Environmental & Safety Consulting

Wallcovering Association: 2004 Environmental Status Report December 31, 2004

USGBC & Green Building The most significant update is the issuing of the draft report by USGBC’s PVC Task Group. Starting back in 2000, USGBC’s Commercial Interiors rating system drafted language in the LEED program for a proposed credit to award the avoidance of vinyl in building products. It has been asserted that the available science does not support such a credit. USGBC referred this issue to its Technical and Scientific Advisory Committee (TSAC). In November of 2002, the TSCA established a PVC Task Group charged with: “…reviewing the evidence offered by stakeholders and independent sources, and advising the LEED Steering Committee on the availability and quality of evidence as a basis for a reasoned decision about the inclusion of PVC-related credit in the LEED rating system.” The materials studied included siding, pipe, flooring and windows. 2500 references were examined.

On December 22, 2004, the USGBC released the 121 page Public Review Draft “Assessment of Technical Basis for a PVC-Related Materials Credit in LEED”. Comments will be accepted on this draft until February 15, 2005. This comprehensive study is believed to be the first internationally to reconcile the occupational and environmental health impacts together with the life cycle analysis (LCA) impacts over all major life cycle stages. It is acknowledged that there are some gaps in the available data, and the sensitivity of final results to these gaps have been assessed. A final report is to be published in 2005.

USGBC Draft Report Conclusions

PVC does not emerge as a clear winner or loser. However, the available evidence does not support a conclusion that PVC is consistently worse than alternative materials. The Task Group concludes that a credit in the LEED system for eliminating PVC, or any particular material is not supportable. The report goes further to state that a credit of this type could steer designers to use materials which perform worse over their life cycles.

Data Gaps include: A) Human Risk Assessment: Lack of accurate exposure data to estimate human health non-cancer and cancer risks. Research is needed for both PVC and non- PVC materials. B) Process Data: The report concludes that improvements are needed on data covering occupational exposure and the report should be updated accordingly. C) Emission Data: PAHs, phthalates, aldehydes, and dioxins need further examination. D) Exposure Analysis: IAQ-material emissions information is required for each product in order to estimate the associated risks.

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E) Non-PVC materials are underrepresented in the data base. Because the available literature is overwhelmingly PVC focused, additional research is needed on alternative materials. Dose – response data is needed.

The committee also concluded that human and environmental health would be better- served by developing credits based on issues or impacts on human health or ecosystems. Within any particular product category, more or less desirable materials can be identified.

The draft report recommends developing issue-based credits using both LCA and risk assessment. It encouraged allowing Innovation and Design Credits to fill data gaps and provide credible evidence that furthers the body of knowledge toward lowering health impacts of building materials. This effort is to include eliminating certain pollutants or particulate emissions associated with building materials.

Final thoughts. Advocacy organizations opposed to PVC inclusion in green building construction are currently preparing their responses to this report and have reported on websites to “stay tuned” for further updates. Industry needs hundreds of responses, because extremists are planning a big response. Numbers are very important.

USGBC GreenBuild Portland (In Brief) 6600 participants, 2005 in Atlanta (10,000 expected), 11 countries, China represented too. Membership: In 2001-570 members, In 2004-5500 members, Chapters are having huge growth spurt. Themes: i) These are the early adopters. ii) Movement is changing the world. iii) Green Building provides new careers iv) Good for environment=good for business v) Build green, everyone profits vi) If it’s not LEED, it’s not green. vii) It’s got to make economic sense as well as green sense. viii) Concern that “green building” effort may be getting corrupted by corporate interest. GBC is “growing up” Fast! Seminars were packed. People were there to learn. More mainstream with more facilities and operations managers -less extremist than previous years. Government and commercial interests are the existing markets with strong foothold in green building initiatives. Next markets: Residential (will pilot in Spring 2005), Cities, and Healthcare. A continuing gap identified includes the rationalization of the green building “Cost Premium”.

Plastics have a place, but this will not happen quickly. PVC Free was a common theme. Perception: “If it’s vinyl it cannot be environmental”. Customers must have a “non- vinyl” product to offer or can’t compete.

Extremists being pushed to fringe; not happy, still influential. The anti-vinyl contingent was allowed to speak. They included highly respected voices-GSA among them. This continued to damage vinyl’s image with green Architects & Designers, however, extremists may also be damaging their own image with GBC staff.

Green Guidelines for Healthcare – ASHE has pulled sponsorship. Progress is being made to moderate this issue.

NAHB Green Home Building Guidelines – Model Green Home Building Guidelines The NAHB Research Center continues to work with home building industry stakeholder group members through an open process to create a set of Green Home Building Guidelines for mainstream home builders.

Areas of their program recommended for Wallcovering Association review include the following: Low VOC carpets and wallcovering under IEQ Inclusion of websites Product groups need to identify point opportunities

PHTHALATES Updates

Massachusetts Toxic Ten Bill: A new form of bill was submitted and it also includes phthalates. A study was to be conducted after the Governor vetoed the original bill.

Prop 65: OEHHA proposed listings. Assuming OEHHA is giving roughly equal attention to each of its listing considerations, this suggests that the Notice of Intent to list the 4 phthalates (DBP, BBP, DnHP and DIDP) may be very soon. OEHHA typically gives a 30-day comment for an ‘Intent to List’, and then will take some time for the final listing. The 4 phthalates may be listed late 1st quarter or early 2nd quarter.

DINP TRI Listing: External peer review completed, revised hazard assessment expected in March, 2005. Finalization on this issue is anticipated for fall, 2005. Phthalate Esters Panel will have an opportunity to comment before it is final.

Canada: Health Canada screening of domestic substances list is ongoing. Persistent, inherently toxic, bioaccumulative conditions are being considered, and those that have a high level of human exposure. 1900 chemicals are currently being considered. Industry is being asked for more information. Some phthalates are included, DEHP and others, are in the low exposure category. They also seem to be appreciative of information, so that they can justify paring down their list of things they need to look at. Open until September 2005.

Phthalate Panel is considering going to Canada to discuss toy issue. No political will left in Europe to fight the ban or possibly even a change in the risk assessment. There is a very real concern that this toy ban be introduced in Canada.

Vinyl Institute Update Vision: Vinyl is the global plastic of choice for infrastructure and diverse applications. Mission: Outreach to other groups so that we are not working at cross purposes. Purposes: Continuous improvement, sharpen focus, reverse declining member sweat equity trend (happening across all trade groups), even more downstream activity, direct activities. Staff Responsibilities: Promotion: Judith Nordgren; Life cycle – Keith Christman; Advocacy – Allen Blakey; Communications: Mike Cicchese & Allen Blakey; E,H,S – Frank Borelli. Members of staff are setting strategic direction of each area of responsibility. Expected Results: Promote vinyl, more externally directed marketing, active partnerships with customers, advocacy/communications split emphasis on importance of both. Ecobenefits Committee NAME CHANGE planned. The committee will now be co- chaired by Keith Christman & Judith Nordgren.

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