Green Star Performance Credit 9 (Exposure to Toxins) sits under the Healthy category of Green Star Performance. 

Up to three points are available with Credit 9. They build on each other:  

  1. The first covers your testing process, sampling and materials policy (“Credit Achievement”,1 point)
  2. The second is added when your air results come in below the limits (“High Performance”, 1 point) 
  3. The third when your water results also come in below the limits (“Exceptional Performance”, 1 point) 

To earn any of them, you need real air samples taken on site with occupants present. If your buildings are already in the NABERS program, and Indoor Environment is one of the Ratings you hold, there are pathways that simplify how you meet this credit. 

What the credit is about 

Credit 9 is about exposure to toxins: Limiting what occupants are exposed to in the spaces they regularly use, through both the air they breathe and the water they drink. 

On the air side, paints, carpets, adhesives, sealants and furniture all release chemical vapours, particularly when new. The credit focuses on formaldehyde and a broader group called volatile organic compounds, or VOCs.  

On water quality, the assessment covers heavy metals such as lead, nickel and copper, as well as chlorine levels and E. coli presence. 

The first point, Credit Achievement, asks for three things: 

A process for testing. A documented routine for checking air and water, logging the results, and acting on what they tell you. For buildings constructed before 2005, it also means reviewing whether any banned or highly toxic materials are still in place. 

Actual air samples. Real measurements taken in the building, with occupants present. 

A materials policy. A rule that when you buy paint, carpet, adhesive or sealant, you buy the low-toxin version, together with guidance for tenants carrying out their own fitouts. 

A second point is available where testing verifies low air toxin levels, and a third where testing verifies low levels in both air and water. 

Testing Method 

The three testing standards the credit names, ISO 16000-6, ASTM D5197 and EPA TO-17, are laboratory methods. Samples are collected on site, then sent away for analysis. 

GBCA’s October 2025 update opened an alternative. Handheld testing instruments may now be used on site in place of those laboratory methods, but the equipment used must meet the NABERS Indoor Environment requirements. 

NABERS Indoor Environment, or NABERS IE, is the government-backed rating that measures how healthy and comfortable a building is for the people in it. The current rules require assessments by a NABERS Accredited Assessor and set out detailed protocols for sampling, timing, documentation and equipment capability, including the range, resolution and accuracy each instrument must achieve. 

 GBCA has adopted these requirements as the qualifying criteria for the expedited testing pathway under Credit 9.  

In practice, this means the shortcut is available to organisations already operating to NABERS IE standards, rather than being achievable simply by purchasing a device off the shelf. 

Fast-tracking Credit 9 through your NABERS IE program 

If NABERS IE is already part of your portfolio program, the two frameworks can share the same work. Where a building holds a current NABERS IE Whole Building Rating that included TVOC and formaldehyde results meeting the thresholds, that testing can be used directly, provided the certificate has at least three months left to run at the time of submission. 

What this means for your portfolio 

Budget for it every year. Sampling for toxins is annual, as are the air and water toxin level criteria at the higher achievement levels. Credit 9 is an ongoing operational cost, not a one-off submission task. 

Sort out your fitout guidance now. The materials criterion asks you to provide guidance to tenants on their fitouts, not just to control your own procurement. Building low-toxin requirements into your standard Building Fitout Guide once is easier than raising them tenancy by tenancy. 

Check what your NABERS ratings already cover. If NABERS IE is already part of your portfolio program, some of what Credit 9 asks will already be done. 

How NettZero can help 

At NettZero, we have 8 NABERS IE Accredited Assessors on our team, including the senior expertise to conduct physical indoor air quality testing in-house using equipment that meets the NABERS IE standard. That is the same standard GBCA points to in its Credit 9 guidance. 

We also hold Green Star Accredited Professional capability, so we can tell you what your existing NABERS ratings already cover and what your Green Star submission still needs. 

If you are planning a Green Star Performance submission, or you hold NABERS IE ratings and want to know what they are worth under Credit 9, contact the NettZero team for a gap assessment.