Why Zero VOCs, green certifications, and positive reviews do not prove a product is safe.

© 2014-2026 Joel Hirshberg

WARNING: This document is technical, and the truths expressed might make you feel uncomfortable or angry.

First, a quick disclaimer: I'm not a doctor, a chemist, or a scientist. Over the last 35 years, I've learned how to evaluate the performance and safety of chemicals through direct field testing of hundreds of products. This includes decades of conversations with chemical technicians and thousands of people with allergies, asthma, and chemical sensitivities. Much of the technical information included here is straight off the US government's websites.

[Click Here to download the pdf version of this paper]

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PURPOSE

It's a simple question: is it safe? Not so easy to answer. Safety is a theoretical concept and almost impossible to define. The US government can't define safety, so it defines what toxicity and hazards are. The absence of toxicity, however, does not mean a product is safe. For example, just because a safety data sheet says there is no lead in the paint, or has low or no VOCs, doesn't mean it's magically safe. Also, just because a product has a green eco-label and a third-party certifier says a product complies with California standards, it doesn't guarantee it's safe either. And finally, just because thousands of reviewers say a product did not harm them, it doesn't ensure it's safe for you and your family.

We should not trust any of these tools of discovery, by themselves, to reveal the truth beyond a reasonable doubt. Aside from the fact that they can be highly technical, confusing, and painfully boring, when taken by themselves, they can also be misleading and give you a false sense of security.

My purpose here is to give you insight into how our government and society decide what is safe and what is hazardous or toxic. After reading this, it's my hope that you will become more skeptical the next time you read a product label, safety data sheet, or review—and have enough curiosity to do more of your own research and personal testing.

Why OSHA Matters (and Where It Doesn't)

It helps to understand how government agencies classify chemicals. A good starting point is the standards laid down by the Occupational Safety and Health Administration (OSHA).

OSHA rules are generally written for manufacturers and for public buildings such as schools, hospitals, hotels, theatres, conference centers, etc. There are enforceable standards and guidelines that must be met in order to maintain a safe environment for employees and occupants who work or live inside those buildings.

To maintain safe and clean indoor air quality (IAQ), these buildings have regulated ventilation systems that guarantee a certain number of air exchanges every hour and maintain standards of cleanliness that are reviewed regularly. Employers must provide Safety Data Sheets (SDS) to employees to explain how to safely handle chemicals that might be hazardous to their health.

Now compare that to a small business or residence: it is much smaller, may have inadequate ventilation (or none), and generally doesn't comply with any indoor air standards beyond what the owner decides that day.

OSHA rules were never intended for small businesses or residences. The Environmental Protection Agency has made it clear that they cannot and do not want to control indoor air quality (IAQ) inside someone's home or business.

While there are many guidelines for building and remodeling residences and small businesses, there is no enforcement of IAQ or product safety in these spaces. It is all "controlled," in theory, at the manufacturing or importing level. Manufacturers of consumer goods and building materials are expected to rely on OSHA's definitions, classifications, and standards.

OSHA: Hazard Communication Standard (https://www.osha.gov/dsg/hazcom/side-by-side.html)

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Definitions

Let's start with a few basic definitions of chemicals.

"Chemical" means any substance, or mixture of substances.

"Substance" means chemical elements and their compounds (i.e. VOC) in the natural state or obtained by any production process, including any additive necessary to preserve the stability of the product and any impurities deriving from the process used, but excluding any solvent which may be separated without affecting the stability of the substance or changing its composition.

Here's a link to a complete inventory of chemical substances on the Toxic Substance Control Act. Of the 86,000 industrial chemicals listed, only 9 have been banned from use.

"Mixture" means a combination or a solution composed of two or more substances in which they do not react.

"Threshold Limit Value" (TLV) refers to a numeric value of airborne concentrations of chemical substances and represents conditions under which it is believed that nearly all workers may be repeatedly exposed over a working lifetime without adverse effects. TLVs will not protect all workers. Some may experience discomfort or serious adverse effects when exposed to a chemical substance at the TLV or even at concentrations below the TLV. Reasons for increased susceptibility to a chemical substance include: age, gender, genetic factors (predisposition), lifestyle choices (diet, smoking, abuse of alcohol or drugs), medications, pre-existing medical conditions (asthma, allergies, chemical sensitivities), etc. (American Conference of Governmental Industrial Hygienists, ACGIH)

Clearly these hygienists realize that there is no one-size-fits-all solution when it comes to chemical safety, as there are too many factors affecting how humans react to chemicals that are outside of their control.

"Health hazard" According to the FEDERAL HAZARDS SUBSTANCE ACT 15 U.S.C. §§1261−1278, the term "hazardous substance" means:

(A) Any substance or mixture of substances which (i) is toxic, (ii) is corrosive, (iii) is an irritant, (iv) is a strong sensitizer, (v) is flammable or combustible, or (vi) generates pressure through decomposition, heat, or other means, if such substance or mixture of substances may cause substantial personal injury or substantial illness during or as a proximate result of any customary or reasonably foreseeable handling or use, including reasonably foreseeable ingestion by children.

Here's the tricky part: the use of the terms substantial and foreseeable are not defined, but they are extremely important. Many illnesses or environmental hazards don't appear "substantial" until many years later, like asbestos, which can take up to 40 years. Bioaccumulation of chemicals that don't biodegrade (i.e., "forever chemicals" such as PFAS) can persist for decades and cause real harm later on. Nicotine is a classic example of a long-term hazard that does not cause substantial personal injury initially.

https://www.osha.gov/laws-regs/standardinterpretations/1997-05-15-1

"Acute Toxicity" refers to serious adverse health effects (i.e., lethality) occurring after a single or short-term oral, dermal, or inhalation exposure to a substance or mixture.

If you want a long and eye-opening read, check out the criteria for determining whether a chemical is classified as a health hazard. It's not as simple as you might think.

Appendix A to §1910.1200 -- Health Hazard Criteria (Mandatory).

The more you read, the more you will realize how challenging it is for the government to define a health hazard and, conversely, what might make a product safe for everyone in all situations.

 

Pictograms and Hazards

We've all seen the warning labels below on product labels and Safety Data Sheets. These can be helpful, but they also leave out important information.

 

Health Hazard Carcinogen Mutagenicity Reproductive Toxicity Respiratory Sensitizer Target Organ Toxicity Aspiration Toxicity	Flame Flammables Pyrophorics Self-Heating Emits Flammable Gas Self-Reactives Organic Peroxides	Exclamation Mark Irritant (skin and eye) Skin Sensitizer Acute Toxicity Narcotic Effects Respiratory Tract Irritant Hazardous to Ozone Layer (Non-Mandatory)
Gas Cylinder Gases Stored Under Pressure, Liquified Gases, Dissolved Gases	Corrosion Skin Corrosion/Burns Eye Damage Corrosive to Metals	Exploding Bomb Explosives Self-Reactives Organic Peroxides
Flame Over Circle Oxidizers	Environment Aquatic Toxicity	Skull and Crossbones Acute Toxicity (fatal or toxic)

 

What These Warnings Do NOT Cover

These warnings do not provide any context, nor do they require labeling of the following chemicals:

• Any pesticide, insecticide, fungicide, or rodenticide

• Any food, food additive, coloring, drug, cosmetic, medical or veterinary device

• Any distilled spirits, wine, etc.

• Agricultural or vegetable seed treated with pesticides

• Tobacco or tobacco products

• Wood or wood products that are not processed

• Ionizing and nonionizing radiation

• Nuclear hazards

Therefore, just because you don't see one of these warnings on a product label doesn't mean a product is safe for all people in all environments. Conversely, if you see one of these labels, you should proceed with caution.

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Toxicity: how much makes it deadly?

This is where people often get tripped up. It can get technical, so let's take it step by step.

Toxicity is defined as a measure of the poisoning strength of a chemical. Chemicals that are only weakly toxic require large doses to cause poisoning. Strongly toxic chemicals only need small doses.

There's a tendency to think of chemicals in two buckets: "poisonous" and "harmless." But that's not how toxicity works. Toxicity (or the absence of it) is not an all-or-nothing proposition. Small amounts may not be harmful. However, any chemical can cause poisoning if a sufficient dose or concentration is taken into the body. Please read that last sentence again carefully.

For example, 6 liters of water drunk at one time are considered potentially toxic (aka hyponatremia, notably the 2002 Boston Marathon), as are 75–100 cups of coffee, or 25–35 drinks of alcohol. Cyanide in apple seeds is considered deadly when over 150 seeds are ingested, and we've probably all read stories of arsenic, strychnine, lead, mercury, and even nacho cheese sauce that contained botulism, etc.

So a better way to say it is: all chemicals may be toxic. It's the amount taken into the body that determines whether or not they will cause a poisonous effect. Poisoning is caused not just by exposure to a particular chemical, but by exposure to too much of it.

The Swiss physician Paracelsus is famous for stating: "the dose makes the poison."

 

Acute toxicity and how its tested

Acute toxicity refers to those adverse effects occurring within a few minutes following oral or dermal administration of a single dose of a substance, or after 4 hours following inhalation exposure. The time period can also be over 24 hours for multiple exposures.

Acute toxicity is measured numerically by two primary test methods called LD50 and LC50.

NOTE: These are primarily conducted on rats and rabbits—not humans. Based on animal data, computer algorithms generate threshold limit values (TLVs) of chemical doses that might be reasonable and non-harmful for normal adult humans. At best, these algorithms do not account for infants, aging adults, or people with allergies, asthma, chemical sensitivities, etc. At best, they are educated estimates.

LD50 is defined as the lethal "dose" at which 50% of the same population is killed in a given period of time. (The D in LD50 stands for dose.) This is usually from chemicals that are swallowed, absorbed through the skin, or injected into the body. The LD50 is usually expressed in milligrams of chemical per kilogram of body weight (mg/kg). A chemical with a small LD50 (like 5 mg/kg) is very highly toxic.

LC50 is the "concentration" required to kill 50% of the same population. (The C in LC50 stands for concentration.) This usually applies to a sample group of animals exposed to chemicals by inhalation of air or gas for a period of 4 hours or 14 days, whichever comes first. This chemical quantity is expressed in ppm per volume of air or mg/liter of vapor for inhalation of vapors, mists or dusts.

There are several organizations that quantify these threshold limits into matrices, and they are slightly different from one another. This is because agencies weigh evidence differently, apply different safety factors, and focus on different endpoints (irritation, vs. cancer, vs. vulnerable populations). Below is from the United Nations Globally Harmonized System (GHS). There is no single agreed-upon standard, and thresholds can vary by country.

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Chart: Globally Harmonized System (GHS)

Below is a chart from the Globally Harmonized System (GHS), which simplifies threshold limit values into five main categories according to how chemicals are ingested (mouth, skin, or lungs).

NOTE: The values are expressed in mg/kg for oral and dermal because those exposures are typically liquids and are measured differently than vapors or gases, which are measured in parts per million (ppm). (For those who like numbers: 1 milligram is approximately equivalent to one part per million.)

Acute Toxicity Categories
The Globally Harmonized System (GHS) classifies substances into 5 categories based on lethal dose (LD50) or concentration (LC50) values:

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Interpreting the Chart in the Real World

Let's take paint as an example. If you read a Safety Data Sheet that shows a threshold limit value of more than 100 ppm, that's Category 1, and it might be wise to reconsider that product. On the other hand, if it shows a threshold limit value of 2500–20,000 ppm, it may be more acceptable, depending on context.

Interpreting this chart correctly is extremely important. These threshold limit values are based on:

• Specific chemicals and not the synergies with other chemicals (e.g. paint can have 5–65 chemicals)

• TLV tests of chemicals using LD50 or LC50 are conducted by the manufacturers of those very chemicals (i.e. not third party certified)

• animal testing (50% of animals that died)

• Mathematical algorithms extrapolated to humans

• Normal adults (not those with allergies, asthma, or other immune disorders)

How do I know what Threshold Limit Value (TLV)  is good for me? That's the best question. As stated, I am not a doctor and cannot tell you what TLV of a certain substance is "good" for you. Unfortunately, it's unlikely that most professionals can tell you either. That's partly because doctors don't test your real-time reactions to these substances—let alone combinations. This is where certifications, research, reviews, and personal testing add some value.

Bear in mind that threshold limit values (TVL), aka permissible exposure limits (PEL) are based on occupational environments such as factories or jobsites where proper equipment, ventilation, and humidity control are provided. Occupational exposures are typically very different from consumer exposures.

This matters because a contractor who performs the same task day after day is exposed to much higher levels than a consumer once the job is completed.

For example, crystalline silicates are considered a hazard. They are found in grout, thinset, stucco and most masonry surfaces and are a "respiratory hazard when breathed in on a regular basis".

They are considered a potential carcinogen by the State of California—but only as an occupational hazard, not a consumer hazard—because the typical consumer exposure is minimal compared to a contractor's prolonged exposure. Therefore, when you read that a product may cause cancer, you must understand what it applies to, to whom, and in what situations.

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How are chemical tests on animals extrapolated to humans?

This is controversial. There are several limitations of testing animals and comparing that to humans, including: routes of exposure, age and size, and species sensitivity.

For example, if 10mg/kg of a chemical is lethal to a rat (Class 1), it might have a very different effect (Class II, III, or IV) on a mouse, rabbit, or chimpanzee. And it might require 10–100x more or less of that chemical to be lethal to a human.

Routes of entry matter too. When swallowed, benzyl chloride has an LD50 of 1500 mg/kg (Class III hazard). However, when breathed in, the LC50 is 390 mg/m3 (Class I hazard).

Even when rodents and humans share similarities, extrapolating between species is speculative at best. There's a strong need for methods that predict safe exposure levels without extensive toxicological information. Today, that prediction is based largely on mathematical modeling and limited anecdotal evidence from humans.

However, it is too expensive and too risky to do long-term, triple-blind studies on humans. Testing even one drug for consumer use takes years and costs millions of dollars. And because the number of chemicals used in construction is so diverse and constantly expanding, it would take decades—and enormous budgets—for any government or organization to produce meaningful safety data for every product and every type of human.

So where does that leave you? If you feel uncertainty and doubt—welcome to the club. I warned you. You should be skeptical of how testing is done in the U.S. Doing your own extrapolation is risky, but that's also what building material manufacturers do.

They tell us that:

• xx amount won't hurt you

• it will off-gas quickly

• ingredients are proprietary (so you can't see them)

They also point to green labels and certifications to build trust, using phrases like:

• "industry standards"

• "California standards"

• "European standards"

The hard truth is that even excellent chemists can't reliably predict the safety of multiple chemicals without data—and much of that data simply doesn't exist.

As long as a manufacturer can prove that their product meets or exceeds the LD50 exposure limit set by the government, their product can be certified by labeling/certifying companies. For example, if it exceeds category 1, they get a silver rating; category 2 or 3 a gold rating; and category 4, a platinum rating.

Here's the catch: while platinum sounds better than silver, simply meeting this standard does not guarantee safety for humans. Everyone is different, and every product contains multiple chemicals. A platinum rating for one chemical does not make the entire product safe. Even a "low risk" (Category 4) chemical could still contribute to severe long-term issues—especially when combined with other chemicals.

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VOC Overview

Organic chemical compounds are everywhere in both indoor and outdoor environments because they have become essential ingredients in many products and materials.

VOC means any compound of carbon (excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, and ammonium carbonate), which participates in atmospheric photochemical reactions (smog), except those designated by EPA as having negligible photochemical reactivity.

Those that don't react with ground-level ozone and cause smog are therefore not regulated by the government and not classified as VOCs. This includes dozens of hazardous chemicals such as acetone and ammonia. Because VOC regulations are based on ozone reduction, toxic chemicals that do not form ozone are excluded from required VOC calculations and labeling.

If you are curious, here's the link to the complete list of exempt VOCs.

As a consequence, consumers who search for safer products with low or no VOCs may be completely misled.

Exempt does not mean safe. Furthermore, all VOCs are not "equal." There are good and bad VOCs. For example, when you cut open an orange, it releases VOCs. The same is true when you bake bread. As a consequence, bakers must use catalytic converters to reduce emissions from their bakeries. Fumes from bread are not harmful to humans, yet they can still react and contribute to smog, so they are regulated.

It's important to remember that VOCs represent only a portion of the chemicals in a product. VOCs are often petroleum-based solvents combined with other chemicals found in paints, coatings, stains, sealers, thinners, adhesives, caulks, etc.

Zero VOC does not mean safe. The existence of VOCs—and the total amount measured—is not a proxy for the "healthiness" of a product.

Potential health effects from exposure to VOCs include:

• eye, nose, and throat irritation

• headaches, loss of coordination, and nausea

• damage to the liver, kidney, and central nervous system

The ability of organic chemicals to cause health effects varies greatly from those that are highly toxic to those with no known health effects. Some organic chemicals, such as benzene, formaldehyde, and vinyl chloride, can cause cancer in animals, and some are suspected or known to cause cancer in humans.

As with other pollutants, the extent and nature of health effects depend on many factors, including:

• level and type of exposure

• length of time exposed

• age, gender, genetic factors (predisposition), 

• lifestyle choices (diet, smoking, abuse of alcohol or drugs), 

• medications, pre-existing medical conditions (asthma, allergies, chemical sensitivities), etc.

The only way to know which toxic chemicals are in a product—and therefore how "healthy" it is—is to know the full list of ingredients. That's easier said than done.

Where do you find such a list when product labels barely contain details?
Glad you asked.

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Safety Data Sheets (SDS): required, limited, and why you should not rely on them exclusively

The only federally required statement of chemicals used in a product must be done on a Safety Data Sheet (SDS), formerly known as a Material Safety Data Sheet (MSDS).

The SDS includes information such as the properties of each chemical, the physical, health, and environmental health hazards, protective measures; and safety precautions for handling, storing, and transporting the chemical. Here is a link to the government's explanation for what is included in each section of an SDS: (https://www.osha.gov/Publications/OSHA3514.html) 

Unless you have a degree in chemistry (and training in toxicology), reading an SDS is not for the faint of heart. You may become frustrated, confused, or worse, may make a poor choice based on the presence or absence of certain chemicals. 

Below are the limitations of these documents and why it's so important to understand them:

• The classification and testing of chemicals is to be made solely by the manufacturer or importer (as described in 29 CFR 1910.1200d). This information must be included on the SDS by manufacturers for their employees.

• There is no oversight; neither OSHA nor any other government agency checks the authenticity or accuracy of these documents.

• SDS do not provide complete information about the chemicals used. There is no requirement for ingredient transparency.

• Proprietary ingredients (trade secrets) are exempt from disclosure.

• Only "known hazards" need to be disclosed. Chemicals not classified as hazards may be omitted, such as: biocides, fungicides, nanoparticles, deregulated VOCs, SVOCs, and many others.

• Chemical manufacturers often change or swap chemicals (or their names) due to upstream supply chain issues. Any change in the substance or mixture must be revised on the SDS in a timely fashion. Make sure the SDS is current and up to date.

• All SDS have a disclaimer at the bottom that states "there is no guarantee of accuracy or completeness of the information contained."

Above are seven strong reasons to distrust SDS and why you should never rely on them for major decisions about what is safe for you in your home or office.

SDS were never intended for consumers to evaluate product safety. Not only are they difficult to interpret unless you have advanced training, but the information is also out of context.

Safety must be evaluated in the context of a home or small business, which depends heavily on:

• application method

• surface condition

• temperature and humidity

• air exchange rate

• volume of air

• personal tolerance levels

At best, SDS are a starting point that provides a few useful details.
At worst, if used to compare products, they can produce a false sense of security and send you down the wrong path.

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Green labels and certifications—specialized, limited, marketing tools.

One way to evaluate products is through independent third-party certifications and green labels.

As of 2025, the Ecolabel Index—which tracks labels and certifications—reported 450 different labels and sustainability certifications operating in 199 countries and 25 industry sectors. That's a lot.

There are about 100 certifications and labels for the building industry. Here are a few of the most common. Some focus on sustainable design, others on recycling, energy or water conservation, climate change (greenhouse gas emissions), indoor air quality, agriculture/forestry, and more.

 

Each of these certifications or labels uses different standards and different testing methods.

How do they test and by what methods? There are about a dozen test protocols for VOCs that identify, quantify, and analyze volatile compounds. Some are more stringent than others. Refer to the end of this document for a more complete examination.

What chemicals are they testing for? There are 10,000+ known VOCs. There are also hundreds of SVOCs and deregulated or declassified VOCs that are rarely tested or labeled. Most laboratories test for the most well-known VOCs—but rarely for all of them.

When do they test? Some begin testing for VOCs the minute the product is opened, and others wait 14 days after some off-gassing before testing. That can make a huge difference.

What level of green is it? Some certifications grade "how green" a product is (light, medium, dark green), giving consumers a sense of safety.

What is clear is that there is no gold standard. Certifications and green labeling have become a big business. While some are independent and non-profit, most are designed as marketing tools for manufacturers to build trust. Consumers tend to rely on these labels. Unfortunately, if you pay enough, you can often get certified. There are many reputable testing companies, but you still need to do your homework to confirm they test what you think they're testing for.

So are certifications and green labels useful? In my opinion, yes, as one tool that provides another piece of the safety puzzle. But they can be misleading if you rely on them without knowing their testing standards. Yes, this is another research project.

Researching building materials and chemical safety is a huge field and not easy to traverse. The terminology is new, there are few experts, and there are hundreds of products to research. 

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Product Reviews – important yet, hard to trust

We all love reviews as they are fun to read. But which ones do we trust?

The main problem is context. Consumers rarely explain:

• where the product was used

• how it was used

• why it worked or failed

• temperature and humidity conditions

• what the surface conditions were before application

The same paint applied over previous paint in a tiny closet with no windows may produce a much stronger odor than one applied in an open living room with vaulted ceilings and excellent ventilation. The reviewer says it was great or it was terrible—but doesn't tell you enough to interpret the review.

The bigger problem: you don't know whether their tolerance levels match yours. A person may leave a negative review because they have allergies to dust or mold, or because they can't tolerate certain VOCs or formaldehyde. But you never know that. You only see the complaint.

On the other hand, if someone you know and trust tells you about a product—and you can ask all the right questions—then, that can be a useful "review."

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Bottom line–How to know if a product is safe?

Relying on product reviews, Safety Data Sheets, or certifications when making long-term decisions about what is safe is risky without complete knowledge and context.

Zero VOC, positive reviews, and green certifications do not automatically mean a product is safe for you and your family in your environment. Each tool has limitations, but together they can provide useful information.

Personal testing of a product is often the most reliable because it:

• uses all the chemicals combined and is real, rather than looking at theoretical lab tests of individual chemicals

• happens in real time and in your environment

• reflects your own sensory and physical response

Combining your personal experience with SDS information, certifications, and reviews provides the best foundation for concluding whether a product is safe for you.

It's my strong recommendation that you use all of these tools before you begin your next project. If you are not used to testing building products before you use them, here's a link on how to test a product for your own tolerances.

Green Building Supply — solutions based on experience

In 1991, my wife Joy and I founded Green Building Supply after we built our own home. Our mission was to provide beautiful, healthy building materials that are natural and non-toxic and perform as good or better than their toxic counterparts. This required years of field-testing hundreds of products. We learned the hard way what was safe. This continues to date and is the backbone of our unique service. While we carefully examine the chemicals shown in safety data sheets and certifications, we never rely on them.

We do our own hands-on real-life testing of every product, consult with the technical experts, and visit the factories to learn exactly how products are made. This is how we curate all of our products.

Then we listen to what our customers tell us in their reviews. Because 30-40% of our customers cannot handle chemical odors, their comments and suggestions help us improve and refine our product offerings…but only after we understand the context of where and how they used it as well as their own personal tolerance levels.

After 35 years, we've learned a great deal about what works and how to solve many building related problems. We are happy to share that information with you when you call us.

Should you need to consult with experienced people, our eco-advisors are ready to take your calls at Green Building Supply: 641-472-1700 9–5 PM CST, M–F or 10–4 PM CST on Sat.

Joel Hirshberg, President

Always Testing

Background materials:
VOC testing protocols–worth reading

Below are several generally referenced testing methods for VOCs. Note that every certification or green label may use one or several methods for evaluation purposes. There is none that is considered superior to another. Each has limitations, and these are important to know.

EPA Method 24. Currently, the United States Environmental Protection Agency's (US EPA) Method 24 is used to test the VOC content of coatings. It is widely accepted that Method 24 is not reliable for the analysis of low VOC water-borne coatings. Method 24 is also not suitable for determining the VOC content of solvent-borne coatings containing high levels of exempt compounds. In both cases the reason for the unreliability of Method 24 results from its being an indirect method of measuring VOCs in these types of coatings. A California Air Resources Board (CARB) Method Survey states this clearly: "… the success in reducing the VOC content has created problems with Method 24 itself, due to the indirect way in which it calculates VOC content from other measurements". In addition, Method 24 cannot determine the level of hazardous air pollutants (HAPs) in coatings.²

ASTM Method D 6886. "Speciation of the Volatile Organic Compounds (VOCs) in Low VOC Content Waterborne Air-Dry Coatings by Gas Chromatography", developed at Cal Poly and published as an ASTM standard method in 2003. This method gives a significant improvement in precision over that of Method 24. The method measures the VOC fraction in water-borne coatings directly, since it was determined that very low VOC levels in water-borne coatings were very difficult or impossible to measure by Method 24. According to the ASTM, the improvement in precision using D 6886 instead of Method 24 is approximately tenfold and improves further as the VOC content approaches zero. Negative VOC values are not obtained as is sometimes the case for low VOC coatings using Method 24.³

California Specification 01350. Standard method for the testing and evaluation of volatile organic chemical emissions from indoor sources using environmental chambers.⁴ This test is performed on samples which have been allowed to "cure" for a period of fourteen days, at which time they are tested for emissions, which are categorized as total VOCs, target VOCs (which are considered more harmful), and aldehydes (including formaldehyde). Performance requirements include a limit for the total VOCs measured, with specific upper thresholds for VOCs that are considered to be of concern.

This test measure is better suited to new construction where buildings could remain unoccupied for several weeks following completion, and where VOCs would be able to disperse before the building was inhabited. For renovation projects, where a building will be occupied either during, or shortly after work is completed, emissions measured at fourteen days are less helpful – particularly as many products have peak emissions as they are applied and dry.

EPA Method 8260B. Method 8260 is used to determine VOCs in a variety of solid waste matrices.⁵ This method is applicable to nearly all types of samples, regardless of water content, including polymeric emulsions. The test identifies sixty-six specific compounds, including some of the most problematic chemicals commonly found in paints such as benzene, chlorobenzene, methylene chloride, styrene, tetrachloroethene, toluene, vinyl acetate, vinyl chloride and xylene. In addition to these named compounds, Method 8260 can be used to quantitate most VOCs that have boiling points below 200 °C. Using standard quadrapole instrumentation and the purge-and-trap technique, measurement limits are approximately 5 µg/kg and paint can be analyzed in its wet form.

Oddy Test. The Oddy test ⁶ is a procedure created in order to test materials for safety in and around art objects. Materials for construction are evaluated for safety. However, though materials may be safe for building purposes, they may emit trace amounts of chemicals that can harm art objects over time. Acids, formaldehyde, and other fumes can damage and even destroy delicate artifacts if placed too close together. A wet paint sample is placed in an airtight container with three coupons of different metals and a small amount of de-ionized water to maintain a high humidity, then heated at 60 degrees Celsius for 28 days. If the metal coupons show no signs of corrosion, then the material is deemed suitable to be placed in and around art objects. The Oddy test is not a contact test, but is for testing off-gassing.

Toxicity Tests and Ingredient Declarations.

ASTM D-4236. ASTM D-4236 ⁷ is the standard practice of labeling art materials for chronic health hazards. The designation "conforms to ASTM D-4236" means all of the potentially hazardous components of the product have been clearly labeled on the product packaging. Some common components, such as solvents, cause allergic reactions or are dangerous if they touch the skin or the eyes; others can cause respiratory problems if over-inhaled. The ASTM D-4236 standard requires these components to be listed on packaging, and checks specifically for oral toxicity, eye irritation, skin irritation, respiratory tract irritation, sensitization, corrosion, and chronic toxicity.

Declare Labels. Declare labels ⁸ are issued to products disclosing 100% ingredient transparency, sourcing, and end of life options. In particular, they reference a "Red List" of all harmful and potentially harmful chemicals that must be declared if present in the material. Declare labels are based on the Manufacturers Guide to Declare, administered by the International Living Future Institute (ILFI) and certified for use in Living Building Challenge projects. Accepted for LEED v4.

Health Product Declarations (HPDs). The HPD Open Standard ⁹ provides a consistent and transparent format to accurately disclose the material contents and associated health information of a building product. Accepted for LEED v4.

Juvenile Product Manufacturer's Association. The Juvenile Products Manufacturers Association (JPMA) is a non-profit association representing approximately 250 manufacturers who make 95 percent of the prenatal to preschool products in the U.S. market. Each of the JPMA Certification Programs is foundationally built on an ASTM standard with federal and state requirements layered on, as well as many of the major retailer requirements.¹⁰

British Allergy Foundation. The British Allergy Foundation ¹¹ evaluates products through testing carried out by independent laboratories to protocols which have been created for the Seal of Approval by leading allergy specialists, specifically to benefit the sufferers of allergy, asthma, sensitivity, and intolerance.

EN71-3. The European Standard EN71 ¹² specifies safety requirements for toys. EN71-3 relates to the total migration of toxic metals (Arsenic, Mercury, Selenium, Barium, Lead, Antimony, Chromium, and Cadmium) in a material to determine if it is safe for use in children's toys, which could be chewed or placed in a child's mouth.

1 https://www.epa.gov/indoor-air-quality-iaq/technical-overview-volatile-organic-compounds
2 http://www.aqmd.gov/docs/default-source/planning/architectural-coatings/current-activities-support-documents/final_report_6_11_09.pdf?sfvrsn=0
3 http://www.astm.org/SNEWS/NOVEMBER_2006/p_wiljon_nov06.html
4 http://www.cdph.ca.gov/programs/IAQ/Documents/cdph-iaq_standardmethod_v1_1_2010%20new1110.pdf
5 https://www.epa.gov/sites/production/files/2015-12/documents/8260b.pdf
6 https://www.britishmuseum.org/pdf/How%20to%20use%20the%20database_web_final.pdf
7 https://www.cpsc.gov/en/Business--Manufacturing/Business-Education/Business-Guidance/Art-Materials/
8 https://living-future.org/declare/basics/
9 https://www.hpd-collaborative.org/
10 https://www.jpma.org/?page=certification/.
11 https://www.allergyuk.org/seal-of-approval/seal-of-approval/.
12 http://ec.europa.eu/growth/single-market/european-standards/harmonised-standardstoys/index_en.htm.

 

15 U.S. Code § 2051 - Congressional findings and declaration of purpose

(a)The Congress finds that—
(1) an unacceptable number of consumer products which present unreasonable risks of injury are distributed in commerce;
(2) complexities of consumer products and the diverse nature and abilities of consumers using them frequently result in an inability of users to anticipate risks and to safeguard themselves adequately;
(3) the public should be protected against unreasonable risks of injury associated with consumer products;
(4) control by State and local governments of unreasonable risks of injury associated with consumer products is inadequate and may be burdensome to manufacturers;
(5) existing Federal authority to protect consumers from exposure to consumer products presenting unreasonable risks of injury is inadequate; and
(6) regulation of consumer products, the distribution or use of which, affects interstate or foreign commerce is necessary to carry out this chapter.

(b)The purposes of this chapter are—
(1) to protect the public against unreasonable risks of injury associated with consumer products;
(2) to assist consumers in evaluating the comparative safety of consumer products;
(3) to develop uniform safety standards for consumer products and to minimize conflicting State and local regulations; and
(4) to promote research and investigation into the causes and prevention of product-related deaths, illnesses, and injuries.

(Pub. L. 92–573, § 2, Oct. 27, 1972, 86 Stat. 1207.)