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."

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.