LEED and human health

16 03 2012

Does living or working in a LEED certified space mean that you are safe from building contaminants – or does it promote a false sense of security?

A study published by the nonprofit,  Environment and Human Health, Inc. (EHHI),  in May 2010, emphatically claims that you are not safe.  The lead author of the study,  Dr. John Wargo, is professor of environmental policy, risk analysis and political science at the Yale School of Forestry & Environmental Studies.  He is also an advisor to the U.S. Centers for Disease Control and Prevention.  This  study outlined why  LEED, which has emerged as the green standard of approval for new buildings in the United States,  largely ignores factors relating to human health, particularly the use of potentially toxic building materials.   As Nancy Alderman, the president of EHHI, told BuildingGreen.com, “it is possible to build a LEED building and have it not be healthy inside, and we’re saying this needs to be fixed.”[1]

Many of the chemical ingredients in building materials are well known to be hazardous to human health. Some are respiratory stressors, neurotoxins, hormone mimics, carcinogens, reproductive hazards, or developmental toxins. Thousands of synthetic and natural chemicals make up modern buildings, and many materials and products “off-gas” and can be inhaled by occupants.   Dr. Wargo points out in a blog posting on Environment 360, that one of LEED’s major accomplishments — saving energy by making buildings more airtight — has had the paradoxical effect of more effectively trapping the gases emitted by these often toxic chemicals used in today’s building materials and furnishings.  

He makes the case that LEED puts almost no weight on human health factors in deciding whether a building meets its environmental and social goals.  And he calls for a comprehensive Federal law to control the chemical content of the built environment.

Many sectors of the economy, including pharmaceuticals and pesticides, are highly regulated by the federal government to protect public health. But the building sector — which now produces $1.25 trillion in annual revenues, roughly 9 percent of U.S. gross domestic product in 2009 — has escaped such federal control. The lack of government regulation is explained, in part, by the building industry’s enormous financial power, but also by its recent success in creating green building and development standards that give the impression of environmental responsibility and protection of human health.

John Wargo called for a new national healthy building  policy, which would  include:

  • New chemicals tested to understand their threat to human health before they are allowed to be sold.  We should adopt the precautionary principle, as in the EU. Existing chemicals should also be  tested, rather than be exempted, as they are currently under the Toxic Substances Control Act.
  • The burden of proof of safety should rest with chemical and building product manufacturers.  The testing itself should be conducted by an independent, government-supervised institute, but paid for by the manufacturers.
  • A clear environmental safety standard should also be adopted to prevent further development and sale of persistent and bio-accumulating compounds.
  • The chemical contents of building materials and their country of origin should be identified.
  • EPA should maintain a national registry of the chemical content of building products, furnishings, and cleaning products.
  • The government should categorize building products to identify those that contain hazardous compounds; those that have been tested and found to be safe; and those that have been insufficiently tested making a determination of hazard or safety impossible. This database should be freely available on the Internet.
  • Distinctive “high performance” environmental health standards should be adopted to guide the construction and renovation of schools and surrounding lands.
  • The federal government should create incentives for companies to research and create new chemicals that meet the health, safety, and environmental standards described above. Funding for “green chemistry” initiatives should be significantly increased and focused on benign substitutes for the most widely used and well-recognized toxic substances.
  • The federal government should take responsibility for codifying these requirements to protect human health in buildings and communities.

The U.S. Green Building Council (USGBC) developed LEED parameters through a “consensus based” process led by LEED committees, and introduced the LEED rating system in 2000.  The USGBC does extraordinary and essential work – and as Howard Williams suggests in a comment on Environment 360, “wanting to add healthy building products onto that effective and successful machine is natural; we always ask more of the high achievers”.  He goes on to suggest that “a clear and supportive endorsement from the USGBC of the need to protect people from the effect of hazardous chemicals in building materials would set in motion the free market forces for accelerating change. Although this is implicitly evident by the very nature of the USGBC work, some things just need to be explicit.”[2]

However, at the time of the publication of the study in 2010, the U.S. Green Building Council (USGBC)  took exception with the conclusions that were drawn.    Brendan Owens, P.E., vice president for LEED technical development at USGBC, criticized the report for “singling out the Indoor Environmental Quality section as the only place that LEED deals with public health.” Arguing that all LEED credits are built and evaluated for multiple environmental and health benefits, Owens said, “the report’s authors would have benefited from a better understanding of the philosophy that underpins the rating system.”

There is an ongoing and emotional debate about LEED, in which it has been criticized by other environmental groups such as the Healthy Building Network, for lacking leadership in addressing chemical hazards. Indeed, the Living Building Challenge may have been introduced as a result of LEED moving too slowly in many areas.

On the one side, the argument is that LEED is an action plan for environmental work through buildings and neighborhoods. It is not a report or even a statement of a perfect world. It is a way to define what green means. LEED, according to these proponents,  is constantly updating and moving the market, pushing it and incentivizing it to be better. And they say that LEED’s explicit purpose has never been human health.  It has always been about minimizing resource use and carbon footprint.   To announce that it “fails” to account for human health is like making the exposé that ballet is not satisfying the tastes of hip hop dancers.

On the other hand, there are those who say that though LEED should be applauded for the things it does well (new energy efficiency standards, building siting standards, water conservation for example), it should also define a “green” building, and this definition should include minimizing the use of known carcinogens, suspected endocrine disruptors, and other harmful chemicals.   It should do this because it is not just the health of the building’s inhabitants that is at stake. Throughout their life from cradle to grave, chemicals of concern in building products effect people, plants and animals–the whole environment.

Bill Walsh, executive director of the Healthy Building Network, told BuildingGreen.com that in his experience, the tone of the report represents a typical response to LEED from people in the human health community.  For example, the Green Guide for Healthcare asks that we “Imagine: Cancer treatment centers built without materials linked to cancer; Pediatric clinics free of chemicals that trigger asthma.” [3] “Their first encounter with LEED is usually highly negative—they react just like this,” he said. “People just can’t believe that you get credit for using all manner of vile material in a green building. So no, they’re not really stepping back to assess the whole thing.”   Walsh added that he hoped USGBC would use the report as an opportunity to build a broader constituency for developing its materials credits.

A pivotal issue is that there needs to be regulatory standards for the toxicity of building materials, because there cannot be a truly “green” building which compromises people’s health.  A comment posted on the Environment 360 web site suggests a new twist: Perhaps  LEED could have DEMERITS as well as credits.  This is based on the commentor’s knowledge of a LEED project in which the project removed toxic soil from a site and sent it to a landfill in someone else’s backyard. He asks the question:   “Can a LEED gold project actually send toxic soil that could be stored onsite to a location in another state? That doesn’t seem like a fully credible environmental leadership to me.” [4]

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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.