RFCI Product Transparency Declaration Challenges Health Product Declaration

The Resilient Floor Covering Institute (RFCI) recently announced their new Product Transparency Declaration (PTD). The introduction of the PTD as an alternate to the Health Product Declaration (HPD) for reporting the chemical ingredients of building products is anticipated to stimulate dialogue about the need and use of detailed chemical hazard information in architectural design.

For background, RFCI is a nonprofit industry trade association representing the manufacturers of most of the resilient flooring sold in North America. In 2005, RFCI initiated FloorScore®, a certification program that identifies flooring products that meet the indoor air quality (IAQ) requirements for emissions of volatile organic compounds (VOCs) according to CDPH Standard Method V1.1 (often referred to as CA Section 01350). This is a true third-party certification program in which RFCI is the brand owner and the certification functions are performed by an accredited certification body, SCS Global Services. Berkeley Analytical tests products for FloorScore and was the first accredited third-party testing laboratory recognized by the program. About 1,600 products are now FloorScore certified. These products include vinyl tile, vinyl composition tile, sheet vinyl, luxury vinyl tiles and planks, rubber, polymeric, and linoleum flooring products along with accessories such as wall base, moldings, stair treads, and adhesives.

The measurement of VOC emissions addresses many of the risks associated with inhalation exposures of building occupants to product-related toxic chemicals. However, the potential hazards of product ingredients are being questioned and there is an increasing demand by architectural firms and others for disclosure of such information. The issue of transparency of product ingredients is being addressed by several different programs. The best known is the Health Product Declaration (HPD), which is a program introduced by the HPD Collaborative. The HPD™ Open Standard provides a standardized format for reporting of product ingredients and identifies a collection of reference lists to determine if there are embodied health and environment hazards associated with these ingredients. Hazards are determined based on GreenScreen v1.2 categories plus several additional endpoints.

The PTD was developed by RFCI as their response to the ingredient transparency question and to provide architectural specifiers with what they consider as more actionable information than does an HPD. The clear emphasis of the PTD is on the use phase of the product (i.e., exposures to installers and building occupants) as all of the referenced lists of substances are related to chronic human health endpoints such as cancer and reproductive toxicity. On the other hand, the HPD includes additional health impacts and extends to environmental concerns such as ecotoxicants, global warming potential and ozone depletion. A significantly unique feature of the PTD, not included in the HPD, is that it lets specifiers know if the product needs to be labeled for exposure risk as required by OSHA HCS 2012 (i.e., Globally Harmonized System of Classification and Labeling) or California Proposition 65. The PTD referenced lists of toxic substances are:

• IARC – International Agency on the Research of Cancer Terminology; Group 1 – Carcinogenic to Humans, Group 2A – Probably Carcinogenic to Humans, and Group 2B – Possibly Carcinogenic to Humans

• NTP – National Toxicology Program – Known Human Carcinogens and Reasonably Anticipated Carcinogens

• OSHA – Occupational Safety and Health Administration – Regulated Toxic Metals or Carcinogens

• Prop 65 – California Proposition 65 – Known to cause cancer or reproductive toxicity

• USEPA TRI – Toxic Release Inventory – Persistent, bioaccumulative and toxic (PBT) chemicals- Known persistent, bioaccumulative, and toxic chemicals and compounds

• REACH Substances of Very High Concern – Candidate List of Substances of Very High Concern

• Plus – Cadmium, hexavalent chromium, lead and mercury must be reported if used as ingredients

Section A of the PTD requires the manufacturer to list the intentionally added product ingredients and to identify if an ingredient is on any of the lists. All of the ingredients above 1% by weight are listed in descending weight order although the actual percent of each ingredient does not need to be disclosed. Ingredients identified as potential carcinogens, mutagens, or reproductive toxins are reported to a minimum of 0.1% by weight (1,000 ppm) or lower if required by the OSHA hazard communication standard. Section B indicates whether a hazard warning is required and provides the specific warning language. Section C discloses whether the product meets the VOC emission acceptance criteria of CDPH Standard Method V1.1 and for wood products if it meets the formaldehyde emission requirements of the California Air Resources Board Airborne Toxic Control Measure for Formaldehyde (ATCM). For adhesives, manufacturers must report if the product is compliant with VOC content regulations. Declarations are signed by an authorized company representative.

The RFCI PTD webpage cites titanium dioxide (TiO2) as an example of how the PTD distinguishes risk from hazard and provides actionable information to specifiers. TiO2 is an IARC possible human carcinogen and is listed on Prop 65. Thus, the hazard will be identified. However, TiO2 is not a risk in the use phase because it is in bound form and there is no significant inhalation exposure to TiO2 particles. Because the risk is negligible, no warning is required.

Product transparency with respect to chemical ingredients is a rapidly evolving movement in architectural design with some big issues that need to be addressed: 1) What is the primary purpose of disclosure – is it the health of occupants or is it more related to other life-cycle impacts? 2) What liabilities are architectural specifiers assuming when they obtain detailed chemical hazard information? 3) How will specifiers interpret and use this information? And 4) How willing are manufacturers to supply the information? Here, the answer probably depends upon the industry. For most flooring categories there may not be that many trade secrets, but product formulators (e.g., paints and coatings manufacturers) often fiercely guard their recipes. The introduction of the PTD is anticipated to increase the dialogue and may force answers to some of these questions.

Al Hodgson; November 1, 2013

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