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1.6 Environmental Policies & Practices

GSA is committed to being a responsible environmental steward through the consideration of the environment in all our business practices, compliance with environmental laws and regulation, using environmentally beneficial products and services, and using resources in a sustainable manner.

Sustainable Design

GSA is committed to incorporating principles of sustainable design and energy efficiency into all of its building projects. Sustainable design seeks to locate, design, construct and operate buildings to reduce negative impact on the environment and the consumption of natural resources. Sustainable design improves building performance while keeping in mind the health and comfort of building occupants. It is an integrated, synergistic approach, in which all phases of the facility lifecycle are considered. The result is an optimal balance of cost, environmental, societal and human benefits while meeting the mission and function of the intended facility or infrastructure. Further information can be obtained on the Internet through the Whole Building Design Guide.

The essential principles of sustainable design and development for Federal agencies address:

  • Site – Optimize site potential
  • Energy – Minimize non-renewable energy consumption
  • Materials – Use environmentally preferable products
  • Water – Protect and conserve water
  • Indoor Environmental Quality – Enhance indoor environmental quality
  • Operations and Maintenance – Optimize operational and maintenance practices
  • These principles shall serve as the basis for planning, programming, budgeting, construction, commissioning, operation, maintenance, decommissioning of all new GSA facilities, and for major renovation and alteration of existing buildings and facilities.

LEED Certification. As a means of evaluating and measuring our green building achievements, all GSA new construction projects and substantial renovations must be certified through the Leadership in Energy and Environmental Design (LEED) Green Building Rating System of the U.S. Green Building Council. Projects are encouraged to exceed basic LEED green building certification and achieve the LEED “Silver” Level.

Energy Performance

By Executive Order mandate, GSA’s overall building inventory has an energy performance goal of 55,000 BTU/GSF/year. For new construction, GSA must achieve better energy performance. Therefore, each new facility shall have specific energy targets (BTU/GSF/ year) as established by the Office of the Chief Architect. The A/E shall design to these targets. For additional information see section 1.7, Energy Conservation Standards.

Building Materials

Prohibited Materials. The use of the following materials is prohibited on all GSA projects:

  • Products containing asbestos.
  • Products containing urea formaldehyde.
  • Products containing polychlorinated biphenyls.
  • Products containing chlorinated fluorocarbons. (See Chapter 5 for replacements.)
  • Solder or flux containing more than 0.2 percent lead and domestic water pipe or pipe fittings containing more that 8 percent lead.
  • Paint containing more than 0.06 percent lead.
Ronald Reagan Building, Washington, D.C.
Ronald Reagan Building,
Washington, DC

Recycled-Content Products. GSA is required to buy recycled-content products as designated by EPA through the Comprehensive Procurement Guidelines (CPG). Architects and engineers should always make environmentally responsible choices regarding new building materials and the disposal of discarded products. Buying recycled-content products ensures that the materials collected in recycling programs will be used again in the manufacture of new products.

Section 6002 of the Resource Conservation and Recovery Act (RCRA) requires EPA to designate products that are or can be made with recovered materials, and to recommend practices for buying these products. Once a product is designated, procuring agencies are required to purchase it with the highest recovered material content level practicable.

EPA also issues guidance on buying recycled-content products in Recovered Materials Advisory Notices (RMANs). The RMANs recommend recycled-content ranges for CPG products based on current information on commercially available recycled-content products. RMAN levels are updated as marketplace conditions change.

Architects and engineers must maximize the opportunity for contractors to bid recycled-content materials by including CPG items in the design specifications. Exceptions will only be permitted if written justification is provided when a product is not available competitively, not available within a reasonable time frame, does not meet appropriate performance standards, or is only available at an unreasonable price.

Examples of CPG construction products are included in Chapter 3, Architectural and Interior Design, and Chapter 4, Structural Engineering. Information can be obtained about EPA’s list of designated products and the accompanying recycled-content recommendations on the Internet.

Lead-Based Paint. Paint will be tested for lead content when alteration or demolition requires sanding, burning, welding or scraping painted surfaces.When lead is found, implement the controls required by OSHA in 29 CFR 1926.62. Do not abate lead-based paint when a painted surface is intact and in good condition, unless required for alteration or demolition. In child care centers, test all painted surfaces for lead and abate surfaces containing lead-based paint.

Asbestos-Containing Materials. Prior to design in a facility to be renovated, a building evaluation by a qualified inspector will be performed. This evaluation will include review of inspection reports and a site inspection. If asbestos damage or the possibility of asbestos disturbance during construction activity is discovered, one of the following four corrective actions must be taken: removal, encapsulation, enclosure or repair.

All design drawings and specifications for asbestos abatement must be produced by a qualified specialist. The guiding standards for this work are the GSA PBS IL-92-8 and OSHA and EPA regulations, in particular 29 CFR 1926.58, 40 CFR 61.140-157 and 49 CFR 171-180. In general, projects should be designed to avoid or minimize asbestos disturbance. The environmental standards will be supplied by the regional office of GSA.

All GSA construction work that disturbs asbestos must be performed using appropriate controls for the safety of workers and the public.

Regular inspection of the abatement work area and surrounding areas should be performed on behalf of GSA to protect the interests of GSA, the building occupants and the public. Such inspections should include visual and physical inspection and air monitoring by phase contrast microscopy and/or transmission electron microscopy, as appropriate. Inspections should be performed under the supervision of a Certified Industrial Hygienist, or individuals accredited under the Asbestos Hazard Emergency Response Act (AHERA) for asbestos abatement supervision.

Laboratories analyzing samples for asbestos must be accredited by the American Industrial Hygiene Association (AIHA) or the National Institute for Standards and Technology's Voluntary Laboratory Accreditation Program. Laboratories analyzing air samples by phase contrast microscopy must have demonstrated successful participation in the National Institute for Occupational Safety and Health (NIOSH) Proficiency in Analytical Testing program for asbestos.

On-site analysis by phase contrast microscopy may be performed as required, provided that the analyst is board-approved in the AIHA Asbestos Analysis Registry and provided that a quality assurance program is implemented, including recounting of a fraction of samples by a qualified laboratory. All final clearance transmission electron microscopy air samples must be analyzed in accordance with the EPA AHERA protocol in 40 CFR 763, Appendix A of subpart E.

Indoor Air Quality
All products to be incorporated into the building, including finishes and furniture, should be researched regarding characteristics of off-gassing and noxious odors that will affect indoor air quality.

Soil Contamination
The Comprehensive Environmental, Response, Compensation, and Liability Act (CERCLA or Superfund) provides authority and distributes responsibility for cleanup of contaminated soil, surface water and groundwater from inactive hazardous substance disposal sites and from hazardous substances released into the environment that facility permits do not cover. If soil or water contamination is a concern during construction of new buildings, major and minor alterations, and work in historic structures, then the EPA regulations under 40 CFR should be followed.

Underground Storage Tanks (USTs)
The EPA finalized regulations USTs in 40 CFR Parts 280 and 281. These regulations apply to all tanks containing petroleum products and hazardous substances as defined by the EPA. The regulations direct facilities to implement technical standards and corrective actions for the management of and releases from USTs. If USTs are a concern during construction of new buildings, major and minor alterations, and work in historic structures, then the EPA regulations should be followed. If a leaking UST is detected/discovered, contact EPA.

Compliance with the National Environmental Policy Act (NEPA)
GSA conducts an environmental review of each project prior to the start of design as required by the National Environmental Policy Act (NEPA). The review identifies environmental impacts and alternative courses of action that may have less impacts. The review can result in:

  • A Categorical Exclusion (CATEX) from the requirement to prepare an Environmental Impact Statement (EIS),
  • The preparation of an Environmental Assessment that results in a finding of No Significant Impact (FONSI),
  • The preparation of an Environmental Assessment that identifies significant impacts, followed by preparation of an Environmental Impact Statement (EIS), or
  • The preparation of an EIS.

If an Environmental Assessment or EIS has been prepared, it will constitute the primary guideline for environmental design issues. In those instances where GSA has committed to implementing specific mitigation measures, programmers and designers must ensure that those measures are carried out in the design.

Guidance
The following documents contain specific design requirements or may influence design decisions:

  • Council of Environmental Quality (CEQ), Code of Federal Regulations (CFR) Title 40, Parts 1500 - 1508: Regulations for Implementing the National Environmental Policy Act.
  • GSA ADM 1095.1F: Environmental Considerations in Decision Making.
  • GSA ADM 1095.2: Considerations of Flood Plains and Wetlands in Decision Making.
  • GSA PBS NEPA Desk Guide.
  • Environmental Protection Agency (EPA), 10 CFR 40, 1.23, 1-4, 1-16: Procedures for Implementing the Clean Air Act and the Federal Water Pollution Control Act.
  • EPA, 40 CFR 50: National Primary and Secondary Ambient Air Quality Standards.
  • EPA, 40 CFR 60: New Source Performance Standards.
  • EPA, 40 CFR 61: National Emission Standards for Hazardous Air Pollutants.
  • EPA, 40 CFR 82: Protection of Stratospheric Ozone.
  • EPA, 40 CFR 260-299: Solid Wastes.
  • EPA, 40 CFR 300-399: Superfund, Emergency Planning and Community Right-to-Know Programs.
  • EPA, 40 CFR 401-403: Effluent Guidelines and Standards.
  • LEED™(Leadership in Energy & Environmental Design) Green Building Reference Guide, developed by the U.S. Green Building Council.

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