PVC and the Green Movement - US Green Building Council

PVC and the Green Movement - DefenseTo:Re:PVC Task Group – US Green Building Council (USGBC)Proposed LEED standard awarding credit for buildings that avoid use of PVC building materialsDate: February 11, 2004As you know, lobbying groups like the Healthy Building Network (HBN) have petitioned, for the second time in 5years, to persuade the USGBC to declare, through the creation of a LEED standard encouraging its disuse, thatPVC/vinyl is NOT a Green building material.HBN, in its email alert dated February 10, 2004, has even gone so far as to declare that the USGBC has “been silenton the hazards associated with the use of PVC” and that this decision is “a fight over the soul of the green buildingmovement, to determine whether it will embrace and ally itself with environmental and public health goals, or tobecome a captive of chemical manufacturers, the Vinyl Institute and manufacturers of PVC building materials.” Inother words, HBN has declared jihad on PVC and that anyone who disagrees with their views is an infidel who mustbe treated as such.Unfortunately, HBN seems to be less concerned with specific facts than with broad-brush allegations and hype. Assuch, there are several facts that a reasonable environmentalist would agree recommend against submitting to theirextreme view and effectively banning PVC from Green buildings.1) Production/Disposal Versus UseHBN confuses the production of PVC/vinyl with the use of PVC/vinyl in buildings. Through their writing andfactual presentations they equate the two things as one. These two things are not one, and we believe that it isimportant that the USGBC fully grasp this fact before making any decisions on additional LEED standards.In the USE of PVC/vinyl (typical daily usage in a building), PVC/vinyl has no significant harmful or carcinogenicemissions. (See fact sheet at the end of this document.) In fact, some vinyl products – such as Lonseal’s LonEco sheet-vinylcomposite surface – emit 1000% LESS volatile organic compounds than linoleum and 50% less VOC than rubber,resulting in superior indoor air quality. And yet, one doesn’t hear a clamor for a LEED standard “banning” linoleumor rubber surfaces for their relatively negative impact on indoor air quality (IAQ).In the PRODUCTION of PVC/vinyl, the carcinogen known as vinyl chloride monomer (VCM) can only be emittedinto the factory environment (or into the air) if there are insufficient emission controls during the production process.HBN assumes that all PVC manufacturers lack such controls because some PVC manufacturers lacked them at onetime. Thus, HBN’s argument assumes that the production of PVC is inherently carcinogenic. This is patently false.Furthermore, the chemical production of PVC changes the VCM into PVC. Thus, once PVC is fabricated, thecarcinogen VCM is no longer an emissions danger. In other words, PVC itself does NOT emit the carcinogen (VCM)in question; the carcinogen is emitted only when PVC is produced AND ONLY IF the emissions process is notproperly controlled during the production process.Lastly, in the DISPOSAL of PVC/vinyl, toxins such as dioxin can only be emitted into the environment IF the PVCis burned AND ONLY IF it is burned at low temperatures.On this point, then, the anti-PVC mob is contending that because there is a health risk posed by PVC/vinyl when it isimproperly made or improperly trashed, that its use is inherently anti-environment. This contention is like arguingthat because I baked my gourmet non-fat pot pie using a microwave instead of a convection oven and tossed the boxinto the food trash instead of the recycle bin that my pot pie is somehow bad for me. This confusion ofproduction/disposal of vinyl with its actual use is the core flaw in the anti-PVC mob’s rationale.Updated 2/11/2004 3:24 PM1

PVC and the Green Movement - Defense2) Vinyl’s Environmental VirtuesThe general understanding of the purpose of the USGBC’s LEED rating system is to encourage the creation ofbuildings whose construction and existence result in less harm to the environment. In other words, LEED supportsthe creation of buildings that are relatively better for the environment than buildings that do not follow the LEEDstandards.However, as perhaps the leading force in the Green building movement, LEED standards are increasingly viewed notas affirmative recommendations (do this to be Greener), but as negative prohibitions (don’t do this or you’re notGreen). In that context, it has become paramount that the USGBC proceed with a fact-centric approach before“declaring” certain building materials or methods to be “un-Green”. Given this need, there are several factors whichillustrate the environmental virtues of vinyl (flooring in particular) which, to be fair, the USGBC should take intoaccount before deciding this issue.2A) The Commerce Department StudyThe US Commerce Department in an April 1999 study titled “Environmental and Economical Impact Analysis – FlooringMaterials” sought to establish some kind of standard by which it could measure various product manufacturers’ claimsthat their products were in fact as “Green” as they claimed. Toward that end, Commerce established six empiricalcategories in which the environmental impact of a product’s raw-materials acquisition, manufacture, transportation,installation, actual usage, and typical disposal could be measured. Those categories were:• Solid waste (impact on the waste stream resulting from product)• Indoor Air Quality (impact on the indoor air quality resulting from product)• Resource depletion (consumption of mineral and fossil fuel resources from manufacturing, transportation anduse of product)• Nutrifaction (ecosystem impact resulting from product – over-production of harmful lifeforms through nutrientbyproducts introduced into the ecosystem)• Acidification (impact of the product on the creation of acid rain)• Global warming (impact of the product on the increase of the average ambient temperature of Earth).The study specifically compared linoleum flooring (generally viewed in the Green building community as the Greensurface of choice) and vinyl flooring (usually portrayed as the boogeyman in Green circles). That study found thatvinyl is better for the environment (results in LESS negative impact on the environment) than linoleum in five of thesix categories.In terms of solid waste, vinyl outperformed linoleum because it lasts longer once installed, resulting in less impact onthe waste stream.In terms of indoor air quality, vinyl outperformed linoleum because it tends to emit less VOCs and other toxins onceinstalled than linoleum. And, as mentioned previously, some vinyl products dramatically increase vinyl’s IAQadvantage.In terms of nutrifaction, acidification, and global warming, vinyl was also the clear winner.Only in terms of resource depletion did linoleum outperform vinyl – and that is largely due to a roughly 10% lead inconservation acquired by linoleum because the production of vinyl consumes ~10% more fossil fuels than does theproduction of vinyl (which is to be expected for a polymer-based product).Updated 2/11/2004 3:24 PM2

PVC and the Green Movement - Defense2B) The Truth about PlasticizersAnother argument that has been raised against PVC/vinyl has been that, once installed, its plasticizers (such asphthalates) migrate out of the building material’s matrix and that these plasticizers are a health threat. Thus, theargument concludes, PVC/vinyl in its use is a health risk. However, this argument is based on exaggeration at bestand duplicity at worst. In certain tests, certain plasticizers were found to be carcinogenic to lab rats. However, as theU.S. Consumer Product Safety Commission has found, the risk these plasticizers pose to Humans is, at most,“extremely low”. This is because a Human would need to ingest the equivalent of 500 grams of plasticizer per day for100 days to re-create the effect observed in the lab rats – a level and rate of exposure that is unrealistic in actualbuilding-material use.2C) Post-Consumer Versus Post-Industrial Recycled ContentAnother argument raised against PVC/vinyl by HBN (“Green Group Reconsiders PVC”, Plastics News, December 1,2003) is that “very little post-consumer vinyl is recycled”. First, as a reference to the Green fact sheet will show, thisis untrue. Second, even if this claim were true, it is irrelevant.The point of recycling material as part of the production process is to reduce the consumption of our planet’s nonrenewableresources and to reduce the amount of trash we create. Why then should it matter whether the trash that isbeing diverted from the waste stream comes from a collection of households (assuming they recycle) or a collection ofenvironmentally-conscious companies? The apparent snobbery against post-industrial materials presumes that thepoint of using recycled-content materials is to encourage consumers to recycle more. However, it seems obvious thatthe point of using recycled-content materials is to encourage everyone (consumers and producers) to recycle more.Thus, the HBN’s charge against post-industrial recycled content seems to miss the point of recycling entirely whilesimultaneously discouraging companies from recycling. To suggest that this position is absurd would be too obvious.2D) The ChlorophilesMuch of the anti-PVC message can be traced to a split that occurred in the Green movement decades ago.Essentially, Green activists in Europe split when Green activist-scientists who were chemical experts in regards toPVC began to dissent when less-expert Green activists began exaggerating the health risks of PVC in an attempt todramatize the risk of improper PVC production or disposal. This dissent led to the formation of a group called theChlorophiles who maintain a running response – in some cases study-for-study – refuting some of the more egregiousanti-PVC propaganda. An in-depth exploration of this group’s findings and history can prove very enlightening as tothe real motivation and zealous disregard of fact behind much of the anti-vinyl jihad being waged by some.Updated 2/11/2004 3:24 PM3

PVC and the Green Movement - Defense3) Vinyl’s Green HorizonPerhaps the most compelling argument, aside from the empirical facts supporting vinyl’s Green virtues, against theestablishment of an anti-PVC/vinyl LEED standard is that many vinyl products companies have been moving soaggressively to embrace the LEED standards – even shifting their product development to increase their products’Green virtues along the lines embodied in the USGBC’s LEED system.Lonseal, for example, created a surface (LonEco) that is comprised of 50% post-industrial recycled vinyl and woodpowder that also emits TEN TIMES LESS V.O.C. than linoleum and 50% LESS than rubber (as measured by thirdpartytesting). Likewise, companies like Lonseal have promoted low-VOC adhesives and have been testing ordeveloping low-VOC plasticizers that have the potential to reduce all VOC emissions on vinyl products by 50%. AndLonseal is not alone in pursuing ever-Greener products in harmony with the LEED standards.To create a standard effectively “banning” PVC/vinyl from Green building designs would be a slap in the face tothose vinyl product manufacturers who recognize the critical importance of the USGBC and the Green buildingmaterials & design movement and who have devoted such energy to be a positive force for and in support of theGreen-building movement.4) Alternate Standard SuggestionsGiven the limited risks to the environment that can occur in the production or disposal of PVC/vinyl, perhaps theUSGBC – instead of proposing a LEED standard effectively banning the use of vinyl outright – should createstandards that “regulate” or reward the proper manufacture/disposal and use of vinyl.4A) LEED Standard on Proper PVC/Vinyl DisposalA LEED credit could be awarded to Facility Managers/Owners for disposing of their waste PVC/vinyl only withwaste management companies who certify that they dispose of the waste PVC/vinyl in incinerators that operate at theminimum temperature required to prevent dioxin or other toxic emissions; alternatively, that same standard couldgrant the credit for the FM/O who disposes of their PVC/vinyl only at waste management facilities with fire-controlmeasures that can ensure that the waste PVC/vinyl cannot accidentally catch fire (reminder: low-temperature burnswere the emissions risk).4B) LEED Standard on PVC/Vinyl VOC Emissions or IAQThere is no LEED standard on hard surface flooring or on PVC. Perhaps an additional LEED standard that awardscredit for using a PVC/Vinyl product that is below a certain VOC emission or IAQ standard (such as the one thatapplies to carpet) would be more productive in ensuring that PVC use is Green.4C) LEED Standard on Proper PVC/Vinyl ManufacturePerhaps the best LEED standard that can address the concerns of some, without engaging in extremism, would be astandard that awards double-credits to Green builders whose PVC/Vinyl products comes from PVC manufacturerswith documented VCM emissions controls designed to protect the health of the plant workers and prevent VCMemissions into the environment at large. This would address the real cause of concern with regards to PVC withoutirrational or reactionary measures.In sum then, to create a LEED standard encouraging Green builders to avoid the use of PVC/vinyl would be thesame as saying that PVC/vinyl is bad for the environment – a claim that not only fails to be supported by the facts,but which is directly contrary to empirical fact. In its use as a building material, PVC/vinyl IS Green – and theUSGBC should not succumb to any pressure to deny the facts and brand PVC/vinyl as anti-Green.Updated 2/11/2004 3:24 PM4

PVC and the Green Movement - DefenseGREEN FACT SHEETENVIRONMENTAL VIRTUES• Unlike most plastics, 70% of all vinyl resin goes into products that are in good use for 10 years or more – vastly reducingthe amount of vinyl that enters the waste stream. Even during the manufacturing process, 99% of all scrap vinyl isrecycled. (The Vinyl Institute, “Vinyl and the Designed Environment”, pp. 16-17.)• Other plastics, such as old bottles and such, as well as old/scrap vinyl are recycled into new vinyl. As of 2001, 18 millionpounds of post-consumer vinyl had been recycled. (The Vinyl Institute, “Vinyl and the Designed Environment”, pp. 16-17.)• “Because of its durability, vinyl flooring does not have to be replaced as often as many other types of flooring. Thisdurability is a significant benefit for the environment because less energy and other resources are used to make andinstall new floors.” (The Vinyl Institute, “Environmental Considerations”, www.vinylbydesign.com, 2001.)• Using the small chamber study method, a prominent testing lab recently found that Lonseal’s LonEco recycled vinylflooring emits TEN TIMES (1000%) LESS VOC (volatile organic components) and/or aldehydes than linoleum, and roughly50% LESS VOC as recycled rubber flooring. (Alpha Environmental Inc., Material Test Report, October 29, 2001.) Inother words, LonEco provides superior indoor air quality (IAQ) to linoleum.• “Environmental concerns have heightened exponentially over the past decade. With that increased concern,manufacturers have positioned products in various degrees of ‘green-ness’. [To address these claims, the] followinganalysis was put together by the US Department of Commerce’s National Institute of Standards and Technology. [Thisanalysis] is designed to look at the total environmental impact of a product, including raw material acquisition,manufacturing, transportation, installation, use, and waste management.” In the course of this analysis, six“environmental impact factors” were studied: solid waste, indoor air quality (including VOC emissions), (mineral andfossil) resource depletion, (ecosystem destabilizing) nutrification, (toxic) acidification, and (lifecycle emissions that speed)global warming. The specific product types compared were linoleum – often touted as a Green flooring option – andVinyl. The result of the study was that, overall, the manufacture, installation, and lifecycle use of vinyl hasa LOWER negative impact on the environment than that of linoleum. (U.S. Department of Commerce – NationalInstitute of Standards and Technology, Environmental and Economical Impact Analysis – Flooring Materials, April 1999.)• Vinyl has lower initial, future, and lifecycle costs than linoleum. (U.S. Department of Commerce – National Institute ofStandards and Technology, Environmental and Economical Impact Analysis – Flooring Materials, April 1999.)• The manufacture, installation, transportation, and use of vinyl flooring produces fewer toxic emissions than that oflinoleum. (U.S. Department of Commerce – National Institute of Standards and Technology, Environmental andEconomical Impact Analysis – Flooring Materials, April 1999.)• The lifecycle of vinyl results in less replacement and less solid waste than linoleum. (U.S. Department of Commerce –National Institute of Standards and Technology, Environmental and Economical Impact Analysis – Flooring Materials, April1999.)• Vinyl and linoleum have a roughly equal impact on resource depletion (except in the crude oil category, where vinyl’spolymer composition gave linoleum an apparent 10% edge). (U.S. Department of Commerce – National Institute ofStandards and Technology, Environmental and Economical Impact Analysis – Flooring Materials, April 1999.)• Though linoleum outperformed vinyl flooring in terms of the renewability of the fuels used in its manufacture, vinyl vastlyoutperformed linoleum on all other fuel/energy consumption standards. (U.S. Department of Commerce – NationalInstitute of Standards and Technology, Environmental and Economical Impact Analysis – Flooring Materials, April 1999.)• Vinyl flooring outperforms linoleum by all standards of emissions (indoor air quality) testing in all stages of use: inproduct emissions, adhesives emissions, and maintenance chemicals emissions. (U.S. Department of Commerce –National Institute of Standards and Technology, Environmental and Economical Impact Analysis – Flooring Materials, April1999.)Updated 2/11/2004 3:24 PM5

PVC and the Green Movement - Defense• A study conducted by the U.S. National Institute of Standards and Technology, in conjunction with the EnvironmentalProtection Agency, developed the Building for Environmental and Economic Sustainability (BEES) model for interiorproducts. That study concluded that “when life-cycle considerations were ‘quantified and combined using the EPAimportance weights, the net effect is environmental scores slightly favoring vinyl.’” (Tim Burns, “Vinyl deserves CarefulLook”, Perspective, June 4, 2001.)• Lonseal’s products typically comprised of up to 20% post-industrial recycled vinyl.• Lonseal’s LonEco is fabricated using an additional percentage of post-industrial recycled vinyl & wood powder (averaging50% recycled content) to reduce its impact on the environment and increase its skin-soft feel. (Meets USGBC’s LEEDStandards MR 4.1 & MR 4.2.)SAFETY/HEALTH VIRTUES• The BEES study model also determined that vinyl flooring outperforms linoleum and ceramic tile – erroneous believed tobe more eco-friendly than vinyl – in terms of its impact on indoor air quality (IAQ), solid waste, acid rain, global warming,and natural resource depletion. Indeed, “vinyl flooring, when installed as recommended, has minimal long-term impacton indoor air quality.” (The Vinyl Institute, “Environmental Considerations”, www.vinylbydesign.com, 2001.)• A study conducted by the Vinyl Institute in Arlington, Virginia found that even when burning, vinyl releases no more toxicchemicals – such as phosgene, cyanide, hydrochloric acid, and carbon monoxide -- than most other flooring materials,including other “organic” substances. In fact, neither synthetic-organic nor “natural” resilient floor emit any contaminantthat pose a significant health risk. (The Vinyl Institute, “Vinyl and the Designed Environment”, pp. 2-11.)• Because of the materials used in its manufacture, vinyl is more resistant to moisture than almost all other flooringproducts. Furthermore, because of sheet vinyl’s capability to have its seams heat or chemically welded, sheet vinyl floorsprevent water seepage and the spread of bacteria (The Vinyl Institute, “Vinyl and the Designed Environment”, pp. 10-11.)• Vinyl is more sterile and allergen-resistant than other flooring materials. (The Vinyl Institute, “Design Considerations”,www.vinylbydesign.com, 2001.)• “Vinyl flooring resists burning and typically does not continue to burn when an external flame is removed.” (The VinylInstitute, “Design Considerations”, www.vinylbydesign.com, 2001.) This property causes vinyl flooring to be described as“self-extinguishing”.• “Sheet vinyl is available in continuous rolls…offering the advantage of installation with few or no seams in which moistureand dirt can collect.” (The Vinyl Institute, “Maintenance Requirements”, www.vinylbydesign.com, 2001.)• Only during its manufacture can the production of vinyl emit a carcinogen (vinyl chloride monomer, or VCM), and thenonly if the transformation of the vinyl monomer gas into the solid polymer during the production process is notadequately controlled by the PVC manufacturer. “Once industry discovered [that VCM was a carcinogen]…major actionwas taken to reduce the level of exposure” to factory workers. (“Science – Vinyl Chloride Monomer”, The European PVCPortal, www.ecvm.org, February 2004.)• Lonseal, which purchases the PVC for its sheet-vinyl from PVC manufacturers, supports the strict regulation of the PVCmanufacturing process to control and/or eliminate any carcinogenic risk to PVC factory workers which might result duringthe PVC manufacturing process.• After its manufacture, there is no significant risk of PVC emitting the aforementioned carcinogen (VCM). (“Science – VinylChloride Monomer”, The European PVC Portal, www.ecvm.org, February 2004.)• In the production of sheet-vinyl flooring, a plasticizer is added to PVC powder/paste. While some plasticizers (such asphthalate-based plasticizers) have been feared to be carcinogenic or to have other deleterious effects, the U.S. ConsumerProduct Safety Commission found that “the risk in humans is at most ‘extremely low’”. (“The Risk to children of DINPplasticizer in PVC is ‘minimal to non-existent’”, Plastics – The Global Newsletter, 2001, p. 3.)Updated 2/11/2004 3:24 PM6

PVC and the Green Movement - Defense• In fact, it was found that the plasticizers (such as phthalates) used in PVC products would have to equal anexposure/ingestion of 500 grams/day for 100 days for a Human in order to approximate the level of phthalate plasticizerswhich caused cancer in lab rats during the anti-PVC studies. (“PVC and alternatives when in use”, Chlorophiles web page,http://www.ping.be/~ping5859/Eng/Chlorophiles.html, February 11, 2004.) Lonseal and other vinyl-flooringmanufacturers are nevertheless testing other forms of plasticizer which might cause less concern in the Greencommunity.• In its disposal, vinyl emits dioxin only when burned and only if the burn is conducted at low temperatures – highertemperatureburns can eliminate the emission of dioxin. In fact, modern “incinerators are operated to the higheststandards and [are] equipped with pollution control equipment that minimizes the release of emissions to theenvironment”. (“Science – Waste Management”, The European PVC Portal, www.ecvm.org, February 2004.)Updated 2/11/2004 3:24 PM7