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Requirements/Process to determine Eligibility of a Type III Environmental Declaration Program

PUBLIC PROCEDURE PRO-PR-165-ISO 14025 Issued: 2016-4-5, Revision: 3

References PRO-FR-104-ECO-ISO 14025: Application for Eligibility of Type III Environmental Declaration Programs
PRO-NT-114: Implementation of the Transition from ISO/IEC Guide 65 to ISO/IEC 17065
PRO-TP-106: ISO 14025 Eligibility Report Document Review
PRO-TP-109: ISO 14025 Remote Evaluation Plan
PRO-TP-110: ISO 14025 Eligibility Report
FTC 16 CFR Part 260 – Green Guides for the Use of Environmental Marketing Claims
ISO 14020:2000, Environmental labels and declarations- General principles
ISO 14025:2006, Environmental labels and declarations – Type III environmental declarations Principles and procedures
ISO 14040:2006, Environmental management - Life cycle assessment - Principles and framework
ISO 14044: 2006, Environmental management - Life cycle assessment - Requirements and guidelines
ISO 21930:2007, Sustainability in Building Construction—Environmental Declaration of Building Products
ISO/IEC 17000:2004, Conformity assessment - Vocabulary and general principles
ISO/IEC 17065:2012, Conformity assessment – Requirements for bodies certifying products, processes and services
ISO/IEC Guide 2: 2004 (E/F/R)
PRO-NT-118 - Guidelines for the use of Product Category Rules (PCRs) by Eligible Program Operators developed by Non-Eligible Program Operators
Contents
1Objective
This procedure defines the requirements/process to determine eligibility of environmental declaration programs in accordance with the ISO 14020 and ISO 14025, and, if applicable, ISO 21930. ISO 21930 will also be used to determine eligibility of the environmental declaration program if the program operator issues a Product Category Rules (PCR) and/or a Type III Environmental Declaration (otherwise known as an Environmental Product Declaration (EPD)) in the building product sector, as defined in ISO 21930 clause 3.2, or has expressed the intention to ANSI to issue EPDs and PCRs in the building product sector in the future.
Note 1: After the environmental declaration program is deemed eligible, it will be considered for use under the ANSI accreditation process to accredit certification bodies to certify Type III Environmental Declaration Program.
Note 2: In this procedure the term “Product’ can be read as “Process” or “Service”.
Note 3: ISO 21930 is an international standard for Environmental Product Declaration (EPD) of Building Products
2Definitions
2.1Environmental Label, Environmental Declaration
Note 1: An environmental label or declaration may take the form of a statement, symbol or graphic on a product or package label, in product literature, in technical bulletins, in advertising or in publicity, among other things.
2.2Type III environmental declaration
Environmental declaration providing quantified environmental data using predetermined parameters and, where relevant, additional environmental information (ISO 14025, clause 3.2).
2.3Type III Environmental Declaration Program
Voluntary program for the development and use of Type III environmental declarations based on a set of operating rules. (ISO 14025, clause 3.3).
Note 1: The predetermined parameters are based on the ISO 14040 series of standards, which is made up of ISO 14040 and ISO 14044.
Note 2: The additional environmental information may be quantitative or qualitative.
2.4Program Operator
Body or bodies that conduct a Type III environmental declaration programme (ISO 14025, clause 3.4).
Note: A program operator can be a company or a group of companies, industrial sector or trade association, public authorities or agencies, or an independent scientific body or other organization.
2.5Product Category Rules (PCR)
Set of specific rules, requirements and guidelines for developing Type III environmental declarations for one or more product categories (ISO 14025, clause 3.5).
2.6Environmental Product Declaration (EPD) (ISO 21930, clause 3.16)
Environmental declaration. (ISO 14025, clause 3.1).
Environmental declaration providing quantified environmental data using predetermined parameters and, where relevant, additional environmental information.
Note 1: The predetermined parameters are based on the ISO 14040 series of standards, which is made up of ISO 14040 and ISO 14044.
Note 2: The additional environmental information may be quantitative or qualitative.
Environmental declaration (ISO 14025, clause 3.1) providing quantified environmental data using predetermined parameters and, where relevant, additional environmental information.
2.7Certification System
Rules, procedures, and management for carrying out certification. (ISO/IEC 17000, clause 2.7)
2.8Certification Body
Third-party assessment body operating certification schemes (ISO/IEC 17065, clause 3.12)
Note: A certification body can be non-governmental or governmental (with or without regulatory authority).
2.9Certification Scheme
Certification system related to specified products, to which the same specified requirements, specific rules and procedures apply (ISO/IEC 17065, clause 3.9)
Note 1: For the ANSI Program to Determine Eligibility of a Type III Environmental Declaration Program, the certification scheme is the General Program Instruction(s) and the Product Category Rules.
2.10Normative Documents
Document that provides rules, guidelines or characteristics for activities or their results (ISO/IEC Guide 2: 2004, clause 3.1)
Note 1: The term ?normative document? is a generic term that covers such documents as standards, technical specifications, codes of practice and regulations.
Note 2: A ?document? is to be understood as any medium with information recorded on or in it.
Note 3: The terms for different kinds of normative documents are defined considering the document and its content as a single entity
Note 4: It is possible to have an EPD for a material, a building product, a component, an assembly and/or a building element. The EPD of a component, assembly or building element can incorporate the results of the EPD of all the assembled materials and building products. This is described in ISO 14025:2006, 5.4.
2.11Building product
Goods or services used during the life cycle of a building or other construction works (ISO 21930, clause 3.2).
Note 1: In this International Standard, the term ?product? used alone relates not only to goods or product systems but can also include service systems. In either case, the declaration is presented in a manner that clearly indicates whether the declaration applies to goods, or to only a part of the goods or packaging, or to an element of service. This is discussed in ISO 14025:2006, 7.2.2.
Note 2: The manufacturing or processing of goods used as building products can take place at the factory or on the construction site.
Note 3: The use of services can occur at any stage of the life cycle of the building or other construction works.
2.12Eligibility
3Scope of ANSI Program to Determine Eligibility Type III Environmental Declaration Program
Program Operators for Environmental Labels and Declarations and to (2) Assess Competence of Certification Bodies that Verify/Validate Environmental Product Declarations (EPD) for Accreditation. These two steps have been divided into two programs at ANSI. In the first step, program operators apply to ANSI to determine if their Type III Environmental Declaration program conforms to the requirements outlined in Chapter 4 of this document. The ANSI Program to Determine Eligibility of Type III Environmental Declaration Programs covers all requirements of a program operator except those related to verification of EPDs and verification of the data developed for the EPD. The second step of the process, certification bodies that verify and validate EPDs are assessed for conformance to ISO 14025 and ISO 17065. This procedure, PRO-PR-165, describes the ANSI requirements and procedures for the first step, Determining Eligibility of Program Operators for Environmental Labels and Declarations. For the requirements and procedures for the second step, Assessment of Competence of Certification Bodies that Verify/Validate Environmental Product Declarations (EPDs), see PRO-PR-102
4Objectives of Type III Environmental Labels and Declaration
The overall goal of environmental labels and declarations is to encourage the demand for, and supply of, those products that cause less stress on the environment, through communication of verifiable and accurate information that is not misleading, thereby stimulating the potential for market-driven continuous environmental improvement. (ISO 14025, clause 4).
The objectives of Type III environmental declaration program are as follows:
a)to provide LCA-based information and additional information on the environmental aspects of products;
b)to assist purchasers and users to make informed comparisons between products; these declarations are not comparative assertions;
c)to encourage improvement of environmental performance;
d)to provide information for assessing the environmental impacts of products over their life cycle.
5Requirements to determine the Eligibility of a Type III Environmental Declaration Program
5.1Requirements
5.1.1Competence of the program operator
Program operators shall demonstrate personnel competence (knowledge of program requirements) involved in the development and administration of a type III Environmental declaration program, and provide objective evidence thereof.
This competence is described in sections related to personnel in the following standard:
a)ISO 14025
5.1.2Requirements to evaluate the program operator?s methodology to develop and operate a Type III environmental label and declaration program
5.1.2.1The following standards and/or normative documents shall be used by ANSI to evaluate the eligibility of a Type III environmental labels and declarations program regarding the method used to develop and operate the program.
a)ISO 14020
b)all of ISO 14025 except clauses 8.1.1, 8.1.3, 8.1.4, 8.2.1, 8.2.2, and 9.4 that relate to verification of EPDs and verification of the data developed for EPDs
c)all of ISO 21930 except clause 9.1 that relates to verification of EPDs
Note 1: This clause is used by ANSI if the program operator issues a PCR and/or an EPD in the building product sector (see ISO 21930 clause 3.2) or has expressed the intention to ANSI to issue EPDs and PCRs in the building product sector in the future
d)ISO 14040 & ISO 14044, on the development of LCA-based information in EPDs and PCRs published by the program operator
e)FTC 16 CFR Part 260 ? Green Guides for the Use of Environmental Marketing Claims
f)The following clauses of ISO/IEC 17065 will be evaluated by ANSI:
1)clause 7.1.2
2)clause 7.1.3
3)clause 7.13
4)clause 8.3
5)clause 8.4
6)clause 8.5
7)clause 8.6
8)clause 8.7
9)clause 8.8
5.1.2.2The program operator shall inform ANSI on the uses other regional or national standards. These will be included as part of the Eligibility evaluation. Such national and regional standards can not contradict the principles of ISO 14020, and the processes and procedures of ISO 14025.
5.1.3Documentation required to evaluate the program operator?s methodology to develop and operate a Type III environmental label and declaration program.
Type III environmental declaration program is voluntary and have a set of rules guiding their overall administration and operation. These rules, managed by a program operator, are referred to as general program instructions. (ISO 14025, clause 6).
5.1.3.1The program operator shall submit the following documents and information to ANSI when completing the application for participation in the Eligibility program (FR-104-ECO-14025)
a)a copy of the general program instructions, including information on how the instructions can be accessed by the public (ISO 14025 6.2).
b)Published list of names of interested parties actually involved in the development of the general program instructions (ISO 14025 6.3b), including representatives of both consumer interests and environmental interests (ISO 14025 9.3) if the program operator has published business-to-consumer EPDs or PCRs, or expresses to ANSI the desire to do so in the future.
c)Documented evidence of methods and/ or procedures used to:
i. Ensure that the Type III environmental declaration requirements (see ISO 14025 Clause 7) are followed (ISO 14025 6.3c) ii. Safeguard the consistency of data within the programme (ISO 14025 6.3 d) iii. Monitoring changes in procedures and documents of related Type III environmental declaration programmes and revising procedures and documentation when necessary (ISO 14025 6.3g) iv. Ensuring the selection of competent independent verifiers and PCR review panel members (ISO 14025 6.3h) v. Establish a transparent procedure for PCR review (ISO 14025 6.3i) vi. Establish procedures to avoid misuse of references to the international standards, type III environmental declaration programme, its Type III environmental declarations, and where relevant, its logo. vii. Define product categories (ISO 14025 6.4 f) viii. Manage data confidentiality (ISO 14025 6.4 h) ix. Develop and maintain PCRs (ISO 14025 6.4 i) x. Ensure competent independent verification (ISO 14025 6.4 j)
d)A list of PCRs developed or adapted under the program
e)Instructions for accessing all PCR documents developed under the program
f)One example of a PCR developed and published under the program, including the corresponding documents demonstrating an open consultation process including responses to comments received, and the report from the third-party review panel for the example PCR.
g)If a PCR was adopted into the program, the program operator shall provide an example adopted PCR and documentation of the following information required in ANSI notice PRO-NT-118:
1)Confirm that the principles in ISO 14020 and the requirements in ISO 14025 (Clause 6.7) is performed during the process of development of such PCRs by the other program operator that developed the PCR
2)Confirm that the General Program Instruction (GPI) covers the category of product of the issued PCR
3)Have evidence from the other program operator that the process used to develop the PCR and GPI complies with ISO 14020 and ISO 14025
4)Have evidence that the program operator uses its own General Program Instruction (GPI) when publishing EPDs from the adopted PCR.
h)If the program operator uses a PCR from another program operator but does not adapt nor adopt the PCR, the program operator shall provide an example of such a PCR and documentation of the following information required in ANSI notice PRO-NT-118:
1)Evidence that the program operator uses the General Program Instruction (GPI) of the program operator that developed the PCR when publishing EPDs produced from that PCR.
2)Documentation of the elements used to confirm that the PCR follows ISO 14025 and ISO 14020.
i)List of EPD already verified and published under the program
j)Instructions for accessing all EPDs developed under the program, including verification documents
k)Example business-to-business (cradle-to-gate) EPD and example business-to-consumer (cradle-to-grave) EPD if one has been published under the program
l)Program Operator procedures on control of documents and records, internal audits, addressing corrective actions, and taking preventative actions
6Process to determine the eligibility of a Type III Environmental Declaration Program
6.1The program operator shall submit the following information:
6.1.1Application
6.1.1.1The application form (PRO-FR-104?ECO-ISO 14025, part XX) for eligibility of a type III environmental declaration program shall be signed by an authorized representative and shall be submitted along with a cover letter and a non-refundable application fee to ANSI.
6.1.1.2Upon receipt of a new application, ANSI staff shall inform the ANSI Accreditation Committee Chair and the ACC Eco-labeling Subcommittee members of this event and request volunteers. Two volunteers from the Eco-labeling Subcommittee will follow the processing of the application by ANSI staff /evaluation team and assist ANSI as necessary, in processing and acting on the application.
6.1.1.3ANSI staff shall evaluate the application for completeness, using ANSI requirements as defined in this procedure (e.g. ISO 14025 and ISO 21930). Additional information and/or clarification may be requested from the applicant.
6.1.1.4The acceptance of the application for eligibility of a type III environmental declaration program is announced in ANSI Standards Action. A 30-day comment period is established for comment on the application. The announcement also contains instructions for submitting comments to ANSI.
6.1.1.5ANSI shall acknowledge receipt of all comments received and provide the applicant with a copy. Where appropriate, ANSI or the applicant will respond to comments by interested parties
6.1.1.6The name of the applicant program operator is added to ANSI’s published list of program operator applicants for the “Eligibility of a Type III Environmental Declaration Program” on the ANSI website.
6.1.1.7If, after the initial application evaluation, it is judged that the applicant has not met the eligibility criteria, ANSI will:
a)notify the applicant and identify the deficiency (ies) in the application; remove the notification from the Standards Action;
b)advise the applicant that if the deficiency (ies) is/are corrected, and a revised application is submitted to ANSI within 90 days, ANSI’s review of the documentation shall resume and payment of an additional fee may be required; Re-post the notice in the Standards Action;
c)advise the applicant that if the deficiency(ies) is not corrected and/or a revised application is not submitted to ANSI within 90 days, the application shall be considered to be withdrawn. A new application may be submitted at any time; and
d)notify the ANSI Accreditation Committee of the final action by ANSI.
6.1.2Review, evaluation for eligibility of a Type III Environmental Declaration Program
6.1.2.1After approval of the application, ANSI staff will review the supporting documents provided by the program operator. An evaluation team led by a member of ANSI staff or a contracted individual shall conduct the review. The evaluation team shall be selected on the basis of competence and absence of potential conflict of interest.
6.1.2.2The applicant will be notified of the names of the proposed members of the evaluation team including any technical expert(s), if needed, and the organization to which they belong. The applicant has 10 days to provide any written objections to any team member(s) and/or expert(s). If the applicant raises objections to any proposed team members, ANSI will provide the names of alternative evaluator.
6.1.2.3The evaluation team, including technical assessor(s), shall have no ties with the applicant that may influence the eligibility process. Team members are required to maintain the confidentiality of all information obtained about the applicant and its operations. The evaluation team shall have appropriate knowledge of the specific program operator for which eligibility is sought.
6.1.2.4The eligibility of a type III environmental declaration program takes the form of an evaluation and therefore involves a document review, with the option of visiting the program operator headquarters. This visit is useful for a discussion of the results and potential finds. The results of the document review are documented (PRO-TP-106: ISO 14025 Eligibility Report Document Review) and submitted to the Program Operator.
6.1.2.5ANSI shall clearly define the assignment given to the evaluation team. The evaluation team shall submit an evaluation plan (PRO-TP-109: ISO 14025 Remote Evaluation Plan) to the Program Operator detailing the evaluation activities to be covered during the remote eligibility review. During the remote evaluation, the evaluation team shall conduct a review and evaluate the program operator submission and determine whether a type III environmental declaration program will be eligible. ANSI shall ensure that the evaluation team is provided with the appropriate criteria, relevant documents, and records provided by the program operator.
6.1.2.6ANSI shall communicate with the program operator to provide feedback and provide opportunity to the program operator to revise documents of a type III environmental declaration program so that they are in accordance with ANSI eligibility requirements.
6.1.2.7The ANSI evaluation team shall analyze all relevant information and evidence gathered during the document and records review. This analysis shall be sufficient to allow the ANSI evaluation team to determine the extent of fulfillment of eligibility requirements defined in this procedure. If necessary or appropriate, formal nonconformity reports (NCRs) will be issued for identified deficiencies that require corrective action by the applicant. All corrective action plans shall be submitted within 30 days after the posting of the nonconformity on the ANSICA platform.
6.1.2.8An eligibility evaluation report (PRO-TP-110: ISO 14025 Eligibility Report) covering all evaluation activities is prepared by the evaluation team and submitted to ANSI. The report includes evaluation details, NCRs issued and concerns identified.
6.1.2.9The program operator shall be invited to comment on the eligibility evaluation report. ANSI staff and the evaluation team shall consider any comments submitted and finalize the report, as appropriate.
6.1.2.10The information provided to the Eco-labeling Subcommittee and made available to ANSI Accreditation Committee members shall include the following, as a minimum:
a)unique identification of the environmental declaration program;
b)date(s) of the review;
c)name(s) of the evaluation team involved in the evaluation;
d)proposed environmental declaration program scope;
e)eligibility evaluation report;
f)statement on the adequacy of the internal organization and procedures adopted by the environmental declaration program to give confidence in its competence, as determined through its fulfillment of the requirements for eligibility;
g)information on the resolution of all nonconformities.
6.1.3Decision on eligibility
6.1.3.1The Eco-labeling Subcommittee reviews the eligibility evaluation report (see 6.1.2.10 e) and determines if the evaluation is complete and a type III environmental declaration program complies with the procedural requirements contained in this document and any other applicable sector specific requirements if applicable. If the subcommittee desires that the eligibility evaluation report be clarified and/or additional evaluation task be performed, ANSI staff shall respond accordingly and submit a revised report to the Subcommittee. A copy of the revised report will be sent to the applicant program operator for technical review and comment. If, based on the revised report, the Subcommittee determines any requirement has not been fulfilled, ANSI staff shall offer the applicant in writing to either terminate the application process or to send a recommendation to deny eligibility.
6.1.3.2ANSI staff will prepare a recommendation based on the Subcommittee conclusion for the eligibility decision by the ANSI Accreditation Committee. The recommendation is presented to the ANSI Accreditation Committee for a vote on the eligibility of the type III environmental declaration program in accordance with Committee Operating Procedures (PRO-PL-103). This vote may be conducted by electronic ballot.
6.1.3.3If the Committee votes to deny the eligibility of a type III environmental declaration program, the basis for denial shall be documented.
6.1.3.4Following the approval of eligibility of the type III environmental declaration program by the ANSI Accreditation Committee, ANSI staff will notify the applicant in writing of the approval. This notification will include information related to a type III environmental declaration program that was eligible.
6.1.3.5If the ANSI Accreditation Committee does not vote to approve the eligibility of a type III environmental declaration program, ANSI staff shall promptly notify the applicant in writing and include the basis for the Committee's decision along with information on any additional steps to be taken by the applicant, which may be deemed appropriate. The applicant may also appeal the decision in accordance with ANSI Accreditation Services appeals procedures.
6.1.3.6The applicant, after correcting all outstanding deficiency (ies)/concern(s), may reapply to ANSI for eligibility at any time. Resubmission may necessitate payment of an additional fee.
6.2Continuing Eligibility
6.2.1Continuing eligibility activities shall be conducted at least once in three years.
The purpose of these activities shall be to:
a)Determine that the environmental declaration program continues to be in compliance with ANSI requirements and the requirements of ISO 14020 and ISO 14025; and
b)Determine if the environmental declaration program continues to operate, as described in the documentation governing the program.
6.2.2The continuing eligibility process shall be conducted in accordance with the clauses 5 and 6 of this procedure.

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