Opinion: HPDs in the Context of Company-Wide Environmental Management

There has been a lot of discussion and resistance about these credits by design teams and building product manufacturers. Making decisions on strategies to consider material transparency in response to these demands must be better understood and reconsidered. In particular, it’s important that the design community and manufacturers find a way to fit material transparency into existing frameworks manufacturers are already using for continuous improvement.

Transparency can’t happen in a vacuum

Having worked in the material evaluation and specification space for 37 years provides me unique insight into continuous improvements to building products. These improvements have been advanced over the years by a number of influences, which include:

• environmental and other government regulations
• building codes
• customer-driven performance requirements
• economic factors
• industry association alignment
• green building certifications
• changes in the supply chain
• product market differentiation
• legal liabilities
• insurance
• best business practices
• employee, community, and global relations.

All of these factors are in play while producing products that must meet specifiable performance and compliance requirements that take years of development and approvals.

Environmental management as a model

Long before LEED requirements for environmental and social impacts of manufacturing were considered, ISO 14001 provided manufacturers a roadmap to an effective environmental management system (EMS). When properly applied, an EMS allows a manufacturer to identify, prioritize, and manage aspects of its operations covered by environmental regulations as well as those that extend beyond legal requirements.

Many companies already have these environmental management systems as well as health and safety management systems, such as OHSAS 18000, in place.

As a result of these systems, life-cycle assessments (LCAs) have been around for many years. LEED has definitely been a key influence, but it is not the only reason to conduct an LCA. LCAs are conducted for the purpose of continuous improvement. Because LCAs and the related summaries, EPDs (environmental product declarations), have already been widely adopted and are now guided by ISO standards, their inclusion in LEED v4 is less contentious than inclusion of Health Product Declarations (HPDs).

HPDs can fit into existing frameworks

Where the challenge in LEED v4 becomes problematic for many manufacturers and their supply chains is LEED recognition of reporting formats such as the Health Product Declaration (HPD), a standard reporting format that is not a recognized industry standard.

The HPD is also asking for information that many product manufacturers cannot provide without input from their supply chain. There is great resistance from the supply chain to provide this deep-tiered information. Their concerns include:

• proprietary formulations
• uncertainties about legal liability and risk
• potential use of the information for material selection or deselection based on chemical ingredients

Some design professionals are also worried about liability. (Editor’s note: See our coverage on legal liability in this issue.)

Meanwhile, EMS programs and certifications already provide the structure to begin comprehensive objectives and strategies for managing:

• chemical inventories of ingredients
• assessment of alternatives and comparables
• chemical risk assessment
• energy and environmental impacts

Incorporating well-established standards such as ISO 14001 for EMS and ISO 14044 for LCA can provide assurance to company management and employees as well as external stakeholders that environmental impacts and human health are being measured and improved.

These ISO standards can also be integrated with other management functions and assist companies in meeting their environmental and economic goals. Full disclosure of ingredients would likely require expanding the scope of an EMS program.

As an example of this type of effort in the context of the market, Kingspan completed an alternatives assessment on its foam insulation products in 2013 and became the first manufacturer in the industry to offer a polyisocyanurate option free of halogenated flame retardants.

Industry is greatly challenged in being able to deliver all the current, fragmented efforts in transparency reporting. Many manufacturers want to see a set of coordinated, science-based, consensus standards to better clarify risk and exposure.

In the meantime, Kingspan is asking for conversations with project teams on product selection and deselection based on chemical reporting that goes beyond functional performance and regulatory compliance.

Paul Bertram is Director: Environment, Sustainability, Government Affairs at Kingspan Insulated Panels.