Comments from VDMA on PCR DRAFT FOR LIFTS

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VDMA

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2.1

Date: 2014-03-31

Type of
comment

Comments

Document: PCR 4354 Draft

Proposed change

ge

The name and address of suppliers is confidential

information requested to be included in the EPD.
This can be included in the LCA report but not
disclosed in the EPD and certainly not as
mandatory information.

Project:
Observations of the
secretariat

Eliminate this request and modify the text as

follows:
Information about the company issuing the EPD
shall be specified in the EPD, including a
description of the company, and a description of
its overall environmental work.
Mandatory information:
Name and address of company
The site(s), company or group of companies or
those representing them for whom the EPD is
representative, i.e. list of all in-house
manufacturing locations
Issuer and contacts
Voluntary information:
Name and address of supplier / manufacturers
and designation of main component supplied by
them.

VDMA

2.2

ed

We suggest to use the terms from the European

Regulations

replace moving walkways by moving walks;

replace elevator by lift

VDAM

3.1

ge

By alternative use of VDI 4707 and ISO 25745 the

EPDs are not comparable. So it is absolutely
necessary that only one norm is used and the PCR
clearly indicates which one has to be used in the
EPD

We suggest to deal with VDI only and to delete all

places in the document where ISO 25745 is
used.

VDAM

3.1

ge

For the differentiated view on components, the VDI

4707-2 is necessary.
See also DIN EN ISO 14025, Figure B.1.

Add VDI 4707-2 in the second paragraph

VDAM

3.1

Table 3-2

te

Hydraulic lifts are usually in the range of 0,15 to

1,00 m/s

extend velocity to 1,00 m/s in the 4th and 5th

column of table 3-2 in the row "Nominal velocity"

VDMA

3.1

Table 3-3

te

"trips per day" and "usage category" are redundant

delete one of them in Table 3-3

VDMA

3.1

Table 3-3

te

There is only one table for one usage category

We suggest to create a total of 5 tables for all

those usage categories mentioned in table 3-1,

Type of comment:

ge = general

te = technical

ed = editorial
page 1 of 6

Comments from VDMA on PCR DRAFT FOR LIFTS

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Date: 2014-03-31

Type of
comment

Document: PCR 4354 Draft

Comments

Proposed change

Project:
Observations of the
secretariat

e.g table 3-3.1 to 3-3.5

VDMA

3.2

rd

3 para

te

Functional unit 'per passenger floor' is not

appropriate. Optionally the functional unit year or
life time could be given.

Replace by 'per year' or per life time.

Doing so the second part of the third paragraph
becomes obsolete and has to be deleted. The
third paragraph will be as follows:
"in order to facilitate the integration of elevator LCI
and LCIA data based on this PCR into whole
building LCAs of "green" building schemes, a
functional unit of " per year" or per "life time" may
be used in the EPD."

VDAM

3.2

Table 3-4

te

Number of passengers is given by the rated load

Delete this line

VDAM

3.2

Table 3-4

te

Functional unit 'per passenger floor' is not

appropriate

Replace by 'per year' or per 'life time' or delete the

line as well as adapt the title of the table

VDAM

2nd and 3rd

bullet

te

"precious metals" as well as "heavy metals" are

used in lifts normally only in components like
electronic components. Because these
components are purchased it is not feasible to
declare the amount of such substances. Of course
their environmental impact will be taken into
account using the adequate background data.

Delete "heavy metal" in the 2nd bullet and text in

parentheses of the 3rd bullet or only replace it with
electronic components without naming precious
metals

VDMA

1st para
following
figure 6-1

ge

In the first sentence it is mentioned that phase A3 is

important. But all LCA studies on lifts show that the
environmental impacts from phase A3 have a minor
relevance.

Cancel: "due to its importance".

If you like you can replace it by "due to the direct
influence of the manufacturer"

VDAM

6.1

ge

Difficult or impossible to apply, because you know

the total environmental impacts of materials only
after having calculated the LCA including all
materials.

This cut off rule should be changed adequately to

the criteria given in chapter 4:
At least 95% of all materials and energies
Plus all materials with very high environmental
burdens

VDMA

6.2

Type of comment:

last para

te

Internal transport can be relevant, e.g. if a

production site of components is in south Europe
and the manufacturing is in Northern Europe, the
internal transport can be relevant and has to be
ge = general

te = technical

internal transport if relevant

ed = editorial
page 2 of 6

Comments from VDMA on PCR DRAFT FOR LIFTS

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Date: 2014-03-31

Type of
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Comments

Document: PCR 4354 Draft

Proposed change

Project:
Observations of the
secretariat

taken into account

VDMA

6.3

te

Direct emissions e.g. VOC emissions may be

relevant

Include a bullet point VOC emissions

VDMA

6.3

last para

te

Internal transport can be relevant, e.g. if a

production site of components is in south Europe
and the manufacturing is in Northern Europe, the
internal transport can be relevant and has to be
taken into account

internal transport if relevant

VDMA

6.4

A5 and B

te

There is no difference between TVOC and VOC

Use only VOC because it is the term normally

used.

VDMA

6.4

C3 & C4

te

Recycling: it has to be defined which allocation

rules have to be used.

For recycling the cut off method has to be used.

To be consistent with the 7.1.5 and with the

recycled content approach in chapter 8.4.1 the cut
off allocation has to be used.
VDMA

6.4

VDMA

VDMA

A5 and B

te

It is enough to give the quantities of VOC emitted

Delete densities and concentrations

7.1.1

ge

According to the experience made with LCAs

performed by the manufacturers, the core module
is of minor relevance for lifts and the applied
degree of detail is not necessary.

We suggest mentioning the relevance of the core

module and what this implies for the degree of
detail.

7.1.2

te

What is meant by LCI data, background or

foreground data? For background data in many
cases only values older than 5 years are available.
It should be the target to use the most actual data.

Replace "shall" by "should" because it cannot be

mandatory.
Replace representative by the latest data available

What is meant by representative for the year/time

frame for which the EPD is valid? Is the meaning to
use prognostic values for the next five years?
VDMA

7.3

Type of comment:

2nd para, last

sentence

te

We are aware that according to ISO 14'040ff the

economic allocation is recommended in third place,
after system boundary extension and physical
allocation. Nevertheless in many cases economic
allocation is the most appropriate allocation
method, which is also used in international
databases like ecoinvent. It is not indicated to make
ge = general

te = technical

The second paragraph has to be deleted.

ed = editorial
page 3 of 6

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Date: 2014-03-31

Type of
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Document: PCR 4354 Draft

Comments

Proposed change

Project:
Observations of the
secretariat

this extra effort when using economic allocation.

rd

VDMA

7.3

3 para

te

It is not always the adequate solution to use the

total amount of produced units at the production
site.

" at the production site can be used."

VDMA

7.4

5th para

te

The electricity production mix should also consider

the export and import of electricity. This means the
consumption mix has to be used

The consumption mix has to be used.

VDMA

7.5

te

Knowing that the core module is of minor relevance

the expenses to do so for the core module are too
high.

Delete chapter 7.5 or replace it with:

If specific data are not available for the core
module, average data for energy, auxiliary
materials and operation materials can be used.

VDMA

8.3

2nd para, last

line

te

VDMA

8.4.1

4th para

te

It is often not realistic to have a representativeness

better than 5%

Replace "better than +/- 5%" with "as high as

possible".

VDMA

8.4.1

Footnote 12

te

The ecoinvent default allocation is an allocation at

the point of substitution and so it is an allocation
with system expansion. This means that this
recommendation is contradictory to bullet point 5 of
this paragraph. In the next months an ecoinvent
version with cut off should be available. We don't
know the name of this allocation version.

Delete "allocation, ecoinvent default" and write

only that attributional models and not
consequentional models have to be used.

VDMA

8.4.1

6th para

te

The transportations are of low significance and not

easy to investigate

Delete the whole paragraph and allow using

average values if no specific value are available.

VDMA

9.1

1st para

The energy used in European countries is

produced by various energy sources and the
differences in environmental impacts between the
different countries are very high. Because of the
relevance of the use phase it is necessary that the
used electricity mix is clearly defined.

We suggest using the European electricity mix

UCTE in the use phase.

VDMA

9.1

approach A

VDMA

9.1

VDMA

9.3

Type of comment:

rd

3 bullet

"can be used", see also remark 7.3

ed

Use standby definition from VDI 4707-2

te

The class is of no relevance

Delete the class

te

In all other stages the cut off approach is equivalent to the

Stop the whole para after "Recycled content (RC)

or cut-off approach shall be applied for the end-of-

ge = general

te = technical

ed = editorial
page 4 of 6

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Document: PCR 4354 Draft

Date: 2014-03-31

Type of
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Comments

Proposed change

recycled content approach. So to be consistent it is

important to use the same approach also in the
downstream module. Furthermore has the

Project:
Observations of the
secretariat

life stage."

manufacturer no long-term influence on its supplied

products and is therefore not in the position to
assess it.
VDMA

9.5

VDMA

10.2

VDMA

10.2.1

VDMA

10.3

VDMA

10.4

Type of comment:

2nd pare, 2nd

bullet

chapter

First para
and the 7
bullet points

te

A lift doesn't contain a significant amount of

combustible material. The formulation does not
makes clear what the intention is.

This point can be deleted or it needs clarification.

ed

CFCs (FCKW) are not used directly in lifts so the

ozone depletion potential can lead to artefacts
according to the used background data and is not a
valuable indicator for the environmental impacts of
a lift.

To be deleted

te

This chapter is according to PAS 2050 and can

make sense for products or services using a
relevant amount of materials from biogenic
resources. But in lift systems this is not the case.
Materials from biogenic resources are marginal. So
it makes no sense to spend time and money to
calculate the carbon storage according to this
norm. We suggest treating biogenic CO2 as climate
neutral as it is done by a lot of LCA methodologies
and studies.

Replace the first three para with the following

sentences:

Toxic indicators are typically very sensitive to

specific substances from background data and so
the results can be misleading. Furthermore a
reader not familiar with these indicators could
conclude that the lift itself and its use has a
negative impact on his health

We suggest deleting this para and the bullets. The

rest of this chapter starting from "The
methodologies outlined." Is fine

The environmental impacts of waste and its

treatment will be calculated and reported over the
whole life cycle. But to report the amount of waste
over the life cycle in the EPD is misleading. In lift
system most of the waste is coming from upstream
processes like mining. The manufacturer has no
influence on these processes. Some time it is

The reported amount of waste is to be restricted to

the core module only

te

ge = general

te = technical

CO2 from biogenic resources has to be treated

as climatically neutral. Furthermore no carbon
storage has to be taken into account.
Followed by the content of the third bullet point.
Bullet point 1 and two have to be deleted.

ed = editorial
page 5 of 6

Comments from VDMA on PCR DRAFT FOR LIFTS

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Document: PCR 4354 Draft

Date: 2014-03-31

Type of
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Proposed change

Project:
Observations of the
secretariat

mentioned that the use of recycling will reduce this

wastes and that's true but especially for metals this
is out of the influence of the manufacturer because
the demand for scrap to recycle is higher than the
supply.
The manufacturer can influence the waste in the
core module.
VDMA

11.6

Table

ed

add ISO 14025

VDMA

12

1st para

te

Lift industry is not as fast as e.g. electronic industry

and the products have a life time of 20 up to 50
years and more

Extend validity to 5 years

VDMA

12

2nd para, 1st

sentence

te

The owner of the EPD has to maintain a

management process to assure that the content is
still consistent with the current situation. However
in this process the verifier can, but does not have to
be involved.

Change the first sentence as follows:

During the validity period the owner of the EPD
has to maintain a process to assure that the
content is still consistent with the current situation

VDMA

14

ed

Title is missing

Add a title

VDMA

15

ed

Title is missing. Where do the table come from?

Add a title and the reference

Type of comment:

ge = general

te = technical

ed = editorial
page 6 of 6