I think it is a fundamental issue that was not resolved after the recent concrete PCR. We proposed the following solutions to move towards a performance-based assessment that realistically address the functionality of the concrete mixture. The following paragraph is a part of a project report that I wrote about meta-analysis and harmonization of concrete EPDs.
“There is an interesting momentum among concrete stakeholders to shift from a prescription-based design to the performance-based design. Considering this momentum, it seems quite relevant and critical to track the EPD results reported through a more comprehensive specification level. One should note that only the 28-day compressive strength (and in few cases 56-day compressive strength) was reported in the published EPDs and the industry benchmarks. Indeed, the 28-day compressive strength might not reflect all the required performance metrics for structural applications. As different design standards and guidelines require different metrics, it seems inaccurate to estimate these performances (e.g. early age strength, flexural strength, workability, and durability) based on the 28-day compressive strength. Therefore, a fair comparison of EPDs for different mix designs selected for a specific structural element, that is exposed to an aggressive environment, may not be viable with the current format. The other example is for concrete pavement that the flexural strength is the main input for the mechanical properties used in pavement design. Therefore, we propose to incorporate at least, the exposure class (according to Table 220.127.116.11 in ACI 318-19- Building Code Requirements for Structural Concrete) for concrete used in buildings as a mandatory performance specification to be reported in EPDs. Also, we propose to include flexural strength, shrinkage, and stiffness (Young’s modulus) as the mandatory specification for EPDs used for concrete pavements. These properties will give a clear apple-to-apple comparison among the other results.”