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Supply Chain Optimization
These requirements builds on programs that many companies already have in place, specifically environmental management systems (EMS) such as ISO 14001 and health and safety management systems such as OHSAS 18000, to meet and document compliance with Option 3. To comply with this option, the building product manufacturer (BPM), and any company that supplies it with ingredients or components that are significant health hazards, must have a robust program for continual improvement in environmental management and health & safety management. Specific industry programs that are consistent with ISO 14001:2015 include:
• RC14001:2013 Responsible Care
• ChemStewards Integrated Management System-2011
The building product manufacturer publishes a publicly available set of guiding principles for the optimization of ingredients and products in their supply chain with an emphasis on human and environmental health. The principles may be a standalone document or part of a website or other document. The principles include, at a minimum and in the building product manufacturer’s own words, the following:
a. a commitment toward continual improvement (e.g., actual or attempted reduction in use of hazardous chemicals) in their supply chain;
b. a commitment toward greater communication and transfer of information within their supply chain and with their industry partners; and
c. a commitment to applying the principles of green chemistry and principles of green engineering
These principles should be endorsed by top management and referenced in documentation relating to Option 3 conformance.
The manufacturer of permanently installed building products determines the composition of the ingredients and components it’s buying, based on final composition of the product in question, to at least the 99% level by mass; no more than 1% of the contents can remain undetermined. A product disclosed via an approved method for Option 1 (such as Declare or HPD or other manufacturers inventory) could also be used to demonstrate conformance. If a supplier chooses to withhold the chemical identity of materials defined as trade secret or intellectual property, they may withhold the name and/or CASRN but must disclose role, amount and associated GHS Hazard classification of each ingredient via Safety Data Sheet and/or supplier’s documentation on company letterhead, signed by a company official. In the case of mixtures, each ingredient in the mixture must be documented. The manufacturer will typically obtain this information from its first-tier suppliers, although if those suppliers provide manufactured components it may be necessary to reach further back into the supply chain to obtain content information to the 99% level.
All documented ingredients representing at least 99% by mass of the final product shall be screened for human health and environmental hazard characteristics according to the most current available criteria of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). For each product, any ingredient that is flagged against the hazard criteria identified in Table 2 is determined to “not pass” the hazard screen, and shall be addressed by the building product manufacturer’s environmental and health & safety management systems and supplier engagement (see below). While the GHS Screening is required, it is encouraged to go beyond the GHS screening criteria. For example, if a hazardous chemical is present at 0.05% in product but the GHS screening level is at 0.1%, the building product manufacturer is encouraged but not required to flag the ingredient.
Ingredients with data gaps (no information available on the substance for one or more endpoints) should be flagged (i.e., should not pass) the hazard screen. If the 99% of ingredients to be screened includes recycled content
, the building product manufacturer shall document its best management practices to characterize the sources of pre- and post-consumer recycled material and reduce or eliminate hazards associated with these materials.
Table 2. GHS Hazard Criteria by Endpoint for Option 3 Screening: http://www.usgbc.org/resources/scowg-li-table-2
Environmental and Health & Safety Management Systems
Building product manufacturers shall have programs for environmental and health & safety management that include all the essential elements listed below and cover the facility, facilities, or portion of a facility where the building products for which the manufacturer seeks credit under Option 3 are manufactured. Building product manufacturers may need to specify new requirements or processes as compared to existing ISO or Responsible Care systems to meet these requirements. This step describes an environmental or health and safety management system as the framework, with health and safety criteria added to the EMS, but the systems can be combined differently as long as they contain the same elements.
For the purposes of documenting conformance with Option 3, all building product manufacturer’s environmental and health & safety management systems must meet requirements 1 through 3 for the facility, facilities, or portion of a facility where the building product in question is manufactured, whether these systems are separate or combined into one:
1. Publicly available policy statement signed by top management that describes the company’s commitment and what the environmental or health and safety management system is intended to achieve.
2. Processes or controls that address continual improvement based on a list of existing and potential environmental aspects and impacts or health and safety risks. The plan must include:
a. Targets and objectives addressing all significant environmental aspects or health and safety risks on list.
b. Monitoring and measurement of key elements in the operation that have relevant impacts.
c. Documented activities implementing the plan.
d. Internal evaluation, corrective action and audits of conformance to plan.
e. Communication to top management about results of audits.
3. The management system policy and plan shall include chemical safety & health as objectives with specific targets and goals in the plan. Joint objectives and targets set at both the corporate level and operational level are found to be most effective as they show a level of commitment throughout the organization. As a general framework, the plan should seek to, on a continual improvement basis:
a. eliminate the use of hazardous ingredients,
b. minimize the use of hazardous ingredients where elimination is not possible,
c. transition to more effective control measures where hazardous ingredients remain, and
d. manage those remaining hazardous ingredients responsibly with a goal of zero exposure and discharge to humans and the environment.
Building product managers with one or more hazard flagged ingredients must further meet requirements 4 through 6:
4. For any building product for which the manufacturer seeks credit under Option 3, at least 99% by mass of the ingredients comprising that product must be identified and screened for hazardous characteristics pursuant to Sections 2.2 and 2.3. ,
5. The building product manufacturer shall share hazardous characteristics for each ingredient that fails the hazard screen with customers to inform their appropriate handling, installation, and management of the product, and with suppliers as an input to their management system prioritization.
6. The management system shall have a continual improvement plan to evaluate and eliminate or reduce chemical hazards and exposure to the ingredients in the final building products as well as chemical hazards and exposures during the manufacturing processes.
a. For optimization purposes established frameworks that contain steps for the comparative or alternatives assessment that meet the intent of this requirement are listed below, but others can also be used as long as they are known as acceptable equivalents. Frameworks that factor in broader environmental impacts such as climate change and resource extraction impacts are encouraged but not required.
i. National Academy of Sciences (National Research Council) Alternatives Assessment Framework
ii. BizNGO Chemical Alternatives Assessment Protocol
iii. Interstate Chemicals Clearinghouse Alternatives Assessment Guide
Suppliers of any chemical ingredient or component flagged in the hazard screen must have systems for environmental and health & safety management as described above, items 1–3. The building product manufacturer will notify its immediate (first-tier) suppliers that this requirement is due to the presence of flagged ingredients or components.
The supplier provides documentation of its management system(s) to the building product manufacturer. This documentation can be third party verification or a self-declaration stating that processes are in place for the ingredients and/or components supplied. Any self-declaration must be accompanied by supporting documentation, which must be reviewed as part of the third-party verification of the building product manufacturer’s environmental and health & safety management systems.
The building product manufacturer obtains third-party validation of fulfillment of the requirements of Option 3. Pre-existing audit processes may be acceptable if the audit process specifically includes validation of Option 3-related steps, including confirming that the steps listed above are completed and a review of documentation from the suppliers about their corresponding programs. Audits are to be repeated at least every three years.
If no ingredients are hazard-flagged, then the fact that the hazard screen was completed is the only specific element required beyond basic conformance with the environmental and health & safety practices described above in parts 1-3. Procedures for building product manufacturer’s assessment of ingredient hazards must be disclosed to the auditor.
The building product manufacturer provides a certificate from a third-party verifying its Option 3-conforming program to anyone seeking to specify or purchase its product for a LEED project. The certificate must include a brief summary of the manufacturer’s continual improvement objectives specific to that product or product line.
Project teams specify and install products that have verified processes in place for assessing and improving the health impact of the product along the supply chain. The team must obtain third party-verification that the building product manufacturer has processes in place for the specific product, as defined above. The LEED project team submits that certification with its LEED application as evidence that the products or materials purchased contribute to the 25% by cost threshold for Options 2 & 3 in the credit.