Is There an EPD in Your Future?

The Biden Administration, partially in response to goals and requirements set by Congress, is pressing infrastructure owners and builders to decrease the embodied carbon associated with building and operating highways, locks and dams, airports, water and wastewater treatment systems, mass transit and anything else bought by or paid for using funds provided by the federal government. This use of the federal purse to drive reductions in emission of climate warming gases is intended to spur similar action in the private sector.

Congress has specifically identified environmental product declarations (EPDs) as the means of communicating information about the climate impacts associated with construction products and materials, and in the Inflation Reduction Act of 2022 provided the Environmental Protection Agency (EPA) with $350 million to develop EPD programs and encourage their use.

While the use of EPDs in this way presents challenges, as I’ll describe later, it seems likely that composites manufacturers will need to provide these documents for their products.

We’ve already heard from composites manufacturers that customers are asking for EPDs, including for products for non-government funded projects like electrical distribution systems and commercial buildings.

Content and Use of EPDs

An EPD is a document prepared in compliance with ISO standards that presents information about a product’s environmental impacts. Here are some of the important elements of an environmental product declaration:

  • The scope identifies the products that are covered by the document. An EPD can present information that is an average across multiple producers of a product or for the product produced by one company at one location.
  • The life cycle stages for which environmental impacts estimates are provided. An EPD can include information on the full life cycle of a product, including product use and at end-of-life, but the majority of EPDs provide only cradle-to-gate impact estimates (including extraction of resources from nature, upstream processing and transportation, and manufacture of the product).
  • A functional or descriptive unit that defines the amount of product to which the environmental impacts data apply. For example, an EPD for glass fiber insulation could provide an estimate of the climate impacts associated with the production of 1 kg of the product (a descriptive unit) or with the amount of the product needed to provide a certain amount of thermal insulation in a standardized test (a functional unit).
  • Estimates of environmental impacts within the scope and specified life cycle stages. An EPD for a product is likely to include, for example, estimates of the amount of climate warming gases associated with the specified life cycle stages for the products included in the scope of the document.

The purpose of an EPD is to convey information that will allow a downstream user to compare the environmental impacts of two or more products or materials that are being considered for a project.

For instance, a contractor building a highway bridge may have two sources of steel rebar potentially suitable for the project and want to consider the amount of climate warming gases associated with the manufacture of each supplier’s product along with other information, such as price and availability. EPDs allow a comparison of the environmental impacts of each of the suppliers’ products, which can be considered as part of the material or product selection process.

Preparation of an EPD

The EPD preparation process identified in the relevant ISO standards starts with a product category rule (PCR) that specifies how environmental impacts data are to be collected, analyzed and presented in an EPD.

A PCR is a consensus standard developed by a committee of industry members and external stakeholders (such as researchers and product end users) and guided by a program manager who ensures compliance with the relevant standards, manages independent verification of the draft document and then makes the final PCR available to the public on its website.

A PCR specifies how a life cycle analysis (LCA) is to be prepared for the product for which an EPD is needed. An LCA is a summary of energy use and environmental impacts associated with a product’s manufacture, use and/or end-of-life, depending on the scope.

Data from an industry average LCA for 1,000 pounds of an open molded composite product is provided in figure 1. As described in an applicable PCR, these data would be presented in an EPD in a format and with other information that facilitates product comparisons and other uses.

Problems with EPDs

Congress decided that EPDs are to be used to drive reductions in climate warming gases associated with infrastructure construction. That doesn’t mean that EPDs are suitable for this job.

My first concern is that EPDs are much better at conveying information about cradle-to-gate impacts, while composite products are typically chosen for their use-phase benefits. The composites industry will have to convey information about the benefits of our products using methods that complement EPDs and support better-informed decision making by infrastructure owners and material specifiers.

Further, producing and maintaining EPDs is costly and burdensome. Figure 2 illustrates the complexity of this process. Our competitors have both more resources for this and less complicated supply chains. ACMA is considering a composites industry EPD program that could lessen the burdens on individual composites manufacturers.

Additionally, it’s not clear that end users and material specifiers will find EPDs for composite products to be all that useful. The composite products used for a construction project are likely to represent only a small fraction of the climate or other environmental impacts associated with the entire project, especially if only cradle-to-gate impacts are considered. Requirements to consider EPDs could become just a check-the-box exercise for many types of infrastructure projects.

Other groups representing both suppliers of construction products and contractors share these same concerns. Many are likely to call on the EPA to limit EPD requirements to projects above a certain size and, on those projects, to materials that comprise more than a certain share of the total cost of a project.

But no one believes EPDs can be completely avoided by manufacturers selling products into infrastructure markets, despite the problems and challenges.

ACMA members should keep an eye out for the Insider e-newsletter, which provides up-to-date information about EPDs and the association’s sustainability programs.

John Schweitzer is vice president of EH&S and sustainability at ACMA. Email comments to jschweitzer@acmanet.org.

Figure 1: Example Industry Average LCA

Impacts of the production of 1,000 pounds open molded composite, from an industry average cradle-to-gate assessment:

ImpactUnitsQuantity
Cumulative energy demandBillion BTUs13.9
Water useGallon447
Solid waste generatedPounds173
Climate warming gas emissionPounds CO2 equivalent1,547
Styrene emissionsPounds7.1
Other VOC emissionsPounds0.51

 

The EPD process shown here must be repeated every five years.

* One industry average EPD per product type

** For each product type, one EPD for each location where the product is made


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