At the end of 2023, the U.S. Environmental Protection Agency (EPA) announced the formal review of five chemicals for further assessment under the Toxic Substances Control Act (TSCA), including vinyl chloride (PVC) – the primary ingredient in vinyl flooring.
What does this assessment mean for the flooring industry? We spoke with Windmoeller Vice President Todd Jones and Tim Cole, director of sustainability and technical services, to gain their perspective on what it could potentially mean for manufacturing, sales and specifications of resilient flooring. Windmoeller has been providing bio-based polyurethane flooring installations in the United States for 10 years.
Floor Trends & Installation: What does the EPA’s assessment of vinyl chloride under the Toxic Substances Control Act (TSCA) mean for the flooring industry?
Todd Jones: Once the prioritization process kicks off, it can take anywhere between six to 12 months to get to the high/low priority substance determination. Vinyl chloride is likely to be designated high priority as it is the only one of the five chemicals announced that is a known human carcinogen. If vinyl chloride is deemed high priority, the risk evaluation process begins immediately.
If the EPA determines that it is an unreasonable risk, they develop restrictions that may include warning requirements, restricting specific uses, or phasing out or banning chemicals. While the EPA could take three years or longer, the market has already spoken.
Vinyl chloride, being the only chemical of the five announced for evaluation that is a known human carcinogen, is likely to be designated as “high priority”. However, the process to establish if a chemical poses an “unreasonable risk” to human health is significantly longer than the designation process.
Therefore, I’m certain the industry will respond through innovation well before any governmental mandate. We’re already seeing a significant increase in PVC-free product introductions and more rapid adoption of existing PVC alternatives like Windmoeller’s bio-based polyurethane.
Floor Trends & Installation: What are the questions we should be asking?
Tim Cole: The history of asbestos and phthalates might serve as examples we can point to. In the case of phthalates, the EPA played a role in raising awareness about phthalates used in vinyl flooring but weren’t directly involved in changes made. The EPA conducted research on human exposure to phthalates in indoor environments, including from vinyl flooring, contributing to the growing body of evidence about potential health risks. This helped raise awareness and educate stakeholders and the resilient flooring industry took action voluntarily.
The story of asbestos in flooring is quite different from that of phthalates. Concerns about asbestos health risks emerged in the 1970s, leading to widespread bans and regulations in many countries. By the 1980s, the EPA banned the use of most forms of asbestos in building materials, including flooring tiles and adhesives. Despite the ban, existing asbestos flooring posed a significant risk in older buildings.
Unlike with phthalates where alternatives were sought, the primary focus with asbestos flooring became proper management, containment, and safe removal. Unlike phthalates where market demand drove the shift towards safer alternatives, regulations were the primary driver for asbestos removal from flooring. With asbestos, the focus is on managing existing risks through removal or containment, while the aim with phthalates was finding safer alternatives for new products. Pertaining to asbestos they had solid evidence that exposure to asbestos caused cancer, and phthalates showed potential negative impact to human health. I think the big point to make is though the government banned the use of asbestos it was more about how long it took to ban asbestos (19 years) after knowing the facts that exposure to it caused cancer.
Vinyl flooring has been the fastest-growing material for a number of years. The EPA's attention and actions will (should) accelerate bringing PVC-free alternatives to the consumer.
Floor Trends & Installation: If the EPA determines environmental protections are needed, what does this mean for the resilient category of flooring?
Jones: It means that manufacturers will need to innovate and overcome the challenges of developing sustainable products that can replace the price, design flexibility, and performance of PVC.
End users have gotten used to the price and design flexibility of PVC/vinyl flooring—one of the main reasons why PVC flooring was developed and received immediate market acceptance and continued growth. The market says that it is committed to sustainability, but users are not willing to spend more than maybe 10 to 15% more for the “environmentally friendly” product. And most green chemistry/materials cost more.
The A&D community has been the primary driver of change towards material health and transparency. Ten years ago, approximately 40 of the leading A&D firms required Environmental and Health Product Declarations (EPD and HPD) from manufacturers, supported by the USGBC's LEED rating system changes. Today, with the American Institute of Architects and other organizations leading over 150 top firms to sign a "Materials Pledge" for healthier materials, this highlights a significant industry evolution.
It means that the shift away from PVC will continue to accelerate.
Floor Trends & Installation: What does this mean for the manufacturers of vinyl flooring?
Jones: PVC has been around for decades; there have been rising concerns about health impacts and environmental hazards in its production, transportation, and disposal so most manufacturers have seen this coming.
Innovation will come ahead of industry regulation. When the market learned that phthalates used in vinyl flooring had negative human health impacts, the demand for change was strong and manufacturers reacted without governmental regulation.
Manufacturers continue to introduce new products, but as we have seen, new materials often bring challenges that take time to be ironed out or they quickly get phased out. Greener materials can mean higher prices, trials with installation, etc.
Floor Trends & Installation: What questions should end-users be asking about vinyl flooring and health and wellness?
Cole: They should be asking for certifications that focus on human health. Cradle to Cradle, founded in 2005, was the first multi-attribute certification and excludes PVC products from certification.
They should be asking why organizations like Healthcare Without Harm and Practice Green Health exclude PVC products from certification and require product transparency requiring a Health Product Declaration (HPD). And why the largest managed care organization in the US, Kaiser Permanente only specify PVC-free.
They should be asking why A&D firms like Perkins & Will take a very public position on PVC. And why 150 A&D firms have signed onto the AIA Framework for Design Excellence that promotes healthier materials and product certifications such as Declare or Cradle to Cradle and promote harmonization with the Health Product Declaration Collaborative and Mindful Materials.
Floor Trends & Installation: What opportunities are manufacturers of sustainable options creating for specifiers and users?
Cole: Manufacturers have introduced non-PVC products to meet the demand. Products like linoleum and rubber that have been in the market for a very long time are also non-PVC but don't have the design and performance attributes that have made vinyl such a popular choice. Windmoeller developed PVC-free bio-base polyurethane with unlimited design and better performance than vinyl nearly 20 years ago.
Most manufacturers have not been able to come up with a cost-effective alternative with the design attributes, performance—attempts have been short-lived, unsuccessful.
Floor Trends & Installation: Where do you see the next opportunity?
Jones: Prior to the EPA’s vinyl chloride prioritization, many healthcare organizations, local governments, and A&D firms initiated removing vinyl-based products from their systems. TSCA designations will only raise awareness and increase demand for alternatives. Considering non-PVC products represented just over 1% of market share whereas vinyl-based products represented nearly 32% in 2022, opportunity found in the rising demand for vinyl alternatives and environmentally conscious materials is apparent.
Read more about the EPA's vinyl chloride risk evaluation: Vinyl Institute Prepared to Work with EPA on Vinyl Chloride Risk Evaluation.
