6 May 2011 – Following is an extract on PVC from the New Zealand Ecolabelling Trust for its proposed licence criteria for interior lining products for buildings, published last year.
Environmental and health concerns about PVC 9,10,11,
There are a number of concerns about PVC, including:
- the use of chlorine. PVC production is the largest user of chlorine and produces the world’s largest volume of an organochlorine. Organochlorines are of concern because of their persistence and toxicity.
- Hazardous wastes produced in manufacturing. Hazardous wastes containing chlorine are produced during the synthesis of EDC and VCM including chlorinated furans (polychlorinated dibenzofurans), PCBs (polychlorinated biphenyls), HCB (hexachlorobenzene) and OCS (octachlorostyrene). These types of substances are of concern because they are persistent bioaccumulative and toxic. The monomer, VCM is also a known human carcinogen. EDC is a probable human carcinogen. The acetylene production process produces large volumes of hazardous wastes, including slag and sludges (up to 3-4 tonnes of slag per single tonne of PVC polymer produced) as well as pollutant emissions to air (including complex hydrocarbons, carbon monoxide and dust) and water.
- On burning (whether intentional incineration or in accidental fires), PVC produces dioxins. Dioxins may also be formed during synthesis of EDC and VCM. Dioxins are of concern because of their persistence and toxicity (human carcinogens and toxic to reproduction and development).
- Plasticiser additives in PVC. Some plasticiser additives, in particular phthalates, are toxic to human reproduction and disrupt the human endocrine system. Phthalates can be moderately bioaccumulative and moderately persistent. Plasticisers can comprise more than 50 per cent by weight of PVC products and can be released to the environment during use and disposal stages of the product life-cycle.
- Other additives in PVC. Heavy metals, including cadmium, lead and organotins may be added to PVC as stabilisers. These heavy metals are of concern because of their persistence and toxicity. Lead is a human developmental and reproductive toxin, is ecotoxic, bioaccumulative and persistent. Cadmium is a neurotoxin and carcinogen, and it bioaccumulative and persistent. Organotin can disrupt the immune system and the endocrine system. These heavy metals can be released to the environment, in particular during the production and disposal stages of the life cycle of the products.
- Pollution from mercury. The acetylene process to produce VCM can release mercury to the environment. Mercury is of concern because it is persistent and is a reproductive, developmental and neurological toxin.
- Energy use. Production of VCM, in particular the carbide process is a significant energy user, reported to consume around 1 per cent of the world’s total electricity output5. PVC is difficult to recycle. In the early 2000s as little as 3 per cent of post consumer PVC was being recycled in Europe.
Responses to concerns
Early responses (in the mid-late 1990s) to the concerns about PVC focussed on substituting
and phasing out PVC5. These responses, however, did not take account of the social and
economic consequences and impacts of substitution and phase-out, or the environmental
probity of the substitutes or alternative products.
There have been a number of other responses to the concerns, including the following.
PVC industry responses:
- Voluntary commitments made in 1995 by European manufacturers of VCM to meet strict emission limits from VCM production and suspension polymerisation processes by 2008 (subject to independent audit in 1998 showing 88% compliance) with further commitment to full compliance by 2003 (also subject to independent audit)2.
- Vinyl 2010, voluntary commitment by European PVC industry including quantitative progressive objectives to recycling and phasing out Cadmium, research, reporting and verification 2,14. A further commitment, Vinyl 2020 is current being developed.
- Hydro Polymers The Natural Step-based PVC for Tomorrow programme launched in 20054.
- A PVC Retailer Working Group, established in 1996 in the United Kingdom which commissioned research by the National Centre of Business and Ecology (NCBE).
- Publication of the NCBE research in 199715 concluding that “careful manufacture, use, recycling and final disposal of PVC products to the highest standards can control the risks associated with the material to acceptable levels but will not completely eradicate them”.
- A PVC Coordination Group established in the United Kingdom in 1998, which also included the Environment Agency and commissioned work on a sustainability gap analysis for the PVC industry and a Code of Practice.
- Publication in 1999 of the Eco-Efficiency Code of Practice for the Manufacture of PVC by NCBE.
- Publication of the sustainability gap analysis completed by The Natural Step in 200016.
- A PVC Stakeholder Forum for Sustainability established to monitor progress on the challenges presented in the Natural Step gap analysis and on the Vinyl 2010 commitment.
- United Kingdom Environmental Agency participation in the PVC Coordination Group in 1998.
- Publication of research on life cycle analysis for PVC, completed for the United Kingdom Government in 200117.
- European Commission/Parliament work to establish a community-wide strategy and approach to PVC including:
o Research projects 1999-2000
o Green Paper on Environmental issues of PVC 20002
o Consultation on the Green Paper
o European Parliament resolution April 2001 on the Green Paper18
o Further research into life cycle assessment of PVC published in 200419.
Green Building Rating Scheme responses:
- New Zealand Green Building Council Green Star rating schemes for buildings have points that encourage reduction in PVC products20.
- In January 2010, the Green Building Council of Australia (GBCA) began a consultation process on a change in its stance on PVC from encouraging minimisation of PVC use, to development and use of best practice PVC21.
The GBCA’s consultation documents include some guidelines about best practice throughout
the life cycle of PVC products. These cover:
- production of chlorine and VCM;
- waste, water, air and product emission thresholds for EDC, VCM, PVC manufacturing processes;
- the use of stabilisers and plasticisers;
- end of life stewardship; and
- publication in August 2010 of the revised Green Star PVC credit and Best Practice Guidelines for PVC in Building Products by the Green Building Council Australia (GBCA)22.
The guidelines are not developed to an extent or expressed in a form that can be used as basis for formal criteria in an eco-label specification at this time. GBCA expects to release a “Verification Guidance Document” by October 2010.
There have been a number of government responses to issues specifically concerning phthalates. These have focussed on specific individual or groups of phthalates.
The European Community has adopted a precautionary approach. In 2005, it banned the use of some phthalates in children’s toys and products that are intended “to facilitate sleep, relaxation, hygiene, the feeding of children or sucking on the part of children” (2005/84/EC).
In June 2009, the European Commission Regulation 552/200923 (amending the REACH Annex XVII) banned six phthalates (DEHP, DBP, BBP, DINP, DIDP and DNOP24) from toys and childcare articles (in concentrations greater than 0.1 per cent).
DEHP, DBP and BBP are included on the REACH Candidate List of Substances of Very High Concern (SVHC) and in June 2009 the European Chemical Agency (ECHA) recommended to the European Commission that seven SVHCs, including DEHP, DBP and BBP be included on the REACH Annex XIV List of SVHCs that will require specific authorisation to be used. A final decision and publication of the Annex XIV List is still awaited.
The effect of being on the Annex XIV List is that authorisation must be obtained for any and every particular use of the listed SVHCs in substances or products in the European market. Under REACH there are two routes for gaining authorisation, either by demonstrating that the proposed use of the substance is safe as the risks are adequately controlled, or demonstrating that the use is so important on socio-economic grounds that its continued use outweighs the risks to human health or the environment.
The ECHA background documents for the recommendations on DEHP25 and the equivalent documents on BBP and DBP, confirm the classification of these plasticisers as Category 2 Toxic to Reproduction. The background documents examine the use of the plasticisers, the environmental and health risks associated with those uses, the European market (number of parties involved) and information on alternatives substances. With respect to DEHP, the background document reports that:
- it is widely used in a broad range of PVC products, including medical devices and in significant proportions (up to 30% by weight in some materials);
- when used as a plasticiser in flexible polymers, it is not chemically bound in the matrix, which means it can be released to the environment during the use phase of its lifecycle (particularly from washing floors or wall coverings);
- there are multiple users and parties involved in the supply chains of products using or containing DEHP;
- while substitute substances have been used in many products (including toys) and there is a range of potential alternative substances to DEHP, only a few have undergone comprehensive environmental and health impact, or technical feasibility assessments for substitution in specific applications;
- some alternatives to DEHP have also been shown to have reproductive toxicity;
- inclusion on the REACH Annex XIV list would result in authorisation being required for use in products at a concentration greater than 0.5%, except for the case of toys and childcare articles (separate regulations for toys and childcare articles set a limit of 0.1 per cent by mass of the plasticised material).
Because of the limits on information available (including assessment information on alternatives) and multiple parties involved, ECHA recommends an extended period for preparing applications for authorisations, allowing applications as late as 30 months after the listing in Annex XIV is confirmed and a sunset date after 48 months. Similar findings and recommendations are made in the ECHA’s background reports on DBP and BBP.
Specific phthalates (DEHP, DBP and BBP) have been subject to some regulatory controls and reporting requirements in the United States for some years. In December 2009, the Environmental Protection Agency (EPA) issued an Action Plan on Phthalates26. The Plan covers eight phthalates (the six covered in the European regulations; DBP, BBP, DEHP, DnOP, DINP, DIDP and two others; DIBP – diisobutyl phthalate and DnPP- di-n-pentyl phthalate). The Action Plan explains these are of concern because of their presence in humans; persistent, bioaccumulative and toxic characteristics; use in consumer products and production volumes. It examines data that are available about the eight phthalates andsubstitutes that may be available.
The Action Plan sets out the EPA’s intentions for further investigation and rulemaking, including the following:
- to initiate rule making later in 2010 to list all eight under the Toxic Substances Control Act as chemicals that present an unreasonable risk of injury to health or the environment;
- to initiate rule making late 2010 to add the six phthalates not already listed to the Toxics Release Inventory;
- begin work for considering initiating rule making in 2012 to regulate the eight phthalates; and
- completing a Design for the Environment and Green Chemistry alternatives assessment by 2012.
PVC and Ecolabels
Other GEN member specifications for furniture or boards also include requirements on phthalates, which may be used in PVC in interior lining products. The Nordic Swan specification of panels (version 4.5) bans all phthalates. The current Australian specification for panel boards (GECA 04-2007) bans the phthalates DEHP, DBP, DAP, BBP, DMP, DMT, DEP, DMEP and DIBP, however, the revised specification (GECA 04-2010 v20) only bans the first four phthalates in this list (i.e. DEHP, DBP, DAP and BBP).
The current GECA specification for Furniture and Fittings (GECA 28-2006 v1.10) and the draft for public comment (GECA 28-2010 v2.0) both include some specific requirements on phthalates as follows:
The following compounds, their functional derivatives or in-situ precursors shall not be added to finished products, their component parts or be used at any stage of the manufacturing process, including as preparatory agents, cleaners or degreasers in the production facility:
The phthalates DEHP, DBP, DAP or BBP.
The draft GECA specification has an additional criterion that requires that “the following Relevant
shall not be added to eco-labelled products during manufacture”.
This implies that all phthalates are included. Background technical information explaining the
rationale for the criteria is not available on the GECA website.
Initial responses to concerns about PVC which focussed only on substitution and phaseout have proved to be simplistic. They have failed to address wider environmental and sustainability issues, such as the environmental probity of alternatives, social and economic impacts and the need to take a more holistic approach to sustainable development.
PVC is a significant technological resource, being used for a wide range of products. Because of its characteristics and widespread use, it has significant economic and social values, contributing to human wellbeing in many applications from infrastructure to medical devices.
Since the 1990s, progress has been made to address many of the particular environmental and health concerns associated with PVC manufacture, use, reuse and disposal. This includes ongoing work to substitute the particular additives of concern (including phthalates), to reduce hazardous waste and emissions from production processes and improve recovery and reuse of PVC. In the case of specific phthalates of concern, regulators in Europe and United States are embarking on careful programmes of investigations (over several years) better to understand risks associated with phthalates and alternatives to phthalates of specific concern. Long-term and ongoing strategies to minimise the specific risks associated with PVC and to work towards closed-cycle recovery and reuse of this technological resource are consistent with sustainability approaches such as ECNZ’s life cycle approach, The Natural Step principles27 and Cradle to Cradle28.
The Trust, having considered the development of approaches to PVC and phthalates is proposing to include a new criterion in this specification that will require information to be gathered and reported on PVC and phthalate use in ECNZ-licensed interior lining boards.
The reporting requirements in Clause 184.108.40.206 b) are based on health concerns and responses from stakeholders identified above and on the criteria in the GBCA’s Best Practice Guidelines. The GBCA is due to release a Verification Guidance Document in October 2010 explaining how its criteria for PVC should be assessed. The Trust intends to use the information gathered from ECNZ licence holders and the information that will emerge from the regulator initiated reviews (in Europe and the United States, in particular) and the work of the GBCA to consider, develop and consult on a more comprehensive approach to PVC, where relevant, in future revisions of ECNZ specifications. This may include establishing more specific criteria (e.g. for certain plasticisers).
Future criteria for this specification may include requirements on the virgin content of PVC.
9 Revision of Eco-label criteria for laundry detergents Final report. Prepared by DHI Water & Environment, May 2003. 10 Commission Decision of 9 July 2009 establishing the ecological criteria for the award of the Community Ecolabel for bed mattresses (notified under document c(2009) 4597. 2009/508/EC. https://eur- lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:203:0065:0080:EN:PDF
11 Hazardous Chemicals in PVC Flooring. A report compiled for the Health Flooring Network by Michelle Allsopp, David Santillo and Paul Johnston, Greenpeace Research Laboratories, November 2000. 12 Life Cycle Assessment of PVC and of principal competing materials. Final Report. Commissioned by the European Commission 2004.
13 Green Paper Environmental Issues of PVC. Com(2000)469 Final. Commission of the European Communities 26 July 2000.
14 Vinyl 2010 Progress Report 2009: Reporting on the activities of the year 2008. Vinyl 2010 The European PVC Industry’s Sustainable Development Programme 15 Summary Report for the PVC Retail Working Group. National Centre for Business and Ecology, Manchester 1997
16 PVC: An Evaluation Using the Natural Step Framework. 2000
17 Life cycle assessment of Polyvinyl chloride and alternatives. Summary report of Entec UK Ltd and Ecobalance to United Kingdom Department of the Environment, Transport and the Regions. 18 European Parliament resolution on the Commission Green Paper on environmental issues of PVC (com(2000) 469 – C5-0633/2000 – 2000/2297(COS)
19 The Australian Ecolabel Programme Good Environmental Choice Australia Standard. Textiles. GECA 19-2007, issued 20 June 2007. 20 https://www.nzgbc.org.nz/main/greenstar/elaboration/ratingtools/nzoffice 21 www.gbca.org.au/green…/pvc-minimisation-credit-review/2716.htm
22 Literature Review and Best Practice Guidelines for the Life Cycle of PVC Building Products, 10 August 2010
23 Commission Regulation (EC) No 552/2009 of 22 June 2009 amending Regulation (EC) No 1907/2006 of the European Parliament and of the Council on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) as regards Annex XVII, Entries 51 and 52. 24 DEHP – Di(2-ethylhexyl) phthalate, DBP – Dibutyl phthalate, BBP – Benzyl butyl phthalate, DINP – Di isononyl phthalate, DIDP – Di isodecyl phthalate, DNOP – Di-n-octyl phthalate.
25 European Chemicals Agency, 1 June 2009. Background document for bis(2-ethylhexyl) phthalate (DEHP): Document developed in the context of ECHA’s first Recommendation for the inclusion of substances in Annex XIV.
27 https://www.naturalstep.org/ 28 Cradle to Cradle: Remaking the way we make things. William McDonough & Michael Braungart, North Point Press, 2002