Småhus, flerbostadshus och förskolebyggnader - Svanen

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Nordisk Miljømerking Hus, leiligheter og barnehager 089/versjon 2 Høringssammenstilling, oppdatert 10. august 2010 Plastindustrien i Danmark Det nævnes i baggrundsdokumentet, at kravene til miljømærkede byggeprodukter vil udelukke næsten alle produkter, som er klassificeret som miljø- eller sundhedsskadelige. Derfor har man i miljømærkekriterierne tilladt produkter med visse klassifikationer. Det virker vilkårlig og ikke objektivt og fagligt underbygget at opstille kriterier ud fra en formodning om, at der så nok vil være nogle produkter, der kan opfylde kravene. Norima (norske mineralullprodusenter) Norima finner det hensiktsmessig, at det legges opp til anvendelse av klassifisering av stoffer i byggematerialer i henhold til internasjonale standarder (EU og GHS). Confederation of Finnish Construction Industries RT Finland The selection of banned products and substances in the Nordic Ecolabel is not based on scientific grounds and does not take account of European legislation. Chemical construction products are already covered by the Construction Products Directive (CPD); it will be replaced by the Construction Products Regulation (CPR) in the near future. Another leading legislation is the new European chemicals regulation, REACH. With REACH, the EU adopted the most stringent and comprehensive chemicals policy instrument in the world. With its entry into force, the chemical safety assessment procedure initiated by the ESR will become the rule for practically all substances including those used in construction products. REACH focuses on gathering existing data, filling potential data gaps, identifying potential hazards, determining exposure and evaluating potential risks through the scientific chemical safety assessment process. REACH clearly recognises that a risk is related to a use or an application. The safe use of a substance is documented via the exposure scenarios in the extended Safety Data Sheet which is passed down the supply chain. This risk-‐based approach throughout the substance life cycle is the common ground of the EU chemicals regulation. BING, Europe Material‐related indicators disregard existing legislation The selection of banned products and substances in the Nordic Ecolabel is not based on scientific grounds and does not take account of European legislation. Chemical construction products are already covered by the Construction Products Directive (CPD) which will be replaced by the Construction Products Regulation (CPR)4. Another important piece of legislation is the new European chemicals regulation, REACH5. With REACH, the EU adopted the most stringent and comprehensive chemicals policy instrument in the world. With its entry into force, the chemical safety assessment procedure initiated by the ESR6 will become the rule for practically all substances including those used in construction products. REACH focuses on gathering existing data, filling potential data gaps, identifying potential hazards, determining exposure and evaluating potential risks through the scientific chemical safety assessment process. REACH clearly recognises that a risk is related to a use or an application. The safe use of a substance is documented via the 66 (165)
Nordisk Miljømerking Hus, leiligheter og barnehager 089/versjon 2 Høringssammenstilling, oppdatert 10. august 2010 exposure scenarios in the extended Safety Data Sheet which is passed down the supply chain. This risk‐based approach throughout the substance life cycle is the common ground of the EU chemicals regulation. The Nord Ecolabel prohibits certain substances / R phrases without verifying whether the use of the substance/ product is leading to risks for users / the environment. Neither does it assess whether the use of a certain substance / product improves the life cycle performance of the overall building (durability, reduced material use etc.). On the other hand, the use / presence of certain substances which are proven to be carcinogenic is authorised without restrictions. Hence, it is doubtful whether environmental and health protection was really the main driver for this Ecolabel. This impression is reinforced by the proposed exclusion of substances for which scientific evidence shows that they are not dangerous (see following section). BING calls on the Nordic Ecolabel to put the material criteria on a scientific basis and apply the approach adopted by European legislation. European Council for Plasticisers and Intermediates (ECPI) The creation of parallel initiatives is unnecessary and confusing Construction chemical products are already covered under the Construction Products Directive (CPD) and in future under the Construction Products Regulation (CPR). Most importantly, their use in all applications is now covered under the new European Chemicals Regulation, REACH. The REACH regulation was developed over several years together with Government, industry and non-governmental stakeholders. On this basis, the REACH process should not be undermined by initiatives which can lead to confusion in the market place and unjustified deselection with associated socioeconomic impact for European society. The European polymer producers (PlasticsEurope), together with the European PVC resin producers (ECVM), and the European plastics converting industry (EuPC) General comments on chemicals/plastics in construction materials : The EU REACH regulation introduces the concept of chemical risk assessment and management before a chemical substance is put on the market and shifts the responsibilities from public authorities to industry. Additionally, the EU Construction Products Directive and the EU Ecodesign directive are undergoing revision to take into account sustainability design aspects of construction products in their conformity assessment. Accordingly, there is no need that the Nordic Swan should contain requirements for chemicals/polymers in construction materials and buildings. Comments on chemicals/plastics in construction materials : The EU REACH regulation introduces the concept of chemical risk assessment and management before a chemical is put on the market and shifts the responsibilities from public authorities to industry. Additionally, the EU Construction Products Directive and the EU Ecodesign directive are undergoing revision to take into account ecological design aspects of construction products in their Conformity Assessment. Accordingly, 67 (165)
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Småhus, flerbostadshus och förskolebyggnader - Svanen

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