Hi Everyone, First off, Shen and Christoph, thank you for the comments/feedback. A couple things to note: ISO 21930 requires 'all hazardous and toxic materials and substances shall be included in the inventory' (their terms). I don't really see this statement affecting anything in the EPD, my interpretation is just it is a precaution to ensure companies don't try to exclude hazardous materials through the cut-off criteria. I understand the points you are both making (and happen to agree with them), but want to be consistent with ISO. In the original language in the cut-off criteria section, I had wrote that these had to be disclosed and this was a misinterpretation on my part. I am not necessarily against disclosing these chemicals in some form, but I would argue it is outside of the scope of an EPD. Especially when there are outlets such as HPDs and GreenScreen (which have their own LEED v4 credits), I do not believe that an EPD is the outlet to properly define and disclose what hazardous material/chemicals are present at this time. As you both noted, the lists would also be difficult to collect and disclose. Finally, I am open to if we use RCRA, GHS, or some other classification scheme for the inventory side. I submitted the draft PCR to Jessica yesterday to share with the reviewers and asked her to highlight these sections to get their comments/thoughts. As such, I recommend that we keep this issue open to discuss once we have their feedback on ISO compliance . After all, being ISO 21930 compliant is one of our main goals. After talking through the hazardous classification schemes more, my only slight preference for GHS is that since most of the potential exposure to these raw chemicals would happen during manufacturing, that the OSHA approach may make more sense. However, given incompatibility of certain schemes and with the limitations of hazards/toxicity, I do not feel very strongly for one accredited system versus another. As such, I am open to whatever the group feels is most appropriate. I hope everyone is doing well. Warmest Regards, Doug From: Christoph Koffler <C.Koffler@xxxxxxxxxxxxxxxxxxxx> To: Shen Tian <shen.tian@xxxxxxxxx>, "Douglas P. Mazeffa" <Douglas.P.Mazeffa@xxxxxxxxxxx>, "aca_pcr_architectual@xxxxxxxxxxxxxxxxx" <aca_pcr_architectual@xxxxxxxxxxxxxxxxx> Cc: "Timothy Serie (tserie@xxxxxxxxx)" <tserie@xxxxxxxxx>, Lisa Marie Nespoli <lisamarie.nespoli@xxxxxxxxx>, Catherine Sayles <catherine.sayles@xxxxxxxxx> Date: 02/11/2015 10:38 PM Subject: RE: [aca_pcr_architectual] Architectural Coating PCR Revised Language Dear all, I want to second Shen’s comments. A threshold may make sense. However, I was wondering, what is the point of including “hazardous materials” in the “inventory” in the first place as these are intermediate flows with no relevance to impact assessment unless emitted. So including material flows in the inventory because they are hazardous seems moot as LCA doesn’t consider hazard - unless the underlying assumption is that if a substance is hazardous, it’s upstream inventory automatically includes emissions of that same substance? But if we don’t look at USEtox anyways, then what’s the point? So disclosing these substances in the EPD itself (e.g., under additional environmental information) may make more sense than including it in the inventory. A threshold may again help to keep this list short. TBD. Best, Chris Christoph Koffler, PhD Technical Director PE INTERNATIONAL, Inc. Boston, MA USA Mobile +1 617 817 1988 Phone +1 617 247 4477 ext. 101 E-Mail c.koffler@xxxxxxxxxxxxxxxxxxxx
www.pe-international.com From: aca_pcr_architectual@xxxxxxxxxxxxxxxxx [ mailto:aca_pcr_architectual@xxxxxxxxxxxxxxxxx ] On Behalf Of Shen Tian Sent: Wednesday, February 11, 2015 5:50 PM To: Douglas P. Mazeffa; aca_pcr_architectual@xxxxxxxxxxxxxxxxx Cc: Timothy Serie (tserie@xxxxxxxxx); Lisa Marie Nespoli; Catherine Sayles Subject: RE: [aca_pcr_architectual] Architectural Coating PCR Revised Language Dear All: I would like to comment this proposed change. After learning from Lisa, here are a few points from our side: 1. GHS vs. RCRA: Unlike RCRA hazard definition, GHS definition on hazards is regional and company specific which means one chemical could be classified as hazard in EU but not in US or vice versa. This may cause inconsistency in building the LCI. Instead, RCRA has a clear list of chemicals should be classified as hazard. Also, with GHS primarily focusing on the occupational setting, for an Environmental Product Declaration, we could be aligned better by using EPA’s RCRA definition which focuses more on environmental fate of a chemical/product/waste. 2. From the LCA perspective, I was thinking if human and eco-toxicity are not mandatory impact categories and for some cases, no characterization factors are associated with those chemicals, is this PCR proposing we need to include every single hazard chemical in the LCI even neither midpoint nor endpoint LCIA results will be generated from those chemicals? I guess we may want to add a threshold because even those extreme “hazard-only” initiatives are using 100 ppm in the ingredients as a threshold (e.g. Cradle-to-Cradle). In addition, if we adopt GHS definition, under certain conditions, the required “hazard chemicals” to be included could be much more than RCRA which might not be practical. We would welcome any further discussions. Thanks Shen Best Shen Tian, P.E.*, REHS Environmental, Health and Safety Engineer Product Safety & Regulatory Affairs Bayer MaterialScience, LLC 100 Bayer Road Pittsburgh, PA, 15205 O: 412-777-2193 C: 412-979-8759 Email: shen.tian@xxxxxxxxx * Licensed in Texas, Pennsylvania and Arizona From: aca_pcr_architectual@xxxxxxxxxxxxxxxxx [ mailto:aca_pcr_architectual@xxxxxxxxxxxxxxxxx ] On Behalf Of Douglas P. Mazeffa Sent: Monday, February 09, 2015 2:22 PM To: aca_pcr_architectual@xxxxxxxxxxxxxxxxx Subject: [aca_pcr_architectual] Architectural Coating PCR Revised Language Hi Everyone, Please see the proposed language change and let me know if there are any concerns/comments/questions. Original Language: Cut-off rules shall be as described in ISO 21930 clause 6.2.7.2. A minimum of 95% of the total mass, energy, and environmental relevance for the system shall be captured. For materials characterized as hazardous and/or toxic by the EPA (As defined by RCRA under 40 CFR 261.33), cut-off rules do not apply and such substances shall be disclosed (see section 13 for where such information should be disclosed). Revised Language: Cut-off rules shall be as described in ISO 21930 clause 6.2.7.2. A minimum of 95% of the total mass, energy, and environmental relevance for the system shall be captured. For materials characterized as hazardous and/or toxic by the Globally Harmonized System (GHS), cut-off rules do not apply and such substances shall be included in the inventory. Also, regarding the changes discussed on page 31 on hazardous waste disclosure: After re-reading ISO 21930 I am not sure we can limit it to just gate-gate. ISO 21930 says that waste data shall be expressed in percentage terms or as mass per functional unit. We may be able to disclose the proportion of waste/hazardous waste in percentage terms (which is left open), but we certainly can't limit it to gate-to-gate if it is in terms per functional unit. I will revise the language to be in percentage terms for gate-gate for now and then will highlight this for the reviewers. Please let me know if there are any other questions or comments and thanks for your help. Cheers, Doug The information contained in this e-mail is for the exclusive use of the intended recipient(s) and may be confidential, proprietary, and/or legally privileged. Inadvertent disclosure of this message does not constitute a waiver of any privilege. If you receive this message in error, please do not directly or indirectly use, print, copy, forward, or disclose any part of this message. Please also delete this e-mail and all copies and notify the sender. Thank you. For alternate languages please go to
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