Antimicrobial WhitePaper PerkinsWill
Antimicrobial WhitePaper PerkinsWill
Antimicrobial WhitePaper PerkinsWill
Healthy Environments:
Understanding Antimicrobial
Ingredients in Building
Materials
MARCH 2017
Understanding Antimicrobial
Ingredients in Building Materials
Melissa Coffin, Operations Manager, Healthy Building Network
Bill Walsh, Founder and President of the Board of Directors, Healthy Building Network
Mary Dickinson, Co-Director Materials Performance Lab and Regional Sustainable Design Leader, Perkins+Will
Dr. Ted Schettler, Science Director, Science and Environmental Health Network
Dr. David Walinga, Senior Health Officer, Natural Resources Defense Council
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4 Understanding Antimicrobial Ingredients in Building Materials
Table of Contents
Purpose Statement 6
Executive Summary 7
Introduction8
a. Triclosan 14
b. Silver Ions 15
c. Copper 17
e. Formaldehyde Donors 18
Conclusion27
Endnotes28
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Purpose Statement
The aims of this paper are to present current information about reported or potential health and
environmental impacts of antimicrobial substances as commonly used within the building industry,
and to assist architects, designers, building owners, tenants, and contractors in understanding those
impacts. This paper is a compilation of information, and does not represent new research.
Perkins+Will strives to make use of this information to inform recommendations to each of our clients,
based on their individual project needs. In general, when we find evidence of the potential for harm
in the lifecycle of products that we specify, including to the environment, occupants, installers,
fabricators, or factory workers, we prefer to proceed with caution in regard to the use of that product.
Antimicrobials, as a class of chemicals, have been flagged in recent years as substances of concern,
most recently in September 2016 when the Food and Drug Administration ruled that companies
will no longer be able to market certain antibacterial washes that are currently in widespread use.
We always work with our clients to find the best possible solutions for their project; sometimes,
criteria other than health or environmental impacts (such as cost, availability, durability, or future
maintenance, to name a few) drive the final decisions.
The purpose of this paper is to provide useful information for our colleagues and clients to consider
in relation to the use of antimicrobials in the building industry. This paper summarizes our present
thinking about the current use of antimicrobials in the building industry, and our current conclusion
that they should be approached with skepticism and caution.
As in all matters regarding caution in relation to human and environmental health, we believe that
the precautionary principle is appropriate as a tool for us to use in discussing design alternatives with
our clients. Where there is information that credibly suggests the possibility of a negative human or
environmental health impact in relation to a particular design choice, then we strive to advise our
clients of that risk, and to see whether other alternatives exist.
No evidence yet exists to demonstrate that products intended for use in interior spaces that
incorporate antimicrobial additives actually result in healthier populations. Further, antimicrobials may
have negative impacts on both people and the environment.1 Their widespread use may be associated
with microbial resistance to these agents, and potentially to therapeutic antibiotics. Evidence is
growing that antimicrobial additives can migrate from the products in which they are incorporated,
finding their way into wastewater systems and the larger environment with unknown ecological
implications, but with reasonable cause for concern.
Following the lead of the Centers for Disease Control and Prevention, 2 the Food and Drug
Administration, 3 and other credible institutions, 4 Perkins+Will will be placing Products Marketed as
Antimicrobial on its Precautionary List (transparency.perkinswill.com). Perkins+Will project teams
should advise our clients of reasonable alternatives where appropriate.
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Introduction
Antimicrobial substances are, by definition and design, substances that are toxic to certain
organisms: bacteria, viruses, fungi, or protozoacollectively known as microbes. Certain substances,
nanoparticles, and metals can all be used as antimicrobials in everyday products, including those
used to construct and finish buildings. However, because their purpose is to kill and control a
target organism, antimicrobial additives are by definition pesticides,5 and as such may impact our
environment and our health beyond their intended purpose.
Other terms you may come across that indicate an antimicrobial additive may be
present include (but are not limited to):
Biocide or Biocidal
Pesticide
Microbes are sometimes commonly referred to as germs because they can cause many familiar
illnesses, such as the flu (the influenza virus) or athletes foot (caused by the Trichophyton rubrum
fungus). However, while people may associate microorganisms categorically with disease or unsanitary
conditions, each microorganism is different. Not every microorganism can cause illness, and some,
such as the microorganisms in our gut, are beneficial to human health.6
An increasing body of scientific evidence is demonstrating that widespread use of antimicrobials may
have negative impacts on the environment,7 and potentially on human health in the long term. 8 This
growing evidence brings with it a renewed focus on whether the inclusion of antimicrobial substances
into building products provides any positive health benefits to outweigh potential negative impacts.
In September 2016 the Food and Drug Administration (FDA) concluded the most extensive review to
date of data on the efficacy of antimicrobial additives in hand soaps and washes. After studying the
issue for nearly 40 years,10 the FDA determined that manufacturers have failed to show any evidence
that these additives provide a benefit to human health.11
Antimicrobial additives used in building products are outside the jurisdictions of the CDC and the FDA
because they are regulated by the US Environmental Protection Agency (EPA). However, this is merely
a bureaucratic distinction. Available evidence supports the same conclusion drawn by the EPAs sister
agencies: antimicrobials do not provide health benefits. When this lack of benefit is measured against
the many costs of antimicrobials, it is clear that the best policy is to avoid products marketed as being
antimicrobial whenever possible.
Consumers may feel a misplaced confidence in antimicrobial products, in part, because of confusing
and in some instances misleading12 marketing materials made possible by the extremely complex
regulation governing antimicrobials in building products. The source of this confusion is that some
products require an antimicrobial additive because it acts as a preservative, and claim no human
health benefits. In other cases, even though a preservative only protects the product from decay
or spoilage, the EPAs legal parameters allow antimicrobial products to be marketed in ways that
consumers may interpret as providing a health benefit. For a more detailed discussion of preservatives
and marketing claims, see Appendix B.
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Elemental Silver / Silver Nanoparticles Upholstery & Fabrics, Hardware, Touchable Surfaces, Tile
CAS: 7440-22-4 Installation Products, Ceramic Tile, Countertops, Adhesives,
Sealants, Paints, Carpets, Textiles
IPBC (3-iodo-2-propynyl butylcarbamate) Paints/Stains, Wire & Cable, Carpets, Textiles, Wood Products
CAS: 55406-53-6
Silver Zeolite
CAS: 130328-18-6 Paints, Carpet Fibers, Wallpaper, Adhesives, Fabrics/Textiles
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Likewise, commercial door hardware is available with a coating impregnated with antimicrobial
agents to give peace of mind in areas where vigilance in the war against [microbes] is critical.21
This use has recognizable appeal as an application of antimicrobials, since a door knob is likely
touched by many hands over the course of a day, and germs could be spread as a result. However, the
antimicrobial additive functions as a preservative only, and its presence in the composition of the
hardware can only protect the hardware itself from mold, mildew, and odor-causing bacteria. 22
A similar application of antimicrobials can be seen with light switches and covers that are coated
with an antimicrobial additive. 23 In one example, product literature promotes independent laboratory
testing showing the additive is effective against bacteria such as the drug-resistant strain of
staphylococcus commonly referred to as MRSA, while only briefly confirming elsewhere, in smaller
text, that the antimicrobial additive is present only as a preservative that protects the switch and cover
from mold, mildew, and other microbes that may jeopardize the integrity of the product.24
In all three of these instances, antimicrobials functioning as preservatives were added to building
products to protect the product itself from attack by microbes. One could argue that in each of these
examples, the typical consumer may have purchased the product assuming that their health may be
improved or protected as a result. In fact, the Federal Trade Commission (the federal agency tasked
with ensuring truth in advertising) warned the EPA of this very issue in 1994. 25
In theory, several of the most popular disclosure tools in the building industry should allow researchers
to determine if antimicrobials are used in a product.
The Pharos Project database, Health Product Declaration, and the International
Living Future Institutes Declare label program, all require that every intentional
ingredient be itemized in order to earn full disclosure status.
However, in practice these programs can miss antimicrobials added further up the supply chain, prior
to their incorporation in the final product. For example, a preservative incorporated into a nylon
carpet fiber might not be reported (or even known) by manufacturers using that fiber in an assembled
carpet. 28 Further, Safety Data Sheets may not list antimicrobial ingredients if they are under the
reporting thresholds and/or do not carry the specific hazards considered.
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Triclosan
Triclosan (2,4,4-trichloro-2-hydroxy-diphenyl-ether, CAS #3380-34-5) is one of the antimicrobial
additives subject to the FDAs 2016 ban in soaps and handwashes. 31 It is an antimicrobial effective
against a broad spectrum of bacteria and fungi. It was first introduced to the market in 1964, and
remains in use in large quantities today. Building products that may contain triclosan include
countertops and table tops, textiles, and cementitious products such as concrete, mortar or grout. 32
The Centers for Disease Control has stated that the human health effects from exposure to low
environmental levels of triclosan are unknown... More research is needed to assess the human health
effects of exposure to triclosan.33 Triclosan is part of a family of molecules called organohalides;
other organohalides were used extensively as pesticides in the 1930s and 1940s before being banned
or phased out over concern for their toxicity to humans and the environment. 34
Silver ion coatings are increasingly used in hardware, switches, window treatments, cubicle curtains
and textiles to provide antimicrobial properties. Silver-containing environmental surfaces and textiles
in healthcare settings are promoted as products that may help reduce hospital-acquired infections by
reducing microbial loads. Silver zeolites, glass-like structures of earthen particles and silver ions, 41
are a common antimicrobial compound used in hardware coatings in building construction and
interior applications. 42
Silver zeolite has not yet been classified for human health or environmental hazards by an
authoritative agency. However, that may soon change. In 2014, The Swedish Chemicals Agency
proposed that silver zinc zeolite be classified as a reproductive toxicant, after an assessment done
as part of an ongoing review program presented reviewers with a relatively clear cut case that the
substance could be harmful to reproductive health. 43 In the dossier prepared in support of silver
zeolites reclassification, results of animal testing are cited as evidence that the substance should be
considered a suspected carcinogen, an eye and skin irritant, capable of causing damage to unborn
children, and capable of causing damage to internal organs. 44 If adopted, the classification as a
reproductive toxicant would make silver zinc zeolite a banned substance under the European Unions
Biocidal Products Regulation. 45
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What is Nanosilver?
What is true about elemental silver and silver-based compounds may not be
true for nanosilverextremely small silver particles measuring approximately
one billionth of a meter. (For scale, note that a human hair is 100,000
nanometers wide.) At the nanoscale, materials begin to behave in ways that can
be quite different from their conventionally-sized counterparts.
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Antimicrobial resistant organisms are already being found for the additives discussed above.
While not yet widely studied, antimicrobial resistance to silver-based additives has been
reported in strains of Salmonella typhimurium, E. coli, and other bacteria, after exposure to
antimicrobial silver in wound dressings.66
Microbes resistant to triclosan are also appearing. A recent study found the presence of
triclosan in the body can actually promote Staph infections.70 In laboratory experiments
with E. coli, researchers were able to isolate organisms with low, medium, and high levels
of resistance to triclosan. In one experiment, 100 times the concentration of triclosan was
required to kill a resistant strain of E. coli as compared to a strain not yet exposed to the
antimicrobial. These resistant E. coli also showed resistance to a new antibiotic being tested
at the time of the experiment.71
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A recent report by the National Institute of Standards and Technology (NIST) found that
nanoparticles can migrate from flooring finishes and indoor paints after cleaning, and can
be present in interior spaces. The report includes a particular caution with regard to small
children who may crawl on such floors, presenting greater opportunity for exposure to these
particles. It also cites a lack of data about how these particles are released, accumulate, and
move within spaces as a barrier to providing a more complete health assessment.76
There is additional evidence that silver-based antimicrobials can leach out of the materials in
which they are incorporated and find their way into the environment. The Swedish Chemicals
Agency tested articles of clothing treated with silver antimicrobials and found that, while the
percentage of silver lost after washing did vary, leaching was common. In at least one case,
98% of the antimicrobial silver was lost over ten washes.77 These silver particles wash down
drains and enter water treatment facilities. Wastewater treatment sludge is sometimes spread
as crop fertilizer or used in landscaping, where they enter the surrounding ecosystem.78
As noted above, nanosilver is considered toxic to aquatic ecosystems, persistent in the
environment, and hazardous to organ systems.79
The Swedish Chemical Inspectorate noted as part of its textile study that silver
concentrations in sewage sludge in Sweden had been on the decline since the photography
industry moved away from chemical development, but that silver concentrations are starting
to accumulate once more: The fact that levels of silver are no longer declining in the
sludge is assumed to be due to increased use of silver as [an antimicrobial additive] in
various articles.80
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By the late 1970s, researchers were finding triclosan The global distribution of triclosan raises concern. It is
contamination in river water and sediments, and in 2002 persistent and bioaccumulativemeaning that it will not
the US Geological Survey named triclosan as one of the break down rapidly in the environment and will increase in
most frequently found contaminants in waterways sampled concentration as it moves up the food chain, is very toxic to
across 30 states. 81 82 In a summary of literature available in aquatic environments, and has known endocrine activity. 84
2014, one researcher writes:
In a collision of unintended consequences, a recent study
[Triclosan] has been detected in drinking water found triclosan-resistant bacteria in the sediments of
resources, 75% of urine samples representative of the waterways, and indications that the presence of triclosan
U.S. population, 97% of representative U.S. breast may result in a less diverse aquatic ecosystem, with fewer
milk samples, and combined [triclosan and related algae available to support an underwater food chain. 85
compound triclocarban] constitute over 60% of the
See Appendix A for more detailed information on the
total mass of 96 pharmaceuticals detectable in
environmental hazards posed by antimicrobials used in
municipal sludge using EPA Method 1694. Indeed, the
building products.
environmental ubiquity of both chemicals has escalated
such that [triclosan, related antimicrobial triclocarban
used in cosmetics,] or both compounds are now
detectable in house dust worldwide, in ocean water, and
locations as remote as the water loop of spacecraft.83
Despite the CDCs 2003 infection control guidance to the contrary, many Perkins+Will healthcare
clients do look to antimicrobial interior finishes and fabrics as a tool in preventing HAIs. Perkins+Will
has identified the following as common factors driving this interest:
Treating patients with HAIs is Patients can look up HAI rates Hospitals fear lawsuits after
expensive and hospitals may and avoid hospitals with more patients contract HAIs.
not be reimbursed. frequent infections. Regardless of how prevalent
In 2009, the CDC estimated The Centers for Medicare and HAIs may be in a given hospital,
that direct medical care needed Medicaid Services created a every case leaves the hospital
to treat hospital-associated website to make rates of HAIs vulnerable to a potential lawsuit
infections cost as much and other information about on the grounds that the hospital
as $33 billion annually. 89 the quality of hospitals publicly was negligent in preventing
Historically, hospitals have available. Where rates of HAIs the infection.92 Hospitals carry
been compensated for these were previously unknown to insurance to protect them from
additional costs by insurance patients,91 this website creates these liabilities,93 and may
and other programs meaning another pressure point for therefore also face pressure
that, while HAIs were certainly hospitals to reduce their from their insurer to bring rates
an unwanted outcome following rates of HAIs in order to of HAIs to as close to zero
a medical procedure, the remain competitive. as possible.
hospital did not feel a financial
pressure to lower the rates of
HAIs. However, recent changes
to Medicare and provisions
under the Affordable Care Act
mean hospitals are increasingly
left to cover the costs of
treating HAIs.90
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In fact, hospitals are successfully reducing their rates of HAIs without the use of these
products. Kaiser Permanente hospitals, for example, receive the highest possible scores
for hospital safety, 97 due in part to their comprehensive approach to controlling these
infections. This approach focuses on hand hygiene and educational materials geared
toward staff. 98 As previously noted, Kaiser recently instituted a ban of building products
containing certain antimicrobial additives, offering further evidence that these substances
are not needed to successfully combat HAIs.
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But architects and designers can also be proactive about finding antimicrobial-
free materials and finishes. Some manufacturers have eliminated antimicrobials
from some or all of their product lines. Design teams should prefer these
products whenever possible.
Another resource for architects and designers is the Pharos Project, which
identifies the common composition of more than 100 products used in building
construction and finishing. These Common Product Profiles identify when the
inclusion of antimicrobial substances is a standard practice in a given product
type.101
Potential impacts to human and environmental health as a result of these additives may include
antibiotic resistance, and the appearance of antimicrobial additives in ecosystems. Because of
this, project teams should be made aware when antimicrobial products are suggested, or when
antimicrobial additives are found in any product specification. If the antimicrobial functionality is
optional, review the benefits and potential risks with the clientopting out may be the best course.
Ideally, manufacturers would clearly disclose when antimicrobials are added to building products,
the specific additives used, and their purpose within the product. Until this is standard practice, the
designers best course of action is to educate clients interested in antimicrobial products, and explain
why they may want to be avoided.
Perkins+Wills Transparency Site is being updated with a Watch Listsubstances of concern that
are generally unavoidable at this point in time. Antimicrobials, as a group, will be added to this
classification. In addition, the Precautionary List itself will soon include Products Marketed as
Antimicrobial, reflecting the position of the CDC, the FDA, and other credible organizations that have
reviewed the state of evidence on these substances and found them to be unnecessary. The growing
inclusion of antimicrobial additives is at odds with the firms commitment to the health and wellbeing
of people and planet, and with the precautionary principle, which is an integral part of the firms
approach to product evaluation.
Ultimately, the decision to include these products in projects is at the discretion of our clients. The
intentional use of antimicrobials in building products beyond what might be required for product
preservation, in our opinion, should be avoided. Many of our clients request antimicrobial qualities
for products we select; as trusted advisors to our clients, it is our responsibility to provide information
regarding the pitfalls of antimicrobials and lack of proven benefit of their use in practice.
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Endnotes
1 For a list of hazards associated with a 9 U.S. Department of Health and Human 20 Cosentino. Silestone USA Bacteriostatic
selection of antimicrobial substances, see Services Centers for Disease Control Protection. Accessed March 25, 2016. http://
Appendix A. and Prevention (CDC). Guidelines for www.silestoneusa.com/what-is-silestone/
Environmental Infection Control in Health- bacteriostatic-protection/
2 Guidelines for Environmental Infection Control
Care Facilities. Centers for Disease Control
in Health-Care Facilities. Centers for Disease 21 See for example, SARGENT Manufacturing
and Prevention, 2003. http://www.cdc.gov/
Control and Prevention, 2003. http://www.cdc. Company. A Whole New Kind of Building
hicpac/pdf/guidelines/eic_in_HCF_03.pdf
gov/hicpac/pdf/guidelines/eic_in_HCF_03.pdf Security. Accessed March 29, 2016. http://
10 Greenfield, Nicole. The Dirt on Antibacterial www.sargentlock.com/solutions/microshield/
3 US Food and Drug Administration. FDA
Soaps. NRDC, March 15, 2016. https://www.
Issues Final Rule on Safety and Effectiveness 22 See for example, US Environmental
nrdc.org/stories/dirt-antibacterial-soaps
of Antibacterial Soaps. FDA News Release, Protection Agency. Agion Silver Antimicrobial
September 2, 2016. http://www.fda.gov/ 11 US Food and Drug Administration. FDA Type AL Label, October 7, 2014. https://
NewsEvents/Newsroom/PressAnnouncements/ Issues Final Rule on Safety and Effectiveness www3.epa.gov/pesticides/chem_search/
ucm517478.htm of Antibacterial Soaps. FDA News Release, ppls/088165-00002-20141007.pdf
September 2, 2016. http://www.fda.gov/
4 See for example, Kaiser Permanente. 23 See for example, Leviton Manufacturing Co.
NewsEvents/Newsroom/PressAnnouncements/
Press Release: Kaiser Permanente Antimicrobial Treated Devices. Accessed
ucm517478.htm
Rejects Antimicrobials for Infection March 28, 2016. http://www.leviton.com/
Control, December 11, 2015. https:// 12 See for example, FTC Charges Companies OA_HTML/SectionDisplay.jsp?section=66321
share.kaiserpermanente.org/article/kaiser- with Bamboo-Zling Consumers with False &minisite=10251
permanente-rejects-antimicrobials-for- Product Claims | Federal Trade Commission.
24 Leviton Manufacturing Co., Inc. Antimicrobial
infection-control/ Accessed March 30, 2016. https://www.ftc.
Treated Devices from Leviton, 2014.
gov/news-events/press-releases/2009/08/
5 US Environmental Protection Agency, OARM. http://www.leviton.com/OA_HTML/
ftc-charges-companies-bamboo-zling-
Pesticides Impact on Indoor Air Quality. ibcGetAttachment.jsp?cItemId=9SsCO-7Ck1
consumers-false-product-claims Press
Overviews and Factsheets. Accessed March nFi0WOCbfU3g&label=IBE&appName=IBE&
Release: The North Face Parent Company,
29, 2016. https://www.epa.gov/indoor-air- LEVCOMP_pses=ZG823CD6CD65D6C24894
Saniguard Marketers, and Califone Fined
quality-iaq/pesticides-impact-indoor-air-quality 60ED2083C88A81F1F11FDF76242E07E35
More Than $500,000 Over Antimicrobial
629C19E119CA10E6C19D24487FA4B8DBC
6 US Department of Health & Human Services. Claims. Accessed March 29, 2016. https://
089655CC8D5199BE0165DAD1F3D8&mini
Understanding Microbes in Sickness and in yosemite.epa.gov/opa/admpress.nsf/0/
site=10251
Health. National Institute of Allergy and AC0C1AF1625888608525771B00561E83
Infectious Diseases, September 2009 (3). 25 Peeler, C. Lee. Public Information and
13 Halden, Rolf. On the Need and Speed of
Records Integrity Branch Information
7 Antibacterial Substances Leaking out with Regulating Triclosan and Triclocarban in the
Resources and Services Division Office of
Washing Water - Analysis of Silver, Triclosan United States. Environmental Science &
Pestcide Programs, July 17, 1998. https://
and Triclocarban in Textiles before and Technology 48 (March 3, 2014): 360311.
www.ftc.gov/sites/default/files/documents/
after Washing. Swedish Chemicals Agency,
14 International Antimicrobial Council. advocacy_documents/ftc-staff-comment-
February 2012. https://www.kemi.se/global/
Antimicrobial Coatings Market Expected environmental-protection-agency-concerning-
pm/2012/pm-1-12-antibact-en.pdf; Halden,
To Reach $4,520.3 Million by 2020. treated-articles-exemption-under-epas/
Rolf On the Need and Speed of Regulating
International Antimicrobial Council, August v980017.pdf
Triclosan and Triclocarban in the United
10, 2015. http://amcouncil.org/antimicrobial-
States. Environmental Science & Technology 26 US Environmental Protection Agency.
coatings-market-expected-to-reach-4520-3-
48 (March 3, 2014): 360311. Pesticide Product Label System. Database.
million-by-2020/
Accessed March 29, 2016. https://iaspub.epa.
8 See for example, Yazdankhah, Siamak P., Anne
15 Excerpted from Appendix A. See Appendix for gov/apex/pesticides/f?p=PPLS:1
A. Scheie, E. Arne Hiby, Bjrn-Tore Lunestad,
sourcing.
Even Heir, Tor ystein Fotland, Kristine 27 Heine, Lauren, Matteo Kausch, Susan
Naterstad, and Hilde Kruse. Triclosan 16 See for example, THOR Specialties, Inc. Klosterhaus, Stacy Glass, and Tom Lent.
and Antimicrobial Resistance in Bacteria: Biocides. Accessed March 29, 2016. http:// Material Health Evaluation Programs -
An Overview. Microbial Drug Resistance www.thor.com/usa/biocides.html Harmonization Opportunities, August 20,
(Larchmont, N.Y.) 12, no. 2 (2006): 8390. 2013. http://www.usgbc.org/resources/
17 Dow Chemical Company. Increasing
doi:10.1089/mdr.2006.12.83;McBain, material-health-evaluation-programs-
Consumer Interest in Personal and Family
Andrew J., Ruth G. Ledder, Louise E. Moore, harmonization-opportunities
Wellness Creates Potential Sales Growth
Carl E. Catrenich, and Peter Gilbert. Effects
Opportunities for Apparel, Footwear and 28 See for example, NSF Sustainability. Health
of Quaternary-Ammonium-Based Formulations
Home Furnishings Treated with Next- Product Declaration. NSF Sustainability.
on Bacterial Community Dynamics and
Generation Antimicrobials, September Accessed March 30, 2016. http://www.
Antimicrobial Susceptibility. Applied and
10, 2013. http://www.dow.com/microbial/ nsf.org/newsroom_pdf/su_health_product_
Environmental Microbiology 70, no. 6
news/2013/20130910a.htm declaration.pdf
(June 1, 2004): 344956. doi:10.1128/
AEM.70.6.3449-3456.2004; Scientific 18 Microban International. Progressive 29 US Environmental Protection Agency, OARM.
Committee on Emerging and Newly Identified Antimicrobial Countertop Product Protection. Pesticides Impact on Indoor Air Quality.
Health Risks. Assessment of the Antibiotic Accessed March 28, 2016. http://www. Overviews and Factsheets. Accessed March
Resistance Effects of Biocides. European microban.com/what-we-do/by-product/ 29, 2016. https://www.epa.gov/indoor-air-
Commission, January 19, 2009. http:// categories/countertops quality-iaq/pesticides-impact-indoor-air-quality
ec.europa.eu/health/ph_risk/committees/04_
19 Microban International. Silestone Case
scenihr/docs/scenihr_o_021.pdf
Study. Accessed March 29, 2016. http://
www.microban.com/about-microban/case-
studies/silestone-case-study
perkinswill.com 29
Endnotes
61 Anton C de Groot, Mari-Ann Flyvholm. 72 Yazdankhah, Siamak P., Anne A. Scheie, E. 82 U.S. Geological Survey. Pharmaceuticals,
Formaldehyde-Releasers: Relationship to Arne Hiby, Bjrn-Tore Lunestad, Even Heir, Hormones, and Other Organic Wastewater
Formaldehyde Contact Allergy. Contact Tor ystein Fotland, Kristine Naterstad, and Contaminants in US Streams. US Geological
Allergy to Formaldehyde and Inventory of Hilde Kruse. Triclosan and Antimicrobial Survey, June 2002. http://toxics.usgs.gov/
Formaldehyde-Releasers. Contact Dermatitis Resistance in Bacteria: An Overview. pubs/FS-027-02/pdf/FS-027-02.pdf
61, no. 2 (2009): 6385. doi:10.1111/ Microbial Drug Resistance (Larchmont, N.Y.)
83 Halden, Rolf. On the Need and Speed of
j.1600-0536.2009.01582.x. 12, no. 2 (2006): 8390. doi:10.1089/
Regulating Triclosan and Triclocarban in the
mdr.2006.12.83.
62 International Agency for Research on Cancer. United States. Environmental Science &
IARC Monographs on the Evaluation of 73 Soumet, C., E. Fourreau, P. Legrandois, and Technology 48 (March 3, 2014): 360311.
Carcinogenic Risks to Humans. Accessed P. Maris. Resistance to Phenicol Compounds
84 Oregon Department of Environmental Quality,
August 3, 2016. https://monographs.iarc.fr/ Following Adaptation to Quaternary Ammonium
Priority Persistent Pollutant (P3) List, http://
ENG/Classification/index.php Compounds in Escherichia Coli. Veterinary
www.deq.state.or.us/wq/SB737/docs/
Microbiology 158, no. 12 (July 6, 2012):
63 American Cancer Society. Formaldehyde. LegRpAtt20100601.pdf European Union,
14752. doi:10.1016/j.vetmic.2012.01.030.
Accessed August 3, 2016. http://www.cancer. Regulation on the Classification, Labelling and
org/cancer/cancercauses/othercarcinogens/ 74 McBain, Andrew J., Ruth G. Ledder, Louise Packaging of Substances and Mixtures (CLP)
intheworkplace/formaldehyde E. Moore, Carl E. Catrenich, and Peter Annex 6 Table 3-1 - GHS Hazard code criteria
Gilbert. Effects of Quaternary-Ammonium- http://echa.europa.eu/web/guest/information-
64 Nichols, Dean. Antimicrobial Additives
Based Formulations on Bacterial Community on-chemicals/cl-inventory-database The
in Plastics and the European Biocidal
Dynamics and Antimicrobial Susceptibility. International Chemical Secretariat, SIN
Products Directive. Plastics, Additives and
Applied and Environmental Microbiology 70, (Substitute It Now) List, http://sinlist.chemsec.
Compounding 4, no. 12 (December 2002):
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AEM.70.6.3449-3456.2004.
85 Drury, Bradley, John Scott, Emma J. Rosi-
65 Levy, S. B. Antibacterial Household Products:
75 Sherwin-Williams. Paint Shield TV Marshall, and John J. Kelly. Triclosan
Cause for Concern. Emerging Infectious
Commercial, 2016. https://www.youtube.com/ Exposure Increases Triclosan Resistance and
Diseases 7, no. 3 Suppl (2001): 51215.
watch?v=s2Fh-MtJWWY US Environmental Influences Taxonomic Composition of Benthic
66 Chopra, Ian. The Increasing Use of Silver- Protection Agency. Sanitizer #1 Notice of Bacterial Communities. Environmental
Based Products as Antimicrobial Agents: A Pesticide Registration, October 8, 2015. Science & Technology 47, no. 15 (August 6,
Useful Development or a Cause for Concern? https://www3.epa.gov/pesticides/chem_ 2013): 892330. doi:10.1021/es401919k.
Journal of Antimicrobial Chemotherapy 59, no. search/ppls/067603-00013-20151008.pdf
86 Centers for Disease Control and Prevention.
4 (April 1, 2007): 58790. doi:10.1093/jac/
76 US Department of Commerce, NIST. NIST HAI Data and Statistics, March 2, 2016.
dkm006.
Manuscript Publication Search. Accessed http://www.cdc.gov/HAI/surveillance/
67 Dow Chemical Company. Increasing March 29, 2016. http://www.nist.gov/
87 Doherty, Diane, and Edward Dunn.
Consumer Interest in Personal and Family manuscript-publication-search.cfm?pub_
Healthcare-Associated Infections: A Deeper
Wellness Creates Potential Sales Growth id=914979
Look. ACE Insured, October 2015. http://
Opportunities for Apparel, Footwear and
77 Ulrike Frank. Identity, Grouping and www.acegroup.com/us-en/news-room/wp-
Home Furnishings Treated with Next-
Characterisation of Silver Based Biocidal healthcare-associated-infections-a-deeper-
Generation Antimicrobials, September
Active Substances Including Nano-Silver. look.aspx
10, 2013. http://www.dow.com/microbial/
February 2012. https://pharosproject.net/
news/2013/20130910a.htm 88 Centers for Disease Control and Prevention.
uploads/files/sources/1828/1398436109.pdf
HAI Data and Statistics, March 2, 2016.
68 Kaiser Permanente. Prohibition of
78 Center for Food Safety. What Is Sewage http://www.cdc.gov/HAI/surveillance/
Antimicrobial Chemicals in Fabrics, Furniture
Sludge? Accessed August 3, 2016. http://
and Finishes, October 15, 2015. http://www. 89 Scott, R. Douglas. The Direct Medical Costs
www.centerforfoodsafety.org/issues/1050/
usgbc-ncc.org/storage/images/newsletter/ of Healthcare-Associated Infections in the
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kp_antimicrobials.pdf?mkt_tok=3RkMMJWWf US Hospitals and the Benefits of Prevention.
F9wsRokvK%2FBZKXonjHpfsX54u0oUa%2Bg 79 Linde, Nancy. Chemical Hazard Assessment Centers for Disease Control and Prevention,
38431UFwdcjKPmjr1YAGTMp0aPyQAgobGp5I for Nanosilver, Metallic (CAS# 7440-22-4) March 2009. http://www.cdc.gov/hai/pdfs/hai/
5FENTLLYX7Nwt6AFUg%3D%3D [Modified from GreenScreen Version 1.2]. scott_costpaper.pdf
NSF International, October 31, 2015. https://
69 Data provided to Perkins + Will by a Dallas, TX 90 Conway, Patrick. Statement by Patrick
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paint supplier November 14, 2016. The cost of Conway, M.D., Chief Medical Officer and
7dd3b0691b37ee19797acae5622d4ba.pdf
this particular antimicrobial paint is currently Director, Office of Clinical Standards and
$304.95 per 5 gallons versus $192.20 per 5 80 Swedish Chemicals Agency. Antibacterial Quality, Centers for Medicare & Medicaid
gallons of standard commercial latex paint. Substances Leaking out with Washing Water - Services, US Department of Health
Analysis of Silver, Triclosan and Triclocarban and Human Services on U.S. Efforts To
70 Syed, Adnan K., Sudeshna Ghosh, Nancy
in Textiles before and after Washing. Swedish Reduce Healthcare-Associated Infections,
G. Love, and Blaise R. Boles. Triclosan
Chemicals Agency, December 12, 2011. September 24, 2013. http://www.hhs.gov/asl/
Promotes Staphylococcus Aureus Nasal
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81 Halden, Rolf. On the Need and Speed of
71 Levy, S. B. Antibacterial Household Products:
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perkinswill.com 31
Appendix A
Health & Environmental
Hazards Associated with
an Abbreviated List of
Antimicrobial Additives
Found in Building
Products (alphabetical)
perkinswill.com 33
Abbreviation, Antimicrobial, CAS No. Hazard Summary Used In
BBIT (2-Butyl-1,2-benzisothiazolin-3-one) Skin Irritation, Aquatic Toxicant 1 Sealants, Adhesives, Caulks, Wallboard, Ceiling
CAS: 4299-07-4 Tiles 2
Copper Skin Sensitizer, Organ Toxicant 7 Knobs/Handles, Touchable Surfaces, Ceiling Tiles,
CAS: 7440-50-8 For copper dust: hazards for copper above, Adhesives, Textiles, Plastic articles 9
plus Gene Mutation, Developmental Toxicant,
Mammalian Toxicant, Aquatic Toxicant 8
CMIT or CIT (Methylchloroisothiazolinone) Mammalian Toxicant, Eye Irritation, Skin Irritation Paints/Stains, Adhesives, Caulks, Grout, Wood
CAS: 26172-55-4 and Sensitization, Aquatic Toxicant 10 Products11
CTAC (1-(3-chloroallyl)-3,5,7-triaza-1- Developmental Toxicant, Skin Sensitization12 Adhesives, Caulks, Grouts, Concrete Admixes,
azoniaadamantane chloride) Paints13
CAS: 4080-31-3
DCOIT (4,5-dichloro-2-octyl-2H-isothiazol-3-one) Mammalian Toxicant, Eye and Skin Irritation, Caulks, Sealants, Grouts15
CAS: 64359-81-5 Aquatic Toxicant 14
DDAC (Alkyl didecyl dimethyl ammonium chloride) Respiratory Sensitizer, Eye and Skin Irritation, Wood Products17
CAS: 7173-51-5 Aquatic Toxicant 16
Elemental Silver / Silver Nanoparticles Mammalian Toxicant, Skin sensitization, Upholstery & Fabrics, Hardware, Touchable
CAS: 7440-22-4 Aquatic Toxicant 18 Surfaces, Tile Installation Products, Ceramic
For silver nanoparticles: Hazards for silver above, Tile, Countertops, Adhesives, Sealants, Paints,
plus Endocrine Disrupter, Organ Toxicant 19 Carpets, Textiles 20
Formaldehyde Carcinogen, Developmental Toxicant, Mutagen, Released into wet-applied products by certain
CAS: 50-00-0 Respiratory Sensitizer, Mammalian Toxicant, Eye preservative additives 22
Irritation, Skin Irritation, Skin Sensitization 21
IPBC (3-iodo-2-propynyl butylcarbamate) Developmental Toxicant, Eye Irritation, Skin Paints/Stains, Wire & Cable, Carpets, Textiles,
CAS: 55406-53-6 Sensitization, Organ Toxicant, Aquatic Toxicant 23 Wood Product 24
MIT (Methylisothiazolinone) Mammalian Toxicant, Skin Irritation and Paints/Stains, Adhesives, Caulks, Grout, Wood
CAS: 2682-20-4 Sensitization, Aquatic Toxicant 25 Products 26
OBPA (Oxybisphenooxyarsine) PBT, Carcinogen, Developmental Toxicant, Flexible PVC, Adhesives, Coatings, Textiles 28
CAS: 58-36-6 Neurotoxicant, Mammalian Toxicant, Organ
Toxicant, Aquatic Toxicant 27
OIT (2-n-octyl-4-isothiazolin-3-one ) Developmental Toxicant, Mutagen, Mammalian Adhesives, Textiles, Wood Products 30
CAS: 26530-20-1 Toxicant, Eye and Skin Irritation, Skin Sensitizer,
Aquatic Toxicant 29
Propiconazole Endocrine Disruptor, Aquatic Toxicant 31 Wood Products, Paints, Coatings, Caulks,
CAS: 60207-90-1 Adhesives 32
QACs (Quaternary Ammonia Compounds) Respiratory Sensitizer, Asthmagen 33 Disinfection Products, Wood Products, Specialty
CAS: specific to individual substances Paints 34
Silver Zeolite At the time of publishing, no authoritative source Paints, Carpet Fibers, Wallpaper, Adhesives,
CAS: 130328-18-6 used in the Pharos Chemical and Material Library Fabrics/Textiles 35
associates this substance with health hazards.
Triclosan (2,4,4-trichloro-2- hydroxy-diphenyl- PBT, Endocrine Disruptor, Aquatic Toxicant 36 Textiles, Plastic Sheets/Parts, Adhesives, Caulk,
ether) Coatings, Tile Installation Products, Hardware,
CAS: 3380-34-5 Ceramic Tile, Carpets, Countertops 37
ZPT (Zinc pyrithione) Reproductive Toxicant, Mammalian Toxicant, Eye Fabrics/Textiles, Wall Coverings, Adhesives,
CAS: 13463-41-7 Irritant, Skin Sensitization, Aquatic Toxicant 38 Caulks, Sealants, Grouts, Joint Compounds 39
perkinswill.com 35
Sources for Appendix A
27 Oregon Department of Environmental Quality, 34 NIH QACs webpage http://nems.nih.gov/soc/
Priority Persistent Pollutant (P3) List, www. Pages/Quaternary-Ammonium-Compounds-
deq.state.or.us/wq/SB737; USEPA, Risk (QACs-or-Quats).aspx US Environmental
Management Actions & TSCA Work Plans. Protection Agency. Sanitizer #1 Notice of
www.epa.gov/oppt/existingchemicals/ Pesticide Registration, October 8, 2015.
Philippe Grandjean and Phil Landrigan, https://www3.epa.gov/pesticides/chem_
Developmental neurotoxicity of industrial search/ppls/067603-00013-20151008.pdf
chemicals, List of 201 Chemicals known to
35 Fuji Chemical Industries. Bactekiller A,
be neurotoxic in man, www.fundrogertorne.
October 21, 2003. https://www3.epa.gov/
org/salud-infancia-medio-ambiente/pdf/
pesticides/chem_search/ppls/059824-
developmental-neurotoxicity-of-industrial-
00003-20031218.pdf
chemicals-grandjean-landrigan.pdf USEPA,
Extremely Hazardous Substances - EPCRA 36 Oregon Department of Environmental Quality,
Section 302, https://www.epa.gov/sites/ Priority Persistent Pollutant (P3) List, http://
production/files/2015-03/documents/ www.deq.state.or.us/wq/SB737/docs/
list_of_lists.pdf European Union, Regulation LegRpAtt20100601.pdf European Union,
on the Classification, Labelling and Packaging Regulation on the Classification, Labelling and
of Substances and Mixtures (CLP) Annex 6 Packaging of Substances and Mixtures (CLP)
Table 3-1 - GHS Hazard code criteria http:// Annex 6 Table 3-1 - GHS Hazard code criteria.
echa.europa.eu/web/guest/information-on- http://echa.europa.eu/web/guest/information-
chemicals/cl-inventory-database on-chemicals/cl-inventory-database The
International Chemical Secretariat, SIN
28 Micropel 5 DIDP, January 2, 2014. https://
(Substitute It Now) List, http://sinlist.chemsec.
www3.epa.gov/pesticides/chem_search/
org/
ppls/005383-00125-20140102.pdf
37 Microban Additive B Label, August 23, 2013.
29 MAK Commission of Germany List of
https://www3.epa.gov/pesticides/chem_
Substances with MAK & BAT Values &
search/ppls/042182-00001-20130823.pdf
Categories, http://onlinelibrary.wiley.com/
book/10.1002/3527600418/homepage/ 38 Government of Japan, GHS Classifications,
access_to_the_list_of_mak_and_bat_values. http://www.nite.go.jp/en/chem/chrip/chrip_
htm Republic of Korea, GHS Classification search/intSrhSpcLst?_e_trans=&slScNm=CI_
and Labelling for Toxic Chemicals, http://ncis. 01_001&bcPtn=6
nier.go.kr/ghs/hcs/en/search/search_en_01.
39 Zinc Omadine Powder Industrial Microbiostat
jsp European Union, Regulation on the
Label, December 19, 2014. https://
Classification, Labelling and Packaging of
www3.epa.gov/pesticides/chem_search/
Substances and Mixtures (CLP) Annex 6
ppls/001258-00840-20141219.pdf
Table 3-1 - GHS Hazard code criteria. http://
echa.europa.eu/web/guest/information-on-
chemicals/cl-inventory-database New Zealand
HSNO Chemical Classifications www.epa.govt.
nz/search-databases/Pages/HSNO-CCID.aspx
perkinswill.com 37
APPENDIX B
Consumers feel a misplaced confidence in antimicrobial building products, in part, because of confusing, and in some
instances, highly misleading marketing materials made possible by the extremely complex regulation governing this sector.
This regulation is known by the acronym FIFRA, which stands for the Federal Insecticide, Fungicide and Rodenticide Act,
and is overseen by the US Environmental Protection Agency.
There are several ways in which FIFRA makes it difficult for the average
person to interpret marketing materials about a products antimicrobial
properties.
1. The EPA must use a case-by-case approach 2. The language considered to be a health
to regulating pesticides.1 claim is very specific.
Rather than regulate antimicrobials by substance, In 2000 the EPA issued a notice attempting to clarify
FIFRA requires the EPA to regulate antimicrobials the distinction between products making health claims
based on how they are used in a product, and how and those considered treated articles. That notice
that product will be marketed. For example, nanoscale lists just seven scenarios where marketing language
silver has the same inherent hazards to humans and constitutes a health claim, and therefore subject to
the environment regardless of its function in a product, regulation under FIFRA:5
or the words used on a products packaging. But
1. A claim that the product controls
the EPA would only consider it subject to regulation
microorganisms that are infectious to the
if a manufacturer wanted to advertise a product
public.
incorporating it as being able to kill microbes that
could make a person sick. This is known as making a 2. Any claim that a product sterilizes, disinfects,
health claim under FIFRA. Cautious that the public kills viruses, or sanitizes.
will see these claims, feel a false sense of security,
3. A claim that uses the specific terms
and let basic sanitation habits lapse, the EPA closely
antibacterial, bactericidal, or germicidal.
monitors the language used to market these products. 2
Manufacturers must also provide documentation that 4. A claim that the product can be used against
the use of the product as intended will not present an infectious fungi.
unreasonable risk to the environment or food supply. 3
5. Claims that the product can control the spread
of allergens because it can control the growth
If the same nanoscale silver compound was added to
of mold or mildew.
an identical product, and as long as the manufacturer
did not seek to make a health claim, the product 6. Any claim that the product will have a benefit
is exempted from further regulation. This is known to public health where it is applied.
as a treated article exemption under FIFRA. The
7. Claiming that a product is antimicrobial
agency does not verify manufacturers assertions
about exempted products abilities to control target without qualifications.
organisms, nor does it evaluate them for health and
environmental impacts.4
perkinswill.com 39
APPENDIX B
FIFRA provides an opportunity for manufacturers to mislead advises that they be cleaned just as frequently as standard
consumers about the benefits of antimicrobial products, hardware would be, 22 so it is unclear what advantage this
whether they intend to do so or not. antimicrobial additive provides in practice.
The term registration can be interpreted by A third example of this phenomenon is of light switches
consumers to be an indication of the EPAs seal of and covers that are coated with an antimicrobial additive. 23
approval. Product literature highlights independent laboratory testing
showing the additive is effective against bacteria such as
All substances that can be used as pesticides need to
MRSA (a drug-resistant strain of staphylococcus), while
be registered with the EPA. The agency then gives the
only briefly confirming elsewhere, in smaller text, that the
substance a unique registration number, and adds it to a
antimicrobial additive is present only as a preservative
database. (The EPA estimates that 275 substances are
that protects the switch and cover from mold, mildew, and
registered with the Agency as pesticides.)17 Advertising can
other microbes that may jeopardize the integrity of the
include statements that a building product contains an EPA
product.24 This disclaimer confirms that despite listing
registered antimicrobial and is resistant to X, Y, or Z. While
infectious MRSA as a microbe targeted by the antimicrobial
a consumer may interpret this to mean that the EPA has
additive, the additive is a preservative only, and is not
reviewed the antimicrobial in question and has issued a
formally making a health claim under FIFRA.
registration as an indication that it is effective, beneficial, or
even harmless, the reality is that the EPA registration simply The EPA is concerned about the growing use of a wide
indicates that the antimicrobial additive is considered a variety of antimicrobial claims made in marketing materials.
pesticide by the agency. The agency takes very seriously public health claims it
finds to be unsubstantiated. 25 At the time of publication, a
Remember that in the case of treated articles, the EPA does
search of the EPAs database of Administrative Enforcement
not verify manufacturer claims of efficacy against microbes,
Dockets related to FIFRA infractions returned 1,000 case
or evaluate its health or environmental impacts.18
numbers, dating back to 2000. 26
Antimicrobial ingredients may be added to building
In a 1998 bulletin, the agency warned:
products as preservatives even though the products do
not require preservationas a marketing ploy. EPA is concerned about these statements because,
in addition to being unlawful, they are also potentially
For example, looking for a way to innovate and differentiate
harmful to the publicif people believe that the
from their competition, a countertop company incorporated
product has a self-sanitizing quality, they may not
an antimicrobial into an engineered stone product. Despite
practice standard hygiene to prevent the transmission
the fact that this additive is a preservativeand has no
of harmful germs. Consequently public health may be
benefit to human healththe company saw a 38% rise
less protected. For that reason, EPA advises consumers
in annual revenue, and a 48% increase in market share.19
not to rely on antibacterial claims as a substitute for
Since the antimicrobial was added to the product in an
following common-sense hygienic practices. EPA
effort to innovate and differentiate, and research
does not know whether these treated products work
finds that engineered stone countertops do not uniformly
as claimed.27
require a preservative, 20 it is difficult to believe that this
antimicrobial was a necessary additive.
perkinswill.com 41
Please consider the environment
before printing this document.
perkinswill.com