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Continuing Education Unit - Sponsored by Interface

Environmental Product Declarations

As demand for environmental transparency grows, EPDs increasingly inform product purchasing and decision making.

August 8, 2012
Trans

LEARNING OBJECTIVES

  • After reading this article, you will be able to:
  • Identify the global demand for Environmental Product Declarations (EPDs) in the building industry
  • Understand how transparency and life-cycle assessment help shape EPDs
  • Explain the importance of Product Category Rules (PCRs) in EPD development
  • Assess the limitations of EPDs and benefits for making smarter product selection decisions

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What is a product’s carbon footprint? To what extent did the product’s raw materials extraction affect the ecosystem? Does the product present a human toxicity risk? Can the product be reused, repurposed or recycled at the end of its useful life?

Environmental transparency is not only emerging as a key competitive differentiator in the building industry, it’s also increasingly becoming a requirement as purchasers call for environmental impact information that reflects a product’s entire life cycle. Such information is not always easy to acquire, however. The green marketplace can be a confusing place, and manufacturers often don’t know where or how to even start communicating their products’ environmental impacts. Promotional materials may overstate environmental claims without providing reliable evidence.

For architects, designers and other professionals in the green building industry, environmental product declarations (EPDs) are becoming the transparency tool of choice. Similar to the concept of a nutrition label on a food product, an EPD breaks down the environmental impacts of a product in a single, written report. EPDs empower buyers and specifiers to make informed purchasing decisions based on the environmental, health and performance impacts of multiple products within a given product category. 

What is an EPD?
An EPD is a tool that:

  • Offers manufacturers a standardized approach for assessing the environmental impact of their products
  • Provides buyers with an effective framework for making informed product comparisons

The similarities between EPDs and life-cycle assessments (LCAs) can be confusing. One of the requirements of an EPD is that it be based on the information reporting guidelines defined in a product category rule (PCR). The creator of an LCA is not required to use a PCR.

EPDs can be created for all types of products and services — from building materials to furniture and electronic equipment — and typically include information on the following impacts:

  • A product’s carbon footprint
  • Water and energy consumption
  • Climate change: long-term changes in global weather patterns — including temperature, precipitation and cloud coverage — that are caused by increased concentrations of greenhouse gases in the atmosphere
  • Waste generation
  • Acidification of land and water: the result of human-made emissions and refers to the decrease in pH and increase in acidity of oceans, lakes, rivers and streams — a phenomenon that pollutes groundwater and harms aquatic life
  • Photochemical ozone creation: happens when sunlight reacts with hydrocarbons, nitrogen oxides and volatile organic compounds to produce a type of air pollution known as smog
  • Eutrophication: occurs when excessive nutrients spawn increased algae growth in lakes blocking the underwater penetration of sunlight needed to produce oxygen and resulting in the loss of aquatic life
  • Ozone depletion: the destruction of the stratospheric ozone layer, which shields the earth from ultraviolet radiation that’s harmful to life, caused by human-made air pollution
  • Abiotic resource depletion/elements: the reduction of available non-renewable resources, such as metals and gases that are found on the periodic table of elements, due to human activity
  • Abiotic resource depletion/fossil fuels: the decreasing availability of non-renewable carbon-based compounds, such as oil and coal, due to human activity

EPDs can also include other impacts, such as human toxicity risk and corporate social responsibility.

Where do EPDs fit in the world of eco-labels? An EPD is a Type III eco-label, as defined under ISO 14025. Type III eco-labels:

  • Are summary documents containing both quantitative and qualitative information
  • Provide specific information about a product’s life-cycle-based environmental impact by category (e.g., climate change)
  • Require validation by an independent party (such as UL Environment)

This is in contrast to Type II labels that contain manufacturers’ self-declared environmental claims, or Type I labels, which verify compliance with a specific, multi-attribute environmental standard. EPDs are developed voluntarily by manufacturers, but they are required to be validated by an independent party and certified to the ISO 14025 standard. It is this independent validation and ISO 14025 that distinguishes EPDs from other environmental labels and documents.

Why are EPDs Important?
Research conducted by an independent third party for UL Environment in October 2010 found that more than 90 percent of architects and building designers surveyed have researched, specified or purchased so-called green products during the past year.

This evidence points to buyers’ increasing desire to know a product’s cradle-to-grave environmental and health impacts. They want environmentally preferable products.

Without environmental disclosure that is transparent, science-based and independently verified, however, it’s difficult for architects and designers to accurately compare the environmental impacts of one product versus another. The prevalence of unsubstantiated and sometimes misleading environmental claims poses a challenge to effective product evaluation. Another challenge is that a product can have some valid environmental claims (energy savings or sustainable materials, for example) but still have a negative environmental impact overall when the product’s complete life cycle is considered.

EPDs are also an important element in the overall effort to reduce environmentally damaging production practices and preserve the availability of important natural resources. EPDs help achieve these goals as:

  • Management tools that monitor product environmental data to improve product environmental performance
  • Communication tools that provide unbiased environmental impact information to enhance overall awareness of that product’s impacts across its life cycle
  • Evaluation and assessment tools for benchmarking environmental information and for evaluating and making product selection decisions
  • Procurement tools that help achieve government, institutional and corporate environmental objectives
  • Action tools that disseminate product environmental information to the public and  identify concerns about efforts to improve product environmental sustainability

How to Tell Whether a Document is a Real EPD
Just because a document contains environmental information doesn’t make it an EPD.

To identify a true EPD, look for the following on the document:

  • Text or ULE Mark indicating ISO 14025 compliance
  • A certification mark from a credible third party
  • An inside cover with signatures from the certifying third-party organization
  • The product category rule (PCR) referenced in the EPD

This last item, the PCR, is particularly important. It is the use of product category rules that distinguishes EPDs from life-cycle assessments. A PCR defines the information that must be reported about products in a specific category (such as paints, cement, textiles, wood, furniture, etc.). These standardized reporting rules create the structured framework necessary for developing an EPD. They also allow for life-cycle assessment comparability between products in a category — for an LCA to be used in an EPD, it must meet the reporting requirements defined in the appropriate PCR.

If you are reading a document that is missing any of the above four items, you are not looking at an EPD. A specifier can also visit a program operator’s website and look for the EPD in the operator’s online database. 

How is an EPD Different from an LCA?
A life-cycle assessment (LCA) is an essential component of an EPD, but many people confuse the two. An LCA is the “data foundation” upon which an EPD is built. It evaluates a product’s environmental impact from cradle to gate or grave (depending on the PCR’s requirements) — from material and component sourcing through final disposal or recycling. An LCA thus provides a comprehensive picture of how much energy, water and materials are consumed in the production and use of a product.

Here are the key differences between LCAs and EPDs that specifiers should be aware of:

  • Unlike EPDs, the creation of an LCA is not governed by a standard set of product category rules.  LCA methodologies can vary from product to product, and manufacturer to manufacturer.
  • LCAs were designed to give manufacturers insights into their supply and production chains. They were not designed to help buyers compare multiple products within a category.

How Buyers Use EPDs
In today’s competitive marketplace for environmentally sustainable solutions, EPDs benefit both manufacturers and buyers. EPD-backed products help buyers make objective and informed purchasing decisions by disclosing the environmental impact of products. Manufacturers who offer EPD-backed products can gain important competitive advantages against producers who lack transparent documentation of their products’ environmental impacts.

It is important to note, however, that an EPD is not a product endorsement. It does not evaluate or verify a product’s performance, nor is it a “green label.” The existence of an EPD does not guarantee that a product is environmentally friendly. An EPD simply details a product’s environmental impacts — good, bad or mixed. 

When evaluating a product, purchasers need to read the EPD thoroughly to learn what it says about the environmental impacts of the product and whether they are positive or negative. In addition, an EPD should always be examined in conjunction with other third-party, performance-based certifications — such as Type I eco-labels, like EcoLogic, NSF and Green Seal, or a leadership-based single-attribute certification such as GREENGUARD Indoor Air Quality/Children & Schools Certification. Together, these tools give buyers a more complete picture of a product’s environmental attributes and performance. 

What is Driving Demand for EPDs?
There are four primary factors increasing the adoption of EPDs.

1. International adoption

EPDs are already widely used in other industrialized countries, mostly in the E.U. and Japan. In France, for example, the government-backed Environment Round Table (Le Grenelle Environnement) has proposed that all high-volume consumer products imported into the country be accompanied by an EPD. In the United Kingdom, the Building Research Establishment Environmental Assessment Methodology (BREEAM) encourages the use of EPDs as a guidance tool to help licensed assessors select green building products. In Abu Dhabi, a large-scale eco-city project — Masdar City — is encouraging the use of EPDs and LCAs to evaluate products used in its construction.

2. Growing interest by the U.S. government

Recent efforts by both government and industry in the U.S. point to the expanded use of EPDs here. Although neither federal nor state regulators require EPDs, purchasing mandates may create de facto requirements for manufacturers and producers. For example, Executive Order 13514 — issued by President Obama in October 2009 — requires U.S. federal agencies to “leverage federal purchasing power to promote environmentally responsible products and technologies.” It is expected that the General Services Administration (GSA) will incorporate compliance with standards for sustainability and EPDs as a factor in government purchasing decisions in 2012 or 2013. With annual expenditures approaching nearly $6 trillion annually, such a move by the U.S. government could very well speed the acceptance and use of EPDs by private industry.

3. Industry initiatives

Even in the absence of national regulations, the use of EPDs is often driven by initiatives within individual industries. For example, the U.S. Green Building Council (USGBC) has contributed to the increased interest in the use of EPDs in the U.S. building industry through a pilot credit, Pilot Credit 61, proposed under its Leadership in Energy and Environmental Design (LEED) program. In the latest draft release of LEED v.4, the proposed Assessment and Optimization Pilot Credit 61 rewards products with EPDs. If the credit ends up being adopted, it is expected that this will lead to the global adoption of the credit through the more than 50 national green building councils that make up the World Green Building Council.

4. Buyer demand for transparent environmental data

The current primary driver for EPD use in the U.S. lies with buyers who are increasingly demanding transparent data that support manufacturers’ environmental claims. Indeed, shifts in market demand are likely to occur much more quickly and with less advanced notice than formal regulations.

How is an EPD Developed?
EPDs are developed voluntarily by manufacturers, but there is a required process that must be followed. Five steps are involved in the creation of an EPD:

1. Available product category rules (PCRs) identified or new PCRs created
2. Life-cycle analysis (LCA) conducted and verified
3. EPD compilation
4. EPD verification
5. EPD registration

Here is a brief explanation of each of the five steps:

Step 1: Product category rule (PCR) identified

The product category rule is the first step in the EPD development process. There are five important things to know about this essential EPD component:

  • PCRs are created for specific categories of products — such as paints, cement, textiles, wood, etc.
  • PCRs define the information that must be reported about a product category
  • These reporting rules apply to all manufacturers in a given product category
  • PCRs are created in conjunction with a stakeholder group, which includes manufacturers, NGOs, government agencies and others
  • After a PCR is created and published, it is an open-source document that anyone can use

 

The PCR is the cornerstone for the rest of the EPD development process. Under the requirements of ISO 14025, an existing PCR must be used whenever a suitable one is already available. The intent of these requirements is to facilitate the global harmonization of PCRs, eliminate duplication of effort and ensure that EPDs produced within the same category use the same PCR. Requiring all EPDs within a given product category to follow the same reporting rules is what allows the EPDs to be compared. Program operators involved in the creation of PCRs are encouraged to maintain publicly available lists of the PCRs they create.

What if no appropriate PCR exists? Then a new PCR must be developed and approved for use through a credible EPD program operator. (See sidebar, “How New PCRs are Developed.”)

Step 2: Life-cycle assessment (LCA) conducted and verified

An LCA provides a structure for identifying and assessing a product’s potential environmental impacts. An LCA typically considers the following factors:

  • Energy and resource consumption
  • Waste generation
  • Pollutant emissions
  • Impacts during use
  • End-of-life considerations

For an LCA to be used in an EPD, it must meet the reporting requirements defined in the appropriate PCR. These requirements ensure all EPDs are based on standardized information. Once an LCA is conducted on a particular product, it must be verified by an independent party to determine that it meets the PCR’s requirements. Manufacturers often work with a consulting company to complete this step.

Step 3: EPD compiled

After the applicable PCR has been identified (or developed) and an LCA completed and verified, the actual EPD can be prepared. The EPD presents the results of the LCA, as well as additional information about the product’s performance and other sustainability information.

Step 4:  EPD verified

When an EPD has been completed, the manufacturer must submit it to an independent third party for a thorough review and verification of the results presented and any additional information supplied. This step is normally conducted through an EPD program operator, such as UL Environment.

Step 5: EPD registered.

The final step in creating an ISO 14025-compliant EPD is the submission of the final document to an EPD program operator for registration and inclusion in the operator’s published list of EPDs.

Who is the EPD Program Operator?
According to ISO 14025 requirements, a program operator is responsible for administering the entire EPD program. As defined in ISO 14015, Section 8.0, the program operator’s responsibilities include:

  • Preparing, maintaining and communicating general program instructions
  • Publishing the names of entities involved as interested parties in program development
  • Ensuring that all environmental declaration requirements are followed
  • Establishing procedures to ensure the consistency of all collected data
  • Publishing PCR documents and Type III environmental declarations developed under the program and maintaining publicly available lists of those documents
  • Monitoring procedural changes in other environmental declaration programs and revising procedures and documentation as necessary
  • Selecting competent, independent verifiers and PCR review panels (according to 8.2.3 of the ISO standard) — See sidebar, “How new PCRs are Developed.”
  • Establishing a transparent process for PCR reviews, including the review scope and the composition of the PCR review panel (according to 8.1.2)

One of the program operator’s most important responsibilities is determining whether an existing PCR is sufficient for the assessment at hand or if a new PCR is required. In cases where a new PCR is required, the program operator should facilitate harmonization with similar documents by adopting content from existing PCRs in the same product category. For example, when UL Environment facilitated the creation of the PCR for building thermal envelope insulation, it ensured that the PCR was harmonized with an existing Norwegian PCR.

The new PCR should document what efforts were made to harmonize with existing PCRs, as well as the reasons for not adopting available PCR content.

The Future of EPDs
While one cannot predict when the U.S. will catch up to the E.U. and Japan in terms of EPD use, it is likely that buyer interest in environmental transparency will continue to grow. EPDs are useful and reliable tools for architects and designers to use when evaluating and better understanding the life-cycle-based environmental impacts of products. Companies that demonstrate leadership by adopting EPDs will drive other industry participants to embrace the process as a way to remain competitive.   

 


How New PCRs are Developed

ISO 14025 requires that an existing PCR be used whenever possible in the development of an EPD. But because there are relatively few publicly available PCRs, developing an EPD often requires the creation of a new PCR. These are the steps a program operator must undertake to create a new PCR:

Identifying the open consultation participants

PCRs are developed in an open and collaborative manner. Any interested party may participate in what’s known as an open consultation process. The open consultation process allows interested parties to review the draft PCR, ask questions and share comments electronically. Interested parties may include material suppliers, manufacturers, trade associations, purchasers, users, consumers, nongovernmental organizations, public agencies, LCA practitioners and certification bodies.

Inviting parties to take part in the open consultation

The program operator preparing a draft PCR is responsible for posting the draft document on a publicly accessible website and alerting interested parties to its availability for discussion and comment.

Addressing the comments received and modifying the draft PCR as necessary

Following changes or amendments to a draft PCR, a program operator submits a final version to a review panel for approval. According to ISO, the review panel must have, at a minimum, a chair and two members. The PCR document must include the result of the PCR review as well as the comments and recommendations made by the panel members. The program operator also prepares a short summary of the comments through the open consultation procedure and the resulting changes made to the draft document.


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