Småhus, flerbostadshus och förskolebyggnader - Svanen

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.
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