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]





SMART Sustainable Standards

17 08 2011

The SMART Sustainable Product Standards  is a group of standards, applicable to building materials, apparel, textiles and flooring. These products constitute 60% of the world’s products, according to the SMART website .  The SMART standards for these products are, again according to their website, “based on transparency, using consensus based metrics and life-cycle analysis.”  The term “consensus based metrics”  means that the standards they use have been pre-established, and are widely available, thereby “eliminating both redundancies and potential inconsistencies”.  Some of these include:

SMART contends that, by using these widely accepted standards, SMART  standards become transparent, i.e.,  nothing is hidden in their requirements or in their decision making.   They further contend that  their rules  prevent industry trade association dominance, allowing the SMART standard to move substantially beyond the status quo.

The SMART Standard confers multiple achievement levels – depending on the number of points a product accrues in the rating system, it can be certified either:

  • Sustainable
  • Silver
  • Gold
  • Platinum

This all sounds lovely, but in sieving through the SMART website, I found it extremely confusing.     It also seems to me the web site is designed for large companies with deep pockets – the first question in their INFO/FAQ tab on the website answers the question:  “Why are sustainable products more profitable than conventional products?”  The answer:

  1. The public prefers sustainable products and will pay somewhat more for them
  2. coupled with the assertion that  sustainable products have “cheaper raw materials”  (I can certainly dispute that in the field of natural fibers – organic cotton simply costs more to produce, sometimes considerably more, than conventional cotton), “less liability” and “fewer regulatory constraints”.

Also, becoming SMART certified is very expensive:  For all levels except Platinum, it costs $7500 for certification; Platinum is $10,000.   Maybe that’s why the web site for the SMART Sustainable Textile  lists only 10 products from three companies as being SMaRT certified.  (see http://mts.sustainableproducts.com/SMaRT_Certified.html )

Finally, the fact that the SMART standards are based on widely available, public standards, such as the Stockholm Toxic Chemicals List, means that the SMART standard is not trying to push any envelopes.  For example, the Stockholm Toxic Chemicals List (actually titled the Stockholm Convention on Persistent Organic Pollutants) originally banned or restricted twelve chemicals because they accumulate in the tissues of living things and are all but indestructible once they’re released into the natural world.  They can spread across the globe with weather patterns and migrating animals.  They have all been linked to a range of health issues, including cancer and reproductive and developmental problems.  In 2010, nine more chemicals were added to the list, making a total of 21.  But today there are 80,000 chemicals in use by industry, most of which have not ever been tested, so we really don’t even know the extent of our exposure to toxins.  So it’s terrific that  SMART incorporates the Stockholm Convention list, but aren’t those chemicals banned by the Stockholm Convention already?   Also, why stop with just the Stockholm Convention list?  Toxic pollution is a problem without national boundaries.  Chemicals are an issue for international negotiation and have been so for decades.  To date, more than 50 regional and international agreements on chemicals and waste management have been adopted by governments.





GreenGuard certification

10 08 2011

GreenGuard was launched in 2000 by Atlanta-based for-profit Air Quality Sciences (AQS), which is now a separate not-for-profit organization. Although GreenGuard was not designed specifically for fabrics, it is often advertised that a fabric is GreenGuard certified, because GreenGuard certified products can automatically meet the requirements of LEED 2009 CI Credit 4.5 and BIFMA X7.1.

GreenGuard has developed proprietary indoor air-quality pollutant guidelines based on standards developed by the government and by industrial bodies.  Maximum allowable emission levels in air concentrations, according to their website,  are based on those required by the state of Washington‘s indoor air quality program for new construction, the U. S. EPA’s procurements specifications, the recommendations from the World Health Organization, Germany’s Blue Angel Program,  LEED for New Construction (LEED-NC) and LEED for Commercial Interiors (LEED-CI).

GreenGuard  has introduced a special certification, called GreenGuard Children and Schools,  which is intended to be applied to products which are used in schools, daycares, healthcare facilities, and places where sensitive adults may reside or work.  This certification is necessary because, as they say on their website, “children are more sensitive to environmental exposures than adults. Their bodies are still developing including their brains. They breathe faster than adults and in return receive a higher dose of indoor pollution per body weight. To account for inhalation exposure to young children, a body burden correction factor has been applied to the current GREENGUARD Indoor Air Quality Certified® allowable levels.”

Those products that pay the testing fee and pass muster earn the right to call themselves GreenGuard certified.  The GreenGuard Product Guide has become a purchasing tool for thousands of specifiers as they depend on it to preselect environmentally preferable products.

In order to become certified, all products are tested in dynamic environmental chambers following test methods as posted on the GreenGuard Environmental Institute (GEI)  web site.   The tests are designed to measure emitting chemicals coming from a product; that means it tests only for evaporating chemicals –  chemicals which are a gas at room temperature.  Specifically, for the GreenGuard certification, emission criteria are established for total Volatile Organic Compounds (TVOC), formaldehyde, total aldehydes, all individual chemicals with currently published Threshold Limit Values (TLVs), respirable particles and certain odorants and irritants.  The requirements for Children and Schools is more stringent and includes limits on emissions for total phthalates,  consisting of dibutyl (DBP), diethylhexyl (DEHP), diethyl (DEP), dimethyl (DMP), butylbenzyl (BBP) and dioctyl (DOP) phthalates, because, again according to the GreenGuard website, “Results from recent research indicate that inhalation is an important route of exposure to phthalates and that these chemicals have been associated with endocrine disorders, reproductive and developmental disorders, asthma and allergies.”

GreenGuard, by measuring only emitting chemicals, is significant for what it does not measure:

  • It does not measure any of the heavy metals (lead, mercury, copper, etc.), such as those used in fabric dyestuffs, because they are not emitted at standard indoor air conditions;
  • It does not measure PVC,  which is a polymer and therefore not volatile (however, some PVC based product types have a special formulation which enables them to meet GreenGuard standards);
  • It does not measure phthalates  except in the Children and Schools certification; phthalates are semi volatile, and don’t begin to evaporate until approximately 7 days after exposure to the air.
  • It does not evaluate the manufacture of a product, nor any byproducts created during production or disposal
  • It does not evaluate any social justice issues
  • It does not evaluate carbon footprint issues

Nobody can debate that we need to rid the indoor environment from irritating contaminants that can have serious effects on people’s health, productivity and quality of life.  Since

Americans spend 90 percent of their time indoors, and indoor air can be as much as 100 times more polluted than outdoor air, this issue must be taken seriously by designers.  It is incumbent on them to specify products (including fabrics) that are low-emitters of formaldehyde and all the other volatile organic compounds that contribute to poor indoor air.  But it is also true that air quality is not the only contributor to poor health, productivity and quality of life of the occupants of indoor spaces – after all, our skin is the largest organ in our bodies, and it’s quite permeable.  So designers should not take this certification as assurance that a product is the best environmental choice – not only does it bypass those chemicals that do not evaporate, it does not look at the production of the fabric, any social justice issues, nor does it look at carbon footprint.  Indeed, a product containing PVC, one of the most toxic substances known – highly toxic in all its phases: manufacture, use, and disposal – can be  GreenGuard certified.

According to GreenGuard itself, as is published on their web site:  GreenGuard is a product emissions performance-based standard, and as such, the complete toxicity effects of the chemical emissions from the products tested are beyond its scope.

So what are the take aways?  Remember that GreenGuard tests for emitting chemicals only, and they do that very well.   But it should not be used as a tool to evaluate a product’s environmental impact and safety.