It’s Time to Take Action: Building the Case for Industry-Wide EPDs

By Margaret Webb

The California Buy Clean Act, specifically AB 262, will require certain building materials to re-port Global Warming Potential (GWP) such as structural steel, rebar, mineral wool and flat glass for most state and construction infrastructure projects as defined by the bill:

(1) A state agency for a contract for a public works project that is subject to the State Contract Act (Chapter 1 (commencing with Section 10100) of Part 2 of Division 2).

(2) The Regents of the University of California for a contract for a public works project that is subject to Chapter 2.1 (commencing with Section 10500) of Part 2 of Division 2.

(3) The Trustees of the California State University for a contract for a public works project that is subject to the California State University Contract Law (Chapter 2.5 (commencing with Section 10700) of Part 2 of Division 2).

This legislation was put into law October 2017 for enactment January 2019 and implementation after July 2019, without any input from our industry. California usually reaches out to industries affected by proposed legislation, but that wasn’t done in this instance.

Clause 3502 of the legislation states:

(a) By January 1, 2019, the department shall establish, and publish in the State Contracting Manual, a maximum accept-able global warming potential for each category of eligible materials in accordance with both of the following requirements: (1) The department shall set the maximum acceptable global warming potential at the industry average of facility-specific global warming potential emissions for that material. The department shall determine the industry average by consulting nationally or internationally recognized databases of environmental product declarations. (2) The department shall express the maximum acceptable global warming potential as a number that states the maximum acceptable facility-specific global warming potential for each category of eligible materials. The global warming potential shall be provided in a manner that is consistent with criteria in an Environmental Product Declaration (EPD).


Typically, construction materials have been chosen from selecting the lowest bidder, which has made glass from China attractive. However, due to the use of naturally mined soda in the U.S., our impacts are lower [than] typical European carbon footprints. If China uses soda produced from the Solvay process rather than naturally mined, it’s likely that their carbon footprint would also be higher. The other question is, if inbound transport of the product to the jobsite is included, this favors glass produced in North America.

If China has a higher GWP than North American flat glass companies, or is unable or unwilling to provide GWP information on their facilities, this could encourage selection of locally sourced glass.

What does this mean for our industry? AB 262 requires contractors to gather GWP impacts from their suppliers during the bid process, and then disclose this data in their project bids. The GWP impact result is compiled using existing methods and standards to produce an ISO 14025 EPD. While all the other industries impacted by AB 262 have an industry-wide EPD, there is not one for the glass industry, and time is running out.


Only one flat glass manufacturer in North America has developed an EPD. In the absence of other available data, it might become the basis for other flat glass company EPDs. Under LEED v4, only those companies that have participated in the industry-wide EPD development can use it for credit or comparison; that’s not the case for California. Flat glass companies may find themselves subject to industry-average data based on only one existing EPD, or an unverified calculation made by California Department of General Services personnel.

Fortunately, the flat glass industry does have a platform under the Glass Association of North America to work together to develop the industry-wide EPD. It’s scary that this data could be developed without any industry input; more advanced knowledge of this legislation would have allowed the industry more time to provide input and develop the required information.

The industry has until August 2018 to provide an industry-wide EPD, or, at minimum, an industry average GWP. All that’s required at this point is the will to do so. There is still time, but the industry must rally behind it. Work would have to commence no later than April 1 of this year. Further information is available here:

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