What if a New PCR is Required?
The PCR is a key element of the EPD development process. It specifically defines the information that is to be reported to ensure that an EPD accurately reflects a product’s environmental impact. The PCR provides a model for the rest of the actions related to the development of an EPD.
Under the requirements of ISO 14025, an existing PCR is to be used whenever a suitable one is available. The intent of these requirements is to facilitat the global harmonization of PCRs and eliminate duplication of effort. For these reasons, program operators and other parties involved in the creation of PCRs are required to maintain publicly available lists of the PCRs the create, so that other parties can easily determine whether an existing PCR is suitable for use in the development of an EPD.
However, because there are currently relatively few publicly available PCRs, the development of an EPD will often require the creation of a new PCR. Of the steps involved in the PCR development process, the most crucial is the open consultation procedure that takes place around the draft PCR. Similar to the consultation process already used in the development of industry standards, the important aspects of the open consultation procedure in the development of PCRs are found in the following sections.
Identifying the open consultation participants
Any interested party that has specific questions about a PCR or wishes to comment on the document is allowed to participate in the open consultation procedure. The parties may include material suppliers, manufacturers, trade associations, purchasers, users, consumers, nongovernmental organizations, public agencies, LCA practitioners and certification bodies.
Inviting parties to take part in the open consultation
The program operator preparing a draft PCR is responsible for posting the draft document on a publicly accessible web site, and alerting interested parties regarding its availability for discussion and comment. A mechanism should be provided so that participants can submit comments for consideration.
Addressing the comments received and modifying the draft PCR as necessary
Following changes or amendments to a draft PCR, a program operator submits a final version of the PCR to a review panel for approval. The program operator should also prepare a short summary of the comments received through the open consultation procedure and the resulting changes to the draft document.
The Role of the EPD Program Operator
All Type III EPD programs are guided by the requirements set out in ISO 14025. According to the standard, a program operator is responsible for the administration of the entire EPD program, therefore playing a significant role in the program’s effectiveness and acceptance.
As defined in ISO 14025, section 8.0, a program operator’s responsibilties include, but are not limited to, the following tasks:
• Preparing, maintaining and communicating general program instructions
• Publishing the names of entities involved as interested parties in program development
• Ensuring that all environmental declaration requirements are followed
• Establishing procedures to ensure the consistency of all collected data
• Publishing PCR documents and Type III environmental declarations developed under the program and maintaining publicly available lists of those documents
• Monitoring procedural changes in other environmental declaration programs and revising procedures and documentation as necessary
• Selecting competent, independent verifiers and PCR review panels (according to 8.2.3 of the ISO standard)
• Establishing a transparent process for PCR reviews, including the review scope and the composition of the PCR review panel (according to 8.1.2)
One of a program operator’s most important responsibilities is determining whether an existing PCR is sufficient for the assessment at hand or if the development of a new PCR is required. In cases when a new PCR is deemed necessary, a program operator should make every effort to facilitate harmonization with similar documents by adopting content from existing PCRs in the same product category. Efforts to achieve harmonization with existing PCRs, and the reasons for not adopting available content, should be documented in any new PCR.