Demystifying the Opacity of Ingredient Hazard Transparency
The idea that we should all transparently know the health and ecological risks of the ingredients in products we purchase is a sound and desirable one. But it is how we interpret and deal with the relatively ‘opaque’ and highly complex chemistry and toxicological information that transparency reporting makes available that is where we run into troubles.
Having toxicological Information is one thing, understanding, accessing and using it effectively and efficiently to inform product choice and determine healthiness, is a completely different thing. Given that toxic precursors exist in many products but don’t appear in the final product, is it reasonable to expect every purchaser or specifier to learn and deal with organic chemistry and human and ecological toxicology just to choose a sustainable product? I suggest not.
As a practising architect in 2015 when I first heard about the ingredient hazards transparency movement my initial reaction was, “wow, that’s fantastic, what a great initiative!” It was only a little while later I realized the implications and what dealing with the hugely detailed chemical and toxicity hazard information would encompass. There was a strong sense of déjà vu associated with that realization.
Many years before the development of our Global GreenTag Certification Marks and processes, as an early healthy eco-design practitioner in the 1980s I had the need to ask manufacturers what was in their products, only to be told “no, sorry that’s commercial in confidence”.
I learned a few years later in the mid-late 1990s when I was the sustainable materials consultant to a number of the Sydney 2000 Olympic “Green Games” venues that all you needed was commercial leverage to get those same manufacturers to answer the same question with “Yes Mr. Baggs, what would you like to know?” It was only once I gained access to that information that I realized it was of little value with the architectural skillset I possessed at the time so then began a brand new education process and indeed eventually a whole new professional direction.
It took nearly 15 years of being involved with trying to understand the topic and issues myself and then communicate human health and eco-toxicology to the profession and clients, to reach the point where, as a company, my Co-founder/Director Mary-Lou Kelly and I, decided to try and short circuit the need for the entire Architecture, Design and Construction (AD&C) sector having to effectively become toxicologists by doing the hard work for them.
We eventually ended up not only researching and publishing ingredients lists and their hazards, but also undertaking a multi-stage risk analysis process to be able to report not only on worker health risk but most importantly for AD&C clients, outcomes for the end user, the ‘in use healthiness’ of products for clients.
In that process, we moved from just checking and reporting ingredient hazards and toxicology, and verifying manufacturers' claims as Ecospecifier (a sustainable product database) in 2003, to developing and launching Global GreenTag Certification (and various country databases) from 2007-2010, to developing and launching our own product ingredient hazards transparency report with risk analysis assessment under the name of the Global GreenTag Product Health Declaration (GreenTag PHD) in early 2017.
In late 2018 we developed and added the product ‘healthiness in use’ rating HealthRATE™, that looks at the toxicology of products as they exist after all the chemical reactions in the manufacturing have been completed. One of the issues uppermost in end users’, consumers’ and homeowners’ minds when they are looking to buy products is to answer the question “what effect will this product have on me, my colleagues or family?”
There is no doubt that protection of worker health and before that minimization of environmental risk are also major considerations, but we believed that each of these things should be considered and reported in their own right. Further, we determined that information needed by anyone should be readily accessible and it should not be left to architects, designers, builders, end users and consumers to have to try and figure the chemistry and toxicology all out for themselves.
After all, who knows what complex reactions occur when a range of chemicals are combined together? Organic chemists for sure, but virtually no-one else. For instance, where would the modern world be without plastics? Plastic polymers involve complex reactions and many such as epoxies, polyurethanes, polystyrenes, polycarbonates and PVCs have toxic precursors, such that when they are reacted together they typically result in more or less benign polymers that are used extensively and in general, safely.
We certainly want to minimize toxics in the environment, and develop lower toxicity processes, so GreenTag PHDs communicate ingredient hazards (as classified by the UN Globally Harmonized System (GHS) and the EUs REACH program) using the most stringent of the LEED and WELL compliant declaration thresholds i.e. 100ppm (0.01%). Actually GreenTag PHDs go deeper to 100ppm of each ingredient, so we can understand the risks to workers in the factory we are assessing. There is a significant list of banned ingredients right from the outset as well.
Recently we joined the Health Product Declaration Collaborative (HPDC) with the intention of more closely aligning the information and processes embodied by the hazard transparency aspects of our PHDs with their HPD program to more closely harmonize the information experience for USA and North American practitioners already used to the HPD program.
That said, the major benefit for any user of GreenTag PHDs and its HealthRATE™ rating TAG is that the ingredient hazard information is then risk assessed by a combination of both remote and onsite audits and risk assessments that enable color radar diagrams to be published on a percentage content basis for High Risk, (RED), Medium-High Risk (ORANGE), Low-Medium Risk (YELLOW), and Negligible-Low Risk (GREEN) ingredients relating to both worker health and end user ‘healthiness in use’. A BLACK color chemical rating also exists, but you will not see it in any GreenTag PHD because that designates a Banned Ingredient. GREY colors indicate that either the chemical effects are unknown, or are not able to be fully identified. In either case, a notation will exist in the interpretive table as to which reason the GREY Category is applied. This means one can see ‘at a glance’ by reviewing each of the three separate color radar strips, how environment, worker, and end user health is potentially affected.
So there is no need to wonder any longer how robust the information is and e.g. why a “RED” ingredient hazard became a ‘GREEN’ outcome:
- because every assessment is externally peer reviewed by an independent third party consultant toxicologist before the PHD is published; and
- to assist the reader understand how these changes in classification come about, each PHD includes a comprehensive plain language explanation, also externally peer reviewed.
As an example of this process, let’s say we are assessing a paint which uses titanium dioxide as a whitening agent. At a ‘Hazard of Ingredient’ level assessment titanium dioxide is an IARC ‘Category 2B Carcinogen’ and would be identified as a RED classification element and potentially (and unnecessarily) lead to misunderstandings of the hazards involved because the ‘Category 2B Carcinogen’ risk for titanium dioxide is for when it is breathed in as a dust. At no time during the application or processing of the finished paint is the ‘at risk’ ingredient present in the form that provides the risk. Even when being sanded the titanium in encapsulated in the dried paint polymer. So the ‘Category 2B Carcinogen’ risk is never present for the end user or occupant and this risk only is involved in the factory where liquids are added to the titanium dioxide powder and the mitigation process and risk assessment is likely to rule out the hazard at this point. This is also due to the material being delivered, transported and mixed into paint inside sealed processes where no worker is expose to the risk. This would be fully explained in the PHD.
The HealthRATE™ rating on a PHD is then made available to manufacturers as a ‘HealthRATE™ TAG’ for separate use on the product packaging and marketing. This is the ultimate in end user or consumer purchasing power, a single TAG result instantly informing the purchaser how healthy the product is for them and their family or colleagues, at the point of sale or specification, and a graphic representation of the outcome of the deep and robust peer reviewed toxicological science underpinning the product.
From 2020 a whole range of asthmagens, identified by the Association of Occupational and Environmental Clinics will be included in the risk assessment process allowing products free of identified asthma trigger chemicals to be able to use the additional claim ‘asthma preferred’ or similar.
Ingredient hazard transparency reporting makes toxicological analysis available to anyone who has the expertise or who wants to put in the work to properly understand the chemistry and toxicology of a product.
The question to ask yourself is “Would I prefer to learn chemistry and toxicology to that level of detail to take on the risk of that assessment personally, or would I prefer to have experts do that work for me and be able to get on with the work I’m trained for?”
If I had that opportunity to live again, I know what I would prefer, and as an architect, it would not involve learning toxicology (as interesting as it is)! What is your preference?
Contact: David Baggs
CEO and Program Director of Global GreenTag International Pty Ltd & Director Global GreenTag LLC (USA)
David was voted one of Australia’s Top 50 Green Leaders and Top 100 Sustainability Leaders Globally. David is a world-renowned sustainability and materials expert, Life Fellow of the Australian Institute of Architects, award winning green building architect, author, LEED AP, Lead Auditor, GBCA Materials Expert Panel member , Member American Chemical Society and Past President of Australian LCA Society.
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Global GreenTag Type 1 Certification assists selection for green infrastructure, building and interiors products by rating performance. GreenTag is an EPD and Product Health Declaration Program Operator globally recognised in WELL Equivalencies & compliant with LEED providing a ‘one stop’ evidence process as well as Green Star ANZ & Africa.
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