Minimum Sustainability Requirements for Federal Government Office Furniture

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Background

The Government Office Furniture Advisory Committee (GOFAC) established an Environmental Sub-Committee in June 2008. The Sub-Committee was tasked with the responsibility for researching, identifying and establishing timelines for the implementation of a set of environmental specifications for government-wide National Master Standing Offers (NMSO's) for Office Furniture.

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Approach

The Environmental Sub-Committee decided to utilize the BIFMA Furniture Sustainability Standard (BIFMA E3-2008) as the basis for the recommendations on the mandatory environmental criteria for office furniture. These recommendations will not specifically include the social responsibility components of the Sustainability Standard, as they are not within the scope of the government's Policy on Green Procurement. However, suppliers will be expected to comply with relevant regulations related to worker Health & Safety and labour rights.

The sub-committee is proposing a tiered approach to incorporate environmental criteria into the procurement strategies for the various commodity groupings for office furniture. A select group of criteria will be mandatory immediately for all NMSO programs starting with office seating; whereas other criteria will be phased in over a four year period.

After consultation with the suppliers on the environmental sub-committee, on the applicability and relevance of the various sections of the BIFMA Sustainability standard, numerous sections have been deleted at this time. The attached 'checklist' denotes those criteria from the BIFMA Sustainability standard that will form part of the immediate and longer-term mandatory criteria for office furniture to be supplied to the federal government. This document provides further detail on the proposed requirements for each of the criteria selected.

In preparation for the eventual introduction of third party registration to the BIFMA Sustainability standard (BIFMA E3-2008), the GoC (Government of Canada) has adopted certain criteria from the Sustainability standard at this time. As soon as there is a registration program in place, the GoC will be considering the Silver level as the minimum standard for all office furniture NMSO programs. Suppliers will need to qualify for Silver using selected criteria that would exclude, some of the social responsibility criteria. Further research and consultation was undertaken with other government departments, who have a vested interest in environmental concerns/issues, including Environment Canada, Natural Resources Canada, Health Canada and Industry Canada; as well as other government jurisdictions. Certification programs, such as Ecologo, were also reviewed.

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Detailed Requirements

The criteria listed in the 'Checklist' are explained in more detail in the following section of this document. Where there is a numbered reference, the reference is to the Business and Institutional Furniture Sustainability Standard (BIFMA E3-2008).

5.1 Design for the Environment

Design for Environment (DFE) is a general concept that refers to a variety of design approaches that attempt to reduce the overall environmental impact of a product and the environmental impacts of the product throughout its life cycle. A type of design for environment is Cradle to Cradle, which works holistically to redesign entire systems.

Life cycle assessment (LCA) is employed to forecast the impacts of different (production) alternatives of the product in question, thus being able to choose the most environmentally friendly.

By 2011, all manufacturers who supply office furniture to the federal government under the NMSO programs must implement a design for environment (DFE) program applicable to those goods supplied. The DFE program as a minimum must consist of the following elements:

• Renewable materials
• Recycled materials
• Recyclable and bio-degradable materials
• End of life management

For the purposes of meeting the 2011 date, water management and energy efficiency are not included.

5.3 Life Cycle Assessment

For all NMSO programs starting in 2011, the manufacturers must incorporate life cycle assessment framework into product design by applying the first two of the four LCA (Life Cycle Assessment) components in ISO 14040 and ISO 14044:

• Goal and Scope Definition
• Life Cycle Inventory

5.6 Sustainable Wood

By 2009, at least 50% of the wood (measured on a volume basis) used in the product shall originate from a forest that was certified to a sustainable forest management standard published by the Canadian Standards Association (CSA), Sustainable Forestry Initiative (SFI), Forest Stewardship Council (FSC) or an equivalent program registered under the Program for the Endorsement of Forest Certification (PEFC). The GoC will establish requirements regarding the submission of documentation to support claims.

Wood is considered solid wood, laminated wood, plywood and other natural fibre such as bamboo etc.

By 2013, all wood used in the manufacture of office furniture, supplied under the NMSO programs must originate from a forest certified under PEFC International (which includes SFI, CSA) or FSC International.

It is the intent of the federal government to develop a means to highlight those companies who offer products for upcoming NMSO programs where all wood used originates from a forest certified under PEFC International or FSC International.

5.7 Recycled Content

Manufacturers will be required to increase the amount of recycled content material incorporated into their products and their packaging. For all upcoming NMSO programs, including office seating, manufacturers must meet the "Recovered Materials Content Requirements" listed in Table One of the Basic Level (paragraph 5.7.1) as stated in BIFMA E3-2008.

By 2011, manufacturers who meet one or more of the Advanced Level (paragraph 5.7.2) recovered materials and content requirements listed in Table One of BIFMA E3-2008 in their product offering shall be recognized in federal government procurement strategies for office furniture. The GoC will establish requirements regarding the submission of documentation to support claims.

5.7.3 Packaging

For all upcoming NMSO programs, including office seating, manufacturers must meet the "Recovered Materials Content Requirements" listed in Table Two of BIFMA E3-2008 (paragraph 5.7.3). The GoC will establish requirements regarding the submission of documentation to support claims.

The GoC encourages the use of re-usable packaging, such as blanket wrapping office furniture for short distances of 100 km or less.

It is the intent of the federal government to develop a means to highlight those companies who have the capacity to consolidate shipments into full truckloads.

5.9.1 Design for Durability / Upgradeability

Design for durability/upgradeability is defined as "A product designed to provide prolonged use, based on either improved durability or an upgradeability feature that result in reduced resource use or reduced waste." (CAN/CSA-ISO 14021, Clause 7.5.1)

For all upcoming NMSO programs, design for durability and upgradeability will be mandatory. Design for durability can be achieved in several different ways; by identifying and eliminating potential weak points in the design; by designing the product to withstand repeated service, repair and handling; by ensuring that standardized parts and components are readily available to facilitate maintenance, servicing and reassembly; by designing a product, including all components to last at least 10 years.

Design for upgradeability requires that the product must be capable of adding new elements to adapt the product to new uses, to extend the first life of the product as long as possible.

For all upcoming NMSO programs, standardized parts and components must be available for at least 10 years; the minimum acceptable warranty on all components, with the exception of fabrics used on seating surfaces, will be at least 10 years and suppliers must indicate how the product can be upgraded for future/continued use. The minimum warranty for fabrics used on seating surfaces shall be at least 5 years.

5.9.2 Design for Remanufacturing (Re-use)

For all upcoming NMSO programs, excluding office seating, product must be designed for remanufacturing/re-use. To meet this criterion, the product must be designed in a modular fashion. A modular design can reduce premature obsolescence and unnecessary disposal as it facilitates the replacement of components that are subject to wear or breakage, likely to go out of style or likely to be upgraded by the end user.

For all upcoming NMSO programs, suppliers will be required to indicate how various components which are subject to wear can be replaced in the field; and how components can be replaced to alter the use of or update the original product.

Design for Disassembly

A characteristic of a product's design that enables the product to be taken apart at the end of it's useful life in such a way that allows components and parts to be re-used.

For all upcoming NMSO programs, products must be designed to be disassembled for re-use. In so doing, the assembly connections of units should be standardized, using screw nuts etc. for ease of assembly/disassembly without damaging the furniture; the assembly and disassembly methods should not require training or the use of special tools; the product should avoid the use of glues, screws etc. Replacing a single component is preferable to replacing an entire assembly or product. I.e. replace work surface trim versus the entire top or table.

The following shall be mandatory requirements within the 'design for disassembly' category:

1. Product disassembly instructions are publicly available
2. Disassembly is possible with standard tools, such as a screwdriver, hammer and pliers
3. Disassembly does not require special training
4. Disassembly can be done in a reasonable time frame (5 minutes or less for each component to be disassembled in a typical office environment)

5.9.3 Design for Recycling

Although it could be stated that design for remanufacturing or design for durability is preferable to design for recycling, products can often not be re-used because of their obsolescence due to technological innovations within the office environment. For example, office chairs designed 20 years ago, do not address the ergonomic criteria of today's office. Because of this, products must be capable of being dismantled and the materials recycled or alternatively furniture must be designed to promote material separation.

Some design concepts to take into consideration are; the material used to manufacture the product has a secondary use; single materials and /or materials that are compatible with recycling are used; avoid the use of co-injected plastics or materials with two types of plastic or plastic and fibre; avoid the use of adhesives and incompatible materials.

It is also critical that there are facilities available to process the components and parts of the product after it has been disassembled.

The following shall be mandatory requirements within the 'design for recycling' category for all office furniture commodities in the National Master Standing Offer Programs:

1. Product disassembly instructions are publicly available
2. Disassembly is possible with standard tools, such as a screwdriver, hammer and pliers
3. Disassembly does not require special training
4. User manual describes material of components (i.e. identifies metal part as steel or aluminum)
5. Disassembly can be done in a reasonable time frame (5 minutes or less for each component to be disassembled, in a typical office environment)
6. Labelled/identified to facilitate separation by material content (i.e. recycling code stamped on all plastic parts)
7. Any materials which may require special handling must be identified
8. It must be possible to separate the metal from other materials in the product without the use of special tools
9. It must be possible to separate plastic parts from other materials in the product without the use of special tools
10. Metals must not be coated with cadmium, chromium, nickel and their compounds

The following shall be mandatory requirements within the 'design for recycling' category for future PWGSC office furniture commodities within the National Master Standing Offer Programs starting in late 2011:

1. All plastic parts > 50 g shall be labelled

Design for Ease of Maintenance

For all upcoming NMSO programs, design for ease of maintenance will be mandatory. Products must be designed in such a manner that maintenance can be undertaken on site, component parts are easy to get to within the confined environment of the normal office and non-organic solvents or other chemicals are not required. The furniture shall be capable of being repaired on-site without the use of solvents; and the cleaning of the product requires the use of organic solvents only. Information must be provided on the cleaning and care of the product.

5.9.4.1 Options for Legacy Product

For all current and future NMSO programs, the end users must be able to obtain information on the suppliers products available on those Standing Offers now and in the future.

Manufacturers must either publish or make available to end users by another means, information on the highest value recovery opportunities for these product lines and the materials that comprise them for all products supplied to the federal government under the National Master Standing Offer Programs starting in 2009 for a period of at least 15 years.

In the event that clients wish to continue to utilize these products, suppliers must indicate where parts and service can be obtained following the discontinuation of a product line.

5.9.4.2 Buy Back/Take Back

By 2011, all NMSO programs, except for office seating, will require a buy back/take back program. The buy back/take back program can be operated by a third party, but must form part of the sales strategy of the product being assessed. This program must be available in at least the following major urban centres: Vancouver, Edmonton, Calgary, Winnipeg, Toronto, Ottawa, Montreal and Halifax.

5.10 Waste Management

By 2011, all manufacturers who supply office furniture to the federal government under the NMSO programs must implement a waste management plan. All furniture shall be manufactured at a facility that has established a program for solid waste auditing, has prepared a waste reduction plan and has instituted a means to track progress towards waste reduction and diversion from disposal of materials such as metals, plastics, fabrics, wood, leather fibreglass and glass.

7.1.1 Human and EcoSystem Health - Demonstration of Compliance

For all upcoming NMSO programs, it is mandatory that the organization evaluate compliance to all applicable environmental and health and safety regulations that govern toxic and hazardous substance use.

The majority of the requirements of WHMIS (Workplace Hazardous Materials Information Systems) legislation were incorporated into the HazardousProducts Act and the Hazardous Materials Information Review Act. Regulations made under these acts include:

• Controlled Products Regulations
• Ingredient Disclosure List
• Hazardous Materials Information Review Act
• Appeal Board Procedures Regulations
• Hazardous Materials Information Review Regulations

7.1.2 Key Chemical, Risk and EMS Policies

For all NMSO programs starting in 2011, it is mandatory that the organization develop and document a chemical management policy that exemplifies how the company assesses and reduces human and ecosystem health impact for chemicals used in their manufacturing facility.

7.2 ISO 14001 or Equivalent

For all Standing Offer Programs, including office seating, the organization shall meet all of the requirements of the BIFMA Sustainability Guidelines for Office Furniture Manufacturers and Suppliers. These guidelines integrate sustainable practices into the organizations operations. As a minimum, the following criteria must be addressed:

• Environmental Policy: include the scope of commitment to sustainability and address all three of its elements (environmental, economic and social)
• Environmental Aspects: commitment to identify and address those elements of the organization's activities, products that can interact with the environment (e.g. recycling of scrap, green house gas reductions, disposal of solid and or hazardous waste)
• Legal and Other Requirements: identify and address legal and other requirements e.g. strive to exceed minimum environmental regulatory compliance
• Objectives and Targets: establish measurements and performance criteria for significant economic, environmental and social impacts e.g. reduce and eliminate waste through source reduction and recycling; increase the use of renewable raw materials
• Implementation: the organization must take actions to implement an environmental management system
• Management Review: the organization must report on their implementation progress and on the achievements made on their environmental management system

ISO 14001

By 2011, all suppliers must be certified to ISO 14001 at the manufacturing site of the product proposed or alternatively meet the requirements of an equivalent Environmental Management System. Companies who are not certified to ISO 14001 must provide third party documentation to attest to the equivalency of their environmental management plan to ISO 14001. Minimum elements for equivalency will include key principles of ISO 14001, namely compliance with all applicable legislation, existence of an environmental management system and a plan for continuous improvement.

7.3 Chemical Management Plan

For all NMSO programs starting in 2011, the organization shall develop a Chemical Management Plan (as outlined in the BIFMA Standard) to manage the chemicals used in products and processes. The organization must implement a system for inventory tracking and control of process, product and facility management chemicals that includes acquisition, use, storage, transportation and final disposition.

All suppliers must meet the requirements of Canada's Chemicals Management Plan, under the Canadian Environmental Protection Act 1999.

A Chemicals Management Plan - Implementation Timetable is also available online.

7.4.1.1 Product Chemicals

By 2011, manufacturers must meet the Intermediate Level, paragraph 7.4.1.2. Thus, the organization must identify and assess all chemicals of concern down to 100 parts per million, using the list from Annex B BIFMA E-3 2008 for materials that add up to 99% by weight of the final product.

By 2013, manufacturers must meet the Advanced Level, paragraph 7.4.1.3 of BIFMA E3-2008. All  chemical constituents down to 100 parts per million must be identified and assessed for materials that add up to 75% by weight of the final product.

7.4.2 Process Chemicals

By 2011, manufacturers must identify and assess all process chemical constituents down to 1,000 ppm of at least 3 manufacturing processes associated with the manufacture of the product.

7.6 Low Emitting Furniture

By 2011, all interconnecting panel systems supplied under the Standing Offer programs and by 2013 all other office furniture supplied under the Standing Offer programs must comply with Section 7.6.1 of ANSI/BIFMA X7.1-2007, when tested in accordance with ANSI/BIFMA M7.1-2007, Standard Test Method for Determining VOC emissions for Office Furniture Systems, Components and Seating. Listing on Greenguard, SCS or other third-party product certification programs which are based on equivalent office furniture emission standards are acceptable.

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Additional Material Requirements

For all upcoming NMSO programs it will be mandatory for the following material requirements to be met:

Wood Based Panels

Wood based panels, i.e. particleboard, fibreboard, and MDF, shall meet the requirements of CARB (California Air Resources Board).

Surface Treatment of Metals

Halogenated organic compounds must not be used for degreasing or the surface treatment of metals.

Metals must not be coated with cadmium, chromium, nickel and their compounds.

Fabrics

Halogenated flame retardants must not be present in the fabric.

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Conclusions

The criteria listed on the Checklist, under 'comply now' denotes those criteria that will be mandatory for the upcoming Request for Standing Offers (RFSO's) for office seating.

For all other commodities, (freestanding furniture, desking systems, filing and storage cabinets and interconnecting panels and supported components), firms will be required to attain "silver" level of conformance, excluding points from Section 8 Social Responsibility, as well as meeting the criteria listed under 2011. PWGSC will require third party verification in accordance with the BIFMA Business and Institutional Furniture Sustainability Standard. However, this requirement is dependant upon a certification mechanism being in place at that time.

At the present time, PWGSC will continue to incorporate "value-added" environmental criteria into the product selection process, through attributes in e-purchasing. For future NMSO programs, PWGSC will attempt to develop a means to highlight those companies who have exceeded the environmental criteria listed.