Are EPDs Required?
EPDs have been used extensively for years, mostly in the European Union (EU) and in Japan. In France, for example, the government-backed Environment Round Table (Le Grenelle Environnement) has proposed that all high-volume consumer products imported into the country be accompanied by an EPD.2 In the United Kingdom, the Building Research Establishment Environmental Assessment Methodology (BREEAM) currently encourages the use of EPDs as a guidance tool to help licensed assessors select green building products.3 Outside of the EU, Masdar City, a large scale eco-city project in Abu Dhabi, is encouraging the use of EPDs and LCAs to use to evaluate the products used in its construction.4
Although regulators in the United States, both federal and state, do not currently require EPDs, purchasing mandates may create de facto requirements for manufacturers and producers. A key example is Executive Order 13514,5 issued by U.S. President Obama in October 2009 that requires U.S. federal agencies to “leverage federal purchasing power to promote environmentally-responsible products and technologies.”6 It is expected that the U.S. General Services Administration (GSA) will incorporate compliance with standards for sustainability and EPDs as a factor in government purchasing decisions in 2012 or 2013. With annual expenditures approaching nearly $6 trillion annually, such a move by the U.S. federal government could very well speed the acceptance and use of EPDs by private industry.
Even in the absence of national regulations, the use of EPDs is often driven by initiatives within individual industries. For example, the United States Green Building Council (USGBC) has contributed to the increased interest in the use of EPDs in the U.S. building industry through a pilot credit proposed in June 2011 under its Leadership in Energy and Environmental Design (LEED) program for projects utilizing products that are accompanied by an LCA or EPD. The second draft of the LEED rating system, slated for release in 2012, is expected to adopt the credit for “non-structural materials transparency,” and will likely result in the global adoption of the credit through the more than 50 national green building councils that make up the World Green Building Council.
In the short term, it is likely that buyer requirements and industry norms, rather than regulations, will continue to drive the expanded use of EPDs in the United States. While this may provide manufacturers and producers with some flexibility regarding the adoption of EPDs, shifts in market demand are likely to occur much more quickly and with less advanced notice than formal regulations. Companies that demonstrate leadership by adopting EPDs will drive all industry participants to embrace the process to remain competitive.
The following sections provide a brief explanation of each of the five steps for developing an EPD.
Select the appropriate product category rule (PCR)
PCRs describe the scope and methodology for performing an LCA, the data foundation for an EPD, and provide detailed requirements for additional environmental and health information disclosure. Therefore, the first step in creating a compliant EPD is to find an applicable PCR for a particular product. When an appropriate PCR does not exist, a new PCR must be developed and approved for use through a credible EPD program operator.
Conduct and verify the product life cycle assessment (LCA)
A range of factors is used to assess a product’s environmental performance. Such factors include energy and resource consumption, waste generation, pollutant emissions, impacts during use, and end-of-life considerations. An LCA provides a structure for identifying and assessing these and other factors. Once an LCA is conducted on a particular product, it must be verified by an independent party to determine that it meets the requirements defined in the product category rules.
Compile the EPD
Once the applicable PCR has been identified or developed and an LCA completed and verified, an EPD can then be prepared. The EPD presents the results of an LCA as well as additional information about the product’s performance and other sustainability information.
Verify the EPD
When an EPD has been completed, it must be submitted to an independent third-party for a thorough review and verification of the results presented and any additional information supplied. This step is normally conducted through an EPD program operator.
Register the EPD
The last step in the process of creating an ISO 14025-compliant EPD is the submissions of the final document to an EPD program operator for registration and inclusion in the operator’s published list of EPDs.