On April 3, 2024, the U.S. Green Building Council released Version 5 of its LEED for Existing Buildings Rating System (LEED-EB) for public comments.
The initial version undervalues the essential role of cleaning to protect building occupant health. It misses the opportunity to provide updates that would help the global cleaning industry demonstrate the value of cleaning. Furthermore, LEED-EB is often used as the roadmap to a comprehensive green cleaning program. If left unchanged, it will be a setback to sustainability in the cleaning industry by more than 15 years, back to the LEED version predating 2009.
Unless members of the cleaning industry provide comments by May 20, improvements will not be made for at least five more years. The following are sample comments followed by directions for how to submit them. Please share your comments, make your voice heard and help make LEED better!
Sample Introductory Comments
My name is ___________, and my comments represent ______________ [NOTE: Add either “my personal recommendations based on ___ years of cleaning experience,” OR “the recommendations of ___________ company, a facility service provider and member of the Building Service Contractors Association International”] regarding the Proposed LEED O+M: Existing Buildings v5.
Specifically, our comments address the elements of Green Cleaning and Equity Within Operations and Maintenance Staff. We are deeply concerned that the standards proposed in these elements are a setback for the entire cleaning industry.
Add Specific Concerns
Below are examples of three comments and recommendations to add to your submission:
- Comment 1: Fundamentally there are too few credits allotted to Green Cleaning programs, particularly in comparison to other credits. For example, currently all cleaning products and processes designed to protect occupant health on a daily basis receive the same amount of points as a one-time occupant satisfaction survey, requiring only 15% of the occupants to respond.
- Recommendation: We recommend increasing the credits for Green Cleaning to 10 points to better reflect the importance of cleaning to protect occupant health.
- Comment 2: Cleaning to protect occupant health is more than just using green chemicals, recycled toilet tissue and other products. Rather, successful cleaning efforts require appropriate management strategies, quality control issues, worker training and other critical success factors. Unfortunately, the current draft has deleted the prerequisite that addressed these management issues and has not integrated those critical program management requirements elsewhere into the credit.
- Recommendation: We recommend that the prerequisite be restored.
- Comment 3: The social equity element is not tailored to the equity needs and working conditions of cleaning personnel. Cleaning teams are generally the largest and most frequently present labor force in buildings over their life span. They are often among the most vulnerable and socioeconomically disadvantaged labor forces onsite.
- Recommendation: The social equity standard in the prerequisite should be better tailored to address the needs of cleaning teams.
We respectfully request that U.S. Green Building Council (USGBC) seriously consider these comments and update the proposed standard to better meet the needs of the global cleaning industry.
How to Submit a Comment
For your convenience, here are the steps to submit comments to the USGBC:
- Go to the USGBC website for LEED Existing Buildings. This is the LEED credit library where you can submit comments.
- In the dropdown, left center, select “LEED O+M Existing Buildings.”
- In the dropdown right center, select “v5 – Public Comment 1.”
- Below this is a search bar. Search for the “Green Cleaning” and “Equity Within Operations and Maintenance Staff” sections.
- Links to these pages discussing green cleaning and social equity in the proposed LEED v5 will appear.
- At the top, you will see a “Comment” box. Click here to share your thoughts. You will need to create an account to comment if you do not already have an account.
- When you are finished commenting, click “Add Comment.”
Share Your Comment Today
Comments are needed from service providers, both individually and those representing an entire organization. You do not need to be a member of the USGBC to comment. To achieve our goal to help LEED improve, 1,000+ comments are needed by May 20. It is essential that your voice is heard. Stand behind a comprehensive green cleaning program, and comment today.
For more information and resources on this issue, visit BSCAI’s LEED V5 webpage.
Stephen Ashkin is president of The Ashkin Group. He serves on the US Green Building Council’s LEED for Existing Buildings committee and was the lead author of BSCAI’s COVID-19 Disinfection and Safety course. He can be reached at Steve@AshkinGroup.com.
