CEN TC 350 - SUSTAINABILITY OF CONSTRUCTION WORKS

Environmental measures are high on the political agenda and up to now SMEs have been less involved as many exemptions existed. Considering the exhaustion of consumable energy resources and the waste issues, it seems obvious that industrialised societies will need to find solutions to save energy and to recycle products. Construction appears as a sector where many environmental improvements can be made. In addition, it will concern essentially SMEs due to the structure of the sector.

This committee will draft a series of standards and technical documents supporting the mandate M 350 on the integrated environmental performance of buildings. NORMAPME identified the interests of many of its members that could be affected while drafting this set of standards.

This TC is composed of 5 Working Groups:

- CEN/TC 350 WG 1 Environmental performances of buildings,

- CEN/TC 350 WG 2 Building Life Cycle Descriptions

- CEN/TC 350 WG 3 Products Level,

- CEN/TC 350 WG 4 Economic performance assessment of buildings

- CEN/TC 350 WG 5 Social performance assessment of building.

The most relevant activities for SMEs take place in the framework of CEN/TC 350 WG 3. It is related to the Environmental Product Declaration (EPD).

A list of published standards and standards under development can be found at http://www.cen.eu/Sectors/TechnicalCommitteesWorkshops/CENTechnicalCommittees/Pages/default.aspx.

The NORMAPME expert following the CEN/TC 350 work is Mr. Frank Koos. For more information please contact him at koos@window.de.

Mr. Koos is monitoring WG 1, 3, 4 and 5 and one task group (TG Framework) which deals with the General Framework and Environmental Performance assessment of buildings.

In February 2010, Mr. Koos issued a position regarding the validity of EPD and the +-I0 percent rule for review vs. cut-off rules at building level assessment. This position was circulated for comment to the TC 350 Working Group members ahead of the CEN/TC350/WG3 meeting on february 22/23, 2010. The concerns raised on clause 6.2 “Validity of EPD” of prEN15804 are:

- Data is provided in form of EPDs to be used at building level assessment. Construction Products are used in their intended use, as part of that building. TC 350 agreed that EPDs should not be used for product level comparisons, only for building level comparisons.

- Considering this, how can +-10 percent for EPD review be justified? There should be evidence that a certain product has a significant effect on the impact at building level. Otherwise we make wrong decisions at product level especially when the product's technical characteristic is playing the main role at building level during the life time, as is the performance of e.g. insulation material. The environmental impact of that product's product stage has no meaning.

- How can a manufacturer monitor this +-10 percent rule? Who is responsible for the reaction to the rule? This is an extra burden for SMEs, who do not have the capacity, be it through resources or know how to comply with the rule.

- Only a comparison at building level could reveal this need for this review, again remembering the aim to use EPD data only at building level.

- In practise many, very many construction products can claim in the future that their impact (product stage), considering the life cycle approach, is meaningless. We find this issue tricky but it must be discussed.

- The last concern is that of the real uncertainties and variations in LCA calculations. Consultants are not willing to discuss it but that will take place sooner or later. Manufacturers are tight with strict rules but there is no responsibility of consultants.

CEN/TC350/WG3 empathized on the issue and concluded that it is therefore informative, not mandatory and shall give only some guidance to the user of the standard. It was decided not to remove the note. But the text of chapter 9 was changed in accordance with ISO standards into: “An EPD is valid for a 5 year period from the date of issue, after which it shall be reviewed and verified. The process for verification and establishing the validity of an EPD shall follow ISO 14025 and ISO 21930.”
In particular, the reference to a “5 year period validity” gives to the note a different sense and moves the demand for informing the verifier from the manufacturer to the owner of the EPD (e.g. Association) in the case of re-viewing the EPD.