Requiring EPDs in Technical Specifications

Do any forum participants have anything they can say to the challenge of developing specification clauses to require EPDs for building projects?

Maybe pointers to resources on this topic?

The industry must be dipping its toes into this challenge by now, but I haven’t found too much discussion on it.

Some of the challenging nuances I recognize:

  • You can’t put a blanket requirement for EPDs for all building materials, because they’re simply not going to be available for everything that goes into a building.
  • You need to have specification text that suits all sorts of materials/products: concrete, doors and windows, MEP equipment, etc. Ideally this isn’t bespoke by project, and not too bespoke by material/product specification, because that would be a nightmare to maintain.

Is there a discussion going on about this online, somewhere I simply haven’t found yet?

Hi Mike,

Great point for discussion.

Of course, it’s not possible to put requirements for all products to have EPDs yet we are at a point now that at least for the most contributing materials, you’ll have EPDs available. At the same time, by implementing such requirements in tenders, more and more manufacturers will get pushed towards creating EPDs for their products.

What can be asked in a tender is that the 5-10 most contributing materials to have EPDs (so concretes, steel, glass, insulation) etc. That implies that there would be a tender stage LCA performed to identify such materials or just pre-define which these ten materials will be.

What must be considered here is that even though simply implementing EPDs as a requirement, won’t be enough. There must be a full set of low-carbon procurement requirements where each one would complement the other. That is because the fact that a product has an EPD does not automatically make it a “Better product for the environment”. It has to be ensured that “Greenwashing” is avoided at all costs, so implementing additional measures would help greatly in achieving this. For example, if we were to implement preset carbon intensity targets (i.e. XYZ kgCO2/m2 etc), that would guide a) designers to perform LCAs and optimize their designs and b) manufacturers to improve their processes instead of simply producing EPDs just to be compliant with a requirement.

At One Click LCA we recently published a report that provides such suggestions for Investors and Developers to reduce embodied carbon. The report can be downloaded from the link below:

Decarbonizing Construction

In page 32 you can find construction and procurement phase requirements. In the Annexes you can find sample language to be used, key intent behind each requirement and sample deliverables asked (example in the screenshot below).

In Annex E you’ll find Carbon limit values for different typologies (apartments, offices, etc.)

2 Likes

Hi Mike, a couple of notes.

1: Even if a supplier does not have an EPD at time of bid, you can still include a requirement for product-specific EPDs in the technical spec at time of submittal. The EPDs take about 6 months for a supplier to complete. You can include a qualification for suppliers in the bid process (are they able to procure an EPD per ISO standard?) and then include the EPD requirement in the bid package.

2: Agreed that requesting an EPD isn’t enough. The goal for our technical specs is for the supplier to submit a low-carbon alternative in each product bid package. The low-carbon specs include:

  • Requirement for Type III, product-specific EPD at time of submittal
  • Carbon benchmarks for the supplier to hit (CLF has some great material baselines that I’ve used, also NRMCA has great regional benchmarks for ready-mix)
  • Prescriptive guidance on lowering carbon (will depend per product; See Carbon Smart Pallet for helpful guidance on wood, steel, concrete, etc)

I’ve also seen a total ‘carbon budget’ per project be included in the specs for the supplier to hit. Yes, education and knowledge about carbon emissions will vary across the board and per industry, but including a requirement for a low-carbon alternative to be included in the bid package is really important to the overall low-carbon project goals.

Hi @lindseyengh and @vkalfou

Thanks both for your responses. I seem to have communicated the main challenge effectively, as your responses have been spot on.

Some further context though:
No problems here with respect to going further than EPDs. This is actually the baseline from which I’m starting: Carbon analysis leading to carbon budgets for projects, and then follow-on consulting we do is to guide specs and other parts of the building procurement process to be more sustainable, and to meet various accreditation criteria. We just feel that the standard specs our business puts out should include some EPD-requirements as default now. And to be clear, we’re speaking from design consultant level, rather than the contractor who is actually procuring the products.

Without EPDs, we can still do our carbon analyses against budgets, but because we have to make conservative assumptions about the materials, it’s far harder to hit those carbon budgets we set at an early stage…

But yes, that’s where we are!

Hi @mike.kovacs,

The Port Authority of NY & NJ has recently updated our Division 1 spec to included EPD requirements. Please feel free to reach out to discuss further.

Best,
Peter Bacas
pbacas@panynj.gov

Hi Peter - would you be willing to share that info with me as well? We’ve got some generic spec language around including EPDs “where available” and we are looking to update our language.

We’re also looking to leverage the great data available from EC3 to give us a better reference point for which spec sections to include an EPD requirement (versus recommendation) and also where we could start to think about implementing an embodied carbon performance spec, as EC3 (with the CLF assistance) has done some of the work on setting some benchmark performance figures.

Anyone sent a project with this kind of approach out to bid yet? Our primary concern is that if we create something with tougher language around EPD performance (rather than just EPD inclusion) that we might significantly drive up construction bids.

Hi @Pjbacas , are you willing/able to share your Div. 1 EPD spec language on this forum? I’m sure many of us would appreciate it - I know I would! Please let me know if I need to contact you via email, which I’ll gladly do if you prefer. Many thanks, Stephen

2 Likes

We limited the materials that we are requiring EPDs for to: concrete, asphalt, aluminum and wood. We require a negative proof showing that the contractor searched EC-3, and could not find an EPD. In the absence of an EPD, we apply emissions factors to the ingredients of a concrete mix, thus accounting for mix-specific SCM substitutions.

Dorian
dbailey@panynj.gov

Dorian,

Applying the emission factors to the ingredients of a concrete mix-specific SCM substitutions are they accepted by LEEDv4 reviewers?

We are attempting the LEED Pilot Credit; ”Procurement of Low Carbon Construction Materials”. We are still in the DD stage of project.

Thank you.

David Sundersingh,

LEED Specialist

Hi all, this is a really interesting thread!
We are also currently looking into integrating carbon targets and EPD requirements into our baseline architectural specifications for the practice I work for. This includes asking for general sustainability submittals in our Section A (=UK equivalent to Division 01). For instance Type III EPDs, Declare certification etc, providing GWP information. The challenge for this is, who checks these submittals when the Contractor submits them- is this a new role all architects need to be versed in, or will Sustainability Consultants take responsibility for this as an additional role?
For them to be meaningful, they need to be more than just “information submittals”, and should be actionable. It should also cover the need for EPD submittals for “Contractor Substitutions”, so if a named product is set a s a benchline in the spec, we can compare and reject or accept accordingly.
The other challenge is setting specific embodied carbon targets (performance targets) in our Work Sections, which are so often locale and material specific. We find that some Sections covering a more prescriptive approach (e.g. specifying actual products like floor finishes, insulation etc) are easier to set targets for than say cladding.
Would love to keep this thread open to find out more from you all…
I would also like to add that I am currently working with a Group from LETI (London Energy Transformation Initiative) on guidance to low embodied carbon specifications, which is due to be published next year, so any experiences or comments are much appreciated.

Hi Sidonie,

I agree this is getting very interesting. We can all mutually benefit from this thread.

Will await the info from LETI when it is released.

I like to add that the substitution phase after the bid is the weakest link which needs to be tightened with better specifications.

But the sad truth is that some of the States in the US have very little to offer with Ohio having 1 supplier which does not help in the bidding environment where we need a minimum of 3 suppliers.

Hoping that this tread will encourage entrepreneurs’ to step in to fill the gaps.

Regards to all in this thread.