Can we substitute this product without breaking the project's sustainability commitments?
A cheaper or faster product is not automatically a sustainability failure. The failure is approving it on price and lead time alone, then discovering that the rating pathway, agency materials rules or carbon model no longer hold. By then the panels are on the wall and the evidence pack is empty.
Direct answer
Approve the substitute against the requirements it must satisfy, then assess whether the total saving is worth making. A lower price or shorter lead time cannot establish technical equivalence.
Use four screens: performance, sustainability commitments, evidence, and authority. Keep a proposed substitute on hold until the relevant reviewers resolve the first three screens and the authorised person records acceptance. Scope the review to the affected requirements; an unchanged label is not evidence of unchanged performance.
This is Makao’s recommended internal decision record. It does not replace statutory approvals, certification assessment or the contract’s change procedure.
The practical approval screen
Use this table before you issue a purchase order or accept a shop drawing. Fill it from the project documents you already have.
Screen | Question | Record | Pass / Hold / Fail |
|---|---|---|---|
1. Performance | Does the substitute meet the same functional performance the design assumed for this use (for example fire, acoustic, structural, thermal, clinical hygiene, durability - as applicable)? | Requirement and revision; original and proposed results; evidence and test conditions; named competent reviewer | |
2. Carbon / materials pathway | Does it keep the pathway the project actually committed to (Responsible Products / finishes where used, agency timber or recycled-content rule, volatile organic compound (VOC) / formaldehyde limit where applicable, upfront-carbon model input)? | Applicable assessment method; evidence coverage; effect on target and remaining margin; reviewer’s conclusion | |
3. Evidence gate | Can acceptable proof be obtained before the latest safe gate for this product (order, fabrication, delivery or installation - whichever the commitment needs)? | Certificate validity; product coverage statement; invoice / cost-evidence format the assessor or agency expects | |
4. Authorisation | Who is contractually authorised to accept the change (superintendent / principal’s representative or equivalent), and who provides technical advice only? | Actual written acceptance, conditions and release authority; approval reference and date |
Pass: all applicable checks are resolved and the authorised person has accepted the change in writing. Hold: evidence, review or a decision is outstanding. Fail: the proposal cannot meet an applicable requirement. A contract change cannot waive statutory obligations or the rating scheme’s rules.
A consultant’s technical recommendation and contractual acceptance are different decisions. One person may hold both roles, but the record should identify which authority they are exercising.
Do not rank products by a carbon number in isolation. Ask the assessment lead to confirm equivalent function, quantities, assessment boundary and accepted data before changing the model. EPD Australasia TC 01 permits stated average, representative or worst-case results for similar products. Confirm coverage; do not reject or accept a family EPD simply because it covers several products.
For Green Star, check the project’s registered tool, applicable guidelines, calculators and rulings. NATSPEC’s public specification guide helps identify evidence and worksections, but does not guarantee certification. Keep a carbon assessment, a recognised-product claim and an indoor-emissions requirement as separate checks: evidence for one does not establish the others.
Apply the project’s requirements, not a generic agency list
Record the jurisdiction, agency brief, applicable edition and contractual requirements on the change request. If the new product changes a declared design input, ask the relevant reviewer whether recalculation or further approval is needed.
- Victorian schools: the Department’s policy requires sustainable design through the Building Quality Standards Handbook and treats Green Star as an additional project-based initiative.
- NSW schools: confirm the applicable EFSG edition and project specification. School Infrastructure’s edition rules depend on project timing and possible later directions.
- NSW healthcare: check the engineering brief for effects beyond the headline efficiency figure. NSW Health’s Engineering Services Guideline says contractor alternatives should not reduce equipment serviceability or accessibility.
- Victorian public healthcare: check the applicable VHBA requirements and project control points before changing a selected product.
These are jurisdiction-specific sources. None creates a single Australia-wide product-approval checklist.
Failure mode (illustrative - not a real project)
Illustrative example: a wall lining substitute has a “low carbon” brochure and an Environmental Product Declaration (EPD) for a product family. The team approves it on lead time without checking product coverage or the separate indoor-emissions requirement. At submission, the team cannot substantiate the required claims. The product might be acceptable, but the missing review makes that conclusion unproven.
A useful second check is the remaining margin. A substitute may satisfy its individual specification yet consume the margin in a project-level carbon or materials target. Record the project-level consequence before deciding.
Concrete next action
Use the four-screen table for the next proposed substitute. Attach the original requirement, proposed product, evidence, reviewer’s conclusion, target impact and actual approval. Record any conditions that must be met at delivery or installation, and assign someone to close them.
If the proposal relies on a lower-carbon product claim, check whether the two EPDs are comparable before treating the headline numbers as equivalent evidence.
If it changes modelling or certification work, record who authorises and pays for the consequential work separately from technical acceptance.
Sources
- Victorian Department of Education - Sustainable and Climate Resilient Facilities policy.
- School Infrastructure NSW - EFSG edition applicability.
- EPD Australasia - Technical Clarification TC 01.
- NSW Health - Engineering Services Guideline, section 3.2: contractor alternatives and serviceability/accessibility.
- VHBA - Guidelines for sustainability in capital works: agency scope and control points.
- The four-screen procedure is Makao’s coordination recommendation. It is not a scheme-issued approval process.
- NATSPEC - Specifying for Green Star Buildings using NATSPEC, v1.2, pp. 4 and 15–16.
- Confirm project editions, appointments and acceptance rules before application.
Questions or corrections: contact Makao.
