New LEED Pilot Credits for chemical avoidance

16 03 2011

I can’t begin to tell you how many times I’ve been told:  “I’ve been an interior designer for (insert number of years here) and in all that time, not one person has ever asked for a “green” fabric!” Or the popular variation:  “my clients don’t care about “green”.   The implication, of course, is that I’m barking up the wrong tree in thinking anybody would ever consider “green” as a valid criteria when buying fabric.  Color – check.  Price – check.  Abrasion rating – check.  But “green”?

Well, if you can’t be altruistic about your purchase, then let’s simply look at what your fabric choices are doing to you and your family.  “Green” should really read as “safe”, because conventional fabrics are filled with process chemicals, many of which are outlawed in other products.  Right now the chemicals in your fabrics are contributing to changes that are taking place in your body.  You can’t see those changes, because they are subtle and insidious:  maybe headaches (especially when you draw the drapes at night); maybe sensitization to some new chemicals is giving you a runny nose.  Or maybe a cascading series of changes is taking place in your body and putting a more  dire outcome into play – cancerous tumors, or Parkinsons disease.  And studies are proving that these chemicals affect unborn babies and infants in much more egregious ways.

China exports fabric to the United States that would be outlawed in China – or in Japan or the European Union [1] – because of the chemicals contained in that fabric.  Americans don’t have a safety net protecting them from these chemical incursions.   The Centers for Disease Control and Prevention have found toxic chemicals in the bodies of virtually all Americans:  the most recent report on Americans exposure to environmental chemicals, July 2010 [2], listed 212 chemicals in people’s blood or urine – 75 of which have never before been been measured.   Some of these are linked to increases in prostate and breast cancers, diabetes, heart disease, lowered sperm counts, early puberty and other diseases and disorders – but the really scary thing is that we have no idea what most of the chemicals are doing to us because they’ve never been tested.

In the interest of fairness and letting you make up your own mind, I have seen some articles which refer to this concern about the many industrial chemicals which are seeping into our bodies as “chemophobia”.  “They” say that this so called “chemophobia” is both wrong and counterproductive (see http://www.american.com/archive/2010/february/our-chemophobia-conundrum/) but I think their arguments are the same old saw: “the amount of what is considered toxic is found in such minute quantities that it’s not doing anybody any harm”.   I challenge you to check the rates of increase of certain health issues – even the development of new ones, such as multiple chemical sensitivity (MCS) – and feel confident that we are entirely safe.   Or better yet,  take a look at what happened in Toms River, N.J. where the Ciba Geigy corporation dumped over 4,500 drums of contaminated waste into one farm (now a Superfund site) and, beginning in 1952, dumped effluent directly into the Toms River.  The children of Toms River developed statistically higher averages for cancers – particularly female children – than the rest of the nation.  The Dover Township landfill was declared a public health hazard.  But do the research yourself and see where you stand on the divide.  And if you’re REALLY interested, check out The Body Toxic: An Environmental Memoir by Susanne Antonetta, who happened to grow up in this area (read a review here.)

But before I go entirely off subject onto a diatribe about our toxic ignorance, what I really want to write about are the new LEED pilot credits which reward precautionary action for chemical avoidance:

  • Pilot Credit 2 tries to reduce the use (and hence release) of persistent bioacumulative toxic chemicals, including the use of PVC, Neoprene, and all brominated or halogenated flame retardants, such as PBDEs.
  • Pilot Credit 11 tries to reduce the quantity of indoor contaminants that are “harmful to the comfort and well-being of installers and occupants”, including halogenated flame retardants and phthalates.

Bill Walsh, Executive Director of  the Healthy Building Network, wrote a review of these new pilot credits in January 2011.  His article, quoted below, might give some of the people, who don’t consider “green” and “safe” when buying fabric, something to think about:

Last year the USGBC introduced two new Pilot Credits that reward precautionary action, the avoidance of certain classes of chemicals in the face of mounting evidence that they present significant threats to human health.[3] Industry trade groups fought these measures as they fight all chemical regulation, with the argument that restrictions or disincentives against chemical use must be based upon “sound science” that proves the connection between a specific chemical and a specific health problem beyond a shadow of a doubt. But due to a catch-22 in current US law, the EPA must prove potential risk or widespread exposure before it can get the data it needs to determine the extent of hazard, exposure or risk.[4] If we want to make green buildings healthy buildings, merely following the law will lead us in circles.

To fully appreciate the importance of precautionary measures such as the LEED Pilot Credits, consider the failure of the chemical industry’s voluntary effort to provide EPA with information about High Production Volume (HPV) chemicals – chemicals produced or imported into the US at volumes in excess of 1 million pounds per year. In the early 1980s, the National Academy of Sciences’ National Research Council found that 78% of the chemicals in highest-volume commercial use had not had even “minimal” toxicity testing.[5] Thirteen years later, a comprehensive report by the Environmental Defense Fund (EDF) found no significant improvement: “even the most basic toxicity testing results cannot be found in the public record for nearly 75% of the top-volume chemicals in commercial use.”[6]

In 1998, multiple studies by federal government agencies confirmed that the government lacked basic data needed to understand and characterize the potential hazards associated with HPV chemicals.[7] There are roughly 3,000 such chemicals. “Most Americans would assume that basic toxicity testing is available and that all chemicals in commerce today are safe… This is not a prudent assumption,” said one review. [8] An EPA review could find no safety information for more than half of them, and complete data for only 7 percent. Additionally, EDF reported, there are tens of thousands of non-HPV chemicals that remain to be addressed, which likely have even larger data gaps than were found for HPV chemicals.[9]

These findings prompted the EPA to swing into action – voluntary action. The High Production Volume Chemical Challenge of 1998 invited American industries to “sponsor” HPV chemicals and voluntarily provide health and safety data in lieu of regulatory action. More than 2,200 chemicals were eventually “sponsored,” but ten years later, in 2008, the EPA still had no data on more than half of them. Of the data sets it had received from industry, fewer than half were complete, according to EDF, an original sponsor of the program.

On January 5, 2011, the EPA finally took regulatory action. It will require testing of just “19 of the many hundreds of HPV chemicals on the market today for which even the most basic, ‘screening level’ hazard data are not publicly available.”[10]

The Dow Chemical Company calls the program “a tremendous success.”[11] An investigative report by the Milwaukee Journal deemed it “a failure.”[12] Richard Denison, Senior Scientist at EDF and one of the most knowledgeable independent experts on the program calls it “a perfect poster child for what’s wrong” with federal chemical regulations.[13]

Efforts to reform the major US law regulating chemical production, the Toxic Substances Control Act, are underway but are unlikely to make it through the Republican controlled House of Representatives. In the meantime, despite the data gaps, it is possible to make responsible, healthier choices based upon the best available evidence. The new LEED Pilot Credits help you make those choices and remove tons of toxic chemicals from our buildings, our bodies and our environment. Take your first step toward earning these credits with LEEDuser, and easily find products that qualify for the credits using the Pharos online system.

That will protect us at work – but there is still nothing to protect you at home.


[3] The 1998 Wingspread Statement on the Precautionary Principle summarizes the principle this way: “When an activity raises threats of harm to the environment or human health, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically.” The US Green Building Council Guiding Principle #4 states: The USGBC will be guided by the precautionary principle in utilizing technical and scientific data to protect, preserve and restore the health of the global environment, ecosystems.

[4] Richard Denison, Environmental Defense Fund. “A Near Sisyphusian Task; EPA Soldiers On to Require More Testing Under TSCA.” 1/5/11. http://blogs.edf.org/nanotechnology/2011/01/05/a-near- sisyphusian-task-epa-soldiers-on-to-require-more-testing-under-tsca/

[5] Environmental Defense Fund. “Toxic Ignorance: The Continuing Absence of Basic Health Testing for Top-Selling Chemicals in the United States.” 1997, p.11. http://www.edf.org/documents/243_toxicignorance.pdf

[6]Environmental Defense Fund. “Toxic Ignorance: The Continuing Absence of Basic Health Testing for Top-Selling Chemicals in the United States.” 1997, p.11. http://www.edf.org/documents/243_toxicignorance.pdf

[7] Meg Kissinger and Susanne Rust. “EPA fails to collect chemical safety data.” JS Online. 8/4/08. http://www.jsonline.com/news/milwaukee/32597744.html.

[8] Meg Kissinger and Susanne Rust. “EPA fails to collect chemical safety data.” JS Online. 8/4/08. http://www.jsonline.com/news/milwaukee/32597744.html

[9] Environmental Defense Fund. “High Hopes, Low Marks: A Final Report Card on the High Production Volume Chemical Challenge.” p.30. 2007. http://www.edf.org/documents/6653_HighHopesLowMarks.pdf

[10] Denison, op. cit. Note that EPA has initiated another rulemaking targeting another 29 chemicals.

[12] Meg Kissinger and Susanne Rust. “EPA fails to collect chemical safety data.” JS Online. 8/4/08. http://www.jsonline.com/news/milwaukee/32597744.html

[13] Denison, op. cit.


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