Last week the US Green Building Council (USGBC) and the American Chemistry Council (ACC) issued a joint press release announcing an unspecified “new initiative designed to ensure the use of sustainable and environmentally protective products in buildings by applying technical and science-based approaches to the LEED green building program.”
In an interview with Environmental Building News, a USGBC spokesperson identified a “supply chain optimization working group” as the heart of the new program. The supply chain optimization working group is not a new initiative, however. It was announced previously in Spring 2013 in a published call for working group members, and has been under discussion since the USGBC’s last minute insertion of the “supply chain optimization” credit pathway in LEED v.4 at the behest of the chemical industry. The working group never achieved liftoff, it appears, because the ACC left the table to wage its war on LEED.
According to Environmental Building News, what is new is that the ACC has returned with the prediction that “risk assessment” will now receive “greater consideration throughout USGBC’s process.” If so, the result will be unequivocally negative for LEED, which currently favors “hazard-based” approaches to reducing unhealthy chemicals in the built environment.
To understand what will be lost if the ACC risk-assessment paradigm is embedded in LEED, one does not need to become expert on the finer distinctions between risk-based and hazard-based approaches. Just consider formaldehyde.
LEED’s most transformative material credit to date used a hazard-based approach to encourage the use of no added formaldehyde products. This credit incentivized green chemistry research, spurred the creation of new businesses, and gave established manufacturers a means to differentiate their products from overseas competition. Most importantly, it is driving dramatically reduced formaldehyde emissions across the board: for building occupants, construction workers, manufacturing workers and the communities where engineered wood products are made.
Graph by J. Vallette / Healthy Building Network. MDF/particleboard production and formaldehyde emission rates indexed to the year 2005.
In 1992 the State of California conducted an extensive analysis to reach the conclusion that there is no safe level for formaldehyde to preclude cancer. Just last month the National Research Council affirmed the recent finding of the National Institutes of Health National Toxicology Program that formaldehyde is a “known human carcinogen.” The ACC responded with an Orwellian press release asserting: “The scientific literature is clear that there is no increased health risk from low-level exposures normally found in home or work environments” [emphasis added] If the ACC’s risk-based standard had been in effect, the LEED formaldehyde credits never would have seen the light of day.
The risk-based approach being advocated by the ACC is the foundation of the Toxic Substances Control Act (TSCA), the failed federal law which, in its almost 40 years of existence, has resulted in restrictions on only five (5) of the more than 80,000 chemicals used in commerce. Is this the kind of result we want to see from “greater consideration” of risk-assessment in LEED?
By contrast, the hazard-based approach adopted in the LEED v.4 Materials Disclosure and Optimization credit is the foundation of the most successful healthy materials initiatives: from the Living Building Challenge, to the Perkins+Will precautionary list, to Google’s healthy materials program. It is the approach taken by health care industry leader Kaiser Permanente in deciding to purchase products that do not contain chemical antimicrobials or flame retardants. It is the approach taken by Walmart and other big box retailers who are requiring that suppliers remove certain hazardous chemicals from consumer products. The Health Product Declaration (HPD) takes a hazard-based approach, as does the Pharos Project, GreenScreen, Declare and Cradle to Cradle.
The joint USGBC/ACC announcement has been widely portrayed as a “truce.” Perhaps it is so intended. Our perspective is that it costs the ACC nothing to cease fire this fall when few bills – especially anti-green bills – are likely to advance during election season. The costs to the green building movement will be high if this initiative results in surrender to the risk-based paradigm that fails to protect human health, and undermines the growing use of successful hazard-based approaches to healthy building.