Environmental Product Declarations: Transparency in Products

The International EPD System is a global program for Environmental Declarations run by EPD International AB headquartered in Sweden with branches around the world, including North America. Most U.S. organizations use this system based on the international ISO 14025 standard, although it may be carried out by an organization such as UL Solutions. An Environmental Product Declaration (EPD) uses this standard to transparently report the lifecycle assessment of a product in a single, comprehensive report, which is independently verified. The EPD provides information about a product’s impact on the environment, such as global warming potential, smog creation, ozone depletion, and water pollution. Architects, designers, building owners, and others can use this information to determine the make-up of building products, such as paints and coatings, and select those that meet their criteria for a new construction or renovation project.

While the EPD is presented as a final report, the foundation of any EPD is a life cycle assessment (LCA). The LCA allows readers to evaluate a product’s environmental performance over its entire life cycle. It typically considers the full value chain, from material extraction to manufactured product, its usage stage, and end of life. The LCA is developed according to Product Category Rules (PCRs) which are product-specific calculation requirements and methodologies that help ensure consistent data collection and analysis during LCA creation. Because of this, EPDs enable the comparison of environmental impacts of like products, providing increased transparency.

An EPD is a so-called type III environmental declaration that is created and registered in the framework of a program, such as UL Solutions. Such registered EPDs are publicly available and free to download through the UL Spot Product Database, accessible online. The EPD differs in many aspects from ISO type I third-party (independent eco-labels) and type II self-declared eco-labels. As such, the EPD’s relevance is steadily growing in voluntary and mandatory engagements.

Image Source: Health Product Declaration Collaborative

Health Product Declarations (HPDs) provide transparency into additional material and product ingredients related to human health.

Health Product Declarations: A Higher Bar

Health Product Declarations (HPDs) are similar documents to EPDs but require additional criteria for transparency and disclosure related to human health. The HPD Open Standard is created and managed by the non-profit HPD Collaborative (HPDC) and is currently the most widely recognized and adopted standard for transparent reporting of building product contents and associated health information. By using the HPD Open Standard, manufacturers have a means to provide verified, clear, consistent, and reliable information about their products’ health impacts. Then, building design and construction professionals can use the HPD Open Standard to make informed decisions about the products they specify and use in their projects.

Among the many items addressed, VOCs are addressed specifically. Among the information required is the amount of VOC material present in the products (expressed in grams/liter) compared to the regulatory limit (also in grams/liter). If EPA-exempt VOCs are part of the product, they still must be identified, and their quantity noted. If colorants are available that do not increase the VOC content of the base paint when tinted, that must be indicated as well.

The standard notes that for any product, interior or exterior, that is wet/liquid-applied on site, i.e., paints, adhesives, and other coatings, the following applies: “A.) If the product has received a certification that addresses VOC content levels, or a third-party laboratory certificate for VOC content testing, the name of that certification or test method is indicated. B.) If the product is compliant with one or more of the regulatory standards applicable to the product category that limit VOC content, such as SCAQMD Rule 1168, SCAQMD Rule 1113 or the CARB 2007 Suggested Control Measure for Architectural Coatings, the name of each applicable standard with which the product complies is indicated. C.) Otherwise, reference the standard that was used to determine Actual and Regulatory VOC content values.” This makes it clear that the appropriate testing needs to be done and reported based on the relevant test. The HPD standard goes on to indicate that “for product categories that are not wet/liquid-applied, VOC Content is not applicable.”

Beyond VOCs, other ingredients and materials must be identified in terms of percentage and descending order of quantity. Of particular relevance, pigments, inks, dyes, and other colorants that are present at or above the selected Threshold(s) in the Content Inventory are required to be reported on an HPD. The maximum percentage of any colorant substance possible in any of the product variations covered by an HPD must be considered and reported in the Content Inventory if it is at or above the selected Threshold(s).

The standard notes that “For products, such as paint, that are formulated and produced as a base product, it may not be feasible to report the full range of possible colorant substances, particularly when they are added by different suppliers in the product distribution process. Manufacturers in this situation may take the following approaches: 1.) Complete an HPD for the base, untinted product, and/or 2.) Complete one or more HPDs for tinted product(s). For either approach, the following steps are required: 1.) In Product Name, include an appropriate term to indicate the scope of colorants, such as “Base,” “Untinted,” “Red Color Family,” “Barn Red,” etc. 2.) In Product Description, include an additional brief description of how colorants were or were not reported in the HPD, and 3.) In Accessories, the colorant system should be included as an accessory.”

Image Source: U.S. Green Building Certification Institute

LEED version 5 is under development and still includes specific criteria for VOC content and emissions for a variety of building products including paints, coatings, and related materials.

LEED and Low-VOC Paints & Coatings

The U.S. Green Building Council’s LEED program is probably the best-known and most-used green building rating system. The current version, LEED v. 4.1 is in effect, although LEED v. 5 is in the development and public comment period. LEED v. 4.1 addresses Low Emitting Materials as part of Indoor Environmental Quality while LEED v. 5 has moved it to the Material and Resources category. However, the fundamental assessment is unchanged between the two versions for reviewing both VOC emissions and VOC content.

• VOC Emissions Evaluation. As described in the LEED BD+C manuals, there are two options to choose from for evaluating VOC emissions. The first is for the product to be tested according to the California Department of Public Health (CDPH) Standard Method v1.2–2017 showing that it complies with the VOC limits in Table 4-1 of the method. Additionally, the evaluation must show the range of total VOCs after 14 days (336 hours) to be measured as specified in the CDPH Standard Method v1.2 and reported. The second option for emissions is to have the product tested according to the European Standard, EN 16516:2017, and comply with the LCI values from Table 1 of the German AgBB Testing and Evaluation Scheme (2015). The results must show a formaldehyde limit of 10 micrograms per cubic meter and the range of total VOCs after 28 days to be measured as specified in EN 16516 and reported. Laboratories that conduct these tests must be accredited under ISO/IEC 17025 for the test methods they use.

Under either option, the statement of product compliance must include the exposure scenario(s) used, the amount of wet-applied product applied in mass per surface area (if applicable), the range of total VOCs, and follow the relevant guidelines. Organizations that certify manufacturers’ claims must be accredited under ISO Guide 17065.

• VOC Content Evaluation. Products being used in a building that is seeking LEED credits and certification must meet the VOC content limits outlined in one of the LEED-identified standards. For projects in North America, methylene chloride and perchloroethylene are indicated to be specifically excluded. Part of the submission for credit includes a statement of product compliance made by the manufacturer or a USGBC-approved third party. That statement must include the results of testing which must follow the test method specified in the applicable regulation. Note that if the applicable regulation requires the subtraction of exempt compounds, then it must be disclosed if there is any content of intentionally added exempt compounds larger than 1% weight by mass (total exempt compounds). Specifically for paints and coatings, the LEED-identified standards include the California Air Resource Board (CARB) 2007 Suggested Control Measure (SCM) for Architectural Coatings or South Coast Air Quality Management District (SCAQMD) Rule 1113 amended February 5, 2016, effective date most current at the time of the project’s LEED registration date.

In all, LEED continues to keep a focus on VOCs as a significant part of defining good indoor environmental quality.

WELL Building Standards

The International WELL Building Institute™is the organization that has developed the WELL Building Standard version 2 (WELL v2). They describe this standard as “a vehicle for buildings and organizations to deliver more thoughtful and intentional spaces that enhance human health and well-being. WELL v2 includes a set of strategies—backed by the latest scientific research—that aims to advance human health through design interventions and operational protocols and policies and foster a culture of health and well-being. Built upon the pioneering foundation of the first version of the WELL Building Standard (WELL v1), WELL v2 draws expertise from a diverse community of WELL users, practitioners, public health professionals, and building scientists around the world.” The standard is recognized by LEED but focuses on the health and well-being of occupants in more categories and in greater detail.

Among the ten different concepts in WELL v2, the Air concept “aims to achieve high levels of indoor air quality across a building’s lifetime through diverse strategies that include source elimination or reduction, active and passive building design and operation strategies, and human behavior interventions.” Specifically, Section A05, which focuses on enhanced air quality, includes Part 2 - Meet Enhanced Thresholds for Organic Gases (i.e., VOCs). The requirements here apply to all spaces and must be verified by performance testing. The requirements are focused on specific VOCs with specific thresholds for emissions to be met in occupiable spaces. These include Acetaldehyde: 140 µg/m³ or lower plus any one of the following: Acrylonitrile: 5 µg/m³ or lower; Caprolactam: 2.2 µg/m³ or lower; Benzene: 3 µg/m³ or lower; Formaldehyde: 9 µg/m³ or lower; Naphthalene: 9 µg/m³ or lower; and Toluene: 300 µg/m³ or lower. Note that not all of these are applicable to paints and coatings but are found in other materials including furniture. The goal is for the interior spaces to be within these limits, regardless of the source.

Image Source: International WELL Building Institute

The WELL Building Standard includes some very specific requirements for VOC emissions that need to be met in order for an interior space to be considered appropriately healthy.