Raising the Bar
By Daniel Overbey
A new partnership between the USGBC and UL sheds light on product transparency.
Mikhail Davis, director of restorative enterprise at Interface, explains it was not until the company adopted a life-cycle approach to sustainability that the true impacts of Interface’s products could be understood. Photo: Huntsman Architecture
It has been 15 years since the U.S. Green Building Council (USGBC) launched the Leadership in Energy and Environmental Design (LEED) green building rating system. That first year, 51 projects participated. Today, LEED is the most widely recognized green building program in the world, guiding the design, construction, operations, and maintenance of over 68,000 projects globally.
With the emergence of LEED, USGBC’s mission of market transformation took the first steps toward realization. Credits for single-attribute building products featuring recycled content, certified wood, or regional sourcing prompted manufacturers to not just divulge such characteristics about their products, but also to make the information easy to find. Today, manufacturers of building products routinely offer lists of green attributes through convenient resources.
As the market for green building products continues to evolve and improve, it is clear that LEED must continue to lead if it is to remain relevant. Enter the rating system’s latest update—version 4—where credits have been revised to ensure that they truly add quality to the utility of a project. In the case of building products, this means going beyond crediting single-attributes and toward an integrative life-cycle-based framework by encouraging manufacturers to disclose information about the materials that comprise their products—enabling practitioners to make better decisions.
For well over a decade, Interface—a global manufacture of commercial carpet tile—has offered customers products with single-attribute “green” characteristics, like recycled content. Yet, Mikhail Davis, director of restorative enterprise at Interface, is quick to point out that it was not until the company adopted a life-cycle approach to sustainability that the true impacts of Interface’s products could be understood. In fact, Interface learned that increasing the recycled content could actually increase the environmental footprint of their products if they did it wrong. “Life-cycle assessment gave us a way to model changes to our products in advance to see if they would move the needle in the right direction, rather than creating unintended new impacts, perhaps at a less visible stage of the product life-cycle.” Interface’s early efforts to put recycled content in their products focused on the backing, the component they make themselves. “But a life-cycle assessment showed us that until we got our nylon suppliers on board, we were not going to be able to seriously shrink our impacts,” explains Davis. In 2011, years of supplier engagement bore fruit in the form of the company’s first 100 percent recycled content nylon yarn products, which have a dramatically lower environmental footprint.
The transformative potential of disclosing the life-cycle environmental impacts of building products is not lost on USGBC. One of the ways LEED v4 encourages life-cycle-based decision-making is by crediting projects for using products with fully disclosed ingredients. The most popular reporting tool through which a product’s life-cycle impacts are conveyed is called an Environmental Product Declaration (or EPD). These are comprehensive, internationally harmonized documents through which manufacturers can provide transparency about their products’ ingredients. Think of EPDs like the nutrition facts label on the side of a box of cereal—only for building products. In the case of LEED v4, eligible EPDs must be third-party reviewed and certified.
EPDs are not new. They have been around in Europe since the 1990s. However, only since USGBC took a bold stand on product transparency with LEED v4 has the EPD marketplace blossomed domestically—a testament to LEED’s ability to shift the market. “EPDs have experienced an explosive level of growth. Five years ago, one would be lucky to find 10 or so EPDs, whereas now there are close to 300 to 400 EPDs, when considering all the North American programs,” states Paul M. Firth, product manager at UL Environment, a division of Underwriters Laboratories (UL).
Manufacturers will be able to develop and certify EPDs with LEED-specific criteria in mind, thus providing their products a differentiator in the marketplace.
—Paul M. Firth
LEED v4 uses EPDs as a tool to promote product transparency, but it also encourages project teams to use the information to make better choices about building products and, consequently, optimize the life-cycle environmental impacts of a project. This is easier said than done in a burgeoning EPD marketplace. The reality is that the market has not quite matured to the point that EPD comparison and product optimization is widely practical. There are a few particular obstacles to greater market uptake. Confusion abounds regarding the usefulness of EPDs; they frequently offer incomparable information; and program operators (the entities that oversee EPD development) are not regulated by consistent standards.
In order to overcome these obstacles and accelerate market transformation, USGBC and UL Environment entered into an exclusive partnership just over a year ago. The partnership is focusing on building materials and product transparency.
The leading program operator in North America, UL Environment is uniquely positioned to facilitate USGBC’s work through LEED. “We decided to partner with UL because they have demonstrated they can produce and deliver high quality EPDs,” says Sara Cederberg, technical director at USGBC. With over 120 years of experience with manufacturers in industries ranging from electronics and consumer products, to the automotive industry, UL understands the challenges that companies face.
Prior to LEED v4, the organic nature of market activity related to building product life-cycle assessment allowed manufacturers to engage substantively in the creation of a broad range of tools with varying degrees of oversight. Transformation and innovation was decentralized. The trade-off was significant confusion and a slow rate of market maturity.
Acknowledging the confusion, one of the first things to be addressed by the USGBC/UL Environment partnership will be EPD delivery. “We’re starting with EPDs because that’s an area where the consistency and credibility are currently a bit problematic,” explains Firth.
UL Environment ensures that all of their EPDs conform to international standards. However, they go a step farther by delivering a concise transparency summary, which essentially serves as an EPD executive summary. The summaries are usually just a few pages, making essential data more palatable to practitioners. Interface—the first North American company to deliver an EPD—has worked closely with UL Environment for a number of years and understands that the market success of EPDs will hinge on content delivery. Davis states, “We worked with UL Environment to develop the transparency summary format because we understood that EPDs will not increase product transparency if the important EPD facts like material ingredients or carbon footprint are too difficult to find.”
Through a joint EPD program, USGBC and UL are endeavoring to bring a clarity commensurate with the UL transparency summary to the EPD marketplace at large. The belief is if project teams are presented with a succinct and coherent EPD format, then a multi-attribute framework for building product choices may be leveraged more successfully.
The real value in promoting transparency is exposing the detrimental environmental impacts over the creation, usage, and disposal (or reuse) of a product. LEED v4 encourages teams to go one step farther by using the information about the impacts in order to optimize product selection. EPDs are useful because they present life-cycle performance information through numerous distinct environmental impact categories. The problem is that the categories—such as acidification of land and water sources, formation of tropospheric ozone, and eutrophication—are somewhat esoteric and measured in complex units that vary considerably based on which method is adopted for the life-cycle assessment (LCA). Firth affirms, “Ultimately, the goal is to be able to use these EPDs to compare products—currently they are not quite ready for this.”
EPDs simply report the results of an LCA. To the extent that LCAs for similar products may be scoped differently, one can look to the “rules” defining their respective assessments—termed product category rules (PCRs). “In order to produce high quality EPDs, we must first provide robust product category rules,” Cederberg explains. There are a handful of PCR guidance documents available internationally, but they are open to a wide range of interpretation.
To establish greater consistency, USGBC and UL Environment are exploring a common PCR development framework that addresses the aspects of inherent variability in PCRs to date. “One of the reasons the USGBC/UL partnership was launched is to try to help narrow in on those aspects of LCAs, PCRs, and EPDs that need to be refined to best provide information necessary to make an informed comparison,” states Firth.
All Type III (third-party verified) EPDs require an independent agency, called a program operator, to ensure that EPDs are developed in accordance with international standards.
According to USGBC’s Cederberg, another important piece of developing a quality EPD is ensuring the program operator is experienced and credible. “Just like we look for credentials for commissioning agents or require labs to be accredited for testing low emitting materials, so too would we want to be sure that there is a level set for program operators.” The USGBC/UL Environment partnership is in the early stages of developing such criteria.
The intended outcomes of the USGBC/UL Environment partnership focus on the coherence, consistency, and technical rigor of the EPD development process. This in turn will accelerate the rate of market transformation and improve the overall quality of transparency in the building product market sector.
Considering past successes in shifting the marketplace, it makes sense that LEED could serve as a vehicle for greater market transformation. Firth suggests, “Manufacturers will be able to develop and certify EPDs with LEED-specific criteria in mind, thus providing their products a differentiator in the marketplace.”
Davis attests that rigorous product transparency holds the promise of incentivizing manufacturers to take on the tough challenges that will really improve their products, rather than doing just enough to make a product claim. “For example, we could claim recycled content using recycled mineral fillers in a product, but EPDs show that only when we replace high-footprint plastics like nylon with recycled or biobased substitutes can we really reduce our impacts.”
The promise of the partnership, however, goes far beyond LEED. Armed with consistent declarations and comparable data, a more sophisticated marketplace may be able to aggregate building product data to achieve environmental building declarations. Practitioners may eventually be able to optimize impact categories through building information modeling (BIM). It is even conceivable that building occupants will someday be able to observe real-time impacts on a dashboard, such as the LEED Dynamic Plaque.
The USGBC/UL Environment partnership sends a clear message to the marketplace—the stakes for product transparency have just been raised.