One of the main reasons USGBC unexpectedly opened a sixth public comment period on LEED version 4 is to gather market feedback on a new option for recognition of sustainability efforts not at the product level, where LEED project teams usually work, but up the supply chain.

“Product Manufacturer Supply Chain Optimization” is a new Option 3 in LEED v4’s Building Product Disclosure and Optimization—Material Ingredients credit. (The credit is slated to be labeled MRc4 and worth two points.)

Option 3: Product Manufacturer Supply Chain Optimization

As currently drafted, the option would reward projects for using building products sourced from manufacturers who procure raw materials from suppliers following health, safety, and environmental standards, with third-party verification.

Like the other options within this credit, the requirements focus on chemical ingredients. But unlike the other credit options, which rely on standards like Cradle to Cradle and formats like the Health Product Declaration to minimize and communicate about ingredient hazards, there are no specific standards named in the current draft. Rather, it calls for verification of general practices along the manufacturer supply chain, such as:

• Communication on health, safety, and environmental characteristics of chemical ingredients.
• Managing the health, safety, and environmental hazard and risk of chemical ingredients.
• Optimizing health, safety, and environmental impacts when designing and improving chemical ingredients.

Transcending the building products industry

In explaining the intent behind Option 3, Brendan Owens, vice president of LEED technical development, told LEEDuser, “I hope it accomplishes a much more systemic engagement with the raw materials and components that end up being the things that we make our buildings out of.” Aside from the new Option 3, Owens explained, “All the credits are targeting the end of the supply chain”—that is, the finished-product end of it—by rewarding projects for using products with certain green labels.

Green specifications have encouraged building product manufacturers to work with their supply chains to provide the necessary products and components to meet LEED requirements. But according to Owens, such credits haven’t directly engaged companies whose businesses are largely or completely about supplying materials to product manufacturers.

By engaging those suppliers more directly, Owens hopes that the new option could increase “the availability of the types of materials that we are encouraging end-use manufacturers to use.” Owens also thinks the credit “has the potential to transcend the building products industry” by introducing LEED’s values and processes into companies that supply multiple industries, such as the automotive or textile industries, to name a couple.

A working group to define specific requirements

Owens acknowledged to LEEDuser that the credit requirements are quite general but that USGBC is now convening a working group to figure out how they would translate to specific industry practices.

Pressed by LEEDuser on the wisdom of introducing a new and poorly defined option into a fraught credit category so late in the LEED v4 development process, especially when other vehicles are open such as the Pilot Credit Library or future introduction as an alternate compliance path, Owens emphasized the statement that USGBC was hoping to make in including Option 3 in the rating system.

“It was an opportunity to say that this is something that we value,” he said. USGBC is “taking advantage of all the different opportunities that exist to leverage LEED as broadly as we can as a transformation mechanism,” he told LEEDuser. According to Owens, while alternate compliance paths and standards are regularly added to LEED without controversy, or member balloting, a member ballot could be used to seek USGBC member approval for specific Option 3 requirements.

LEEDuser also asked Owens if the option is an olive branch to the chemical industry, which has been stirring up trouble for USGBC and LEED. “It’s not very cynical to think that it would be,” Owens said, but “I don’t think it is. We didn’t go down this path trying to find a solution that would mollify the chemical industry, but a good idea came up, and it’s a win for everybody, potentially.”

Not everyone is so enthusiastic about Option 3, however—or the whole makeup of the MR category, for that matter.

“I do appreciate that they’re trying to go up the supply chain,” Eden Brukman, principal with Concenter Solutions, told LEEDuser, but “It adds yet another level of complexity to a credit that’s already fairly complex.” Brukman points out that just within MRc4, there are three options with ten total pathways to earning the credit.

“At the end of reading it, the intent is lost,” she said. Brukman supports a vast simplification of the credit with a focus on Health Product Declarations, GreenScreen, and Cradle to Cradle while putting Option 3 in the Pilot Credit Library for testing and development. Tom Lent, policy director at the Healthy Building Network, makes similar points in a comment on LEEDuser’s LEED v4 forum.

Sizing up the papal candidates

Owens says that it will be up to the working group to define where the rubber meets the road in terms of standards and processes defining MRc4 Option 3. However, LEEDuser has heard the following programs mentioned as being under consideration.

• The Responsible Care program is a condition of membership in the American Chemistry Council (ACC). The program focuses on environmental, health, and safety programs as well as energy efficiency. This year, on the 25th anniversary of Responsible Care in the U.S., ACC announced plans to “enhance” and strengthen the program. The idea of an ACC program becoming a part of LEED has a fox-in-the-henhouse quality to some onlookers. Owens told LEEDuser that Responsible Care has come up in some conversations, and while “it could on its face do some of what we’re after, whether it is sufficient is too soon to tell.”
• The Occupational Safety and Health Administration (OSHA)’s revised Hazard Communication Standard (HCS 2012) covers at least some aspects of Option 3, such as “comprehensive hazard communication programs.” As a basic law of the land, and not a leadership standard, OSHA shouldn’t be seen as a serious contender here, but it could help define the parameters that a leadership program is expected to exceed.
• NSF/GCI/ANSI 355: Greener Chemicals and Processes Information Standard is, to quote NSF, “the only standard available with which to document information on sustainability-related attributes of chemical products and processes, thus allowing manufacturers and formulators to easily compare the hazards and process impacts of chemical products.” NSF, which has other credible sustainability-related standards, could be seen as a more credible benchmarking group for Option 3, but NSF-355 hasn’t been evaluated yet for this credit.
• Various ISO standards.

What do you think of the new Option 3, the MR category in general, and the LEED v4 process? How do you think the industry might adapt to these new requirements? Please post your comments below.