Product. Transparency and the Emergence of EPDs, HPDs, and PTDs. For: Vicki Worden,

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1 Product For: Transparency and the Emergence of EPDs, HPDs, and PTDs Vicki Worden,

2 Objectives A bit of history on transparency issues. What are EPDs? What are HPDs? What are PTDs? What are the market drivers for green products? What other initiatives may influence markets?

3 A Bit of History of on Transparency Issues

4 History of Product Life Cycle Assessment Use Graphic of bags credit:

5 History of Chemical Transparency Prop 65 CARB Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH)

6 Latest Transparency Tools Two most noted tools are EPDs and HPDs, but others are emerging. Environmental Product Declarations - EPDs - are documents disclosing the potential life-cycle environmental impacts of a product. EPDs were developed starting in 1993 and published as an ISO Standard (14025) in Health Product Declarations - HPDs - are documents intended to disclose ingredients, including potential human chemical hazards, in building products. HPDs were introduced by the Healthy Building Network and BuildingGreen in 2011 at GreenBuild in Toronto. The HPD Open Standard Version 1 was formally introduced at the 2013 GreenBuild in Philadelphia. Alternatives Product Transparency Declarations PTDs developing through ASTM and updated MSDSs on international front more to come.

7 USGBC s LEED v4 Big Driver Product transparency and LEED v4 Product transparency into the Materials and Resources (MR) section of the rating system: MRc2 Building product disclosure and optimization - environmental product declarations Possible 2 points - credit provided for EPD-covered products MRc3 Building product disclosure and optimization - sourcing of raw materials Possible 2 points deals with sourcing of raw materials, including biobased materials, certified wood, recycled content, etc. MRc4 Building product disclosure and optimization - material ingredients Possible 2 points requests disclosure of that chemical content and inventory of products. Completion of the HPD provides the needed certification or use of GreenScreen or Cradle to Cradle certification.

8 What are EPDs? These EPDs and transparency briefs are third-party verified by UL Environment

9 EPDs are declarations of potential environmental impacts Nutrition labels = food nutrition reporting EPDs = product and service environmental impact reporting plus primary energy consumption Figure 1: Excerpt from page 10 of 15 of ULE certified EPD on North American Softwood Lumber. Source: USDA Nutrition Label

10 EPD Impact Assessment Results Figure 1: Excerpt from page 10 of 15 of ULE certified EPD on North American Softwood Lumber.

11 International trends EPDs are being developed worldwide, with the largest momentum in Europe and Asia.

12 Industry-wide vs. brand specific Concrete Flooring Ceilings Cross-Laminated Timber

13 Cradle to Gate vs. Grave

14 What are HPDs?

15 HPD Origin The Health Product Declaration Standard was originally developed by the HPD Working Group with the support of the Materials Research Collaborative, a non-profit collaboration of the Healthy Building Network and Building Green. It is now managed by the HPD Collaborative.

16 HPD Standard The HPD form is broken into sections: IDENTIFY Fill out manufacturer information and product description. INVENTORY Collect the documentation and list product contents. ASSESS Review contents against authoritative chemical Hazard Lists. COMPLIANCE Provide the details of product testing and compliance. ACCESSORIES Note installation/maintenance/cleaning/operations materials. SUMMARIZE Confirm the summary page, fill in explanatory notes & release date. PUBLISH Share with your customer

17 Industry Concerns about HPDs HPD Open Standard is not developed through true consensus process HPDs focus on hazard lists without consideration for exposure/risk Many of the 32 hazard lists in HPD are not authoritative bodies HPD requires disclosure of product formulas HPDs encourage the use of third party certification that may cost between $1000 to $6500 HPDs are complex and manufacturers are hiring third party firms to complete the document GreenScreen is used by HPD and some industries consider it to be incomplete, using draft assessments, and not consensus based. Addresses health impacts of substances used during manufacturing although they may not appear in the final product.

18 Quote from Certainteed HPD The HPD Standard is solely a declaration of product content and direct health hazards associated with exposure to its individual contents. It is not a full assessment of environmental impacts from the life cycle of this product. It is not an assessment of risks associated with actual use of the product. It does not address the potential health impacts of substances used or created during manufacture that do not appear in the final product as residuals, nor substances created during combustion or other degradation processes.

19 Example of Industry Concern Titanium Dioxide (TiO 2 ) Used in white cool roofs, linoleum, toothpaste Listed carcinogen IARC and California Prop 65 Listed on HPD as a cancer hazard

20 Examples of Ingredients on AOEC Hazard List Cement Dust Carbon Black Clay Fiberglass Plaster Polyvinyl Chloride Rubber Dust Tooth Enamel Dust Chlorine Vinegar Linseed Oil Cake Camphor Oil Thyme Grain Dust Coffee Bean Sunflower Corn Starch Western Red Cedar Frog Cricket Honey Bee Fruit Fly

21 Alternatives are emerging Alternatives New generation of MSDSs that are starting in 2014 based on a globally harmonized system endorsed through international treaties and endorsed and integrated by the U.S. EPA. Product Transparency Declarations (PTD) address risk as well as hazard assessment. PTDs look at threshold levels and paths for exposure. Developed by the Resilient Floor Covering Institute and submitted to become an ASTM standard.

22 Be careful what you wish for Chris Dixon, Walls and Ceilings Magazine when did architects become responsible for ensuring occupant health resulting from exposure to building material ingredients? And since when did architects acquire the knowledge and skill necessary to be able to do such a thing? The aggressive, almost militant, behavior of some those demanding more transparency reminds me a little of the Occupy Wall Street movement. Mad as hell and not afraid to tell you, Occupiers ultimately could not articulate what it was they wanted, or how they proposed to solve the issues that so upset them. While striving for greater transparency is something that nearly everyone will agree with, coming up with the why and how seems much more difficult. To avoid exposure to unwanted liability, architects should not attempt or agree to evaluate building materials for occupant health. If the Owner wants to see HPDs, or PTDs, or even MSDSs, the architect would be better off transmitting that information directly to the Owner, without review, and letting the Owner make the call about what goes into the building, and what does not.

23 What are the market drivers for green products and transparency initiatives?

24 What or Who is Driving Demand for Product Transparency? International Trends Competitive Industries California Demand Drivers for: EPDs HPDs PTDs Architects & ENGOs US EPA U.S. Administration s Focus on Changing Climates

25 Why Product Transparency? We believe in transparency and that it is essential for people to know what is in building products. We also believe that to bring about transparency, it should be easy for manufacturers to tell the story of their materials in a forthright, clear, and standardized format. Peter Syrett, Perkins+Will Full disclosure of material content as proposed by the Health Product Declaration format will enable designers, specifiers, builders and those who own and occupy buildings to make informed decisions about the environmental and economic costs and benefits of building materials. Michael Deane, Turner Construction Company Source: %20Release% %20Revised.pdf

26 Blog at Perkins Will Why Perceived Need for EPDs & HPDs + alts? LEED V4 and Environmental Product Declarations have a giant, toxic loophole that designers, green professionals, and the USGBC need to know about. ISO compliant EPDs are hiding a nasty blemish manufacturers are not effectively required to publish their product s impact on human health and ecological toxicity impacts. The same EPD that offers a broad, detailed environmental impact statement for everything from global warming to acid rain is not required by the ISO or LEED V4 to identify their impacts on human health and ecological toxicity. - See more at: epds/#sthash.0kj5iryq.dpuf

27 Demand is There Contractors will be asked to submit EPDs in the submittal process as a part of the verification process for LEED and Green Globes Architects are already requesting HPDs.

28 Thanks and Credit Due The EPD portion of this presentation was created using content owned by the American and Canadian Wood Councils. The HPD portion contained content provided by RFCI. This content is shared with permission.

29 Questions? Vicki Worden

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