FAQs for BCCA

References: Where can I get more information on EPDs and the Buy Clean California Act (BCCA)?
Below are a list of resources related to BCCA guidance and implementation:
BCCA: What is the BCCA?
The Buy Clean California Act (BCCA) (Public Contract Code Sections 3500-3505) is part of California's overall strategy to address climate change. The BCCA requires facility specific EPDs reflecting Global Warming Potential (GWP) values within the limits set forth by the Department of General Services (DGS) for specified structural steel, concrete reinforcing steel, flat glass, and mineral wool board insulation.
Applicability: Do the BCCA provisions only apply to projects with an estimate over $1M and 175 working days? So if a project is $2M but only 150 working days, then the BCCA provisions do not apply, correct?
Correct, but to clarify, the dollar value criterion is based on the total bid amount, not the Engineer's estimate amount for Caltrans projects. On non-emergency construction contracts, both criteria need to be met to trigger the requirement. The requirement will not apply if only one of the criteria is met, like in the example you provided.
GWP Limits: How did DGS set the limits? And will they change?
A. DGS set the limit for that material to be the industry average of facility-specific GWP. See Buy Clean California Act Legislative Report (Issued 1-1-22) .
Beginning on January 1, 2025, and every three years thereafter, DGS will review the GWP limits for each material and may adjust the limit downward. The BCCA legislation prohibits DGS from adjusting the limit upward.
How do I submit an EPD on the EPD Data Collection System?
Under "Help & Support" >> "EPD database Guide", there is a detailed walkthrough of how to submit an EPD to the database.
Temporary structures: Are EPDs exempted when the material is for a temporary structure? For example, we have the following bid items:
  • 108 TEMPORARY BRIDGE (BAR REINFORCING STEEL, BRIDGE) 269,787 LB
  • 109 TEMPORARY BRIDGE (STRUCTURAL STEEL, BRIDGE) 27,597 LB
There are no exceptions for BCCA eligible materials that are temporary in nature. There are other exemptions that may apply (based on the size of the project, the cost of project, or the weight from the source mill), but there is no exemption based solely on temporary items.
Temporary "Bailey" bridge: We are providing a temporary modular bridge superstructure using a "Bailey" bridge-type system. Is an EPD required for this? The bid item is 110 TEMPORARY BRIDGE (MODULAR BRIDGE SUPERSTRUCTURE)
A "Bailey" bridge type system is portable and reusable, and there will generally not be any components milled or fabricated for this project's specific use. As such, the Bailey bridge will not require EPDs.
Emergency projects: Are EPDs required for "Emergency" projects?
No, EPDs are not required on Emergency projects. See your project's Special Provisions to verify if the project has requirements for EPDs, which will be in Section 6-1.06, BUY CLEAN CALIFORNIA ACT.
Stainless Steel rebar: Are EPDs required for stainless steel rebar, specifically ASTM A955/A955M Standard Specification for Deformed and Plain Stainless Steel Bars for Concrete Reinforcement?
No, EPDs are not currently required for stainless steel rebar. Special Provisions Section 6-1.06, BUY CLEAN CALIFORNIA ACT, refers to Section 52-1.02B, which references the following rebar specifications that apply to the BCCA:
  1. ASTM A706/A706M Standard Specification for Deformed and Plain Low-Alloy Steel Bars for Concrete Reinforcement
  2. ASTM A615/A615M Standard Specification for Deformed and Plain Carbon-Steel Bars for Concrete Reinforcement
Stockpiled material: We have material that was produced many years ago, before the EPD for the mill was issued. Can we still provide this material if there is a current and valid EPD from the mill?
Yes.
Local agency projects: We are a local agency and are advertising, awarding, and administering a project on the Caltrans right of way. Do these provisions apply if we're only installing traffic control devices within Caltrans's right of way?
If project criteria, including project bid and total working days, are met, then the provisions will apply to specific materials listed in Caltrans standard special provision Section 6-1.06, BUY CLEAN CALIFORNIA ACT. Footnotes for each of the materials state the quantity thresholds that also need to be met in order for the provisions to apply.
Local agency projects partially on Caltrans ROW: If only a small portion of our project is within Caltrans right of way, do the BCCA provisions apply to the entire project or only the portion that is within Caltrans right of way?
If you are the advertising, awarding, and administering agency, then BCCA would only need to be met on that portion of work within the state right of way. However, it may be easier to apply the requirements to the total project.
Are EPDs required for dowel bars and tie bars for concrete pavements?
No, EPDs are not currently required for dowel bars or tie bars for concrete pavements, as referenced in the latest Standard Specification Section 40-1.02C(3) Dowel Bars and 40-1.02C(4) Tie Bars. For example, Section 40-1.02C(3) states, "For a project not shown to be in a high desert or any mountain climate region, dowel bars must be plain bars complying with section 52 and must be one of the following... Epoxy Coated... Stainless-steel... Low carbon, chromium-steel..." Per Section 6-1.06 of the latest standard specification, the black rebar used for making epoxy coated dowels requires EPDs.
Does Merchant Bar (MBQ) used in structural steel applications require EPD?
AISC 303-22 and the product category rule for steel does not categorize MBQ as a structural steel element. Hence, it does not require EPD.