Sustainability Program for Architectural Coatings (NSF/ANSI 498)

Background

In 2018, ACA partnered with NSF International, an ANSI accredited organization, to develop a multi-attribute sustainability framework for architectural coatings. There are several goals for this initiative: 1) To develop a sustainability framework that would provide coatings manufacturers an advantage in gaining certifications for green building standards and assessments; 2) Provide industry some measure of influence in the development of the framework (since many of the green building standards were developed without industry input or even notice); and 3) Clarify and prevent any confusion in the marketplace about the sustainable nature of architectural coatings. In partnering with NSF, ACA agreed to the use of ANSI protocols during the development and maintenance stages of the framework, which included the establishment of a “balanced” Joint Committee, controls over distribution of work product, and a balloting process for acceptance of the framework.

In May of 2022, the NSF/ANSI 498 Sustainability Program for Architectural Coatings completed a balloting process under the ANSI protocols. The program achieved a successful vote in both the Joint Committee as well as the Public Health Committee. Subsequent to this balloting process, several issues were raised regarding the scoring methodology, the testing protocols for washability, and the prerequisite of a publicly available Environmental Product Declaration (EPD). Amendments were proposed to address these concerns. Another balloting process occurred and concluded in late October 2022. The Joint Committee and the Public Health Committee approved these changes.

Under the ANSI protocols, the program is required to be published within 90 days of the balloting or other action must be initiated. The current status of the NSF 498 Program is that it is on hold pending further review and possible action. A decision about further action must occur before the end of January 2024 to comply with the ANSI requirements.

ACA Action

1. work to increase participation by industry on Joint Committee as observers and voting members;
2. Developed ACA Task Force that included personnel nominated by ACA Board members to manage further work on this program;
3. Conducted Task Force meeting on December 1 and identified priority issues of the industry;
4. Continues working with NSF to determine the process to achieve amendments to the program; and
5. Raised issue of publication of LEED Version 5 (LEEDv5) and delay of publication of NSF 498 in order to determine and address differences in requirements.

Membership of the Joint Committee: Voting and Observer Members
Observer members: ACA has reached out to all members of the Issue Management Committees, including the Legal and Government Affairs Committee, and urged them to become “observer” members of the Joint Committee. Since the beginning of October, the list of observers has grown to over 41 members from industry. Observer members have access to all documents and meetings; but do not have a vote in the balloting process.

Voting Members: Throughout most of the duration of the development of NSF 498, the voting members of the Joint Committee was relatively small. It consisted of four members from the certifier/user category, three members public health community, and 6 members from industry. ACA has reached out to several regulatory personnel at the federal and state levels and encouraged them to apply to become voting members. Several of these regulatory folks have agreed to do so. In addition, ACA identified several persons who meet the criteria for the user/certifier category and have asked them to apply to be voting members. These persons have also agreed to participate as voting members. To date, ACA has been successful is obtaining the agreement of at least 5 additions to the voting roster of the Joint Committee. Although these persons have not yet been approved for voting membership, ACA is working with NSF to accomplish this.
If additional user/certifiers and regulatory/public health members are added to the Joint Committee, we anticipate that additional industry members will be granted voting status. Approval to be come a voting member is the responsibility of the Chair of the Joint Committee.

ACA Task Force Activities

ACA identified members of the Task Force by 1. Soliciting nominations from the ACA Board of Directors; and 2. Soliciting members from all ACA Issue Management Committees. A meeting for December 1 was conducted where an overview of the program was conducted. Members of the Task Force were asked to review NSF 498 and provide specific comments to ACA by December 15. The comments have been collected and compiled into a single document for additional review by the Task Force. The goal is to develop a comprehensive list of proposed amendments to NSF 498 and ask the Joint Committee to respond. At this writing, a list of over 10 pages of proposed changes to NSF 498 has been compiled, a follow up Task Force Meeting has been scheduled as well as follow up meetings with NSF staff to discuss the path forward. It is anticipated that a final list of proposed amendments will be formally submitted to the Joint Committee in early January.

Publication of LEED Version 5 and Impact on NSF 498

ACA has raised the issue of the anticipated publication of LEEDv5 and the concern that the requirements of LEEDv5 will differ from the elements of NSF 498. ACA has requested that the publication of NSF 498 be delayed until after publication of LEEDv5 so that an appropriate analysis can be developed. NSF has agreed to present this issue to the Joint Committee in a late January meeting. NSF has indicated that all Joint Committee members, voting and observers, will be permitted to provide comment on this issue. Only voting members, however, will be able to cast a vote on the actual question.

Since January, NSF has conducted several Joint Committee meetings using the ACA Industry comments as the agenda for each meeting. Currently, these meetings have addressed comments from industry up to Chapter 6. The Annual Meeting of the Joint Committee is to take place on Wednesday, April 17. At this virtual meeting, the pivotal issue of the scope of 498 will be addressed. Members of the Joint Committee will debate whether the social chapters should be eliminated and the program converted to a product standard OR should it continue to be a sustainability program that includes the social chapters (chapters 12, 13, and 14). In preparation for this meeting, ACA has prepared a comparison chart of NSF 498 with other sustainability standards as well as a redline version of Chapters 12, 13 and 14.

ACA Staff

Heidi McAuliffe
Senior Vice President, Government Affairs

Katherine Berry
Director of Sustainability & Environment

Suzanne Chang
Counsel