As a California-based manufacturer of composite architectural products, Kreysler & Associates is keeping a close eye on the sustainability movement.

“We’re getting hit from both sides. The architect clients we serve are getting pressured to improve the efficiency of buildings, and we are located in California,” says Bill Kreysler, president of Kreysler & Associates. “But what happens here gradually works its way through the country. And if that turns out to be the case, then more of our fellow ACMA members are going to start hearing from their customers asking about the environmental impact of the products they make.”

Last fall, California passed two climate disclosure bills – the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261) – that were signed into law by Governor Gavin Newsom. The first disclosures go into effect in 2026. But Kreysler & Associates isn’t standing by waiting for these bills and other regulatory requirements at the state and federal level to be enacted. The company has been proactively developing life cycle analyses (LCAs) and environmental product declarations (EPDs).

“We are trying to get ahead of the game,” says Kreysler.

 The CIRCLE Program

During the past decade, Kreysler & Associates has periodically collaborated with graduate students in an environmental engineering class at Stanford University who have created LCAs for some of the company’s products. That experience – coupled with repeated requests from clients for EPDs – prompted the manufacturer to participate in a case study project spearheaded by ACMA in conjunction with Sustainable Solutions Corp., an environmental consultancy.

The purpose of the project, which began in August 2023, is to develop a life cycle inventory of a cladding product manufactured by Kreysler & Associates and to prepare a third-party verified EPD and associated LCA report for the product. Sustainable Solutions will create a case study for ACMA members sharing the company’s EPD development journey.

“We want more of our members to begin developing LCAs and EPDs,” says Hannah Henry, ACMA’s project manager for sustainability. “We are creating resources such as the case study to help them understand the importance of these documents and begin to quantify the environmental impacts of their products.”

Case studies are one component of the CIRCLE program, a partnership between ACMA and IACMI – The Composites Institute to help composites manufacturers assess and reduce their cradle-to-gate environmental impacts and educate their customers about the climate benefits of using composite products. Other elements of CIRCLE, which stands for Climate Impact Reduction through Composites Lifecycle Evaluation, include development of an LCA-to-EPD generator and product category rules (PCRs).

“In response to federal policy, state procurement practices and climate mitigation programs at automotive OEMs and many other large companies, manufacturers need to provide data on the emission of climate warming gases associated with the manufacture and use of their products,” says John Schweitzer, vice president of EH&S and sustainability at ACMA.

An EPD Case Study

The cladding product EPD case study included four phases: data collection, data analysis, LCA report development and EPD publication. Kreysler & Associates was responsible for the data collection, and Sustainable Solutions did the bulk of the work for the remaining three phases.

At first glance, data collection may seem like an arduous process. Key data required for an LCA and EPD includes information on raw materials, energy use, waste and wastewater, emissions, transportation, disposal and more.

“It’s not nearly as much work as you might think from a manufacturer’s perspective,” says Matt Hettinger, a polymer chemist and engineering manager with Kreysler & Associates. “If you make the same product over and over, you know what goes into it. So, it comes down to figuring out how many pounds of each material go into the final product and how much of it is waste.”

Hettinger oversaw data collection for the project, drawing the required information from material inventories, energy and water bills, and other sources. He already had easy access to some of the data from previous LCA work with Stanford students, so he was able to complete the task in approximately one day.

Sustainable Solutions analyzed the data and created a life cycle inventory (LCI) and life cycle impact assessment – part of the LCA process that shows how resource use and emissions identified in the LCI affect the environment and human health. Several environmental impact categories are incorporated into an LCA, including global warming potential, ozone layer depletion, smog formation, fossil fuel depletion and respiratory effects.

Kreysler & Associates was slated to receive an LCA report in April, and the final EPD was scheduled for mid-May. Life cycle analyses include proprietary information and are available exclusively to companies that generate them, while EPDs are the forward-facing documents for customers and other interested parties.

An LCA-to-EPD Calculator

While ACMA is creating EPD case studies with Kreysler & Associates and a second member company, the association is simultaneously developing an LCA-to-EPD generator tool with two consulting firms – Smart EPD and Trinity Consultants.

“We are enabling a streamlined solution for EPD generation that cuts out a lot of the background steps that individual manufacturers would need to go through,” says Anna Lasso, founder and CEO of SmartEPD, a digital EPD program operator. “The cloud-based tool will be accessible to association members, who will be able to generate third-party verified EPDs that can be shared with architects, designers, engineers and contractors.”

Environmental product declarations are a combination of quantitative and qualitative information about the manufacturer, the manufacturing process and the final product. They include several tables with life cycle environment impact details, such as resource use, carbon emissions, water use, waste generation and more.

Creation of the generator tool involves several steps. Trinity Consultants is building the LCA model to support the workflow with information provided by composites suppliers and manufacturers. The LCA model will then be piloted with three composite products. Next, the model will be integrated with the Smart EPD platform to create ACMA’s LCA-to-EPD generator tool. The generator will undergo third-party verification by Smart EPD and be piloted with the same three products used for LCA model pilot testing. ACMA hopes to roll out the generator tool to members by 2025.

“The generator will take all the guesswork out of EPD generation,” says Lasso. “Manufacturers will log onto the SmartEPD platform and fill out very high-level information that engineering and marketing staff already have access to, such as product descriptions and images. All the nitty-gritty back-end work will already be done.”

Having an LCA-to-EPD generator tool will be increasingly helpful for composites companies as Inflation Reduction Act programs, the state and federal Buy Clean initiatives and other sustainable procurement policies take effect.

“You can point to what the Environmental Protection Agency is pursuing right now, which is a low embodied carbon construction materials program,” says Wendy Merz, sustainability services director with Trinity Consultants. “ACMA is striving to position composites as an alternative construction material, and members will need to be able to provide the same data as competitor materials. The LCA-to-EPD generator is future proofing your products for green procurement policies coming online.”

In addition to providing public procurement information, life cycle assessments also yield valuable insight for internal decision-making, says Merz. For example, generating LCAs has helped Kreysler & Associates better understand the impact of its manufacturing processes, such as creating a sandblasted surface finish.

“When we did an LCA on that process, which includes a sandblasting step, we learned that step  had the single biggest environmental impact, as well as more cost than we realized in energy,” says Kreysler. “Now we are able to guide our clients toward other finish options that provide similar aesthetics but with lower cost and impact.”

PCR Development

When considering sustainability reporting requirements, there’s another central element – product category rules. PCRscomprise two parts: Part A includes general LCA requirements applicable to all products, and Part B details the requirements specific to a product category. They are created by program operators, who are typically organizations with LCA expertise.

“Now that we have this demand for EPDs, it’s very important to build the foundation for doing LCAs for specific product categories,” says Kim Hammer, director of technical services and senior LCA analyst for Sustainable Minds. “The creation of more cradle-to-grave PCRs will allow the composites industry to get more EPDs out into the world.”

ACMA took an important step in this direction by co-leading the creation of the utility pole PCR. As program operator, Hammer reached out to manufacturers of utility poles and related material industry associations to form a committee that met regularly to draft Part B, put it out for review and public comment, then revise and publish the PCR. Committee members included two dozen representatives from the composites, wood, cement and concrete industries.

“ACMA’s goal is to get composites on the map as the sustainable material of choice,” says Hammer. “Together, we identified a product category where composites compete against an incumbent material to create a PCR that addresses not just cradle-to-gate impacts, but cradle-to-grave. That’s where composites shine.”

The utility pole PCR was published in February 2024 and is available on the Part B page of the Transparency Report Program tab on the Sustainable Minds website (

“I encourage composites companies to use the PCR and go make EPDs,” says Hammer. “They are science-based, public-facing reports you can use in branding and marketing and provide to anyone who says, ‘Show me the data.’”

ACMA is currently working on a PCR for rebar and putting together a project team for one on FRP platforms and stairways. And there will be more in the future.

“When you think about the next PCR, consider where composites last the longest looking at cradle-to-grave, the use phase for products and the number of replacements needed over a lifetime,” says Hammer. “Where are composites outperforming incumbent materials? That’s where you start next.”

Staying Ahead of the Game

As the sustainability movement gains greater momentum, composites companies need to stay ahead of the game.

“Know who your competitors are, what product you’re competing against and how long it will be until you need an EPD,” says Hettinger. “For us, it’s right now.”

Kreysler & Associates recently fabricated an FRP sculpture for a large tech company that has begun requiring EPDs. “They are super strict about the environmental impact of products they buy that wind up in their end-use products and facilities,” says Kreysler. “Fortunately, because this was a sculpture, we are exempted from providing the documentation.”

The sculpture was a one-off project unlike many of the multi-component jobs Kreysler typically handles. The company is preparing the EPD for its cladding products so it can provide third-party verified information about environmental impact to customers working on large projects. It’s looking down the road at other EPDs – and is grateful ACMA plans to launch an LCA-to-EPD generator to streamline the process.

“We could not tackle EPDs on our own because of the variety of products we manufacture and the significant cost associated with it. By being a member of ACMA, we can piggyback on the work that’s being done,” says Kreysler. “If you need an EPD, you will save the cost of membership for two or three years just by using the resources and the help ACMA can provide.”

Susan Keen Flynn is managing editor of Composites Manufacturing magazine. Email comments to

Kreysler & Associates is teaming up with ACMA and Sustainable Solutions to create a third-party verified EPD for its cladding products, such as the GFRP shade hoods shown here on a building in San Francisco.

Photo Credit: Kreysler & Associates

The utility pole product category rule (PCR), published in February 2024, is an important tool for companies in the utility market segment that are creating environmental product declarations (EPDs).