The ABCs of EPDs

July 10, 2019 Jay Shilstone

The ABCs of EPDs 
December 17, 2012 

Odds are, many of you have already heard about EPDs, Environmental Product Declarations, and PCRs, Product Category Rules. For those who haven’t, an EPD is sort of like a food nutrition label, except it lists things like CO2 generation, heavy metals content and waste water generation. The purpose of an EPD is to inform the owner/consumer of the impact his construction choices will have on the environment. The owner can then make more intelligent decisions about choosing construction options that will minimize a building’s impact on Mother Earth. This is an admirable goal, but …. (you can fill in your own concerns here). An even bigger potential problem is that some of the decisions about EPDs and their use are being made by people who don’t know anything about concrete. Members of the concrete industry must get involved in the process to avoid being governed by those who either don’t know about concrete or, even worse, those who compete against concrete. 

Let me preface the remainder of this discussion by stating that I am not an expert in this stuff. It is incredibly convoluted and to truly understand it requires a strong time commitment. There are rules for creating rules, rules for defining rules, rules for labeling rules and rules for creating rules for creating rule, ad nauseum.  The following is my understanding of what is going on. 

How is an EPD created? The rules for creating an EPD are set up in a document (or documents) called “Product Category Rules”, PCRs. The European Union has already developed its own PCR, and now the U.S. is has one, primarily being led by the University of Washington’s “Carbon Leadership Forum” – www.carbonleadershipforum.org. The document was finalized on November 30, 2012. The National Ready Mixed Concrete Association was one of the contributors to the document. A really good PowerPoint presentation on their website is at http://www.nrmca.org/sustainability/EPDs%20for%20Concrete.pdf . As far as I know, the American Concrete Institute wasn’t directly involved in the process. This process if moving much too quickly for typical ACI involvement. Other industry participants include Central Concrete, in California, and a group of Contractors and Architects. To give you an idea of how fast things are moving in this area, the final review process for the PCR was almost over before I even heard about it.  

What is an EPD based on? In summary, the contents of an EPD are based on the following: 

  • EPDs (food labels) for the primary constituents, cement, rock, sand and potentially water. Admixtures and mineral additives, such as fly ash, GGBFS and silica fume, that are the by-products of other process are excluded. 

  • The energy expenditure to get the constituents from their supplier to the concrete producer. This is primarily a function of the distance between the supplier and producer and the type of fuel used by the delivery vehicle. This includes backhauls for empty vehicles. 

  • The type and source of energy to produce the concrete 

  • The distance from the plant to the jobsite and the fuel source for the concrete trucks. 

  • A life cycle cost analysis of the above 

  • There is even talk of requiring a life cycle cost analysis to include disposal of the concrete when the structure reaches its end of life. 

How will the concrete producer create an EPD? Probably initially to create an EPD most producers will have to hire a consultant. It is my understanding that a website is currently being set up to do them, and probably most software vendors will create programs to do them, but even so, it will probably be easiest to hire an outside consultant who knows about these things. 

How much will it cost to create an EPD? It is my understanding that Central Concrete spent well over $100,000 to put into place their EPD infrastructure. Their process went way beyond to the typical involvement most producers will have, but in any case the first EPD will be very expensive. After that the price of creating additional declarations for mixes using the same materials should be minimal, but the price of adding additional materials will be higher. The problem is that after the EPD is created, it must be certified by an outside agency. The NRMCA has registered to become an EPD Program Operator to handle the certification, but initial indications are that it is expected the cost for reviewing an EPD for a single mix, or possibly a mix family, will be about $3,000-$5,000.  

Note that there are provisions for non-certified EPDs, but unless someone can champion their acceptance by specifiers, non-certified EPDs will not be accepted. 

Will producers have to create EPDs? In my opinion any producer that provides concrete for public projects will ultimately have to provide an EPD. LEED certification may also require EPDs. Additionally, I wouldn’t be surprised if California, and possibly Oregon, Washington and Colorado, required EPDs for all concrete mixes. 

What can possibly go worng? (For you sharp-eyed grammarians, yes, I misspelled “wrong”. Thanks to the movie “Future World” for the idea.) In my opinion, pretty much anything that can go wrong either has or will go wrong. While Central Concrete’s and NRMCA’s involvement in the process has helped, the NRMCA doesn’t represent all concrete producers. Also, they were just 2 voices among many others, a number of whom don’t understand the concrete construction process. We need more people to participate in the entire process. Just attending the NRMCA’s Sustainability Forum once a year isn’t enough. The Sustainability movement operates in Internet time, not on concrete association time. Small producers who can’t afford to be involved in the process can easily get steam-rollered. 

Finally, think of what can go wrong when the politicians, environmentalists and accountants get involved (and don’t think they aren’t already). If the rules are stacked against concrete, or for another product, concrete may lose significant concrete market share. I have a friend who claims the entire EPA/fly ash issue is an effort on the part of environmental groups and industry competitors to shut down coal fired power plants. While this sounds like “conspiracy theory” talk, who is to say that he isn’t right? Lobbyists make a fortune trying to get laws written in a way that will help their clients. 

Don’t get me wrong. I think we have to protect the planet. I drive a Prius. I recycle as best I can. However, I don’t bring my own bags to the grocery store and I still use Styrofoam cups. I also believe that if the concrete industry doesn’t get more involved in setting up the rules that will govern us, we will be at a disadvantage compared to other materials industries that do get involved. 

[Ed. Note – A lot has changed in the world of EPDs since 2012. The NRMCA now produces “Industry Standard EPDs” https://www.nrmca.org/sustainability/EPDProgram/ . COMMANDqc now integrates with Climate Earth’s EPD generator and can request EPDs from CE and attach them to the related mix designs. If you are interested in EPDs, check out the NRMCA website, as well as ASTM’s EPD webside, https://www.astm.org/CERTIFICATION/EpdAndPCRs.html and do a Google search. A lot more information is now available.] 

As always, please post a comment and let me know what you think.

 

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