Listmania: LBC Red List and others

19 06 2012

I love lists – you know, all those “best of” lists – movies, books, toxic chemicals.

Having a list makes it easy for us to tick off those bad chemicals that nobody wants to live with.  And in the building industry there have been a proliferation of lists which identify chemicals of concern:  the Perkins & Will Precautionary List, the LEED Pilot 11 and the Living Building Challenge Red List, among others.  And make no mistake, we think it’s critical that we begin to develop these lists, because we all need a baseline.   As long as we need to eat and breathe, toxics should be an important consideration.  We just have a problem with  how these lists are used.

So let me explain.

First, lists for the most part are developed on the basis of science that usually occurred five or 10 years ago, so they can  (though not always) be lagging indicators of safety to humans and the environment.  (But that’s a minor point, just wanted us to remember to maintain those lists.)

When using lists, it’s important to remember the concept of reactive chemistry:  many of the chemicals, though possibly deemed to be benign themselves, will react with other chemicals to create a third substance which is toxic.   This reaction can occur during the production of inputs, during the manufacture of the final product, or at the end of life (burning at the landfill, decomposing or biodegrading).   So isn’t it important to know the manufacturing supply chain and the composition of all the products – even those which do not contain any chemicals of concern on the list you’re using – to make sure there are no, say … dioxins created during the burning of the product at the landfill, for example?

It’s also important to remember that  chemicals are synergistic  – toxins can make each other more toxic.  A small dose of mercury that kills 1 in 100 rats and a dose of aluminum that will kill 1 in 100 rats, when combined, have a striking effect: all the rats die.  So if the product you’re evaluating is to be used in a way that introduces a chemical which might react with those in your product, shouldn’t that be taken into consideration?

So, O.K., the two problems above would be extremely difficult to define  – I mean, wouldn’t you need a degree in chemistry, not to mention the time and money, to determine if these could occur .  The average consumer wouldn’t have a clue.  Just wanted you to know that these problems do exist and contribute to our precautionary admonition regarding lists.

Each list has a slightly different interpretation – and lists different chemicals.  The Healthy Building Network published this Venn diagram of several of the most prevalent lists used in building materials:

The real reason we don’t like the way lists are used is that people see the list, are convinced by a manufacturer that their product doesn’t contain any of the chemicals listed, so without any further ado the product is used.

What does that mean in the textile industry, for example?

By attempting to address all product types, most lists do not mention many of the toxic chemicals which ARE used in textile processing. In the Living Building Challenge Red List, no mention is made of polyester, the most popular fiber for interiors, which itself is made from two toxic ingredients (ethylene glycol and terephthalic acid – both carcinogens, neither of which are on the list).  That means  a fabric made of polyester – even recycled polyester – that has been processed using some pretty nasty chemicals – could be specified.   Chemicals which are commonly used in textile processing  and which are NOT included on the Living Building Challenge Red List, for example,  but which have been found to be harmful , include:

Chlorine   (sodium hypochlorite NaOCL); registered in the Toxic Substances Control Act   as hypochlorous acid ; sodium chlorite
Sodium cyanide;   potassium cyanide
sodium sulfate   (Na2SO4)
Sodium sulfide
 APEOs ( Alkylphenolethoxylates)
Chromium III   and VI (hexavalent chromium)
pentachlorophenol   (PCP)
Dichloromethane   (DCM, methylene chloride)
Tetrachloroethylene   (also known as perchloroethylene, perc and PCE)
Methyl ethyl   ketone
Toluene:   toluene diisocyanate and other aromatic amines
Methanol (wood   alcohol)
Chloroform;   methyl chloroform
Phosphates   (concentrated phosphoric acid)
Dioxin –   by-product of chlorine bleaching; also formed during synthesis of certain   textile chemicals
Benzenes and   benzidines; nitrobenzene; C3 alkyl benzenes; C4 alkyl benzenes
Sulfuric Acid
Optical   brighteners: includes several hundred substances, including triazinyl   flavonates; distyrylbiphenyl sulfonate
ethylenediaminetetra   acetic acid [EDTA]
diethylenetriaminepenta   acetic acid [DTPA]
Perfluorooctane   sulfonates (PFOS)

In the case of arsenic (used in textile printing and in pesticides) and pentachlorophenol (used as a biocide in textile processing) – the Living Building Challenge Red List expressly forbids use in wood treatments only, so using it in a textile would qualify as O.K.

Perhaps we should manufacture with a “green list” in mind: substituting chemicals and materials that are inherently safer, ideally with a long history of use (so as to not introduce completely new hazards)?

But using any list of chemicals of concern ignores what we consider to be the most important aspect needing amelioration in textile processing – that of water treatment.  Because the chemicals used by the textile industry include many that are persistent and/or bioaccumulative which can interfere with hormone systems in people and animals and may be carcinogenic and reprotoxic, and because the industry often ignores water treatment even when it is required (chasing the lowest cost) the cost of dumping untreated effluent into our water is incalculable.

The textile industry uses a LOT of water – according to the World Bank, 20% of industrial freshwater pollution is from the textile industry; that’s another way of saying that it’s the #1 industrial polluter of water on the planet.  In India alone textile effluent averages around 425,000,000 gallons per day, largely untreated[1].   The chemically infused effluent – saturated with dyes, de-foamers, detergents, bleaches, optical brighteners, equalizers and many other chemicals –  is often released into the local river, where it enters the groundwater, drinking water, the habitat of flora and fauna, and our food chain.  The production of polychlorinated biphenyls (PCBs) were banned in USA more than 30 years ago (maybe that’s why they’re not listed on any of these lists?), but are still showing up in the environment as unintended byproducts of  the chlorination of wastes in sewage disposal plants that have a large input of biphenyls (used as a dye carrier) from textile effluent.[2]

Please click HERE to see the PDF by Greenpeace on their new campaign on textile effluent entitled  “Dirty Laundry”, which points the finger at compliant corporations which basically support what they call the “broken system”.  It asks corporations to become champions for a post toxic world, by putting in place policies to eliminate the use and release of all hazardous chemicals across a textile company’s entire supply chain based on a precautionary approach to chemicals management, to include the whole product lifecycle and releases from all pathways.

Another problem in the textile industry which is often overlooked is that of end of life disposal.  Textile waste in the UK, as reported by The Ecologist, has risen from 7% of all waste sent to landfills to 30% in 2010.[3]  The US EPA estimates that textile waste account for 5% of all landfill waste in the U.S.[4]  And that waste slowly seeps chemicals into our groundwater, producing environmental burdens for future generations.  Textile sludge is often composted, but if untreated,  that compost is toxic for plants.[5]

What about burning:    In the United States, over 40 million pounds of still bottom sludge from the production of ethylene glycol (one of the components of PET fibers) is generated each year. When incinerated, the sludge produces 800,000 lbs of fly ash containing antimony, arsenic and other metals.[6]

These considerations are often neglected in looking at environmental pollution by textile mills[7] – but is never a consideration on a list of chemicals of concern.

So yes, let’s recognize that there are chemicals which need to be identified as being bad, but let’s also look at each product and make some kind of attempt to address any other areas of concern which the manufacture of that product might raise.  Using a list doesn’t get us off the hook.

[1] CSE study on pollution of Bandi river by textile industries in Pali town, Centre for Science and Environment,New Delhi, May 2006 and “Socio-Economic, Environmental and Clean Technology Aspects of Textile Industries in Tiruppur,South India”, Prakash Nelliyat, Madras School of Economics.  See also:

Jacks Gunnar et al (1995), “The Environmental Cost of T-Shirts”, Sharing Common Water Resources, First Policy Advisory Committee Meeting, SIDA, Madras Institute of Development Studies, Chennai.

Also:  CSE: Down to Earth Supplement on Water use inIndia, “To use or to misuse”;

[3] Ecologist, “’Primark effect’ sill clogging up UK landfills”, January 19, 2010,

[5] Scientia Agricola, vol. 62, no 3 May/June 2005

[6] Sustainable Textile Development at Victor,

[7] Assuming a beginning value of 375ppm of antimony in an undyed polyester fiber, as much as 175ppm of antimony can be leached from the fiber during the dyeing process. This seemingly insignificant amount translates into a burden on water treatment facilities and is still a hazardous waste when precipitated out during treatment. The U.S. EPA lists the allowable limit for antimony in drinking water to be 6 parts per billion (ppb). Countries that can afford technologies that precipitate the metals out of the water are left with a hazardous sludge that must then be disposed of in a properly managed landfill or incinerator operations. Countries who cannot, or who are unwilling to employ these end-of-pipe treatments, release antimony along with a host of other dangerous substances to open waters. Victor Defining Sustainability,


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 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. 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.

[6]Environmental Defense Fund. “Toxic Ignorance: The Continuing Absence of Basic Health Testing for Top-Selling Chemicals in the United States.” 1997, p.11.

[7] Meg Kissinger and Susanne Rust. “EPA fails to collect chemical safety data.” JS Online. 8/4/08.

[8] Meg Kissinger and Susanne Rust. “EPA fails to collect chemical safety data.” JS Online. 8/4/08.

[9] Environmental Defense Fund. “High Hopes, Low Marks: A Final Report Card on the High Production Volume Chemical Challenge.” p.30. 2007.

[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.

[13] Denison, op. cit.