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

Updated calculator to display all Material content on other tabs
Removed 30% cap language

Make changes to “FURTHER EXPLANATION > CALCULATIONS” as follows:
“Program valuation factor = multiplier assigned to each compliance program:

• GreenScreen benchmark. Products that have fully inventoried chemical ingredients to 100 ppm:
o All ingredients assessed using GreenScreen List Translator and have no Benchmark-1 hazards, 100% value (by cost)
o All ingredients have undergone a full GreenScreen assessment and have no Benchmark-1 scores, 150% value (by cost)
• Cradle to Cradle Certified version 2.1.1:
o Gold, 100% value (by cost)
o Platinum, 150% value (by cost)
• Cradle to Cradle Certified version 3.0:
o Silver, 100% value (by cost)
o Gold or Platinum, 150% value (by cost)
• REACH Optimization. This is an alternative compliance path for projects outside the U.S. If the product contains no ingredients listed on the REACH authorization or candidate list, value it at 100% of cost.”
…
Make changes to “FURTHER EXPLANATION > MATERIAL INGREDIENT REPORTING (TABLE 1)” as follows: Modify Table 1:

First row under "Based on what framework" column, modify to read as follow: " GreenScreen (GS) (either GS Translator List or full GreenScreen assessment)"

Manufacturer’s Inventory
Manufacturers may publicly disclose all ingredients by name and Chemical Abstract Service (CAS) registry number. No third-party verification is required for this option, but the information must be publicly available; direct disclosure to the designer or contractor is not acceptable.
If a specific ingredient cannot be disclosed for proprietary reasons, the manufacturer may withhold the name and CAS registry number but still provide the following information:
• Role or function in the product
• Amount, as a percentage of total product content or ppm
• GreenScreen LT score (GS List Translator) or GS Benchmark score (full GS). Report hazard levels and hazard endpoints that result in scoring the ingredient as LT-1 or LT-P1 using GS List Translator (e.g. High for Carcinogenicity) or hazard levels and hazard endpoints that result in scoring the ingredient as Benchmark 1 using full GreenScreen. It is not necessary to report hazards associated with higher Benchmark levels or LT-UNK (Unknown) using GS List Translator.
All ingredients that constitute 0.1% (1,000 ppm) or more of the product must be accounted for. This threshold is 10 times lower than the typical 1% minimum threshold for reporting on a material safety data sheet (MSDS).

Health Product Declaration Open Standard
Disclosure is done through Health Product Declaration (HPD), which is an open standard for reporting product ingredients and their associated health hazards. Manufacturers that use HPDs must provide the nonproprietary information listed above (role or function, amount, and health hazards) for every ingredient, not just those whose names have been withheld. The manufacturer affirms “full disclosure of known hazards” on the front summary page and further affirms the level of disclosure with residuals/impurities. For the material to comply with the credit requirements, the HPD standards for the 1,000-ppm level must be attained and the appropriate box on the summary page checked.

An HPD is several pages long, with a one-page summary listing company information, metadata about the report, and ingredients, and continuing on subsequent pages with more detail about individual ingredients and their associated health hazards, plus details on any certifications and associated materials. GreenScreen List Translator scores and/or Benchmarks, if any, are listed for each ingredient in HPDs, in the contents section. A report from a certified GreenScreen profiler may also be used to document the GreenScreen benchmarks for a product’s ingredients.
Manufacturers that use the standard HPD format reduce uncertainty about whether the information that they have provided meets the credit requirements, and they create a report that should be useful in other settings as well.

Qualifying HPDs developed under the Open Standard version 1.0, 2.0, 2.1 or subsequent versions of the standard are eligible for documenting credit achievement if the HPD is still valid at the time that the product is purchased and used on a project.

Make changes to “FURTHER EXPLANATION > MATERIAL INGREDIENT OPTIMIZATION” as follows:

GreenScreen Benchmark 1
The GreenScreen hazard assessment method evaluates individual chemicals. GreenScreen is based on a toxicological assessment that starts with a collection of authoritative lists of “chemicals of concern” published by governmental and nongovernmental organizations (GreenScreen List Translator). These substances are known to be associated with certain health problems. The assessment then proceeds to reviews of the scientific literature, use of structure activity relationship models and chemical analog data to fill data gaps (Full GreenScreen). Chemicals are assigned to one of four main categories: those of highest concern, as indicated in the authoritative lists, are assigned Benchmark 1. Chemicals that are not on the major authoritative lists and pass a toxicological review based on Clean Production Action’s protocols can be assigned benchmarks that indicate lower levels of concern; Benchmark 4 is the lowest level of concern. A full GreenScreen assessment overrides the results of screening using the GreenScreen List Translator only.

The GreenScreen List Translator has been automated by two software providers. It can be accessed through the Chemical and Material Library found in Healthy Building Network’s Pharos Tool, the ToxNot website, and in the GS List Translator module in the GreenWERCS software tool by The Wercs. The Interstate Chemicals Clearinghouse has created a website where GreenScreen assessments can be posted by various participating State governments and shared with no costs or restrictions. The GreenScreen Store is another source for some freely available full assessments: www.greenscreenchemicals.org/gs-assessments

Option 1 of this credit requires only the GreenScreen List Translator review of ingredients to ensure that none of the ingredients are on the authoritative lists and thus flagged as Benchmark 1 substances. Project teams should look for documentation from manufacturers that either identifies all ingredients in the product or identifies and characterizes any benchmark hazards.

Option 2 requires the Full GreenScreen toxicological assessment to ensure that none of the ingredients are Benchmark 1. Project teams should look for documentation from manufacturers that shows each ingredient in the product has been subject to a full GreenScreen assessment by a licensed GreenScreen Profiler and that the product contains only Benchmark 2 and higher ingredients.

Products using GreenScreen version 1.2, 1.3, or subsequent versions are eligible for documenting credit achievement if the analysis/scores are valid at the time that the product is purchased and used on a project.


For Manufacturers and Suppliers
GreenScreen’s List Translator assigns hazard classifications based on the various governmental and authoritative hazard lists including lists of chemicals classified using the Globally Harmonized System of Classification and Labeling. The GreenScreen List Translator can be used to identify chemicals that achieve or may achieve the Benchmark 1 level of concern. Under Option 1, manufacturers that keep certain ingredients proprietary must characterize any health hazards from those ingredients, as indicated by the List Translator or a full GreenScreen assessment.
Under Option 2, the manufacturer must warrant that no ingredients in the product at levels of 0.01% or more (100 ppm) are designated as Benchmark 1 chemicals based on the referenced lists defined by the List Translator. These products achieve compliance at the first level of the option.

The second level of compliance requires that all ingredients be Benchmark 2 or higher. There is no definitive List Translator for Benchmark 2, so manufacturers must engage an independent third party to screen all their ingredients, using the screening protocol defined by GreenScreen, and certify that none of them are Benchmark 1.

Products using GreenScreen version 1.2, 1.3, or subsequent versions are eligible for documenting credit achievement if the analysis/scores are valid at the time that the product is purchased and used on a project.

Make changes to “FURTHER EXPLANATION > EXAMPLES” as follows:
…
Example GreenScreen List Translator Result
The GreenScreen List Translator identifies each list that GreenScreen references, including its source, which hazards in the GreenScreen it covers, whether it is “authoritative” or “screening,” and which GreenScreen hazard level and subsequent Benchmark score applies, along with other data.

Table 2. GreenScreen List Translator Result (version 1.2 shown). Used with permission from Clean Production Action.

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 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."

Added the following programs to Material Ingredients tab:
Manf Inv – GHS
Manf Inv – GS
Declare
ANSI/BIFMA e3 Furniture Sustainability Standard
C2C MHC

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).

Change the first sub-bullet under GreenScreen version 1.2 benchmark to read "All ingredients screened using GreenScreen List Translator and no ingredients with Benchmark 1 hazards, 100% value (by cost)"
Change the second sub-bullet under GreenScreen version 1.2 benchmark to read "All ingredients fully assessed by full GreenScreen method and no ingredients with Benchmark 1 hazards, 150% value (by cost)"

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."