Ins and outs of curative action

Ins and outs of curative action

Thursday, February 7, 2019
/ By:
Kate Rube

WELL Tips

In order to achieve WELL Certification, projects must successfully complete a documentation submission and pass performance verification. Performance verification provides assurance that WELL Certified projects have successfully passed all on-site performance tests and a visual inspection of relevant features. Projects that do not pass elements during performance verification have the opportunity to remediate the non-compliant elements in a process called curative action. Curative action is an important step in correcting issues that, without performance verification, may have otherwise gone undetected and continued to cause potentially negative impacts on occupants.

Read on to learn about how curative action works, what to expect from the process and common remediation strategies that have been pursued to bring projects in line with the health-based performance metrics of the WELL Building Standard™ (WELL™). For registered projects, your WELL coaching contact is a great resource to help support you through the curative action process, including identifying strategies to correct any issues that exist related to WELL requirements.

When does curative action occur?

Following performance verification, a WELL report is issued by the WELL Reviewer, which details all features the project has pursued and their status, based on verification methods. After the WELL report is issued, the project owner has 180 calendar days to accept the report. However, if the WELL report includes features that were pursued, but not achieved, the project may initiate curative action and/or file an appeal in order to pursue those features if desired.

Curative action is available to project teams that wish to undertake corrective measures to address unmet performance testing criteria and schedule follow-up performance testing. Appeals are available to projects that wish to contest findings of the WELL report. For more information on appeals, see the WELL Certification Guidebook.

How does the curative action process work?

To pursue a curative action path for any features where WELL requirements were unmet in performance verification, a curative action plan must be submitted in WELL Online within 180 calendar days after issuance of the WELL report. The plan must outline steps for how the project team plans to address unmet features before features are reviewed again by the WELL Reviewer or tested again by the performance testing agent. The curative action plan will be reviewed by the WELL Reviewer and results will be provided within 20-25 business days.

If the curative action plan is accepted, the project must then enact curative actions as outlined and schedule performance re-testing as necessary. Unmet features that are verified through a performance test, including those related to air quality, water quality, lighting, acoustics, and thermal comfort, require re-testing by the WELL Reviewer or a performance testing agent during a follow-up site visit. Re-testing for most WELL features is only required in the sampling locations that did not pass. The one exception is light testing, which requires a re-test of all tested locations because feature compliance is based on the averages of the entire population of test locations. For features where the verification method is a visual inspection, spot check, or photograph, a photograph provided by the project team can often suffice for the curative action.

What does a curative action plan typically include?

A typical curative action plan is a brief narrative describing the corrective action(s) for the feature that was unmet. Best practice curative action plans include:

  1. A summary of the WELL requirement that was not passed during performance verification.

    • For example: Conference Room 01 failed Feature 75 acoustics testing. It achieved an Noise Criterion (NC) of 41 instead of the required 30 NC.

  2. A description of how the issue was assessed by the project team.

    • For example: The project owner hired a local acoustics consultant to assess the sound issues. The acoustics consultant analyzed mechanical noise, outdoor noise intrusion, interior noise intrusion and current acoustical treatments in the conference room.

  3. A description of the proposed solution.

    • For example: The acoustics consultant found that a damper was creating noise issues and worked with the building engineer to correct the issue. The acoustics consultant also recommended acoustical treatments on the door of the conference room, which have been installed. In addition to this, the project is pursuing the AAP that allows an additional 5 NC for projects attempting WELL Gold certification under WELL v1.

  4. A description of how this proposed solution will thoroughly address the original issue, without negatively impacting any other WELL features.

    • For example: The acoustical engineer confirmed through testing that implemented solutions have reduced the NC of the conference room down to 33 NC.The acoustic improvements implemented met the VOC requirements of Feature 4, and are not expected to have any negative air quality impacts.

What are the associated fees?

The fee for the review of a curative action plan is $500 per WELL feature. If required, re-testing fees are additional and vary depending on the size of the project, the number of sample locations that did not pass WELL feature requirements and local lab fees.

Performance testing agents will set their own re-testing fees. For GBCI performance testing, which is utilized for all v1 projects and may be used if desired on WELL v2™ Pilot projects, re-testing fees do not require project teams to pay for travel costs or travel time in order to keep such fees low.

For projects that may want to set aside a contingency budget for possible curative action, we recommend the following as an estimate:

  • Up to 9,290 sq. m (100,000 sf) = $2,500 USD

  • 9,290-23,226 sq. m (100,000- 250,000 sf) = $5,000 USD

  • 23,226 sq. m (250,000 sf) or bigger = $10,000 USD

What steps can I take to avoid curative action?

If necessary, curative action is not a negative part of the WELL process- it helps project teams to ensure their project has not only been designed for occupant health and well-being, but that it is operating to accomplish those goals. To be prepared for performance verification, consider the following:

  • Performing a thorough inspection of the project site at least 15 days before your performance testing date with your WELL checklist, ensuring that every feature that will be spot checked or subject to a visual inspection or photograph is meeting the outlined feature requirements.

  • Conducting pre-testing, as necessary, of the elements that will be performance tested. For example, a project that tests its drinking water on site and find that some contaminants are elevated above WELL-prescribed levels can decide to install appropriate filtration in advance of performance testing. If you do choose to conduct pre-testing, review and share the Performance Verification Guidebook with your project team so that correct methodologies are followed and proper equipment is used. However, for some projects it may be more cost effective to simply undergo performance testing, and then undergo curative action and re-test if necessary.

For more tips on preparing for WELL performance testing, please see this article.

My project has entered into curative action- what are remediation strategies for my project to consider?

This section includes some remediation strategies that projects have employed successfully in curative action to meet WELL’s performance tested features. However, every project is different, and we recommend an individual assessment of the possible contributors to the unmet requirement and full consideration of potential remediation strategies, including ones that may not be listed here.

The first step to any curative action solution is to work with your WELL Reviewer or performance testing agent to understand the specific locations that did not pass WELL’s requirements, and start with an examination of the factors that may be contributing to poor performance in that location. You can also utilize relevant local assets, such as your facilities staff, your architect, etc. to help you identify issues and potential solutions. Your WELL coaching contact can also help to support consideration of remediation strategies.

Example Curative Action Solutions:

Air quality

[Relevant Features: WELL v1 - Feature 1; WELL v2 - A01]

You may use common remediation strategies to improve air quality overall- install higher grade filters into the mechanical system, ensure that filters are changed and cleaned regularly, add stand-alone air purifiers, conduct an air flush, elevate ventilation rates or identify and remove sources of the possible air contaminant. Understanding the outdoor levels of the contaminants tested for WELL can be helpful in identifying whether the source is interior or exterior-driven- many governments have publicly accessible air quality reports detailing local outdoor air contaminant levels that can be referenced.
Some of these contaminants include:

  • Particulate matter (PM10 and PM2.5) – Common sources of particulate matter originate outside the building, such as construction waste, dust, sand and industrial pollution. Particulate filters, such as MERV or HEPA, can be implemented to filter out particulate matter. Use of vacuum cleaners with HEPA filters can also help remove such contamination.

  • Volatile organic compounds (VOCs) - Common sources of VOCs include building materials, furniture and cleaning products, which can off-gas these compounds into the air. Solutions for high levels of VOCs include installing carbon filters to remove VOCs from the air, replacing high VOC furniture or building materials with non-emitting or low-emitting options or implementing a cleaning program with low-VOC /no-VOC products. VOCs levels do typically reduce over time as long as new sources are not being introduced in the space.

  • Ozone – Ground level or "bad" ozone is created by chemical reactions between oxides of nitrogen (NOx) and VOCs in the presence of sunlight. Some of the major sources of NOx and VOC that can contribute to ozone levels are emissions from industrial facilities and electric utilities, motor vehicle exhaust, gasoline vapors and chemical solvents . Office items like photocopiers can potentially contribute to ozone levels as well. Check the outdoor levels of ozone to help identify if the source is likely from the interior or exterior of the building. If the exterior air has elevated levels of ozone, additional carbon filtration can help; if indoors, look to identify potential source culprits for remediation such as printers.

  • Carbon monoxide – Common sources of carbon monoxide are from the incomplete burning of natural gas and any other material containing carbon, such as gasoline, kerosene, oil, propane, coal or wood. Vehicles, stoves and heating systems can contribute to elevated levels of carbon monoxide in the atmosphere. Similar to ozone, check the levels of carbon monoxide outside the building, especially in adjacent parking areas and loading docks or from local equipment such as generators, to help identify if the source of the issue is from the exterior or interior and help inform the remediation strategy.  

Water quality

[Relevant Features: WELL v1 - Features 30-34, 37; WELL v2 - W01, W02, W04]

Water contamination can be tied to problems at the water source (the municipal water supply, for example), the infrastructure through which the water travels (pipes) or on-site issues (improper cleaning of faucets, etc.). First, work to identify the likely source of your problem by examining any available local water reports. Then, check with the facilities management about the status of the plumbing system - for example, how old is it and does it have a history of leaks or other issues?

Filtration is typically the most effective means of targeting elevated levels of contaminants or sediment (turbidity) in drinking water. Choose a filter that is targeted to the specific contaminant(s) that is above WELL’s health-based metrics. WELL v2 Feature W05, Part 2 can serve as guideline. Filters can be installed at the base building, or at the source (either under-sink or on the faucet directly).

There are two main types of water filters: membrane and porous media. Membranes (including reverse osmosis) tend to be more energy intensive, but can remove smaller particles or ions. Porous media allow for greater flows and can reduce the amount of water wasted, but they don't remove dissolved ions. Over-filtering water can be inefficient, so choose a water filter that targets the specific contaminants that are an issue in your supply as well as one with an adequate flow rate. Filters need to be prepared for operation before use, usually through immersion several times in freshwater, and need to be maintained/changed over time; projects should follow the manufacturer's instructions.

Consider the following additional strategies if these WELL requirements are the problem:

  •  Sediment - Sediment filters can reduce the turbidity of water by removing suspended solids.

  • Coliforms - Coliform bacteria are naturally present in the environment and are generally considered harmless. However, total coliform presence in water suggests that water may contain more dangerous pathogens, such as the specific coliform, E. coli. UV disinfection systems can be effective at destroying coliforms and other microbes. If the elevated coliform level was tied to a moment-in-time problem, flushing it with clean water could remove any lingering problems, as well as proper cleaning of the faucets on site. You can also consider informing your municipal water supplier and inquiring about any water works performed nearby, as well as hiring a licensed water consultant to determine whether your plumbing system requires disinfection. Follow-up sampling is highly recommended.

Lighting

[Relevant Features: WELL v1 - Features 53, 54; WELL v2 - L02, L03]

Lighting is performance tested for its ability to meet both visual and circadian lighting requirements. For both of these issues, elevating the lux levels in a space can help to meet WELL’s requirements, which could be facilitated through switching out existing lamps or ambient lighting, adding supplemental lighting (LED strips, lamps, task lights, etc.), modifying the reflectiveness and colors of surfaces, evaluating the capacity and settings of the lights, verifying that overhead lights are not being blocked by any ductwork or other building elements in workstation areas or possibly considering moving workstations that are not in compliance.

  • Visual lighting design – WELL v1 requires that projects meet certain levels of ambient lighting intensity and minimum lux levels on the work surface, while WELL v2 requires compliance with illuminance recommendations specified in approved lighting reference guidelines. Projects should consider ways to increase the lux levels in the space and at workstations by the methods described above.  

  • Circadian lighting requirements (EML) – WELL requires that projects meet minimum equivalent melanopic lux (EML) on the vertical plane at eye level for occupants to support circadian health. (Note that Circadian lighting design is an optimization in WELL v2.) EML is a function of photopic lux at eye level multiplied by the melanopic ratio, which is in turn impacted by the spectral distribution of the on-site lighting (see Table L1 and L2 in the WELL Building Standard v1 for details on how to calculate EML). Therefore, strategies to increase the lux levels in a space can help to meet WELL’s circadian lighting requirements, as can increasing the melanopic ratio.

Increasing the lux levels on the vertical plane at eye level can elevate the amount of light entering the eye, helping to stimulate the circadian system. Project teams should keep in mind that increases in light levels need to be balanced with glare mitigation requirements outlined in WELL. Light with higher color temperatures (4500-6500K) tend to have higher melanopic ratios and can help to increase circadian entrainment during the day. Another factor to consider is the color of surfaces in testing point areas. If the surfaces absorb light in the blue wavelength of the light spectra, EML values measured may be lower at the location. Colors to consider avoiding are red, orange and other warm tones.

WELL v1 has two pathways for meeting the circadian lighting design feature (and projects must meet only one of these options) – a pathway that measures both daylight and electrical light together (Part 1a), which requires higher EML, and an electrical light only pathway (Part 1b), which requires a lower EML. WELL v2 only includes an electrical light pathway, and as stated above, this feature is an optimization.

WELL v1 projects can also consider employing an approved alternate adherence pathway (AAP) to meet the circadian lighting design requirements, which allows projects to demonstrate that task or supplemental lighting, provided to occupants upon request, can ensure all workstations can meet the prescribed EML. Additional requirements and details are included in the AAP here.

Sound

[Relevant Features: WELL v1 - Features 74, 75, 78; WELL v2 - S02, S04]

Acoustics issues can derive from the interior or exterior of a project site. Identifying the source(s) of the problematic noise is an important first step in the remediation process. In general, sound absorbing materials can help projects to meet WELL’s acoustics requirements and to improve acoustical comfort in a space. These can include: softer surfaces, plants and landscaping or ceilings and carpeting, all of which can also help absorb sound once it enters a space. Utilizing materials with high STC (Sound Transmission Class )/NIC (Noise Isolation Class), and NRC (Noise Reduction Coefficient) ratings can also help to reduce noise in and between interior spaces. Finally, project teams can help to ensure that conference rooms and breakout rooms, as well as enclosed offices, are well-insulated, with non-hollow doors and partitions or walls that extend up to the ceiling slab (through the dropped ceiling, if applicable).

  • Exterior noise – WELL measures the amount of noise that is able to intrude from the exterior to the interior of the space, which is impacted by outdoor noise levels and the acoustic rating of the building façade. Remediation strategies to reduce exterior noise levels in a space, in addition to those detailed above, could include:

    • Improving the sound insulation of windows by bolstering window frames or installing secondary glazing, creating an air gap between panes

    • Insulating window glass with high STC/OITC (Outdoor Indoor Transmission Class rating), such as with film, unbalanced glazing, etc.

    • Checking the envelope for the source of any sound to identify and fill or resolve any holes or issues

    • Moving workstations away from windows or sides of the building where exterior sound is a greater concern (note that this may require light retesting to ensure new workstation locations meet the WELL lighting requirements)

  • Internally generated noise– WELL v1 measures noise from a building’s HVAC system specifically for this feature. Remediation strategies could include installing sound-absorbing materials within the ductwork, employing best practice door design as detailed above or implementing strategies to reduce the source of the noise. While these methods may be intuitive (i.e. best practices to minimize mechanical noise from diffusers, AC units, VAV boxes, fan coil units, fan powered boxes or other similar appliances), projects may wish to hire an engineer to investigate the HVAC system more accurately. The engineer can rebalance the HVAC system to run more quietly and efficiently, or consider remediation strategies such as relocating ducts, insulating ductwork, selecting diffusers, etc.

Finally, New & Existing Interiors project teams pursuing WELL v1 can also consider use of an approved AAP that allows projects to meet higher noise criteria (NC) levels, but caps certification levels at Silver or Gold. Additional requirements and details are included in the AAP here.

Thermal comfort

[Relevant Features: WELL v1 - Feature 76; WELL v2 - T01, T02]

WELL requires projects to meet thermal comfort standards that help provide a means of predicting whether humans in a mechanically conditioned space will be satisfied with the thermal environment. This is based on six core parameters: air temperature, humidity, air movement, mean radiant temperature of surrounding surfaces, metabolic rate and clothing insulation. Projects that do not pass the thermal comfort requirements for WELL on site can evaluate ways of adjusting their mechanical system parameters as outlined previously to bring the indoor environment in compliance with one of the thermal comfort standards referenced. Solutions may include commissioning or re-commissioning systems, balancing systems, commissioning controls, inspecting mechanical systems for issues and blower air door testing (to find leaks in thermal envelope) followed by leak remediation.

Recap

Curative action provides registered projects with the ability to remediate and gain credit for any features that were non-compliant with WELL’s requirements during performance verification. This includes visually inspected features or those assessed through the on-site testing. Your project’s WELL reviewer can help to ensure you understand if any elements need to undergo curative action, and then your coaching contact can help support your team in identifying solutions as needed. Curative action is an important step in correcting issues that, without performance verification, may have otherwise gone undetected and could cause potentially negative impacts on occupants. It helps to ensure that all WELL-certified spaces have met health-based requirements and are supporting people’s well-being.

 

With expertise in active design, urban planning, and policymaking, Kate brings extensive experience in project management, policy development, and training to her position on the Technical Solutions team. Prior to joining IWBI, Kate was Senior Director, Delos Solutions at Delos. In this role she consulted with organizations in the US and globally to drive their successful adoption of WELL. Prior to Delos, Kate was Vice President at Project for Public Spaces, where she helped cities create plans to improve walkability, activate public spaces, and create safer, more vibrant streets. Kate also served as the Active Design National Training Manager for the New York City Department of Health and Mental Hygiene, where her work helped lead to the creation of new active living programs in several cities. Earlier in her career, Kate was the Policy Director of Smart Growth America, and the Assistant Field Director at the U.S. Public Interest Research Group. Kate received her bachelor’s degree fro

CITATIONS

[1] U.S. EPA https://www.epa.gov/ozone-pollution. Accessed October 11 2018.

[2] OSHA https://www.osha.gov/OshDoc/data_General_Facts/carbonmonoxide-factsheet.pdf. Accessed October 11 2018.