Småhus, flerbostadshus och förskolebyggnader - Svanen

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estrict the use of zinc in building products. Nordisk Miljømerking Hus, leiligheter og barnehager 089/versjon 2 Høringssammenstilling, oppdatert 10. august 2010 Zinc is not classified as CMR (#O16 of the Nordic Ecolabelling document). Zinc is not a prohibited substance according to the criteria of the Nordic Ecolabelling document. It is an essential element needed for all life forms, from bacteria to man. Also, in addition to the Nordic Ecolabelling or the EU Flower Ecolabel, there are other highly regarded environmental labels that do not restrict the use of zinc. Those can be used in an ecolabelling scheme for sustainable building. Several types of schemes exist that all specify or will specify using building products having Environmental Product Declarations (EPDs), e.g. BREEAM in the UK, LEED in the US, ‘Démarche HQE’ in France. EPDs in accordance with ISO 14025 type III systematically present a multi-criteria and multi-stage approach, reflecting multiple aspects of products environmental profiles including results of Life Cycle Assessments. Comments from Nordic Ecolabelling Thank you for your comment. We would like to point out that the voluntary Nordic Ecolabelling scheme is free to have mote stringent requirements than the authorities based on concern about materials, even thought risk assessments do not lead to restrictions from the governments. We have altered the requirement and will not forbid zinc in this version of the criteria. Zink will be further assessed in the next revision. 11. European Copper Institute and Scandinavian Copper Development Association The European Copper Institute objects to the proposed restriction on copper roofs and claddings. Our comments are based on knowledge related to the durability and recycling capacity of copper and the results from a comprehensive voluntary risk assessment initiative1 (see ECHA website: http://echa.europa.eu/chem_data/transit_measures/vrar_en.asp). This risk assessment, covering the production, use and end-of life aspects of the copper value chain, shows that the existing legislative framework generally safeguards Europe’s environment, the health of industry workers and the general public. The conclusions from the copper risk assessment do not support the need for additional risk reduction measures such as restricting the use of copper roofs and claddings. 1 The assessment process was initiated by the copper industry in 2000 and endorsed by the EC competent authorities. The Italian Government’s Istituto Superiore di Sanità, agreed to act as the review country on behalf of the European Commission and the EU Member States. The risk assessment dossier has been agreed by the European Commission’s Technical Committee for New and Existing Substances and The European Commission’s Scientific Committee on Health and Environmental Risk (SCHER) performed a final evaluation and further endorsed the conclusions on the environmental and human health risk characterisations. In the course of the review process, the studies and results were extensively discussed also with Nordic authorities. 114 (165)
Nordisk Miljømerking Hus, leiligheter og barnehager 089/versjon 2 Høringssammenstilling, oppdatert 10. august 2010 The results from the copper risk assessment have contributed to the selection of national priority substances under the Water Framework Directive in Finland and in Sweden, resulting in the exclusion of copper. Useful considerations, addressed in the copper risk assessment, are: - Copper is an essential element for all life forms and therefore organisms need copper to ensure normal growth and development. Nature and humans both have natural regulating systems for copper allowing for adequate uptake/elimination, in accordance to nutritional needs. The Predicted No Effects Concentrations (PNECs), set in the copper risk assessment report, recognise copper excess, as well as copper deficiency. They integrate up to date science on copper bioavailability, in line with the REACH and Water Framework Directive guidelines. - Copper emissions into water systems have actually decreased drastically during the past decades due to: (1) the introduction of industrial on-site treatment plants; (2) the introduction of municipal waste water treatment plants; (3) better optimisation of fertiliser usage - These lower emissions have also resulted in decreased levels of copper in rivers, lakes and coastal waters. Monitoring data, covering surface waters throughout Sweden, has demonstrated that today’s copper levels are typically below 1 µg/l. Copper concentrations in the Baltic Sea have drastically decreased between 1978 and 1996 (see figure 1) and are now typically around 0.6 µg/l. HELCOM further assessed copper time series (> 15 years) in Biota (herring, cod fish liver and mussels) and concluded that “copper levels have remained stable during the assessment period”. Some variations were observed and related to natural homeostasis factors rather than to anthropogenic activities. The HELCOM report also concluded that copper concentrations in blue mussels from Denmark and Sweden were lower than the ones reported at the reference sites and lower than the concentrations levels regarded as “high” background levels. These data clearly demonstrate the success of historical risk reduction measures and do not indicate a need for further market restrictions. - Copper roofs represent one of the smallest diffuse sources of copper in the EU environment, only 1%. By far the largest source is agricultural chemicals. - Due to general increased air quality, runoff from roofs has decreased. Over 15 years, runoff levels have been extensively studied at the Royal Institute of Technology’s Dept. of Corrosion Science in Stockholm. In addition to long term field studies, a mathematical model has been created to predict copper releases. Results show that these are in fact very small and have (kommentar: Can this be better quantified?) reduced, during the past decades, as the air SO2 content has reduced. The very small amount of copper which is released from the outer 115 (165)
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Småhus, flerbostadshus och förskolebyggnader - Svanen

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