GSA's New Carbon Standards Add Requirements for Contractors

On March 30, the U.S. General Services Administration (GSA) issued new carbon standards under its Facilities Standards for the Public Buildings Service (P-100) to require the use of lower carbon concrete products and asphalt paving practices for all GSA design and construction contracts that involve at least 10 cubic yards of those materials. The general contractor now must source concrete that meet specific carbon requirements; collect and maintain documentation associated with both materials; and, in the case of asphalt, employ carbon reduction practices such as recycled content or reduced mix temperatures.

These requirements must be included in the scopes of work for all new projects effective March 17, 2022.  If the contractor is not able to meet the new requirements, they must request a P-100 waiver for each mix.  The standard does not require the contractor to source outside the maximum transport range for the mix design.  However, the contractor will need to provide alternative strategies to reduce global warming potential (GWP) for concrete waiver requests.  The contractor also will need to include GWP estimates for each approved waiver (applies to concrete and asphalt).

The new carbon standards are available on GSA’s website

For more information, contact Melinda Tomaino at or Jordan Howard at

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