BASIC DOCUMENTATION
I13-1 Materials Tracking Table (MTT)
READY AUDIT
A complete Materials Tracking Table and supporting documentation showing Red List compliance for at least 90% by cost of new materials used on the project. The Materials Tracking Table has a built-in calculator to determine percentage compliance by cost.
I13-2 Materials Vetting Process Narrative
READY AUDIT
A detailed 2- to 3-page narrative outlining the project team’s materials research and vetting process. The narrative must address:
- Timeline of materials vetting in relation to project design and construction schedule, including any instances where conflicts between the project schedule and product vetting or availability timelines affected product selection, including any noteworthy scheduling events or conversations.
- Parties responsible for product selection and specification.
- Parties responsible for manufacturer outreach and Materials Petal vetting and documentation, including advocacy.
- Specific resources and databases used for vetting and documentation.
- Materials vetting achievements by the project team, specifically identification of new compliant products, product substitutions, manufacturer education, and other examples of market transformation.
- Types of products requiring the General Red List Exception and explanation of market limitations experienced by the project team.
- The decision-making process the team relied on in instances where the standard requirements may have led to competing rationales for the selection of specific products.
I13-3 Ingredients List (Product Content Inventory) Documentation
READY AUDIT
Product content inventory documentation is required for each product. The following is accepted documentation confirming no Red List chemicals are present:
- Active Living Product Challenge certification ID number (i.e. XYZ-LP001).
- Active Third Party Verified (3PV) or self-disclosed Declare label ID number with Red List Free or Red List Approved Declaration Status (Products renewed or published before February 1, 2020 must have a Red List Free or LBC Compliant Declaration Status).
- Published HPD inventoried at 100 ppm representing 100% of intentionally added ingredients and residuals present in the final product (HPD marked “Yes” for Characterized, Screened, and Identified).
- Product Content Inventory (Ingredients List) at 100 ppm representing 100% of intentionally added ingredients and residuals present in the final product.
I13-4 VOC Content Documentation
READY AUDIT
Supporting data is required for each wet applied product. Acceptable documentation must include one of the following, confirming compliant VOC content:
- Active Declare Label with VOC disclosure.
- Health Product Declaration (HPD) with VOC disclosure.
- MSDS or GHS SDS with VOC data.
- Image of VOC content on product label.
- Signed statement of compliance and VOC content disclosure from manufacturer.
I13 Case Study
FINAL AUDIT
A summary narrative describing the project team’s approach to the imperative, highlighting any lessons learned or particularly rewarding outcomes.
EXCEPTION DOCUMENTATION
Projects that use Exceptions or compliance paths that are not standard for all projects must submit additional documentation per the below. Unless the exception is tied to the 12-month performance period, all exception documentation must be submitted at the Ready Audit.
I13-a Due Diligence Documentation
Documents demonstrating genuine effort and investigation to exclude Red List products, such as project team meeting notes, emails exchanged or specifications calling out compliant products. Communications must include requests to the parties supplying and/or requiring the non-compliant material, as well as the response from those parties.
I13-b Technical Documentation
Legal, economic, contract, or performance documents that verify Exception requirements have been met, including, as applicable:
- Official documents such as current business licenses, registrations, or permit documents.
- Contracts or receipts showing transactions related to Exception requirements.
- Documentation showing reference standard threshold has been met, including written ingredient level or emissions concentration confirmed by applicable test results.
- Certificate or stamp of approval from certifying body indicating requirements of industry standard test has been met.
- Specified system performance requirements.
- Narrative of Red List disposal methods in conformance with local regulations.
- List of de-listed CASRNs
I13-c Ingredients Documentation
Documents explicitly stating the following for the product selected:
- Ingredient percentage (%) disclosed
- Ingredient percentage (%) withheld
- Threshold disclosed (100 ppm or other)
- Written confirmation that the product is Red List compliant with note of any applicable Chemical Class Exceptions
I13-d Advocacy Letters
A letter to the entity that provides or requires Red List products advocating for the elimination of Red List materials.
Advocacy is required for all non-compliant products that are part of a Living Building Challenge project, including those addressed in Specific Exceptions. Letters should address why the product is non-compliant (lack of transparency or use of Red List ingredient, or both).
There are three types of advocacy letters:
- Letters to whichever Authority Having Jurisdiction (AHJ) requires Red List ingredients be used, requesting that the policy be changed.
- Letters to the manufacturer of the code-required but non-compliant material, requesting a Red List–compliant alternative.
- Letters to the manufacturer advocating that the manufacturer provide 100% ingredient transparency at 100 ppm using an Industry Standard Public Disclosure Program, and/or letters advocating that a manufacturer remove a Red List chemical from their product in future formulations.
Only one type of letter is required for any given Exception, unless noted otherwise.
I10-e Manufacturer Letters
A letter from a manufacturer confirming information that is not otherwise available, such as a letter confirming there are no Red List materials present at or above 100 ppm in any proprietary ingredients or as otherwise required by the Exception. For example, RL-004a requires that the manufacturer provide a minimum of 50% of the product’s ingredients to the project team.
