Op-Ed

Opinion: Chemical Ingredients in Building Products—What Do You Really Need to Know?

HPDs can’t be used in isolation to make decisions about the safety and environmental performance of a product.

November 2, 2015

Phillips

Photo courtesy American Chemistry Council
Advances in chemistry help to provide a wide variety of high-performance, sustainable building and construction materials at reasonable costs.

From roofing membranes that reflect light to window systems that help better regulate internal building temperatures to caulks and sealants used to keep basements dry, chemistry contributes not only to performance but also to the aesthetics, resilience, and energy efficiency of buildings every day.

Amid growing interest in the chemical ingredients that enable these material and technological innovations, designers, architects, and builders are seeking more information about what’s in the materials used in building and construction, how they affect product performance, and whether there are any potential risks to building occupants associated with the use of these products.

Some tools are better than others

The American Chemistry Council (ACC) understands the value of sharing information about chemicals along the building and construction value chain and in fact requires this type of information sharing under the Responsible Care Product Safety Code.

Some tools, however, such as Health Product Declarations (HPDs), that seek to generate more information about the detailed chemical composition of each building material, seem to suggest that this information can be used in isolation to make decisions about the safety and environmental performance of a product. We disagree.

Simply listing ingredients and their potential hazard offers an inherently incomplete picture of both the ingredient and the product itself, and misses important factors needed to accurately account for the safety profiles of chemicals used in products, such as amount used or real-life exposure.

They also fail to take into account how these chemicals and products contribute to improved energy efficiency, reduced water use, or lower greenhouse gas emissions. Such an approach can lead to ill-informed decision-making and can even result in chemical substitutions that may reduce product safety and performance. 

An article in this publication this past April highlights this the limitations of HPDs by providing information on five specific chemicals that in their raw form can trigger significant health effects, but when present in final products are highly unlikely to cause harm to building occupants. The author notes that placing these ingredients on an HPD or other list is “confusing and places non-scientists like architects and contractors in the untenable position of making judgment calls about exposure risk—the business of toxicologists and industrial hygienists.”

Understanding various screening tools

To address this shortcoming, ACC has been working to demonstrate the technical feasibility of methodologies and frameworks that use more robust scientific, risk-based, and life-cycle approaches to characterizing chemicals in products. Such work includes a comparison of hazard screening tool results when looking at a common set of chemicals, and the testing of a methodology for combining exposure models with existing hazard-based screening tools.

Through this work, ACC is hoping to contribute to the science in this quickly evolving space, and to bring forward the benefits of using scientific, risk-based, life-cycle-oriented approaches as opposed to hazard-oriented listing tools. 

Managing exposure is key

ACC members work directly with their suppliers, customers and other value-chain participants to foster product safety management and information exchange along the entire value chain.

Through the industry’s Responsible Care performance initiative, ACC members share product safety and stewardship information to enhance the safe use of chemical products. The Responsible Care Product Safety Code articulates specific requirements for companies to cooperate and communicate along their supply chains. Chemical manufacturers engage with their upstream suppliers and downstream customers to ensure that knowledge of potential product hazards, exposure levels and safe handling practices are shared to manage product safety along the lifecycle of chemical products.

Key to this commitment is providing access to safety information in an understandable format. Companies develop material safety and information sheets that contain specific information on a chemical and its safe handling practices, and make these publicly accessible on their own websites as well as through an online portal that contains data on more than 4,600 chemical products.

Future of chemical evaluation frameworks

ACC and its members are building relationships with key stakeholders so that there is a better understanding of the steps chemical companies take to manage the safety of their products along their supply chains.

We are engaging in standards-setting processes and stakeholder dialogues, with the goal of value chain reliance on science-, risk-, and life-cycle-based approaches, while at the same time promoting companies’ abilities to develop new, innovative products and solutions in downstream markets such as building and construction.

These dual goals are crucial to continual improvement, which is a core value for chemical manufacturers. ACC members are listening and responding to customers’ desire for innovative chemistries that help make their products perform better and are continually working to review chemicals and their potential hazards and appropriate exposure levels.

We encourage the HPD Collaborative to continue to seek input from all stakeholders, including industry, so we can work together toward a mutual goal of sustainable building and construction products.

Debra Phillips is Vice President, Responsible Care and Value Chain Outreach at the American Chemistry Council.

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Comments

November 4, 2015 - 7:02 pm

Ms. Phillips needs to do some more homework on the HPD before she critiques it.

The HPD does not “miss important factors … such as amount used or real-life exposure.” The percent of the product a chemical represents is a requirement in the HPD. Manufacturers are also encouraged to provide contextual information about exposure in the notes associated with hazardous substances.

The HPD also does not “fail to take into account how these chemicals and products contribute to improved energy efficiency, reduced water use, or lower greenhouse gas emissions.” Addressing environmental flows such as these is the job of an EPD. The HPD was designed to complement the EPD by providing health hazard information that is not included in an EPD, not to duplicate or replace the EPD.

We welcome the ACC expression of concern for life cycle approaches to characterizing chemicals. While exposure factors in the use phase may reduce the chances of a building occupant being harmed by hazardous chemical, that is only one part of the life cycle. Before chemicals get “bound” in a product and during their disposal or recycling they are handled in unbound forms that can and do expose workers and fenceline communities to hazards even greater than what the building occupant may experience. To say that "managing exposures is not key" ignores a fundamental principle of industrial hygiene. The hierarchy of controls in industrial hygiene prioritizes replacing toxic chemicals with less hazardous ones first, before trying to manage exposures.

The HPD does not pretend to be the final word on product decision making. Rather it is a format that supports consistent disclosure of key information that is needed for good decision making: namely product contents and the hazards associated with them with accommodation for exposure information where manufacturers have it. Manufacturers have supported the HPD in the interest of establishing a single format to provide this information that is increasingly demanded by users.  

Rather than attack the HPD that product users are requesting, the ACC and its member companies would better focus their efforts on providing information to help fill the disclosure gaps.