What’s the Risk?  
A Closer Look at Material Health Transparency  
b y M a r k S i l v e r b e r g  
he Living Future Institute has Risk of inconsistency  
introduced its “red list” of unde- The most common disclosure pro- hazardous, but when transformed into  
sirable chemicals as well as its grams manufacturers use are self-re- glass, the risk of exposure is negligi-  
desiccants. In dust form, silica is very  
Declare label. Likewise, the U.S. Green ported. This means the manufacturer ble. An HPD for insulating glass may  
Building Council introduced ingredi- is responsible for understanding the have several ingredients that appear  
ent disclosure requirements into LEED disclosure rules that apply to report- hazardous, but which pose negligible  
v4. Because of these actions, building ing ingredients and their hazards. This exposure risk to building occupants  
component manufacturers have been unverified self-reporting has resulted because they are: (i) present in insignif-  
challenged to provide material health in misinterpretation of the rules and icant quantities, (ii) inaccessible to the  
declarations. Here, we’ll look at some disparities in reporting hazards. For occupant, or (iii) transformed into an-  
learnings my colleague Dr. Helen example, the rules for HPD (version other less hazardous material. Readers  
Sanders and I have gained on this 1) require that the hazards of all inten- of HPDs generally are not technically  
important field.  
tionally added ingredients be disclosed, equipped to make this determination,  
so some architecture firms are con-  
sidering hiring toxicologists to enable  
them to understand these disclosures  
Disclosing the hazards of ingredients used to  
make a product does not clarify the risk of expo- better.  
HPDs and the Declare label focus  
only on the raw ingredients and don’t  
identify the hazard or risk of exposure  
sure at different points in a product’s lifecycle.  
Material disclosures attempt to no matter how small a quantity is used. to that hazard of the final transformed  
clarify the hazards of the ingredients That means for low-E coated insulating material.Third-party certification pro-  
present in building products so archi- glass, the materials used in the coating grams such as C2C and Product Lens  
tects and building owners can make should be disclosed. However, some provide an assessment of exposure risk  
informed material choices. These dis- manufacturers’ Version 1 HPDs for to ensure the actual hazard is reported.  
closures focus on identifying poten- coated glass products include the coat-  
Material transparency is here to stay,  
tial human and eco-toxicity hazards. ing materials, while others incorrectly and fabricators will continue to be  
There are several disclosure pathways neglect to disclose them, saying they faced with requests for such documen-  
that companies use—the most com- are below 1,000 ppm. Version 2 of the tation. The question for fabricators is  
mon are Health Product Declarations HPD system now allows for not report- which program to use? To reduce busi-  
HPDs) and Declare (a requirement for ing intentionally added ingredients ness risk and deliver more accurate,in-  
the Living Building Challenge). More below 1,000 ppm level. The only way to terpretable information, consideration  
recent entrants are the Cradle-to-Cra- overcome these challenges and ensure of third-party programs such as C2C  
dle (C2C) Material Health Declaration uniformity and consistency of report- and Product Lens is recommended. n  
and UL’s Product Lens.  
ing is third-party assessment and  
The initial concern from product verification.  
manufacturers relates to disclosure  
M a r k S i l v e r b e r g is  
president of Technoform North  
America Inc. in Twinsburg, Ohio.  
He has worked in the glass and  
glazing industry since 1984 and  
has been with Technoform for 15  
years. He is a third-generation member of the  
glazing industry. Read his blog each month at  
of proprietary ingredients; however, Risk vs. HazaRd  
all disclosure pathways have ways of  
Disclosing the hazards of in-  
managing this issue effectively. There gredients used to make a prod-  
are, however, other significant busi- uct does not clarify the risk of  
ness risks associated with material exposure at different points in a  
disclosures that manufacturers need product’s lifecycle. For example,  
to consider.  
silica is used in making glass and  
USGlass, Metal & Glazing | July 2017  

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