Warehouses-NC-v4 MRc4: Building product disclosure and optimization - material ingredients 1-2 points

At the end of the “Requirements” section in each of the BPDO credits, change text to the following:
“Structure and enclosure materials may not constitute more than 30% of the value of compliant building products. Projects with significant amounts of structural and enclosure materials may exceed the 30% limit by calculating an alternative structure and enclosure limit (See Equation 3 under Further Explanation).”

Furthermore, add the following new section in every BPDO credit under “Further Explanation - CALCULATIONS”:
“Equation 3: Alternative Structure & Enclosure Percentage Limit for Option 2
For projects with significant amounts of structure and enclosure materials, the following calculation can be made to determine an alternative limit for the percentage of value that structure and enclosure materials can contribute to credit achievement. Note: this option is only available for projects that use the actual materials cost method (not the default cost method) to determine total project material costs.
Equation 3: Alternative Structure and Enclosure limit
Alternative Structure and Enclosure limit = (value $ of total building materials that are structural or enclosure) [divided by] (total actual materials value $)
Use the results of equation 3 to replace the 30% contribution factor limit in determining compliance with the credit.”

Change language to read as follows:
Option 1. Material Ingredient Reporting (1 point)
• Manufacturer Inventory. The manufacturer has published complete content inventory for the product following these guidelines:
o A publicly available inventory of all ingredients identified by name and Chemical Abstract Service Registration Number (CASRN) and/or European Community Number (EC Number)
o Materials defined as trade secret or intellectual property may withhold the name and/or CASRN/EC Number but must disclose role, amount and hazard screen using either:
GreenScreen benchmark, as defined in GreenScreen v1.2.
o The Globally Harmonized System of Classification and Labeling of Chemicals rev.6 (2015) (GHS)
• The hazard screen must be applied to each trade secret ingredient and the inventory lists the hazard category for each of the health hazards included in Part 3 of GHS (e.g. “GHS Category 2 Carcinogen”).
• Identify in the inventory all hazard classes for which a classification cannot be made because there are insufficient data for a particular endpoint(s).

Make the following addition:
Option 1, add to the list of approved programs, after the bullet for “Cradle to Cradle Material Health Certificate” and before “USGBC approved program”:
• Product Lens Certification
• Facts - NSF/ANSI 336: Sustainability Assessment for Commercial Furnishings Fabric at any certification level

AND/OR
Change language to read as follows:

Option 2. Material Ingredient Optimization (1 point) Use products that document their material ingredient optimization using the paths below for at least 25%, by cost, of the total value of permanently installed products in the project... • International Alternative Compliance Path – REACH Optimization. End use products and materials have fully inventoried chemical ingredients to 100 ppm and assess each substance against the Authorization list – Annex XIV, the Restriction list – Annex XVII and the SVHC candidate list, (the version in effect in June 2013 ), proving that no such substance is included in the product. If the product contains no ingredients listed on the REACH Authorization, Restriction, and Candidate list, value at 100% of cost.

Add a new section after "Supply Chain Optimization" titled, "Supply Chain Optimization - Enhanced Achievement Options"
Supply Chain Optimization - Enhanced Achievement Options
In addition to the minimum requirements described in Further Explanation – Supply Chain Optimization, building product manufacturers have the option of pursuing more advanced supply chain optimization measures, which can help their products contribute more value towards earning the LEED point, as described in Calculations. Seven enhanced achievement options are available for this LEED point, described below. Each relates only to the product for which the building product manufacturer is seeking credit under Option 3.
Additional ingredient inventory
Instead of identifying ingredients to the 99% level, the building product manufacturers identifies and includes in the screening (and, if appropriate, additional requirements) all ingredients to the 99.9% level (1,000 ppm).
Additional hazard screening
Use GHS Category 2 criteria for hazard screening for carcinogens, mutagens, reproductive toxicants, skin irritants, and Systemic Toxicity & Organ Effects Repeated Exposure sub‐endpoint (ST‐repeat) for determining which ingredients are subject to management, reporting, and optimization (the basic requirement stops at GHS Category 1 for these endpoints). See Table 2.
Supplier documentation for all ingredients
To address hazardous substances that do not persist into ingredients comprising the end product, the building product manufacturer shall require either self-declared or third-party validated environmental management and health & safety management systems for ALL ingredients up to the 99% threshold, not just those that fail the initial Hazard Screen. If the building product manufacturer is also seeking extra credit in the Supply Chain Depth factor, this would also apply to all ingredients at the additional tier or tiers.
Green chemistry optimization
The building product manufacturer takes actions to design and improve chemical ingredients within their supply chain. To demonstrate compliance, building product manufacturer must:
• Take at least one supply chain ingredient that triggered a Hazard Criteria in Table 1 and conduct a comparative assessment on that ingredient.
• Based on the comparative hazard assessment, the building product manufacturer must substitute or eliminate (e.g. product design change or process change) that ingredient.
• Where substitution occurs, manufacturer shall take action based on that alternatives assessment such that the hazard is no longer flagged at the Enhanced Achievement hazard Criteria level (table 2) in place of the original ingredient.
• After substitution or elimination, safety and stewardship information about the chemical ingredient is publicly available for all points along the supply chain.
Ingredients that are substituted must have been incorporated within 3 years of the alternative assessment date, and the ingredient being replaced must have been present in the product manufacturing processes no more than 6 years prior to the alternatives assessment and a subject of said alternatives assessment (e.g., the alternatives assessment was intended for the ingredient).
Enterprise-wide application of the EMS
The building product manufacturer has met the Option 3 minimum requirements for the entire business unit or company.
Extension of supplier engagement to Tier 2
All Tier 2 suppliers have documented environmental and health & safety management systems as described for Tier 1 suppliers. Building product manufacturer must procure third party verification or self-declaration with documentation that all first and second tier suppliers have those systems in place for the material they are supplying.
Extension of supplier engagement to source
All suppliers in the supply chain of the product have documented processes in place as described for Tier 1 suppliers. Building product manufacturer must procure third party verification or self-declaration with documentation that all suppliers have processes in place for the material they are supplying.

Add a new section, "Supply Chain Optimization" at the bottom of the page.
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
Guiding Principles
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.
Inventory
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.
Hazard Screen
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
Supplier Engagement
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.
Verification
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.
Customer Communication
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.
LEED Documentation
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.

Delete the last sentence in the first paragraph, "For Option 3 Product Manufacturer Supply Chain Optimization, check USGBC’s website for updates on how to achieve compliance."

At the end of the seciton, add the following for Option 3:
Use the following equation for Option 3 Supply Chain Optimization (see Further Explanation, Supply Chain Optimization). Products that meet the requirements of Option 3, as outlined below, contribute toward earning LEED credit at 100% of the product cost. To encourage actions beyond those minimum requirements, additional credit can be earned in a number of ways.
Equation 2 Percentage Supply Chain Optimization of compliant materials cost.
% of materials cost = {〖product cost〗_1 (criterion val.factor)(supply chain depth factor)(location val.factor)} + {〖product cost〗_2 (criterion val.factor)(supply chain depth factor)(location val.factor)} + ⋯ X100 / Cost of all permanently installed products
where:
Criteria valuation factor = multiplier assigned to number of enhanced achievement measures
100% value (by cost) where the minimum requirements are met.
150% value (by cost) where the minimum requirements plus:
Inventory and screening performed to 99.9% level
OR
Use GHS Category 2 criteria for hazard screening for carcinogens, mutagens, reproductive toxicants, and skin irritants for determining which ingredients are subject to management, reporting, and optimization (the basic requirement stops at GHS Category 1 for these endpoints). See Table 1.
OR
The building product manufacturer shall require either self-declared or third-party validated environmental management and health & safety management systems as described in the requirements in Section 4 for ALL ingredients up to the 99% threshold, not just those that fail the initial hazard screen. If the building product manufacturer is also seeking extra credit in the Supply Chain Depth factor, this would also apply to all ingredients at the additional tier or tiers.
The building product manufacturer shall document substitution or elimination of at least one ingredient that was flagged in the hazard screening process. Where substitution occurs, manufacturer shall take action based on that alternatives assessment such that the hazard is no longer flagged at the Enhanced Achievement hazard Criteria level (table 1) in place of the original ingredient.
200% value (by cost) where the minimum requirements are met plus any two of the four above options.

Supply chain depth factor = multiplier assigned to level of supply chain engagement
100% value (by cost) where the minimum requirements are met.
150% value (by cost) where the minimum requirements plus one of these two:
The building product manufacturer has met the Option 3 minimum requirements for the entire business unit or company.
OR
All tier 2 suppliers have documented processes in place as described for tier 1 suppliers. This multiplier is not available to products with only tier 1 suppliers in their supply chain.
200% value (by cost) where the minimum requirements plus:
All suppliers in the supply chain of the product have documented processes in place as described for tier 1 suppliers. This multiplier is not available to products with only tier 1 and tier 2 suppliers in their supply chain.

Revise the second bullet to read, "Option 2 Material Ingredient Optimization and Option 3 Supply Chain Optimization are for projects with 25% permanently installed products,
by cost, that meet at least one of the paths listed in the credit requirements."

Add a new bullet under the Cradle to Cradle bullet that reads:
• Declare. The Declare product label must indicate that all ingredients have been evaluated and disclosed down to 1000 ppm.

Revise the second sub-bullet under Manufacturer's Inventory, and add additional sub-bullets, so that the second sub-bullet reads:
o Materials defined as trade secret or intellectual property may withhold the name and/or CASRN but must disclose role, amount and hazard screen using either:
• GreenScreen benchmark, as defined in GreenScreen v1.2
• The Globally Harmonized System of Classification and Labeling of Chemicals rev.6 (2015) (GHS)
_____• The hazard screen must be applied to each trade secret ingredient and the inventory lists the hazard category for each of the health hazards included in Part 3 of GHS (e.g. “GHS Category 2 Carcinogen”).
_____• Identify in the inventory all hazard classes for which a classification cannot be made because there are insufficient data for a particular endpoint(s).

Revisions to the 30% cap on structure and enclosure materials.

In the fourth row of the table, change "lists of ingredients with GreenScreen benchmarks" to "lists of ingredients with GreenScreen Benchmark or LT scores"

Table 1. Manufactures' documentation for compliant products
In the column labeled "What Has to be Reported" change the row for "Manufacturer's inventory to, "All ingredients at or above 0.1%; Report hazards associated with LT-1, LT-P1 (GS List Translator) or Benchmark 1 (full GreenScreen) scores"

In the column labeled "Based on What Framework" change the row for "Manufacturer's Inventory" to "GreenScreen (GS) v1.2 or higher (either GS List Translator or full GreenScreen)"

In the column labeled "Based on What Framework" change the row "Health product declaration" delete "Health risks based on"

In the last sentence of the third paragraph, replace "also" with "not" so that the sentence reads: "Projects in the U.S. may not use this alternative compliance path."