Health and Transparency in Product Declarations  

When selecting and specifying building materials, architects and interior designers need to rely on data from manufacturers regarding the make-up and performance of those materials. In order to verify product claims, independent testing or certification is required so the building owner has some basis to feel comfortable and protected in the selections being made. This type of process has been routine for decades related to things like fire safety, structural integrity, and worker safety. Another category of information is becoming common and in some cases being demanded related to building products of all types, namely the environmental impact of products and materials. The emerging use of standardized Environmental Product Declarations (EPDs) is quickly becoming the tool that can inform those who specify products on a range of environmental issues. This is fundamentally viewed as a good thing since it makes the manufacturing process and the true make-up of the product more transparent to everyone involved. However, there are still some limitations in the data made available through the criteria behind the EPDs or disclosed by some product manufacturers. Recognizing this, a movement has begun that looks deeper into the impacts of building products not only on the natural environment, but also on human health as well. In order to get the whole truth about the environmental and human health impacts of the products being specified, complete transparency in reporting is needed by industries and individual product manufacturers.

Defining Environmental Product Transparency

Ever since 1987 when the UN-sanctioned Brundtland Commission convened, Sustainable Development or “Sustainability” has been defined as the kind of development that meets the needs of the present without compromising the ability of future generations to meet their own needs. Needs have been broadly and variously defined, but the intent is to allow all generations, all social classes, and all geographic locations around the world not only to sustain themselves, but in fact to thrive.

Working from this point, different industries and organizations have used this concept of sustainability as an overarching motivation to move their individual areas of expertise forward.  In terms of the design and construction industry, this focus took shape in the early versions of green building rating systems such as the USGBC LEED® program. As these programs have incrementally evolved, Life Cycle Assessment (LCA) has become an agreed upon basis for measurement of the total sustainability impact of a building or its component parts. As the development and usage of LCA tools and computer software has matured, even the smallest of start-up companies and product manufacturers can now accurately assess their environmental and sustainability footprint. The key variable, of course, is how detailed and how complete an analysis should be performed?

There are certainly people in the design and construction industry who feel that some green building standards are the compromised result of pressure to reach consensus among diverse entities with differing interests. As such, a focus on selected “attributes” of materials and products rather than an assessment of the product as a whole has been blamed for manufacturers being able to “green-wash” their products over the past 20 years or so. Similarly, there is a concern that the emerging use of Environmental Product Declarations (EPDs) focuses on certain environmental impacts but stops short of being fully transparent in all areas particularly in terms of human health. Full transparency requires steps beyond the current EPD process. So, let’s begin with the basics of this overall process which includes each of the component parts discussed briefly below:

Life Cycle Assessment (LCA)

Properly performed, a life cycle assessment is an analysis of every phase of a product’s manufacturing process and usage over time. Typically, this includes these five basic phases:

• Extraction Phase: (sometimes called the “cradle”) A true life cycle starts with the extraction phase where the raw material(s) of the product are identified along with the means of extracting (e.g. mining) and transporting that material to a manufacturing site such as a factory.
• Manufacturing Phase: Next, the manufacturing phase is examined in terms of the processes and procedures needed to turn the raw materials into a finished product ready for delivery (when ready for delivery it is sometimes referred to as being at the “gate”).
• Construction Phase: The third phase is where design and construction professionals usually see the products, namely the construction phase where the products are transported from a factory to the jobsite and installed as part of the normal construction process.
• Use Phase: From there the product begins its useful service life or use phase as part of the building to the benefit of the building owner and users.
• End of Life Phase: (sometimes called the “grave”) At the end of its usefulness in the building, the product moves to its end of life phase where it needs to be removed and either reclaimed, repurposed, recycled, reused, or disposed of.

Assessing the issues and impacts across all five of these phases makes up a full life cycle assessment (sometimes called a full “cradle to grave” assessment) of a particular product or even a category of products and materials.

International Standards

The International Organization for Standardization (ISO) (www.iso.org) has become recognized around the world for establishing LCA standards and rules.  This organization, while an independent body, is actually a network of national standards organizations from many countries. In the United States, the American National Standards Institute (ANSI) is the member body that participates in and contributes to the standards that are promulgated under ISO. A process of global consensus is employed for these voluntary standards with the intentions of creating state-of-the-art specifications for products, services, and good practice, helping to make industries more efficient and effective, and helping to break down barriers to international trade. It is the ISO 14044 family of published standards that specifies requirements and provides guidelines for conducting a LCA. In much the same way that building products are tested by independent laboratories for any range of other characteristics, an ISO-compliant LCA is meant to be conducted by an independent third party following the requirements of the standard, thus ensuring unbiased results and confidence by end users of the results.

Product Category Rules (PCR)

A product category rule (PCR) is the standardized method for conducting and reporting the results of a life cycle assessment for a particular group (category) of products. The PCR ensures that all products in its defined category (e.g. concrete products, flooring products, etc.) are measured the same way in each of the five life cycle phases. It also assures that their environmental impacts are quantified in the same way so comparisons can be readily made between different manufactured products within the same category. The PCR defines the means for measuring and reporting out by requiring that the same functional unit of measure is used for all products within a category (e.g. impact per cubic yard of concrete, or per 100 square yards of a flooring, etc.). PCRs are developed using a consensus-based, collaborative, and fairly transparent process by industry experts and stakeholders, following certain ISO guidelines. They are then verified by an expert review panel. At present, however, there are only a limited, but steadily growing number of fully developed PCRs, although more are being developed each year.

Environmental Product Declaration (EPD)

An environmental product declaration (EPD) is a document created by a manufacturer to show the results of the life cycle assessment performed on its product(s) in accordance with ISO standards. Where appropriate, the relevant Product Category Rule should be used to conduct the LCA and the completed Environmental Product Declaration should reflect that. Before being published, the EPD needs to be verified and approved by an independent entity such as UL Environment (ULE) or the Institute for Market Transformation to Sustainability (MTS). The fully vetted EPDs thus enable everyone involved to make accurate direct comparisons of the environmental strengths and weaknesses of similar products, thus providing a degree of transparency in terms of the environmental impacts of using different building products. Many in the green products industry regard the EPD to be a standardized tool used to communicate the environmental performance of a product. It works in the same way that a nutrition label on a food product informs us about the fat, sugar and cholesterol in the foods we eat. Only in this case, it is an environmental impact label informing us about energy, pollution, and resource depletion contained in the products that we select and specify.

Impact Categories

While the information contained in EPDs is clearly useful and desirable, it should be recognized that it is limited to the specific environmental impacts assessed. These environmental impacts are typically organized into different categories to describe the specific impacts during a product’s life cycle (or individual phases) on specific areas of concern. The ISO standard requires that a minimum number of specific environmental impact categories must be measured and included in the LCA. Where applicable, PCRs further define which impact categories must be reported in each EPD. Of course, EPDs can always report more impact categories than required by the PCR. Environmental impact categories generally include, but are not limited to, such things as:

• Resource Depletion (Biotic/Abiotic) —the consumption of non-renewable resources including those used for energy (oil, gas, coal, metals, etc.)
• Acidification potential—the potential for the product to contribute to acid rain
• Eutrophication potential—the product’s contribution to water or soil nutrients that cause algal blooms
• Global Warming potential—emissions of carbon dioxide or methane that affect the earth’s atmosphere

• Ozone Layer Depletion potential—the reduction in beneficial environmental ozone caused by chlorofluorocarbon emissions
• PhotochemicalOzone Creation potential—contributions to smog caused by hydrocarbon emissions

It is important to recognize that all of the parts of the process as discussed above are inherently tied together. Product category rules (PCRs) for a specific product type or category are developed following the guidelines authored by ISO. A life cycle assessment (LCA) is then performed by an independent entity for a specific product or material according to the PCR and the specific minimum impact categories that indicates must be measured and accounted for. The results of the LCA are then used to publish an environmental product declaration (EPD) that comes from the manufacturer. When architects, engineers, or others request this EPD, then, it is a representation that the proper process has been followed to produce it. It is the EPD that ultimately is used by the design team to assess different products and materials for sustainability and to provide documentation for green building certification programs.

Defining Product Toxicity

In order for a building product and its life cycle impacts to be completely transparent, additional information is needed beyond the basic information provided in EPDs. The missing item in the process so far has been toxicity, that is, the presence of substances that can poison or create toxic conditions. Those substances come from the various ingredients, minerals, compounds, etc. that are included in or are the result of creating a building product.

 

The concern over these ingredients is seen in two areas:

• Eco-toxicity is the potential or biological, chemical or physical stressors to adversely affect ecosystems. There are plenty of examples over the past 100 years or more of a product manufacturer polluting the air, water, or soil to the point that animals, birds, fish, or vegetation were destroyed due to the toxic nature of the pollution. Of course, it is important to recognize that products can contribute to eco-toxicity during several or even all phases of their life cycle. Extracting raw material in a manner that kills off parts of an ecosystem immediately or over time have been seen in many products that are mined or harvested. Manufacturing plants that use industrial process to create products sometimes also create toxic by-products or emissions that can damage or kill living things of all types. And the disposal of some products has led to landfills or incinerators producing toxic air or liquids emanating from them. This recognition of toxicity is a significant environmental impact, but not all PCRs or EPDs fully address the toxic potential to the environment over the life cycle of their products.
• Human Toxicity is the likelihood of an environmental toxicant to have an adverse effect on human health. In essence it talks about the ability of a product, its component materials, or its byproducts to be toxic (i.e. poisonous) to people. Unfortunately, the construction industry can point to plenty of instances where some rather mainstream and standard materials proved to be detrimental to people. Products that contained asbestos, lead, and urea-formaldehyde garnered a lot of public attention and many companies are still paying the astronomical costs of abatement and legal liability from the real or threatened human harm that occurred. The business consequences were disastrous for the product manufacturers and the consequences were equally staggering for the architects, specifiers and building owners who unwittingly put these toxic products to use. In recognition of these past issues and in the interest of avoiding such issues in the future, green building rating systems began to address indoor environmental quality (IEQ). This is definitely a step in the right direction and limits the use of particular chemicals such as urea-formaldehyde and VOCs in building products. However, there are plenty of other chemicals, compounds, and by-products that can be harmful or toxic to people over the life cycle of the manufactured products. It should also be noted that the concern here has often been the exposure to people during the building use phase but the reality is that people can be exposed throughout the full life cycle of the product.


All building products are made up of selected and necessary ingredients, some of which have raised concerns over their toxicity to the environment, people, or both.

Photo courtesy of Forbo Flooring Systems

Architects and interior designers have been aware of the need to address human toxicity in the built environment for some time. Diane Brandli, ASID, CID, LEED AP is principal of dbdesign, a sustainability & interiors consulting firm in upstate New York. She has undertaken to independently research and investigate building products in depth and look at the substance behind different product certifications. She notes that “There are specific means by which human health is affected by building products. For example the very act of inhaling in an indoor environment containing volatile organic compounds (VOCs) exposes our airways and lungs to potentially serious harm.” What if we are eating in a space that has toxic materials in it? Diane warns that “ingestion of toxic dust particles is entirely possible when people are exposed to materials that contain toxins.” But we don’t need to inhale or ingest to be affected. “Dermal Exposure, which is toxic components absorbed through the skin, can come about just by being in contact with surfaces, furnishings, or finishes.” She also points out that “human health reaction can be immediate (allergic) or long term (persistent bioaccumulative toxins or PBTs.)  The long term effects are the most insidious.” Given all of the potential ways that people can be affected, it is clear that addressing human toxicity is not only the right thing to do from a health, safety, and welfare perspective, it is paramount to protecting life.

Ecotoxicity and human toxicity are broad and complex issues. They aren’t always easy to categorize or inexpensive to quantify. For these reasons, it is tempting to simply deny or ignore them. Unfortunately, denial and ignorance can sometimes seem to be a fairly effective marketing strategy but the evidence of history proves otherwise.

Green Product Certifications and Product Transparency

The growing availability and use of LCAs and EPDs as a means to assess and compare different materials and products for green buildings has led to their growing recognition and use in different green building and product certifications. These certifications set a performance standard and act as a benchmark for what acceptable or preferred levels should be sought in regards to environmental impacts. A summary of those certifications follows below:

 

SMaRT Sustainable Product Certification

Beyond conducting LCAs solely according to the ISO standard, a more stringent product certification program has been developed in this country known as the Sustainable Materials Rating Technology (SMaRT©) Consensus Sustainable Product Standard©. This ANSI standard acts as a PCR to define a category of exemplary certified sustainable products. It was developed by the Institute for Market Transformation to Sustainability (MTS) and uses environmental, social, & economic criteria applied to manufactured products. (http://mts.sustainableproducts.com)  To achieve SMaRT© certification, an ISO-compliant life cycle analysis is performed but some impact categories above and beyond those required by ISO must also be included, mostly related to human health and toxicity of materials used. Once complete, the LCA results are used together with other rating criteria to generate a LEED-style certification that is based on earning points in 6 categories:

• Safe for Public Health & Environment (PHE)
• Renewable Energy & Energy Reduction (RE&ER)
• Biobased or Recycled Materials (MATLS)
• Facility or Company Based MFG)
• Reclamation, Sustainable Reuse & End of Life Management (EOL)
• Innovation in Manufacturing (IM)

Depending on the number of points received out of the 173 total that are possible, a product can be certified as follows:

Sustainable:	28-40 points
Sustainable Silver:	41-60 points
Sustainable Gold:	61-89 points
Sustainable Platinum:	90-173 points

Note that this is a consensus-based certification that has been developed by industry experts and thought leaders. It requires environmental excellence in a variety of impact categories that go beyond those required by ISO. For example, no Stockholm Chemical Persistent Organic Pollutants are allowed (CFCs, pesticides, etc.). In addition to a full LCA, it also requires an energy inventory, manufacturer social indicator reporting, and indications on product durability.

Under the SMaRT program, EPDs alone are not a statement of environmental superiority. Instead they are statements of transparency that show quantification of the environmental impacts of a product. SMaRT Certification is, however, recognized as a statement of environmental superiority due to its extremely rigorous and comprehensive requirements. In serving as a general-purpose PCR, it also defines how products can be classified and reported under an EPD:

• Type I: Environmentally preferable product—product environmental superiority
• Type III: ISO-compliant LCA EPD—product transparency

LEED 2009

The concept of using LCAs and EPDs has already been a part of the LEED® rating system as developed by the U.S. Green Building Council (USGBC). In the current version of LEED 2009 in the Materials and Resources (MR) category, pilot credits have been available for use of an EPD in at least 20 permanently installed products in a building. This pilot credit has required at least a partial LCA (cradle-to-gate) scope and allows the use of product-specific or industry-wide (generic) declarations. It also requires that the 20 products be sourced from at least five different manufacturers.

In addition to this pilot MR credit, Innovation in Design (ID) credits have been made available for using products with a SMaRT Certification. A Credit Interpretation Request (CIR) has been issued in regards to the SMaRT Certification, and the determination has been made by USGBC that since the certification “encourages innovation through product improvement” it is acceptable for an innovation credit provided proper documentation is provided in the LEED application. That documentation needs to show that the percentage of SMaRT certified materials must equal at least 2.5 percent of the total materials cost. The contribution to the cost analysis depends on the level of certification, with Platinum projects counting double, silver half and gold 100 percent.

LEED® v4

The fourth version of LEED® has been in development for several years and is anticipated to be released sometime during 2013. The Materials and Resources (MR) section is proposed to have substantial revisions such that points previously available for regional materials and recycled content are being rolled into the points available for LCAs and EPDs. Happily, the USGBC is not asking project design teams to conduct LCAs or to become LCA experts. Instead, the project team will be able to request an EPD (or perhaps another approved form of reporting) that discloses the required LCA-based information. In essence, LEED® version 4 will ask product manufacturers to gather the life cycle information on their products and to disclose relevant portions of that information in the standard EPD format. This affects four out of the five MR credits beyond the prerequisites and can earn up to 11 points in the process. In addition to earning points in this revamped MR section of LEED v. 4, an Innovation in Design credit remains available for use of products with SMaRT Certification.

Health Product Declarations

As the previous discussion points out, there is clearly growing recognition and use of EPDs for addressing the environmental impact of building products and materials. Still missing, though, is the attention needed to ecotoxicity and human toxicity in those products. In response, a group of leading architects, building managers and product manufacturers have banded together to create a whole new standard for product hazard reporting that responds more responsibly to concerns of human health and environmental toxicity. The new standard is called the Health Product Declaration (HPD), and it represents a major step forward in product transparency. HPDs build on and incorporate the data from the EPD but goes on to combine it with trustworthy and verifiable measures of ingredients that impact ecotoxicity and human toxicity.

 

As such, it creates a disclosure document that truthfully indicates the toxicity impact of a product on the people who live with it, and the natural environment that it exists within. As envisioned, the HPD will create a single standard that can be used to create an apples-to-apples comparison of products based on their ingredients.

The true beauty of the HPD is its ability to be impartial, while also addressing industry concerns about the fairness of standards. To remain objective, HPDs use an open-source approach to deciding which criteria are included, placing decision making power in the hands of architects, specifiers and others without a vested interest in the outcome, hence no individual can unduly influence it. On the one hand radical environmentalists cannot unduly sway the standard but neither can industry insiders with a status quo to protect. All professionals can have input in shaping the standard to keep it practical and fair. Admittedly, it is difficult to measure the absolute potential for future toxicity without a crystal ball. But if judgments must be made, it is a far better idea to have everyone in the product safety equation at the table sharing all the information available. It is far better for human health and our natural environment as well.

Health Product Declaration Collaborative™

HPDs are an emergent new tool in the quest for greater product transparency - the pilot program was announced at the USGBC GreenBuild convention in 2012. They have come about from a group known as the Health Product Declaration Collaborative TM (HPDC). This is an independent organization for companies and individuals committed to the continuous improvement of the building industry’s environmental and health performance, through transparency and innovation in the building product supply chain. They have created the HPD Open Standard which may be used free of charge - no copyright applies for this purpose. However, sharing the HPD Open Standard, whether in-part or in its entirety, must be accompanied by attribution to the Health Product Declaration Collaborative.

The HPDC operates on the premise that designers, specifiers, and owners that have been frustrated by a lack of an industry accepted standard definition for what constitutes disclosure of a product’s ingredients will appreciate the clear definitions provided in the HPD Open Standard.

 

It also accommodates differences in the ability and readiness of manufacturers to disclose highly variable contents in many diverse products. It facilitates apples-to-apples comparisons and clear discussions about product formulations: between and among manufacturers; their customers and their suppliers; product certifiers; and building standards organizations.

The HPDC points out that manufacturers that are ready and able to provide a complete accounting of their product contents and hazards will find the HPD an excellent vehicle for full disclosure. Any manufacturers facing challenges with intellectual property and supply chain communication gaps can also use the HPD to better characterize the level of disclosure they can accomplish. The HPD is intended to facilitate clear communication among all players in the building industry regardless of their position on the spectrum of disclosure and transparency.

The HPD Standard itself is broken into sections to ease the documentation process for product manufacturers. Individuals within the manufacturing company are asked to follow seven distinct steps:

• Identify: Fill out manufacturer information and product description on the HPD forms.
• Inventory: Collect the documentation and list all product contents.
• Assess: Review contents against authoritative chemical Hazard Lists.
• Compliance: Provide the details of product testing and demonstrate compliance.
• Accessories: Note the installation, maintenance, cleaning, and operations materials needed for the product to function.
• Summarize: Confirm the information on a summary page, fill in explanatory notes & identify a release date.
• Publish: Share the final HPD with customers, designers, owners, etc.

The Healthy Building Network

The HPDC is led by an organization that was founded in 2000 known as the Healthy Building Network (HBN). This group of leaders from the national environmental health movement recognized the many opportunities for change in the building materials market. For example, until 2004, pressure-treated wood was the most common source of arsenic exposure to children and adults in the United States. Due to loopholes in waste disposal laws, arsenic leaching from the wood in landfills was (and remains) was implicated in groundwater contamination. Another common building material, polyvinyl chloride plastic, also known as PVC or vinyl, is estimated to be the single largest material source of dioxin to the global environment over the course of its life cycle, production, use and disposal. The HBN contends that substituting cost-effective, healthier building materials for these products is the single most effective step we can take to preserve and regenerate our environment, and to protect public health.

The Healthy Building Network is also very committed to the goal of achieving environmental justice. They cite studies in the United States that have repeatedly demonstrated that poor communities and communities of color suffer disproportionate environmental and health impacts associated with heavy industry and waste facilities. Internationally, the globalized economy has been shown to often inflict environmental and human health consequences upon indigenous peoples living far from the site of industrial activity. For example, Inuit women living subsistence lifestyles in far northern Canada have higher concentrations of industrial chemicals in their breast milk than any other community of women on Earth. For these holistic reasons, the Healthy Building Network employs comprehensive lifecycle thinking when evaluating green building materials, mindful of David Orr’s observation that "Nothing is beautiful that causes ugliness in any other place or at any other time in the world."

Since their founding HBN projects have directly resulted in the introduction of new, healthier building materials into commercial markets, shifting over $4 billion in materials purchases from toxic materials to healthier alternatives that are comparable in both price and performance to the materials they have replaced. They played a key role in establishing precedent-setting Green Building Guidelines for Health Care Facilities that became the basis for LEED for Healthcare.

 

They have also been involved in demonstrating well-built, healthy and green modular homes to the affordable housing market in the Gulf States region.

With all of the above background and support, the HBN has developed the first, on-line evaluation tool for building materials known as The Pharos Project. At its core, this is a tool for users to locate the best materials to meet their current needs for transparency in building materials and products. It is a tool to help cut through “green-washing” and identify the realities about what makes a product truly green. It is also a platform from which to show manufacturers what constitutes a market in support of the best environmental, health and social equity practices. It is a fee based program but open to all and includes

• Building product library: Transparent and in-depth information about what's really in building products, with comparative scores on environmental and health impacts
• Chemical and material library: Over 20,000 chemicals and bio-based materials with health and environmental hazards have been screened from over 40 authoritative lists
• Certifications and Scoring: Transparent scoring protocols for environmental and health impacts of building products are linked to a library of over 150 certifications

As a result of the combined, collaborative work of the HBN and the HPDC, the tools and information needed for making truly informed decisions about building products and materials is now more available than ever before. This is good news for all of us interested in creating buildings that are truly healthy, green, and sustainable in all aspects.

Conclusion

When specifying building materials, it is now entirely possible to ask for full transparency and demand the submittal of both Environmental Product Declarations and the Health Product Declarations. If that request isn’t met, then it is reasonable to ask why. Since owners or lessors of buildings can make product transparency and toxicity a criterion in purchasing or leasing decisions it may be incumbent on specifiers to follow through on these requests.

Ultimately, ask the tough questions on every design project before making a decision on a material and be willing to consider all the ways it could contribute to a healthy environment. Some of those questions can now include:
• Is it sourced from sustainable materials?
• Is it designed to minimize construction waste?
• Does it emit compounds that might impact human health?
• Are excessive amounts of energy or scarce raw materials used in its creation?
• Can it be safely removed and naturally recycled at the end of its working life?
• Will its performance attributes contribute to a more energy efficient, healthy living space?
• Is it a truly sustainable product, or a product with sustainable attributes?

The information in the EPDs and HPDs will answer these questions and allow a final determination on which products to accept as suitable for building projects of all types.

Peter J. Arsenault, FAIA, NCARB, LEED AP practices, consults, presents, and writes about sustainable design topics nationwide. www.linkedin.com/in/pjaarch

Forbo Flooring Systems has been creating better environments with its beautiful, durable flooring products for over 100 years. Forbo is committed to complete transparency in its products and the industry, and recently released a full and transparent Health Product Declaration (HPD) going beyond the industry standard EPD to include a product's impact on human health and ecotoxicity. www.forboflooringna.com