Minimum Environmental Criteria
What are the Minimum Environmental Criteria for urban design?
It is increasingly common to hear the term Minimum Environmental Criteria, also known as MEC. This term groups together the environmental requirements defined for the various stages of the purchasing process, aimed at identifying the best design solution, product or service from an environmental point of view throughout the life cycle, taking into account market availability. From the point of view of jurisdiction, the content and application of the Minimum Environmental Criteria are regulated by Article 18 of Law 221/2015 and Article 34 of Legislative Decree 50/2016 “Procurement Code”, subsequently amended by Legislative Decree 56/2017. There are specific Minimum Environmental Criteria for each sector. In our case, it is the one approved by Ministerial Decree of 5 February 2015, published in the URBAN DESIGN Official Journal 50 of 2 March 2015: "Purchase of articles for urban design".
MINIMUM ENVIRONMENTAL CRITERIA (CAM) IN FORCE FOR URBAN DESIGN FOR THE PURCHASE OF ITEMS FOR URBAN DESIGN OFFICIAL JOURNAL OF THE ITALIAN REPUBLIC Purchase of items for urban design (approved with Ministerial Decree 5 February 2015, in the OJ 50 of 2 March 2015)
What is the purpose of applying the Minimum Environmental Criteria?
The regulations mentioned in the previous paragraph have made the application of the Minimum Environmental Criteria (MEC) mandatory for all contracting authorities, so for the time being, the main stakeholders are public administrations. The focus of the Minimum Environmental Criteria is on the circular economy of resources. The intention is to motivate green purchasing, thereby promoting the development of technologies and products with a low environmental impact and, at the same time, reducing the consumption of raw materials by using waste as a resource.
Materials and processes that do not comply with the Minimum Environmental Criteria
The Ministerial Decree of 5 February 2015 concerning Urban Design mentions a list of substances classified as highly related to by Articles 57 and 59, paragraph 1 of Regulation 1907/2006 of the European Parliament and of the Council that must not, even in the slightest solution, be found in furnishing elements, playground equipment and safety matting intended for playgrounds.
Specifically, surface treatment products must not contain substances or mixtures classified or classifiable with the following hazard statements:
H300 Fatal if swallowed;
H301 Toxic if swallowed;
H304 May be fatal if swallowed and enters airways;
H310 Fatal in contact with skin;
H311 Toxic in contact with skin;
H330 Fatal if inhaled;
H331 Toxic if inhaled;
H340 May cause genetic defects (indicate the route of exposure if no other route is known to cause the same hazard)
H341 Suspected of causing congenital disabilities (indicate the route of exposure if no different route is known to cause the same hazard)
H350 May cause cancer (indicate the route of exposure if no other route is known to cause the same hazard)
H350i May cause cancer if inhaled
H351 Suspected of causing cancer (indicate the route of exposure if no different route is known to cause the same hazard)
H360F May impair fertility
H360D May damage the foetus
H360FD May damage fertility. May damage the foetus
H360Fd May damage fertility. Suspected of harming the foetus
H360Df May damage the foetus. Suspected of damaging fertility
H361f Suspected of impairing fertility
H361d Suspected of harming the foetus
H361fd Suspected of damaging fertility Suspected of harming the foetus
H370 Causes damage to organs (or indicate all affected organs, if known) (indicate the route of exposure if no other route of exposure is known to cause the same hazard)
H371 May cause damage to organs (or indicate all affected organs if known) (show route of exposure if no other route of exposure is known to cause the same hazard)
H372 Causes damage to organs (or indicate all affected organs if known) through prolonged or repeated exposure (indicate the route of exposure if no other route of exposure is known to cause the same hazard)
H373 May cause damage to organs (or indicate all affected organs if known) through prolonged or repeated exposure (indicate the route of exposure if no other route of exposure is known to cause the same hazard)
H400 Very toxic to aquatic organisms
H410 Very toxic to marine life with long-lasting effects
H373 May cause damage to organs (or indicate all affected organs if known) through prolonged or repeated exposure (indicate the route of exposure if no other route of exposure is known to cause the same hazard)
H400 Very toxic to aquatic organisms
H410 Very toxic to marine life with long-lasting effects
- must not contain additives containing lead, cadmium, hexavalent chromium, mercury, arsenic, barium (excluding barium sulphate), selenium, antimony.
Autoclave impregnated wood (use class 4) does not comply with Minimum Environmental Criteria
The strict application of the Minimum Environmental Criteria in the playground and urban furnishings has led manufacturers to reconsider how they work entirely. Until then, Nordic pinewood impregnated in an autoclave with anti-mould and rot salts accounted for most of the raw material used. Although in recent years the percentages of harmful substances traditionally present in impregnating agents have been removed, or at least reduced, there are no impregnating agents for autoclave treatment that meet the Minimum Environmental Criteria, i.e. no impregnating agents correspond to use class 3 (outdoor, above ground, exposed to weathering) and 4 (outdoor in contact with soil and/or freshwater) according to EN 351-1:2007 and EN 335. Should anyone claim otherwise, it is always advisable to obtain the safety data sheets to check that the substances listed in the Ministerial Decree of 5 February 2015 are not contained.
Could surface treatments for wood be a viable alternative to impregnation?
On the other hand, surface treatments for wood carry the Ecolabel label and/or meet the requirements set out in the Annex to the Decision of 28 May 2014. According to Holzhof, this type of product is at odds with the philosophy of the Minimum Environmental Criteria: that of the circular economy and the prevention of waste of resources. In addition to being costly due to the application method and the need to repeat the treatment at regular intervals, it is advisable to recommend the use of these products only for covered items such as gazebos with roofs or playhouses, preventing any wood treated from coming into direct contact with the ground. However, some surface treatments meet the Minimum Environmental Criteria because they do not contain substances of "concern", which unfortunately also reduces the effectiveness of the finished treatment. The manufacturing of wood products comprises several working phases from the logging of the trunk to the assembly of the finished product, and consequently, using a treatment that considerably reduces its durability can only be a "waste". Another reason against impregnated or varnished wood is disposal at the end of its life: impregnated timber belongs to the "special waste" category since some components are contained in the impregnating/painting agents such as copper are not recyclable.
In the following section, we will show you environmentally friendly alternatives to don't have to forego wood.
Which materials comply with the Minimum Environmental Criteria?
Holzhof was one of the first manufacturers to take seriously the challenge of introducing the Minimum Environmental Criteria, demonstrating its support for a regulation that aims to protect the environment in which we live. Hopefully, manufacturers and consumers will now start to take the issue seriously by using the alternative materials discussed below:
Black Locust
Black locust is a natural alternative to impregnated pine (link to the Black locust pseudo acacia page). This carbon-neutral plant grows in abundance throughout Europe; its wood is resilient and resistant to sudden climate changes. This is one of the toughest wood species on our continent and is resistant to fungal, insect, and a bacterial infestation - durability class 1 /2 (Very Durable/Durable) according to point 5.2 of EN 350:2016 - and does not require treatment for outdoor use. Furthermore, this wood can be used for class 4 (outdoor use in contact with soil and/or freshwater) according to EN 351-1:2007 and EN 335.
Heat-treated wood (thermowood)
Heat-treated wood (thermowood) is the alternative solution to using pressure-impregnated wood. The manufacturing process occurs in a vacuum or steam system in a particular plant. Once the thermo-treatment process has been completed, its durability becomes equivalent to impregnated wood, equal to class 1-2 of the UNI EN 350 standard (very durable -durable). The thermo-treated wood acquires a natural brown colour, and since it has not undergone any chemical treatment, it can be disposed of at the end of its life without any problem.
Aluminium - lightweight and corrosion-resistant
To offer our customers a wide range of products that meet the Minimum Environmental Criteria, Holzhof has also chosen to use aluminium as the load-bearing structure of our play equipment. The raw material for aluminium production is abundant, and the finished aluminium product is very easy to recycle thanks to a low melting temperature of around 660 °C. Its high corrosion resistance makes it particularly suitable for installation near the sea.
Can recycled plastic be part of green procurement?
Recycled plastics are a good solution for developing playground furniture and play equipment. A distinction is generally made between rotationally moulded polyethene, second life plastic and polyethene panels.
Polyethene is very easy to recycle after use, requires very little maintenance and has a long service life. Holzhof has more than 80 moulds for rotational moulding of the plastic material, preferring this type of component for its excellent surface finish, high corrosion resistance and dimensional stability. The Minimum Environmental Criteria state that semi-finished products manufactured using rotational moulding technology must contain at least 30% recycled material. The rotational components made by Holzhof include on average 50 to 60% recycled material.
The percentage of recycled plastic in the second life plastic that Holzhof uses to make furniture products is even higher. These profiles can contain up to 100% recycled plastic but, in some instances, require a steel core to maintain stability, and the surface finish is less smooth than rotationally moulded polyethene. Due to the very high percentage of post-consumer material, this type of product reduces the amount of waste in landfills.
Polyethene panels belong to the third category of semi-finished plastic products. They are used as a structural part (e.g. platforms) of play structures, especially as static equipment panels. They have excellent durability, retain their colours and are ideal for customisation by milling. They are considered compliant with the Ministerial Decree of 5 February 2015 if they contain at least 50% recycled plastic.
How can I be sure that the material offered corresponds to the Minimum Environmental Criteria?
There is still a lot of confusion on the subject of Minimum Environmental Criteria, the correct application of the criteria, and the type of materials that correspond to the directives of the decree. Doubts are mainly focused on wood. Attention must be paid to whether the product offered is of sustainable origin, made of recycled wood and/or wood from sustainably managed forests. In this case, the product must have FSC or PEFC certification. The so-called "chain of custody",, i.e. the origin of the wood, is demonstrated through the commercial documents accompanying the product. Therefore, it is advisable to check that both the delivery note and the invoice contain the appropriate declarations relating to the certification of the various products supplied. A further check should be made on the FSC or PEFC website to check that the supplier is actually in possession of the FSC or PEFC certification, that it is still valid, and the list of woods that the supplier can sell as "certified". The links where this search can be carried out are given below:
There is also the case where the trader/retailer is not certified but can sell FSC or PEFC certified products, as they are purchased from another manufacturer in possession of regular certification and sold without any additional processing. In this case, the end customer can still ask the supplier for a copy of the documents that accompanied the product throughout its life cycle (from raw material onwards) to reconstruct the so-called "chain of custody".
As previously stated, no impregnating wood product, which can guarantee a "long term" durability, is free from substances classified as "worrying", which, according to the Minimum Environmental Criteria, must not come into direct contact with the users of the product. Suppose impregnated wood is offered with a declaration of conformity to the Minimum Environmental Criteria. In that case, it will be necessary to obtain the safety data sheet of the impregnating product to verify which substances it contains. It will also be essential to ascertain that any surface treatments (varnishes and others) are Ecolabel certified, as required by the Minimum Environmental Criteria.
The decree of 5 February 2015 states: “Plastic articles or semi-finished plastic products from which they are made shall be made predominantly of recycled plastic, i.e. a minimum of 50% by weight of the total weight of plastic used. In cases where semi-finished products are used (e.g. playground slides) that can only be produced using “rotational moulding” technology, the minimum recycled plastic content of these semi-finished products may be 30%, by weight, in relation to the total weight of the item”. Consequently, proof of the percentage of recycled plastic in the product must be requested from the manufacturer and/or supplier.
The issue of safety matting is a significant problem for all playground equipment manufacturers. The Minimum Environmental Criteria require loose natural safety materials such as sand, gravel, bark, wood shavings etc. Plates made of rubber or a mixture of rubber and freshly applied resin (rubber casting) are not permitted. Even if the plates, such as those supplied by Holzhof, contain rubber granulate derived from used tyres, they could not be placed in a playground in compliance with the Minimum Environmental Criteria. Similarly, the resins used as the binder for the granulate used to make the poured safety matting also contain substances classified as “worrying”.
Examples of commonly used impact-absorbing materials, depths and corresponding maximum free-fall heights (extract from EN 1176-1:2018 clause 4.2.8.5.2)
It is advisable to always ask for a declaration of compliance with the Minimum Environmental Criteria in which the supplier explicitly declares to be aware of the Ministerial Decree of 5 February 2015 in all its parts and that the content has been applied for the part for which it is responsible.
Recently, there has been a growing perception of creating recreational products suitable for all users. In particular, contracting authorities are increasingly asking for inclusive and shockproof equipment that meets the Minimum Environmental Criteria. As far as shock proofing is concerned, the Minimum Environmental Criteria would require the use of natural bulk material. However, how would a child in a wheelchair or with severe motor impairments access the playground if this type of shock-absorbing material is present? After consultation with the responsible ministry, the conclusion was reached that rubber shock-resistant matting can be used in these cases and that the right of children with disabilities to play should take precedence over the correct application of the shock-resistant guidelines.