Why Chemical Transparency Matters
You can’t manage what you don’t measure—especially if you don’t know it exists.
November 2, 2015
CEUs are available for reading all the short pieces on this featured topic. Click here to learn more and take the quiz.
As loyal shoppers at our local food co-op, we’ve gotten used to personal care products with full ingredient disclosure. A Tom’s of Maine toothpaste tube lists “every ingredient, its purpose, and its source.” If you’re not satisfied with that, you can go online and see a lengthy description of each substance, including the company’s take on any hazards associated with the chemical as well as an explanation of why the company still thinks it’s okay to use.
When you buy conventional personal care products—most of which, unlike food, don’t have to provide an ingredient list—you could spend hours online trying to puzzle out why the newest bottle of your usual shampoo is suddenly making you wheeze, or what kind of plastic they use to make those freaky blue ibuprofen pods.
This is why we both tend to stick with “natural” products—not necessarily because we think they’re more wholesome (which is debatable) but rather because manufacturers freely tell us what’s in them. That builds trust. It also means that if something goes awry, we can probably track down which ingredient might be causing the problem.
From toothpaste to … insulation?
In the last few years, green building professionals have been looking for the same kind of ingredient lists and explanations for building materials that Tom’s of Maine puts on its toothpaste tubes—often in the form of a Health Product Declaration (HPD).
Many manufacturers and trade groups have resisted: they suggest design professionals should stick with designing buildings and let suppliers and manufacturers manage the chemical side of things. And since we don’t eat building products or even brush our teeth with them, it’s worth asking why we should want to know what’s in there.
There are three good reasons.
1. There may be too many chemical cooks
The HPD gives us a chemical inventory of a building product and characterizes the level of concern about each ingredient.
Although other data reporting formats may allude to human health effects, they fall short. Reference to toxicity in environmental product declarations (EPDs), for example, looks at health in a fairly indirect way. It focuses on public health impacts from manufacturing and not on toxic substances in the materials themselves. The material data safety sheet (MSDS) was created to warn first responders about what they might be dealing with in case of a chemical spill or other crisis.
But we are becoming more aware of our sensitivities to long-term, low-level chemical exposures. One recent study noted that 30 different chemicals present in common household dust all could be contributing to obesity. None on its own was present in significant quantities, but researchers think that in combination, they could be asserting a surprisingly strong effect. Another recent study looked at how multiple chemicals, each in small quantities on its own, could be combining into a carcinogenic “soup.”
HPDs can help address these effects by bringing to light small chemical quantities and giving us more data to analyze for patterns.
2. Transparency is a means to an end
Suppose you had to choose between a world in which all products are disclosed and one in which all products are optimized for minimal health impact and maximum performance. You would choose optimization, right?
You wouldn’t know it from transparency opponents, but that’s not our choice to make. We need transparency to get to optimization, and there will never be a land of unicorns and rainbows where everything is optimized.
Look at the U.S. Green Building Council’s experience in developing LEED v4. USGBC signaled clearly in early development of the system that it wanted to encourage avoidance of chemicals of concern. It also wants to move its materials and resources credits toward life-cycle assessment and away from single-issue credits.
With both issues, though, it found out that it could only make token rules because, fundamentally, the building industry lacks data. We need massive generation of disclosure data to tell us exactly what we’re dealing with—before we can really start thinking about optimization.
We commend companies that are ahead of the curve and already optimizing. But for this to scale across the rest of the industry and start showing widespread results in our buildings, we need more data.
3. Disclosure changes products
With the transparency movement several years old, we’re hearing lots of stories from manufacturers who, simply by looking to find out what’s in their products and characterize the hazard levels of any chemicals, have found that asking questions leads to change.
For architects who have asked for products with HPDs, having those conversations with manufacturers is a clear way of communicating an interest in health without boxing those companies into solutions that aren’t a good fit.
We’d like to see more companies optimize formally, but the on-the-fly optimization that happens through asking questions is more accessible as an everyday practice.
Presenting the HPD issue
In this special issue, we are providing a series of shorter articles focusing on a single topic: chemical transparency, specifically HPDs.
We’re including expert voices from around the industry in the op-ed section as well as in our in-depth analysis of a variety of topics, which include a look at how HPDs fit into the market, a case study of how one furniture manufacturer is leading the way on optimization, and a special report on the legal risks associated with knowing and disclosing hazard data.
Although these issues are complex, we hope this special issue contributes to an ongoing dialogue about the hazardous substances in our building products—and how we can find alternatives that don’t compromise our other sustainability goals.
Receive continuing education credit for reading this feature on HPDs. Please note that all eight of the shorter pieces must be read for credit.
The American Institute of Architects (AIA) has approved this course for 2 HSW Learning Units. The Green Building Certification Institute (GBCI) has approved this course for 2 CE hours towards the LEED Credential Maintenance Program. The International Living Future Institute has approved this course for 2 LFA hours.
To earn continuing education credit, make sure you are logged into your personal BuildingGreen account, then read all the articles associated with the feature and pass this quiz.
Upon completing this course, participants will be able to:
- Discuss why chemical transparency matters and answer common technical and practical questions regarding HPDs.
- Offer solutions for the legitimate concerns that manufacturers, designers, and building owners have about chemical transparency and liability.
- Explain how HPDs help in everyday work for the specifier, architect, and building owner and how architects and toxicology experts can work together to balance toxicity concerns with more traditional design considerations.
- Describe how Google scores building products.
Use the following questions to inform class discussions or homework assignments.
- A new project is underway at your firm and you want to introduce HPDs into the process of identifying environmentally preferable products for it. The project team seems interested but wants to know “why (they) should want to know” the ingredients in building materials. How do you respond? Can you think of more than the three reasons laid out in “Why Chemical Transparency Matters”?
- Why do “we need transparency to get to optimization”? What do you think of “the on-the-fly optimization that happens through asking questions” of manufacturers? How does the HPD play a “very limited… but critical role” in the “transparency marketplace”? What environmental issues are not taken into account by the HPD? What are all the jobs that need doing in identifying environmentally preferable products? If you had to choose two programs to do all of them, which would they be?
- How important is third-party validation, certification (and enforcement) for a tool like HPD, particularly if it becomes “the primary source of consistent information for Pharos, Cradle to Cradle, Declare… LEED, and others”? Where is HPDC in developing a third-party program? What would you say (or draw) to encourage the effort?
- What’s the difference between version 1.0 and version 2.0 of the HPD? (See New HPD Promises Better Reporting, More Participation for additional details and history.) How does the new HPD add clarity on several points? What challenges remain?
- What do you make of the claim that “we are becoming more aware of our sensitivities to long-term, low-level chemical exposures”? What does one need to know to “understand and manage risk” of getting sick from building products? What do you think of attorney Donald Simon’s comment that “HPDs don’t create a legal duty… so the building professional is unable to evaluate whether there is a risk of harm”? How do you imagine this factor evolving as we become more attuned to material causes of environmental diseases?
- If “design and construction professionals aren’t the main audience of the HPD itself,” who is? How do they communicate their assessments to the other players involved in product specification? How would “designers, with their graphic sensibility, be the prefect storytellers” for incorporating HPD information into the vetting process? Architect John Amatruda emphasizes the importance of creating specification criteria while vetting specific products. How do the two processes “feed off each other”?
- What’s your response to sustainability director Anne Harney’s assertion that “you’re never going to not use a product just because it doesn’t meet your ideal sustainability criteria”?
Keep exploring our featured topic:
John and Catherine prove that designers can work successfully with HPDs, especially if they have a toxicology consultant to support their multi-faceted selection process.
An architect, a specifier, and a building owner walk into a bar. Then they talk about how ingredient transparency informs their work.
Experts say HPDs probably won’t add professional liability, but do you know the do’s and don’ts for avoiding a suit in the first place?
We answer frequently asked questions on HPDs, which allow manufacturers to disclose product ingredients and hazards.
HPD version 1.0’s promise of greater material transparency didn’t always deliver, but version 2.0 should provide accurate reporting.
The Portico program turns chemical disclosure into a powerful decision-making tool.
Why do we need Health Product Declarations when we have safety data sheets, Cradle to Cradle, Declare, and other frameworks?