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Chemicals of Concern: Cut through the Controversy
The debate over safe building materials shows no signs of stopping as LEED v4 draws closer to its official release. It’s clear that the certification system will include credits for optimizing building material ingredients and the supply chain in some form, but what does that optimization actually mean?
Not surprisingly, the answer isn’t black or white. In fact, it’s more gray than green. That’s why a smart manager weighs the evidence to make optimal material choices, minimize potentially harmful chemicals, and ensure top building performance.
But what’s an FM to do when even that evidence is a matter of interpretation? For example, if you’re trying to eliminate chemicals of concern from your facility, can you still use Neoprene for its tough, tear-resistant qualities in waterproofing membranes, or should you find an alternative because hazardous gases can be released when it’s produced or burned?
Develop a solid strategy to dodge the rhetoric from all sides – if you don’t, your purchasing policy will be stuck in a gray area.
Develop a Game Plan
First, understand and develop specifics regarding greening your organization’s material purchases. What product attributes matter most to your company’s decision-makers? Is a product permissible if its manufacturing process has a negative environmental impact, or can it be used as long as it poses no risk to building occupants? There are two major schools of thought seeking to answer that question:
The Precautionary Principle: This way of thinking acknowledges that there is still much to learn about the effects of various chemicals found in building products. Rather than risk exposure to a health hazard due to a lack of available knowledge, practitioners of the Precautionary Principle refrain from using the chemical of concern until it’s proven to be safe without a doubt.
“We know that a lot of these substances have long-term effects,” says Jerry Yudelson, leader of Yudelson Associates’ consulting team, LEED Fellow, and founder of the first regional USGBC chapter. “The concern is that we may be creating long-term unhealthy environments even while we’re doing all of these green upgrades. The overarching principle is that we ought to err on the side of caution.”
The Risk Assessment Approach: Instead of avoiding chemicals of concern altogether, this principle examines how the chemical is used in a specific application and determines the risk of hazard exposure. A chemical that causes adverse health impacts on its own may behave differently when it’s combined with dozens of other substances.
“This approach says that there are thresholds of concern, and depending upon where a particular chemical is used, you may or may not eliminate it,” explains Steve Baer, chair of USGBC’s Technical Advisory Group for the Materials & Resources (MR) category, which will likely include materials restrictions and/or supply chain credits when the final version of LEED v4 is released.
Neither practice is wrong or right, but knowing where your organization stands is critical to wading through the contradicting claims from proponents of both principles. PageBreak
Where to Find Answers
There’s also the rarely discussed middle ground – eliminating the worst offenders with the most scientific evidence against them and making informed choices about other chemicals.
Architecture firm Perkins+Will generally adheres to the Precautionary Principle whenever possible – to the extent that it developed a separate section on its website, the Precautionary List, to catalog general chemicals of concern, asthmagens and asthma triggers, and halogenated flame retardants. But this resource isn’t a red list, says Robin Guenther, Perkins+Will’s sustainable healthcare design leader.
Rather, it serves as a library of sorts to help clients make informed decisions about materials.
However, the answers to those questions aren’t always readily available. Manufacturers tend to be wary about releasing information about proprietary materials, and toxicological profiles of many chemicals are incomplete. Sometimes, Guenther explains, the best an FM can do is to weigh the risks, find out if there are any high-performing product alternatives on the market, and make the best choice possible with the information available.
“As an owner, you’re asked to weigh a product that contains endocrine-disrupting chemicals against a product that contains carcinogens. Which do you pick?” Guenther says. “It seems to amplify the complexity the more you study it. Sometimes our specifications still include substances on the Precautionary List because there aren’t available alternatives and they have particular performance characteristics.”
Fortunately, you have three powerful strategies at your disposal to assess chemicals of concern: materials red lists, lifecycle assessment (LCA), and supply chain optimization.
Strategy No. 1: Materials Red Lists
A red list simply designates a registry of chemicals that cannot be included in building materials. It’s often encountered when earning a green building certification. The Living Building Challenge, for example, lays out 20 substances ranging from asbestos to wood treatments that contain creosote, arsenic, or pentachlorophenol. Your project cannot use any of the 20 if you want to earn this certification.
The materials optimization credit in drafts of LEED v4 includes a voluntary red list of sorts, a move that has drawn fire from organizations like the American Chemistry Council and the Center for Environmental Innovation in Roofing. LEED’s proposed credit for material ingredient optimization is voluntary, but some critics are concerned that it could someday become a prerequisite.
The proposed credit is designed to “transform the marketplace” and encourage safer formulations, says Baer, and having a pass-fail system for every product based on its contents certainly offers an easier way to choose one product over another. However, red lists miss the key component of exposure, notes Denise Van Valkenburg, Design for the Environment and sustainability engineer for Herman Miller and chair of the human and ecosystem health committee for BIFMA.
“Risk is hazard plus exposure or time plus exposure, and red lists don’t take that into account,” Van Valkenburg notes. “In some cases, the hazard’s going to persist throughout the lifecycle. In other cases, the material is bound up in a way that it’s not going to be an issue. Personally, I would love to see all red list chemicals go away, but I know from a cost and performance standpoint that there are times when we need to use them.”
Also note that though red lists are black and white – a product is either permissible or not – it can result in some surprising exclusions. For example, PVC, which appears in everything from piping to roofing membranes, appears on many red lists because dioxins (a potent type of neurotoxin) are released during its manufacture and when it’s burned. However, when it’s installed in a building, it poses few to no risks to building occupants, and its long lifetime, recyclability, and durability make it a popular choice.
So is PVC safe or not? The answer depends on how your organization defines “safe” in terms of product ingredients.
“The definition of green and sustainable varies depending on who you talk to,” explains Debra Phillips, managing director of the American Chemistry Council. After the first versions of LEED v4 were released, this industry group helped found the American Coalition for High-Performance Buildings, which publicly opposed the materials optimization credit.
“We take a broad view of sustainability – it deals with safety, environmental impacts, end of life issues, whether the material can be recycled or reused, and its durability,” Phillips adds. “Cost is also part of the sustainability equation – how are monies best spent in building construction and maintenance? The red list approach may look attractive because you can say ‘Does the product you’re giving me contain any of these ingredients?’ But the easy approach can lead organizations in the wrong direction when issues of material performance, longevity, energy intensity, and environmental impacts are left out of the analysis. You might end up with an alternative that has a worse environmental and health profile than the original material.” PageBreak
Strategy No. 2: Lifecycle Assessment
Among all of the outcry over LEED’s materials optimization credit, it’s easy to overlook the other two credits awarding careful materials choices – one supporting the use of environmental product declarations (EPDs), which incorporate lifecycle assessment data, and one for choosing responsibly sourced raw materials.
Compared to the red list, lifecycle assessments (LCAs) are more akin to the nutrition facts label on a box of cereal, but they, too, have limitations. There is no single uniform standard for lifecycle assessment, though EPDs are standardized.
“Lifecycle assessment is multi-attribute parameterization,” Yudelson explains. “You’re looking at 15 different characteristics simultaneously and trying to make the best decision based on the information you have. Understanding where you can make better decisions across any of those parameters is an important part of leveraging all of the information out there – for example, there are situations where high global warming products have durability that makes them last for centuries.”
The proposed lifecycle assessment credit in LEED is designed to work in tandem with the raw materials and chemicals of concern credits, notes Brendan Owens, vice president of LEED technical development for USGBC.
You can take a similar approach to your chemicals of concern policies. Lifecycle assessments and red lists are two separate tools, but could be used together, especially since they focus on different aspects of product development.
“Right now, lifecycle assessment isn’t necessarily giving you sufficient information to truly understand what happens from a human health standpoint when you specify a particular material,” Yudelson says. “If you augment your thinking around a lifecycle assessment, but with another lens that helps you factor in human health impacts and ecosystem disruption, you get a much more complete picture of the impact of your decision.”
This clearer picture will help you prioritize which qualities you most require in a product and which ones you can sacrifice in the name of specifying the greenest, highest-performing product.
“Lifecycle assessments give you a look at things like greenhouse gas emissions, energy, and water use,” notes Keith Christman, managing director of the American Chemistry Council. “They may have some shortcomings on chemicals, but they’re about as good as anything out there right now. You’re able to look at tradeoffs and say one product does better on emissions, but it might do a little worse on energy or water use.”
Strategy No. 3: Greening the Supply Chain
Who makes the products you use most often? If your organization buys large quantities of certain products – for instance, if you have a large portfolio – you may be able to leverage that purchasing power by working directly with suppliers and manufacturers to develop greener alternatives.
This type of initiative is also reflected in the newest proposal for LEED v4, Owens adds.
“A company like Herman Miller or Interface doesn’t necessarily manufacture all of the raw materials they use. The ability to control the supply chain of raw materials and components happens further upstream,” Owens explains. “We added a mechanism to LEED intended to provide an opportunity for supply chain optimization to play a role in how products are selected. Some companies don’t have the ability to bring on half a dozen material scientists or epidemiologists, but they could reach out to people who do.”
Approaching manufacturers directly with a carrot instead of a stick incentivizes them to develop more environmentally friendly products and increase transparency, Baer adds.
“When faced with the reality of being encouraged to disclose their practices, most manufacturers are going to change,” Baer explains. “The rationale is that if you look in the mirror and see that you’re ugly, you’re probably going to go back and improve. If you see that you’re desirable, you’ll publish your EPD for manufacturing processes and environmental impact so buyers will be able to make better choices. Think about going to the supermarket – food is now labeled with at least the country of origin, and it might tell you whether the fish is farmed or natural. You might make a different choice than I make, but the information is presented.”
This type of encouragement from consumers is already shaping changes in material composition to some extent, notes Phillips. Identify the ingredients you’re concerned about, then head upstream until your questions are answered. You may just wind up with a solution.
“The agent for the company you’re buying from should take your information back and facilitate a dialogue between you and whichever part of the organization can take up your quest, whether that’s the environmental health and safety department, research, or procurement,” Phillips notes. “It’s a matter of simply raising the concern or asking more about a product.”
For example, consider the PVC question raised by its inclusion on several red lists. In conversation with your vendor, you may learn that your particular manufacturer adheres to stringent quality management protocol that minimizes your human health concerns.
“One of our members was involved on a million-square-foot project for General Motors in Flint, MI. They completely removed a 20-plus-year-old PVC roofing system,” says Jim Hoff, vice president for research for the Center for Environmental Innovation in Roofing and president and CEO of TEGNOS Research. “They took all the material back to their manufacturing plant and recycled it into new PVC roofing material that could last another 20 to 30 years. In fact, the project was so big that the last few rolls for the GM project contained parts of the old roof. That’s as close to closed loop recycling as you can get.”
So what’s an FM to do? Set priorities, pick a strategy, and make the best decisions you can with the information you have. The decision may not be black or white, but you can make it as green as possible.
Janelle Penny email@example.com is associate editor of BUILDINGS.