31 April 2014 — UPDATED: PVC is big business in buildings. Here in Australia, 75 per cent of PVC produced is used in built environment applications. But the issue of PVC is complex. Concerns exist over the environmental and health implications of PVC manufacture, use and disposal. A significant part of the market – the Green Building Council of Australia and green product certifiers in particular – have come to accept its use and say there have been huge improvements in its manufacture. But others, such as US-based Bill Walsh of Healthy Buildings Network, say there are better alternatives, and incorporating credits for PVC into green rating tools is lowering the bar. So can PVC be produced safely, or has the green building industry capitulated to a well-funded vinyl industry?

A special report by Willow Aliento and Tina Perinotto 

The Green Building Council of Australia recently released revised best practice guidelines for the use of PVC. While this is good news for the vinyl industry, the topic continues to be controversial.

According to Bill Walsh, executive director of the highly regarded US-based Healthy Building Network, it also represents a lowering of the bar for environmental standards, which is counter-productive for firms who have developed less toxic alternatives.

The GBCA’s chief operating officer, Robin Mellon, however, told The Fifth Estate that the GBCA’s review into PVC had been done in a fully transparent and scientifically rigorous way, with much of the concern around PVC outdated or not relevant to the Australian context.

What the Healthy Building Network says

The Healthy Building Network published an in-depth report, Environmental Impacts of Polyvinyl Building Materials by Dr Joe Thornton in 2002. Among the report’s findings is that vinyl manufacture is a major and preventable source of dioxins, a group of chemically related compounds that are persistent environmental pollutants.

The report also pointed out that there is no such thing as a safe dose of dioxins, stating, “Dioxin causes damage to development, reproduction, and the immune and endocrine systems at infinitesimally low doses (in the low parts per trillion). Toxicological studies have not been able to establish a “threshold” dose below which dioxin does not cause biological impacts.”

Is it green science or plastic politics?

Speaking with The Fifth Estate by phone from the HBN office in Vermont, USA, Bill Walsh said the GBCA’s review process and the resulting amended guidelines appeared to be a political rather than environmental response.

“The problem with the literature review was that it didn’t weigh the industry assertions against other science, and did not seek out expert scientists who draw different conclusions from the data,” Walsh says.

Taking climate change as analogy, he explains that if coal industry information was relied upon as heavily to review a credit relating to climate change, “we would see a credit which rewarded the status quo and penalised innovators”.

Walsh sees that the softening towards PVC does no favours for the companies who provide less toxic alternative products.

“There are many companies that have invested and innovated away from PVC into demonstrably better technology, such as Alpar Architectural products in the health care sector,” Walsh says.

“Also, in the US we have companies that were not PVC companies at all, such as Carnegie Fabrics, who are improving their non-PVC products and moving towards bio-based content. We have got companies that were really doing best practice.

“This [revised GBCA] credit has shifted from being [about] avoidance of PVC to being a PVC promotion credit.

“[Green ratings] are supposed to be leadership standards; [these revisions] are muddling the waters and true innovation is being stifled. Is there any material not being considered green under these codes?

“I would think the whole point of materials credits is to set an above and below bar, [and therefore] to move people to better products and stimulate innovation.”

The GBCA’s reasoning

Robin Mellon, chief operating officer for the GBCA, told The Fifth Estate that in the review of the Green Star credit for PVC it was important to consider the international evidence, “but also to recognise the differences in how PVC is used in Australia.”

“Of course, there are alternatives to PVC – as there are to most building products – but our research looked at all the environment impacts of products – including production, transport and lifetime use.  We also need to consider how a material is procured and whether it can be recycled at the end of its useful life.

“What’s important for people to understand is that a blanket ban doesn’t help change the industry. You can say ‘product x’ is bad and we shouldn’t use it, but markets and innovation tend to react better to encouragements than penalties.  Green Star is a voluntary rating tool, so people can simply choose not to go for that credit.”

Banning something doesn’t help the industry to change, he says. It simply “demonises” a product.  Encouraging best practice, on the other hand, does help industry to move forward.

“Green Star has always been about driving best practice and beyond.  We will always incentivise best practice – which is exactly what this PVC credit does.

“We will only reward best practice and those making or using uncertified, unmeasured or unregistered products will get no reward.”

Mellon says many PVC production processes have improved dramatically in the last few decades.

“Some of the concerns about PVC is founded on old research – some that goes back as far as the 1960s,” he says.

The industry has made “dramatic improvements” in the manufacture of extruded pipework, for instance and is making the same products using less material and with recycled content.

“It’s important that we understand what best practice looks like now – which is what the revised PVC credit does.  It is not giving a green light to all PVC – but it is incentivising manufacturers to adopt best practices.”

However, it’s unclear exactly what best practice is in a quantitative sense.

If it’s not the “smoke belching factory” in a developing country that some people imagine with old practices, how much better are current practices? Are they a 50 per cent improvement on former practices? Or 20 per cent?

This is almost impossible to answer simply, Mellon says.

The problem is, for each component, the level of toxins and environmental outcomes varies.

The issue of how much better best practice PVC is, though, is complicated. Varying uses of PVC such as in flooring or cabling have differing levels of [toxic] plasticiser, depending on their need for flexibility.

Mellon says there is a similar issue with volatile organic compounds. Removing them altogether is difficult and impractical. Rewarding better and better practice, with a view to eliminating their inclusion in the long term, is a more practical way of ensuring best practice outcomes.

But certainly, practices are far better than they were 10 years ago, he says.

What about separating out the toxicity of a material? Does PVC stir up heated debate because the lifecycle assessment process does not separate the toxicity of PVC from general environmental impact?

Mellon agrees, adding that there are no longer Green Star credits relating to the avoidance or elimination of PVC. And there is no banned list.

On the issue of rewarding innovation, Mellon refutes Bill Wash’s suggestion that, in awarding a Green Star point for use of “best practice” PVC, the GBCA is not innovating, as it should.

“By revisiting and revising the PVC credit, we recognised that it was important to promote innovation,” Mellon says.

“There are currently Green Star credits that relate to the minimisation and elimination of hazardous materials in Green Star projects; materials such as asbestos, formaldehyde and volatile organic compounds.

“We also have a range of Innovation Challenges within Green Star rating tools, and are trying to collaborate with industry on specific projects that can demonstrate improvements on best practice and quantify the environmental benefits achieved.

“And Green Star is also developing its Life Cycle Assessment approach, working with members and industry professionals to work out how better materials choices can be rewarded within the rating tools – a further Discussion Paper was released on this issue in mid-April 2014 and we are calling for feedback on the topic.

But it begs the question of why not reward the total elimination of certain chemicals known to be dangerous?

Green Star is a voluntary tool, Mellon points out, and so is the choice of materials within Green Star ratings.  “It is only through rewarding best practice that we get market transformation.  Green Star is helping to influence the entire supply chain not just in Australia, but internationally as well.  This outcome would be impossible were we to impose a ban on PVC.”

Mellon agrees it’s a complex issue. And one of the toughest issues for Green Star is to balance the range of different environmental impacts and alternatives.

“When a product features a minimum levels of toxins, is created in stable and environmentally-sustainable ways, doesn’t create off gassing and is delivering other environment impacts, and if it is recycled at the end of life – then we know we are starting to get the balance right.”

GBCA is not alone on PVC

The GBCA is not the only sustainability certifying body that now tacitly approves some forms of PVC. Ecospecifier and Good Environmental Choice Australia also both give a range of PVC products, including some brands of vinyl flooring, the green stamp of approval.

“Technology, scientific knowledge and community expectations change and we need to update these standards to reflect this,” Rupert Posner, chief executive of GECA commented.

“This will normally mean increasing the environmental rigour or social compliance expected but may occasionally mean revisiting something that may not have been acceptable in the past. If this is to occur we need to ensure it is done because it is a better choice, not because it is an easier choice.

Australian companies have started to use the alternatives

Even though some industry sectors had advocated for a revision of GBCA materials credits to allow use of some PVC types, there have been trades, suppliers, designers and builders who have embraced the challenge of going PVC-free.

Already some Australian construction projects that have used alternatives to PVC either partly or exclusively as part of improving the project’s ESD outcomes include:

  • The Graythwaite Rehabilitation Centre at Ryde Hospital, which used alternatives to PVC cabling, HDPE for drainage systems and recyclable copper and PEX pipework for the water supply systems
  • The 5 Star Green Star 70 Franklin Street used PVC-free pipework, ducting, insulation, conduits and cabling
  • Hutchinson Builder’s Goods Shed South project
  • Grocon’s One Bligh Street
  • Melbourne Water’s 6 Star Green Star As Built Digital Harbour building, which has no PVC pipework – all pipework is either push-fit stainless steel or HDPE as part of the former Green Star V2 PVC minimisation credit
  • AMP-NET Connect, a division of Tyco Industries, installed all non-PVC based low smoke, zero halogen cabling which is Reduction of Hazardous Substances (RHS) compliant throughout the 5 Star Green Star Sirius Building in Canberra.

Have the facts been stacked?

In both the USA and Australia, Walsh says he has observed a global campaign by the chemicals and plastics industries to put pressure on both the US Green Building Council’s LEED rating system and GBCA’s Green Star.

In terms of the GBCA literature review, which Walsh examined, he says there appears to have been a degree of “cherry picking” of scientific data from the Stockholm Convention on Persistent Organic Pollutants’ website.

“Under [the] POPs [convention] there is acknowledgement that dioxin is associated with chlorine, and the PVC industry uses about 35 per cent of the chlorine used worldwide. But the PVC industry is able to rig the system to make it hard to find the PVC contribution to dioxins,” Walsh says.

“[In the literature] they look at point source dioxins from landfill, but they don’t look at the fact the facilities do release dioxins.”

Walsh also points out that in terms of recycling of PVC cable, in most cases it is the copper inside that is recycled, with the PVC coatings [in the case of US cable waste] mostly exported to China where it is are burned in open pits, producing dioxin emissions that are “off the charts”.

He obtained government data from the Department of Environment on the Australian situation, which stated:

“Post-consumer PVC cable insulation is mechanically recycled in Australia each year at a level of approximately 1500-2000 [tonnes per annum]. Given that at least 10,000 tpa of PVC cable scrap is available substantial quantities of PVC cable strippings are still being landfilled or exported. In much of this the current high level of residual copper content in the PVC strippings (sometimes [greater than five percent by weight]) is too high for PVC recyclers to tolerate.”

This is contrary to what is stated in the GBCA literature review, which says there is a general lack of lifecycle analysis information available for PVC cable applications, yet goes on to state:

“Economically feasible options currently exist for the recycling of recovered PVC cable insulation. Such options are made feasible because of the high value of the copper and aluminium metals which are actively recovered from cable and wire waste streams, thereby significantly minimising the overall associated impacts.”

Walsh says this interpretation is a concern.

“All of this is indicative that in this review they just ignored data – I would say it was aiming for a conclusion,” Walsh says.

“All the data GBCA cited from the [US Green Building Council Technical Scientific Advisory Committee Report] hasn’t changed, and has not been refuted – and all that is being ignored.”

Another aspect of PVC production that Walsh identified as problematic is the energy use involved in manufacturing chlorine. The majority of chlorine used in PVC is a by-product of caustic soda manufacture. As a by-product, by repurposing it as an ingredient in PVC, Walsh points out it displaces what would otherwise be a major toxic waste issue for the caustic soda manufacturing industry into a toxic ingredient issue for the PVC industry.

One PVC door closes, a less toxic window opens

Asked about the viability of alternatives to PVC for pipework, such as High Density Polyethylene (HDPE), Walsh says that while it is not a clean process producing HDPE from petroleum, it is potentially a more sustainable product due to its high recyclability and the absence of chlorine compounds such as dioxins.

“You have to look toward what your goal is – if the goal is through time to reduce the toxic footprint of buildings over time, if you move to recycled HDPE it’s simple to envision – very simple,” Walsh says.

“The point is: where are we headed? If we look at PVC on an objective level, if our goal was to take out one of the most toxic and one of the oldest formulas for plastic, which is also hard to recycle [then phasing out PVC makes sense].

“And if we are going to reduce the number of plastics [through discouraging PVC manufacture], then we create greater economies of scale for the plastics they do use. It’s market disruption – and PVC itself is no stranger to market disruption.

The job of a green building council, their goal should be to produce a system that improves footprints over time – their job is not to tweak industries

“The job of a green building council, their goal should be to produce a system that improves footprints over time – their job is not to tweak industries. If green building councils tweak all the industries we’ll end up simply with the status quo.”

While end-of-life recycling is a key aspect of the new GBCA best practice guidelines, Walsh’s own research has found no successful examples of large scale PVC recycling.

Ultimately, he says, the PVC industry is an aspect of the “deeply embedded, interrelated infrastructure of the petroleum industry and highly effective plastic production industries”.

“Therefore it is difficult for someone to do something new and compete in such a low margin industry as plastics,” Walsh says.

LEED remains firm on materials – and even toughens up

In the USA, the US Green Building Council’s LEED Scheme has strengthened the materials credits, though not without a fight. There are two parts to the credit, one relates to complete disclosure of the composition of all products, the second part relates to minimisation or substitution of products including PVC, phthalates and halogenated flame retardants.

LEED and the hugely sensitive Vinyl Institute

“LEED has improved the way it handles materials… but in terms of the percentage of the rating system, [the credits] are not much; there’s not a lot of incentive,” Walsh comments.

This credit does not mean PVC is banned per se, but that did not stop the US Vinyl Institute reacting as if it were, even stating to the USGBC that the LEED V4 MR credits “can actually lead architects and designers to make bad decisions in order to secure credits so they can market their buildings”.

Tristan Roberts, LEEDUser editorial director wrote, “It’s important to note that LEED-NC 4 does not actually ban any building materials. MRc4 is optional, and only 25 per cent of permanently installed products have to meet the criteria in order to achieve Option 2 – but we still wondered if a product containing PVC could still contribute to MRc4. The answer is decidedly ‘yes’.

“PVC is on the banned list in Cradle to Cradle (C2C), but any product with an [health product declarations] or a manufacturer inventory can contribute to Option 1: as long as the ingredients are disclosed, it doesn’t matter what they are. Contributing to Option 2 would certainly be more challenging, particularly for products that include certain phthalates (plasticisers that make PVC flexible), but it’s still quite doable.”

Further, Roberts points out that the MR credits are worth one or two points to projects – making them hardly a deal-breaker in terms of achieving a rating.

Google and the move towards healthy buildings

Bill Walsh says the market was moving towards healthy buildings.

“The USGBC received a $3 million grant from Google to promote these [materials] credits, and hired some materials and chemical policy experts as Fellows to promote healthy building within the green building market,” Walsh says.

“The market is moving towards healthy buildings. Generally, for ordinary people, the precautionary principle makes a lot of sense. You operate on the evidence in front of you.

“Endocrine disrupting chemicals [like dioxins and phthalates] are different from other poisons in that they don’t operate from a dose-based toxicity. People look [now] to avoid them.

“Green building has been driven by architects, engineers and designers, and by the owners of buildings because they are aware of toxicity from a risk management point of view.

“Who wants to be caught with the next asbestos?”

“For the type of high value employee [someone like] Google wants to attract, they are people who invest a lot in their lifestyle – they eat organics, they use organic personal care products, and there are women of child bearing age who are expecting those values to be reflected in their workplaces, so [companies like] Google are investing in a healthy environment. It’s the carrot AND stick.”

You eat organic but work in a chemical laden office?

Walsh points out that when an employee who avoids chemicals in their personal lives finds out the work cubicle they spend a substantial amount of their life in is emitting the same chemicals they’ve been trying to avoid, it becomes hard for companies to attract and retain them. In that sense, providing a healthy workplace becomes an edge in keeping valuable employees.

“PVC is out of step with the market in a big way,” he says.

“Companies looking to innovate and be on the leading edge enjoy dialogue with their vendors so they can be proud of improving what they do. There is a virtuous cycle starting [in business] and companies who are doing good are reaping rewards.”

It’s war out there

Walsh believes that globally, the signs are clear that petroleum power is exercising itself to “thwart the movement away from toxic chemicals and towards green chemistry”. He describes the mentality behind the attacks on the USGBC by the chemical and plastics lobby as “take no prisoners – destroy the institution”.

Ultimately, he believes the increasing availability of information is the key to the greening of the built environment. HBN invests substantial resources into providing tools and transparent information to assist decision making by designers, engineers and building owners.

These decisions he says will be driven not by LEED or Green Star, but by the ability of people to process information and make good decisions as a result.

“That’s where my optimism comes in –  information is power,” he says. “[People can] analyse and interpret it and have the tools to process it. We’re at the beginning of the information exchange; it’s in its infancy.

“There’s a real commercial edge to knowing what you’re talking about, not just taking [industry information] on face value. Because greenwashing and green marketing are becoming ubiquitous, you have to pay more attention.

“Beyond LEED and Green Star there is the potential to address the standard building codes and reduce the barriers for [green] materials.”

Why we all promised to stop making products that create dioxins

The World Health Organisation has stated that due to the human health effects of dioxins, prevention or reduction of exposure to them is required. As the toxins bio-accumulate, this means also preventing them entering the environment through emissions during manufacturing, leaching either during use or in landfill post-use, and preventing emissions during combustion. Once in the environment, dioxins then enter the food chain, which has resulted in their detection around the world in human breast milk.

“Prevention or reduction of human exposure is best done via source-directed measures, ie, strict control of industrial processes to reduce formation of dioxins as much as possible,” WHO has stated.

“Since 1987, WHO has conducted periodic studies on levels of dioxins in human milk, mainly in European countries. These studies provide an assessment of human exposure to dioxins from all sources. Recent exposure data indicate that measures introduced to control dioxin release in a number of countries have resulted in a substantial reduction in exposure to these compounds over the past two decades.

“WHO is now working with the United Nations Environmental Programme on the implementation of the ‘Stockholm Convention’, an international agreement to reduce emissions of certain persistent organic pollutants, including dioxins. A number of actions are being considered internationally to reduce the production of dioxins during incineration and manufacturing processes.”

The International Chemical Secretariat’s Substitute It Now database shows up 19 substances of very high concern that are connected to the various forms of PVC. They include proven carcinogens, endocrine disruptors and bio-accumulating and widely dispersing environmental toxins.

There are proven non-toxic alternatives

Greenpeace has produced a summary of alternatives to PVC, including HDPE pipe for plumbing, polyethylene or rubber sheathing for cables and linoleum for flooring.

2 replies on “PVC: the debate goes on”

  1. There is no doubt that Dioxins are very toxic chemicals and build up and bio-accumulate in the environment. So, I strongly support the actions prompted by the Stockholm convention to reduce man-made dioxin emissions – a beacon of success compared to our repeated failings on global warming. Luckily the US EPA still believe in good science to direct their efforts and have not been swayed by Bill Walsh’s myopic and relentless advocacy.

    According to the US EPA’s latest update of the US Dioxin emissions inventory US emissions have reduced by 75% since 1987, revised (down from 90% reduction) to take better account of NATURAL Dioxin sources – bush fires.

    Reading Bill Walsh’s powerful commentary you would get the impression that PVC was virtually the only source of dioxins and toxic exposures to people, but this is blatantly misleading. The USEPA inventory shows that the contribution of dioxins from all chlorinated organic chemicals (of which PVC is a part) is just 25 Toxic Equivalents (TEQ’s), 0.6% of the inventory 99.4% coming from other sources.

    This is where our efforts need to be focussed. The largest source is backyard burning of refuse in rural communities at 2600 TEQ’s. Next is forest (bush) fires, an all natural hit of 730 TEQ’s. This would almost certainly be MUCH higher for Australia but I don’t think that anything can be done to reduce this. Medical waste incineration comes in third at 400 TEQ’s, but what are the healthy alternatives to incinerating medical waste? Structure fires come in at 180 TEQ’s and municipal waste incineration 127 TEQ’s (reduced 74% since 1987 mainly through potent regulation). 82 TEQ’s come from industrial wood burning and this is mostly used for the kiln drying of all natural timber (one of the alternatives materials to PVC).

    HBN imply that PVC itself harbors a toxic load of dioxins, but in fact the chemical most contaminated with dioxins (according to USEPA) is a wood preservative – PVC carries practically no residual dioxins.

    So, the point is that a simplistic view of toxicity from any material or product that ignores the toxic emissions from alternatives can be totally misleading, Dr Thorntons work on toxicity in the life cycle of PVC is good work, but unless compared to toxicity in the life of the alternatives on the same basis it is misleading.

    That is why the USGBC established its Technical Scientific Advisory Committee and convened an independent expert panel on PVC tasked with investigating the life cycle environmental impacts and health risk impacts of PVC products AND the most common alternatives used in the US.

    The study used Life Cycle Assessment undertaken by World renowned expert Dr Gregory Norris from Harvard University and Health Risk Impact Assessment undertaken by Dr Kara Altshuler, an ex-US EPA toxicologist. Nadav Malin of Building Green, a nationally and internationally acknowledged expert in Green Building materials was the final member of the expert group. The panel reviewed close to 2000 scientific reports and submissions from stakeholders (all still available catalogued on the web), including that provided by HBN and Dr Thornton. They also held 2 public consultation meetings which Dr Thronton and HBN participated in.

    As Vice President of USGBC responsible for LEED (and as a Chartered Chemist), I assisted the group mainly with providing resources and access to USGBC’s extensive stakeholder and member network for public consultations.

    Having formerly Chaired the UK Government’s public consultation on its own LCA based environmental assessment, I was aware of how difficult this work is. I believe that the TSAC panel’s work was and probably still is the most comprehensive assessment of PVC for building products and alternatives ever conducted and by a panel of impeccable credentials.

    GBCA made the right decision to not attempt to repeat this work, but rather to adapt the TSAC report for relevance to Australia – using Australian product equivalents and Australia relevant LCA data sources and practices.

    Bill Walsh accuses GBCA of cherry picking their data, but nothing could be further from the truth. The Australian adapation of the TSAC work was also comprehensive and confirmed that the US findings were very similar to the US work. They revealed that compared to alternatives, PVC products were no better or worse than alternatives on either life cycle environmental impact grounds OR on human toxicity grounds. Staggeringly, Bill Walsh claims that the TSAC work supports his opposition to PVC – in fact the TSAC work completely discredits this position.

    So, am I a supporter of PVC products? I am neither a supporter or opponent of any product or material – my allegiance is to robust science used to assess everything. We need to make environmental assessment as simple as it can be but no simpler. Materials questions are usually complex and unless assessed correctly we risk dangerously perverse outcomes and greenwash. Unfortunately both prevail internationally.

    The relentless attrition from HBN and its supporters, promoting a technically flawed opposition to PVC has forced USGBC to respond and in ways that are not technically robust. Credits based on ingredients will usually be very misleading because toxic ingredients may react together to form non-toxic products or non-toxic ingredients can react to form toxic products . So, it is ironic that Bill accuses GBCA of not following the TSAC findings – it is truer to say that LEED has now departed from the TSAC findings.

    So what is the effect of credits that oppose the use of PVC products? Well it is to promote the use of alternatives. But robust science says that some of these alternatives can expose people to higher health and mortality risks, but perhaps putting different people at risk or through different pathways. Particulate emissions from power stations and industrial processes, formaldehyde (a known carcinogen) from timber…etc. So the Healthy Building Network may actually be working against its own declared aims.

    I want to be a supporter of HBN’s objectives, but until their campaigns are directed by good science I can’t.

    First, do no harm!

  2. Very good analysis and expose of the way in which so many ostensibly trustworthy not for profit certification bodies become coerced by the mighty dollar and effectively infiltrated in their assessments. PVC is a huge part of the construction industry and opposing it is made very difficult indeed at all levels. Who is watching the investigators of these things? Well at least Fifth Estate is giving it a red hot go! Well done.

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