EPDs, HPDs and Red Lists (Oh My)!
A deeper look into Health Product Declarations
The latest Green Globes and LEED green building rating systems have introduced new building materials credits that move away from simpler single-attribute credits and points we have all grown used to. Both rating systems are instead now placing more emphasis on transparency and disclosure. Green Globes offers a new credit that rewards project teams for submitting building materials’ Environmental Product Declarations, something this author wrote about at length not too long ago. LEED has introduced a similar credit that, in addition to rewarding teams for submitting EPDs, also includes credit for submitting Health Product Declarations.
In a white paper entitled “A More Effective Approach to Selecting Materials & Resources,” Green Globes explains that HPDs, in their current state, are misleading to the design community because they simply list hazardous (or potentially hazardous) ingredients that come from several “red lists” without addressing the actual risk (or lack thereof) to people and the environment. By contrast, EPDs include thorough Life Cycle Analyses and are consensus-based, making it possible to conduct a meaningful evaluation between one EPD and another.
LEED V4 rewards submittal of HPDs among several options that project teams may pursue for points under its new building product disclosure credit. The intent of the credit is to:
“… reward project teams for selecting products for which the chemical ingredients in the product are inventoried using an accepted methodology and for selecting products verified to minimize the use and generation of harmful substances.”
In addition to and/or in lieu of submitting HPDs, LEED V4 allows manufacturer-prepared content inventory, a Cradle to Cradle certificate, or some other material reporting program approved by the USGBC (but not defined).
For some reason, these other options have been ignored by a handful of architecture firms that have sent out some very strongly written, and downright threatening, letters to select building material manufacturers demanding that they immediately fill out and publicly post HPDs. The letters stipulate that not doing so by such-and-such date will result in those manufacturer’s products being stripped from resource libraries, specifications and projects. Although only a few dozen of these “Do this or else!” letters have been sent by fewer than 10 architecture firms, they have grabbed the attention of the unlucky recipients.
WHAT ARE HPDS AND WHERE DID THEY COME FROM?
The Health Product Declaration Standard was developed by a small group of architects and manufacturers named the Health Product Declaration Collaborative. It was created “to be the industry standard format for conveying details about product content and associated health information.” Its developers believed that HPDs would allow designers to “specify products with full knowledge of what’s in them and how they will impact a building’s environment and occupants.” As I discovered after digging into one of the few HPDs I could find, this could not be further from the truth.
BREAKING DOWN AN HPD
Each of the manufacturers involved in the development of the HPD standard reportedly provided all necessary information for a product (or products) during a pilot stage of the standard’s development, an exercise that was to culminate with a collection of actual HPDs. But you will not find these HPDs on the collaborative’s Web site. Nor will you find them at each of the participating manufacturers’ Web sites. I could find only one. It turns out that one HPD is more than enough to illustrate the utter fantasy contained in the belief that an evaluation of a HPD will do anything to make a building greener or occupants safer.
The HPD I found is for wall protection specialties such as crash rails, corner guards and wall coverings. Only two ingredients are listed in the HPD; a corn-based plastic called polyactide (PLA) and a flame retardant called melamine polyphosphate. Both ingredients are reported as having, “No warnings found on HPD priority lists.” The HPD priority lists are a collection of roughly 30 “red lists” of chemicals of concern including governmental and non-governmental, all of them referred to as “authoritative” on the HPD collaborative Web site. In the hands of a designer that trusts that the HPD is what its developers claim it to be, this manufacturer’s HPD declares the products sustainable and healthy, no warnings found—specify with abandon!
DIGGING A LITTLE DEEPER
On a whim, just to see what happened, I did an internet search for “polyactide resin” and was surprised to get a laundry list of results that paints an entirely different picture portrayed by the HPD.
I learned from an article on about.com that PLA is typically made from genetically modified corn, the largest producer of PLA in the world being the world’s largest provider of genetically modified corn seed, and that the future costs of genetic modification to the environment and human health are still largely unknown and could be very high.
I also learned from an exhaustive Life Cycle Analysis on PLA done by the Athena Institute in 2006 that:
- PLA degrades only with difficulty, and will not degrade in a home composting project, which means reliance on a commercial operation, of which few exist in the United States. Claims about the biodegradability benefits of bio-based plastics are in the realm of conjecture.
- If PLA is incinerated, the same results could be expected as for conventional plastics.
- PLA production requires considerations such as the possible requirement for more water or the use of ancillary materials such as nitrogen fertilizer, pesticides and herbicides to grow corn as compared to many other crops.
- While conventional plastics can be recycled, PLA cannot be mixed with other plastics for recycling. In fact, if PLA plastic is mixed with PET plastic, the potential to harm the existing extensive PET recycling infrastructure is likely because of the incompatibility of the two materials.
And finally, in an article by Scientific American, I learned that PLA bottles could take anywhere from 100 to 1,000 years to decompose in a landfill. In landfills PLA exudes methane when it decomposes—and methane is a potent greenhouse gas. That PLA may not be much better than the plain old plastic it’s designed to make obsolete. None of this information is contained in the HPD.
I then searched for the second ingredient listed in the HPD, melamine polyphosphate. While I did not get as many results as for PLA, I did get one of huge significance—a Green Screen assessment. The Green Screen rating for melamine polyphosphate was given a Benchmark Score of 2 based on HIGH systemic toxicity, and MODERATE carcinogenicity and mutagenicity. This is significant because the HPD standard rules require that Green Screen assessments and chemicals listed as hazardous in the assessment be reported in the body of the HPD. None of this was included in the HPD, leaving the reader to conclude, erroneously, that there is nothing hazardous to report.
I have merely scratched the surface here in showing just how difficult it can be to believe what you read, and rely upon something like an HPD to make intelligent decisions about healthy, environmentally friendly building material selection. It comes as no surprise then that many manufacturers are resisting the demands from designers to develop HPDs, since it is clear that HPDs will not necessarily help them make the “right” decisions.
Without a truly consensus-based development committee in charge of developing the HPD standard, it will remain in the realm of wishful thinking. I believe that a transparency standard could be developed that would satisfy (and better serve) all parties—including those designers currently demanding HPDs from manufactures, but this will require involvement of all concerned stakeholders in an open, consensus-based process. I think that the HPD is a step in the right direction, but there is still much to be done before we have something that can be used with any confidence.