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Author Susan M. Young
Executive Sec’y
Chemical Fabrics & Film Association
cffa@chemicalfabricsandfilm.com
www.chemicalfabricsandfilm.com
 
Comment
The Chemical Fabrics and Film Association (CFFA) has reviewed the TSAC PVC Task Group Report. We would like to thank you for your willingness to address this issue. We were quite impressed with the obvious depth of investigation and fully understand the effort by each of the group members to distill the volumes of documentation into a meaningful set of conclusions.

Our organization has always stressed the importance of sound science as a mechanism for the decision making process. For this reason, we support your use of a combined Life Cycle Analysis (LCA) and risk assessment methodology in your study. The LCA and risk assessment are currently the most scientifically sound and rigorous tools available to conduct an investigation of this type and to objectively sift through the mountains of data available to the TSAC group. Life cycle analysis is broadly recognized as one of the most realistic ways of assessing the broad range of environmental impacts from materials, and risk assessment is widely used by EPA and other governmental entities as the basis for rule making on issues affecting public health and environmental impact.

CFFA has done considerable work to investigate issues of interest and importance to our members. These programs have provided direction for each new generation of products created and marketed by our member companies. It has always been the policy of the organization to promote education and objectively define product performance through specification development. CFFA manages the activities of an Environmental, Health & Safety Committee and a Technical Committee. Among the accomplishments of the organization is the progress made participating collectively in working to achieve environmental and technical goals. There are many product choices in the marketplace. Each alternative needs to be able to demonstrate a consistent level of quantifiable performance. Our programs on specification development have helped to establish the minimum level necessary to achieve acceptable lifetime performance characteristics. Any material selected should be able to demonstrate its key performance characteristics through standardized and uniform testing methods.

Our active Committees have developed information in the following areas:

Mold and Mildew
• Mold – Cause, Effect and Response.
• Residential Wallcoverings – Answers to Your Questions Regarding Mold.
• Commercial Wallcoverings – Answers to Your Questions Regarding Mold.
• Decorative Building Components.
• What Is Fungi?
• Wallcoverings: Mold and Mildew – An Overview.
• Marine Upholstery: Mold and Mildew – An Overview.

Indoor Air Quality
• "Questions and Answers: Vinyl's Health, Safety and Environmental Performance".
• Environmental Profile: Vinyl Wallcovering.
• The Vinyl Advantage in Transportation Interiors.
• Vinyl Wallcoverings: Indoor Air Quality.

General Literature
• "Questions And Answers: Vinyl's Health, Safety And Environmental Performance".
• Facts About The Environmental, Health And Safety Performance Of Vinyl And Vinyl Wallcovering.
• The Vinyl Advantage In Transportation Interiors.
• "Vinyl Advantages: Compelling Reasons To Specify Vinyl Upholstery Fabrics".
• Chemical Fabrics And Film Association Standards.
• Chemical Fabrics And Film Association Technical Reports.

To improve on indoor air quality, the Association worked to develop state-of-the-art Mold & Mildew publications, and worked to promote Mold and Mildew Education. Informing the industry and marketplace on the causes and solutions to mold and mildew provide the best course to maintain higher indoor air quality. The Association offers to make these documents available to you for your consideration. A great deal of time and effort went into their development to insure quality and accuracy. You might find these important communication tools for green building development.

The Chemical Fabrics and Film Association and team members have also supported the development of an Infection Control Study to better understand t°Xº0Ú¸(,Ô+(ÔP~ûwö›.d~ûw0?º¢o Ô/d~ûw?º¢o .Ô0/d~ûwP?º¢o ԯÀi»ðÖ¸ Û¸ØyºÉExecutive Sec’yðxºpÛ¸ÉChemical Fabrics & Film
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