Back in 2003, the Association for Contract Textiles (ACT), a trade organization for North American manufacturers of contract textiles consisting of many of the big textile companies (click here for members), identified the need for a universal standard to better serve suppliers, distributors and specifiers. According to Petie Davis of NSF International, a not-for-profit, non-governmental organization, which provides standards development, product certification, education, and risk-management for public health and safety, “Architects, designers, and specifiers have been demanding a uniform, transparent sustainability standard that would give them the assurance they need to specify sustainable product.” The manufacturers saw the writing on the wall, and a cynical person might think they wanted to get a jump start on creating their own set of standards before something else was foisted on them.
In early 2004, the ACT Environmental Committee selected GreenBlue[1] to develop a standard suitable for textiles used in commercial interiors. That fall, ACT and GreenBlue approached NSF International to provide American National Standards Institute (ANSI)[2]-certified credentials needed to build a standard, which became NSF/ANSI 336. They saw this new standard as being applicable on a national level and available as a model to other areas of the textile industry. The standard was developed using a consensus-based process, which included textile mills, suppliers, architects and designers, academics, trade associations, representatives from the U.S. Environmental Protection Agency as well as state agencies and non-governmental organizations.
As you might imagine, it took a long time to hammer out an agreement: 7 years of wrangling and compromise, suggestions and counter-suggestions, before everybody agreed on a standard that they could all live with. The new NSF/ANSI Standard 336 was officially finalized in April, 2011, and debuted in June, 2011 at NeoCon.
So now it’s supposed to be a lot easier to specify a sustainable fabric. But is this new standard the one that provides specifiers with the assurance that what they’re buying is indeed a sustainable product?
Environmental Building News (EBN) said that “this new standard represents significant progress for an industry with significant toxicity concerns due to fabric processing and finishes.”[3] This time we do not agree with EBN, because we think the standard represents a roadblock to progress.
Let’s just consider how the standard deals with toxicity issues, which were highlighted by EBN. When you do that, you find that the new NSF standard is anemic when compared to existing standards, such as Oeko Tex and GOTS, which
are both stunningly more strict than the new NSF/ANSI 336. Even though 336 pertains to contract textiles, which are overwhelmingly made of synthetics, the processing and finishes of these synthetics could follow the same parameters as are in place now with existing standards such as GOTS. For example, see the limits for metals in dyes and pigments as listed in section 6.4.1 of NSF/ANSI 336 versus Oeko Tex and GOTS:
|
Metal |
NSF/ANSI 336 |
||||
| Limit for dyes (ppm) |
Limit for pigments(ppm) |
1: Baby in ppm |
IV: interiors fabrics : in ppm |
||
| Antimony |
50 |
250 |
30 |
30 |
prohibited |
| Arsenic |
50 |
50 |
0.2 |
1 |
prohibited |
| Cadmium |
20 |
50 |
0.1 |
0.1 |
prohibited |
| Chromium |
100 |
100 |
1 |
2 |
prohibited |
| Lead |
100 |
100 |
0.2 |
1 |
prohibited |
| Mercury |
4 |
25 |
0.02 |
0.02 |
prohibited |
| Zinc |
1500 |
1000 |
not listed |
prohibited |
|
| Copper |
250 |
unlimited |
25 |
50 |
prohibited |
| Nickel |
200 |
unlimited |
1 |
4 |
prohibited |
| Tin |
250 |
unlimited |
not listed |
prohibited |
|
| Barium |
100 |
100 |
prohibited |
||
| Cobalt |
500 |
unlimited |
1 |
4 |
prohibited |
| Iron |
2500 |
unlimited |
not listed |
prohibited |
|
| Manganese |
1000 |
unlimited |
prohibited |
||
| Selenium |
20 |
100 |
prohibited |
||
| Silver |
100 |
unlimited |
prohibited |
||
Consider lead – under the new Consumer Product Safety Improvement Act of 2008, products designated for children must meet 100 ppm lead content by August, 2011. Does this limit value of 100 ppm really represent progress when studies have shown that exposure to lead in any amount can be hazardous? Sorry, this time we do not agree with Environmental Building News – we think this new standard represents an obfuscation of the issues and is a roadblock to progress.
Next week we’ll show you how the standard is set up so as to allow the obfuscation of issues.
[1] GreenBlue is a non-profit institute
that stimulates the creative redesign of industry by focusing the expertise of
professional communities to create practical solutions, resources, and
opportunities for implementing sustainability. GreenBlue is recognized for its
ability to convene stakeholders, establish ambitious objectives, and develop
practical design tools and resources. http://www.greenblue.org
[2] The American National Standards Institute
or ANSI is a private non-profit organization that oversees the development of
voluntary consensus standards for products, services, processes, systems, and
personnel in the United States. The organization also coordinates U.S.
standards with international standards so that American products can be used
worldwide.
ANSI accredits
standards that are developed by representatives of standards developing
organizations, government agencies, consumer groups, companies, and others.
These standards ensure that the characteristics and performance of products are
consistent, that people use the same definitions and terms, and that products
are tested the same way. http://www.ansi.org
OEcotextiles 
As a member of the Joint Committee for NSF/ANSI 336 I would like to point out some misrepresentations in this post with regard to how NSF/ANSI 336 compares to both the Oeko-Tex® and GOTS standards.
First, in the case of GOTS, lead is listed as “prohibited” in dyeing and printing, but the GOTS “prohibition,” as noted in Annex A of that standard, is in accordance with ETAD. The ETAD definition of “heavy metal free,” allows 100 ppm, so in fact NSF/ANSI 336 and GOTS cite the same limits.1
Secondly, the chart is equating the heavy metals in dyes and pigments in NSF/ANSI 336 to heavy metals in fabrics under Oeko-Tex®. Even if a dye contained the maximum allowed 100ppm of a heavy metal, it would impart considerably less to the fabric on which it was used. For instance, the NSF/ANSI 336 limit for lead in dyes is a maximum of 100 ppm or 0.01%. Yarn-dyed fabrics can contain less than 0.4% dye by weight, so, if my rusty math serves, the equation is .01% lead in dye x 0.4% dye in fabric equals .004% lead in the overall fabric by weight.
To be clear, this example yields a maximum level of 40ppm in the fabric, which is admittedly more than the 1ppm allowed in Oek-Tex®, a standard in which direct skin contact is a driver. However, a result of 40ppm for a commercial furnishing fabric is considerably lower than the 100ppm accepted by LEED for Healthcare, Cradle to Cradle, and the EPA’s Toxin Release Inventory (TRI) program. I see room for improvement, but not an irresponsible limit.
Pointing out these details is not evidence of obfuscation in NSF 336. On the contrary, locating the heavy metal criteria on dyes and pigments shines a light on the potential source of these toxins. Bringing awareness to the opportunities for chemical optimization, conservation of resources, and social equity at the very lifecycle stage in which they occur, from fiber sourcing to end of use, is a major theme and the organizational logic behind the Sustainability Assessment for Commercial Furnishing Fabrics.
As with any version 1 of a new standard, clarification may be the key to understanding, and for this, one can file an Interpretation Request with NSF International. The Sustainability Assessment for Commercial Furnishing Fabric, is also maintained under “continuous maintenance,” which means any suggestions for revisions or additions can be submitted by any interested party as an Issue Paper. Forms for this purpose can be found on NSF’s website at http://standards.nsf.org under the Standards tab.
I’m glad NSF/ANSI 336 has come to the attention of O Ecotextiles, and I hope this can be the beginning of a continued fruitful discussion. Until this post, the standard’s major critics have come from some segments of manufacturing, where the standard’s criteria was seen as unnecessarily stringent, complex, and potentially costly. It’s refreshing to hear from the other end of the spectrum (O Ecotextiles being a strong advocate for the health of the end user), where the desire is to see the standard strengthened. As a wise observer on our Joint Committee once pointed out to us, consensus means everyone leaves the table a little bit unhappy, or in my case, a little bit happy.
1See page 31 of http://www.global-standard.org/images/stories/gots-version3_01march2011.pdf
Hi Carole: Thanks for your comments.
First, we want to make clear that we certainly did not intentionally mislead anyone; indeed being amateurs rather than chemists we feel our strong point may be our amateur status. We’re believers in the power of data, and think that getting to the truth and advertising it is the best way to progress. After all, if we can’t figure out what the standards mean, in terms of our health and well being, then those with less invested are sure to be confused.
Regarding our criticism of the NSF 336 standard, you said that our example, as published, was in error because the input threshold values for NSF 336 and GOTS are actually the same, both using the ETAD definition of “heavy metal free”. The corrected table is below:
Metal NSF/ANSI 336 OEKO TEX GOTS
Limit for dyes (ppm) limit value in finished textiles (ppm) Limit for dyes (ppm) limit values in finished textiles limit vlaue for dyes(ppm) limit value in finished textiles (ppm)
Class I: Baby (in ppm) Class IV: interiors fabrics : (ppm)
Antimony 50 not listed not listed 30 30 50 0.2
Arsenic 50 not listed not listed 0.2 1 50 0.2
Cadmium 20 not listed not listed 0.1 0.1 20 0.1 / 45.0*
Chromium 100 not listed not listed 1 2 100 1
Lead 100 not listed not listed 0.2 1 100 0.2 / 50.0*
Mercury 4 not listed not listed 0.02 0.02 4 0.02
Zinc 1500 not listed not listed not listed 1500 not listed
Copper 250 not listed not listed 25 50 250 25
Nickel 200 not listed not listed 1 4 200 1
Tin 250 not listed not listed not listed 250 2
Barium 100 100 not listed
Cobalt 500 not listed not listed 1 4 500 1
Iron 2500 not listed not listed not listed 2500 not listed
Manganese 1000 1000
Selenium 20 20
Silver 100 100
* both cadmium and lead are listed twice, depending on sampling methods used
You then discuss how the lead limit of 100 ppm in a dye can translate to total lead content in the final fabric of 40 ppm – more than the 1 ppm allowed by Oeko-Tex – which you dismiss as being a standard in which direct skin contact is a driver. ( Oeko Tex concerns itself with the safety of the finished fabric, but direct skin contact is only the driver in the Class I standards (those intended to be used for infants); Oeko Tex class III and IV limits of 1 ppm are designed for fabrics which would have no direct skin contact (such as drapery).)
You arrive at the 40 ppm figure by stating that “yarn-dyed fabrics can contain less than 0.4% dye by weight”; it could just as easily read “yarn dyed fabrics can contain more than 0.4% dye by weight”. In fact, if one were to use a dyestuff containing 100 ppm of lead (0.01% by weight), and a 90% exhaustion rate (not atypical) in achieving a dark shade, adding 4.0% dyestuff by weight, then the residual lead in the finished fabric is 400 ppm (0.01% lead in dye x 4.0% dye in fabric = 0.04% lead in fabric) – which exceeds the LEED for Healthcare guidelines, for example, by 300%.
But more importantly, the NSF 336 limit values (or lack thereof in final product) are not pushing the envelope we’d like to see pushed. In the case of lead, studies are showing that any detectable lead can harm developing children if exposed at critical times during their development, and even the Consumer Product Safety Improvement Act of 2008 requires that any products designated for children must, after August 14, 2011, contain no more lead than 100 ppm – so this limit value is already legislated in some instances.
We remain convinced that the NSF 336 is at best misleading because we feel that this new standard will be used by companies to trumpet their certification, after spending relatively little effort to comply with rather anemic standards. It does not enable the consumer to evaluate their real choices, or to evaluate what progress is really being made.
So our disagreement is not really with the comparison of dyestuffs to finished fabrics in this example, but rather to the development of a document that does not provide guidance to those consumers who want to support companies that are helping to bring change to this industry. Why would a few credits allow a product to be certified “Compliant” under this new standard, when the real progress is being made only at Gold and Platinum levels? Shouldn’t we do away with these meaningless categories and begin to reward those companies that are putting their research dollars into new programs and processes?
I guess I will agree to disagree, especially with the statements that the NSF standard “does not provide guidance to those companies and specifiers who want to support companies that are helping to bring change to this industry” and “does not enable the consumer to evaluate their choices, or to evaluate what progress is really being made.”
You say consumers can’t “evaluate what progress is really being made,” but in the next paragraph you say that “real progress is being made only at Gold or even Platinum levels?” I think consumers in this industry are actually savvy enough to comprehend a standard, and will reward companies that they see achieving progress (if they choose to use the standard as their guidance – they may choose another method of rewarding companies, which leads me to the following question).
If a consensus-based national standard that brings forth reporting on chemistry, energy use, water use, and raw material sources does not provide guidance to consumers, I would like to know what in your opinion would? Straight 1st party marketing claims by companies?
Hi Deidre: We strongly support third party certifications. Many of our fabrics hold one, plus we try to educate specifiers about how to read the extant third party certifications. But the major point is supporting meaningful, progressive third party certifications. We are in the field every day talking to specificers about fabrics, and we rarely meet a specifier who has the time to differentiate between a meaningful, progressive certification and a weak, meaningless one.
In our experience we continue to meet specifiers who don’t really know what a certification means – let alone what the various levels of that certification mean. It’s enough for them that a fabric has a certification – any certification – so they can say they’ve done their job. They pay no attention to the level of certification awarded the product. And you can’t really blame them, when they have to concern themselves with all kinds of finishes and products, each of which has unique sourcing and manufacturing processes, for instance. So we think that having one or two, easy to understand third party certifications is the way to go.
Yet we’re bombarded by a proliferation of certifications. You ask what we would like in place of a consensus-based national standard? First, we see no benefit to having a consensus based standard. A consensus built of textile manufacturers, even including other interested parties, too closely resembles, in our opinion, a second party certification. In addition, we think that in order to arrive at standards that everybody agrees will work is pretty sure to mean that we’re not going to be at the cutting edge of what is possible. Henry David Thoreau said: “In the long run, men hit only what they aim at. Therefore, though they should fail immediately, they had better aim at something high”. Even William McDonough, in his address to the recent Dwell on Design conference, said that he thinks progress is moving too slowly. He said he would like us to expose what’s in front so we can move toward it. We would have liked to see the NSF/ANSI 336 adopt cutting edge requirements (even though they may be difficult – or impossible at this stage – to achieve), or to adopt the third party Cradle to Cradle platform – starting at the Gold level; and/or GOTS or Oeko Tex 1000 – after all, we’re in a global economy, and these certifications are recognized around the world, and most large manufacturers are familiar with those requirement – they just don’t like them.
Hi Carole: Thanks for your comments.
First, we want to make clear that we certainly did not intentionally mislead anyone; indeed being amateurs rather than chemists we feel our strong point may be our amateur status. We’re believers in the power of data, and think that getting to the truth and advertising it is the best way to progress. After all, if we can’t figure out what the standards mean, in terms of our health and well being, then those with less invested are sure to be confused.
Regarding our criticism of the NSF 336 standard, you said that our example, as published, was in error because the input threshold values for NSF 336 and GOTS are actually the same, both using the ETAD definition of “heavy metal free”. Because I cannot figure out how to insert our corrected table into this reply post, let me just say that in terms of lead: NSF 336 and GOTS both list 100 ppm as the limit for dyes; GOTS also (in Section 2.4.15 of GOTS version 3.0, “Limit values for residues in GOTS goods”) lists limit values of 0.2 – 50 ppm as acceptable limits in finished fabrics.
You then discuss how the lead limit of 100 ppm in a dye can translate to total lead content in the final fabric of 40 ppm – more than the 1 ppm allowed by Oeko-Tex – which you dismiss as being a standard in which direct skin contact is a driver. ( Oeko Tex concerns itself with the safety of the finished fabric, but direct skin contact is only the driver in the Class I standards (those intended to be used for infants); Oeko Tex class III and IV limits of 1 ppm are designed for fabrics which would have no direct skin contact (such as drapery).)
You arrive at the 40 ppm figure by stating that “yarn-dyed fabrics can contain less than 0.4% dye by weight”; it could just as easily read “yarn dyed fabrics can contain more than 0.4% dye by weight”. In fact, if one were to use a dyestuff containing 100 ppm of lead (0.01% by weight), and a 90% exhaustion rate (not atypical) in achieving a dark shade, adding 4.0% dyestuff by weight, then the residual lead in the finished fabric is 400 ppm (0.01% lead in dye x 4.0% dye in fabric = 0.04% lead in fabric) – which exceeds the LEED for Healthcare guidelines, for example, by 300%.
But more importantly, the NSF 336 limit values (or lack thereof in final product) are not pushing the envelope we’d like to see pushed. In the case of lead, studies are showing that any detectable lead can harm developing children if exposed at critical times during their development, and even the Consumer Product Safety Improvement Act of 2008 requires that any products designated for children must, after August 14, 2011, contain no more lead than 100 ppm – so this limit value is already legislated in some instances.
We remain convinced that the NSF 336 is misleading because we feel that this new standard will be used by companies to trumpet their certification, after spending relatively little effort to comply with rather anemic standards. It does not enable the consumer to evaluate their real choices, or to evaluate what progress is really being made.
So our disagreement is not really with the comparison of dyestuffs to finished fabrics in this example, but rather to the development of a document that does not provide guidance to those consumers who want to support companies that are helping to bring change to this industry. Why would a few credits allow a product to be certified “Compliant” under this new standard, when the real progress is being made only at Gold and Platinum levels? Shouldn’t we do away with these meaningless categories and begin to reward those companies that are putting their research dollars into new programs and processes?