Regulatory Review: Holistic Environmental Regulation
Lifecycle assessments will likely play a major role in future environmental regulations.
One argument many industries have against environmental regulation has been that it often ignores a holistic view of a product and instead focuses on only one attribute (e.g., volatile organic compounds, or VOCs). The premise is that lowering VOC levels negatively impacts performance attributes, such as durability or adhesion, and therefore more product is required, essentially negating any environmental benefit achieved through VOC reduction.
Environmentalists and regulators alike have the same concern as manufacturers, but for different reasons. These groups want to know the impacts of products on a holistic scale in order to provide end users, themselves and so forth with the information they need to make knowledgeable decisions about products in the market place.
Today, the most recognized way to look at the overall ecological impact of a product is a lifecycle assessment (LCA). This method is being recognized more frequently, with LCA-based submittals becoming a requirement in many markets. These submittals can be found in green building programs, such as LEED v4 (going into use this month), green building codes (e.g., ASHRAE 189.1) and several environmentally preferable purchasing programs. Lifecycle thinking, while not the same as full LCA, is taking hold in regulation such as the Safer Consumer Products Rule in California and the most recent draft of the Chemical Safety Improvement Act in the U.S. Senate.
PCRs, LCAs and EPDs
LCA is a method of evaluating a product by reviewing the ecological impact over the life of the product. This calculated eco-impact is based on 13 attributes, such as eutrophication and greenhouse gas contribution. The evaluation is governed by an ISO-defined process and covers five stages of product life:
• Raw material acquisition (the “cradle”)
• Raw material transport.
• Manufacturing (the “gate”)
• Installation and use
• Disposal/recycling (the “grave” in the case of disposal, or back to the “cradle” in the case of recycling).
The data used to conduct an LCA is called the lifecycle inventory (LCI) and spans the supply chain. In fact, lifecycle stages through the supply chain will overlap. For example, cradle-to-gate for a manufacturer of an adhesive pre-applied to a vinyl tile is only part of the cradle for that vinyl tile. In other words, output from one LCA can be a piece of an LCI feeding into another product’s LCA.
Product category rules (PCRs) are the basic boundaries, conditions and assumptions for conducting an LCA. A product category is a group of products that fulfill equivalent functions. Tiling is a simple example. Various cements, grouts and adhesives, among other items, can all be used for sticking tile to a substrate. While not all are viable options for any one tiling application or type, all are viable in the general application of placing tile. Given this, the best PCRs are industry-accepted and application/function-oriented. PCRs do not need to cover all lifecycle phases, but normally go cradle-to-gate or cradle-to-grave/cradle.
Environmental product declarations (EPDs), especially those that are Type 3 (defined below), are the endgame to creating PCRs and LCAs. They are a statement on the ecological profile of a product and have various levels or “types.” Type 1 EPDs are focused on a single attribute and are third-party verified. An example of this in sealants and adhesives is volatile organic content emissions testing. Type 2 EPDs can be focused on single or multiple attributes and are typically self-declared. The most common example of this would be the letters many manufacturers have listing VOCs, recycled content, etc., for green building submittals. Finally, Type 3 EPDs are multi-attribute, LCA-based and (as a result) third-party verified. Many call them an “ecological nutrition label” and “the ultimate eco-label” because they are detailed, provide data-driven claims and allow for easy reading of the impacts of a product. A great example can be found on most boxes of Timberland boots.
Progress and Issues
Our industry has taken notice of these evaluation methods. Many manufacturers have implemented elements of LCA, if not LCA itself, into the R&D process. Through its Certification Services Group, ASTM is facilitating creation of PCRs to allow for LCAs of building seals and sealants. Getting into one application area, The American Architectural Manufacturers Association (AAMA) is nearing completion of a PCR for commercial and residential fenestrations. Building seal/sealant EPDs would feed into the LCI for LCAs based on the AAMA PCR.
Issues do exist, however. For example, industries and their supply chains have a lot to work through regarding LCA and information sharing. Matters of confidential business information need addressed through the supply chain, especially given the overlap of lifecycle stages. While these conversations may be a challenge, they must occur to ensure a proper outcome.
Another issue is that the LCA learning curve for much of industry is quite steep. For various reasons, product/building designers, end users and formulators have much to learn about the concepts in LCA. Industry has just begun to understand ecological issues, let alone the complexity associated with LCA. For the majority, this is a whole new approach and science to learn.
Finally, chemicals of concern have their own challenges, and many believe they are not addressed rigorously enough in LCA. Regulators have incorporated lifecycle concepts in green chemistry schema, but alternative assessment is the preferred approach there.
The Future of Environmental Regulation
While it is not a panacea, LCA will play a significant role in the future of environmental regulation and environmental-based product selection. Whether your market is construction, automotive or widgets, customers and regulators are demanding to know more about the eco-profile of your products. While there is a learning curve for all parties, LCA and the resulting EPDs are the future of much green marketing and regulation.
Any views or opinions expressed in this column are those of the author and do not represent those of ASI, its staff, Editorial Advisory Board or BNP Media.