Småhus, flerbostadshus och förskolebyggnader - Svanen

Nordisk Miljømerking
Hus, leiligheter og barnehager 089/versjon 2
Høringssammenstilling, oppdatert 10. august 2010
The lacking scientific basis is even more clearer in the case of the proposed generalised
ban of halogenated flame retardants. This ban covers also substances that do not require
any labelling as they are not considered dangerous or harmful. It would be illogical to
refer to the precautionary principle in this case, as detailed risk assessments are available.
RT firmly believes that the (supposed) negative impacts must be compared with the
potential benefits. If the benefits largely outweigh the risks, the substance should not be
simply banned. In any case, this proposal for Ecolabel should establish the proposed bans
with scientific evidence. It is also confusing that the Background report (appendix 8, page
3) only refers to brominated flame retardants, whereas the requirements O17 and O22 ban
all halogenated flame retardants.
The Nordic Ecolabel proposes chemical material indicators without reference to the
end‐use application (O14‐O21) and without assessing what benefits / negative effects
these substances provide over the building life cycle. This will lead to material choices
which may neither provide the most environmentally friendly nor the most sustainable
solution for a given building over its life cycle.
Existing legislation must be taken into account in material related indicators
.....
This proposal for Ecolabel prohibits certain substances / R phrases without verifying
whether the use of the substance/ product is leading to risks for users or the environment.
In addition it doesn’t assess whether the use of a certain substance / product improves the
life cycle performance of the overall building (durability, different safety issues, reduced
material use etc.). On the other hand, examples can be found that use or presence of
certain substances which are shown to be carcinogenic is authorised without restrictions.
Taking into account what is said above on environmental and health protection makes the
aims of this proposal for Ecolabel confusing. This impression is reinforced by the
proposed exclusion of substances for which scientific evidence shows that they are not
dangerous.
Construction polyurethane industry of Finland (CPIF)
The case of halogenated flame retardants (O17, O22)
The lacking scientific basis is even more striking in the case of the proposed generalised
ban of halogenated flame retardants. This ban covers also substances that do not require
any labelling as they are not considered dangerous or harmful. It would be illogical to
refer to the precautionary principle in this case, as detailed risk assessments are available.
CPIF firmly believes that the (supposed) negative impacts must be compared with the
potential benefits. If the benefits largely outweigh the risks, the substance should not be
simply banned. In any case, the Ecolabel should underpin the proposed bans with
scientific evidence. It is also astonishing that the Background report (appendix 8, page 3)
only refers to brominated flame retardants, whereas the requirements O17 and O22 ban
all halogenated flame retardants.
Example:
86 (165)