Opinion: Orwellian EPDs Ignore the Worst Impacts of Wood, Vinyl
Although life-cycle assessment has great promise, in the wrong hands it can be used for greenwashing.
by Jason Grant
Jason Grant is the director of Greenwash Action.
Image courtesy Jason Grant Consulting Life-cycle assessment (LCA) and environmental product declarations (EPDs) are touted as comprehensive, objective sustainability assessment and reporting tools—and indeed they have their merits. Among their strengths is that they deal with things that are more or less precisely measureable.
But results produced by LCA are only as good as underlying data, methods for calculating impacts, and rules for what impacts must be disclosed—and how—in the related EPD.
Sometimes critical impacts are not addressed in EPDs. For example, the ecological impacts of different forms of land use, such as logging and agriculture, are ignored in most EPDs. So are the health impacts of toxic chemicals.
In other words, despite assertions by LCA promoters, as things stand today, LCA is not truly comprehensive.
A wood EPD that doesn’t address forest management
The unfortunate fact is that certain industries benefit from (and appear to actively exploit) blind spots such as these. Take, for example, this EPD for North American softwood lumber.
Prominent on the first page is a claim that the LCA study covers all processes, including forest management. The average reader may assume that it covers all forest management impacts, but it doesn’t. The most significant impacts of industrial forestry—including but not limited to harm to forest ecosystems, biodiversity, and soil and water quality—are not addressed, a critical omission that is not mentioned in the EPD.
What many regard as the most important impacts underlying forest products—namely, those arising from logging—are simply not considered. This not only hides major impacts but also paints all forms of logging as having the same environmental profile, regardless of whether the logging practices are low-impact or highly intensive.
A vinyl EPD that doesn’t mention toxicity
Or consider this EPD for PVC pipe. It leads with a statement that the “PVC pipe industry recognizes the benefits of communicating credible, science-based and transparent environmental information about its products.” But nowhere does the EPD mention the serious threats to the health of humans and other animals related to the manufacture and disposal of PVC.
The conclusion is obvious: in the wrong hands, LCA and EPDs can be used to greenwash rather than reveal the most serious environmental and health impacts of certain products and materials. To do this in the name of science and full disclosure is nothing less than Orwellian.
LCA and EPDs hold great promise—but reform is needed so that their potential can be realized.
Jason Grant is the director of Greenwash Action, an initiative with roots in the environmental community whose mission is to defend leadership and challenge greenwash in the green building sector. He is also the principal of Jason Grant Consulting, a consultancy focused on serving the ecological forest products industry.
Grant, J. (2015, August 3). Opinion: Orwellian EPDs Ignore the Worst Impacts of Wood, Vinyl. Retrieved from https://www.buildinggreen.com/op-ed/opinion-orwellian-epds-ignore-worst-impacts-wood-vinyl
I agree with Jason's assessment of EPDs and would add an additional observation.
One LCA practitioner told me that even when they are following a specific PCR, the results can be expected to be +/- 10% accuracy. Another practitioner said that, in the case of wood products, the accuracy (or inaccuracy) can be as much as +/- 1000%, if on-the-ground forestry impacts are taken into consideration.
As designers, we are used to looking at an ASTM standard for two similar products and making a decision based on the numbers reported. One cannot do this (yet) with EPDs given their level of inaccuracy. Perhaps one day individual companies will be issuing EPDs that report their carbon footprint down to the level of an individual manufacturing facility. I would love to be able to specify a product knowing that it was carbon neutral, but until then I have to assume that EPDs are very general, generic, and mostly industry marketing tools.
I'm not sure about that 1,000% number, but it does depend on the quality of the PCR. There is no real standard for PCR quality, and to the extent that there is a standard, there is no one to enforce it.
I would say, though, that ASTM standards can be gamed as well. And very much are! They also tend to be for one very tiny aspect of performance, such as R-value. But if you followed our research on the temperature-dependent R-value of insulation, you can see that ASTM standards aren't straightforward. There are a lot of ways that even these slivers of information get their hairs split by manufacturers during every stage from test setup to results reporting. This goes for VOC emissions, permeance, textile durability, and every other thing that there are standards for.
For non-biobased products, embodied carbon is probably the most reliable number you will get out of an EPD. But can you trust the carbon number in a wood product EPD? I am not so sure about that. The science, as I understand it, is still evolving.
But I do think it's pretty clear that wood overall has a much better carbon profile than any other structural material. So for choosing wood, the focus should be on impacts that are not captured in the EPD. That's why BG's guidance for any wood product recommends FSC or reclaimed wood.
Director of Global Market Sustainability Interface
BuildingGreen Premium Member
August 17, 2015 - 1:33 pm
Whether you are talking about choosing a doctor or a building material assessment tool, the same rule applies; never trust the one who claims to have all the answers. i don't trust the accupuncturist who claims he can solve everything any more than I trust the Harvard Medical School guy. Every material assessment tool out there has holes in it, that's a just a fact right now, whether we're talking about EPD, C2C, or your favorite Red List. The problems arise when organizations attempt to gloss over these problems and pretend that their material or standard is inherently more sustainable, rather than just a different set of trade offs. Given the lack of a silver bullet for materials assessment, we need to reward standards and organizations that are actually transparent about what their assessment actually does and does not do. Or, in the words of Ray Anderson, we need to realize that "the companies that are for real are the ones who talk about what's still to be done, not what they've already done."
[BuildingGreen Editor's note: Mikhail Davis is Director of Restorative Enterprise at Interface.]
After publishing a thoughtful and balanced series of EPD-related articles in your recent newsletter (by Paula Melton, Brent Ehrlich, and others), I am surprised that Jason still seems to have a fundamental misunderstanding of what an EPD is and does.
First, Jason criticizes a wood EPD for not accounting for logging impacts - which is simply not true. The first paragraph on page 7 of the EPD states "primary data on raw materials, energy, and emissions were provided by logging operations and lumber milling facilities..." These inventory items and corresponding environmental flows are aggregated into a set of environmental impact potentials based on a characterization method developed by the US EPA. These environmental impacts are "potentials" and not intended to be actual impacts, as some impacts can vary depending on geography and other factors. Jason criticizes the fact that specific impacts such as ecosystem damage, biodiversity, and soil & water quality are not addressed. Certainly those aspects are important, but there are no well-established methodologies for determining these impacts on a global or even regional basis. Those impacts would be different for every single logging operation and would require detailed site-based environmental impact assessment studies. There is currently no practical way to accurately report those in an EPD, especially for the industry-wide EPD being criticized, which represents operations from a wide area of the North American continent.
Second, Jason criticizes a PVC pipe EPD for not including impacts "related to the manufacture and disposal of PVC." Again, this is based on a lack of knowledge and facts about the product. This EPD does clearly include impacts related to the manufacture of PVC. For the input PVC material, it uses a comprehensive cradle-to-gate industry-wide inventory of PVC developed by the well-respected firm Franklin Associates. It accounts for the fact that the vinyl industry has significantly reduced waste and air emissions over the past few decades. These impacts are included in the results. Regarding the disposal of the PVC pipe, the EPD reflects the most standard practice today, which is just to leave the pipe in the ground (there's no economic benefit to digging up a pipe even though it's fully recyclable). The stability of PVC pipe means that there are no detectable degradation products from the pipe during and after its useful life.
While LCAs and EPDs may not be perfect, they are the best tools we have to measure an array of important environmental impacts. These industries should be applauded for embracing transparency and recognizing they have a role to play in our collective journey toward a more sustainable society.
These comments deflect attention from the fundamental point I'm making: as tools that are touted as being both transparent and comprehensive, EPDs should, for any given product system, disclose the significant impacts that are NOT addressed by the underlying LCA study.
If well-established LCA/LCIA methods do not exist to account for the ecological impacts of logging, then in the name of transparency, an EPD for forest products should clearly and prominently disclose this important fact since many people are likely to assume otherwise. This is particularly true when the tool in question is called "life-cycle" assessment and references are made to "cradle-to-gate" or "cradle-to-grave" impact assessment. When I think "cradle" for wood, I think of the forests that timber comes from, and I'll bet I'm not alone. For the average person reading the EPD in question, the statement cited ("primary data on raw materials [my emphasis], energy, and emissions were provided by logging operations and lumber milling facilities...") leaves the impression that all bases are covered when they are not. As I noted, this impression is created even more strongly on the first page of the EPD, where one reads that it includes LCA results "for allprocesses up to the point that planed and dry lumber is packaged and ready for shipment; the cradle-to-gate product system includes forest management, logging, [my emphases] transportation..." etc.
The same point applies to the PVC EPD. It's certainly true that a number of important impacts are addressed, and it's great that "the vinyl industry has significantly reduced waste and air emissions over the past few decades." But this does not obviate the fact that what many consider the most significant impacts associated with PVC/vinyl -- namely, the toxic pollution and health risks associated with its production and disposal -- is conveniently omitted from the EPD.
I stand by my original position: to engage in such "glossing over" in the name of comprehensiveness, science and transparency is indeed Orwellian.
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