Big Green: MR 7 Question

Andrew Gil amg at holt.com
Tue Apr 28 19:15:38 UTC 2009


Amy,

Thanks again, especially for your great efforts and positive outlook. I agree that the best all-around and best long-term solution is for the local mill shop to get COC certification, but I know that the prospect of doing that will tips the scales for them and keep them from wanting to work on future green projects.

I'm still a bit less than 100% sure about the logic behind the rules (and I did look up the Errata and CIR that Ralph referenced) but I have so far decided, rightly or wrongly, that when the USGBC's rules changed a while back from requiring COC certification for every product shipment (which was impossibly hard) to instead certifying the wholesaler, that the USGBC's change to allowing processing and all that can cover (including manufacturing) to be permitted by a company with COC Certification, there was an unavoidable - and, I suspect,  unintended - downside of having to exclude the opposite: So, any party that alters the product, even the packaging, before the end user must have COC certification. In this situation, the chain of custody is not broken by the fact that the local mill shop IS the end user and, therefore his labor can't be included.

Andrew

Andrew M. Gil, AIA
Architect, LEED-Accredited Professional
Project Manager

HOLT Architects, P.C.
217 N. Aurora St.
Ithaca, NY 14850
p. 607 273-7600
f. 607 273-0475
http://www.holt.com

From: Amy Bauman [mailto:abauman at greengoat.org]
Sent: Tuesday, April 28, 2009 12:24 PM
To: Andrew Gil; biggreen at lists.biggreen.org
Subject: RE: Big Green: MR 7 Question

Hi again -

I have an alternate question that might channel you in a productive direction.

If he could emulate the COC certification process and provide that, then that piece of paper would seem to bridge the gap.  I am a huge believer in chain-of-custody (COC), and it would seem that going through this process would be a good investment for him in the long run and be something he should be thinking about anyway.

Sadly, this is the danger of any certifying organization (USGBC, in this case) using brand names (FSC, in this case) absolutely.  On the other hand, USGBC prefers strongly that the documentation needs to meet the _intent_ of the point.  I believe you could make the case that providing complete chain-of-custody that is comparable to that supplied by FSC should satisfy the point.

... Then you're back to his invoicing protocol, which is much easier.

Best of luck!  Thanks for making me think!


Amy Bauman
Director
greenGoat
501(c)3, WBE helping building owners spare construction waste
617-666-5253
abauman at greengoat.org


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