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Author Gabe Wing
Chemical Engineer
Herman Miller
gabe_wing@hermanmiiler.com
www.hermanmiller.com
 
Comment
Response to the USGBC Draft Report on PVC

Herman Miller would like to thank the USGBC for its efforts to develop a methodology for assuring that building products and materials are sustainable. We also appreciate the opportunity to participate in this process and provide comments on the draft report from the PVC Task Group.

Herman Miller is concerned that the precedent being established by the USGBC’s PVC Task Group will reduce the incentive in the marketplace to develop innovative and sustainable materials and products. The life cycle analysis (LCA) methodology used to characterize PVC, and the resulting decision that PVC cannot be proven to be any worse than other materials, clearly illustrates the need to modify this process. Herman Miller recommends that a hazardous and toxic material evaluation becomes a requirement in any assessment methodology proposed by the USGBC. As a member of the US Green Building Council, we recommend that alternative approaches to material selection and product design such as Cradle to Cradle be used to identify sustainable materials. Tools such as LCA should be used to optimize those materials that have the potential to be truly used in a sustainable manner.

The issue of toxicity is often lost inside the detail and complexity of a life cycle analysis. The USGBC’s PVC Task Group attempted to address this shortcoming of LCA, by incorporating a risk assessment analysis. However, the methods used by the PVC Task Group failed in identifying many of the recognized issues raised by McDonough Braungart Design Chemistry (MBDC) and many other environmental organizations including the use and generation of persistent, bioaccumulative, and toxic chemicals associated with the manufacturing and disposal of PVC compounds.

When PVC is evaluated according to Cradle to Cradle principles, it becomes apparent that there are serious issues about the safety of the inputs for PVC itself and PVC compounds. Since 2001, Herman Miller has been working to phase out of the use of PVC. This remains a challenging issue due to the low-cost and natural flame retardant properties of PVC. However, Herman Miller remains committed to eliminating the use of PVC where cost-effective materials meet performance demands.