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ISO 14025

EPDs are New and Untested but in Short Order will Dominate

EPDs are New and Untested but in Short Order will Dominate

written by CleanTechies.com Contributor

An environmental product declaration (EPD) is a method of quantifying the environmental impacts of a product in order to provide a sound basis for making decisions about the use of that product. As explained in my recent blog post, EPDs are Among the Hottest Topics in Green Building. Most simply put, an EPD in analogous to a nutritional label on a box of cereal. But beyond that explanation nothing is simple.

As a threshold matter, EPDs have been a European construct in part to comply with the European Union Integrated Product Policy. There is no similar U.S. law. Credits in LEED v4 related to EPDs are rapidly heightening interest in the U.S.

But just as Metric measurements have not overtaken the English measurements used in the U.S., it is not clear what success those ISO based country specific varied EPDs will find in the U.S.

Among the loudest critics of the LEED v4 Materials & Resources credits related to EPDs is Perkins+Will architect Douglas Pierce, who authored a White paper, “LEED V4 Should Lead On Material Health Transparency By Accepting Only Environmental Product Declarations (EPDs) That Comply With the Federal Trade Commission’s (FTC) Truth in Advertising Law”. Pierce highlights that EPDs and their use in LEED V4 “have a large loophole related to toxicity”. The White paper argues that toxicity must be detailed or risk violating the Federal Trade Commission Green Guides.

The White paper is legally not correct, .. but who would seek legal advice from architects (even a well respected architecture firm like Perkins+Will)?  However, the White paper is useful in identifying the shortcomings of EPDs and in particular ISO based EPDs.

It is troubling that ISO 14025, specifying the procedures for developing Type III EPDs, was published in 2006, a long time ago in the realm of science and years before the current widely accepted ESEtox toxicity tool even existed.

USGBC has responded to the controversy:

USGBC believes that the coordinated use of EPDs, HPDs and raw material sourcing data – the path that’s been established in LEED v4 – generates information that can be practically acted upon in a way that USETox data reported in an EPD currently cannot be. However, the two paths are not mutually exclusive and USGBC applauds manufacturers who include USETox information as part of an EPD in addition to those that generated EPDs and HPDs.

The reliance on standards created by others, that is by a particular interest group for a limited purpose at a specific time, be it an ISO, ANSI, ASHRAE or other standard offers efficacy to a process or product, but is greatly problematic when the limitations of the standard are not appreciated.

Of note, the federal government is moving toward EPDs not based on the ISO standards, but rooted in TRACI, as described in my recent blog post.

USGBC has since the first version of LEED referenced third party standards and, on balance, it appears that LEED v4 has the bleeding edge materials disclosure ‘stuff’ just about right. And possibly of greatest import, many believe building product and material disclosure and optimization will, in short order, be a bigger business than LEED itself. Our law firm is working with a broad breadth of manufacturers and material suppliers, including their trade groups in this new era of EPDs.

Article by Stuart Kaplow, appearing courtesy Green Building Law Update.



March 20, 2014 0 comment
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Environmental Product Declaration a Hot Topic in Green Building

Environmental Product Declaration a Hot Topic in Green Building

written by CleanTechies.com Contributor

An environmental product declaration (EPD) is a method of quantifying the environmental impacts of a product. It is analogous to the nutritional label on a box of cereal. In the context of green building, EPDs will provide a way describing the environmental impact of a building material or product.

EPDs articulate the conclusions of a life cycle assessment. The aim of an EPD is to facilitate the comparison of the range of environmental effects attributable to a product in order to provide a sound basis for making informed decisions.

Life cycle assessment is widely accepted to encompass 5 stages: raw material acquisition, manufacturing, transportation, use, and end of life.

U.S. EPA developed TRACI, the “Tool for the Reduction and Assessment of Chemical and other environmental Impacts” that assists in impact assessment for life cycle assessment. TRACI requires consideration of the 5 stages described above. And TRACI facilitates the characterization of environmental impact categories that have potential effects, including: ozone depletion, global warming, acidification, eutrophication, photochemical oxidation (smog), ecotoxicity, human health: criteria air pollutants, human health: carcinogenics, human health: non-carcinogenics, fossil fuel depletion, land use, and water use.

In the U.S. TRACI can provide most of the information required for an EPD. Product and company information would be added.

ISO 14025 (produced by the International Organization for Standards, the world’s largest developer of voluntary standards) describes an “environmental declaration”, as quantified environmental data for a product with pre set categories of parameters based on the ISO 14040 series of standards, but not excluding additional environmental information. The ISO standard establishes the principles and specifies the procedures for developing a Type III environmental declaration. Type III environmental declarations “are primarily intended for use in business-to-business communication, but their use in business-to-consumer communication under certain conditions is not precluded.”

In contrast to TRACI that was created specifically for the U.S. using input parameters consistent with U.S. locations, ISO 14025 was created to play a role in “regional eco-label programmes, such as the European Union Integrated Product Policy”. That observed, ISO 14025 is becoming the early benchmark for EPDs (possibly because Europe is ahead of the U.S. in this arena?).

This post is about Type III EPDs, which require an independent agency to oversee the EPD process, Of note, Type I environmental labels are multi criteria third party programs that award environmental labels to products meeting a set of predetermined requirements. And Type II environmental labels specify requirements for self declared environmental claims made by manufacturers, importers, distributors, retailers or anyone else likely to benefit from such claims.

All of this is new, in particular in the U.S. where EPDs are soon to be crucial in green building because LEED v4 and Green Globes both recognize EPDs. The new versions of IgCC 2015 and ASHRAE 189.1-2015 are each considering the use of EPDs. And while EPDs most directly contribute to LEED v4 point in the MRc1 and MRc2, they potentially have some role to play in 21 different LEED credits.

Not only are EPDs key in LEED v4, but EPDs are among the hottest topics in green building.

Article by Stuart Kaplow, appearing courtesy Green Building Law Update.



March 17, 2014 1 comment
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