EPDs are failing, here’s how.

Environmental Product Declarations (EPDs) quantifiably demonstrate the environmental impact of a product through Life Cycle Assessments (LCA).

Ryan Philp
Greener Together

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Photo by Ashkan Forouzani on Unsplash

We are OBSESSED with Net Zero.

It’s tangible. Relatively easy to comprehend and easy to measure.

Whether or not you are reducing carbon emissions is pretty black and white.

The construction industry in the UK seems to have recognised the significance of measuring whole life carbon and is now fully embracing EPDs.

Manufacturers and suppliers alike are rushing to produce EPDs to meet the growing demand and expectation for more environmentally friendly products.

And yet, in our race to reduce carbon emissions, are we missing something?

Have we been blinded by Carbon?

Let’s start with what an EPD is…

The Life Cycle Assessment and subsequent EPD publication is a desktop exercise requiring information to be gathered relating to the factories material consumption, energy, water and waste typically for 1 full production year.

BRE: What is an EPD — Lifecycle analysis

An LCA is performed using a peer-reviewed Product Category Rules document (PCR) in line with EN 15804, ISO 14025, and other related international standards.

They can be used as marketing material, and for the improvement of product manufacturing/ process efficiency.

They can also feed into whole building assessment schemes, building information modeling (BIM) CAD software to make comparisons and assess design options that improve a building’s environmental performance.

This is where their value is being realised by the construction industry. To help credibly determine whether a building/ development is meeting (whole life) carbon reduction targets.

Photo by Danist Soh on Unsplash

When we talk about product EPDs, we are essentially looking into the whole supply chain process that feeds into the production of said product/ material.

In the same sense, when organisations measure their Scope 3 emissions — they are taking into consideration the whole supply chain that feeds into their business.

The GHG Protocol’s Corporate Value Chain (Scope 3) Standard identifies 15 Catagories

To understand where EPDs fall short, we need to know what EPDs are not…

EPDs measure carbon and environmental impacts.

They do not measure societal impacts*.

Very few emissions may have gone into creating product X, but we’ve no clear way of ascertaining the quality of safety standards that workers were subjected to when mining, transporting or assembling this product.

I’ve just finished reading Cobalt Red, and if you’ve read this book, then you’ll already know where I’m going with this article. If you haven’t, please keep reading, and then pick up a copy of the book yourself.

*It’s worth noting here that EPDs do measure ‘human toxicity’ — though this can be viewed as a loophole.

View of artisanal miners working at the Shabara artisanal mine near Kolwezi on October 12, 2022.

Cobalt is used to make lithium iron batteries, used in smart phones and increasingly EVs.

70% worlds cobalt supply comes from Democratic Republic of Congo (DRC), as the world transitions to green energy, demand for cobalt has tripled in the last decade and expected to double again by 2030.

Many of the mines operate illegally, some of which with child labour. Working conditions are unregulated and dangerous.

In truth, this is a tame summary of the conditions that the Congolese people are exposed to.

Carbon Tunnel Vision

This brings me onto Carbon Tunnel Vision.

Sustainability isn’t about just focusing on Carbon Emissions, and yet it takes up most of the conversations we are having.

Carbon Emissions, Health, Education, Air Pollution, Biodiversity, they are all interconnected.

Carbon Tunnel Vision

We cannot and should not, address one without considering the impacts on another.

Understanding how social injustices cross with the environmental crisis, is a core part of the Intersectional Environmentalist movement, coined by Leah Thomas.

The climate crisis is pressing and serious, we need to reduce carbon emissions as much as possible and as quickly as possible.

We need EPDs and similar peer-reviewed processes to ensure we are doing this in a credible way.

But we also need to protect people, workers and livelihoods around the world in a just and equitable way.

What about Construction?

Positive steps are being made.

Many leading developers (domestic and non-domestic) and real-estate agencies have supply chain agreements and frameworks in place; these ensure supply chain partners provide a safe and healthy working environment, respect fundamental human rights, have modern anti-slavery policies and work to reduce environmental impacts.

This is an area where EPDs and Scope 1,2,3 tracking can really help.

By no means does this absolutely ensure the whole supply chain will meet these standards, but it does at least set a standard and an expectation, one we should all continuously strive to meet.

More awareness is needed on this topic from all of us, as well as a greater level of accountability from those across the whole supply chain to make sure we are working together to improve the lives and working conditions of those affected by our products/ services.

At manufacturer and supplier level, there are standards set in place by the likes of the BRE — such as BES6001 — to establish Framework Standards for Responsible Sourcing of materials.

This does look into business ethics, human rights and modern slavery, as well as LCA and energy use among other criterion.

The topics included in version 4.0 of the BES 6001 standard

What else can be done?

Reducing demand of raw materials will certainly play a part in a sustainable future, having control over the materials that are already in circulation and sit within our existing building stock can help alleviate the strain put onto countries that have these mineral resources.

What’s not getting recycled on your projects that could be?

Desks? Glass? Metal? Wiring? Carpet Tiles? Cable Trays? Wood? Refrigerants?

Of course, we cannot simply shift our material demand and supply chains away from problematic areas, in doing so could create further unknown economic disruption to the people whos livelihoods are based on this employment (which often can be the only available option).

But supply chains can co-operate, pull together and put in place protection and safety measures for those most vulnerable.

Lets celebrate organisations that are prioritisng environmental and societal standards across their business and supply chains, and demand better from those that aren’t.

Request Environmental Product Declarations AND Responsible Sourcing/ anti-slavery statements.

Our ‘Green Buildings’ and Sustainable Lifestyles™ should not come at detriment to others around the world.

We cannot continue to allow the Worlds most vulnerable Nations to suffer disproportionately

Photo by Photo Boards on Unsplash

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