July 2013

Volume 22, Number 7

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Article Contents

Transparency Is the Secret Ingredient in "Declare" Products

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Several dozen products are now participating in the Declare database, supporting Living Building Challenge documentation and ingredient disclosure.

By Paula Melton


With a flame-retardant-free foam cushion, the Visio task chair from Teknion US is the first furniture product to be designated Red List-free in the Declare database.

Photo: Teknion US

A new program called Declare provides a database of building products with at least 99% of their ingredients fully disclosed. Introduced early in 2013 by the International Living Future Institute (ILFI), this free and publicly accessible tool included only about 30 products by late June—but it’s growing rapidly, according to ILFI’s Amanda Sturgeon.

The concept behind Declare is to “increase transparency as fast as possible,” she told EBN, adding that the group expects to have at least 100 product listings by the end of 2013—a goal Sturgeon believes to be well within reach for the database’s “trial year” despite a number of obstacles. “What we see happening right now is that we get one [product] of a type, and then other manufacturers that might be their competitors start getting interested.” She said manufacturers who’ve already listed products are also “wanting to do a whole product line.”

What manufacturers declare

It’s not difficult, in theory, to get a product into the Declare database. You just fill out a form and pay a fee. If you’re like Coldspring or Amorim Isolamentos, you might only have one minimally processed ingredient to list, such as granite or cork, both in the Declare database and marked “Red List Free” (see “Stone, the Original Green Building Material” and “Expanded Cork: All-Natural Rigid Boardstock Insulation”).

EcoBatt Ingredient List


As this screen capture shows, product ingredients are all on view, and manufacturers can't even hide behind chemical brand names or euphemisms because they must also list CAS numbers.

Screen capture: Declare website

But with multi-component products, filling out that form isn’t always so easy: assuming manufacturers know what materials their suppliers use and can get permission to disclose them, they must also declare at least 99% of intentionally added ingredients—including proprietary ones. A proprietary ingredient may be left off the list if it’s less than 1% of the total, but the manufacturer has to declare that that ingredient is free of chemicals proscribed by ILFI’s stringent Living Building Challenge rating system (and despite that declaration, these products are marked Red List-compliant in the database rather than Red List-free). “It’s just a list of ingredients, not a recipe,” Sturgeon says she sometimes has to reassure manufacturers.

With the exception of undisclosed proprietary ingredients, a product can be listed in Declare regardless of how toxic its components may be. ILFI does two additional things with the data, though: it vets the ingredient list by comparing with industry standards, and it cross-checks each ingredient against two other lists—chemicals targeted by the U.S. Environmental Protection Agency’s chemical action plan and those considered “of very high concern” in the European Union’s REACH program. Known human carcinogens and several persistent, bioaccumulative toxic substances will be marked as chemicals of concern in the database and will show up in orange on the product’s accompanying Declare label.

Weak links in the supply chain

Even though companies can participate in Declare with more questionable products, it’s not surprising that virtually all those currently listed are relatively clean—marked “Red List-free” or “Red List-compliant” (meaning the product contains Red List ingredients that have been granted a temporary exception for that application, such as formaldehyde in structural timber glulams). Teknion US has listed one of each and plans to add several more products in the near future.

The process wasn’t without some surprising speed bumps, reports Tracy Backus, Teknion’s director of sustainable programs. “We have the benefit of owning a lot of our own supply chain,” Backus says, “so we haven’t run into many unexpected obstacles” that other manufacturers may face. “Because of Google being one of Teknion’s clients, we’ve been doing this work for about a year and a half,” she adds. “The company has a really good handle on the areas we need to address.”

So when Teknion first decided to participate in Declare, the formaldehyde came as a shock.

Despite all Teknion’s prior work on the minimizing Red List ingredients, its laminate supplier had been using an adhesive containing formaldehyde resin. The company decided to switch to a linoleum-based material instead of laminate for its Livello table before submitting the product. On the up side, the old supplier “found out they had work to do as well.”

Feedback like this from Declare participants bodes well for the future of product transparency and optimization, notes Sturgeon. “The misconception is that [manufacturers] are trying to hide something deliberately from us,” she says, but “in most cases, they really want to know” what is in their products and remove potentially harmful ingredients, she argues. “In working with the companies that are selling the product, it’s been a really valuable process. They feel more assured about what they’re selling and what they’re representing.”

Exemplary Declare products

Listings in the Declare database include everything from green roof systems to graywater equipment and from compost to cellulose insulation. Below we highlight a handful of interior products that use less-toxic components than is standard in the industry.

Declare Label for Naturally Northwest Cabinets


With a soy-based adhesive and FSC-certified veneers, these agriboard Neil Kelly cabinets stand out from comparable conventional particleboard products. Some finishes have trace amounts of toxic solvents, but natural finishes are also available.

Image: Declare website

Manufactured wood products like plywood, particleboard, and oriented-strand board often contain formaldehyde-based binders. Although Collins Pine FreeForm particleboard uses MDI (methylene diphenyl diisocyanate), a U.S. EPA chemical of concern due to potential harm to exposed workers, the isocyanates in this binder are not expected to offgas into interiors once the product cures in the factory—unlike formaldehyde, a VOC and known human carcinogen. Collins Pine, which uses wood certified by the Forest Stewardship Council (FSC) in many of its products, has received widespread recognition for its innovations over the years (including a BuildingGreen Top-10 award in 2007) and has decided to participate in Declare because “several well-noted architecture firms” were requesting a Declare label for their specifications, according to a spokesperson.

9Wood takes a different approach with its plywood ceiling panel products, 2100 Panelized Linear, EcoGrille, and 1100 Cross Piece Grille. The binder is soy flour mixed with an adipic acid-based resin (a chemical precursor to nylon) as a curing agent. Naturally Northwest cabinetry by Neil Kelly Cabinets uses a similar technology for the locally harvested veneers on its agriboard panels. The listing for that product reveals a few trace chemicals of concern—like acetone and ethylbenzene—but the company offers a variety of finishes that don’t contain these materials. (The appearance of chemicals like these in disclosures illustrates a Catch-22 for manufacturers: other companies may use chemicals that are just as bad or worse but not tell us about them.)

Furnishings can contain any number of toxic components, from halogenated flame retardants in foam cushions to perfluorinated fabric treatments. Hamilton Sorter’s Modular Caseworks includes a proprietary trace ingredient and therefore can’t be marked Red List-free despite having no Red List ingredients. Teknion’s Livello table appears as Red List-compliant (due to a temporary exception for phenol formaldehyde in particleboard), while the company’s Visio chair is the first furniture product to achieve Red List-free status in the database.

With a flame-retardant-free polyurethane cushion and glass fiber and polypropylene components instead of textiles, Visio avoids some of the most common pitfalls of multi-component furnishings, giving Teknion a leg up with health-focused clients like Google and the Bullitt Foundation (owner of the recently completed Bullitt Center, which is aiming for LBC certification and where ILFI employees actually work while sitting in Visio chairs).

Declare and the Health Product Declaration: A Comparison


Declare overlaps significantly with another recently launched transparency effort, the Health Product Declaration (HPD)—the two share a basic disclosure methodology—but the programs differ.

Source: BuildingGreen, Inc.

Mainstreaming healthier materials

Participating in Declare has been “a great business opportunity,” Backus frankly admits, but she says her reasons for leading Teknion through this process have nothing to do with making money.

“I don’t think I know anybody who’s not impacted by cancer in some way,” she told EBN. “I don’t know a more compassionate industry than the design industry. It’s just helping them find out where to go; major firms known for their good work come to us and say, ‘Can you give use some guidance? Because we don’t know what we don’t know.’” She emphasizes that the approach from manufacturers needs to be holistic: “It’s not about addressing just an edge detail on a product”—although such details can become a big focus as materials are replaced with safer alternatives. Rather, she says, it’s about blazing a trail toward better materials—and eventually getting the worst offenders “out of the mainstream.”

The mainstream has a powerful current, though, as Backus has discovered. During recent presentations at NeoCon 2013, she says, “a gentleman in the audience challenged the speakers, saying the chemicals are only bad if there’s a high concentration of exposure.” Later, she said, presenters discovered this audience member was not an architect, but rather a lobbyist from a major chemical company.

“He hijacked a couple of minutes of the Q&A, which was fine,” Backus says, “but I wish he had represented who he was. A lot of people left there kind of confused.”

“We’re trying to get better, not to put anybody out of business,” she adds. “My feedback to him was it’s not a matter of black and white right now. LEED, LBC, and BIFMA [the Business + Institutional Furniture Manufacturers’ Association] are all moving from a technical kind of sustainability to restorative sustainability, which is about health and well-being.”

As it grows, Declare is set to provide strong support for that transition.

For more information:

International Living Future Institutedeclareproducts.com

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June 27, 2013