Update! HEALTHY BUILDING NETWORK IS NOW HABITABLE.
Update! HEALTHY BUILDING NETWORK IS NOW HABITABLE.
Update! HEALTHY BUILDING NETWORK IS NOW HABITABLE.
Update! HEALTHY BUILDING NETWORK IS NOW HABITABLE.
Update! HEALTHY BUILDING NETWORK IS NOW HABITABLE.
Update! HEALTHY BUILDING NETWORK IS NOW HABITABLE.

Phase 1 of this report is the first of its kind plant-by-plant accounting of the production, use, and releases of chlorine and related pollution around the world. It is intended to inform the efforts of building product manufacturers to reduce pollution in their supply chains.

 

Chlorine is a key feedstock for a wide range of chemicals and consumer products, and the major ingredient of polyvinyl chloride (PVC) plastic. The report includes details about the largest 86 chlor-alkali facilities and reveals their connections to 56 PVC resin plants in the Americas, Africa and Europe. (The second phase of this project will inventory the industry in Asia.) A substantial number of these facilities, which are identified in the report, continue to use outmoded and highly polluting mercury or asbestos.

Demand from manufacturers of building and construction products now drives the production of chlorine, the key ingredient of PVC used in pipes, siding, roofing membranes, wall covering, flooring, and carpeting. It is also an essential feedstock for epoxies used in adhesives and flooring topcoats, and for polyurethane used in insulation and flooring.

Key findings include:

  • In the United States, the chlor-alkali industry is the only industry that still uses asbestos, importing 480 tons per year on average for 11 chlor-alkali plants in the country (including 7 of the 12 largest plants).
  • The only suppliers of asbestos to the chlor-alkali industry are Brazil (which banned its production, although exports continue for the moment) and Russia, whose Uralasbest mine is poised to become the sole source of asbestos once Brazil’s ban is in place.
  • The US Gulf Coast is the world’s lowest-cost region for production of chlorine and its derivatives. It is home to 9 facilities that use asbestos technology, and some of the industry’s worst polluters including 5 of the 6 largest emitters of dioxin.
  • One Gulf Coast facility has been found responsible for chronic releases of PVC plastic pellets into the Gulf of Mexico watershed.
  • The US, Russia and Germany are the only countries in this report that allow the indefinite use of both mercury and asbestos in chlorine production.
  • The world’s two largest chemical corporations – BASF and DowDuPont – have not announced any plans to phase out the use of mercury and asbestos, respectively, at their plants in Germany.
  • Chlor-alkali facilities are major sources of rising levels of carbon tetrachloride, a potent global warming and ozone depleting gas, in the earth’s atmosphere.
  • Far more chlorinated pollution, such as dioxins and vinyl chloride monomer, is released from chlor-alkali plants that produce feedstocks for the PVC industry than from plants that produce chlorine for other uses.

Supplemental Documents:

While attending a 2018 meeting of U.S. EPA’s National Environmental Justice Advisory Council (NEJAC) in Boston, I heard the testimony of Delma and Christine Bennet. They live in Mossville, LA, amidst what is likely the nation’s largest concentration of PVC (polyvinyl chloride) manufacturing facilities. I was there to present the findings of HBN’s inventory of pollution associated with the chlorine/PVC supply chain.

Our study found, among other things, that the Gulf Coast region (which includes Mossville) is home to nine facilities that use outmoded asbestos technology, and home also to some of the industry’s worst polluters: Five of the six largest emitters of dioxins––a long lasting, extremely toxic family of hazardous waste that causes cancer and many other health impacts, are located there. The Bennets reminded the EPA that according to studies by a division of the Centers for Disease Control, Mossville residents have three times higher levels of dioxin in their blood than average Americans, and the dioxin levels found in their yards and attic dust exceed regulatory standards typically used for toxic waste remediations of industrial sites. Even the vegetables in their gardens tested positive for dioxin.

When I think about why we fight so hard to exclude PVC from any palette of green, healthy, or sustainable building materials, I think first of people like Delma and Christine. I then think about the many non-profits, government agencies, and private enterprises dedicated to recycling. Way back in the 1990’s, the industry Association of Plastic Recyclers declared PVC a contaminant to the recycling stream. A generation later, a 2016 study by the Circular Economy evangelist Ellen MacArthur Foundation called out PVC packaging for global phase-out, citing low recycling rates and chemical hazard concerns. Much of the concern about PVC packaging is driven by worries about ocean pollution.  HBN’s study found that at least one U.S. PVC manufacturer is routinely dumping tons of PVC pellets into local waterways and refusing to stop even after being ordered to do so by the state of Texas.

The list goes on. Our report documents the types of industrial pollution in addition to dioxin that could be reduced or avoided by a switch to more recyclable plastics that are not made with the chlorine that is an essential ingredient of PVC, including ozone depleting and potent global warming gasses. HBN’s earlier studies have documented the hazards posed by legacy pollutants that are returning to our consumer products in recycled PVC content––heavy metals such as lead, and endocrine-disrupting plasticizers known as phthalates.

There is a better way.

There is virtually no use of PVC in building products that could not be replaced with another plastic or other material. Indeed, from siding, to wallpaper, to window frames, PVC has displaced materials that are more recyclable, such as aluminum and paper. Because the industry is not held accountable for the environmental health damages wrought in places like Mossville, PVC has artificially low costs that present barriers to entry, or inhibit market expansion of less hazardous, more sustainable alternatives.

That is why PVC should not be part of any building, or any building rating system, that claims to advance environmental and health objectives. It’s not green. It’s not healthy.  It’s not sustainable. It’s just cheap––for us. Because folks like Delma and Christine Bennet pay the true cost.

Know Better

Learn more about the implications of chlorine as a feedstock in plastics in HBN’s Chlorine and Building Materials report.

Research from Healthy Building Network (HBN) documents how vinyl building products, also known as PVC or polyvinylchloride plastic, are the number one driver of asbestos use in the US.

The vinyl/asbestos connection stems from the fact that PVC production is the largest single use for industrial chlorine, and chlorine production is the largest single consumer of asbestos in the US. [1] More than 70% of PVC is used in building and construction applications – pipes, flooring, window frames, siding, wall coverings and membrane roofing. [2] This makes the building and construction industry the single largest product sector consuming chlorine, bearing sizeable responsibility for the ongoing demand for asbestos. [3]

Despite the existence of asbestos (and mercury) free chlorine production methods, the PVC industry has positioned itself at the vanguard of industry efforts to frustrate stronger asbestos regulation. According to Mike Belliveau, the Executive Director of the Environmental Health Strategy Center and a senior advisor to Safer Chemicals Healthy Families coalition, “The PVC market has spurred chemical industry lobbyists to urge the Trump Administration to exempt their use of deadly asbestos from future restrictions.” The last time the vinyl industry positioned themselves so publicly on the other side of common sense, they were defending the use of lead in children’s vinyl lunch boxes.

Among HBN’s Findings:

  • The U.S. chlor-alkali industry (Olin/Dow, Occidental, and Westlake/Axiall [4]) consumed 88% of asbestos imports in 2014, and all asbestos imports in 2016.
  • Three U.S. chemical companies are importing 1.2 million pounds of asbestos per year for use in 15 chlor-alkali plants. PVC used in building products requires an estimated 250,000 pounds of imported asbestos per year.
  • Asbestos miners in Minaçu, Brazil, are literally dying to prop up the U.S. chemical and PVC building product industries’ reliance on asbestos. Dozens of asbestos baggers are dying or have died of asbestos related diseases, according to local reports. [5] Overall, Brazil exports over 13,000 bags of asbestos each year to the U.S. chlorine industry.
  • Occidental Chemical imported 900,000 pounds of asbestos from Oct. 2013 through 2015, but apparently failed to report those imports to the EPA in possible violation of the Chemical Data Reporting rule as required under TSCA.
  • Asbestos imports by Occidental Chemical and Olin Corporation more than doubled from 2015 to 2016, perhaps indicating a stockpiling of asbestos in anticipation of further restrictions on mining in Brazil or use in the U.S.
  • Russia shipped asbestos to Dow in 2014 and to Olin in 2016 (when Olin took over Dow’s U.S. chlor-alkali plants). If the mine in Brazil closes, the U.S. chlor-alkali industry’s backup plan is the massive mine in Asbest, Russia.

The health hazards of asbestos exposure, painful and deadly lung diseases including cancer, are clear. Green building professionals do not have to wait. Do your part to prevent asbestos-related diseases here and abroad. Don’t specify vinyl building products.

SOURCES

1. In the US more than half of chlorine is produced using asbestos, despite the availability of an alternative production method that does not require either asbestos or mercury.

2. http://www.vinylinfo.org/vinyl/uses

3. According to IHS Markit, “A majority of chlor-alkali capacity is built to supply feedstock for ethylene dichloride (EDC) production. EDC is then used to make vinyl chloride (VCM) and subsequently used to manufacture polyvinyl chloride (PVC). This chain, EDC to VCM to PVC, is normally called the vinyl chain. PVC demand correlates closely with construction spending, therefore, it can be concluded that chlorine consumption and production are driven by the construction industry. Hence, chlorine consumption growth depends on the growth of the global economy, since a country will spend more on construction if it has a healthy gross domestic product.” (IHS Markit. “Chemical Economics Handbook: Chlorine/Sodium Hydroxide (Chlor-Alkali),” December 2014. https://www.ihs.com/products/chlorine-sodium-chemical-economics-handbook.html)

4. Fifteen chlor-alkali plants last reported to be using asbestos diaphragms include, in order of estimated chlorine capacity:

    • Olin (formerly Dow), Freeport, Tex. (3,158,000 tons per year)
    • Westlake (formerly Axiall), Lake Charles, La. (1,100,000 tpy)
    • Olin, Plaquemine, La. (1,068,000 tpy)
    • Occidental, Ingleside/Corpus Christi, Tex. (668,000 tpy)
    • Occidental, La Porte, Tex. (580,000 tpy)
    • Occidental, Hahnville/Taft, La. (567,000 tpy)
    • Olin, McIntosh, Ala. (468,000 tpy)
    • Westlake, Plaquemine, La. (410,000 tpy)
    • Occidental, Convent, La. (389,000 tpy)
    • Occidental, Niagara Falls, N.Y. (336,000 tpy)
    • Westlake, Natrium/New Martinsville, W.Va. (297,000 tpy)
    • Occidental, Geismar, La. (273,000 tpy)
    • Occidental, Wichita, Kans. (182,000 tpy)
    • Occidental, Deer Park, Tex. (162,500 tpy)
    • Olin, Henderson, Nev. (153,000 tpy)

5. Carpentier, Steve. “Minaçu, a cidade que respira o amianto.” CartaCapital, May 21, 2013. http://www.cartacapital.com.br/sustentabilidade/minacu-a-cidade-que-respira-o-amianto-8717.html

The recycling industry has made significant strides toward a closed loop material system in which the materials that make up new products today will become the raw material used to manufacture products in the future. However, contamination in some sources of recycled content raw material (“feedstock”) contain potentially toxic substances that can devalue feedstocks, impede growth of recycling markets, and harm human and environmental health.

Since May 2014, the Healthy Building Network, in collaboration with StopWaste and the San Francisco Department of Environment, has been evaluating 11 common post-consumer recycled-content feedstocks used in the manufacturing of building products. This paper is a distillation of that larger effort, and provides analysis on two major feedstocks found in building products: recycled PVC and glass cullet. This research partnership seeks to provide manufacturers, purchasers, government agencies, and the recycling industry with recommendations for optimizing the use of recycled content feedstocks in building products in order to increase their value, marketability and safety. This report was prepared in support of a research session at the 2015 Greenbuild conference in Washington, DC.

New HBN research reveals that legacy toxic hazards are being reintroduced into our homes, schools and offices in recycled vinyl content that is routinely added to floors and other building products. Legacy substances used in PVC products, like lead, cadmium, and phthalates, are turning up in new products through the use of cheap recycled content.

Funding for research on post-consumer PVC feedstock was provided by StopWaste and donors to the Healthy Building Network (HBN). It was conducted using an evaluative framework to optimize recycling developed by StopWaste, the San Francisco Department of the Environment, and HBN. This briefing paper on post-consumer recycled PVC is a prequel to a forthcoming white paper by this new collaboration.

This paper was prepared by Perkins+Will, in partnership with Healthy Building Network (HBN), as part of a larger effort to promote health in the built environment. Indoor environments commonly have higher levels of pollutants, and architects and designers may frequently have the opportunity to help reduce or mitigate exposures.

The purpose of this report is to present information on the environmental and health hazards of PVC, with an emphasis on information found in government sources. This report is not intended to be a comprehensive analysis of all aspects of the PVC lifecycle, or a comprehensive comparative analysis of polymer lifecycles. Rather, in light of recent claims that PVC formulas have been improved by reducing certain toxic additives, this paper reviews contemporary research and data to determine if hazards are still associated with the lifecycle of PVC. This research has been surveyed from a perspective consistent with the precautionary principle, which, as applied, means that where there is some evidence of environmental or human health impact of PVC that reasonable alternatives should be used where possible. Furthermore, and more generally, this paper is intended to build greater awareness of this common building material.

Home Depot, the world’s largest purchaser of building products, announced that by the end of 2015 it will eliminate phthalate plasticizers from the vinyl flooring it sells.

Phthalates are endocrine disrupting chemicals that have been banned in children’s products since 2008 but are still widely used in a wide range of vinyl products to make them flexible.

The announcement came after lengthy negotiations led by the Mind The Store Campaign, a grassroots effort supported by the Healthy Building Network’s (HBN) cutting-edge research on building products.  Mind The Store is challenging the country’s largest retailers to restrict 100 hazardous chemicals in the products they sell. Also today, the Mind The Store campaign released a report identifying phthalates and other chemical hazards detected in vinyl flooring products.

HBN first addressed the issue of phthalate substitution in polyvinyl chloride (PVC or “vinyl”) flooring in our 2014 report, Phthalate-free Plasticizers in PVC.  The HBN analysis was intended to help purchasers evaluate the claims of phthalate-free product lines in order to make informed choices about a wide array of materials including flooring, wall guards and coverings, wire and cabling, upholstery and membrane roofing.  And it worked: the report helped to convince Home Depot that change was possible in short order.  Now that Home Depot has acted, the whole industry will surely follow.

And what a relief it will be for people who live, work and play on vinyl floors. PVC sheet floors can contain over 20% phthalate plasticizers. These semi-volatile organic compounds readily migrate from flooring into dust and are inhaled by building occupants. Researchers are finding that exposures to phthalates occurs in the womb as well as after birth, and can impair the development of lungs and immune systems. This disruption in turn can lead to the development of asthma, as we first reported in 2004, and genital deformities in boys.

For over a decade now, leading green designers, architects and building owners have taken a precautionary approach, avoiding PVC building products in commercial buildings as evidence grew of the many toxic impacts associated with PVC and its additives. As a result, phthalate-free formulations of vinyl floor and wall coverings began appearing in this market a few years ago. Home Depot’s leadership marks a tipping point that will bring these products to everyone.

This Healthy Building Network (HBN) Research Brief examines replacements for phthalate plasticizers in Polyvinyl Chloride (PVC) building materials. Plasticizers are added to PVC to make it flexible, but since they are not tightly bound to the PVC molecules, they migrate from PVC products.

Phthalates, the most commonly used plasticizers in PVC, are known endocrine disruptors – chemicals that interfere with hormone signaling, which is especially critical to early childhood development. Additionally, many phthalates are known carcinogens and reproductive and developmental toxicants. Exposures to these toxic plasticizers from PVC products can occur throughout their lifecycle. Therefore, it is crucial that PVC products containing phthalate plasticizers be eliminated from the built environment.

Fourteen residents of McCullom Lake Village, Illinois (population 1,000) have brain cancer.

The incidence in the US population is 4 in 100,000.[1]  This is the largest brain cancer cluster identified in a non-occupational setting. In epidemiological terms, the chance that this is a coincidence is something like your chance of winning the lottery.  It’s far more likely that the 14 victims share some sort of common link. The evidence in this case points to the vinyl chloride in the groundwater flowing into their wells from a nearby factory that made vinyl food wrap.[2]

Aaron Freiwald is an attorney representing the cancer victims in a class action lawsuit against Rohm & Haas, which bought the suspect facility from the Morton Chemical Company in 1999. According to Freiwald, “By the time we are done with this case, the association between vinyl chloride and brain cancer is going to be much stronger. They are going to have to revise the way current textbooks discuss cancer risks associated with vinyl chloride.”

One critical factor in the case is the clear connection between the vinyl chloride and the cancers.  It can be difficult to prove a specific chemical causes a specific cancer because so often people have multiple exposures to carcinogens.  But, Lake McCollum is an isolated community.  There are no other significant industrial sources of chemical contamination to which the 14 victims have been exposed.  According to the International Agency for Research on Cancer (IARC), vinyl chloride is carcinogenic to humans and has been associated with brain cancer.

Improved methods of analyzing DNA allow scientists to compare cancer cells in ways not available in earlier cases – such as the case of vinyl chloride plant worker Dan Ross featured in the PBS documentary Trade Secrets, and HBO’s Blue Vinyl.   This new DNA analysis shows that the damage to brain tissue among the Illinois victims is strikingly similar, and that this pattern is different from other types of brain cancers – further evidence of a common local cause. 

Freiwald is most excited by what his investigation has uncovered about industry-sponsored studies of vinyl workers. These have been the backbone of the vinyl industry’s defense that there is at best a “weak statistical correlation” between vinyl chloride exposure and brain cancer.  The industry studies have long been criticized for having diluted the surveyed worker population with employees unlikely to have been exposed to vinyl chloride. “Our questioning of industry experts under oath,” says Freiwald, “has brought to light evidence that is going to strike at the heart of the whole industry’s defense of vinyl chloride.”

In depositions taken as part of this case, Freiwald says that industry experts acknowledged that had just one more case of cancer been identified in the worker population that was studied, the conclusion would have changed from a “weak statistical correlation” at best to a “statistically significant” correlation. 

The McCollum case reminds us that the many problems associated with chlorinated materials, such as PVC plastic, are likely under-estimated, masked by the limits of scientific investigations to date, and obscured by the intensive cigarette science campaigns of its manufacturers.

SOURCES

  1. According to Freiwald, the number of glioblastomas (the dominant brain cancer in this group) is 3-4 per 100,000.  The number of oligodendrogliomas, the second and related type of brain cancer among the victims, is 0.3 cases per 100,000.  The number for all “brain and CNS” cancers, which is a more inclusive group of diseases, is 7 in 100,000. 
  2. The chemical alleged to have been released into the Lake McCollum’s groundwater is known as dichlroroethylene, or 1, 1-dce, which undergoes reductive dechlorination to vinyl chloride in groundwater and landfills.

In Doubt Is Their Product, Dr. David Michaels, a former Assistant Secretary of Energy for Environment, Safety and Health under President Clinton, exhaustively documents the rise of the “product defense industry” and its strategy of using scientific discipline to establish controversies (i.e., starting something that is intended to continue or be permanent[1]), rather than establish facts (i.e., investigating something to confirm its truth or validity[2]) as a means of frustrating efforts to address public health risks from asbestos, benzene, aspirin (Reye’s syndrome in children), global warming and, of course, vinyl.

“Doubt is our product,” wrote a Brown and Williamson[3] executive in 1969, three years after the iconic warning label first appeared on cigarette packs, “since it is the best means of competing with the ‘body of fact’ that exists in the minds of the general public. It is also the means of establishing a controversy.”[4]

Michaels concentrates his reporting on his considerable first-hand experiences where, he writes, “I had the opportunity to witness what is going on at close range.”[5] He bears witness for 256 pages and backs up his observations with an additional 119 pages of endnotes, many of these referencing original documents that can be accessed through his website, www.defendingscience.org.

One of his first-hand experiences involves polyvinyl chloride plastic, also known as PVC or vinyl. The story of the vinyl industry’s cover-up of rare cancers among its workers in the mid-1970’s has been well documented elsewhere[6], including the documentary Blue Vinyl and the PBS investigative report Trade Secrets. Michaels connects the dots, documenting how, in 1974, the same public relations firm that created the “selling doubt” strategy for the tobacco industry would “establish uncertainty” about the risks of vinyl chloride for the PVC industry. They’re still at it.

Doubt Is Their Product concludes with a chapter offering “a dozen ways to improve our regulatory system.” Many of these could be adapted by green building policy makers or by anyone interested in testing whether an industry stakeholder is interested in establishing the facts, or just establishing a perpetual controversy.[7

SOURCES

  1. Encarta® World English Dictionary ©1999 Microsoft Corporation.
  2. Ibid.
  3. Brown & Williamson was an American tobacco company and subsidiary of the giant British American Tobacco, that produced several popular cigarette brands including: Kool, Lucky Strike, Pall Mall and Viceroy. It became infamous as the focus of investigations for chemically enhancing the addictiveness of cigarettes. Its former vice-president of research and development, Jeffrey Wigand, was the whistleblower in an investigation conducted by the highly respected CBS news program 60 Minutes, an event that was dramatized in the film The Insider. Wigand claimed that B&W had introduced chemicals such as ammonia into cigarettes to increase nicotine delivery and increase addictiveness. Brown & Williamson had its headquarters at Louisville, Kentucky until July 30, 2004, when the U.S. operations of Brown & Williamson merged with R.J. Reynolds, creating a new publicly traded parent company, Reynolds American Inc. Source: http://en.wikipedia.org/wiki/Brown_and_Williamson.
  4. Doubt Is Their Product, p. 11, footnote 43, document available at http://legacy.library.ucsf.edu/tid/nvs40f00.
  5. Doubt Is Their Product, Introduction, p. x.
  6. See, e.g. Deceit and Denial: The Deadly Politics of Industrial Pollution. Gerald Markowitz and David Rosner. University of California Press, 2002. See also Toxic Sludge is Good For You and Trust Us We’re Experts, both by John Stauber and Sheldon Rampton, and The Republican War on Science, by Chris Mooney.
  7. These include e.g., (#1) Require full disclosures of any and all sponsor involvement in scientific studies; (#3) Manufacturers must disclose what they know about the toxicity of their products; (#5) Hold real people accountable for the accuracy—and completeness – of statements of corporations and trade groups.