Comments 521-560 of 562.
| Page(s) |
Lines(s) |
Submitter |
Organization |
Comment |
| 90 |
13 |
Craig Kneeland |
NYSERDA |
Ignoring the potential risk of neurotoxicity and potential resultant mortality from exposure to t... |
| 90 |
22 |
Craig Kneeland |
NYSERDA |
The statement about the use of mercury cell technology should be highlighted in the executive sum... |
| 90 |
9-12 |
Arthur E. Dungan |
Chlorine Institute |
We discuss this statement in the above comments which we are repeating below:
The data cited r... |
| 90 |
19-22 |
Arthur E. Dungan |
Chlorine Institute |
We discuss this statement in the above comments which we are repeating below:
Mercury exposure... |
| 90 |
22-24 |
Arthur E. Dungan |
Chlorine Institute |
We strongly dispute the statement that “...the continued use of mercury cell technology for chlor... |
| 90 |
43-44 |
Marian Stanley |
American Chemistry Council Phthalate Esters Panel |
The Panel agrees that the available data do not indicate that DEHP is estrogenic. In addition to... |
| 90 |
9-24 |
Frank Borrelli |
The Vinyl Institute |
It is important to understand that one of the reasons mercury cell technology evolved was that it... |
| 90 |
9-12 |
Frank Borrelli |
The Vinyl Institute |
The PVC Task Group states “Given that it is known that the U.S. chloralkali plants have recently ... |
| 91 |
|
Jack Geibig |
Center for Clean Products and Clean Technologies
University of Tennessee |
The exposure assessment does not take into account ingestion of DEHP or any other route of exposu... |
| 91 |
9-16 |
Arjen, David Sevenster, Cadogan |
European Council of Vinyl Manufacturers, European Council for Plasticisers and Intermediates |
It should be added that the EU Risk Assessment of DEHP acknowledges that this NOAEL of 4.8 mg/kg ... |
| 9-10 |
20-41,1-19 |
Charlie Stephens |
Oregon Department of Energy |
The “Additional Analyses” section should be deleted from the report entirely. The air monitoring... |
| 92 |
4 |
Ted Schettler |
Dept of Medicine, Boston Medical Center |
See comments above. This Rais-Bahrami study is extremely limited because of its lack of exposure... |
| 92 |
23 |
Ted Schettler |
Dept of Medicine, Boston Medical Center |
Although additional studies are necessary to fully understand species differences in tissue sensi... |
| 92 |
26-34 |
Arjen, David Sevenster, Cadogan |
European Council of Vinyl Manufacturers, European Council for Plasticisers and Intermediates |
This may be misleading with regard to DBP exposure because it is based on early CDC biomonitoring... |
| 93 |
40 |
Ted Schettler |
Dept of Medicine, Boston Medical Center |
It appears that the risk assessment and LCA failed to include any consideration of the potential ... |
| 93 |
25+ |
Arjen, David Sevenster, Cadogan |
European Council of Vinyl Manufacturers, European Council for Plasticisers and Intermediates |
It would be appropriate to insert here a further fundamental concern regarding the Bornehag et al... |
| 93 |
26-43 |
Marian Stanley |
American Chemistry Council Phthalate Esters Panel |
Additional studies are available, which indicate it is highly unlikely that phthalates cause or e... |
| 94 |
3 |
Jonathan Herz |
General Services Administration |
The whole Data Gap discussion suggests that answering the original question is not prudent or wis... |
| 94 |
32 |
Michelle Halle Stern |
Delta Institute |
What is the scientific basis for assuming that manufacturers try to meet TLVs? |
| 94 |
12 |
Craig Kneeland |
NYSERDA |
I do not understand the statement that “lack of more accurate data does not negate the findings o... |
| 94 |
19-20 |
Mike Kolosseus |
North American Pipe Corporation (Westlake Chemical) |
North American Pipe Corp. tests for the exposure to additive dust if the additive is considered h... |
| 94 |
12 |
Tom Lent |
Healthy Building Network |
“Lack of more accurate data does not negate the findings or lessen their significance.” This is o... |
| 94 |
24 |
Tom Lent |
Healthy Building Network |
"(PELs) can result in very high estimates of risk." This artifact could help explain th... |
| 95 |
26 |
Tom Lent |
Healthy Building Network |
"TRI and Air Data, which are plant or industry-specific, are not usually adequate for proces... |
| 95 |
31 |
Tom Lent |
Healthy Building Network |
"SimaPro mainly contains data from the European sources (APME…" These are the databases... |
| 96 |
|
William Carroll |
OxyChem |
Because of the diversity of the materials summarized in the category “dioxins” any further refine... |
| 96 |
3 |
Tom Lent |
Healthy Building Network |
"Data Gaps in emissions data" Each issue may contain order of magnitude uncertainties r... |
| 97 |
7 |
Erik Jansson |
Department of the Planet Earth |
We find the specific overall conclusion of the report to be substantially in factual error (i.e. ... |
| 97 |
34-39 |
Frank Borrelli |
The Vinyl Institute |
The Task Group correctly notes that “non-PVC building materials are under-represented in the data... |
| 97 |
9 |
Tom Lent |
Healthy Building Network |
"For the exposure estimates, intake fractions … were used" This is another case of aver... |
| 97 |
21 |
Tom Lent |
Healthy Building Network |
"Intake fractions for metals have not been evaluated. Therefore this report's analysis ... |
| 98 |
7 |
Vernon Abelsen |
SMR Architects |
I think this report does the environment, and the people who inhabit this planet, a disservice by... |
| 98 |
6 |
Jonathan Herz |
General Services Administration |
The conclusion that PVC is no worse than any other building product is not reassuring, nor is it ... |
| 98 |
8 |
Tom Lent |
Healthy Building Network |
The available evidence that actually survived the exclusionary filters of this tool does support ... |
| 99 |
11 |
Michelle Halle Stern |
Delta Institute |
If the LSC follows your recommendation to combine LCA and Risk Assessment for every credit, it is... |
| 99 |
9 |
Michael McHugh |
E. Verner Johnson and
Associates |
I feel that the USGBC should begin drafting a credit for the reduction/elimination of PVC
buildi... |
| Appendix B |
|
David Yopak |
Teknor Apex Company |
We recognize that LCA is sometimes criticized for failing to adequately consider human health ris... |
| GENERAL
COMMENTS
AS WELL AS COMMENTS TO PAGE 41 |
GENERAL
COMMENTS AS WELL AS COMMENTS TO PAGES 7-8 AND PAGES 27-32 |
Philipp Leferenz |
Freudenberg Building Systems, Inc. |
Dear Task Group,
On February 17, 2004 Freudenberg Building Systems, Inc., nora® Rubber Flo... |
| Overall and p42 |
1-5 |
Kenneth Abate |
VEKA Incorporated |
To: U. S. Green Building Council PVC Task Group
From: Kenneth Abate, Ph.D.
Subject: Commen... |
| Risk Spreadsheets |
|
Frank Borrelli |
The Vinyl Institute |
The spreadsheets include notes for errors that were found after the report’s release such as “NOT... |