Småhus, flerbostadshus och förskolebyggnader - Svanen

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Nordisk Miljømerking Hus, leiligheter og barnehager 089/versjon 2 Høringssammenstilling, oppdatert 10. august 2010 available on the market, which will significantly improve the overall energy and material balance of the building (see examples above). BING calls on the Nordic Ecolabel to achieve consistency between the Background report and the draft ecolabelling text, to remove the ban of halogenated flame retardants or limit it to brominated flame retardants or, at least, allow the use of those flame retardants for which the EU risk assessment has concluded that the substance is not hazardous and hence no classification and labelling is required. European Council for Plasticisers and Intermediates (ECPI) Substances should not be grouped (Prohibited Substances, 017 and 022) Grouping substances by family is entirely inappropriate as many “families” of chemicals consist of substances which are both structurally and toxicologically quite different. Phthalates are one such example. The phthalate “family” consists of numerous substances, each of which has a different chemical structure which gives it its own characteristics. Whereas phthalates such as DEHP, DBP and BBP are classified as category 2 reproductive toxicants, there are those such as DINP and DIDP which have no hazardous properties and which are therefore quite different. There are no grounds for prohibiting the use of DINP and DIDP There are no grounds on which the use of Di-isononyl phthalate (DINP) and Diisodecyl phthalate (DIDP) should be prohibited from use: • DINP and DIDP have been the subject of a comprehensive EU risk assessments 1 conducted over a 10 year period. The conclusion of the risk assessment reports is that no risk reduction is required for any current application of DINP or DIDP. • DINP and DIDP are not classified or labelled under the EU Dangerous Substances Directive for any hazardous properties. This has been confirmed by expert review within the EU regulatory process. • DINP and DIDP are not PBT or vPvB substances. This is also addressed in the EU Risk Assessments. Published laboratory and field studies have shown that DINP and DIDP do not bioaccumulate or biomagnify in the food chain. These studies are based on advanced analytical techniques which can detect trace levels of the substances in the environment. Detection capability does not equate to risk to health or the environment. • DINP and DIDP are not endocrine disrupters as defined by Weybridge 2 , REACH and other international definitions. DINP has been subject to a comprehensive 2generation rodent study - the test recognized by OECD to be one of the most rigorous tests for effects on the reproductive system mediated via the endocrine system. More than 10 years ago, assessments of the oestrogenic potential of DINP using yeast cells and human cell models showed a weak response for DINP. The report authors warned that the relevance of these results to a whole animal was unclear and that further tests were recommended 3 . Additional tests were carried out in cells and in suitable whole-animal models and the original findings were not confirmed 4 . Additionally, proposed effects of DINP on testosterone and other proposed anti-androgenic effects from non-guideline research studies 5 , 6 ,are of unclear significance and have not been confirmed in the robust OECD Guideline two-generation rodent study 7 . 88 (165)
Nordisk Miljømerking Hus, leiligheter og barnehager 089/versjon 2 Høringssammenstilling, oppdatert 10. august 2010 Other research studies have reported associations between DINP metabolites and raised hormone levels in infant males 8 . When analysed further these “effects” were found to be within normal levels and there was no evidence of any antiandrogenic effects. On this basis, it can be concluded that DINP does not meet the criteria for a “substance of very high concern”. Further information can be found at the DINP Information Centre website: www.dinpfacts.com 1 DINP European Risk Assessment, European Commission Joint Research Centre, 2006 and DIDP European Risk Assessment, European Commission Joint Research Centre, 2006 2 European Workshop on the impact of endocrine disruptors on human health and wildlife, 2-4 December1996, Weybridge, UK report of proceedings [REPORT EUR 17549] (Copenhagen,Denmark: European Commission DG XII, April 16, 1997). 3 "The estrogenic activity of phthalate esters in vitro. " Harris CA, Henttu P, Parker MG, Sumpter JP. Environ Health Perspect. 1997 Aug; 105(8):802-11. 4 "Examination of the in vitro and in vivo estrogenic activities of eight commercial phthalate esters." Zacharewski TR, Meek MD, Clemons JH, Wu ZF, Fielden MR, Matthews JB. Toxicol Sci. 1998 Dec; 46(2):282-93 5 Steroidogenesis in fetal male rats is reduced by DEHP and DINP, but endocrine effects of DEHP are not modulated by DEHA in fetal, prepubertal and adult male rats. Borch J, Ladefoged O, Hass U, Vinggaard AM. Reprod Toxicol. 2004 Jan-Feb; 18(1):53-61. 6 Perinatal exposure to the phthalates DEHP, BBP, and DINP, but not DEP, DMP, or DOTP, alters sexual differentiation of the male rat. Earl Gray Jr L, Ostby J, Furr J, Price M, Rao Veeramachaneni DN, Parks L. Toxicological Sciences 58, 350-365 7 Two-generation reproduction study in rats given di-isononyl phthalate in the diet. Waterman SJ, Keller LH, Trimmer GW, Freeman JJ, Nikiforov AI, Harris SB, Nicolich MJ, McKee RH. Reprod Toxicol. 2000 Jan-Feb; 14(1):21-36. 8 Human breast milk contamination with phthalates and alterations of endogenous reproductive hormones in infants three months of age.Main, KM, Mortensen, GK, Kaleva, MM, Boisen, KA, Damgaard, IN, Chellakooty, M, Schmidt, IM, Suomi, A-M, Virtanen, HE, Petersen, JH, Andersson, A-M, Toppari, J; Skakkesaek, N. (2006). Environmental Health Perspectives 114: 270-276. Nordisk Miljømerkings kommentar Thank you for your comments. As BING points out, Appendix 8 in the background report is only mentioning brominated flame retardants. This will now be corrected to halogenated flame retardants. We are following the precautionary principle as long as alternatives exist. We have however changed the criteria for flame retardants to only cover the bromaded ones in this version of the criteria. The criteria for phtalates has also been change to exclude 7 specific phthalates in sealants. The national authorities in the Nordic countries have published observation lists for substances that are suspected to cause health or environmental problems, and the Nordic Ecolabel restricts chemicals in O17 and O22 based on these lists. Further, we focus on classified chemicals in accordance with rules for classification set by REACH (O15 and O16). AkzoNobel Sverige Klorparaffiner - det är en stor skillnad på kortkedjade klorparrafiner <strong>och</strong> mellankedjade (C14-17). Det finns en officiell klassning på kortkedjade som är Cans 3 R40 N R50/53. 89 (165)
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Småhus, flerbostadshus och förskolebyggnader - Svanen

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