PVC, Chlorine and Building Materials – When we know better, we can do better.

Construction Materials – A Social Justice Issue

Having knowledge and transparency in respect of the materials we incorporate into our buildings remains a significant global social justice issue, as much as it is one of health and wellbeing. As ILFI Declare label asks, “where does a product come from, how is it used and what happens at end of its life” are vital questions in todays built environment.

This aspect, social justice in sustainability, was the theme of my presentation (*) at Green Build Europe 2019 in Amsterdam last week that mentioned the social impact of PVC and the report from HBN launched the same day.


PVC and Chlor-alkali

On the 19th March, HBN released part two of their investigative research into PVC and chlor-alkali looking at the Asia market (Part One Covered USA and EU). This was also the focus for their webinar on 27th March. Having transparency on PVC production is vital, from both the social justice and wellbeing perspectives, if we are to create buildings that are socially justice, ecological sound and culturally rich.

Healthy Buildings Network Vision: All people and the planet thrive when the environment is free of toxic chemicals

Moving Forward. While environmentalists, building owners, architects and designers, and building-product manufacturers differ in their opinions on avoiding PVC, there is widespread and growing support for the elimination of pollution from the supply chain of PVC and of other chlorine-based products. A public global inventory of chlorine and PVCproducers is a necessary first step for taking action.HBN is providing this report, and accompanying online materials, spreadsheets, and map, as full open-accesscontent. This data can help manufacturers to avoid chemicals derived from toxic technologies, and scientists to fill gaps in understanding the material flow of pollutants like mercury, PFAS, and carbon tetrachloride.


A worrying aspect that I take away from these reports is the use of mercury, asbestos and coal in the production of chlorine and its widespread use within PVC production.

PVC is the most common plastic used in building materials, by far. With the resources
developed by HBN, users can trace PVC production sites back to the source of chlorine,
understand the technologies (those that use mercury, asbestos and/or PFAS), and make informed decisions about the materials used in their products. HBN’s Chlorine and Building
Materials initiative also details the ties between chlorine production and other plastic building
products, including epoxy, polyurethane, and polycarbonate.

China

An increasing proportion of PVC is sourced from massive new plants in the coal mining region of interior China. The highest concentration of these plants is in the Xinjiang Uyghur Autonomous Region. These government owned plants consume local coal that is inexpensive due to its abundance and low labor costs. They use toxic mercury catalysts to turn coke and chlorine into VCM for the PVC.

These plants, including three of the world’s largest, are located near internment centers into which the Chinese government is forcing Uyghurs to undergo so-called “re-education.” Some of the PVC flooring made in this region is entering the building and construction market. There are many other social justice issues involved in the industrial geography of the chlor-alkali and PVC industries, but this is potentially the most dire. This raises some questions, in particular:

Is forced labor involved in the mining of coal, the building, the operation, and the handling of waste, from these massive new coal-to-PVC plants?

Has the industry taken any steps to ensure that PVC used in building and construction does not come from entities (including government agencies and related private investors) that violate human rights?

HBN Report

The HBN Report can be downloaded and read here: Chlorine and Building Materials: A Global Inventory of Production Technologies and Markets. Phase 2: Asia. (with Spreadsheets, maps, and reports, all of which are free to use with attribution) Part One is also available from the same pages.

Many thanks to Jim Vallette, report author and President Material Research, L3C  for insights on China and related social issues.

GreenBuild Europe Presentation

(*) The GreenBuild Europe presentation was in conjunction with Emmanuel Pauwels Green Living Projects and Paola Moschini Macro Design Studio who presented on their experience of attaining the ILFI JUST Label (at present the only two organisations Europe)

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Modern Slavery Bill: transforming construction CSR and supply chain management.

No responsible organisation in construction would want any association with modern day construction slavery, forced employment, child or migrant exploitation as we read increasingly often in the mainstream news, for example Qatar construction or closer to home with construction gangmaster organisations. Hence the Modern Slavery Bill should be welcomed by the built environment sector.

Included within the Modern Slavery Bill introduced on 31 August 2015 (coming into affect on 31 October 2015) is a clause that has significance for most construction organisations – the Transparency in Supply Chains (TISC) clause.

We have introduced a transparency in supply chains clause to the Modern Slavery Bill. This will require businesses above a certain size threshold to disclose each year what they have done to ensure that there is no modern slavery in their supply chains and own business. This will be a truly world-leading measure. There are similar transparency requirements in California, but they only apply to businesses producing goods for sale, whereas this disclosure will apply regardless of what it supplies, whether goods or services.
Minister for Modern Slavery and Organised Crime, Karen Bradley

What does the Bill and Transparency Clause mean for construction:

Chris Blythe, CE CIOB in Foreword to the CIOB Dark Side of Construction publication: The dark side – the systematic exploitation of millions of vulnerable migrants – is rarely acknowledged, even by the clients and multinationals that commission and create our shiny new cities. Our sector is rife with human rights abuses. Bonded labour, delayed wages, abysmal working and living conditions, withholding of passports and limitations of movement are all forms of modern slavery.

The scope of the TISC clause will cover construction products companies importing goods or components to the UK, as well as contractors and consultancies operating in the home markets and/or overseas.

The Modern Slavery Bill (with its Transparency in Supply Chains clause) will transform and elevate construction CSR and Supply Chain Management as important legislative responsibility processes.

Organisations with a turnover of £36 million will have to:

  • publish a “slavery and human trafficking statement” setting out the steps it has taken to ensure that slavery and human trafficking is not taking place in its supply chains and within its own business.
  • From October 2016, to publicly share their policies and strategies to tackle modern slavery in their supply chains.

Guidance on what might be included in such a statement:

  • Companies’ due diligence processes relating to slavery and human trafficking in their supply chains;
  • Reporting on the parts of companies’ supply chains where there is a risk of slavery and trafficking taking place, and how to assess and manage such a risk;
  • Reporting on staff training on slavery and human trafficking;
  • Reporting on companies’ effectiveness in ensuring that slavery and trafficking are not taking place in their businesses or supply chains.

“Implications of non-compliance with this reporting obligation in such a morally compelling context could leave a large dent in an otherwise sterling company reputation” Victoria Ball, projects & construction associate at law firm Trowers & Hamlins

“It will involve a deep dive into the supply chain to understand what’s really going on many tiers down – getting visibility of the many layers to truly see the conditions of workers at the bottom of the chain. The message to companies is clear – it is no longer an option to stay below the radar, refuse to take responsibility for problems in your supply chain and hope you won’t get exposed.”Cindy Berman, head of knowledge & learning ETI

What is not so clear is where the responsibility under the Bill rests for SME’s below the threshold that have organisations above the threshold within their supply chains. Most construction organisations procuring goods and services from large product distributors or manufacturers.

Actions construction and built environment organisations should take?

  • Embed Modern Slavery into CSR policies and statements, where, arguably there should be a statement anyway if base on a recognised CSR structures(eg ISO 26001, Global Reporting Initiative (GRI), JUST, Global Compact or the Human Rights Charter)
  • Understand the concept of Transparency in Supply Chains (TISC)
  • Include questions statements in supplier procurement processes. (And probably best to do so for all suppliers who are close to or over the threshold)
  • Develop a PQQ and Project Bid standard text.
  • Understand what an annual“slavery and human trafficking statement” for your organisation could look like

And of course, these good practices should be adopted even if below the £36million turnover threshold as a matter of social responsible construction.

Sources:

Related iSite blogs:

JUST: a social justice label for construction …

Constructing CSR iTransparency 

Understanding CSR in Construction