CI-v4 MRc5: Building product disclosure and optimization - material ingredients

  • Stepping stones to optimization

    Certified Silver under v2 of Cradle to Cradle, Styrofoam extruded polystyrene insulation, manufactured by Dow Building Solutions, meets the criteria for the transparency option in the LEED v4 material ingredients credit.Certified Silver under v2 of Cradle to Cradle, Styrofoam extruded polystyrene insulation, manufactured by Dow Building Solutions, meets the criteria for the transparency option in the LEED v4 material ingredients credit.This credit comprises what may be the two most controversial points in all of LEED v4.

    The credit has no precedent in prior versions of LEED. It offers three very different options for addressing chemicals of concern, with a strong focus on disclosure of hazardous substances (hazard avoidance), rather than risk-assessment, which seeks to account for the risk of exposure to a substance, and not just its presence. A third option, that has not yet been made available, may incorporate some kind of risk-assessment methodology. (See details below.)

    Inherent value of transparency and disclosure

    The credit offers one point for material ingredient reporting. The presence of potentially hazardous materials does not disqualify a product from being counted toward this initial point—a source of consternation to some critics. With the release of the April 2016 LEED Addenda the number of resources and paths for complying with this option more than doubled, making it relatively easy to achieve on most projects. 

    But don’t underestimate the power of disclosure. According to advocates for this process, just the act of writing up an inventory of product ingredients can be transformational for manufacturers. Manufacturers may not be aware of everything that's in their products, and simply having those conversations with their suppliers and developing their inventory can lead to change without pressure from consumers.

    Option 1: Manufacturer Inventories

    Option 1 allows for several different ways to provide a “manufacturer inventory” of ingredients:

    • A manufacturer may publish Chemical Abstract Service Registration Numbers (CASRN) for all ingredients in the product; some ingredients may be kept proprietary, but their hazard potential based on the GreenScreen benchmarking system must be disclosed (see below). This inventory is very similar to the Health Product Declaration program, which has more manufacturer participation. All ingredients that constitute 0.1% (1,000 ppmParts per million.) or more of the product must be accounted for, a threshold that is 10 times lower than the typical 1% minimum threshold for reporting on a material safety data sheet (MSDS1. Material safety data sheets (MSDS) are detailed, written instructions documenting a method to achieve uniformity of performance. 2. A report that manufacturers of most products are required to make available to installers and purchasers, informing them of product information on chemicals, chemical compounds, and chemical mixtures, the existence of potentially hazardous ingredients, and providing instructions for the safe handling, storage, and disposal of products).
    • Globally Harmonized System (GHS) path: With the April 2016 Addenda a new hazard identification option was introduced that references the Globally Harmonized System for the Classification of Chemicals (GHS) instead of GreenScreen. GHS is the framework underlying standard Safety Data Sheets (SDS) which are replacing the older Material Safety Data Sheets (MSDS) internally as a chemical safety reporting format. While GreenScreen is partially based on GHS, it includes more stringent screening criteria than GHS. The screening criteria for GHS are tied to more common industry standards and regulatory requirements, which can vary by country. The requirement to include a list of hazards that cannot be classified due to insufficient data, however, is a nod toward additional rigor.
    • The Health Product Declaration (HPD) is a standardized format for disclosure by manufacturers of product contents, emissions, and health information. It has been likened to a nutrition label for building products focused on health-based issues not addressed by EPDs. Because the HPD is an open standard for reporting product ingredients and associated health hazards, it’s up to individual manufacturers to choose to use the HPD and to choose the level of detail to provide.
      • To qualify for LEED in a version 1.0 HPD, the manufacturer must affirm “Full disclosure of known hazards” on the front summary page and further affirm the level of disclosure with the check box under “Residuals disclosure.” Also, HPD standards for the 1,000-ppm level must be attained and the appropriate box on the summary page checked.
      • With version 2.0 HPDs the specific requirements are similar: all contents characterized and screened at the 1000 ppm level or better and a description of how residuals were considered either for individual materials within the contents list or for the contents as a whole. A graphic illustrating the requirements is available here.
    • Cradle to Cradle (C2CA protocol developed by McDonough Braungart Design Chemistry that establishes guidelines for the manufacture of products in ways that harmonize with natural systems. These guidelines require, for example, that products be recyclable indefinitely, contain no hazardous ingredients, and be manufactured using renewable energy.) is a multi-attribute sustainability certification that does not require manufacturers to publish product ingredients, making it an odd choice for a “disclosure” option. Products certified at the Bronze level or higher under version 3 of C2C have had their ingredients disclosed to a third-party assessor, who vets the list for accuracy. C2C also rates products based on energy, water, carbon, waste, and indoor air quality targets. Cradle to Cradle also now has a streamlined program that includes only the Material Health aspects of the full certification. That Material Health certification was officially accepted as a compliance option for this credit with the April 2016 Addenda. 
    • Declare, the product labeling program from the International Living Future Institute (ILFI) that’s designed to identify ingredients for the purposes of screening against ILFI’s Living Building Challenge Red List, was added as a reporting option with the April 2016 Addenda. To comply with this option Declare products don’t have to be Red List Free nor “LBC-compliant” but they must indicate that all ingredients down to 1,000 ppm were evaluated and disclosed.
    • Contract furniture products can comply using the ANSI/BIFMA e3 certification program, as long as they’ve earned at least three points in the required section of that system (7.5.1.3 Advanced Level in e3-2014 or 7.4.1.3 Advanced Level in e3-2012).

    Where to find products

    C2C-certified products are listed in an online database run by the Cradle to Cradle Product Innovation Institute (C2CPII). When LEED v4 launched, there were roughly 100 certified building products listed, including some from major manufacturers—enough to contribute to many LEED v4 projects but not all.

    Manufacturer inventories and HPDs are available on individual manufacturers’ websites, and the design firm SmithGroupJJR has created a public HPD Library. BuildingGreen, the company behind LEEDuser also collects products with LEED-compliant HPDs and other transparency documents in its Transparency Collections, which are available from the Green Products tab on BuildingGreen.com.

    Declare products are accessible in ILFI’s Declare database, which was relaunched in May 2016 with enhance search capabilities.

    The mindful MATERIALS program provides spreadsheets from manufacturers that indicate which transparency declarations and certifications are available for each product.

    BuildingGreen, the company behind LEEDuser also collects products with LEED-compliant HPDs, C2C certifications, Declare labels, BIFMA certification, and other transparency documents in its Transparency Collections, which are available from the Green Products tab on BuildingGreen.com.

    Tips & field notes

    Since the release of the April 2016 Addenda this option has become quite accessible for most whole-building projects in the U.S., where these programs are relatively well established. It’s not as easy for projects in other countries.

    Small CI projects that don’t use many different products sometimes have trouble getting to the magic number of 20.

    Watch your Vs and 2s! The C2C options for this credit are weighted differently depending on the version of C2C the product is certified under. As of 2016, there are no longer any C2C version 2 certified products so new projects and projects that have yet to specify their products will all be referencing version 3 of C2C.

    Few manufacturers have published HPDs so farFloor-area ratio is the density of nonresidential land use, exclusive of parking, measured as the total nonresidential building floor area divided by the total buildable land area available for nonresidential structures. For example, on a site with 10,000 square feet (930 square meters) of buildable land area, an FAR of 1.0 would be 10,000 square feet (930 square meters) of building floor area. On the same site, an FAR of 1.5 would be 15,000 square feet (1395 square meters), an FAR of 2.0 would be 20,000 square feet (1860 square meters), and an FAR of 0.5 would be 5,000 square feet (465 square meters). under version 2.0 of that standard, and HPDs have a lot of competition that they didn't have when the format was first introduced, so it remains to be seen how much of an option this will be. But HPDs still have strong support from the design community and are being positioned as a common data entry format that could also serve Declare and C2C. Version 2.0 of the HPD includes many technical improvements that make HPDs easier to produce and interpret.

    Option 2: Ingredient Optimization

    Here’s another area where LEED’s long-term goal of performance-based accountability begins to take shape. Option 2 offers an incentive for manufacturers to go beyond awareness and disclosure of product formulations and to begin eliminating potentially hazardous chemicals from their supply chains.

    Optimization options

    • C2C v3 Silver certification means that a manufacturer has reached the final stages of replacing hazardous materials. The C2C methodology for chemical assessment includes a list of banned chemicals (products on this “black list” can’t enter the system even at the Basic level), as well as a tiered watch list (called an “ABC-X” system, with X identifying hazards that eventually must be phased out). A v3 Silver product has had an ABC-X assessment on 95% of its ingredients and contains no known or suspected carcinogens or reproductive toxicants.
    • The GreenScreen benchmarking system looks not only at the toxicity, persistence, and bioaccumulative potential of chemicals but also at how they degrade once they enter ecosystems. | Source – Clean Production ActionThe GreenScreen benchmarking system looks not only at the toxicity, persistence, and bioaccumulative potential of chemicals but also at how they degrade once they enter ecosystems. Source – Clean Production ActionThe GreenScreen List Translator, developed by the nonprofit Clean Production Action, is essentially a mega-red-list—a collection of chemicals that are considered hazardous by a number of regulatory bodies around the world. The List Translator includes both “authoritative” and “screening” lists—but to qualify for credit, products only need to come up clean when compared against the authoritative lists. This means that none of the ingredients in the product can be flagged as the equivalent of “Benchmark 1,” which in the GreenScreen benchmarking system includes the most persistent, bioaccumulative, and toxic chemicals—including known human carcinogens, mutagens, and reproductive and developmental toxicants. But for a full GreenScreen hazard assessment, the List Translator is just the beginning. With manufacturers routinely introducing new chemicals, all the red lists in the world can’t keep track of every potential hazard. A full GreenScreen assessment involves a wide-ranging review of published data about the material’s entire life cycle and the life cycles of similar chemicals. To qualify for credit, each ingredient of a product must be assessed by a licensed GreenScreen profiler and must include no Benchmark 1 chemicals throughout its life cycle.
    • REACH (short for Registration, Evaluation, Authorisation and Restriction of Chemical Substances) is a European Union regulation that aims to identify the most potent hazards used in European industry. The program is gradually assessing more than 30,000 chemicals and has begun creating its Authorisation List of Substances of Very High Concern; the list contained 22 chemicals as of September 2013, and European manufacturers must get special permission to use these substances. To qualify for LEED v4, products must contain no chemicals from this authorization list and none from the Candidate List of Substances of Very High Concern for Authorisation—which includes more than 100 chemicals still being assessed for possible inclusion on the authorization list.

    Where to find products

    C2C rates products based on multiple attributes; the product gets the lowest of these scores as its rating.C2C rates products based on multiple attributes; the product gets the lowest of these scores as its rating.Finding C2C-certified products is easy in the C2CPII database.

    As of the LEED v4 launch, a central database for products and materials that have undergone a full GreenScreen assessment has not emerged. One option, however, is to use an HPD to document fully inventoried chemical ingredients to 100 ppm that have no Benchmark 1 hazards:

    • If any ingredients are assessed with the GreenScreen List Translator, value these products at 100% of cost.
    • If all ingredients are have undergone a full GreenScreen Assessment, value these products at 150% of cost.

    All companies that produce building materials for European markets should have information about their European products’ status relative to REACH. The REACH option may apply to North American products if the formulations are identical.

    Tips & field notes

    Not all international manufacturers will formulate their products the same way in Europe and North America, so check that documentation produced for a product sold in Europe translates to the U.S., and vice versa.

    Option 3: Supply Chain Optimization

    Many manufacturers of chemicals and plastics have objected to the new MR credits (see A Ban on PVC?), prompting USGBC to develop a third compliance path for MRc4. A draft implementation guide for this option was developed in 2015, but as of June 2016 it is not yet available for use by LEED projects pending field testing. Availability is expected by the time LEED v4 becomes mandatory in November 2016.

    The credit language encourages manufacturers to seek third-party verification of supply-chain optimization regarding material health. It appears to favor “risk-assessment” methods.

    A hazard assessment characterizes the inherent health and environmental dangers of a material without taking exposure into account; hence it typically focuses on the most toxic substances—chemicals for which, some would argue, there is really no “safe” amount.

    A risk assessment goes beyond identifying hazards and analyzes the level of risk involved in using a particular chemical in a particular way. A hazard assessment might identify a halogenated flame retardant as a persistent, bioaccumulative toxic chemical. A risk assessment would then focus on how much of the chemical could be considered safe for humans and ecosystems; this information is usually used to seek ways to limit exposure through environmental regulations.

    Although these methodologies are complementary, they have in the past few years come to be seen as opposing, with consumer and environmental advocates tending to argue for more hazard screenings and outright bans of certain chemicals, and industry advocates tending to argue for more risk assessments and exposure controls. 

  • MR Credit 5: Building product disclosure and optimization - material ingredients

    Intent

    To encourage the use of products and materials for which life-cycle information is available and that have environmentally, economically, and socially preferable life-cycle impacts. To reward project teams for selecting products for which the chemical ingredients in the product are inventoried using an accepted methodology and for selecting products verified to minimize the use and generation of harmful substances. To reward raw material manufacturers who produce products verified to have improved life-cycle impacts.

    Requirements

    Option 1. material ingredient reporting (1 point)

    Use at least 20 different permanently installed products from at least five different manufacturers that use any of the following programs to demonstrate the chemical inventory of the product to at least 0.1% (1000 ppmParts per million.).

    • Manufacturer Inventory. The manufacturer has published complete content inventory for the product following these guidelines:

      • A publicly available inventory of all ingredients identified by name and Chemical Abstract Service Registration Number (CASRN)
      • Materials defined as trade secret or intellectual property may withhold the name and/or CASRN but must disclose role, amount and hazard screen using either:
        • GreenScreen benchmark, as defined in GreenScreen v1.2.
        • The Globally Harmonized System of Classification and Labeling of Chemicals rev.6 (2015) (GHS)
          • The hazard screen must be applied to each trade secret ingredient and the inventory lists the hazard category for each of the health hazards included in Part 3 of GHS (e.g. “GHS Category 2 Carcinogen”).
          • Identify in the inventory all hazard classes for which a classification cannot be made because there are insufficient data for a particular endpoint(s).
    • Health Product Declaration. The end use product has a published, complete Health Product Declaration with full disclosure of known hazards in compliance with the Health Product Declaration open Standard.
    • Cradle to Cradle. The end use product has been certified at the Cradle to Cradle v2 Basic level or Cradle to Cradle v3 Bronze level.
    • Declare. The Declare product label must indicate that all ingredients have been evaluated and disclosed down to 1000 ppm.
    • ANSI/BIFMA e3 Furniture Sustainability Standard. The documentation from the assessor or scorecard from BIFMA must demonstrate the product earned at least 3 points under 7.5.1.3 Advanced Level in e3-2014 or 3 points under 7.4.1.3 Advanced Level in e3-2012.
    • Cradle to Cradle Material Health Certificate. The product has been certified at the Bronze level or higher and at least 90% of materials are assessed by weight.
    • USGBC approved program. Other USGBC approved programs meeting the material ingredient reporting criteria.

    AND/OR

    Option 2. Material ingredient optimization (1 point)

    Use products that document their material ingredient optimization using the paths below for at least 25%, by cost, of the total value of permanently installed products in the project.

    • GreenScreen v1.2 Benchmark. Products that have fully inventoried chemical ingredients to 100 ppm that have no Benchmark 1 hazards:

      • If any ingredients are assessed with the GreenScreen List Translator, value these products at 100% of cost.
      • If all ingredients are have undergone a full GreenScreen Assessment, value these products at 150% of cost.
    • Cradle to Cradle Certified. End use products are certified Cradle to Cradle. Products will be valued as follows:
      • Cradle to Cradle v2 Gold: 100% of cost
      • Cradle to Cradle v2 Platinum: 150% of cost
      • Cradle to Cradle v3 Silver: 100% of cost
      • Cradle to Cradle v3 Gold or Platinum: 150% of cost
    • International Alternative Compliance Path – REACH Optimization. End use products and materials that do not contain substances that meet REACH criteria for substances of very high concern. If the product contains no ingredients listed on the REACH Authorization or Candidate list, value at 100% of cost.
    • USGBC approved program. Products that comply with USGBC approved building product optimization criteria.
    AND/OR
    Option 3. Product Manufacturer Supply Chain Optimization (1 point)

    Use building products for at least 25%, by cost, of the total value of permanently installed products in the project that:

    • Are sourced from product manufacturers who engage in validated and robust safety, health, hazard, and risk programs which at a minimum document at least 99% (by weight) of the ingredients used to make the building product or building material, and
    • Are sourced from product manufacturers with independent third party verification of their supply chain that at a minimum verifies:
      • Processes are in place to communicate and transparently prioritize chemical ingredients along the supply chain according to available hazard, exposure and use information to identify those that require more detailed evaluation
      • Processes are in place to identify, document, and communicate information on health, safety and environmental characteristics of chemical ingredients
      • Processes are in place to implement measures to manage the health, safety and environmental hazard and risk of chemical ingredients
      • Processes are in place to optimize health, safety and environmental impacts when designing and improving chemical ingredients
      • Processes are in place to communicate, receive and evaluate chemical ingredient safety and stewardship information along the supply chain
      • Safety and stewardship information about the chemical ingredients is publicly available from all points along the supply chain

    Products meeting Option 3 criteria are valued at 100% of their cost for the purposes of credit achievement calculation.

    For credit achievement calculation of options 2 and 3, products sourced (extracted, manufactured, purchased) within 100 miles (160 km) of the project site are valued at 200% of their base contributing cost. For credit achievement calculation, the value of individual products compliant with either option 2 or 3 can be combined to reach the 25% threshold but products compliant with both option 2 and 3 may only be counted once.

    Structure and enclosure materials may not constitute more than 30% of the value of compliant building products.

    Meet the requirements of the credit above and include furniture and furnishings within the project’s scope of work.

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10 Comments

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Joanna Switzer Sustainability Project Manager Atkins North America
Mar 27 2017
LEEDuser Member
868 Thumbs Up

UL Product Lens - any USGBC issued acceptance/precedent?

Project Location: United States

Hi all,

Rumor has it "UL Product Lens" evaluated products qualify for Ingredients Reporting, Option 1. Although the UL website claims this qualification, I am not finding any USGBC/GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC). issued addenda, credit interpretation (or even a press release) to formally approve this strategy.
Anyone aware of a formal precedent for this UL administered program?

Thx

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Jonathan Weiss
Feb 17 2017
LEEDuser Member
2617 Thumbs Up

REACH

Project Location: United States

I see that REACH is listed as an international compliance path, what about a US based project that is using some REACH compliant materials - some specialized application flooring, for example, is manufactured internationally. Does anyone know if this is applicable?

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Paula Melton Senior Editor, BuildingGreen, Inc. Feb 21 2017 LEEDuser Moderator

Sadly, no. REACH is for non-U.S. projects. :-(

Post a Reply
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Laci Wilkes Program Manager CBRE
Dec 03 2015
LEEDuser Member
5 Thumbs Up

Declare Labeled Products

Does the Declare program (and therefore products with Declare labels) fall under the "other USGBC approved programs" for meeting Option 1 for Material Ingredient Reporting?

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Paula Melton Senior Editor, BuildingGreen, Inc. Dec 03 2015 LEEDuser Moderator

Hi, Laci! Good question.

It's my understanding that Declare is in the process of becoming a USGBC-approved program. When the official announcement will be made I do not know.

That said, since we don't have the details yet, keep in mind that a Declare label in itself does not necessarily meet the credit intent, as some people have released them with only 99% of ingredients disclosed, or with proprietary ingredients. So you can probably plan on Declare being acceptable soon, but there may be nuances to which Declare labels count once the official guidance appears. Hope this helps!

Post a Reply
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Jaspreet Pahwa
Jul 16 2015
Guest
26 Thumbs Up

Example of a populated BPDO calculator fro LEEDv4?

Project Location: United States

Trying to determine for EPD tab within BPDO calculator, if the bottom-line of Weighted EPD value needs to be 20 or as long as 20 products from 5 manufacturer's are noted, compliance is met?

Also how would a UL PCR for Insulated Metal panels be classified - my hunch is Industry-wide, but seeking advise from others, below is the PCR link
http://industries.ul.com/wp-content/uploads/sites/2/2014/09/IMPandMetalC...

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Paula Melton Senior Editor, BuildingGreen, Inc. Jan 11 2016 LEEDuser Moderator

Jaspreet, all PCRs (product category rules) are industry-wide. They set the ground rules for doing the LCA and EPD for a whole category of products.

On the calculator, I believe the weighted value must be 20.

Post a Reply
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John Mlade Director, LEED Fellow, WELL AP YR&G
Dec 01 2014
LEEDuser Expert
68 Thumbs Up

Natural Materials

Project Location: United States

Natural materials such as solid wood, stone, clays, etc. all have advantageous material attributes in terms of transparency and health. There does not appear to be any mention of natural materials in the BPDO - Material Ingredients credit.

If a solid stone building product is specified, for example, does it automatically meet Option 1 for Material Reporting or Option 2 for Optimization?

I recognize that FSCIndependent, third-party verification that forest products are produced and sold based on a set of criteria for forest management and chain-of-custody controls developed by the Forest Stewardship Council (FSC), an international nonprofit organization. FSC criteria for certifying forests around the world address forest management, legal issues, indigenous rights, labor rights, multiple benefits, and environmental impacts. wood product and qualifying bio-based materials are addressed in the Sourcing of Raw Materials credit.

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John Mlade Director, LEED Fellow, WELL AP, YR&G Feb 03 2015 LEEDuser Expert 68 Thumbs Up

Currently, untreated and natural stone and wood products can count for both Option 1 and Option 2 of this credit, provided you can prove that they are free of any additives.

Expect that additional guidelines and definitions will be developed to address natural materials in the future.

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Johnna Keller Sep 16 2016 Guest 3 Thumbs Up

John, has any additional information (i.e., published guidance, interpretations, addenda, etc.) regarding natural materials, especially stone, been posted?

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