Environmental Product Declarations - The New Benchmark?
Assessing the comparative environmental impact of products and materials using single attribute characteristics, such as recycled content, point of extraction, and VOC content, is like trying to figure out how many miles to the gallon a car gets based on color. It is impossible to do in any really meaningful way. There is so much more that needs to be considered to really know what product or material is less harmful to the environment that another. Energy used for extraction of raw ingredients, manufacturing and transport; in-service life expectancy; maintenance requirements; etc.
The latest and greatest draft version of LEED has been struggling mightily with this in moving toward a more comprehensive appraisal of the Materials and Resources credits, the sixth public comment period having just concluded. Although the USGBC insists that this will be the last public comment period before v4 goes to ballot, public comments would seem to indicate otherwise. Here is a small example of some of the most recent comments:
“The language relating to valuation factor is very confusing.”
“MR credits need to be radically simplified.”
“We have been reaching out to members of the LEED practitioner community to get their thoughts on these credits. The consensus is that the way the credits are written is overwhelmingly too complex.”
“… there are inconsistencies within the reporting requirements, which will create frustration and confusion for all involved—project teams, manufacturers, LEED Reviewers, GBCI, etc.”
“… the complexity is truly a deal-breaker for me. As a practitioner and as a state employee involved in policy discussions, simplicity is key - what do we want to achieve and what’s the simplest manner in which to get there? This confusion and complexity doesn’t make this credit more likeable or useable …”
Despite the issues highlighted above, the possibility that LEED will revert to a single-attribute-based materials credit is highly unlikely. LEED will eventually get something finalized in the new rating system, and it will look very different from what it does now. One of the most prominent and recurring features that is likely to survive the public comments, is the requirement for Environmental Product Declarations.
CREDIBLE THIRD PARTY ASSESSMENT FOR PRODUCTS
There has been some recent effort undertaken in the industry to provide EPDs to the design and construction community. I discovered one while reviewing a product data sheet for resilient flooring products, a third party sustainable certification based on NSF/ANSI 332 Sustainability Assessment Standard for Resilient Floor Coverings. Prior to seeing this listed in the data sheets, I was unaware of the organization NSF International and also unaware that it had developed an ANSI standard for the sustainability of resilient flooring. After a little digging, I learned that NSF International is an independent global organization that writes standards, tests and certifies products for the commercial flooring, construction, food, water and consumer goods industries. In addition to its resilient flooring standard, NSF has developed more than 50 ANSI standards, among them standards for sustainable carpet, wallcovering, furniture and single ply roofing.
The NSF/ANSI 332 uses a point-based system in which manufacturers achieve one of four levels of certification—conformant, silver, gold or platinum. The language in the standard is straightforward, clear, reasonable and understandable—a testament to the rigorous process ANSI requires in developing any standard that bears its name. The consensus process used to develop the standard was built upon scientific principles, including the ISO 14000 series standards on Life Cycle Assessment and feedback. Products are evaluated against the standard using five key criteria:
- Product design
- Product manufacturing
- Long-term value,
- Corporate governance
The criteria are incredibly comprehensive, and include prerequisites and point categories that include Life Cycle Assessment, minimization of chemicals of concern, greenhouse gas reduction, durability and employee injury rate, to name just a few. In total, 100 points are available across eleven prerequisites and 47 point-earning categories.
NSF/ANSI 332: DIGGING A LITTLE DEEPER
Jane Wilson, director of standards, NSF International, states that “Certification to NSF/ANSI 332 offers buyers of resilient flooring the highest level of confidence and credibility in a market that is awash in green claims.” I was able to download resilient flooring products certified by NSF to this standard by going to the NSF website and searching for resilient flooring products. The certificates for the products I found contain only the basic information—the manufacturer, product, certification number and certification level. This level of reporting, however, does not provide information as to what points were achieved and in what assessment categories.
The points that a manufacturer elects to pursue in obtaining certification are optional and prerogative. For a design professional wanting to compare one product against another, this information is critical. So, I sent an email to NSF to find out how to get the full certification document. The response was that this information is not available through NSF and that I should contact the manufacturer. And so I did.
The manufacturer responded that this was information I should ask NSF about. I explained that NSF told me the same thing and it went up the ladder a bit with the manufacturer. I then received information from the manufacturer giving me only the percentages of points accumulated across the five categories, nothing else. I tried another manufacturer that has resilient products certified to the standard—not by NSF but UL Environment. I got nearly the exact same run around—both from the manufacturer and from UL Environment.
Withholding information smacks of something far less than the whole point of an independent, third-party certification of a product using a consensus-based ANSI standard. A careful reading of the standard reveals several points that look very much like “business as usual”—things like recycled content in the product packaging, reporting employee turnover rate, and profitability (“gimme” points). What I am interested in knowing (and where LEED and the rest of the world is headed) are the other point categories in the standard, such as the reporting and elimination of chemicals of concern, Life Cycle Assessment, and greenhouse gas reductions. Without this, the certification itself tells very little about a product’s true greenness.
The introduction of independent, third-party certified EPDs into the market is a beautiful thing. Certifications based on truly consensus-based processes and procedures under the guiding principles of organizations such as ANSI and ISO. But be warned: That Gold NSF/ANSI 332 Certified product doesn’t necessarily mean that it has fewer chemicals of concern, lower indoor carcinogenic VOC emissions, or more recycled content than a product with a Conformant certification—or no certification. To make everybody happy and to continue pushing the envelope, 100 percent transparency is required.
The good news is that we are getting there very quickly and organizations like NSF, with the development of robust sustainable product ANSI standards, are helping the effort tremendously.