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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Do we need a national plastics control law?

20 10 2010

John Wargo wears at least three hats:  he is a professor of environmental policy, risk analysis, and political science at the Yale School of Forestry & Environmental Studies, he chairs the Environmental Studies Major at Yale College, and is an advisor to the U.S. Centers for Disease Control and Prevention.  He published this opinion on plastics in the United States last year – and I couldn’t have said it better myself:

Since 1950, plastics have quickly and quietly entered the lives and bodies of most people and ecosystems on the planet. In the United States alone, more than 100 billion pounds of resins are formed each year into food and beverage packaging, electronics, building products, furnishings, vehicles, toys, and medical devices. In 2007, the average American purchased more than 220 pounds of plastic, creating nearly $400 billion in sales.

It is now impossible to avoid exposure to plastics. They surround and pervade our homes, bodies, foods, and water supplies, from the plastic diapers and polyester pajamas worn by our children as well as our own sheets, clothing and upholstery,  to the cars we drive and the frying pans in which we cook our food.

The ubiquitous nature of plastics is a significant factor in an unexpected side effect of 20th century prosperity — a change in the chemistry of the human body. Today, most individuals carry in their bodies a mixture of metals, pesticides, solvents, fire retardants, waterproofing agents, and by-products of fuel combustion, according to studies of human tissues conducted across the U.S. by the Centers for Disease Control and Prevention. Children often carry higher concentrations than adults, with the amounts also varying according to gender and ethnicity. Many of these substances are recognized by the governments of the United States and the European Union to be carcinogens, neurotoxins, reproductive and developmental toxins, or endocrine disruptors that mimic or block human hormones.

Significantly, these chemicals were once thought to be safe at doses now known to be hazardous; as with other substances, the perception of danger grew as governments tested chemicals more thoroughly. Such is the case with Bisphenol-A (BPA), the primary component of hard and clear polycarbonate plastics, which people are exposed to daily through water bottles, baby bottles, and the linings of canned foods.

Given the proven health threat posed by some plastics, the scatter shot and weak regulation of the plastics industry, and the enormous environmental costs of plastics — the plastics industry accounts for 5 percent of the nation’s consumption of petroleum and natural gas, and more than 1 trillion pounds of plastic wastes now sit in U.S. garbage dumps — the time has come to pass a comprehensive national plastics control law.

One might assume the United States already has such a law. Indeed, Congress adopted the Toxic Substances Control Act (TSCA) in 1976 intending to manage chemicals such as those polymers used to form plastics. Yet TSCA was and is fundamentally flawed for several reasons that have long been obvious. Nearly 80,000 chemicals are now traded in global markets, and Congress exempted nearly 60,000 of them from TSCA testing requirements. Among 20,000 new compounds introduced since the law’s passage, the U.S. Environmental Protection Agency (EPA) has issued permits for all except five, but has required intensive reviews for only 200. This means that nearly all chemicals in commerce have been poorly tested to determine their environmental behavior or effects on human health. The statute’s ineffectiveness has been recognized for decades, yet Congress, the EPA, and manufacturers all share blame for the failure to do anything about it.

In contrast, the European Union in 2007 adopted a new directive known as “REACH” that requires the testing of both older and newly introduced chemicals. Importantly the new regulations create a burden on manufacturers to prove safety; under TSCA the burden rests on EPA to prove danger, and the agency has never taken up the challenge. Unless the U.S. chooses to adopt similar restrictions, U.S. chemical manufacturers will face barriers to their untested exports intended for European markets. Thus the chemical industry itself recognizes the need to harmonize U.S. and EU chemical safety law.

The most promising proposal for reform in the U.S. is the “Kid-Safe Chemical Act,” a bill first introduced in 2008 that would require industry to show that chemicals are safe for children before they are added to consumer products. Such a law is needed because there is little doubt that the growing burden of synthetic chemicals has been accompanied by an increase in the prevalence of many illnesses during the past half-century. These include respiratory diseases (such as childhood asthma), neurological impairments, declining sperm counts, fertility failure, immune dysfunction, breast and prostate cancers, and developmental disorders among the young. Some of these illnesses are now known to be caused or exacerbated by exposure to commercial chemicals and pollutants.

Few people realize how pervasive plastics have become. Most homes constructed since 1985 are wrapped in plastic film such as Tyvek, and many exterior shells are made from polyvinyl chloride (PVC) siding. Some modern buildings receive water and transport wastes via PVC pipes. Wooden floors are coated with polyurethane finishes and polyvinyl chloride tiles.

Foods and beverages are normally packaged in plastic, including milk bottles made from high-density polyethylene. Most families have at least one “non-stick” pan, often made from Teflon, a soft polymer that can scratch and hitchhike on foods to the dinner table. Between 1997 and 2005, annual sales of small bottles of water — those holding less than one liter — increased from 4 billion to nearly 30 billion bottles.

The billions of video games, computers, MP3 players, cameras, and cell phones purchased each year in the United States use a wide variety of plastic resins. And the almost 7.5 million new vehicles sold in the United States each year contain 2.5 billion pounds of plastic components, which have little hope of being recycled, especially if made from polyvinyl chloride or polycarbonate.  The American Plastics Council now estimates that only about 5 percent of all plastics manufactured are recycled; 95 billion pounds are discarded on average yearly.

The chemical contents of plastics have always been a mystery to consumers. Under federal law, ingredients need not be labeled, and most manufacturers are unwilling or unable to disclose these contents or their sources. Indeed, often the only clue consumers have to the chemical identity of the plastics they use is the voluntary resin code designed to identify products that should and should not be recycled — but it offers little usable information.

The true costs of plastics — including the energy required to manufacture them, the environmental contamination caused by their disposal, their health impacts, and the recycling and eventual disposal costs — are not reflected in product prices.  Adding to the environmental toll, most plastic is produced from natural gas and petroleum products, exacerbating global warming.

Plastics and Human Health

The controversy over BPA — the primary component of hard and clear plastics — and its potential role in human hormone disruption provides the most recent example of the need for a national plastics control law.

Normal growth and development among fetuses, infants, children, and adolescents is regulated in the body by a diverse set of hormones that promote or inhibit cell division. More than a thousand chemicals are now suspected of affecting normal human hormonal activity. These include many pharmaceuticals, pesticides, plasticizers, solvents, metals, and flame retardants.

Scientists’ growing interest in hormone disruption coincided with a consensus within the National Academy of Sciences that children are often at greater risk of health effects than adults because of their rapidly growing but immature organ systems, hormone pathways, and metabolic systems. And many forms of human illness associated with abnormal hormonal activity have become more commonplace during the past several decades, including infertility, breast and prostate cancer, and various neurological problems.

BPA illustrates well the endocrine disruption problem. Each year several billion pounds of BPA are produced in the United States. The Centers for Disease Control and Prevention has found, in results consistent with those found in other countries, that 95 percent of human urine samples tested have measurable BPA levels. BPA has also been detected in human serum, breast milk, and maternal and fetal plasma. BPA travels easily across the placenta, and levels in many pregnant women and their fetuses were similar to those found in animal studies to be toxic to the reproductive organs of the animals’ male and female offspring.

Government scientists believe that the primary source of human BPA exposure is foods, especially those that are canned, as BPA-based epoxy resins can migrate from the resins into the foods. In 1997, the FDA found that BPA migrated from polycarbonate water containers — such as the five-gallon water jugs found in offices — into water at room temperature and that concentrations increased over time. Another study reported that boiling water in polycarbonate bottles increased the rate of migration by up to 55-fold, suggesting that it would be wise to avoid filling polycarbonate baby bottles with boiling water to make infant formula from powders.

Scientists have reported BPA detected in nonstick-coated cookware, PVC stretch film used for food packaging, recycled paperboard food boxes, and clothing treated with fire retardants.

Since 1995 numerous scientists have reported that BPA caused health effects in animals that were similar to diseases becoming more prevalent in humans, abnormal penile or urethra development in males, obesity and type 2 diabetes, and immune system disorders. BPA can bind with estrogen receptors in cell membranes following part-per-trillion doses — exposures nearly 1,000 times lower than the EPA’s recommended acceptable limit.

In 2007, the National Institutes of Health convened a panel of 38 scientists to review the state of research on BPA-induced health effects. The panel, selected for its independence from the plastics industry, issued a strong warning about the chemical’s hazards:

“There is chronic, low level exposure of virtually everyone in developed countries to BPA… The wide range of adverse effects of low doses of BPA in laboratory animals exposed both during development and in adulthood is a great cause for concern with regard to the potential for similar adverse effects in humans.”

The American Chemistry Council, which advocates for the plastics industry, has criticized most scientific research that has reported an association between BPA and adverse health effects. The council’s complaints have included claims that sample sizes are too small, that animals are poor models for understanding hazards to humans, that doses administered in animal studies are normally far higher than those experienced by humans, that the mechanism of chemical action is poorly understood, and that health effects among those exposed are not necessarily “adverse.”

Research on plastics, however, now comprises a large and robust literature reporting adverse health effects in laboratory animals and wildlife at even low doses. Claims of associations between BPA and hormonal activity in humans are strengthened by consensus that everyone is routinely exposed and by the rising incidence of many human diseases similar to those induced in animals dosed with the chemical. Two competing narratives — one forwarded by independent scientists and the other promoted by industry representatives — have delayed government action to protect the health of citizens through bans or restrictions.

Action Needed

How has the plastics industry escaped serious regulation by the federal government, especially since other federally regulated sectors that create environmental or health risks such as pharmaceuticals, pesticides, motor vehicles, and tobacco have their own statutes? In the case of plastics, Congress instead has been content with limited federal regulatory responsibility, now fractured among at least four agencies: the EPA, the Food and Drug Administration, the Consumer Product Safety Commission, and the Occupational Safety and Health Administration. None of these agencies has demanded pre-market testing of plastic ingredients, none has required ingredient labeling or warnings on plastic products, and none has limited production, environmental release, or human exposure. As a result, the entire U.S. population continues to be exposed to hormonally active chemicals from plastics without their knowledge or consent.

What should be done? The Kids Safe Chemical Act represents a comprehensive solution that would apply to all commercial chemicals including plastic ingredients. Yet the nation’s chemical companies, with their enormous political power, are not likely to agree to assume the testing costs, nor are they likely to accept a health protective standard. Rather than pass another weak statute, Congress should consider a stronger alternative.

The nation needs a comprehensive plastics control law, just as we have national laws to control firms that produce other risky products, such as pesticides. Key elements of a national plastics policy should include:

  • tough  government regulations that demand pre-market testing and prohibit chemicals that do not quickly degrade into harmless compounds. Exempting previously permitted ingredients from this evaluation makes little sense, as older chemicals have often been proven more dangerous than newer ones.
  • The chemical industry itself needs to replace persistent and hazardous chemicals with those that are proven to be safe.  Plastics ingredients found to pose a significant threat to the environment or human health should be quickly phased out of production. Congress chose this approach to manage pesticide hazards, and it has proven to be reasonably effective since the passage of the Food Quality Protection Act in 1996.
  • Federal redemption fees for products containing plastics should be set at levels tied to chemical persistence, toxicity, and production volume. These fees should be high enough that consumers have a strong incentive to recycle.
  • We need mandatory labeling of plastic ingredients, in order to allow consumers to make responsible choices in the marketplace.
  • Finally, manufacturers should take responsibility for cleaning up environmental contamination from the more than one trillion pounds of plastic wastes they have produced over the past 50 years.