The Buy Clean California Act (BCCA), (Public Contract Code Sections 3500-3505), states the Department of General Services (DGS) is required to establish and publish the maximum acceptable Global Warming Potential (GWP). The BCCA targets carbon emissions associated with the production of structural steel (hot-rolled sections, hollow structural sections, and plate), concrete reinforcing steel, flat glass, and mineral wool board insulation. These materials must have a GWP that does not exceed the limit set by DGS.

 

Find key legislation dates below.  

On July 1, 2021: Awarding authorities will gauge GWP compliance of eligible materials with the required Environmental Product Declaration (EPD). 

News

On January 1, 2021: DGS established the BCCA Maximum Acceptable GWP Limits.

Eligible Material

Subcategory

Limit

Declared Unit

Functional Unit

Structural Steel

Hot-rolled sections

1.44 metric tons 
CO2-eq

1 metric ton

N/A

Hollow structural sections

2.83 metric tons 
CO2-eq

1 metric ton

N/A

Plate

2.12 metric tons 
CO2-eq

1 metric ton

N/A

Concrete Reinforcing Steel

N/A

1.06 metric tons 
CO2-eq

 

1 metric ton

N/A

Flat Glass

 

N/A

1.72E+03 kg 
CO2-eq

1 metric ton

N/A

Mineral Wool Board Insulation

 

Light-density mineral wool board insulation

4.00 kg 
CO2-eq

N/A

1 m2 of insulation material with a thickness giving average thermal resistance of

RSI = 1 m2K/W and with a building service life of 75 years.

Heavy-density mineral wool board insulation

9.79 kg 
CO2-eq

N/A

1 m2 of insulation material with a thickness giving average thermal resistance of

RSI = 1 m2K/W and with a building service life of 75 years.

Unit

Abbreviation

carbon dioxide equivalent

CO2-eq  

kelvin

K

kilogram

kg

square meter

m2

thermal resistance

RSI

watt

W

Additional information on the GWP limits can be found in the References and Resources section below.

May 15, 2020

DGS participated in a Buy Clean California Act training for the California State University system.

 

July 9, 2020

DGS held an awarding agency workshop.

 

November 6, 2019

DGS participated in a teleconference with the North American Insulation Manufacturers Association.

 

November 6, 2019

DGS participated in a teleconference with Sierra Club.

 

October 31, 2019

DGS conducted a second External Stakeholder Meeting.

 

October 23, 2019

DGS participated in a teleconference with UL Environment.

 

October 16, 2019

DGS participated in a teleconference with SCS Global.

 

October 9, 2019

DGS participated in a teleconference with Oregon Department of Environmental Quality.

 

September 27, 2019

DGS participated in a teleconference with UL Environment.

 

DGS expects to continue engaging with internal and external stakeholders as we implement BCCA.

1.0 Environmental Product Declarations:

1.1 What is an Environmental Product Declaration, or EPD?

An Environmental Product Declaration (EPD) is an independently verified and registered document that reports a product’s environmental impact over its life cycle.

1.2 How do I obtain an EPD?

Contact a program operator to begin the EPD development process. A manufacturer will need to conduct a product life cycle assessment and utilize a program operator to verify and publish an EPD.

1.3 Where can I find a program operator?

Find program operators at the Program Operator Consortium and in the references and resources section below.

1.4 What environmental impact category does the Buy Clean California Act use as a metric?

The BCCA uses Global Warming Potential (GWP), which is reported as carbon dioxide equivalent (CO2-eq).

1.5 What is Global Warming Potential, or GWP?

Greenhouse gases (GHGs) are those that trap heat in the earth’s atmosphere. Carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), and perfluorocarbons (PFCs) are types of GHGs. While all GHGs have the effect of trapping heat, each gas has a different amount of impact. The various GHGs produced when manufacturing a product, for example, can be represented by an equivalent amount of carbon dioxide associated with the warming effect of a given quantity of a GHG. This amount is known as the global warming potential and is expressed as CO2-eq.

2.0 Eligible Materials:

2.1 What construction materials are affected?

Structural steel, concrete reinforcing steel, flat glass and mineral wool board insulation.

Table 1: Description of eligible materials

Eligible material

Description

Structural steel

Hot-rolled sections consisting of wide flange beams (W-shape), standard beams (S-shape), misc. beams (M-shape), channels, angles, tees, bearing piles.

Hollow structural sections with round, square, or rectangular cross-section.

Plate material.

Concrete reinforcing steel

ASTM A615/A615M standard specification for carbon steel bars.

ASTM A706/A706M standard specification for low-alloy steel bars.

ASTM A767/A767M standard specification for zinc-coated steel bars.

ASTM A775/A775M standard specification for epoxy coated steel bars.

Flat glass

Float or rolled glass that is clear or tinted.

Mineral wool board insulation

Board insulation made of rock or slag in light and heavy density categories.

2.2 Will any other construction materials be added to the BCCA?
It is likely that other materials will be added in the future.

3.0 Affected Entities:

3.1 Which state agencies must comply with the BCCA?

The awarding authorities include: Department of Transportation, Department of Water Resources, Department of Parks and Recreation, Department of Corrections and Rehabilitation, Military Department, Department of General Services, Regents of the University of California, Trustees of the California State University and state agencies granted authority to work on public works projects under Management Memo 18-01.

4.0 GWP Limit:

4.1 Who is responsible for setting the GWP limit?

The DGS, Procurement Division's Engineering Branch.

4.2 How many limits will DGS establish?

There will be seven limits established for compliance by January 1, 2021:

  • Three for structural steel (one each for hot-rolled sections, hollow structural sections, and plate)
  • One for concrete reinforcing steel
  • One for flat glass
  • Two for mineral wool board insulation (one each for light- and heavy-density types)

4.3 Where will DGS obtain the data to establish the GWP limit?

DGS will obtain the data from publicly available EPDs.

4.4 How will the GWP limit be determined?

Legislation requires the limit to be set at the industry average of facility-specific GWP for that material. Prior to the required publication date, DGS will assess the data collected to date and determine the average.

Since EPDs have a level of uncertainty in the reported GWP, DGS will add a tolerance to the baseline average to establish the GWP limit.

4.5 Will DGS exclude the GWP contribution from material fabricators when establishing the GWP limit?

Yes. For the four material types identified in the BCCA, the majority of GWP production is attributed to the manufacturer of the material rather than the fabricator. Therefore, the GWP limit will be based on manufacturer’s impacts.

For example, a steel mill consumes much more energy to melt iron ore (or steel scrap) to form it into a steel beam than a typical fabricator whose operations would consist of welding, drilling, or finishing. GWP production is directly proportional to energy use.

4.6 Once the GWP limit is established, will it ever be changed?

Beginning on January 1, 2024, and every three years thereafter, DGS will review the maximum acceptable GWP for each material and may adjust the limit downward* to reflect industry improvements.

* The BCCA legislation prohibits DGS from adjusting the limit upward.

4.7 Where and when will the GWP limit be published?

The GWP limits will be published on this webpage by January 1, 2021.

5.0 Compliance:

5.1 Who needs to submit EPDs to state agencies?

The successful bidder for a public works project must submit EPDs for all eligible materials to the state agency awarding the contract.

5.2 Is there a particular type of EPD that must be submitted?

An EPD must meet certain requirements before an awarding agency can determine material compliance.

An EPD must be:

  • A facility-specific manufacturer 
  • Independently verified in accordance with ISO 14025 (Type III environmental declarations – Principles and procedures)
  • Developed according to the guidelines of the applicable Product Category Rule (PCR) as identified by DGS
  • Validated by a date that has not expired
  • Represented as an eligible material (as described in Table 1, Section 2.0)

An EPD must not be:

  • An industrywide/industry-average product declaration
  • A fabricator’s product declaration
  • An average reported GWP from multiple manufacturing facilities

5.3 What is a facility-specific manufacturer EPD?

It is a product EPD in which the environmental impacts can be attributed to a single manufacturer and manufacturing facility.

5.4 What’s the difference between a manufacturer, a producer, and a fabricator?

With respect to the BCCA, a manufacturer is the entity that produces the basic construction material that typically requires additional processing by fabricators before use in a construction project.

Consider rebar, for example. A steel mill that melts steel and forms it into rebar would be viewed as a manufacturer, whereas a facility that turns straight lengths of rebar into shapes, bends, or welds rebar would be considered a fabricator.

The terms “manufacturer” and “producer” are used interchangeably by the BCCA implementation team.

5.5 What is a Product Category Rule, or PCR?

A PCR is a set of rules, requirements and guidelines used to develop an EPD for a product group.

5.6 Where can I find a PCR that pertains to the eligible materials identified in the BCCA?

The current PCRs are identified in the References and Resources section below.

5.7 When do EPDs need to be submitted to state agencies during the bid cycle?

Contact the state agency conducting the solicitation for specific requirements.

5.8 How long is my EPD valid?

The expiration date is determined by the program operator and identified within the EPD. An expired EPD will not be accepted for compliance.

North American Program Operators, PCRs, and EPDs

ASTM International: https://www.astm.org/CERTIFICATION/EpdAndPCRs.html

Embodied Carbon in Construction Calculator (EC3): https://www.buildingtransparency.org/en/

NSF International: https://info.nsf.org/Certified/Sustain/epd_search.asp

Program Operator Consortium: https://programoperators.org/

SCS Global Services: https://www.scsglobalservices.com/certified-green-products-guide

Sustainable Minds Transparency Catalog: https://www.transparencycatalog.com/

UL Environment PCRs: https://industries.ul.com/environment/transparency/product-category-rules-pcrs

UL Environment EPDs: https://spot.ul.com/


Reference PCRs for eligible materials

Below are PCRs that can be used to develop EPDs for a wide variety of products within the eligible material category (i.e., structural steel, concrete reinforcing steel, flat glass, and mineral wool board insulation). Please refer to table 1 in the Frequently Asked Questions section above to understand exactly which products need to comply with the initial rollout of the Buy Clean California Act.

 

Structural steel and concrete reinforcing steel 

Title: Part B: Designated Steel Construction Product EPD Requirements 
Valid through: August 26, 2025 
Version: 2.0 
Program operator: UL Environment

Flat glass 
Title: NGA PCR for Flat Glass: UN CPC 3711 
Valid through: September 30, 2025 
Version: 2 
Program operator: NSF International

Mineral wool board insulation 
Title: Part B: Building Envelope Thermal Insulation EPD requirements 
Valid through: April 10, 2023 
Version: 2.0 
Program operator: UL Environment


Maximum acceptable GWP for eligible materials

 

DGS established seven GWP limits for the four eligible materials in the BCCA based on industry-average EPDs and Life Cycle Assessment (LCA) background reports. The limits include a tolerance (a percent increase) to account for uncertainties of reported GWP in EPDs. The limits exclude impacts due to fabrication and only represent the manufacturer’s GWP of the eligible material’s production life cycle.

 

The BCCA legislative report describing the methodology to establish the GWP limits will be posted on the
DGS legislative report webpage.

 

Structural steel

 

The industry-average EPDs for the manufacturing of hot-rolled sections and plate only represent U.S. production, whereas the industry average EPD for the manufacturing of hollow structural sections represents global production. Since the industry-average EPDs were published in 2016, newer data became available. GWP recalculations with the newer data were performed, resulting in new industry averages as follows:

 

Hot-rolled sections: 1.02 metric tons CO2-eq/metric ton.

Hollow structural sections: 2.36 metric tons CO2-eq/metric ton.

Plate: 1.57 metric tons CO2-eq/metric ton.

Due to uncertainties and lack of representation of steel imports, a tolerance of 35% will be added to the recalculated average for hot-rolled sections and plate to establish the final limit. As hollow structural sections already represent global production, a tolerance of 20% will be added to the recalculated average to establish the final limit.

 

BCCA Maximum Acceptable GWP Limit:

Hot-rolled sections: 1.02 metric tons CO2-eq/metric ton + 35% = 1.44 metric tons CO2-eq/metric ton or 1440 kg CO2-eq/metric ton.

Hollow structural sections: 2.36 metric tons CO2-eq/metric ton + 20% = 2.83 metric tons CO2-eq /metric ton or 2830 kg CO2-eq /metric ton.

Plate: 1.57 metric tons CO2-eq/metric ton + 35% = 2.12 metric tons
CO2-eq /metric ton or 2120 kg CO2-eq/metric ton.

Concrete reinforcing steel

 

The industry average GWP for the manufacturing of rebar is 0.92 metric tons
CO2-eq/metric ton, or 920 kg CO2-eq/metric ton. Due to uncertainties, a tolerance of 15% is added to this GWP to establish the final limit for rebar under the BCCA.

BCCA Maximum Acceptable GWP Limit:

0.92 metric tons CO2-eq/metric ton + 15% = 1.06 metric tons CO2-eq/metric ton.

The kilogram equivalent is 1060 kg CO2-eq/metric ton.

Flat glass

 

The industry-average GWP for the manufacturing of flat glass is 1.43 E+03 kg
CO2-eq/metric ton of glass. Due to uncertainties, a tolerance of 20% is added to this GWP to establish the final limit for flat glass under the BCCA.

 

BCCA Maximum Acceptable GWP Limit:

 

            1.43 E+03 kg CO2-eq/metric ton + 20% = 1.72 E+03 kg CO2-eq/metric ton.

 

Mineral wool board insulation

 

The industry-average GWP for the manufacturing of light-density mineral wool board insulation is 3.33 kg CO2-eq/1 m2 of insulation material at average RSI = 1 m2K/W. Due to uncertainties, a tolerance of 20% is added to this GWP to establish the final limit for light-density mineral wool board insulation under the BCCA.

 

BCCA Maximum Acceptable GWP Limit:

 

3.33 kg CO2-eq/1 m2 of insulation material at average RSI = 1 m2K/W + 20% = 4.00 kg CO2-eq/1 m2 of insulation material at average RSI = 1 m2K/W.

 

The industry-average GWP for the manufacturing of heavy-density mineral wool board insulation is 8.16 kg CO2-eq/1 m2 of insulation material at average RSI = 1 m2K/W. Due to uncertainties, a tolerance of 20% is added to this GWP to establish the final limit for heavy-density mineral wool board insulation under the BCCA.

 

BCCA Maximum Acceptable GWP Limit:

 

8.16 kg CO2-eq/1 m2 of insulation material at average RSI = 1 m2K/W + 20% = 9.79 kg CO2-eq/1 m2 of insulation material at average RSI = 1 m2K/W.


Local governments supporting the BCCA:

The following local governments have issued executive directives and resolutions in support of the BCCA:

 

 

 

CONTACT

Engineering Branch

Department of General Services
Procurement Divsion

707 Third Street, Second Floor
West Sacramento, California 95605

BuyCleanCalifornia@dgs.ca.gov

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