By Colin Hartke
Update: Read the comments that Toxic-Free Future, Healthy Building Network, and Natural Resources Defense Council submitted to the Department of Commerce Evergreen Sustainable Development Standard Team.
From PFAS to toxic flame retardants, dangerous chemicals harmful to health are in the materials used to build housing, including affordable housing. These chemicals don’t stay put in flooring, insulation, and other materials; they get into indoor air and dust. This means that families and communities are exposed to toxic chemicals even at home.
We can eliminate these dangerous chemicals from building materials so that affordable housing provides a safe place to live. In Washington State, the Department of Commerce (DOC) has the opportunity to protect the health of people living in affordable housing by adding strong protections to the Evergreen Sustainable Development Standard (ESDS). The Department of Commerce is currently updating this state-wide regulation that governs construction and remodeling of affordable housing that gets state funding. But the draft of the updated standard lacks important protections to eliminate harmful and long-lasting chemicals. There’s still time to take action by voicing support for restrictions on toxics.
With our Safer Products for Washington law, Washington State is a leader in addressing toxic chemicals in products and finding safer substitutes—and where they can, all Washington agencies need to adopt this approach to protect us from toxics. The draft update of the Evergreen Sustainable Development Standard recognizes that it is important to minimize materials that have toxic chemicals, but it falls short of making sure they are absent. Instead, it makes the use of materials without the chemicals an optional way to meet overall requirements. While we enthusiastically support the recognition of the danger that toxic chemicals present, we know that eliminating these chemicals is the best way to protect the health of people living in affordable housing. By taking this action, Washington State would help lead other states towards the use of safer building materials in affordable housing.
There’s clear evidence that these toxic chemicals hurt the public’s health. With manufacturers now producing healthier alternatives, there is no reason to continue using materials that contain these harmful chemicals.
In addition to not having strong enough protections for certain chemicals, the draft update of the Evergreen Sustainable Development Standard is weaker than the national criteria it’s based on when it comes to protections against lead in drinking water—the draft Washington standard leaves out the national requirement to identify and replace lead water service lines. The update of the Evergreen standard must include this requirement.
We have the chance to take action and show the DOC that it is critical to have stronger protections against toxics in affordable housing.
We are asking the DOC to include the following requirements in the Evergreen Sustainable Development Standard, and we’re asking for your help. We know that the more people who speak up, the more likely we are to convince the state to take action to protect residents of affordable housing.
Restrict two-part spray foam insulation: Unhealthy chemicals, such as organohalogen flame retardants and diisocyanates are found in two-part spray foam insulation. This type of insulation is commonly used in affordable housing. Research shows that the type of organohalogen flame retardants often found in this type of insulation may harm the thyroid and nervous system development. They are also closely related to two other organophosphate flame retardants that are carcinogens. Other forms of insulation are available that do not contain these dangerous chemicals. DOC must protect residents of affordable housing and air and water quality by adding a mandatory requirement to avoid the use of two-part spray foam insulation.
Eliminate PFAS in Carpet: When carpets include PFAS chemicals, the people living in the buildings are exposed to the dangerous toxics. At the same time, water, air, and soil are contaminated by their production and disposal. PFAS chemicals are linked to immune system harm, organ toxicity, and increased cholesterol and cancer. Carpets are believed to be one of the largest contributors to PFAS in indoor air, and this has been associated with higher PFAS in people’s blood. Carpeting without PFAS is available. Many larger carpet manufacturers and retailers like Lowe’s and Home Depot have banned PFAS in carpet, making it easy to find healthier alternatives. The Department of Ecology has identified PFAS as a priority product to be regulated under the new Safer Products for Washington Act so the DOC should include a mandatory requirement to avoid the use of carpet with PFAS.
Restrict APEs in Paint: Alkylphenol ethoxylates (APEs) are known hormone disruptors, and there are concerns about a range of health impacts, including reproductive, nervous system, and immune effects. APEs break down into persistent chemicals such as nonylphenol and octylphenol that also have a toxic effect on marine life. National paint brands have introduced APE-free paints, making it possible to eliminate their use. Due to the impact that APEs have on the health of people and wildlife, we want a mandatory requirement to avoid its use.
Eliminate Ortho-phthalates in Sealants: Ortho-phthalates have been linked to serious health problems, including obesity, reproductive harm, altered physical development, and asthma. They are commonly used in sealants, but healthier alternatives are available today. We want a mandatory restriction on ortho-phthalates to be added to the Evergreen Sustainable Development Standard.
Require Lead Service Line Identification and Replacement: When people are exposed to lead, it can harm nearly every human body system, with impacts ranging from slowing children’s growth and development to behavioral and learning problems. Children are the most vulnerable to lead’s harm, particularly its devastating effects on brain development, and no safe level of lead exposure has been identified. The danger of lead in drinking water became a national issue when Flint, Michigan’s water system became unnecessarily contaminated with lead. The draft of the Evergreen Sustainable Development Standard falls short of the protection from lead in water included in the national criteria that it is based on. We believe Washington’s standard must include the national criteria, and require the identification and replacement of lead service lines.
Add Ingredient Transparency as a Criteria: To avoid toxic chemicals that damage health, housing developers need to know what chemicals are in products they may choose. The national standard that forms the basis for the Evergreen Sustainable Development Standard includes ingredient transparency as an optional criterion, but the draft of the Washington state standard lacks this. Health Product Declarations, which list product ingredients, are a key tool for builders to make safer choices, and this should be reflected in the standard.