The Solution is Transparency: Public disclosure of product content and hazard is critical to solving material health challenges

Tom Lent and Rebecca Stamm | January 2019 | Newsletter

Manufacturers are sometimes understandably reticent to reveal the “secret sauce” behind their building product formulations. In recent years, however, we have learned that thousands of the substances used in our built environment endanger human and environmental health. Many more substances have yet to be fully evaluated. Only through full public disclosure and assessment of contents and hazards can we identify and solve the problems — in buildings, on worksites, and in communities — created by hazardous substances in building products.

In this article, HBN outlines why the building industry needs to demand full public disclosure of product content and hazard.  

Transparency is critical because it enables rights and responsibilities

  • Right to know – As occupants of buildings, we all are exposed to the chemicals that make up the built environment in which we live, study, work, and play. So too are the workers who build those buildings, and the communities where building products are manufactured. All of us have a right to know what chemicals we are being exposed to and what health hazards may be associated with those chemicals, regardless of where they are used in the supply chain. So also do all of those responsible for the design, construction, and operation of buildings have a right to know, and a responsibility to avoid, known and potential hazards to building occupants, workers, and fenceline communities.  
  • Liability – Cases involving lead and asbestos have shown that building owners can become liable for remediating hazards from materials which were legally installed but later deemed to be too hazardous to leave in place. Owners need disclosure of contents and hazards from manufacturers in order to be able to avoid future liabilities.    

  • Right to decide – Through their market choices, occupants, and those responsible for the design, construction, and operation of buildings, have the right to decide what chemicals and what health hazards they want to avoid. A fundamental principle of free market economics is the importance of access to complete information about transactions.

Transparency is critical because it powers public health research

  • Need to prioritize target chemicals to avoid – Health impacts can be additive or synergistic.1 Assessors cannot accurately describe exposure and risk on the basis of an individual chemical or product. Only with information about multiple products across multiple product categories, can the industry begin to understand which chemicals of concern are most prevalent and have the most exposure and hence warrant prioritization for avoidance.

  • Need to identify priorities for toxicology research – Identifying all health effects of all chemicals in commerce will take centuries of research. Similar to the work of prioritizing target chemicals to avoid, researchers need to be able to inventory all the chemicals in products to which people are exposed, so they can use this information to prioritize health research.

  • Need to understand epidemiology – Public health scientists can’t study how building products contribute to environmental toxic loads without knowing the content of building products. Scientists can’t link biomonitoring results to people’s exposure to products and can’t even know what chemicals to look for in environmental and biomonitoring sampling without knowing the contents of products.

Transparency is critical because it drives both innovation and industrial transformation

  • A circular economy requires knowledge of feedstock contents – Product manufacturers can’t implement effective closed-loop recycling without knowledge of material contents. Lacking information, manufacturers are playing a guessing game and are liable to introduce contaminants into their products that can interfere with the recycling process or ruin performance of the product.

  • Open innovation requires multiple-industry cross-fertilization – The most innovative solutions to a functional problem often come from outside of the industry seeking it. Avoiding the toxicity problems of the known solutions in an industry may require looking at how related challenges are solved in other industries. This requires an open exchange of information about the chemical contents of products and the functions of those chemicals.

  • Green chemistry requires multiple industry opportunities – Often the use of a single chemical by a single manufacturer or even by a product sector is too small of a market to stimulate investment in R&D for safer alternatives. Green chemistry innovators need to be able to identify multiple opportunities to understand the market scale to warrant investing in research.

Transparency is critical because it accelerates change

  • Standards are inherently limited and slow – Because of the consensus processes by which they are developed, certification programs are slow to respond to changes in science and in the market. Users should have the option of acting nimbly on emerging knowledge ahead of certifications but cannot do that if manufacturers and certification programs keep the contents of building products a secret.
  • Disclosure creates an incentive for precautionary action – Manufacturers are more likely to act on precaution when they need to disclose contents and hazards to their marketplace instead of just to a trusted assessor.

Transparency will happen when customers demand it

The act of asking for transparency is a radically important one. What can you do?

Step 1. Ask for and prefer products that have a public Health Product Declaration (HPD). HPD is the industry’s collaborative, user-designed, open standard for disclosing product contents and associated health hazards. Do this even if you use other tools such as product certifications and/or “red lists” to evaluate products. The data provided by HPDs improves all of these tools, and manufacturers have greater incentive to participate in this voluntary system when more of their customers ask for the information. You can check whether or not a product has an HPD in the HPD Public Repository.

Step 2. Use HPDs as part of your product evaluation process by preferring products with public HPDs that have all contents characterized, screened, and identified to 100 ppm (parts per million). Prefer those products whose public content disclosure has been verified by a third party. This information can be found on the first page of an HPD.

Step 3. If you have a materials specialist on staff, they can use the detailed information provided by HPDs to screen and compare specific contents and hazards as part of your evaluation process.

You can learn how to Practice Transparency Now, and get your first free CEU credits for 2019, with this helpful online training offered by the Health Product Declaration Collaborative.

Footnotes

1] Additive impacts means that when a person is exposed to multiple chemicals, the resulting health impacts are equal to the sum of the effect of each chemical alone. Synergistic means that when a person is exposed to multiple chemicals, the resulting health impacts are greater than the sum of the individual chemicals’ expected impacts.