Focus on Transparency - Aug/Sep 2013

By Darius Helm

LEED v4 may not be launched until Greenbuild this November, but for all intents and purposes it has already altered the trajectory of the U.S. green building movement. At the broadest level, the new version demonstrates a greater commitment to the three pillars of sustainability—environmental, social and economic—and, as it relates to the flooring industry, it shifts the focus from single-attribute and multi-attribute certifications to lifecycle assessments, environmental product declarations (EPDs) and increased transparency through health product declarations (HPDs) and other vehicles.

Architecture and design firms are already looking at projects through this new lens, specifying products with EPDs and HPDs. Carpet manufacturers are also already in position, with most of the commercial firms launching EPDs on products this year. And many are completing or working on HPDs, as are some hard surface and resilient producers.

In early March, Cannon Design, an international design firm that ranks in the top five for healthcare and education design work, sent a letter to product manufacturers, entitled “Re: Product Transparency and Chemicals of Concern Disclosure,” laying out guidelines for what it considered to be specifiable material. The design firm requested that HPDs be publicly provided for all products used in its buildings, and also stated that as of the beginning of 2015 it will only use materials with product content transparency. According to the firm, its purpose is “transparency to enable our project teams to make informed health-minded decisions.” Several prominent design firms are also coming up with similar approaches. In fact, most of the top design firms, including Cannon Design, Gensler, HOK and Perkins+Will are founding endorsers of the HPD Open Standard.

This move en masse by the A&D community, coupled as it is to LEED v4, is reminiscent of other milestones in the brief history of green building, like indoor air quality certification. And what it means to manufacturers is unequivocal; to participate, they’re going to have to embrace the issue of transparency.

DEFINING TRANSPARENCY
Manufacturers are in a unique position among the players involved in the commercial building process. As the materials providers, they are essentially alone in bearing the burden and the risk of exposing their businesses through transparency certifications. And to reveal proprietary information seems to undermine the competitive principles upon which free market capitalism is built.

However, transparency is not always as transparent as it sounds. There are many ways to approach the issue of verifying environmental impacts or eco-toxicity and human health issues without publicly disclosing any proprietary chemistries. And even the more opaque programs get some sort of recognition in the new LEED certification system. But higher levels of transparency do increase the value of the flooring in its contribution to LEED credits.

It’s also worth noting that even though manufacturers can buffer themselves against disclosing all their processes and materials, in some circumstances there will likely be ways of teasing out more information to reveal chemistries or possibly even suppliers. And on top of that, the demand for increased transparency will grow stronger. After all, this is being driven by concerns about eco-toxicity and human health, two areas where you can only really move in one direction—forward. 

So the manufacturers and chemical companies that have resisted material transparency are right to be concerned about it, though they’re probably wrong to fight against it. It’s like trying to save a sandcastle from the rising tide. Fortunately, manufacturers are pragmatists. They’re in the business of competing to sell products, and they’ll go where the competition takes them.

EPDs, which in the new LEED version contribute to points in MRc2 in the section on building product disclosure and optimization, focus on lifecycle impacts and don’t figure into the transparency discussion as much as HPDs, Pharos, Green Screen and cradle-to-cradle certifications. EPDs are developed through lifecycle assessments that are defined and reported according to a product category rule (PCR). The PCR developed for the flooring industry describes products through a set of impact categories. As such, there’s a lot of territory EPDs don’t cover, like human health, which the consensus group that developed the PCR decided was covered by indoor air quality certifications.

HPDs, which at least for now are self-declared, take a closer look at materials and also highlight hazardous chemicals, and they contribute to a LEED credit in MRc4, the material ingredients section. And cradle-to-cradle certification is included in the same section because of its focus on chemistry. MRc3, which deals with the sourcing of raw materials, gives credit for third-party verified corporate sustainability reports that include environmental impacts up and down the supply chain. Accepted frameworks include a Global Reporting Initiative Sustainability Report, along with other global programs.

ROOM FOR IMPROVEMENT
The biggest issues for everyone from manufacturers to designers with the new LEED version have to do with clarity. A lot of criticism has been directed at the way in which the credits are written, and many feel that there’s going to be a lot of confusion. And, as always, there are disputes about the relative worth of the many different certifications and reporting systems that are included.

It seems clear that there will be plenty of controversy with LEED v4, though many feel that simply making it this far is a victory, considering the push and pull of the various stakeholders. Few people think it’s a perfect document, but the sense is that it will be periodically revised and fine-tuned.
At the same time, certifications are likely to develop as well. It seems inevitable, for example, that HPDs will eventually require third-party verification.

Also, there’s a lot of room for development in chemical assessment systems. When it comes to human health, there’s a huge distinction between the toxicity of a material and assessing the exposure of people to that toxic material. For instance, there’s a big difference in health risk between a toxic substance in upholstery fabric and the same substance in a ceiling tile, or between the plasticizer in an IV tube and the plasticizer in a vinyl floor. Creating programs that accurately reflect exposure levels are essential in implementing sustainable building solutions.

In the end, the most significant aspect of LEED v4 and the movement toward lifecycle assessment and material transparency is the speed with which the changes arrived. Just two years ago, as the PCR for flooring was still being developed, there was a lot of skepticism in the flooring community about the traction EPDs would receive. Certification of NSF 140, the multi-attribute carpet assessment standard, was still getting a lot of attention, and resilient flooring manufacturers were busy getting NSF 332 certifications. And now multi-attribute certifications look more like evolutionary dead ends, bypassed by the next generation of sustainability tools. The good news is that this more comprehensive approach to sustainability is likely to be relevant for many years to come.

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