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Author Jeff Church
Association Manager
Plastic Pipe and Fittings Association (PPFA)
jeffc@cmservnet.com
www.ppfahome.org
 
Comment
General Comments: The Plastic Pipe and Fittings Association (PPFA) appreciates the opportunity to comment on the draft “Assessment of Technical Basis for PVC Related Materials Credit in LEED”, prepared by the U.S. Green Building Council (USGBC) PVC Task Group. We commend USGBC for its use of a scientific approach to this complex issue, as well as its courage to base its findings on facts rather than being swayed by external pressures or misguided negative sentiment.

The PPFA supports the conclusions that a substantial body of evidence from LCA and risk assessment studies have shown in the report. The Task Groups report does not support the supposition that PVC is consistently a worse choice than alternative materials on a life cycle environmental or health basis and obviously does not deserve a negative credit . While the PPFA supports the technical, lifecycle-based approach used by the Task Group as an appropriate method for comparing the potential environmental impacts of PVC and competing materials the 50 year time period chosen still does not give full advantage to PVC pipes. To take full advantage of PVC’s durability a more appropriate time period for rigid vinyl pipe would be 100 years. We also believe that cost-benefit analysis should be a significant part of the deliberation when comparing alternative construction products, as this promotes the expansion of “sustainable building” in our society. Cost savings, applied in other construction choices such as better insulation or more efficient appliances, will result in other benefits to the overall building and cannot be ignored in such a study.

The PPFA has noticed, that since the initial report has been presented, at least one error has been reported that would further benefit all vinyl products.. The error relates to the application of RfD values for vinyl chloride and ethylene dichloride. “The correction made by USGBC produced lower values for non-cancer risk (HI values) for these compounds, resulting in lower overall HI value for manufacture of vinyl resin than was originally reported.” The PPFA encourages the USGBC to correct any observed errors such as this, and to explain the ramifications of the error to interested parties (USGBC members, meeting and exhibition attendees, and activist groups). The PPFA hopes the Task Force Report does not degenerate into a moving target for anti-vinyl special interests to repetitively attack with unfounded information for years to come.. To avoid this from developing into a wasteful distraction, the report, after going through the necessary USGBC processes, should be “closed.” It is our belief that a “closed” report should not be reopened. When new information warrants additional studies, a new Task Force (on any material or process, etc.) would be formed to consider all materials equally.

While the PPFA generally supports the approach outlined by the PVC Task Group and definitively supports USGBC’s goals to improve the environmental impact of buildings, we are troubled that it was felt that PVC had to be singled out for review. PPFA believes it is in the best interest of the environment for USGBC to create Task Groups to review the lifecycle of all building materials, products and applications in a fair and balanced manner. Without like Task Groups for other materials, a fair and unbiased consensus process is undermined.

In conclusion, the PPFA is confident that the many benefits of PVC and other plastic pipes allow them to favorably compete against other building materials when evaluated by fair, scientific principles that consider all factors, including cost and performance across their total lifecycle.