CHAPTER SEVEN

Our Global Chemical Experiment

If we are going to live so intimately with these chemicals—eating and drinking them, taking them into the very marrow of our bones—we had better know something about their nature and their power.

—RACHEL CARSON

OVER 200 INDUSTRIAL CHEMICALS are now readily detectable in the blood, breast milk, or urine of Americans and of most people in industrial nations around the world.¹ Many of these chemicals come from the products we use in our buildings. Because we know so little about them, our Harvard colleague Elsie Sunderland calls this our “global chemical experiment.”

The fundamental problem is that these 200 industrial chemicals are just the beginning. In the United States there are more than 80,000 chemicals in commerce. Guess how many have been thoroughly evaluated for health and safety? About 300. If that number is shocking to you, it should be. But here is an even more shocking number. Guess how many chemicals the Environmental Protection Agency (EPA) has banned since 1976, the year the first “toxics” law was passed? Nine. Yes, you read that right—9 chemicals out of more than 80,000 are currently banned by the EPA. That’s it. And the story gets worse, because 5 of those chemicals were already banned before the law was established in 1976.² So in 40 years, the EPA has banned a total of 4 new toxic chemicals. Its approach is so ineffective that even something like asbestos (asbestos!) has not yet been banned. And there are many more chemicals with worrisome toxicological profiles that are not even being reviewed.

Many of these chemicals are used in everyday products—our carpets, furniture, building materials, and on and on. In many cases these chemicals can migrate out of their original product and, because of their environmental persistence or ubiquity, appear all over our homes, schools, hospitals, and the planet—in some instances up to the North Pole. And we find them in our bodies.

In this chapter we’re going to focus on how the stuff we put in our buildings affects our health. This is the next frontier in Healthy Buildings—sometimes called “healthier materials,” “material health,” or “chemicals of concern.” This movement is just starting to gain traction, with major players, from industry to environmental activists to nonprofit rating systems, all getting in the game.

Bodybuilding

In the Arnold Schwarzenegger era of bodybuilding in the 1970s, it was an open secret that anabolic steroids were commonly used. Even Arnold admits to using them, and no doubt he did plenty of hard work to sculpt a barrel chest that you could balance a glass of water on. The ultimate Mr. Universe. A picture of perfection. On the outside.

Hidden from the judges were the ravaging effects steroids can have on the body. The one that was most famously discussed (and true!)? Smaller testicles. At least one antisteroid ad campaign attempted to use this fact to scare young men, showing a bodybuilder with massive shoulders, arms, and chest … wearing the world’s smallest jockstrap.

Steroids, and other chemicals you’ll read about in this chapter, can affect our natural hormone balance. The increased testosterone throws our endogenous hormones out of whack, leading to impacts on the male testes and sperm production, as well as, for some, breast growth. Later in life, armed with additional scientific evidence, Arnold talked about his steroid use not as bodybuilding but as “body destroying.”³ He looked great on the outside, but the steroids were destroying the parts of the body we couldn’t see.

To bring this back to buildings, the analogy we’ll make here is that bodybuilding is similar to what is called the “core and shell” of a building. If that term is new to you, the core and shell are what the design and construction teams deliver before the “fit-out.” Meaning they deliver the skeleton and skin of the building—the concrete and steel, the windows and outside wall. The fit-out is everything else that goes into the building, based on the desires of the future occupant. Sometimes the core and shell can look really good on the outside but be wildly polluted on the inside.

Smaller Testicles from Building Materials?

Here’s the connection to bodybuilding and steroids: some of the chemicals we are exposed to in buildings affect our reproductive system, just as steroids affect the reproductive system. For our male readers, let’s put this another way: the chemicals in your chair could be wreaking havoc on your penis. For our female readers: don’t worry, we’ll get to your reproductive system shortly. We started this section by focusing on men on the advice of a female friend who, rightly fed up with action only happening when it affects men, gave us this sage advice: “ Making it about MEN and THAT, you will get people’s attention real fast.”

Some of the chemicals used in building materials are what scientists call endocrine-disrupting chemicals. Your endocrine system is your hormone system, so this phrase “endocrine-disrupting” really just means “chemicals that interfere with your hormones.”

Sounds a bit like steroids. Some of these chemicals can cause testicular cancer. Others affect sperm count. Others have been associated with failure of testes to descend in babies.

That’s the story for men. The reality, of course, is that most of these chemicals are equal-opportunity offenders, affecting both men and women. For women, they can interfere with and disrupt the natural balance of the thyroid system, including the production of thyroid hormones like thyroxine (T4) and the transport protein transthyretin (TTR) that carries T4 around the body.

The assault on women’s health from these chemicals also extends to their reproductive health. Some chemicals commonly found in buildings have been associated with adverse reproductive success—for example, increasing the likelihood by twofold that it will take a year or longer to become pregnant. Women in that study were also more likely to report irregular menstrual cycles.⁴

Let’s now look at how we got to this state of affairs, and what you can do to tackle the problem in your buildings.

Chemicals of Concern

America’s problem with “chemicals of concern” all started with a well-intentioned law in 1976, the Toxic Substances Control Act (TSCA, pronounced “tos-ka”).⁵ The 1970s was a time of intense recognition of the issues surrounding environmental pollution, following the publication of Rachel Carson’s book Silent Spring, which focused on the overuse (and misuse) of pesticides like DDT and the resulting impact on the environment, birds and other wildlife, and human health.⁶ This spurred a series of environmental regulations signed by President Richard Nixon and led to the creation of the EPA, the Occupational Health and Safety Administration, and TSCA.

TSCA was designed to regulate new and existing chemicals. One big problem right out of the gate was that all existing chemicals in use in 1976 were grandfathered in. The EPA was then tasked with sorting out which of these chemicals, if any, represented an “unreasonable risk to human health or the environment.” It had the same goal for new chemicals introduced into the market. Seems straightforward enough, right?

While well intentioned, the EPA has clearly been overwhelmed in the enforcement of TSCA. Just look at the sheer number of chemicals currently in commerce (80,000), the number of these chemicals adequately studied for health and safety (~300), and the number that have been banned since 1976 (4). It seems unlikely that more than 79,700 of the 80,000 of the known chemicals—never mind the unknown—are fully safe for long-term ingestion, inhalation, and direct contact by humans. In fact, the scientific community has identified many dozens, if not hundreds, of chemicals since 1976 that are dangerous to human health but not on the immediate regulatory radar.

But there is a more insidious aspect of TSCA. It has led to repeated swapping out of one harmful chemical for another, in what scientists have dubbed “regrettable substitution.”

Regrettable Substitution: The BPA-Free Story

Here’s how regrettable substitution works. Let’s take bisphenol A (BPA) as an example. We’re certain most of you have seen “BPA-free” baby products or water bottles on the market. This came about as a direct result of a consumer-led campaign against BPA after word got out of its toxicity.

BPA is a compound widely used in plastics that interferes with our natural hormone systems.

To put some specifics on this, BPA binds with your body’s thyroid and estrogen receptors, and a few others. We recognize that phrases like “hormone disruption” and “hormone binding” may not mean much to the average reader (and “endocrine-disrupting chemical” is understood by even fewer), so let’s make this a bit more concrete. A recent review of the toxicological effects of the compound show that BPA can cause abnormalities in the female reproductive tract, decreases in fertility, impacts on the mammary glands, alterations in the function of brain neuronal synapses, and metabolic changes like altered blood glucose and insulin levels.⁷ We could go on, but you get the picture. Hormones are our body’s signaling system, and interfering in that system can affect our major biological systems—from our brain and reproductive systems to our metabolic and even immune systems.

All of these effects, it should be noted, were found at low levels of exposure to BPA (what we call low-dose effects).

We’ll continue the BPA story by focusing on consumer products because that is how most people have heard about BPA, but the phenomenon applies to many building materials as well. BPA is part of polycarbonate and epoxy resins, which means it can be found in building facades and roofs, in paints and caulk, and in flooring and fiberglass binders.

Consumer concern triggered a widespread movement to shun many products, leading to the ubiquitous “BPA-free” labels showing up on baby products, toys, and water bottles on every store shelf. A public health win? Not so fast.

In many cases BPA has simply been swapped for bisphenol S (BPS), a chemical cousin with a similar toxicological profile; BPS is as hormonally active as BPA. BPS, we learned, is also estrogenic and androgenic, just like BPA. And now BPS, having gotten a bad rap, is often being swapped for bisphenol F (BPF), which, surprising no one, targets our body in the same way and has been found to have “actions and potencies similar to those of BPA.”⁸ Why is this not surprising? They are chemical cousins (“structural analogs” is how it would be written in a scientific journal).

So even when the market responds with BPA-free everything, it turns out that in some cases we are simply making regrettable substitutions. This is sometimes referred to as playing a game of “chemical whack-a-mole,” a reference to the carnival game where a mole pops up and the player has to quickly hit it on the head with a soft mallet. As soon as that happens, a similar, but different, mole pops its head out that the player needs to hit. Over and over. Joe wrote about this in an op-ed published in the Washington Post in 2016, showing how this “chemical whack-a-mole” has happened with not just BPA, but also with pesticides like DDT, plasticizers in nail polish, and even the toxic flavoring chemicals used in e-cigs.⁹ There are also a few other notable examples related to building materials that we’ll go into soon.

This is what the current regulatory system allows. As soon as a bad actor chemical is identified, it can quickly be swapped out for a chemical cousin, with no proof needed that the replacement is safe. Thus the cycle starts anew each time, with scientists having to prove that the chemical is harmful after it’s already on the market. We “whack” one chemical only to have a similar one appear. This is how we got BPA → BPS → BPF →?. Simply put, the approach of allowing industry to police itself has not worked. Consumers are being treated as guinea pigs in a global chemical experiment.

Using a test offered by Silent Spring Institute, Joe gave himself and his team at Harvard urine tests as a holiday gift one year so they could all learn about the chemicals in their own bodies.¹⁰ (Nerds!) Turns out, he is a perfect example of regrettable substitution. Check out his results, compared against national averages. Joe is “BPA-free,” just like a baby’s sippy cup. But he’s loaded with BPS.

Nick Kristof, op-ed columnist for the New York Times, took this same test a year later. Guess what he found? Low in BPA, just like Joe. Unlike Joe, Kristof was also low in BPS. But Kristof didn’t escape this saga entirely. He’s an even better example of “advanced stage” regrettable substitution. It turns out he’s loaded with the next substitute for BPA: BPF.¹¹

So if you briefly switched to glass bottles only to have migrated back to BPA-free plastic, you may want to think twice about that decision. Here’s the bad news: there are dozens of stories just like the BPA example. And it’s happening in your buildings right now.

FIGURE 7.1 Test results for Joe’s urinary levels of the metabolite of BPA and BPS, compared against nationally representative US data. Silent Spring Institute.

Chemical Whack-a-Mole on Steroids: Forever Chemicals

A great way to transition to focusing on buildings is to think about the highly fluorinated chemicals we use as water and stain repellents. Like BPA, most of us are familiar with these chemicals from their use in consumer products. We use them in our clothing, outdoor gear, dental floss, cosmetics, nonstick pans, and many other consumer applications. But they are also used in and on products found all over buildings—chairs, couches, curtains, carpets, and paints.

It’s worth taking a look at the chemistry behind these chemicals because it’s fascinating and it helps explain both why consumers like them and why they are so problematic. These stain-repellent chemicals are characterized by the carbon-fluorine bond, one of the strongest bonds in all of organic chemistry. When manufacturers string these together to create a carbon-fluorine backbone, some useful industrial properties appear. This chain of repeated carbon-fluorine links is able to resist oil, water, and grease. The ultrastrong bond is what prevents this stuff from penetrating to the underlying material. That’s why we have coated our furniture, camping tents, and even our clothing with these chemicals for the past 60 years or so. It’s the chemistry behind our nonstick pots and pans and waterproof rain jackets and tents, and it’s a component of aqueous film–forming firefighting foam.

The problem is multifold. First, the chemicals don’t always stay in the products—they escape, entering our air, food, and water. Ever wonder why your nonstick pan loses that nonstick ability after some time? Or why some stain-repellent surface treatments ask you to reapply every few months? Where do you think the chemicals are all going? The answer is that they are now found all over the globe, from the polar regions to the middle of our oceans, inside our buildings, and inside all of us. Ninety-eight percent of Americans have at least one set of these chemicals in their blood.12

Second, that superstrong bond comes with a dark side: the bonds are so strong that these chemicals will never fully break down in the environment. Ever. And when we say “ever” here, we mean millennia. This is why Joe dubbed them “Forever Chemicals” in an op-ed he wrote for the Washington Post.¹³ The name is a play on the F and the C that constitute the carbon-fluorine bond, while also highlighting their most salient feature—extreme environmental persistence. (The technical name for these chemicals is “per- and polyfluorinated alkyl substances” [PFAS]—technically accurate but wholly inaccessible terminology for the general public.)

A skeptic might reasonably ask, Is there a health concern with these chemicals? The answer is a resounding yes. In fact, these are the very chemicals we were referring to when we first mentioned chemicals that are associated with testicular cancer in the beginning of this chapter.

Some Forever Chemicals, such as C8, are also associated with kidney cancer.¹⁴ The public learned this only after an egregious environmental contamination issue surfaced. DuPont, the maker of many products using Forever Chemicals, was dumping them into the Ohio River for many years from its Washington Works plant in Parkersburg, West Virginia. The river supplied drinking water to tens of thousands of people downstream, who were unknowingly drinking the contaminated water. A resulting lawsuit revealed the shocking scale of this dumping activity, and the courts, seeking to understand the potential impact on those downstream, created a scientific panel (the C8 Science Panel) to investigate the spread of these chemicals in the water and throughout the environment (the plant was also emitting Forever Chemicals into the air). The C8 Science Panel was charged with determining whether there were “probable links” to human health effects.¹⁵ Through a series of rigorous, high-profile research studies, the panel established an association between exposure to C8 and cancer. Subsequently, a class action lawsuit was filed against DuPont and the plaintiffs were awarded $671 million. (Full disclosure: Joe worked as an expert witness for the plaintiffs in this lawsuit.) This story was subsequently told in the movie Dark Waters.

Other studies have shown that some Forever Chemicals also elicit the most dramatic immune suppression ever observed for an environmental toxicant¹⁶ and interfere with body weight regulation.¹⁷ So much so that they are now being called “obesogens”—meaning that they may contribute to the obesity epidemic in America. Even if you don’t use nonstick pans or spend time on office chairs whose fabric has been coated in this stuff, you still can’t escape—they are in the drinking water of tens of millions Americans above the “safe” level set by the EPA, according to a study led by Elsie Sunderland and her team from the Harvard T. H. Chan School of Public Health and John A. Paulson School of Engineering and Applied Sciences.¹⁸

And just like the BPA → BPS → BPF example, the original Forever Chemical that grabbed our attention, C8, has now been swapped for C6 and C10 (C is the number of carbons; C8 has an 8-chain carbon-fluorine backbone, C6 has 6, and C10 has 10). C8 started to get a bad rap with major lawsuits under way in the mid-2000s. A book was even written about it called Stain-Resistant, Nonstick, Waterproof, and Lethal: The Hidden Dangers of C8.¹⁹ With the rising public awareness of these hazards, C8 was phased out. But that doesn’t mean the problem was solved. One C6 variant that has captured headlines is known as “GenX,” having gained notoriety because DuPont (now Chemours) was dumping GenX into the Cape Fear River in Fayetteville, North Carolina—a river that supplies drinking water to people in the Wilmington, North Carolina, area.²⁰ Because the scientific community has only recently begun to investigate GenX, there aren’t any human health studies yet. But what we know from animal toxicology studies is damning—cancer of the liver, pancreas, and testicles.

GenX is not the end of the story. We wish the story of regrettable substitution with Forever Chemicals were as simple as the linear BPA story: BPA → BPS → BPF. For Forever Chemicals, it’s more like the mythical Hydra, where every snake head that is cut off returns in multiples. Sure, we wised up to the dangers of C8 and banned them from the market. But instead of just one or two substitutes, like C6 and C10, there are over 5,000 variants of these Forever Chemicals! It’s chemical whack-a-mole on steroids. The game is exhausting, and dangerous.

Chemical Flame Retardants

If you thought that was a crazy story, wait until you read about this one.

This story starts in the mid-1970s, with the use of chemical flame retardants in kids’ pajamas. (Do kids spontaneously combust?) One chemical flame retardant used in pajamas, which we’ll call “tris” for short, was a brominated flame retardant. (Think of the far-right side of the periodic table, where the halogens reside. We’ve been talking about one halogen already, fluorine, and now we’ll talk a bit about the halogens bromine, chlorine, and iodine.) This chemical, tris, was known to be carcinogenic and mutagenic (that is, it damages DNA), but it only really grabbed the public’s attention after a simple (and elegant) study that showed that tris “escapes” from pajamas and gets into the bodies of kids.²¹ In that study, they tested the urine of kids in the morning, comparing those who wore pajamas treated with tris with those who did not. They showed, definitively, that tris was being absorbed into the body overnight. As a result, tris was banned from the market. (By now in this chapter, you know this is not the end of the tris story. We’ll move on chronologically, but stay tuned for more on tris.)

Also in the 1970s, another brominated flame retardant was in use, and this one was used in buildings. Polybrominated biphenyls (PBBs) are a class of flame retardants that were used in plastics found in televisions and in foam found in couches and chairs. PBBs were used in our buildings and consumer products for about a decade, but then use abruptly stopped. Why? A crazy, but true, story about how a human error at a manufacturing plant led to the poisoning of Michigan and a toxic legacy that lasts through to today.

A chemical company that sold PBBs in the 1970s, Michigan Chemical Company, also sold animal feed supplement. A shortage of preprinted bags at the packaging plant led to an accidental mislabeling, and bags of PBBs were shipped out as cattle feed supplement.²² Want to hazard a guess as to what happened next? Farmers and ranchers reported animals with a loss of appetite (go figure …). Then things got bad. These PBBs are lipophilic chemicals—literally “fat loving.” As the cows ate the PBBs, they stored the chemicals in their fatty tissue. It was months before the mislabeling issue was discovered, and by that time PBBs had lodged themselves into the fatty tissue of millions of animals in the food chain. Humans, at the top of that chain, were the final repository of these PBBs.

The remedy? PBBs were banned and millions of animals had to be killed (culled, in the “make us feel OK about this” parlance). But it was too late—by then, anyone consuming meat in Michigan was consuming those PBBs and, just like the animals, storing those PBBs in their own fatty tissue. But we can’t cull humans (!), so the result is … the people of Michigan were unwilling participants in a great human toxicological experiment.

The environmental persistence of PBBs and their ability to store in our bodies meant that this was not a problem that went away quickly. The legacy persists to this day: 60 percent of people tested in Michigan in the 2000s still had levels of PBBs in their bodies that were higher than 95 percent of the rest of the US population. And it’s a toxic legacy—a summary of research findings hosted at Emory School of Public Health shows that women with higher levels of PBBs in their blood had fewer days between menstrual cycles, more days of bleeding, lower estrogen levels, and higher rates of breast cancer.²³

But that’s not where things ended.

It turns out that kids born to parents from Michigan have PBBs in their blood, despite being born after the ban went into place. Their moms passed these PBBs to them through the womb and through breastfeeding. Boys born to moms with higher levels of PBBs in the body reported more genital and urinary issues. Girls born to moms with higher levels of PBBs in the body started menstruating a year earlier than their peers. When these girls became women of childbearing age, they were more likely to suffer miscarriages.

Three generations have been affected.

As shocking as these results were, they shouldn’t really have been unexpected. As far back as 1978, a Harvard study reported that “these compounds readily enter the fetus by crossing the placental barrier and can be transferred to newborn children after extensive passage into breast milk.” “Interestingly,” the study went on, “low doses of PBBs exert a broad spectrum of toxicological, pharmacological, and biochemical effects despite low acute toxicity,” causing the authors to conclude that “PBBs are teratogenic, immunosuppressive, and potentially carcinogenic” (emphasis added).²⁴

Knowing that PBBs are toxic to animals; knowing, based on research published in 1978, that PBBs cross the placenta and are teratogenic (that is, that they can alter the normal development of an embryo or fetus), and possibly carcinogenic; and seeing that the populace was rightly outraged after the Michigan debacle, what was the industry response? Add an oxygen in the middle of the molecule and create a “new” brominated flame retardant to be used just like PBBs—in couches, chairs, mattresses, and plastic casings around televisions and computers.

From the perspective of the market, and regulators, this was a new chemical with a new name. No longer PBBs, but PBDEs—polybrominated diphenyl ethers. The only way to really show you the insanity and the shortsightedness of this approach is to show you the chemical structures. You don’t need a degree in organic chemistry to see that the “safe replacement” for PBBs looks an awful lot like the original.

For both PBBs and PBDEs, there are two rings (called phenyls in organic chemistry). Depending on the number of bromines and their position on the rings, you can have up to 209 variants (called congeners). Here we are showing two tetrabrominated flame retardants (four bromines). The only real difference is that, for PBDEs, there is an oxygen between the rings (this is called an ether). That is the full deconstruction of the name “polybrominated diphenyl ether.”

PBDEs were used from the early 1980s through the mid-2000s, much of that time escaping the notice of health scientists and the public. It wasn’t until a Swedish study was published in the early 2000s that concern started to rise. In that study, researchers looked at breast milk samples from a biobank, which had stored samples dating back to the 1970s. These scientists noticed an exponential rise in the level of this “new” chemical in the breast milk.²⁵ (New to researchers, anyway; the industry certainly knew about it.)

FIGURE 7.2    Chemical structures of PBBs and PBDEs.

This sparked intense interest from researchers—a “scientific feeding frenzy,” in the words of professor Tom Webster at Boston University.26 The scientific process followed a familiar pattern, asking and answering a series of questions.

Where were these chemicals in our environment? (Answer: in air and dust in every home, office, school, and place we looked, including in polar bears, eagles, and sea turtles.)²⁷

Could they be found in humans? (Answer: yes. They are detected in the blood of nearly everyone.)²⁸

Were they determined to be toxic in animal studies? (Answer: yes. PBDEs interfere with thyroid hormones and affect neurodevelopment reproductive systems.)²⁹

Was that enough to ban them? (Answer: no. Claims were made that the results of animal studies do not represent human health effects.)

Were human health effects found in the subsequent human studies? (Answer: yes. Surprising no one, the human studies found what the animal toxicology studies found: impacts on the thyroid, neurological development, and reproduction.³⁰ In one study, Joe and his collaborators found that women with higher levels of PBDEs in their body had a higher risk of developing thyroid disease—a risk that was threefold higher for women postmenopause.)³¹

What was the mechanism of action? (Answer: PBDEs look an awful lot like your endogenous thyroid hormone T4.) And here, we get to bring in that last halogen we haven’t yet touched on—iodine. T4 has a phenyl ring on one end of it, just like the one we showed you for PBBs and PBDEs. But instead of bromines around it, T4 has iodine.

FIGURE 7.3 Chemical structure of thyroid hormone T4 showing similar ring and halogen structure as PBBs and PBDEs (left side).

If you have a keen eye and were comparing T4 in Figure 7.3 with the PBBs and PBDEs in Figure 7.2, you might have noticed that the left side of T4 here looks similar to PBBs and PBDEs. But you might have also noticed that T4 has an -OH hanging off that ring, whereas PBDEs do not, and maybe you were wondering if that difference made them dissimilar.

Well, that -OH is called a hydroxyl group, and after PBDEs (and PBBs and many other chemicals) enter our body, our metabolic system tries to make them a bit more water soluble by adding this -OH group right in between the two bromines, just like the -OH in between the two iodines. Once that happens, these “hydroxylated” PBDEs look even more like T4. In other words, PBDEs already look a lot like T4, but once PBDEs enter the body, they transform into something that looks even more like T4 than the original chemical. Does our body notice?

The science shows how much our bodies are confused by these chemicals. These hydroxylated PBDEs have a binding potency to thyroid transport proteins that is up to 1,600 times higher than PBDEs without the -OH.³² They also inhibit a key enzyme that regulates estrogen with a potency up to 220 times higher than PBDEs without the -OH.³³ This may be getting slightly technical, but once you see the mechanism of action, you can understand how much PBDEs trick our body’s hormone receptors, inviting them to mistake hydroxylated PBDEs for endogenous hormones. In light of this, the research showing that PBDEs interfere with thyroid hormones and are associated with thyroid disease make perfect sense.

Recall, PBDEs were introduced in the early 1980s. But research on exposure and toxicity only started in earnest in the late 1990s. This body of research on PBDEs took more than a decade to accumulate. In the end, after 30 years of use and widespread global contamination, for 20 of which they were entirely off the radar of health scientists, PBDEs were banned.

If you think the story ends here, you haven’t been paying attention.

Once PBDEs were banned, a whole new set of regrettable substitutes were introduced, one of which was tris. (We warned you that we weren’t done with tris from the kids pajamas just yet …) But how could that be? We told you tris was banned in the 1970s after the pajama fiasco. Well, it turns out that brominated tris was banned in the 1970s, but its chemical cousin, chlorinated tris, also used in kids’ pajamas during the 1970s, wasn’t technically banned. It was just quietly removed from the market—only to be reintroduced as a “safer” alternative to PBDEs 30 years later. Again, like PBDEs, we only discovered this when enterprising scientists like Heather Stapleton at Duke University started to investigate a “new” and curious chemical that started showing up in the data—but this time it wasn’t in breast milk from a biobank. This time Stapleton and colleagues started seeing tris in baby products.³⁴ It was everywhere, and at high levels. It turns out that chlorinated tris was being used in kids’ car seats, baby chairs, changing-table pads, nursing pillows, and mattresses. Oh, we almost forgot to tell you—tris is carcinogenic.³⁵

But this is also not the end of the story.

Tris got a bad rap, again. So, with attention turning toward the halogens (bromine and chlorine), the industry deftly moved on to another set of chemical flame retardants. Next up in the “regrettable substitution” chain were halogen-free organophosphate (OP) flame retardants.

The idea that these OP flame retardants were “safer” was soon debunked. A study led by the chair of Joe’s department, Russ Hauser, showed that OP flame retardants were associated with severe adverse reproductive issues, including a decreased likelihood of fertilization and embryo implantation and a decreased likelihood of having a clinical pregnancy.³⁶ It gets worse—if you were lucky enough to get pregnant, those with higher levels of OP flame retardants in their body were less likely to have a live birth. (As of the writing of this book, OP flame retardants are still widely used in buildings.)

Do we need these flame retardants? It turns out that our massive global experiment in flame retardants was thrust on us by an intense industry lobbying effort in the 1980s that aimed to take the focus off cigarettes as the core cause of an increase in the number of house fires and redirect that focus to the products that caught fire. In an outstanding six-part series called “Playing with Fire” published in 2012, the Chicago Tribune uncovered the work of tobacco lobbyists as they pushed to limit regulations that favored self-extinguishing cigarettes in favor of putting flame-retardant chemicals in … well, everything.³⁷ The award-winning series shows how these lobbyists relied on, and promoted, faulty science and testimony from an unscrupulous doctor who fabricated tales of children burning in fires, among other tried and true tactics intended to manufacture doubt. This led to the widespread and global use of flame-retardant chemicals in couches, chairs, curtains, televisions, remote controls, drywall, computers, pillows, and on and on.³⁸ Another gift from Big Tobacco.

(There are two terrific books that describe these tactics used by companies to inject doubt into the scientific debate, if you want more examples: Doubt Is Their Product, by David Michaels, and Merchants of Doubt, from our Harvard colleague Naomi Oreskes and her coauthor Erik Conway.)³⁹

BPA, Forever Chemicals, and flame retardants are but three of many examples of harmful chemicals in our products and in our living and working spaces. Phthalates, pronounced “tha-lates,” are another group of chemicals found all over our buildings. They are primarily used as plasticizers in polyvinyl chloride (PVC). The short list of where they can be found in our buildings includes flooring, sealants, adhesives, upholstery, and shower curtains. Why do we care about phthalates from a human health perspective? Because they have been found to interfere with our bodies’ natural hormones, altering sexual development. To get a sense of what that means, consider this list: phthalates have been linked to the absence of the epididymis (testicular duct that carries sperm), failure of the testicles to descend (cryptorchidism), opening of the urethra on the underside rather than the tip of the penis (hypospadias), decreased anogential distance, and testicular lesions.⁴⁰ One study found a relationship between phthalates and premature breast development.⁴¹ In another large study of children, higher levels of the phthalate BBzP in dust was associated with rhinitis and eczema, and another phthalate (DEPH) was linked with asthma in kids.⁴²

Stay with us through this depressing story; we will give solutions for how to break this vicious cycle at the end of this chapter. But first, let’s look at the economic impacts.

The Business Impacts of Chemicals of Concern

So far we’ve made the case for why these chemicals matter from a health science perspective. The chemicals we are talking about are toxic, and they can be found all over our buildings: in chairs, couches, carpet and carpet backing, hard flooring, wallboard, ceiling tiles, composite wood materials, wall insulation, electronics, and even things like grout. What about the business perspective? This one is easy.

To get a sense of the scale of what’s at stake, consider this: one year after the landmark $671 million lawsuit against DuPont,⁴³ 3M settled one for $850 million. At issue in the 3M case was the years-long dumping of Forever Chemicals (used in products like Scotchgard and Teflon) at four manufacturing sites.⁴⁴ That’s $1.5 billion in legal settlements around one class of these Forever Chemicals in year—$1.5 billion.

We might also look at legacy pollutants and what they cost to the building industry. Anyone with a building constructed before 1976 is undoubtedly familiar with the legacy pollutants asbestos and polychlorinated biphenyls (PCBs). For those not familiar with PCBs, they are a class of chemicals that were used in transformers but also light ballasts, caulking, and exterior paint. (For those not familiar with asbestos, it is a mineral mostly used for insulation in buildings that was found to cause mesothelioma and asbestosis, a chronic lung disease characterized by shortness of breath and scarring of lung tissue.) Banned in the 1970s, these chemicals are long lasting and still an issue in older buildings.

Building owners are also undoubtedly familiar with the costs associated with dealing with asbestos and PCBs in any renovation project. By some estimates, safely removing and disposing of the PCBs in the caulking from an old building will cost you $9–$18 per square foot. That figure goes up to $24 / sq. ft. if it’s the exterior paint you’re dealing with, and add in an additional $6 / sq. ft. for transportation and disposal of the hazardous waste.⁴⁵ Same for asbestos, which will cost you an additional $5–$15 / sq. ft. if you find it during a renovation (and up to $150 / sq. ft., depending on the type of building and difficulty of accessing the materials). Not to mention the disruption to work and risks to brand—having a team of workers running around your building in full hazmat gear for a few weeks isn’t generally considered good for business.⁴⁶

All that to say, it’s not a stretch to think about the millions of dollars in additional expenses caused by legacy pollutants, and then to realize that PCBs share some common traits with chemicals that are currently in wide use in our buildings. PCBs are just like PBBs, except with chlorine instead of bromine. That means PCBs are also very similar to PBDEs and other brominated flame retardants. And this means that they look like thyroid hormone T4, too. (Not surprisingly, studies that examine the combined effect of PCBs and PBDEs show a synergistic impact on thyroid hormones in the body.⁴⁷ To our regulatory system they are different, but to our bodies they look very similar.) The Forever Chemicals all have fluorine, another halogen. All of these chemicals are persistent, bioaccumulative, and toxic—and found all over our buildings. It doesn’t take a great leap to extrapolate that future remediation of these newer chemicals, not to mention toxic torts—and settlements—is likely.

Having trouble winning this economic argument at work based on remediation and disposal costs? Then ask this: What is the cost of providing a work environment laced with chemicals that interfere with a young woman’s or young man’s chance of reproductive success? Mention “testicular cancer” or “decrease in live births” and see what response you get. We have seen it stop a recalcitrant architect in his tracks. But too few people know about this, and few doctors ever make a connection between problems of infertility and the flame retardant in the insulation in the walls or in your office chair.

New TSCA

TSCA has set us up with a regulatory framework that (1) has failed to address the 80,000 chemicals in commerce and keep pace with the 2,000 new ones introduced each year, (2) has failed to even catch and ban known bad actors like asbestos, (3) has succeeded in giving us a false sense of assurance that replacements are “safe” despite the problem of regrettable substitution, and (4) has set up building owners with the prospect of millions of dollars in future liabilities around what will most certainly become future legacy pollutants.

The gross failings of TSCA spurred the creation of a new TSCA in 2016—the Frank R. Lautenberg Chemical Safety for the 21st Century Act—named after Senator Lautenberg, who championed the legislation. Unfortunately, the new act is not off to a great start. Promulgated under the Obama administration, it required that the EPA start reviewing the 80,000 chemicals currently in use. But with 2,000 new chemicals coming into the market each year, what was the plan to tackle the backlog? Well, it listed 10 chemicals the EPA would start with, including trichloroethylene, perchloroethylene, and methylene chloride. Do the math—it would take hundreds of years at this speed to tackle the tens of thousands of chemicals waiting to be evaluated.

Still, the new Lautenberg Act was thought to be a big improvement on the old TSCA because at least it started to address this problem. But a few years in, we are still working on those same 10 chemicals. And yes, asbestos is on that list and unbelievably still has not been banned. Supporters of new act blame this lack of progress on the Trump administration, which has deprioritized this work, but you have to wonder: Was it ever going to work? Seems like there were obvious flaws, right from the beginning.

Lack of Transparency = Lack of Awareness = Lack of Action

What is a building owner, developer, tenant, or consumer to do? Well-intentioned decisions to buy “BPA-free” products have really meant we have been buying products that should be labeled “BPA-free* (*but contains BPS).”

Imagine walking through your local grocery store and picking up a granola bar that only had a label that said, “peanut-free,” but that didn’t tell you that the peanuts were substituted for almonds, another common nut allergen. This is akin to what happened with “BPA-free”; they told us one potentially harmful chemical wasn’t in the product, but they didn’t tell us what else was in there that was apt to be harmful.

This is unacceptable. On our food packaging we see the claims about “peanut-free” but we can also verify this by looking at the fully disclosed ingredient list, and we can see what else might be in there that we should be aware of. We do the opposite for our buildings and the products we put in them. Ask a building owner about the chemicals that are in the building materials or products in his or her building and the owner will give you a blank stare. (Can you imagine if a food product manufacturer didn’t know what was inside its product?)

But it’s worse than this. If that same building owner asked his or her product suppliers what’s in their products, the product supplier may not even know. Take this example (not from buildings, but you will get the point). Joe was at several meetings with a major airline manufacturer that at the time was working to remove the toxic flame-retardant chemical decabromodiphenyl ether (deca for short) from its airplanes in response to new restrictions on its use as a result of the aforementioned phaseout of PBDEs. What he learned was shocking. It took them 18 months just to determine where in the airplane this chemical was used. This company didn’t readily know. And neither did their suppliers, apparently.

The same thing is true of buildings.

The underlying issue is one of a lack of transparency, tracking, and tabulation. Transparency is what we get on a food nutrition label—a full disclosure of what we are putting into our bodies. Going forward, the absolute first step must be transparency. We simply must know what we are putting into our buildings. This seems eminently reasonable, and at some level it is sad that it even has to be written.

But it has to be real transparency. Take what happens with personal care products as a note of caution, because personal care products walk a fine line here. Many have ingredient labels, but that information is not completely transparent. Take a look at your shampoo bottle the next time you’re in the shower. You’ll see the ingredient label, but you’re also very likely to see one of those ingredients listed as “fragrance.” Hmmm. That seems like a disclosure of the ingredients, but at this point in the chapter you should be asking yourself, What do they mean by “fragrance”? Turns out, in many cases, “fragrance” is a code word for phthalates. (In addition to their use as a plasticizer for PVC, phthalates act as a gelling agent in consumer products, allowing the actual fragrance to last longer in the product.)

There has been some positive movement on the transparency front. Groups like the International Living Future Institute have put forth the Declare Label project, which aims to get material suppliers to disclose what’s in their products. Most everyone, we think, would agree that we need to have more transparency. But it is also not sufficient to tell a customer (be it a dad at the grocery store or the owner of a multibillion-dollar building), “This product contains 2,2,4,4-tetrabromodiphenyl ether,” because that doesn’t mean anything to anyone. What we really need is a full reckoning of ingredients with potential health concerns. This is where groups like the Health Product Declaration (HPD) Collaborative have helped to advance the field by developing HPDs that not only list the ingredients but also list the potential health hazards. A real strength here is that the HPD Collaborative is a not-for-profit open standard with over 250 members, including architects, designers, owners, and manufacturers, and the HPDs are harmonized with the Healthy Building rating systems we discuss in Chapter 8. A key goal for these groups is increased transparency in the building and construction market. The ultimate goal, of course, is to drive solutions upstream, through green chemistry, for example.

But there is a cautionary tale to all of this. We can’t just go around doing what California did with Prop 65.⁴⁸ (For those unfamiliar with this, it is the law that has led to the rise of everything—and we mean everything—being labeled as “potentially containing carcinogens.”) This is a great, and sad, example of the backfiring of a well-intentioned law requiring health disclosures on products. The law has resulted in buildings in California having to post a sign to this effect:

Please be advised this building may contain chemicals or materials known to cause cancer or reproductive harm.

—State of California Proposition 65 Health and Safety Code; Chapter 6.6, Section 25249.6

Given the choice between souvenir coffee cup A, which has the Prop 65 label, and cup B, which doesn’t, a consumer might be more likely to choose cup B. But for buildings, it’s all but meaningless at this point. All that label is telling us is that somewhere in the building there is a chemical that may be a carcinogen. There is pretty much no chance of any consumer altering his or her choice because of that information. Very few people are in a position to switch jobs because of a diffuse warning like this; not a lot of patients would refuse to meet with their doctor in one of these buildings; and how many clients will turn away from a conference meeting after coming across that notice by the entrance of the building?

One Solution: Leveraging Demand-Side Purchasing Power for Market Transformation

With an “innocent until proven guilty” regulatory approach that is currently incapable of protecting us from chemicals of concern in consumer products and building materials, a 50-year-old supply-side approach that has delivered decades of regrettable substitution, and a Prop 65–type law that is all but meaningless for buildings, a new approach is needed. We have been working with leading companies on a market-based solution that focuses on the demand side of the equation—the buyers—to accelerate a shift to healthier building materials.

At Harvard, we started with a simple idea: we cannot ignore the science produced by our own scientists. Great research on BPA, Forever Chemicals, and many other chemicals of concern is being done at universities across the world, including our own. So we asked ourselves, How can we possibly continue to purchase products with these chemicals? The answer is, we can’t. So we decided to put this research into action. We partnered with Heather Henriksen, the managing director of the Harvard Office for Sustainability, and created the Harvard Healthier Building Materials Academy. This academy has a goal of putting research into practice: to use the latest scientific evidence to inform purchasing practices at Harvard, and beyond.

We aggressively educated the purchasing community at Harvard on the science, and then, thanks to the tireless work of Henriksen, her team, and an army of purchasers, project managers, product specifiers, designers, executives, and facilities managers, we showed that we could actually purchase products with a lower overall toxic load without affecting product performance, project timelines, or costs. As of the writing of this book, there are dozens of projects under way on campus that are piloting new green building standards that specify the use of products without certain chemicals of concern like flame retardants, stain-repellent Forever Chemicals, and antimicrobials, for starters.

As with everything we do, our goal is not simply to improve conditions at our home institution; we aim to promote solutions well beyond Harvard. So we announced a partnership with Google in 2018 and began working with other leading companies with a similar mission and vision. If the leadership team at Google wouldn’t buy food without knowing the ingredients, why would they buy products for their buildings without knowing what’s inside them? Amazingly, Google is a company focused on organizing the world’s data, but like the rest of us, its leaders were flying blind when it came to data about the products they were putting into their own buildings. That’s changing.

Along the way, we came across many other organizations, architects, and construction firms confronting these same challenges. We realized many of us were aligned on mission and vision, but not on how we were approaching suppliers. We were in fact contributing to the confusion in the market space because we were asking for similar things in slightly different ways. But this is evolving. The market is quickly coming up to speed on the potential hazards of these chemicals and developing solutions. For example, the international design firm Perkins + Will has put together Transparency, a web-based resource on material health that brings together toxicity concerns and practical information on which building products are likely to contain toxic chemicals.⁴⁹ Recognizing that industry and science are dynamic, it also has a “Watch List” to go along with its “Precautionary List” so it and others can work to avoid any future regrettable substitutions.

BOX 7.1    Healthier Materials Approach

FOLLOW THE PRECAUTIONARY PRINCIPLE

• Use a “health first” mind-set and err on the side of caution (or on the side of human health).
• “Less toxic” is not “nontoxic” and “safer” is not necessarily “safe.”
• Do not ignore history. (It can’t be called “regrettable” if we knowingly do it over and over.)

IT’S UP TO YOU TO ACT

• Regulation has been proven ineffective; industry has not successfully policed itself.
• “Innocent until proven guilty” may be good for criminal justice, but it is disastrous chemical policy.
• Avoid future “legacy pollutants” and their associated massive costs. (What are the next PCBs?)

START WITH A FEW CLASSES OF KNOWN “BAD ACTORS”

• A class approach is warranted for some bad actors like flame retardants and stain repellents (because it’s impossible to deal with these chemicals one at a time when there are over 5,000 variants).
• Persistent organic pollutants are an issue: an indoor hazard today is an outdoor hazard tomorrow.

LEVERAGE EXISTING SCIENCE

• Demand to know what’s in the products you are buying and putting into your building.
• Don’t ignore science simply because the regulatory apparatus has not caught up (remember, the EPA still hasn’t formally regulated asbestos). Regulations trail leading science by years, or even decades.
• Don’t delay decisions based on manufactured doubt. (Oftentimes we “know enough to know” that we shouldn’t use some chemicals, but there are calls for more evidence and additional studies, which leads to delays.)

PRIORITIZE BASED ON THE LARGEST PRODUCT CATEGORIES IN YOUR BUILDING

• Consider the largest product categories by volume or mass (think about the overall “toxic load” in a building).
• Identify alternatives in most purchased products. (For many of these largest product categories, the market has products that don’t have these chemicals of concern and the product performs the same and costs the same.)

THE PROCESS IS DYNAMIC

• Take this approach where feasible (alternatives for some products may not be available … yet).
• Do not violate code (flame retardants are still required in some instances, for example).
• Create a watch list to track what you should be thinking about next (nanomaterials, anyone?).

Our recommended approach, in broad terms, is simple: start with transparency; identify a few classes of toxic chemicals that we can all agree we don’t want in our buildings; identify a few of the largest product categories in use in buildings; recognize that uncertainties exist; make decisions based on the best available science; take a precautionary approach, with eyes wide open about regrettable substitutions and legacy pollutants; and focus on optimizing for health.