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Current Newsletter:
Trends in Transparency (July 14, 2010)
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In December, 2004, the USGBC's PVC Task Group handed a Christmas present to the chemical industry with the release of their 121 page draft report on PVC. The draft report not only fails to protect human health, it punishes green market leaders and innovators supporting reduced use of PVC.
An esteemed group of experts submitted technical and scientific comments to the USGBC, detailing the many problems with the draft PVC report. (List under construction)
To read HBN's comments, click here (PDF)
- Architects, Designers, Planners for Social Responsibility (PDF)
Perspective on past environmental warnings that went unheeded, such as the asbestos issue, as well as support for USGBC's ability to transform markets.
- Lucia Athens, City of Seattle (PDF)
Concern that the USGBC report disregards the precautionary
principle and urging the USGBC to demonstrate the same leadership regarding this issue as USGBC public sector members, such as the City of Seattle, the first city program to formally adopt LEED.
- Jared Blumenfeld, City of San Francisco (PDF)
Concern that the USGBC report disregards the precautionary principle and suggesting an alternative assessment methodology utilizing screening approaches for high hazard chemicals of concern as demonstrated in their draft
plastic pipe alternatives assessment.
- Timothy Boers, Boulder Associates (PDF)
Indications of how this report is already being misused by the PVC industry to tout its products as "green" and a call for working together to change the market to move away from hazardous chemicals.
- Cascadia Chapter, USGBC (PDF)
Strong call for the Council to reassess and affirm guiding values and principles for evaluating sustainability and a call for the Council to make clear that the report does not represent official policy of the Council, to demand that that Vinyl Institute cease use of the report until it is final and complete and to address other adversarial activity of the trade associations.
- Clifton Curtis, World Wildlife Federation (PDF)
Concerns that the USGBC report undermines non profit and industry efforts to transform the market away from hazardous chemicals.
- Terrence Collins, Carnegie Mellon University (PDF)
On the growing global hazard of dioxin releases from PVC in fire.
- Jack Geibig, U of Tennessee (PDF)
Critique of the quality and credibility of the LCA methodology, including scoping and boundaries, transparency, allocation, and handling of uncertainties and missing concerns. Concern is also raised about the integration of risk assessment with LCA, the use of PELs, the exclusion of critical information and assessments and the inconsistency of the application of conservatism in selecting risk values.
- Cliff Goldman, Carnegie Fabrics (PDF)
Concern that the USGBC report undermines industry efforts to move away from a widely understood hazard (chlorine chemistry).
- Jamie Harvie, Institute for a Sustainable Future (PDF)
Information about lead and organotin leaching from PVC plastic, which was not considered by the TSAC committee.
- Kaiser Permanente (PDF)
Healthcare perspective on the importance of persistent bioaccumulative toxic chemicals (PBTs), and concern that the report ignores this and other critical issues with PVC and threatens to confuse the market and undermine market transformation progress.
- Stephen Lester, Center for Health, Environment & Justice (PDF)
How the report fails to adequately evaluate: the public health and environmental risks posed at the end of the useful life of a PVC product from burning or leaching, the impact of additives and the contribution of PVC to dioxin air emissions nationwide.
- McDonough Braungart Design Chemistry (PDF)
Critique of how the USGBC use of LCA for this analysis, its inadequacy to the task of evaluating health hazards from chemicals and its tendency to obscure important information.
- Mary O'Brien, PhD (PDF)
Critique of the LCA / RA approach, the Science around DEHP and other additives, fires, organochlorines and more.
- Mark Rossi, PhD, Health Care Without Harm (PDF)
Critique of the lack of analysis of methodology and suggesting alternative analytic methodologies that are proven, transparent, replicable, easily used, and more appropriate to assess material choices for LEED.
- Ted Schettler, Science and Environmental Health Network and Dept. of Medicine, Boston Medical Center (PDF)
Concerns about the shortcomings and Task Group's inappropriate use of TRACI and other methodologies, mischaracterizations of the science on DEHP and other phthalates, intake fractions, averaging of data on chemical groups, selective bias on acceptance of scientific data by the Task Group, selective bias on interpretation that favors finding no result, mischaracterization of the nature of occupational risks.
- Katherine Silberman, Center for Environmental Health (PDF)
Concerns that the USGBC report undermines nonprofit and industry efforts to transform the market away from hazardous chemicals.
- Sandra Steingraber, PhD (PDF)
Analysis of how the report excludes crucially important categories of impact, most notably groundwater contamination, risk of catastrophic accident, and threat of terrorism; accepts evidence that is not credible, most notably data from the Louisiana Tumor Registry; makes benefit-of-the-doubt assumptions that are unwarranted by the evidence; and employs shifting criteria for including or excluding evidence, holding favorable and unfavorable evidence to different standards.
- Wilma Subra, Subra Company (PDF)
Explanation of the Task Group's misunderstanding and mischaracterization of the Louisiana ambient air data and their inappropriate statistical approaches that hide a consistent pattern of serious emissions of toxic chemicals like vinyl chloride monomer and ethylene dichloride from PVC plants exceeding air quality standards in neighborhoods around the plants.
- Joe Thornton, PhD (PDF)
Concern about the quality of the analysis, failure to conform to scientific standards of reporting and transparency, failure to include critically important hazards throughout the life cycle of PVC, biased treatment of the science, and inadequacy of the methodology.
- Deborah Wallace, PhD (PDF)
Concerns about the depth of the Task Group's analysis of the health impacts on occupants and firefighters in burning buildings with PVC content. She indicates that there is a substantial body of literature that was not utilized by the Task Group that adds up to a compelling body of science indicating serious hazards from fires.
- Howard Williams, Construction Specialties (PDF)
Concern that the USGBC report provides no useful guidance to manufacturers and misses key opportunities to work to reduce human exposure to dioxin and phthalates.
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