This article identifies some of the most common reasons that documentation for feature X01.3 - Restrict Lead - is marked as pending in preliminary documentation review (WELL Certification) or round 1 (WELL at scale) reviews. This guidance does not include all possible reasons for a pending status, but provides information and context based on common review issues.
Sample documentation is available for this feature part–be sure to reference this resource as you prepare your documentation.
Provide product specification sheets
You must provide product specification sheets for up to 10 distinct applicable products. The product specification sheets should either demonstrate compliance with EU restriction of hazardous substance (RoHS) regulations or show that the product contains no more than 0.01% (1000 ppm) of lead by weight.
Applicable products include newly installed:
- Fire alarms
- Meters
- Sensors
- Relays
- Thermostats
- Load break switches
- Paints applied as finishes
If your project is located in a place where laws prohibit the sale of products that do not comply with RoHS restrictions, you may provide a narrative that identifies those applicable laws instead of providing product specification sheets.
Provide Proper Letters of Assurance
Feature X01.3 requires, for all spaces, a Contractor Letter of Assurance for requirement 1 (Paints and electronics), and an Engineer Letter of Assurance for requirement 2 (Drinking water pipes, fittings and solder). For each Letter of Assurance submitted, always ensure that the letter is fully complete, including checking that you have corrected for any:
- Missing signatures (usually towards the bottom of the LOA)
- Sections not checked or initialed
The correct type of letter corresponding to the feature. (i.e., ensure Contractor AND Engineer Letters of Assurance are submitted).
Document Compliance with Restriction of Hazardous Substances Requirements
Feature X01.3 can also be met through demonstrated compliance with the European Union’s Restriction of Hazardous Substances (RoHS) directive which entered into force on July 12, 2011. Please keep in mind that documentation must show compliance with European Union RoHS standards, not China RoHS standards (unless the project is located in China, where EP #00304 can be used to meet this requirement using China Standard GB/T 26572).
In some cases, projects may require a narrative that identifies applicable laws that prohibit the sale of products that do not comply with RoHS restrictions. If this is the case for your project, please ensure that any and all applicable laws are identified.
Properly Format Documentation
Multiple pieces of documentation are required to meet Feature X01.3:
For part 1:
- Technical document (product specific sheets or a narrative identifying laws that prohibit the sale of products that do not comply with RoHS restrictions)
- Contractor letter of assurance
For part 2:
- Engineer letter of assurance
To avoid having documents marked as pending, ensure any documents submitted for feature X01.3 are:
- Submitted for the right part
- Properly translated to English when necessary
- (WELL at scale only) Assigned to the correct locations in your WELL Scorecard
- Properly identified, in the case of alternative adherence pathway documentation
Document Equivalencies and Alternative Adherence Paths
Some projects may choose to meet Feature X01.3 through the use of an Equivalency or Alternative Adherence Path (AAP). There are multiple alternative pathways to complying with X01.3, including meeting relevant LEED, BREEAM and China Standard GB/T parts. When submitting for an Equivalency or AAP, always ensure:
- Proper documentation is included for the type of Equivalency/AAP pursued
- All Equivalency documentation is properly uploaded (and assigned to the correct option for WELL at scale projects)
- Any Crosswalk or Skybridge documentation is included in your submission