One of the hottest topics in the field of healthcare design is understanding the sustainable requirements and relevant information available for specifying materials. With the advent of LEED v4, which includes LEED for Healthcare, and the update of Green Globes—New Construction and Green Globes—Continual Improvement for Existing Buildings (CIEB) for Healthcare, there are now extra demands placed on healthcare interior designers as they evaluate product for hospitals, outpatient and residential care facilities.
Taking a healthcare-oriented perspective on sustainability can lead to an extremely complex set of challenges, because product evaluations must take into consideration both environmental and potential human health impacts. Factors such as service life, infection control, maintenance efficiency are also critical to performance. Here is some guidance for navigating the maze of sustainable information available and advice on what to request from manufacturers.
Environmental Product Declarations
In an effort to provide transparency regarding product contents, Environmental Product Declarations (EPDs) have been deemed an appropriate vehicle for identifying the ingredients (feedstocks) used to manufacture a product. A Type-III EPD is based upon ISO standards that utilize a life-cycle approach for evaluation. This means that potential impacts to the environment are considered for each phase in a product’s life, including sourcing/extraction, manufacturing, installation, use and end-of-life.
There are two classifications of Type III EPDs: industry wide EPDs, which are generic to a product type, and Product Specific Declarations, which are manufacturer-specific for a family of products. The most recent EPDs that I’ve reviewed are available from the Resilient Floor Covering Institute (RFCI), and include third-party industry wide EPDs completed for various synthetic rubber and vinyl products. The development process spanned more than a year and included 12 resilient flooring manufacturers. These EPDs are available from UL Environment and RFCI.
Another way to compare and evaluate products for sustainable specification is the utilization of third-party certified multiple-attribute standards. Multiple-attribute standards are based upon a consensus process (usually ANSI) that includes all product-specific stakeholders. Criteria for product evaluation are agreed upon through the consensus process, and include information on feedstocks and manufacturing processes.
Examples of multi-attribute standards include NSF International sustainability assessment standards, UL Environment sustainability certifications and sustainable forestry certifications, such as NSF/ANSI 140 for Carpet and the ANSI/BIFMA e3 Furniture Sustainability Standard.
The third way to evaluate products is to utilize third-party certified Life-Cycle Assessments (LCAs) of products. Some manufacturers complete third-party LCAs that demonstrate the complete life-cycle of their product. These LCAs can be completed by a manufacturer and third-party certifier, or the LCA can be completed in its entirety by a third-party. This option allows a design professional to compare products from the same manufacturer based upon their environmental footprints.
Health Product Declarations
The latest development in understanding the impact of products on human health is the inclusion of Health Product Declarations (HPDs) in LEED v4. HPDs are intended to provide transparency in regard to product ingredients to help designers ensure a building is safe for both workers and occupants. Designers using HPDs can verify if any of the ingredients in a product are hazardous or not, although it has also unfortunately given rise to a “red list” approach to evaluating product hazards. This can be misleading to the design community.
HPDs treat ingredients as pure chemicals rather than part of a formulation that is bound into a product, creating a perception that products and their ingredients are either “good or bad.” Most chemical lists developed by the EPA and other agencies in the United States and abroad evaluate risks based upon thresholds (the amount of a substance or chemical utilized), and provide labeling and handling instructions as a result of a certain threshold. The evaluation of products based upon a listing of ingredients without understanding the formulations and risk thresholds leads to a “de-selection” approach to product selection, which is not necessarily the most sustainable or safest choice.
Product Transparency Declarations
The other development that healthcare designers will find useful is the Product Transparency Declaration (PTD). This document is intended to disclose the known ingredients of a product specified for a project, and provide design professionals, contractors and building occupants with additional information that is helpful in assessing those ingredients’ health risks. PTDs include additional information regarding recycled content and VOC analysis from a finished building perspective, as well as a section that covers various product certifications like EPDs, multiple attribute standards and LCAs.
The overall goal of Product Transparency Declarations is threefold:
- to provide a simpler, less expensive way to determine ingredient and exposure information in an easy-to-use and understandable format;
- to focus on the need of a specifier to determine if the ingredients in a building product will potentially expose building occupants or installers to harmful ingredients; and
- to ensure that the information is based on an authoritative list and regulatory program(s) that have hazard-exposure triggers and labeling requirements.
The stakeholders behind the development of PTDs have committed to putting the format through the ANSI consensus process to ensure that all industry stakeholders have an opportunity to participate in its further development. This will allow different manufacturers across different fields, design professionals and building rating entities to come together to develop a common standard for PTDs, and will benefit design professionals by ensuring consistent reporting and formatting of the requested data.
HPDs and PTDs: What’s the Difference?
HPDs require a manufacturer to state the actual percentage or percentage ranges of each ingredient in a finished product. Manufacturers must also include the percentage of an ingredient if it varies over time and describe why the ranges vary.
This type of information is unnecessary in determining whether an ingredient in a product is listed as a hazard. There are over more than 30 chemical lists referenced in HPDs; however, most of them carry no authoritative backing. PTDs, on the other hand, use six well-recognized regulatory sources—among them, OSHA’s Hazard Communication Standard 2010 and California’s Proposition 65, both of which relate to exposure and require warning labeling based upon exposure levels.
Neither OSHA nor Prop 65 are intended as “de-selection listings,” but lists that address a level of exposure and labeling relevant to the hazard. For example, wood dust is considered a carcinogen by Prop 65; however, if a wood product is manufactured and installed properly, wood dust is not a concern within a finished building space. If those working in a manufacturing facility or installing a finished wood product on a job site follow the appropriate procedures and use protective equipment, then a product is not a health risk within that space.
I’ve received calls and emails from association representatives, speakers, manufacturers, standard developers and design professionals trying to sort through the maze of environmental product information that is applicable to healthcare projects. Understanding that EPDs, LCAs and multiple attribute certifications are available in the marketplace and growing based upon the development of standards and green building rating systems is a step toward desired transparency.
However, HPDs or PTDs have to be considered in conjunction with considerations of potential liability on the side of a design firm. If a firm requests and accepts an HPD that includes hazardous ingredients, the firm accepts the responsibility for either evaluating the hazardous ingredients or sharing this information with their clients. One of the attorneys on the EBN webcast “Increased Transparency, Increased Liability for Designers” mentioned that designers do not have the technical knowledge to determine if there is a health risk from product ingredients. Therefore, the development of PTDs that include the exposure/risk concept may be a better direction for firms evaluating transparency related to health hazards when balanced with a firm’s liability risk.
In 2014, the updated ASHRAE 189.1 Standard for the Design of High-Performance Green Buildings Except Low-Rise Residential Buildings and the ASHRAE 189.3 Proposed Standard for the Design, Construction and Operation of Sustainable High Performance Health Care Facilities are anticipated for publication. Similar to ASHRAE 189.1, it is the goal of industry stakeholders for 189.3 to become the healthcare alternative path of compliance to the International Green Construction Code (IgCC).
In regards to licensing, the Facility Guidelines Institute is finalizing a sustainability white paper in collaboration with the ASHE Sustainability Committee referenced within the 2014 “Guidelines for Design and Construction of Hospital and Outpatient Facilities.” Sustainability information is also provided within the brand new 2014 “Guidelines for Design and Construction of Residential Health, Care, and Support Facilities,” including references to the “Senior Living Sustainability Guide®”.
From both a building code and licensing code perspective, it is anticipated that product transparency, EPDs, LCAs and multiple attribute certifications will be addressed and continue to develop as HPDs and PTDs evolve, continuing to impact the evaluation and specification of sustainable products in healthcare environments.
Jane Rohde is the founding Principal of JSR Associates, Inc. located in Ellicott City, Md. She champions a global cultural shift toward de-institutionalizing senior living and healthcare facilities through person-centered principles, research and advocacy, and design of the built environment. Rohde speaks internationally on senior living, aging, healthcare, evidence-based design and sustainability.
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