This CE Center article is no longer eligible for receiving credits.
NOTE: LEED 2012 has not been finalized as of the date of this publication (November 2012). The second public comment period closed in September 2011, and a third public comment period is scheduled to open early in the first quarter of 2012.
From corporate America to the average household, the move to live and work more sustainably is on. But with all the environmental claims made by companies seeking to advance their products, businesses and consumers are at the mercy of competing claims of "green," "eco friendly," "environmentally sound," and the like. Amid the proliferation of eco-labels and green washing, the market is demanding greater transparency and reliable evidence of sustainability claims.
This article is a primer on the latest step in that direction: environmental product declarations (EPD), which seek to provide relevant, verified and comparable information about the environmental impacts of goods and services. Under discussion will be the basics of EPDs—the information they contain, their evolution, status in North America, and how they offer real evidence of a product's environmental footprint. Examples of EPDs will be presented with a focus on the wood industry, as will a discussion of how architects can use EPDs along with other environmental rating systems in designing more sustainable structures.
EPDs—What Are They?
"Today there are hundreds of labels intended to signify environmental attributes of various products," says Dr. Jim Bowyer, director of the Responsible Materials Program at Dovetail Partners, which provides information about tradeoffs and impacts of environmental decisions. "Many of these labels focus on one or two product attributes. Others are more comprehensive but lack commonality in scope or evaluation methods to allow straightforward comparisons of products. Some have no science behind them at all," says Bowyer, who is author of a 2011 Dovetail report entitled Environmental Product Declarations Are Coming—Is Your Business Ready?
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Materials like western redcedar are beginning to have environmental product declarations. Architect: Battersby Howat |
Enter EPDs—voluntarily developed documents that provide standardized, third-party-verified data on a product's environmental performance. EPDs are applicable to all types of products and services—from carpets to keyboards to lumber—within clearly defined product categories and are used to facilitate purchase decisions in the same way that a nutrition label on a cereal box or an energy performance indicator on a refrigerator does. An EPD includes data on both project attributes and environmental impacts like climate change, depletion of the stratospheric ozone layer, acidification of land and water sources, eutrophication, formation of photochemical oxidants, etc. Typically, information on some or all of the following impacts is provided.
Unlike other environmental labels, an EPD is not a seal of approval. Because it doesn't promote a product's environmental benefits, but simply discloses verified environmental impact information, an EPD has the potential to lead both purchasers and manufacturers farther down the path toward sustainability. Buyers can select products with lower adverse environmental impacts, and manufacturers can understand the source of their product's environmental liabilities. "Both these drivers should lead to the reduction of environmental impacts," writes Rita Schenk, executive director of Institute for Environmental Research & Education in a white paper published by the group in 2009.
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Western redcedar has one of the first wood-related EPDs in North America.
Project: Orange Memorial Park; Marcy Wong & Donn Logan Architects |
Primarily intended for use in business-to-business procurement, EPDs are certified to a transparent standard, the ISO Standard 14025. To meet this standard, EPDs must comply with three distinct criteria:
Use Product Category Rules (PCR)
for the relevant product type. In short, PCRs can be thought of as a blueprint for what information is collected, measured, and then reported in the product LCA. PCRs are developed for a given product category, such as wood siding or carpet. They determine the scope, boundaries, functional unit, assessment criteria, product and environmental performance information that all manufactures must use for their product LCA, thereby ensuring consistency of data, calculations, and methodology.
While EPDs are owned by the company selling the product, PCRs are developed and owned by a third party, known as a program operator. Program operators assure that the rules are developed in a transparent manner per international standards, and that individual EPDs utilizing the PCR are completed with integrity.
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Project: First Peoples House; Architect: Alfred Waugh |
Be based on a Product Life Cycle Assessment (LCA). LCA is a tool recognized worldwide in measuring environmental impacts associated with a product or service, such as raw material acquisition, energy use and efficiency, content of materials and chemical substances, emissions to air, soil and water and waste generation.
Provide an EPD Report certified and signed by an outside expert. By meeting these three requirements, an EPD provides scientifically robust and transparent information about a product's environmental performance, and can be considered to be:
Objective—because it is based on scientifically accepted, valid methods set by international standards for LCA
Neutral—no claims are made, or predetermined environmental performance levels involved.
Flexible—the content can always be changed or updated subject to external review and verification.
Comparable—EPD-to-EPD comparisons are envisioned as being apples-to-apples comparisons because the data is collected, analyzed, and reported to comply with ISO standards for PCRs and LCAs.
Credible—EPDs are reviewed, approved, and verified by an independent expert
Accurate—EPD information must be continuously updated according to the company's procedures for documentation and follow-up.
The arrival of EPDs is good news for the design community, which will not only have a reliable tool to help differentiate competing environmental performance claims but a means of enabling manufacturers, architects, builders, and consumers to fully understand the implications of building products they specify and use. In other words, EPD data, which can appear on a label or may reside in product literature, is a straightforward means of bringing environmental information into the decision-making process. EPDs not only remove greenwashing from the promotional landscape, they also facilitate responsible purchasing. Without proper disclosure from manufacturers, architects may select a product that claims to save energy, but is actually detrimental when the total environmental impact is measured. "As the design community and clients demand the most environmentally responsible solutions, science-based, holistic comparisons are more essential than ever," said Marcy Wong, LEED AP certified principal with San Francisco firm Marcy Wong Donn Logan Architects. "Life cycle analyses and EPDs will offer independent measurements that environmentally-conscious architects, engineers and owners can trust."
"We don't see EPDs nearly enough, but things are changing," says Michael Green, MAIBC, AIA, MRAIC, principal in mgb in Vancouver, British Columbia. "EPDs are essential to counteract the green-washing we all grapple with." Green would like to see EPDs applied to architectural firms themselves. "Indeed, applying EPDs to our own services might be the biggest breakthrough of all," he says. "If we consider that many firms producing a majority of LEED Platinum projects in a year are often designing a few highly unsustainable projects at the same time, EPDs offer clients an opportunity to look more holistically when evaluating different architectural firms—what is the firm's real footprint when all projects are summed? EPDs on building products and services then become absolutely critical to our practice as we work hard to provide consistently rigorous solutions on all of our projects. Maybe then we will contain even our profession's own green-washing tendencies."
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Project: Bernal Park Restroom Building; Architect: Mark Cavagnero & Associates
Photo by Marcus Hanschen |
The Evolution of EPDs and their Status in North America
According to Dovetail's Bowyer, work on EPDs was begun by the Europe-based International Organization for Standardization (ISO) in 1993. EPDs were brought into focus in 2002 with a study commissioned by the European Union Director General for Environment to document and evaluate national and sectoral EPD initiatives. A 2005 European platform on LCA spurred further attention, and EPDs grew slowly within the European Community until a recent burst of activity, notably by the German Institute for Construction and the Environment (IBU). That organization has now developed building product EPDs for floor coverings, roofing, wood products and other categories 1. "There is a lot going on in Europe, both within the EU community and in individual countries," says Bowyer, noting that "France has been the impetus for much of the activity."
In 2009, France mandated that after January 2011 all "large-volume" consumer products have an EPD consistent with the French standardization body ANFOR—a decision that was rescinded for further study. Subsequently, the French government gave the go-ahead to a one year experimentation period for EPDs effective July 1 2011, after which it will evaluate the situation with an eye toward mandating EPDs for a wide range of domestic and imported products. It is anticipated that this policy will become commonplace in other EU countries as well.
Bowyer says that in terms of EPD development, Japan is leading the world. The Japan Environmental Management Association for Industry (JEMAI) started an ecological labeling program in 2002, and has been developing it systematically ever since. As of this writing, PCRs have been developed for 275 product lines, with most having LCAs completed and online
The trend to adopt EPDs will have far-reaching implications for trade. "EPDs are beginning to be required by governments as part of trade and purchasing program requirements. Activity is currently concentrated in the EU and parts of Asia—and especially Japan, but EPDs are receiving considerable attention in the international community," says Bowyer. North America, where EPDs are just beginning to gain recognition, will indeed need to play catch up with their European counterparts. "It may come as a surprise to many U.S. manufacturers that international protocols for science-based environmental labeling of products are well advanced," says Bowyer. "The near-term likelihood of requirements for environmental labeling of exported products may also be surprising. EPDs are an increasing focus of governments and, in some cases, agencies that regulate international trade." Bowyer goes on to say, "While there are indications that EPDs are gaining recognition in the US, a general lack of attention to environmental reporting, LCA, and related tools such as EPDs have raised concerns that unprepared firms and industry sectors may soon face legal non-tariff barriers to trade in attempting to export to the EU and elsewhere." Some argue that if the U.S. fails to develop a national EPD system, a trade imbalance may result.
However, there are signs that EPDs are gaining favor in the U.S. Discussions among the U.S. Environmental Protection Agency and other organizations indicate that government procurement policies in the U.S. could soon favor products accompanied by EPDs. Since the 2009 Executive Order 13514 required federal government agencies to improve energy efficiency, reduce carbon emissions, and promote environmentally preferable materials, agencies have begun to use EPDs to meet those mandates. In addition, in 2012, the U.S. Green Building Council's LEED system may give credits for selecting products that an LCA-based EPD (see LEED & EPD sidebar on page 5).
EPDs: What Do They Look Like?
Typically, an EPD is a multi-page document that is divided into separate parts, including program-related information, product-related information, LCA and other environmental information, and mandatory statements. A typical EPD might include the following.
- Name and address of the manufacturer(s)
- Product identification by name, production code and a simple visual representation of the product
- Description of the product's use and a description of the product installation if applicable
- A detailed list of the substances, by weight, that make up the product
- Additional environmental information
- A statement of whether the EPD is cradle to gate or cradle to grave
- A statement that EPDs from different programs may not be comparable
- A statement that the EPD represents an average performance, in such cases where an EPD declares an average performance for a number of products. In addition the standard deviation of the products' performance with respect to the average is stated
- Information on where explanatory material may be obtained
- A diagram of the life cycle stages included in the LCA subdivided into product stage, building stage and end of life stage, and system boundaries
- A description of the nature of the processes and ancillary materials that are required for installing the building product in the building works and their replacement and maintenance according to the cut-off criteria
- Identification of the PCR that the EPD is based on, and whether the independent review of the EPD and data was conducted by an internal or external verifier (third-party verification is mandatory for business-to-consumer EPDs)
Other criteria include contact information of the program operator, the PCR review panel chair, the third party verifier. According to ISO 14025:2006, 9.2.2, Type III environmental product declarations intended for business-to-consumer communication must be available to the consumer at the point of purchase.
Close-up: an EPD for Western Redcedar. An EPD for typical western redcedar decking is a 14-page document that begins with brief sections on manufacturer information and product description. In this case, the EPD addresses products from multiple manufacturers and represents an average based on a sample that included two lumber mills in British Columbia, combined with recent secondary data on western redcedar resource extraction from the Athena Institute. The total data represents 20 percent of western redcedar decking production in the year 2007. Product description information includes:
The EPD describes wood decking as a board-type product horizontally applied in a load-carrying capacity and as the final surfacing for an outdoor flat surface attached to a house and typically elevated above the ground. A decking product in the most common size, as specified below, is modeled for this EPD.
- Typical board size: 5/4" x 6" (31.75 mm x 152.4 mm)
- Grade: Average
- Product composition (on the basis of 1 m2 installed decking with a 25-year service life):
Western redcedar lumber: 8.14 kg (oven dry basis)
Optional coating
Stain: 1.25 liters
Fasteners (2½" galvanized nails, No 8 or 10): 0.1 kg per 1 m2 installed decking
- Installed and used according to specifications2. Base case is an uncoated deck. An alternate scenario has regular applications of a stain coating.
The EPD goes on to address the LCA of the decking, noting the organization that performed the LCA, and when and where the data was collected. System boundaries are defined. In this case, the boundaries extend to all production steps from extraction of raw materials from the earth through to final fate of the product at the end of its service life, including all transportation of major inputs to and within each activity stage including the shipment of products to a hypothetical building site location in North America and eventual transportation to landfill. The city of Minneapolis was chosen as the typical building location, as a central location in North America.
Ancillary materials and other materials such as coatings, fasteners, and packaging are included in the boundary, though mass or energy flows less than 1 percent of model flows and less than 2 percent of life cycle impacts are excluded as are human activity and capital equipment. Assumptions for the use phase are stated, such as, the use of water and cleaning solutions is common to all decking types and is excluded.
End-of-life assumptions are spelled out in detail. In the LCA used for this EPD, materials at the end of their service life are assumed to be transported through municipal solid waste collection to inert material landfills, as is estimated by Franklin Associates to be the norm for 70 to 80 percent of construction and demolition debris (USEPA, 1998). Organic materials in landfill decompose into the greenhouse gases methane and carbon dioxide, the methane portion of which may be captured for heat recovery or flaring. The USEPA (2006) estimates that 59 percent of landfills are equipped with gas collection systems and 75 percent of emitted gases are captured; of that, 53 percent is burned with energy recovery and 47 percent is flared. The handling of municipal solid waste is modeled with representative process data provided in the ecoinvent database (Doka, 2007), with electricity-fuel breakdown, energy supply chain, and combustion processes substituted with USLCI data. Wood products are known to not completely decompose in landfill, leaving some or most of the carbon essentially in permanent storage; estimates for the proportion of wood that will decompose vary from very low to the most recent estimate of 23 percent (Skog, 2008).
Environmental performance of western redcedar is based on the U.S. Environmental Protection Agency's TRACI (Tool for the Reduction and Assessment of Chemical and other environmental Impacts) life cycle impact assessment methodology is used to characterize the flows to and from the environment. Impact measures shown include global warming potential, acidification potential, eutrophication potential, smog potential, and ozone depletion potential. A sample of the information relating to environmental performance is presented in the following figure.
The EPD also shows environmental performance of decking with a regular application of stain. "It's important that an EPD represent a product in all its common uses," says Jennifer O'Connor, group leader, Energy & Environment, for the Building Systems Program at FPInnovations, which prepared the EPD. "Because decking is frequently stained, which can have an added environmental burden, we wanted to assure that this common use of western redcedar was accounted for."
In terms of other environmental information, the western redcedar EPD discusses carbon balance. This is because the carbon that is part of the molecular composition of wood is derived from carbon dioxide removed from the atmosphere by the growing tree that produced the wood; this carbon is often a consideration in greenhouse gas calculations and carbon footprints for wood products. "At the manufacturing gate, wood products are typically carbon-negative; that is, more carbon is stored in the product than was emitted during harvesting and manufacturing," says O'Connor. Wood products often remain carbon-negative through their entire life cycle, but not always. "Emissions from transportation to a building site, product maintenance such as repainting, transportation to landfill, and decomposition in landfill can render wood products into net carbon emitters at the end of the full life cycle." The end-of-life processes for wood products have the most effect on cradle-to-grave carbon footprint. The EPD transparently discusses end-of-life assumptions used in calculating the carbon data.
EPDs and Wood: Where Are We?
Not surprisingly, Europe is far ahead of North America in the number of EPDs related to wood, with individual EPDs for oriented strand board, particle board, plain structural timber, sawn-dried timber and cross laminated timber, among other products. The German Institute for Construction and the Environment (IBU), for example, has developed a number of building product EPDs for use in Germany and the European Union, many of them having to do with wood3. New EU regulations may mandate the use of EPDs in the construction industry. "In Europe there is regulatory pressure to minimize carbon footprints," says Robert Glowinski, president of the American Wood Council. "In the absence of that kind of regulation, what's driving EPDs in North America is the desire for credible information on product environmental performance presented in a standardized format." Glowinski says the American Wood Council is "in the beginning stages" of developing EPDs for structural wood products, and looks forward to the contribution EPDs will eventually make to the architect's toolbox. He notes that when using EPDs, architects should look for the environmental impacts most relevant to their projects and values. "A given product won't be everybody's top pick across the board. But the beauty of an EDP is that it allows users to weight what is important to them in a given situation, be it life cycle impacts such as greenhouse gases, air quality, solid waste generated, or energy efficiency, and make an informed choice about a product based on their value system," says Glowinski.
"Within the wood industry there has been something of an awakening," says Bowyer, explaining that there is substantial attention to looking at PCRs among several industry groups including the American Forestry and Paper Association and the Hardwood Export Council. "I'm a lot more optimistic than I was a year ago."
See RESOURCES at the end of this course for a list of websites for EPDs for western redcedar decking and siding, along with select other EPDs for wood-related products.
PCRs—The Backbone of An EPD
Key to an EPD are the PCRs, Product Category Rules, which are a specific set of requirements and guidelines for developing an EPD. They form the basis of credible and comparable EPDs. "A PCR specifies allocation rules for products and co-products in the life cycle inventory aspect of an LCA, defines materials and substances and impact categories that must be reported, and establishes a time frame for data validity," says Bowyer. "Because PCRs establish rules that apply to manufacturers of an entire product category, they must be developed in consultation with a wide range of stakeholders." This open process is key to maximizing the quality of the PCR document. After the incorporation of all relevant comments, a PCR is approved and established by a technical committee typically composed of independent LCA-experts from academia and the business sector. The resulting PCR documents are usually valid for three years. If necessary they can be revised and updated after that period, or at shorter intervals should important changes arise.
Theoretically each unique product would have its own PCR, however, this would flood the market with different PCRs making comparisons difficult. When the various product groups have the same raw materials, composition, types of components, etc., the same set of general rules should be applicable to a large number of similar products. Experts say it's not necessary to reinvent the wheel with each PCR. Bowyer says that PCRs and associated LCAs need not be prepared from scratch. "They should be based on previously completed PCRs and LCAs for similar industries nationally or globally," he says.
Issues to Watch For
In the burgeoning field of EPDs, questions and concerns will certainly arise.
Architects may want to consider the following issues as they begin to incorporate EPDs into their decision making process.
Who Develops It. Who actually develops the EPD is a critical concern. For products that are similar across an industry, such as wood, a trade or technical association will typically take the lead. But for products that are unique or those that have more favorable environmental impacts than the industry norm, a single manufacturer may actually take the initiative to develop an EPD.
EPDs vs. LCAs. LCA has been widely touted as the premier means of systematically evaluating the environmental impacts linked to a product or process and for guiding process or product improvement efforts. So why add an EPD into the mix? The principal reason is that consistency is needed when comparing one product to another, both in terms of what is and isn't included when analyzing environmental impacts, and in reporting results. Rules governing the preparation of EPDs ensure that information regarding environmental performance is uniformly reported and based on apples-to-apples comparisons. An EPD also includes all relevant performance information for a given product, notably safety, human health, and other relevant issues, as well as product and company information.
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Project: Columbia Sportswear Company
Photo: Ben Schneider |
LEED and EPD
The U.S. Green Building Council has recognized EPDs in its new LEED Pilot Credit 43 released in June. Credit can be earned via two pathways that can be combined—the certification pathway and the EPD pathway. The certification pathway rewards products with third-party labeling or certification for single or multiple environmental attributes. The EPD pathway rewards products with a life cycle assessment report or with an EPD. The stated intention is to bring awareness of certification and labeling to all products and materials (rather than singling out only some materials such as wood), and to provide an incentive for more informed material selection based on data transparency and knowledge of product life cycles.
Third-party certification provides a rating but no data, while EPDs provide data but no rating. The new pilot credit recognizes the usefulness and value of both in helping inform product selection. Advocates say that EPDs help bring more multi-attribute awareness to LEED, which currently emphasizes single-attribute characteristics like recycled content and local manufacturing in its materials and resources credits.
"EPDs are at the core of our approach to Materials and Resources in the next version of LEED and they are essential to move to the next level of environmental decision making about materials and products. You can think of them like a type of nutrition label. They will tell you information that you would not have had otherwise which will lead to more informed decisions, says Scot Horst, Senior Vice President of LEED, U.S. Green Building Council. "Additionally, once EPDs are widespread in the market, we will be able to set benchmarks for performance measures such as Global Warming Potential or Water. Without this information, such performance measures are almost impossible."
However, LEED 2012 has not been finalized. It is still in the public comment phase as of this writing (October 2011). The second public comment period closed in September 2011, and a third public comment period is scheduled to open early in the first quarter of 2012. |
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Project: Experimental Media Performing Arts Center. Architects: Grimshaw Architects |
LCAs are essential in providing systematic assessment of environmental impacts. However, in comparisons of one product to another using LCA results it is essential that the same attributes be compared, and within the same boundaries of consideration. EPDs that are based on PCRs that specify the parameters to be considered for a given family of products, ensures that consistency. Bowyer notes that "while LCAs provide valuable information, there are opportunities to play games." He recalls several recently published LCAs that concluded concrete was environmentally preferable to wood as a building material. "We looked closely at those LCAs, and found that they were comparing buildings that weren't thermally equivalent. This is an example of why EPDs are necessary—to compare functionally equivalent units and establish system boundaries so that information is truly comparable."
Type of Eco-label. Strictly speaking, an EPD is a Type III eco-label per ISO criteria. It is not to be confused with types I and II ecolabels, which have their own ISO criteria. Type I eco-labels designate environmentally preferable products with respect to one or more product attributes and involve verification by a third party and consideration of lifecycle environmental impacts. They act like a stamp of approval on products that meet the ISO criteria, and indicate overall environmental preference within a product category. Type II eco-labels are self-declared, usually by the manufacturer of a product, and not subject to third party verification. Type III eco-labels are EPDs, third-party verified and based on full life cycle assessment detailing environmental impacts associated with a product or service, and performed in accordance with international protocols. "Many companies were making environmental claims anyway, and ISO came out with guidelines for them to follow even if they are self-reporting," says Bowyer. "But ultimately, we'll be looking at a global requirement for Type III declarations."
Same Funtional Units. It's necessary to read the fine print in an EPD, all the way down to the functional unit of the product or material under consideration. The EPD is based on only one functional unit. When comparing windows, it's essential to select EPDs where the window unit is of the same size, or the same square footage in the case of wood vs. aluminum siding, for example.
Cradle-to-Gate vs Cradle-to-Grave. LCA methodologies can differ, and one important consideration is investigating cradle-to-gate environmental impacts as opposed to cradle-to-grave impacts. Cradle-to-grave is the full life cycle assessment from resource extraction, or "cradle" to use phase and disposal phase, or "grave." Cradle-to-gate is an assessment of a product life cycle from the resource extraction "cradle" through manufacturing to the factory "gate," which measures impacts up until a product is transported to the consumer. While the cradle-to-grave analysis is more extensive, it might not always be necessary, depending on the material involved. "Particularly for a business-to-business product such as lumber, a cradle-to-gate analysis may be more appropriate," says O'Connor. "But when that lumber is made into a consumer product such as decking or siding, a cradle-to-grave analysis is the more appropriate methodology."
The Future Calls
With the European Union proposing regulations that mandate EPDs, and a growing movement to embrace EPDs in Europe and Asia, can a U.S. system be far behind? Certainly a lot is happening. Webinars and workshops on EPDs and PCRs are sprouting up. The American Society for Testing of Materials (ASTM) Committee E-60 is in the process of refining PCRs for building products. Executive orders are mandating green building programs. Advocates are calling for national legislation to support EPD.
Certainly the benefits of EPDs are far reaching. According to the Institute for Environmental Research & Education's Schenk, "The simple fact of disclosure has proven to be a very effective spur to pollution prevention, as companies see where they stand vis-à-vis their competition. Decreasing pollution leads to better public health, lower medical costs, and therefore an economically stronger nation. EPDs provide a low cost method to decrease the environmental impacts of the economy, and ongoing measurement provides an embedded continuous improvement mechanism."
Or, as architect Michael Green puts it, "Someday I can see a world where reading a high carbon footprint on a material or service will be a revulsion paramount to seeing trans fats on a nutritional guide: both are addictive, but with labels we can no longer hide while making unhealthy choices."
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| The Western Red Cedar Lumber Association (WRCLA) has been "the voice of the cedar industry." Its members account for 65% of the world's production of Cedar. WRCLA works with architects, designers and builders to ensure the right product is specified. The association offers extensive resources including specification, installation guides and assistance is sourcing materials. For architects, these include online and in-person seminars eligible for AIA Learning Credits, live technical support through the architect advisory service program and access to sample materials and other resources to aid product selection. Visit the website or call 1 866 778 9096 for more information. www.wrcla.org |
