material transparency - usgbc · 2015-04-29 · material transparency . manufacturing sites ....

Paul Bertram, FCSI, CDT, LEED AP- BD&C, GGP

Director: Environment, Sustainability, Government Affairs Kingspan Insulated Panels

Material Transparency

Manufacturing Sites

Kingspan Insulated Panels Inc.

ASM Modular Systems Inc.

Morin Corporation

Tate Access Floors Inc.

North America Locations

Architectural

Commercial & Industrial

Cold Storage

Learning Objectives

1. Better understand EPD data reporting for the purposes of

material evaluation, and specification

2. Review or Fill Out a Health Product Declaration (HPD), why it was

created and what material data is being reported

3. Differentiate data reporting of the other “Declaration” formats

such as the Product Transparency Declaration (PTD), C2C, Declare

4. Assess Health Product Declarations in relationship to other key material evaluation and specification per CSI’s Sustainable Design & Construction Practice Guide and Project Delivery Practice Guide

At the end of the this course, participants will be able to:

[Material Matters]

See: aia.org/materials

COTE definition of sustainability and sustainable design: Measure 8: Materials & Construction

Sustainable design includes the informed selection of materials and products to reduce product‐cycle environmental impacts, improve performance, and optimize occupant health and comfort. http://www.aia.org/aiaucmp/groups/aia/documents/pdf/aias076652.pdf

Shutterstock image

Insurmountable environmental challenges are

converging in arbitrary actions as mandatory assessment in whole

building design, materials and systems that have become part

of the “Building Team’s” responsibility.

Human Health & Material Transparency Trends

“If humankind poisoned nature, nature would in turn poison humankind”. http://www.amazon.com/Silent-Spring-Rachel-Carson/dp/0618249060/ref=sr_1_1?ie=UTF8&qid=1411322878&sr=8-1&keywords=silent+spring

‘Silent Spring’ Ignited the US Environmental Movement

Human & Environmental Health

Impact of Buildings on Occupant Health Has a High Influence on Firm’s design/Construction Decisions (Current and Expected Future by Player)

http://www.aia.org/aiaucmp/groups/aia/documents/pdf/aiab103914.pdf

LEED Materials Retrospect

• Single Attributes • Multiple Attributes • Eco Labels • What’s in materials?

LEED Evolution 1.0 Pilot 2.0 2.1 2.2 3.0 (2009) v4

Material Transparency Certification Classifications

ISO 14021 - Self Declared Environmental Claims, 1999 (Type II labels / declarations) – single-attribute label developed by the producer

ASTM E2129 - 10

Standard Practice for Data Collection for Sustainability Assessment of Building Products

The CSI Product Sustainability Information Reporting Guide

ISO 14024 - Type I Environmental Labelling – multi-attribute label developed by a third party

ISO 14025 - Environmental labels and declarations - Type III environmental declarations - eco-label whose awarding is based on a full life-cycle assessment – (EPD) developed by a third party

Eco-Labels Manufacturers no longer make products;

they make label carriers (Overheard at an ASTM meeting)

http://www.ftc.gov/news-events/media-resources/truth-advertising/green-guides

Material Transparency Influences

What’s in our building materials?

Full Disclosure • Chemical makeup • Environmental Impacts

LEEDv4 - Materials & Resources (MR)

Building Life-Cycle Impact Reduction

• Whole Building LCA Building Product Disclosure and Optimization

• Environmental Product Declaration (EPD) Material Ingredients

• Health Product Declaration, GreenScreen v.1 Benchmark, Cradle to Cradle Certified, REACH

• Raw Material Source and Extraction Reporting o Specify products from manufacturers that can provide reports of raw

materials from their suppliers.

v4

STRONG Support for Material Transparency

Mandatory?

Material Transparency Request Changes

What do these labels mean in material evaluation?

REALLY

INFORMATION

Relative Standards related to Material Transparency

E2129 - 10

E2432 - 11

E2921-13

WK23356 New Practice for Development of Product Category Rules for Use in Development of Environmental Declarations for Building Products and Systems

WK44075 New Practice for Standard Practice for Issuing Product Transparency Declarations

WK35702 New Guide for Evaluation of Environmental Aspects of Sustainability of Manufacturing Processes _____________________________________________________

ISO 14020 series (14020 to 14025) Environmental labels and declarations

ISO 14025:2006 Environmental labels and declarations - Type III environmental declarations - Principles and procedure

ISO 14040:2006 Environmental management -- Life cycle assessment -- Principles and framework

ISO 14044:2006 Environmental management - Life cycle assessment - Requirements and guidelines

European Committee for Standardization (CEN). “EN15804:2012

ISO 21930:2007 Sustainability in building construction -- Environmental declaration of building products

____________________________________________________________________

ANSI/BIFMA Furniture Standards M7.1-2011and e3-2011

IGCC, AIA, ASHRAE, USGBC & IES align to combine green codes into one regulatory tool

In August 2014, AIA, IGCC, ASHRAE, USGBC & IES announced the signing of a memorandum on coordinated evolution of Standard 189.1, the

International Green Construction Code (IgCC) and the LEED green building program.

http://www.usgbc.org/Docs/Archive/General/Docs9246.pdf

http://www.iccsafe.org/cs/igcc/pages/default.aspx

Environmental Impacts End Product Ingredients Mixtures & Components

Single Chemistries Assembly Chemistries ---------------------------

Hazards Only Risk

Exposure

EPDs, LCAs, and PCRs Process based LCA

Product Category Rule (PCR) “Set of specific rules, requirements, and guidelines for developing Type III environmental product declarations for one or more product categories” (ISO 14025)

The Guidelines

Life Cycle Assessment (LCA) “Compilation and evaluation of the inputs, outputs and the potential environmental impacts of a product system throughout its life cycle” (ISO 14040)

The Analysis

Environmental Product Declaration (EPD) “Providing quantified environmental data using predetermined parameters and, where relevant, additional environmental information” (ISO 14025)

The Declaration

Graphic Provided by ThinkStep (PE International)

PCRs – Product Category Rules

An Assembly PCR PCR for multiple Insulations

EPD and ISO 21930

The overall goal of EPDs is to encourage continuous environmental improvement

An EPD of a building product provides information for the assessment of the environmental performance of buildings ISO/TS 21931-1

5.6 Comparability of EPD of building products • Comparison of building products using EPDs shall be carried

out only at the building level

What is EN 15804?

When developing a PCR Step 1. research globally for established PCRs BS EN 15804:2012+Amendment 1:2013 Sustainability of construction works. Environmental product declarations. Core rules for the product category of construction products

How are European PCRs to be considered in LEEDv4?

Types of EPDs

Product Specific

Industry Wide

Series of Gate to Gates +

Specific Product aggregated Cradle to Gate

Industry

Gate

to Gate

Industry

Gate to Gate

Industry

Gate to Gate

End Product

Processes

Cradle

to Gate

LCA

Product PCR

Product EPD

Steel Slab to Steel Coil Production

Galvanizing of Steel Coils

Types of Chemistries*:

•Zinc phosphates/activators

•Iron phosphates

•Chrome chromates

•Chrome phosphates

•Chrome dry-in-pace treatments

•Complex oxide treatments

•E-CLPS® chrome-free pretreatment technologies

•Tri-CLPS® RoHS compliant passivations for HDG and galvalume

•Metal passivations

•Acrylic fingerprint-resistant coatings (clear or tinted) * Depends on the supplier as to which of these chemistries are used

Steel Coil Coating Process

Fluropon coatings are durable Polyvinyldene coating system containing 70% Kynar or Hylar resins ceramic and other inorganic pigments Provides a powerful chemical bond, and superior resistance to ultraviolet radiation Primer

IMP Production Process

Polyiso Chemical Components per EPD MDI, Polyol, HCFC Free Blowing Agent, Flame Retardant, Catalyst

Packaging/Wrapping: Plastic Wrap, either recycled Polyiso, sheets or EPS foam

Lamination Adhesive

Chemicals are applied and reacted in controlled environment per EPA and OSHA requirements

Note: All Coils are galvanized and coated BEFORE coming to the

IMP Process Line

ISO 14025 - Environmental Type III environmental declarations

Overall goal of environmental labels and declarations is to encourage the demand for, and supply of products that cause less stress on the environment

• Type III EPDs are primarily intended for use in business-to-business communication, but their use in business-to-consumer communication is not precluded

UL 3rd Party EPD 2 page Transparency Briefs

• Reporting of Environmental Impacts per ISO and relevant Product Category Rules

• An EPD is a simplified, consistent report for a LCA

Product EPDs Carry Burdens of All Upstream Impacts

Challenges in EPD Comparisons

One PCR and relative EPD

Multiple PCRs & EPDs

Single assembly with steel exterior/interior skins, air &

moisture barrier + insulation

What is an article?

For the purpose of CDR reporting, an “article” is defined at 40 CFR 704.3 as:

“Article” means a manufactured item (1) which is formed to a specific shape or design during manufacture,

(2) which has end use function(s) dependent in whole or in part upon its shape or design during end use, and;

(3) which has either no change of chemical composition during its end use or only those changes of composition which have no commercial purpose separate from that of the article, and that result from a chemical reaction that occurs upon end use of other chemical substances, mixtures, or articles;

EPD Comparative Analysis EPD Comparative Assertions ISO 14025

MCA has conducted life cycle assessments to quantify and report the environmental impacts (EPDs) of its products.

Comparative analysis of environmental performance of its members’ products when used in building envelope assemblies, compared to other functionally equivalent assemblies

For the purposes of making Comparative Assertions

LCA Databases & Tools

Integrates with REVIT

http://www.athenasmi.org/our-software-data/impact-estimator/

http://choosetally.com/download/

What is NOT currently in an EPD

Required Impact Reporting • Resource Consumption

o (e.g., energy, water • Emissions to air, water, soil • Climate Change • Ozone Depletion • Acidification of Land& Water • Eutrophication • Photochemical oxidants

formation • Depletion of Abiotic

Resources o Fossil Energy o Minerals

• Optional Impact Reporting – Biodiversity

– Human and/or Environmental Toxicity

– Geographical Aspects

– Product Environmental Performance

– Other Environmental Certifications

– Recycling or Recovery Programs/Activities

– Instructions for Limits and Use

– Human and/or Environmental Hazard and Risk Assessment

– Environmental Significant Materials

– Preferred Waste Management Option

– Potential for Incidents that Impact the

Environment

Based on given Product Category Rules

4/29/2015

HPDs attempt to address these issues – Human Heath Focus – HAZARD ONLY REPORTING

– Developed by HPD Working Group • Support of the Materials Research Collaborative, a non-profit collaboration of

the Healthy Building Network and BuildingGreen

– As volunteer effort could bypass chemical regulatory policy obstacles in more robust reporting

– MSDS not considered enough information for material selection or deselection

– Development of an “Open Standard” without ANSI certification

Toxicities and Hazards of materials not currently reported in EPDs

Why Health Product Declarations?

39

Paul Bertram, FCSI, CDT, LEED AP – BD&C, GGP

Director: Environment, Sustainability, Government Affairs 386-785-3063 – [email protected]

Questions

Provided by HPD Collaborative

The Wrong Way • Ask suppliers for each ingredient’s

chemical name and CAS number

• Suppliers often can’t or won’t disclose an ingredient’s identity

• Lacking any information about the ingredient, you are stuck with an HPD that doesn’t qualify for LEED credit because it can’t claim Full Disclosure of Intentional Ingredients

The Right Way • Ask supplier for each ingredient’s

chemical name and CAS number – if they are unable or unwilling to share, ask for the generic material type

• If they’re using Ethoxylated-

2,4,7,9-tetramethyl-blah-blah they may be willing to share the generic material name ‘surfactant’

• Some generic materials exist in the material database of choices

Building an HPD – Data Collection

The Wrong Way • Enter each raw material as intentional

ingredients

• If the individual chemicals or materials undergo a physical change, they may no longer exist in the final product

• For example, Polyurethane foam is commonly made from MDI, polyol, blowing agent, and catalyst. The hazards associated with these ingredients in isolation are very different after they’ve been reacted into Polyurethane foam.

The Right Way • Identify the product’s composition as it

exists on the jobsite

• If chemical reactions happen at manufacturing, only the final product should be listed

• Chemical reactions that happen en-route to the jobsite (e.g., in a concrete mixer truck) or at the jobsite (e.g., spray foam) must be listed as the sum of their individual components

Building an HPD – Hazard Identification

The Wrong Way • Enter all the information you have

then publish the HPD

• Certain ingredients may need to be renamed or grouped together (e.g., as ‘additives’) to protect IP

• Some hazards shown are likely irrelevant to the customer, especially when hazards are related to workplace exposure during manufacturing

The Right Way • Revise the names of ingredients if

necessary to protect IP, while leaving hazard information intact

• Use a narrative to describe why certain hazards are irrelevant or if you protect the customer against them

Building an HPD – Completing the HPD

MSDS & SDS Reporting Global Harmonization

HPD 2.0 Still Hazards ONLY Report

Titanium Dioxide

GreenScreen® For Safer Chemicals

Comparative SINGLE Chemical Hazard

Assessment (CHA) for identifying chemicals of high concern and safer alternatives.

Assessing chemical hazards

• Pharos researches the chemistry for substances in their listed products, and screen for hazards

Chemical assessment with Pharos

requires a LEEDv4 credit interpretation

http://www.pharosproject.net/blog/detail/id/175/greenbuild-2013-features#sthash.Resf0FSh.dpuf

4/29/2015

C2C Certification

http://www.c2ccertified.org/images/uploads/C2CCertified_Banned_Lists_V3_121113.pdf

Banned List of Chemicals for Technical Nutrients

More Material Transparency

The Healthy Materials Program criteria is based on the Health Product Declaration, GreenScreen, and Cradle to Cradle and is aligned with the LEED version 4 rating system.

• 2006 - 2015 by Healthy Building Network & Google

4/29/2015

August 20, 2013 Report of the Material Health Harmonization Task Group

HAZARD BASED

Material Health Evaluation Programs Harmonization Opportunities Report

http://www.usgbc.org/sites/default/files/material_health_evaluation_programs__harmonization_opportunities_130819.pdf

4/29/2015

Material IQ

55

BETA Program with BIFMA

4/29/2015

Performance-focused system for measuring, certifying, and monitoring features of the built environment that impact human

health and wellbeing

Delos WELL Certification

56

http://nowinteractive.net/delos-downloads/WBS-Executive%20Summary-Apr2014.pdf

THE WELL VITAL SIGNS SCORECARD

WELL Building Standard®

The WELL Building Standard® is 3rd party certified by the Green Building Certification Institute (GBCI) – Renamed Green Business Certification Inc.

http://www.wellcertified.com/standard

LEED 3.0 extended until October 2016

A Bar to High?

Hazard assessments evaluate ONLY the toxicological effects of a chemical or product, Typically tested at very high (i.e., worst case) exposure levels/dosages.

DO NOT consider use conditions (Risk) or exposure levels GreenScreen determines a product formulation based upon a single attribute

(i.e., toxicological effect) Risk assessments are based upon the premise that all substances are hazardous, but “the dose

makes the poison” – i.e., safe levels of usage/exposure can be determined

Risk & Exposure of an IMP

Assembly on EXTERIOR

Foam insulation reacts in controlled factory environment

Chemical make up of foam encapsulated between impervious steel skins

Pre-coated when delivered to factory for assembly

As reported in EPD

Code required Fire performance with Flame retardant

Non- Halogenated Flame retardant option

4/29/2015

PTD Product Transparency Declaration

This standard provides requirements for publishing a Product Transparency Declaration including : (1) Listing of product ingredients (2) Product ingredients identified as hazards (3) Warning label requirements for finished building materials (4) Intentionally added heavy metals (5) VOC emissions and VOC content information (6) Recycled content and (7) environmental certifications.

This practice shall include all building products incorporated in a building.

http://www.astm.org/DATABASE.CART/WORKITEMS/WK44075.htm

4/29/2015

WASHINGTON, DC - (August 27, 2014) – The U.S. Green Building Council (USGBC) and the American Chemistry Council (ACC) announced a new initiative … … designed to ensure the use of sustainable and environmentally protective products in buildings by applying technical and science-based approaches to the LEED green building program.

USGBC Supply Optimization Working Group

“According to Environmental Building News, what is new is that the ACC has returned with the prediction that “risk assessment” will now receive “greater consideration throughout USGBC’s process.” If so, the result will be unequivocally negative for LEED, which currently favors “hazard-based” approaches to reducing unhealthy chemicals in the built environment.” Bill Walsh - September 3, 2014

http://www.healthybuilding.net/news/2014/09/03/truce-or-surrender-at-usgbc

Precautionary Principle

vs. Approach

Shadow Regulatory Action

4/29/2015

Building Product Disclosure and Optimization— Material Ingredients

4/29/2015

Environmental Defense Fund blueprint for safer chemicals

1.Institutional Commitment: corporate chemicals policy and solid. 2.Supply Chain Transparency: Know the chemicals used to make products. 3.Informed Consumers: Transparency meets customer demands for increased product safety and sustainability. 4.Safer Chemicals Plan: A roadmap for using safer chemicals and phasing out hazardous chemicals. 5.Public Commitment: Communicate the company’s policy, timelines and progress — successes and pitfalls — towards safer chemicals http://www.environmentalleader.com/2015/04/28/5-steps-to-safer-chemicals-in-products/#ixzz3Yds9Bc5O

What the “Chemical” Professionals Recommend

You can’t prove safety – can only reduce risk

Majority of Architects & Specifiers do not understand risk or material hazards

Informed choices, options and trade-offs need considered

Provide information to qualified assessors to make informed choices based on what has greater importance, weight, value to them.

• Information will be needed on multi-attributes (i.e. not just hazard)

Shift focus from “Safer” to “Informed” Choices

4/29/2015

What you need to know

Alternative Assessment (AA) Frameworks

AA Framework

Characteristics Attributes Included in AA

Performance/ Cost

Hazard Exposure Life-Cycle Considerations

Social

Coalition Green Chemistry AA Coalition Document Principles of Alternatives Assessment 2012

Framework considers various trade-offs within a sustainability setting (e.g. hazard, risk, LCA implications)

X

X

X

DTSC 2012 AA workshop tables

Describes tools, data sources and methods for hazard, exposure, and life cycle (environmental, cost and social) assessment. AA methods/frameworks and other background are cited.

X

X

X

X

X

Lowell Alternatives Assessment Framework 2006

The framework is designed to evaluate and identify environmentally and socially preferable alternatives.

X

X

X

X

X

UBA Guide Sustainable Chemicals

A decision tool for manufacturers, formulators and end users of chemicals. Designed to assist in the selection of sustainable chemicals

X

X

X

UCLA Developing Regulatory AA Methodologies

Decision making framework. Evaluates the application of two primary MCDA (multi-decision criteria analysis) tools - multiple attribute utility theory (MAUT) and outranking - were investigated.

NA

NA

NA

NA

NA

UCSB Safer product alternatives analysis report 2011

Compendium of publically available tools, methods and data sources that relate to AA, and relevant background information.

TAAG Alternatives Assessment Guidance document

Coalition led by Washington State Department of Ecology to development guidance on alternatives assessment for chemicals.

X

X

X

X

X

Provided by DOW Chemical

4/29/2015

Pathways for Option 3

Third party audits and certification are a normal part of Responsible Care® and ISO 14001 chemical management systems

Led to Halogenated FREE Flame Retardant Option

4/29/2015

Chemical Compliance Systems, Inc GreenSuite

GreenSuite is currently the only risk assessment tool supported by hazard data for 44 ecological, health and safety endpoint criteria defined in NSF/GCI/ANSI 355

Alternative Assessment

ASTM WK40619-1 Use of Alternatives Assessment Data in Making Chemical Selection Decisions Across the Product Life Cycle (Guide)

General principles can vary by framework but often place heavy emphasis on hazard traits with additional attributes including • Technical Performance,

Feasibility/Cost • Hazards (human &

environmental) • Lifecycle Considerations • Social Justice

Building Science & Material Transparency

Human Health has been positioned as most important criteria in material evaluation and specification

What are the Trade-OFFs that need considered? • Interior vs. Exterior, Functional Performance and

Compliance…

Shutterstock image

Architect

Specifier

Material Scientist

Biologist/Microbiologist

Certified GreenScreen analyst

Chemist

Toxicologist

Industrial Hygienist

Clinical Scientist (Doctors)

Who is REALLY Qualified to be an ASSESSOR?

CSI’s Role in Balanced Material Evaluation & Specification

How should data with known “UNCERTINTIES” be weighted in material selection – deselection decisions?

How are MSDS, SDS, EPDs, and HPDs handled in the Submittal Documents?

Specifying EPDs, HPDs & Material Transparency

Discouraging bidding by specifying unrealistic LEED requirements

Not recognizing that performance is a sustainable attribute

Calling LEED “good enough”

Not discussing Trade-Offs

Use Common Sense Design Strategies

http://www.masterformat.com/numberstitles/

Climate Change and Health

Reduction of GHGs and Health

Talk to your manufacturers

Summary

Should CSI consider greater engagement in this discussion? • Information requested and used today is not adequate to

guide choices/selection of “greener” alternatives

• How does this information impact project specifications?

o EPDs & HPDs are collected with little understanding on how to use for evaluation

• What are associated liabilities?

Opportunities

• Focus more on type of information needed to make “greener” choices less on tools

oBalance material selection/deselection while considering Human Health

Leverage current/exiting safety assessment methods/advancements to quickly identify priorities and eliminate unnecessary information

Paul Bertram, FCSI, CDT, LEED AP – BD&C, GGP

Director: Environment, Sustainability, Government Affairs 386-785-3063 – [email protected]

Questions