2 The Context |
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2.1 Aim of this Guide
2.2 Objectives
2.3 How to use this Guide
2.4 Target audience
2.5 Justification
2.6 Policies and Regulation
2.6.1 Key Policies
2.6.2 The Role of Regulation
2.7 Responsibilities and Roles
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Key Principles
1. The use of chemicals in modern buildings is widespread yet very few have been comprehensively tested for carcinogenicity or other health threats.
2. Responsibility for the level of toxicity in the indoor environment falls to specifiers in the absence of more prohibitive, building regulations.
3. That the use of toxic chemicals has an impact on health is evidenced by a number of research projects into building related illnesses.
4. Adopting the precautionary principle relates to the practice of the removal of materials from the indoor environment, where a specifier has concerns that there is insufficient proof to determine that a material is safe for use.
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2.1 Aim of the Guide
To increase uptake of benign construction techniques and thereby reduce chemical loads on humans and the environment.
2.2 Objectives
- To highlight the potential risks to building users and the wider environment associated with chemical toxicity in buildings and building products;
- To highlight the benefits of benign specification which can improve the indoor environment, contribute to well-being of occupiers, improved performance, staff retention and reduction in building-related ill-health (also known as sick building syndrome);
- To promote an overall approach of simplification that replaces, or renders unnecessary, certification schemes and specification sheets; [8], [9]
- To reduce the burden placed on the environment due to chemical toxicity in construction waste;
- To promote cost effective design solutions that eliminate the use of chemical toxins as the norm;
- To enable those who wish to adopt the precautionary principle to do so.
2.3 How to use this Guide
Sections One, Two and Three of this guide cover an overview of the issues, and Section Four looks at approaches to minimising chemical loads and provides sources of good information.
Section Five discusses cost issues with reference to case studies.
Section Six provides a selection of details for a variety of construction types. It includes an indication of the basic problems with existing specifications and identifies the reason for alternatives on the materials used. These are provided in order to illustrate discussion and are not in any way intended for replication. Any solutions need to be designed for their unique context.
At the end of this Guide there is an annotated list for further reading, which is separated into a short guidance list and background reading, as well as a list of useful contacts and websites.
Toxicity can be an issue at every stage from extraction to disposal of a material or product. This publication prioritises the building user and the indoor climate. It also addresses the total life cycle of a material such as when it is toxic in its manufacturing (e.g. PVC) or its installation (e.g. timber treatment spray) or if it becomes a problem at the end of its useful life (e.g. Composite panels).
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Building
Case Study #1
“Non-Toxic” House,
Stavanger, Norway
Architects - Gaia Lista, Norway

Photo source:
Gaia Lista
The ‘Giftfti’ (toxin-free) house in Stavanger
Environmentally sound and healthy house.
Key Design Features
• Breathable Construction with Limecrete + lightweight locks for moisture regulation.
• Internal wood panelling treated with lime wash that bleaches but preserves moisture regulating properties.
• Kitchen and bathroom in limecrete to prevent mould.
• Non-toxic silicate paint preserves moisture regulating properties.
• Flooring is either wax/oiled timber, or loose laid brick tiles.
• Cellulose fibre insulation in all walls + roof.
• Expanded clay aggregate and foam glass are used at ground level.
• Sheepswool used for draught sealant around windows. |
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PVC
Many finishes, decorating and bonding materials - paints, lacquers, adhesives and sealants - can off-gas a range of chemicals.
Risks
- During manufacture: ingredients such as the vinyl chloride monomer emit dioxin and other persistent pollutants present both acute and chronic health hazards.
- During use: PVC products can leach toxic additives, for example, flooring can release softeners called phthalates (recognised asthma triggers also linked to genital deformities, premature births, hormone disruption and cancer).
- In disposal: leaches toxic additives when disposed of in landfill; emits dioxin and heavy metals when incinerated.
- In fire: emits hydrogen chloride gas and dioxin.
Possible PVC alternatives
- Stainless steel conduits;
- PE, PP or rubber sheathing to wiring;
- Copper or PE water pipes;
- PTFE (Polytetrafluoroethylene) non-reactive pipework;
- Cast iron rainwater goods;
- Linoleum or rubber in lieu of vinyl floor coverings.
There are a number of websites giving detailed guidance on alternatives to pvc and on suppliers. [10],[11]
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PVC Pipe routinely used inside and out.
Source: H Liddell
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PTFE is an economic substitute for PVC.
Source: H Liddell |
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2.4 Target Audience
This Guide will help all those who wish to reduce the toxic chemical loads in buildings and thereby to reduce the environmental damage and minimise the risks to users and the wider environment associated with their projects, including:-
- clients, building owners and users
- architects
- architectural technicians
- health professionals
- voluntary agencies
- project managers
- builders
- interior designers
- structural engineers
- building service engineers
- building surveyors
- quantity surveyors/cost consultants
- maintenance/facilities managers
- planning officers
- building control officers
- funding bodies/professional advisors
- government agencies
- lobby groups
2.5 Justification
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Rauli Kindergarten (2005) by Gaia Lista was designed with 100% benign materials in the indoor climate.
Source: B Berge |
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“Of the 75,000 synthetic chemicals which are now in common commercial use, less than 3% have been tested for carcinogenicity. In 1994, 2.26 billion pounds of toxic chemical were released into the environment, of which, 177 million pounds were known or suspected carcinogens. Most testing of chemical toxicity is undertaken on the basis of exposure at work by adults. We are ignorant of the effects on children and other species which might be vital to the ecological make-up of the planet. No one knows the cocktail effect. It is permitted only because the victims are anonymous.”
Steingraber in Living Downstream [12]
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The UK Off site construction (OSC) industry is heavily chemically laden. This is in contrast with OSC in Austria, Switzerland and Germany. (Image UK)
Source: F Stevenson |
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There is substantial evidence to indicate that a proportion of construction materials are potentially hazardous to health and deleterious to the environment. They continue to be used for lack of evidence of their toxicity. The Royal Commission on Environmental Pollution (RCEP) highlighted this in a report in 2003. [13]
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“...The current system for managing the risks from chemicals fails to secure public confidence and is overloaded by the massive backlog of chemicals waiting to be assessed. ... A more inclusive, precautionary and effective approach is urgently required.” [14]
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Considerable amounts of time, expense and effort have been spent on the detailed numerical analysis of the environmental impact of building materials and components. The work has come up against real practical and philosophical difficulties and there is little information of direct day-to-day value to manufacturers and specifiers. The picture is also clouded. It is not unusual for manufacturers to seek to find fault with competitor’s products whilst looking to show their own in the best possible light.
Changes in attitudes towards the impact of construction have taken place in Europe recently, in part prompted by the disturbing results of research into pollution of the environment. There are abundant water, land and air-borne pollutants and there are numerous reports on a wide range of them including carbon dioxide, ozone, dioxins, heavy metals and Polychlorinated biphenols (PCBs). Impacts are evident at all life-cycle stages from manufacturing to leaching of waste materials in landfill. [15], [16]
The international response has led to serious attempts to reach agreements to limit pollution. [17] This is leading to more stringent legislation and changes in economic policy to reverse unsustainable trends. The climate change levy, WEEE regulations, changes to building regulations and landfill tax are some examples. It is notable that these policies are leading to changes in construction activity, and in the use of materials. European regulations are being introduced including a directive on VOCS and controls on chemicals through the REACH regulations. [18], [19]
The World Wildlife Fund (WWF) has undertaken research on chemical loads on people. They conducted monitoring surveys of human blood, to identify hazardous man-made chemicals that contaminate our bodies. The alarming results highlighted a wide range of chemicals in human blood originating in buildings. [20]
There is increasing attention to minimizing waste arising from construction, and increasing pressure on primary resource conservation is leading to reuse and recycling of construction materials. However, many materials in our buildings have embodied toxicity. This may be intrinsic to the material, as is the case with asbestos or occur largely as a result of manufacture, as in PVC. It is also possible for toxicity to accumulate during the product life, as is the case with bricks next to a busy road. Builders and specifiers need to be aware of the potential hazards posed by this embodied pollution and act accordingly to avoid exposure to future risk and liability.
Given the trend towards improving health & well being, enhancing biodiversity and waste minimisation there will be increasing attention to the toxicity of materials in the future. The burden of responsibility increasingly lies with designers to use materials that can be safely re-used and can withstand future, more stringent, regulation. The use of outputs from other industries as inputs to the construction industry demands that we use extreme caution to ensure that these materials do not introduce a toxic burden to buildings. |
Building
Case Study #2
Sunnmoeregate, 1, Oslo, Norway
Architects - Alice Reite

Photo source: A Reite
Project aim:-
Non-toxic renovation in inner-city flat in Oslo.
Key Design Features
• Natural materials throughout inc. clay, eco-paints, oils and woodwork.
• Humidity controlled without fans.
• Heating cables in walls to reduce dust circulation.
• Plastic materials completely avoided. |

Chipboard is a ubiquitous flooring material. It is usually bonded together with Phenol formaldehyde resin (formaldehyde is one of the most virulent triggers for allergic reactions). In addition it is sometimes treated with preservatives of a type banned in the USA since 2002.
Source: H Liddell |
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There is growing concern about indoor air quality and other adverse factors within buildings, highlighted by ‘Building Related Illness’. Indoor air quality is now legislated for in many countries. [21], [22] This guide limits its remit to construction and fixtures, but not the ventilation, fit-out, furnishings and finishes that are also implicated. They are highly likely to introduce or contain toxic materials and have cleaning and decoration regimes that are potentially chemically hazardous. There can also be a risk that inappropriate construction can lead to biological toxicity for example through mould growth. Whilst this study is focussing on chemical toxicity, the authors feel that it would be an artificial boundary not to refer to this significant risk. Designers and specifiers should discuss these issues with clients and users.
Radon and radiation are also recognized as significant in relation to indoor air quality but are outwith the scope of this publication. We have provided references to further information.
Radon emissions from the ground, and their seepage into buildings are of serious concern in some geographical locations. Radiation and electro-magnetic smog is an area of increasing concern and speculation. [23], [24], [25], [26]
“The Health Protection Agency acknowledges that little study has taken place on electric fields and that links between electromagnetic fields and cancer are not ruled out, with further research required. They advise a precautionary approach which minimises people’s exposure to certain types of electromagnetic radiation. The building regulations do not take account of electromagnetic radiation but do require housing to be protected from radon gas, where it occurs at significant levels.” [27]
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Legal Case Studies
There have been a number of legal cases brought against landlords, homebuilders and insurers over health problems originating from poor indoor air quality. Four are highlighted in this publication.
Most examples are from the United States where legal action on indoor air quality is common, and often results in the payment of large damages.
A large number of cases in the US concern toxic mould growth and associated health problems. Toxic mould is widely regarded as a medical hazard and is more open to litigation, than other indoor pollutants such as dust mite allergens and VOCs where medical research is complex and less conclusive.
In the US the number of claims has increased rapidly with 7143 cases being reported in 2001 compared to only 3 cases a decade before. Substantial sums have been awarded to plaintiffs in a trend that has seen contractors placing exclusions in their contracts and insurance companies raising premiums or adding exemptions to their policies. |
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Legal case Study #1
Call vs. Prudential (Settled 1992)
This first major IAQ case argued before a jury in the US generated important IAQ related law.
The main charges of negligence brought by the plaintiff included:
- The use of building materials that off-gassed formaldehyde and other noxious chemicals.
- Failure to notify that the building was not suitable for occupancy due to noxious fumes and chemicals infiltration.
- Failure to supply adequate levels of fresh air.
- Failure to act on reports of tight building syndrome (TBS) and sick building syndrome (SBS).
- Failure to provide information on the health effects of TBS and SBS.
Liability for problems with the HVAC system was extended to the manufacturers and sellers of the system as well as everyone involved with the construction and design of the system including architects, engineers and installers.
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2.6 Policies and Regulation
2.6.1 Key Policies
Since 1990 there has been a succession of policies that have evolved to promote sustainable construction. The UK policy paper A Better Quality of Life – A Strategy for Sustainable Development in the UK [28] included the following:-
“ Effective protection of the environment. We must act to limit global environmental threats, such as climate change; to protect human health and safety from hazards such as poor air quality and toxic chemicals; and to protect things which people need or value, such as wildlife, landscapes and historic buildings.“
EU and International Policy on the environment includes the Construction Products Directive, promotion of the precautionary principle and implementation of policy to enforce the polluter pays principle, such as the WEEE regulations. [29]
- Precautionary Principle [30]
Wherever there are threats of serious or irreversible damage, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation. This is very relevant to the question of chemical toxicity because of the lack of scientific proof.
- Polluter Pays
The ‘polluter pays’ principle requires those people who cause pollution to be responsible for paying the cost of remediation. The recently introduced Waste Electrical and Electronic Equipment Directive (WEEE) makes producers responsible for financing the collection, treatment, recycling and recovery of waste electrical and electronic equipment. This type of regulation initially targeting the most hazardous and widespread pollutants is having, and will continue to have, wide-ranging impact. The chemical toxicity in building products is going to be less easy to ignore. These are also part of international agreements on the environment, the latter in the generic context of internalizing external costs. In addition international policy relates to the rights of future generations, all sectors of the current generation and our responsibilities to enhance biodiversity.
- Protection of Biodiversity
There is significant evidence of the value that people place on biodiversity and the contribution to human well-being. [31] However the issue extends beyond well-being to survival. Reducing biodiversity diminishes the gene pool and impairs the robustness of natural systems. This increases the risk of exponential failure of natural systems, which can in turn jeopardise human life. Protection of biodiversity requires us to be attentive to the lifetime impact and the final destination of construction materials and products.
Whilst we have an abundance of sustainability policies representing the stated priorities, aims, aspirations and objectives of national governments, international bodies, professions and companies – we have little by way of regulation or controls to enforce improvements at the design stage. However, ‘end of pipe’ measures to treat pollution or charge polluters are driving changes in the supply chain.
In reality it is widely recognised that the value of regulation remains in
minimising bad practice. Driving forward changes in practice that are
desirable and necessary often falls to committed leaders prepared to
innovate, from whom others then take the lead.
It is for this reason that this guide promotes the higher order EU and International requirements of precaution, responsibility and good sense. It is an overall approach of simplification and good sense that is necessary in the first instance, in order to produce the new generation of affordable buildings with reduced chemical load that can provide the evidential base and momentum to facilitate moving legislation forward.
2.6.2 The Role of Regulation
The issues which have prompted this guide have come to the fore in recent years, as yet such policy that exists is very generalised due to the lack of detailed research in to the area. Where policy has been translated into regulation to date it has only looked at specific ‘end of pipe’ issues – such as with the control of asbestos.
In Scotland the current position is that, in the absence of detailed investigative research into individual toxins and groups of toxins, the current regulations concentrate on controlling air quality through guidance on ventilation. It is vitally important that adequately funded research is undertaken and that the results are used to minimise toxic loads through stricter controls.
The Building (Scotland) Act 2003 led the UK by introducing the powers to make building regulations to further the “achievement of sustainable development.” In 2004 the agency initiated a review of the Building (Scotland) Regulations 2004 and the associated Technical Handbooks in order to identify any barriers to sustainable development and possible strategies to enhance sustainability.
Research into sustainable construction and the regulatory framework for the Scottish Executive included an appraisal of building regulations in other countries. [32] It indicated that there was significant opportunity pro-actively to set objectives and to develop the appropriate mechanisms for achieving them. It identified examples of promotion of sustainable development objectives through a Building Regulatory Framework in Norway, Sweden and Germany.
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Prefab sheets for playhouse.
Oriented Strand Board (OSB) – contains formaldehyde and is being used e.g. for a pre-fabricated kit playhouse for children. Source: H Liddell
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Paint finishes need to be both moisture permeable and avoid off-gassing. The last 10 years has seen a wide range of benign options come onto the market in the UK.
Photo taken in The Green Shop, Bisley, Stroud
www.greenshop.co.uk
Source: H Liddell
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Paints and preservers now come with warning labels attached and explain the harmful toxins that they contain.
Source: H Liddell |
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2.7 Responsibilities and Roles
The responsibility for toxicity in building materials in Scotland lies between a number of organisations – SEPA (Scottish Environmental Protection Agency), HSE (Health and Safety Executive), British Standards Institute (BSI) and Local Authority Environmental Health Departments.
SEPA covers the cradle and the grave – i.e.
Cradle:- the process surrounding the initial gleaning of the raw material - through mining, extraction, harvesting, etc. and
Grave:- the waste stream that ends up in the ground, in water or in the air.
The HSE covers the area of occupational hazards and is responsible for any identified risks at a factory, assembly plant or building site. They also overlap with Local Authority Environmental Health Departments in terms of any clearly identifiable Sick Building Syndrome factors.
The EU Construction Products Directive embodies the idea of life cycle responsibility.
“The environmental impact of construction products and materials is subject to standards set by the International Organisation for Standardisation (ISO) EU harmonised standards (CEN) and European Technical Approvals (ETA). Under the EU Construction Products Directive 89/106/EEC (CPD) section on “hygiene, health and the environment” construction work must be designed and built in such a way that it will not be a threat as a result of any of the following:
- The giving-off of toxic gas
- The presence of dangerous particles or gases in the air
- The emission of dangerous radiation
- Pollution or poisoning of the water or soil
- Faulty elimination of waste water, smoke, solid or liquid wastes
- The presence of damp in parts of the works or on surfaces within the works
From ISO 14040:2006 and ISO 14044:2006 [33]
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There are many studies which show the fibres shed from Mineral wool can irritate the skin, and there is also evidence of links to cancer. [34]
Source: H Liddell
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A number of relatively benign products are entering the insulation market including sheepswool (See spec note 23 in Appendix F)
Source: F Stevenson |
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Footnotes:
8. Liddell H.L., (2002) Ecominimalism www.seda2.org/articles/Ecominimalism.html
9. Select Committee on Science and Technology www.parliament.the-stationery-office. co.uk/pa/ld200506/ldselect/ldsctech/21/4111706.htm
10. Greenpeace www.greenpeace.org/international/campaigns/toxics/polyvinyl- chloride/pvc-alternatives-database/
11. Healthy Building Network www.healthybuilding.net/pvc/alternatives.html
12. Steingraber, S. (1997) “Living Downstream” Virago Press, London
13. Royal Commission on Environmental Pollution (2003) “Chemicals in Products” TSO
14. Ibid
15. www.defra.gov.uk/environment/statistics/
16. www.scotland.gov.uk/Publications/2005/08/15135632/56452
17. Brenton T., (1994) The Greening of Machiavelli RIIA
18. www.defra.gov.uk/environment/ppc/old-consultations/vocs-transpose/consult doc.pdf
19. REACH - http://ec.europa.eu/environment/chemicals/reach/reach_intro.htm
20. www.wwf.org.uk/chemicals
21. www.hse.gov.uk/LAU/lacs/75-1.htm
22. www.unison.org.uk/safety/doc_view.asp?did=181
23. Saunders, T. (2002),
24. BRE publication BR376 (1999) Radon: guidance on protective measures for new dwellings in Scotland BRE
25. www.hse.gov.uk/radiation/ionising/radon.htm
26. Scottish Building Standard 3.2 Site preparation – protection from radon gas, in the Domestic and Non-domestic Technical Handbooks.
www.sbsa.gov.uk/tech_handbooks/th_pdf_2007/Section_3_Domestic_2007.pdf
www.sbsa.gov.uk/tech_handbooks/th_pdf_2007/Section_3_Non-domestic_2007.pdf
27.Health Protection Agency, offers testing and guidance on Radiation Protection
www.hpa.org.uk/radiation/
28. A Better Quality of Life – A Strategy for Sustainable Development in the UK
www.sustainable-development.gov.uk/publications
29. EU Sustainable Development Strategy
http://ec.europa.eu/sustainable/welcome/index_en.htm
30. http://europa.eu/scadplus/glossary/precautionary_principle_en.htm
31. Royal Commission on Health and Pollution (RCEP) Study on Urban Environments, Well-being and Health www.rcep.org.uk/urbanenvironment.htm
32. Halliday S.P., and Stevenson F. (2004) Sustainable Construction and the Regulatory Framework, Gaia Research, Edinburgh, ISBN 1-904680-19-4
33. www.iso.org Also www.eota.be/ http://ec.europa.eu/enterprise/construction/internal/intdoc/id3/explanid3.htm
34. Pohlabeln, H., et. al. (2000). Lung cancer and exposure to man-made vitreous fibers: results from a pooled case-control study in Germany. American Journal of Industrial Medicine, Vol. 37 Issue 5 pp. 469 - 477
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