Red List Mania: Three Ways to Make Chemical Avoidance Guides Work Better

This Venn diagram shows the overlap of various "red lists" that recommend chemicals to exclude from building products. Courtesy Healthy Building Network

A "red list" of chemicals is supposed to make the screening process simple. But with so many red lists popping up, which ones should you trust?

If you're one of the many people becoming increasingly concerned about chemical hazards found in building products, you might turn to a "red list" of chemicals for help in your screening process. Red lists have been proliferating, and whose should you trust? How does the Living Building Challenge red list of chemical hazards match up with the list associated with the LEED Pilot Credit 11? What's covered by the Perkins+Will Precautionary listthat isn't covered by the others?

Visualizing the complexities

Tom Lent from Healthy Building Network (HBN) has given me liberty to share this incredible Venn diagram that he developed, in which he's shown a host of pertinent chemical hazard lists and how they relate to each other. I want to share it here not just because it's an amazing diagram that anyone who cares about these issues should have on hand, but also to illustrate a few additional points. For one, the chart shows how attention to chemical hazard concerns has increased over the years--and how far behind federal regulators are in addressing these concerns. The U.S. EPA is currently extremely limited in its ability to regulate hazards. There are numerous efforts to address the situation at the state level, but national efforts like Senator Lautenberg's Safe Chemicals Actbill, move a lot slower.

Red-listing is harder than it looks

The design community has stepped up to fill in the gap. Green Guide for Health Care, Perkins+Will Precautionary list, the Living Building Challenge, and most recently, LEED, have all provided their own lists. There are more lists that we could challenge Tom to artfully add to his diagram. Many standards and certifications for green building products also use red lists--but they're each somewhat unique in both the chemicals on the list and the rules about when and how those lists are used. (For more detail on that, see our special report Green Building Product Certifications, and the EBN article What's New in Multi-Attribute Environmental Certifications.) Closer to home, our company's GreenSpec guide to green building products doesn't use a red list per se --there isn't a list of chemicals that automatically knocks outs a product. No, not even PVC--a common target of red lists. We keep an eye out for all the hazards captured in this diagram, but what we do with that information depends on what else is a key concern for the product category, the degree of hazard represented, and how bad the alternatives are. It really depends on the product category. For example, we decided long ago not to list electrical wire at all until someone made a halogen free ROHS compliant wire (now available), because the hazard concerns were significant and there wasn't another key environmental differentiator between wiring products. However, we list PVC framed windows with a unit U-factor of 0.20 (a higher efficiency threshold than windows with other framing) and we list a PVC-based flashing productfor which there is currently no equivalent, because we believe the unique performance benefits are paramount.

How to make it better

Making use of a red list can be an important step in starting to incorporate hazard concerns into designer's work. The EBN article Chemistry for Designers, is our effort to help our readers understand these red lists and add context for making decisions in practice. Ultimately there are a few other things we'd like to see happen:

1. Greater disclosure. It's hard to assess constituent hazards for a product if you don't know what's in it. We do the best we can while working toward ever greater transparency and clearer reporting standards, in partnership with HBN. HBN has been diligently working with manufacturers to get more complete disclosure of contents for listing in its Pharos directory of products. When designers make Requests For Information through the Pharos system, manufacturers hear a clear message from their customers.
2. Stronger national regulation. While clear market signaling can make a big difference and move us toward cleaner products, we need industry-wide shifts, which are hard to get without regulation. Too often innovation toward healthy products happens in response to international regulations like REACH, leaving both domestic manufacturers who can't sell in those markets, and domestic consumers, who still can't buy the healthier alternatives, in the lurch. A clear regulatory signal gives all manufacturers an even playing field; so healthy products are not just a niche high-end market but standard practice. A glance again at Tom's diagram reminds me that federal clarity is also important for everyone's sanity.
3. Focus on hazard characteristics and greener lists. While a good first step, ultimately we need to get beyond a red-list mentality. First by focusing on hazard endpoints (as illustrated by broadest circle--the Pharos part of the chart). Instead of replacing a listed carcinogen for an unlisted carcinogen we need to be assessing the hazard profile for all constituents and avoiding those that have the hazard characteristics of concern.

Focus on the positive

Going further, we need to be manufacturing and designing with a "green list" in mind: substituting chemicals and materials that are inherently safer, ideally with a long history of use (so as to not introduce completely new hazards (For example, we've written about emerging nanotechnology concerns). The Green Screen for Safer Chemistry by Clean Production Action provides benchmarks for rating chemicals on their hazard characteristics to point toward inherently safer and informs the Pharos scoring protocols that rank building products on the hazard characteristics of their contents. In the meantime, this is a really cool diagram that I hope helps you understand what each list does and doesn't cover should you be considering adopting a red list in your own work.