Småhus, flerbostadshus och förskolebyggnader - Svanen

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Nordisk Miljømerking Hus, leiligheter og barnehager 089/versjon 2 Høringssammenstilling, oppdatert 10. august 2010 Nordisk Miljømerkings kommentar: Takk for kommenateren. Detta är en fråga som vi får värdera inför nästa revidering av kriterierna. O28 Fasade og takbekledning Veidekke Norge Se O15 European Lead Sheet Industry Association (ELSIA) I have noticed that the draft document contains the notion of avoiding the use of lead in housing. More specifically, page 16 of the document contains this notion: “Lead or alloys containing lead or lead compounds may not be used for roof work”. In addition, the document contains two forms (appendix 11a and 11b) for suppliers in which they confirm that this notion is respected. I strongly believe that this proposal is based on a false perception of the environmental and health aspects of the use of lead. My request to the Nordic and National Ecolabelling boards is to review our arguments made in this e-mail, as well as the underlying scientific documentation, and to remove the ban on lead from the Nordic Ecolabelling criteria. Perceived health concerns Stringent health and safety legislation throughout the European Union has been established to protect both the general public and lead workers. As a result, the risks to health are negligible if simple health and safety guidance is adopted. Recent studies indicate that the general population has decreasing levels of lead within the human body. Against the background of this improving situation, there remain some perceived minor risks and areas of concern where lead sheet is used for certain applications that can be easily accessed by house owners or members of the public. However, the reality is this: touching the surface of lead sheet poses virtually no health risk, provided hands are washed before eating, drinking or smoking. Lead is not absorbed through the pores of the skin. Independent research carried out by the Institute of Occupational Medicine (Edinburgh) demonstrates that even regular contact with lead sheet has a negligible impact on human health. However, despite these facts, in order to avoid any unnecessary concerns by the general public, the industry has developed coating applications which ensure a continuous barrier between the lead surface and the straying hands of visitors, particularly young children. The coatings are either two coats of patination oil or a clear matt finish lacquer or varnish. Pre-treated lead sheet with a colour-coating is also available. 110 (165)
Nordisk Miljømerking Hus, leiligheter og barnehager 089/versjon 2 Høringssammenstilling, oppdatert 10. august 2010 In summary: the perceived health risks are negligible. In the rare cases where physical contact with lead takes place, coatings and technical installation techniques are readily available to eliminate all perceived risks. Environmental aspects Lead sheet has a better environmental performance than all of the available substitutes. This is the conclusion of an independent study by TNO (The Netherlands). The study (TNO 2006-A-R0232/B) indicates that lead sheet is fully recycled and has a low CO2 footprint. All alternative products are proven to have worse life cycle environmental impacts than lead. Banning lead sheet will have a negative environmental impact. Based on all available scientific information and documentation, there is no evidence that the use of lead sheet for roofing applications creates a risk in terms of human toxicity or for the ecosystem. In summary • There is no scientifically sound reason to ban the use of lead sheet in roofing applications - Environmental and human risks related to the use of rolled lead in building applications are virtually absent and constitute no threat to the environment or human health • Lead sheet has a better environmental performance than all its available substitutes - source TNO study on “Environmental performance of lead sheet and alternative weatherproofing products – TNO 2006-A-RO232/B)”. A ban on lead sheet will have a negative, environmental impact – the reverse of what is intended. • The proposed ban of lead sheet is inconsistent with EU policy - none of the three essential conditions of the EU for applying the precautionary principle appear to be met. Hazards alone do not form a sufficient reason for measures to be taken if enough knowledge is available; in this case there is no scientific uncertainty. • The proposed ban is a disproportionate response - although virtually absent, whatever environmental and human risks that do exist can be effectively managed by properly applying the standard industry risk management options (RMOs). We therefore strongly suggest permitting the use of lead sheet as the preferred weatherproofing product under the Nordic Ecolabelling scheme. We are willing to constructively work with you to specify coating requirements and technical guidance in order to include them in your criteria documents. I am ready to provide additional information and to meet with you and the Nordic and national Ecolabelling boards to further discuss this matter. 111 (165)
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Småhus, flerbostadshus och förskolebyggnader - Svanen

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