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Director of Regulatory Affairs
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Council Focuses on Material Ingredient Reporting, Rating Systems, EPD Inclusion, and Process
December 17, 2012 – Bethesda, MD – The Adhesive and Sealant Council (ASC) provided significant input to the United State Green Building Council’s (USGBC) latest revision of their new building construction rating system, Leadership in Energy and Environmental Design (LEED v.4.).
The Council focused its commentary in four areas: Materials Ingredient Reporting, Ratings Systems, Environmental Product Declarations (EPD) and the LEED review process.
“ASC appreciated the opportunity to share its concerns, even though the Council is not a member and therefore not a part of the members-only process the USGBC follows,” stated Matthew E. Croson, President of ASC. “With USGBC’s LEED program becoming a de facto code throughout the United States with zoning boards consistently adopting the program as part of their local code, it’s critically important that input into the draft is considered from the entire supply chain, including non-members.”
Material Ingredient Reporting
With regard to the Material Ingredient Reporting credit, ASC pointed out that the USGBC is suggesting that industry uses a tool for material reporting that was developed to support the research and development efforts of a formulator. The inclusion of the Clean Production Action Network’s GreenScreen Tool as a means for identifying hazards within finished building products is not how the product was envisioned.
“That tool characterizes individual raw material components but does not evaluate the fully reacted ‘finished product’ which is a critical element of building construction,” said Mark Collatz, ASC’s Director of Regulatory Affairs. “Any reference to the GreenScreen Tool should be deleted from the Material Ingredient Reporting credit, or industry should come together and further develop the GreenScreen tool to address building construction materials in their finished form.”
ASC also noted that the USGBC is relying on the “Cradle to Cradle” program as a certification tool for establishing the safety of a given building product.
The concern ASC has with the Cradle to Cradle program is that it is administered by a private organization, and has not been vetted by any standards organizations such as ANSI or ASHRAE.
“Like LEED, the ‘Cradle to Cradle’ system is well known, and there is value within the program as it was developed by engineers and visionaries,” said Collatz. “The problem is that not all industry supply chain participants were included in the process and there are disagreements on definitions, guidelines and practices.”
Environmental Product Declaration Credit
Responding to the proposed Environmental Product Declaration (EPD) credit, ASC offered cautionary support. The desire to leverage EPD’s within the design community is a positive step, but there is no agreed upon product category rule (PCR) established for adhesives and sealants, much less an agreed upon EPD.
“This is a clear example of putting the cart before the horse,” adds Collatz. “An EPD needs PCR information, criteria and boundary conditions in order to be of value to the downstream stakeholders, the design community and building owners, and none of this is spelled out or explained in the draft, and can’t be spelled out without considerable input and consideration from stakeholders.”
ASC also noted that the USGBC should consider a ANSI process for future draft reviews to ensure a broader input of data and information in order for an even stronger, more credible product.
“Everyone knows how powerful a tool like LEED is, with zoning boards across America making LEED the code of choice for new construction with local developers,” said Croson. “But without a true consensus program, the LEED tool will only reflect opinions, and not science or fact, in some of the key areas such as material selection.”
The Adhesive and Sealant Council (ASC) is a North American trade association dedicated to representing the adhesive and sealant industry. The Council is comprised of 124 adhesive and sealant manufacturers, raw material and equipment suppliers, distributors and industry consultants, representing more than 75% of the U.S. industry with operations around the world. Offering education, legislative advocacy, professional networking and business growth solutions for its members, the ASC is the center of knowledge and catalyst for industry growth on a global basis for manufacturers, suppliers and end users.
For more information about ASC, visit www.ascouncil.org.