Al Sa'fat Testing for Listed Existing Buildings

Clause 401.07 of Al Sa'fat, the Dubai Green Building System, 2nd edition January 2023, is the point at which the green building system requires measured indoor air results from buildings that already exist. It names the categories of building that must apply testing, sets a parameter list broader than the one carried by the Municipality's indoor air tables, distinguishes between values expressed as eight-hour time-weighted averages and counts that are not time-weighted at all, and attaches a retesting interval. It is also the page of UAE indoor air compliance where the figure 0.08 ppm on an eight-hour basis is correct, which makes precision about attribution unusually important here. This page sets out the clause, its categories, its parameters and their bases, and the interval that follows a compliant result.

The listed categories

Clause 401.07 requires listed categories of existing building to apply testing. The categories are hotels, shopping malls, educational facilities, government buildings, healthcare facilities, mosques and worship buildings, theatres, and cinemas.

The list is a list of categories rather than a threshold of size, occupancy or age, so the question for an owner is one of classification rather than of measurement. A building that falls into one of the named categories is reached by the clause; a building that does not is not reached by it, whatever its floor area or occupant load.

The presence of healthcare facilities in the list is worth noting alongside the separate Municipality guideline, whose scope excludes premises exclusively dedicated to industrial and medical sectors, giving hospitals and factories as examples. Exclusion from one instrument does not produce exclusion from the other, and the two scopes must be read independently.

Parameters and their bases

Clause 401.07 sets formaldehyde below 0.08 ppm as an 8-hour time-weighted average, TVOC below 300 micrograms per cubic metre as an 8-hour time-weighted average, carbon dioxide below 800 ppm as an 8-hour time-weighted average, carbon monoxide below 9 ppm as an 8-hour time-weighted average, ozone below 0.06 ppm as an 8-hour time-weighted average, and respirable dust below 150 micrograms per cubic metre as an 8-hour time-weighted average.

Respirable dust is a parameter the Municipality's indoor air tables do not carry, so a survey designed only against those tables does not produce a result capable of answering the clause 401.07 list in full.

The values are expressed as limits to be sat below rather than as targets, and each is tied to the eight-hour time-weighted basis. A spot reading, however low, is not an eight-hour time-weighted average, and reporting one against these entries misdescribes what has been measured.

The microbiological counts are not time-weighted

Clause 401.07 also sets bacteria and fungi each below 500 CFU per cubic metre. Those two figures are per-sample counts and are not time-weighted, which places them outside the logic that governs the rest of the parameter list.

The practical consequence is that a report cannot carry a single heading describing the whole exercise as eight-hour time-weighted. Six parameters are eight-hour time-weighted averages and two are per-sample counts, and a report that flattens the distinction has misdescribed two of its eight results.

The presence of microbiological counts in the clause does not turn the exercise into a biological contamination investigation. Mould, damp and biological contamination as subjects, together with their causes and remedies, are covered by separate references; clause 401.07 supplies only the per-sample threshold against which counts are read.

The five-year interval

Clause 401.07 requires retesting within 5 years of the last compliant test. The interval runs from a compliant result rather than from the date of any survey, so a non-compliant result does not start the clock.

The interval belongs to Al Sa'fat alone. No validity period or retest interval is published for the Dubai Municipality certificate, and the five-year figure that circulates in UAE indoor air discussion is regularly and incorrectly transposed onto that certificate. It is an Al Sa'fat interval and describes only the Al Sa'fat obligation for listed categories of existing building.

Because the interval attaches to the last compliant test, the record that matters is the record of compliance rather than the record of activity. A building that has tested repeatedly without a compliant result has no interval running.

Formaldehyde attribution

This clause is the source of the correct eight-hour 0.08 ppm formaldehyde figure in Dubai, and it is the reason the figure is so frequently misattributed.

The same number appears under both instruments on different bases. Dubai Municipality's eight-hour formaldehyde value is 0.01 ppm, and its 0.08 ppm figure is a thirty-minute short-term value. Al Sa'fat separately and correctly applies 0.08 ppm as an eight-hour time-weighted average. It is therefore incorrect to attribute 0.08 ppm over eight hours to Dubai Municipality.

A building in one of the clause 401.07 categories that is also an existing building for the purposes of the Municipality guideline is therefore assessed against two formaldehyde entries on two bases under the guideline, and against one entry on one basis under Al Sa'fat. Reporting a single formaldehyde number without stating which instrument and which basis it answers leaves the position unresolved under both.

Reading clause 401.07 with the rest of the system

Clause 401.07 does not stand alone inside Al Sa'fat. Clause 401.01 requires the latest edition of ASHRAE Standards 62.1, 62.2 and 170, with no edition year attached, and clause 401.02 requires return air filters of minimum MERV 8. Those are design and specification conditions rather than measured ones.

Clauses 404.01 and 404.02 require VOC content limits set by Dubai Municipality and certified by Dubai Central Laboratory, landing on standard DMS 0020:2016. Those are grams per litre limits on product composition, not airborne concentrations, so no averaging period applies to them and they are not answered by a clause 401.07 survey.

Al Sa'fat's tier structure also frames the clause. Dubai Municipality states that Al Sa'fat includes a set of mandatory requirements for all new buildings to obtain the Silver Sa'fa, with Golden and Platinum optional for higher performance, and that from 19 October 2020 Al Sa'fat replaced the Dubai Green Building Regulations and Specifications. Clause 401.07 addresses existing buildings in the listed categories rather than new construction.

Listed categories

Hotels, shopping malls, educational facilities, government buildings, healthcare facilities, mosques and worship buildings, theatres and cinemas.

Eight-hour parameters

Formaldehyde 0.08 ppm, TVOC 300 micrograms per cubic metre, carbon dioxide 800 ppm, carbon monoxide 9 ppm, ozone 0.06 ppm and respirable dust 150 micrograms per cubic metre, each as an 8-hour time-weighted average.

Per-sample counts

Bacteria and fungi each below 500 CFU per cubic metre as per-sample counts that are not time-weighted.

Retest interval

Retesting within 5 years of the last compliant test, an interval belonging to Al Sa'fat alone.

Status of the instrument

Al Sa'fat, the Dubai Green Building System, 2nd edition January 2023, requires at clause 401.07 that listed categories of existing building apply testing, setting six parameters as 8-hour time-weighted averages, bacteria and fungi as per-sample counts below 500 CFU per cubic metre that are not time-weighted, and retesting within 5 years of the last compliant test.

No validity period or retest interval is published for the Dubai Municipality certificate; the five-year interval is an Al Sa'fat interval only.

Which buildings must apply testing under clause 401.07?

The clause lists hotels, shopping malls, educational facilities, government buildings, healthcare facilities, mosques and worship buildings, theatres and cinemas. The trigger is category rather than size or occupancy, so classification of the building is the first question rather than any measurement of its floor area.

What are the clause 401.07 parameters?

Formaldehyde below 0.08 ppm, TVOC below 300 micrograms per cubic metre, carbon dioxide below 800 ppm, carbon monoxide below 9 ppm, ozone below 0.06 ppm and respirable dust below 150 micrograms per cubic metre, each as an 8-hour time-weighted average, together with bacteria and fungi each below 500 CFU per cubic metre as per-sample counts that are not time-weighted.

Is 0.08 ppm formaldehyde an eight-hour value?

Under Al Sa'fat clause 401.07 it is. The same number appears under both instruments on different bases. Dubai Municipality's eight-hour formaldehyde value is 0.01 ppm, and its 0.08 ppm figure is a thirty-minute short-term value. Al Sa'fat separately and correctly applies 0.08 ppm as an eight-hour time-weighted average. It is therefore incorrect to attribute 0.08 ppm over eight hours to Dubai Municipality.

When does the five-year interval start?

Clause 401.07 requires retesting within 5 years of the last compliant test, so the interval runs from a compliant result rather than from the date of any survey. A building with no compliant result has no interval running. The interval belongs to Al Sa'fat and does not attach to the Dubai Municipality certificate, for which no validity period or retest interval is published.