Tom Lent | September 09, 2011
The USGBC is seeking comment by next Wednesday, September 14, on an important new LEED credit that has been proposed "to increase the use of products and materials that disclose chemical ingredient data and reduce the concentrations of chemical contaminants that can damage air quality, human health, productivity, and the environment." The new credit, entitled "Avoidance of Chemicals of Concern in Building Materials," would reward building projects with one point toward LEED certification if 20% of all building products and materials, by cost, have a publicly available list of ingredients and do not include California Proposition 65 chemicals in their contents.
For anyone who has struggled to find out from a manufacturer what is in their product, the prospect of LEED weighing in to encourage disclosure should be very welcome. This proposed credit creates a valuable new framework for addressing health impacts from building materials. It is built upon transparency and amenable to continuous improvement as more data become available and quantification methodologies improve.
This is particularly important since as currently drafted, the proposed credit is just a first step, albeit a very important one, to understanding and reducing the true health impacts of materials. It only addresses health impacts of product contents in use, and does not yet account for the substantial health impacts of chemicals used or generated in manufacturing and end-of-life. For example, dioxin generated in the production and disposal of PVC will not be accounted for in this credit. Full disclosure of product ingredients, however, is an important step toward a full assessment of health impacts throughout the life cycle and for that reason this framework deserves vigorous support.
The proposed credit, however, requires unambiguous definitions in order to avoid becoming another Trojan Horse for greenwash. Most importantly, it must spell out exactly what is required to be disclosed in the list of product ingredients. Otherwise intentional omission of small percentages of highly toxic ingredients will mislead the public. Halogenated flame retardants, formaldehyde and perfluorinated compounds may migrate out of products and create health hazards when they constitute far less than one percent of the product content. We strongly suggest the definition used by the US EPA for participation in their Design for the Environment (DFE) program requiring disclosure of all intentionally added ingredients, regardless of percentage, and all residuals* present at greater than 100 parts per million (ppm), equal to 0.01%. Numerous manufacturers currently disclose their ingredients at this level in order to participate in the DFE program. McDonough Braungart’s Cradle to Cradle certification and the Business and Institutional Furniture Manufacturers Association (BIFMA) certification programs also have established 100 ppm standards.
It is also important that the credit target disclosure and avoidance of chemicals of concern in the interior finishes of a project where the pathways for human exposure are most direct. The current draft language requiring that "20% of all building products and materials" meet the criteria could inadvertently create a huge loophole through which a project could meet the requirement with disclosure of a single set of bulk structural elements like cement or steel without ever addressing the materials to which occupants are most exposed.
Getting the right red list, rewarding verification of content and providing sufficient points to encourage improvement are other important issues that also deserve attention to ensure that the USGBC's proposed Chemicals of Concern credit truly helps us achieve real disclosure and safer products.
Please take some time to read and join in the discussions in LEEDuser by next Wednesday, September 14, and let the USGBC know that you support both the intent of the credit and improvements to this proposal that will ensure it meets its stated objectives.
This is one of several new material selection credits in LEED 2012 aimed at improving how manufacturers assess, disclose and formulate the products with which we build. Read our blog entry on LEED 2012 for more on the critical issues around this Chemicals of Concern credit as well as LCA, forestry practices and indoor air quality issues that are at stake in this draft. Your perspective is important to support and reshape this important tool to be effective and avoid greenwash.
* Residuals include unintended byproducts and carry overs of the manufacturing process, such as catalysts or monomers and contaminants from raw materials.