Opinion: Seven Things Manufacturers Wish You Understood About EPDs

It’s relatively easy for advocacy groups to embrace market disruption, but for manufacturers, strong economic forces work against revolutionary rethinking of how building products are made. And even though many sustainability champions within manufacturing firms are pushing for change, there are limits to how quickly these changes can happen.

A message to the design community

We asked several manufacturers the following questions:

• What is your approach to EPDs, and how has it changed recently?
• What have been the challenges for the company so far?
• What useful data is coming out of this process to improve operations?
• What feedback do you have for designers on streamlining what they are asking manufacturers to document?
• Are costs going down at all?
• Are there any synergies between EPD creation and other new LEED v4 approaches (CSRs, material transparency, updated indoor emissions guidance)?

We’ve excerpted some of the most insightful answers below to promote dialogue between building product manufacturers and design and construction professionals.

Here are the seven most important things these companies want you to understand about EPDs.

1. LCAs and EPDs cost tens of thousands of dollars.

From Susan Hines, a LEED Green Associate and Director of Industry & External Affairs at the Gypsum Association:

Although the Gypsum Association (GA) and its member companies had one EPD ready for public distribution within months of the release of LEED v4, other building product manufacturers have struggled to respond to the call for EPDs under LEED v4.

As an 85-year-old association with early LCA experience, GA was better positioned than many trade associations to its assist member companies in this effort. However, a really solid LCA from a reputable practitioner, and engaging a program operator for the purposes of PCR and EPD development, requires tens of thousands of dollars and significant manufacturer staff time. 

Meanwhile, USGBC has initiated an EPD Consortium that aims to address the dearth of existing EPDs for building products. The GA is participating in the consortium, which has had three meetings so far in 2015. The Consortium is restricted to trade associations and LCA practitioner representation and seems to be an effort on the part of USGBC to help industry overcome what the Council sees as a reluctance to engage in LCA.

Interestingly, for an organization that touts its own business savvy, a primary point USGBC makes to encourage manufacturer engagement in LCA is return on investment (ROI).  Does USGBC really assume that building product manufacturers are not already on the lookout for these savings, and already implementing them where possible?

An LCA can and should point out areas for improvements in energy consumption, water consumption, etc. Improvements can lead to savings on the production side without compromising quality.

As one of my colleagues at the GA points out: The data is there at the manufacturing level because every part of the manufacturing process has an associated cost. The “data collection burden” is not insurmountable; however, supplying that data for solid interpretation via LCA, and then proper third-party verification—followed by revision every five years—is not easy or cheap.

Costs are slowly going down, especially in the program operator arena, where long-established industry organizations such as ASTM and UL are entering the market. I believe the initial costs of LCA will also decrease with greater demand for these services and as LCA databases expand to reflect increased use of LCA methodology.

2. High costs make it hard for small, regional manufacturers to get in the game.

From Lionel Lemay, Senior Vice President, Sustainable Development, at the National Ready Mixed Concrete Association:

Cost for publishing an EPD (conducting the LCA, publishing the EPD, and getting them verified) does seem to be going down as volume increases. The National Ready Mixed Concrete Association (NRMCA) became an EPD program operator for two reasons:

1. to provide an efficient and cost-effective pathway for publishing product-specific EPDs
2. to encourage our members to publish EPDs

So far, nine companies have done so, with nearly 2,000 products with EPDs. From what I can tell, this is considerably higher than any other industry, so the strategy may be paying off.

We are also working with consultants to develop and certify EPD tools to help our members publish EPDs at a much lower cost and with a shorter timeframe. Currently, it can take months for the process from start to finish.

We envision getting that process down to a few weeks or even days and getting the cost down to several dollars per EPD—not thousands.

3. The design community should be realistic and consistent about what it’s asking for.

From Amanda Goetsch, Environmental Sustainability Manager at Inpro:

Architects and designers have an amazing opportunity to shape the future!

The current challenge from a manufacturer’s perspective is that architect and design firms are all asking for very complex information, very rarely in the same format.

Inpro recognized this change was coming years ago and therefore committed to hiring a full-time sustainability manager. I have the pleasure of corresponding with architects and designers in order to get them the information they need.  However, the ripple of product compliance documentation doesn’t have the number of rings it needs yet to work all the way through the supply chain.

We do all that we can to get the applicable information; sometimes the data just isn’t there yet. This is no excuse, though, just something that needs to be understood as we discover new ways of communicating information about sustainability attributes.

4. Lack of standardization is just as challenging for product manufacturers as it is for designers.

From Martin Grohman, Executive Director, Sustainability, at GAF:

In my view, there are problems with the way functional units are selected.  As far as I am aware, there is no requirement to use SI units as a primary measure. However, that is what we have done on both [our] PCRs. This means that instead of impacts measured in the familiar “square” (100 ft² of roofing), we get m², a unit that no one in our industry understands.

This leads to a situation where we make the EPDs less accessible to the trade. In my view, we would have been better served to give the SI units or provide a conversion table, but have the base unit be the square. Roofers just aren’t ready to talk in units of 9.29 square meters (one square).

Also, there is a need for a concerted effort toward harmonization among operators in the development of PCRs.

For example, I believe it is unfortunate that different PCRs were developed for asphaltic and single-ply roofing products, with different functional units. This creates unnecessary confusion and cost.

5. EPDs are far more useful to manufacturers than they are to designers.

From Amy Costello, Sustainability Manager, Armstrong Flooring Products:

EPDs are a tool in the toolbox to help designers and to help manufacturers better understand the impacts of sustainable products.

My fear is that designers are going to make direct comparisons. That is not the intent: it is more to give you an idea of what the impacts are. An EPD is an indication that the manufacturer has taken a step to understand their product. It is so rewarding for manufacturers. Hopefully when they do it, it’s an eye opener for them: This is what I need to do to make my products better.

I think there are actually synergies far beyond what anyone understands with EPDs, corporate sustainability reporting, and material transparency. By doing EPDs, you truly understand what’s going on in your supply chain, what’s happening with your products. That’s the real beauty of EPDs. There’s a lot of learning that comes by doing this process at a level detailed enough to do life-cycle assessment.

6. Everyone needs to communicate better, especially internally.

From Amy Vigneux, Manager of Sustainable Building Solutions, Assa Abloy:

It’s been a very good learning experience for us in understanding that we need to err on the side of over-informing and over-communicating because it’s such a new process for us.

I would love to see communication streamlined within architecture firms. We get advocacy letters from these firms, and then we’ll go do a lunch-and-learn and ask about EPDs and get a blank stare. We’re happy that they’re pushing it, but I don’t think the message has crossed all of their offices and locations yet. I’d love to see some cohesion on that end of things.

We’re also curious to understand how to get our information across to them. We’re not face-to-face with them every day. They are also inundated with information at this point. It would be helpful if we could tell our story and deliver information to them so it’s relevant.

7. Carbon is a human health issue.

From Mikhail Davis, Director of Restorative Enterprise, Interface:

We get all kinds of questions and a lot of focus on health product declarations (HPDs), ingredient disclosure, and all this stuff. People are actually starting to ask questions about specific ingredients.

That’s something they do not have the appetite to do with EPDs. But if you have a Red List-free product with four times the carbon footprint, that’s a health issue.

For most products that do not conserve energy during their lifespan, cradle to gate is most of the impact. For carpet, 60%–70% of the impact is in raw material extraction, before it even gets to our factory. That’s what we’re trying to cut out with recycled content.

We learn through LCA how we can eliminate that process and change the supply chain so we are no longer supporting mining or oil refining, which has a huge impact on toxicity—which LCA doesn’t measure well. But in some ways, carbon footprint serves as a proxy for a lot of the other really intense impacts in the life cycle.