LEED TSAC PVC Study Database > Comments on Draft Report

Comments on Draft Report
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Comments 201-240 of 562.
Page(s) Lines(s) Submitter Organization Comment
24 19 Tom Lent Healthy Building Network hazard index is highly dependent upon the validity of reference doses
24, 29, 54 Richard Johnson Tin Stabilizers Association (TSA) General letter explaining situation regarding OSHA PEL and organotins, This situation arises in ...
25 13-38 William Carroll OxyChem The simplifying assumption regarding constituents in various groups—especially dioxin--may be ove...
25 19 Ted Schettler Dept of Medicine, Boston Medical Center Treatment of chemical groups: The chemicals within each group vary considerably with respect to ...
25 footnote Arjen, David Sevenster, Cadogan European Council of Vinyl Manufacturers, European Council for Plasticisers and Intermediates Reference is made to 2-methyl phthalate. This substance is not among the usual PVC plasticisers
25 20 Tom Lent Healthy Building Network "An advantage of using intake fractions is that they are already averaged for the United Sta...
25 22 Tom Lent Healthy Building Network "Existing intake fractions do not include metals and therefore we do not include metals in o...
26 13 Tom Lent Healthy Building Network "New characterizations developed for unspecified dioxins, PAHs, aldehydes and phthalates&quo...
27 David Yopak Teknor Apex Company It is interesting to note that there is a preponderance of data for vinyl and vinyl products, how...
27 19 Tom Lent Healthy Building Network Data gaps seem to be evaluated very conservatively. If there is not rigorous robust data that wor...
29 32 Ted Schettler Dept of Medicine, Boston Medical Center “Because occupational exposures were the focus of this exercise….” But, for non-cancer and cance...
29 33 Ted Schettler Dept of Medicine, Boston Medical Center The committee did not review recent toxicity studies. They do not explain why. Such a review is ...
29 42 Ted Schettler Dept of Medicine, Boston Medical Center Discussion of general population exposure limits for individual compounds: Why is this discussio...
29 1-5 Debbie Schober OxyChem In the risk_worker_vinyl_chloride_resin spreadsheet, the calculated value of Hazard Index for hig...
29 32-33 Debbie Schober OxyChem The report states that the toxicity values for some of the compounds evaluated in this assessment...
29 22-25 Richard Johnson Tin Stabilizers Association (TSA) Report states that there is insufficient information (toxicology data or published exposure limit...
29 and 54 and 116 22-25 31-33 19 Table A entry for dialkyl tins John Batt Arkema Inc. The report indicates that TSAC relied solely on OSHA PELs in assessing risk associated with the p...
29, 31, 54, 116 John Batt Arkema Inc. Arkema would like to thank the USGBC for conducting such a thorough review of thousands of docume...
30 16 Ted Schettler Dept of Medicine, Boston Medical Center If a one order of magnitude difference in risk estimates is not an unacceptable degree of error, ...
30 18 Jack Geibig Center for Clean Products and Clean Technologies
University of Tennessee		 The assertion by the TSAC that “The majority of the scientific community does not consider DEHP t...
30 45 Jack Geibig Center for Clean Products and Clean Technologies
University of Tennessee		 - “It is noted by ACGIH, however, that its PEL values... Replace PEL with TLV.
30 1 Arjen, David Sevenster, Cadogan European Council of Vinyl Manufacturers, European Council for Plasticisers and Intermediates It is stated that the current US Reference Dose (RfD) (similar to Tolerable Daily Intake) for non...
30 17-27 Marian Stanley American Chemistry Council Phthalate Esters Panel The Panel agrees that di(2-ethylhexyl) phthalate (DEHP) should not be considered as carcinogenic ...
31 10 Ted Schettler Dept of Medicine, Boston Medical Center The discussion of PELs notes that they may be frequently exceeded (31-12,13). This is another obv...
31 29 Ted Schettler Dept of Medicine, Boston Medical Center Discussion of the “protective” or “conservative” nature of the PEL assumptions: The notion that w...
31 41 Ted Schettler Dept of Medicine, Boston Medical Center It seems that the primary goal is to compare occupational risks to those of the general populatio...
31 10-13 Debbie Schober OxyChem The USGBC TSAC report states that the OSHA PELs were used in the absence of more accurate exposur...
31 21-23 Debbie Schober OxyChem The USGBC TSAC report states, “To provide an upper bound estimate of risk, particularly when expo...
31 20 Richard Becker American Chemistry Council The overall assessment is not an evaluation of the maximum likelihood of potential health risks. ...
31 8 Tom Lent Healthy Building Network "it is expected that companies strive to put good industrial hygiene practices in to place… ...
31 8 Tom Lent Healthy Building Network When trying to estimate the absolute risk of a single material or process, using a high end assum...
32 22-23 Dave Kitts Mannington Not necessarily – bulk handling and well designed ventilation systems can effectively help worker...
32 41 Frank Borrelli The Vinyl Institute Although the VI recognizes that there are some concerns about the sampling protocols used by the ...
32 10 Tom Lent Healthy Building Network "Lack of accurate exposure data prevents the estimation of potential health risks…it is beli...
32 18 Tom Lent Healthy Building Network "...dermal exposures difficult to quantify" Once again uncertain data, leads to no conc...
32 40 Tom Lent Healthy Building Network The authors used a CIWMB study for flooring installer exposure assessment. This is an inappropria...
32 44 Tom Lent Healthy Building Network The CIWMB materials emissions study is already old obsolete data for linoleum. Forbo has already ...
32-34 all Don Hodges Hodges & Hodges Architects See comment above for occupational health costs of wood products.
33 29 Jonathan Herz General Services Administration The methodology is flawed by too many disclaimers. One factor after another is dropped by the com...
33 34 Ted Schettler Dept of Medicine, Boston Medical Center The decision to ignore phthalate emissions from vinyl products in residences, schools, etc. is un...