fitness regimens, and personal relationships by adopting supportive travel policies.'


Verification type
Type: Verification type
Post Date: 24 Oct, 2016

Under Appendix D, change the feature type for Part 1 from "(Protocol)" to "(Organizational Protocol)"


Feature 92: Building health policy

Type Description
Amendment
Type: Amendment
Post Date: 07 Jun, 2018

In part description, remove: "elementary, middle, and high schools". Add: "primary and secondary schools"


Amendment
Type: Amendment
Post Date: 27 Apr, 2017

Add: "or any other employer-established benefit plan designed to reimburse employees for qualified medical expenses" after "Flexible spending accounts"


Equivalency
Type: Equivalency
Post Date: 17 Jan, 2017

The 'Five Insurance' offered under the Labor Law of the People’s Republic of China has been approved as an acceptable method to comply with F92.


Intent
Type: Intent
Post Date: 24 Oct, 2016

In the Feature description, remove the second paragraph. Replace with the following text:
'Intent: To protect the overall health and well-being of occupants and their families by adopting comprehensive health policies.'


Verification type
Type: Verification type
Post Date: 24 Oct, 2016

Under Appendix D, change the feature type for Part 1 from "(Protocol)" to "(Organizational Protocol)"


Feature 93: Workplace family support

Type Description
Intent
Type: Intent
Post Date: 24 Oct, 2016

In the Feature description, remove the second paragraph. Replace with the following text:
'Intent: To ensure occupants are able to properly care for themselves and their families by adopting supportive family care policies.'


Verification type
Type: Verification type
Post Date: 24 Oct, 2016

Under Appendix D, change the feature type for Parts 1, 2, and 3 from "(Protocol)" to "(Organizational Protocol)"


Feature 94: Self-monitoring

Type Description
Amendment
Type: Amendment
Post Date: 26 Jul, 2017

Remove: "occupant" after "is made available to each". Add: "employee" after "is made available to each"


Verification type
Type: Verification type
Post Date: 24 Oct, 2016

Under Appendix D, change the feature type for Part 1 from "(Protocol)" to "(Organizational Protocol)"


Intent
Type: Intent
Post Date: 24 Oct, 2016

In the Feature description, remove the second paragraph. Replace with the following text:
'Intent: To promote awareness of individual biomarkers associated with health and wellness.'


Feature 95: Stress and addiction treatment

Type Description
Intent
Type: Intent
Post Date: 24 Oct, 2016

In the Feature description, remove the second paragraph. Replace with the following text:
'Intent: To avoid or mitigate substance use and addiction issues by providing access to stress management programs.'


Verification type
Type: Verification type
Post Date: 24 Oct, 2016

Under Appendix D, change the feature type for Parts 1 and 2 from "(Protocol)" to "(Organizational Protocol)"


Feature 96: Altruism

Type Description
Intent
Type: Intent
Post Date: 24 Oct, 2016

In the Feature description, remove the second paragraph. Replace with the following text:
'Intent: To enhance community identity and promote social cohesion.'


Verification type
Type: Verification type
Post Date: 24 Oct, 2016

Under Appendix D, change the feature type for Parts 1 and 2 from "(Protocol)" to "(Organizational Protocol)"


Feature 97: Material transparency

Type Description
Equivalency
Type: Equivalency
Post Date: 30 Nov, 2018

Building materials evaluated as "recommended" or "accepted" in byggvarubedömningen has not been accepted as an equivalent to meet the requirements of Feature 97 – Material Transparency, Part 1 - Material Information.


Equivalency
Type: Equivalency
Post Date: 29 May, 2018

The Good Environmental Choice Australia (GECA) Furniture, Fittings, Foam and Mattresses (Level A) (FFF&M v3.0-2017) standard has not been accepted as an alternative for the requirements of Feature 97 Part 1. Note that the intent of the feature is to promote material transparency along the supply chain. Feature 97 Part 1 requires that “the product must indicate that all ingredients have been evaluated and disclosed down to 1,000 ppm.” The GECA FFF&M v3.0-2017 standard requires products to disclose hazardous ingredients but not all ingredients (including non-hazardous).