CPVC: Why a Coalition of Environment, Consumer and Labor Organizations are Demanding a Thorough Environmental Review

• Leaching studies commissioned by the State of California and conducted by UC Berkeley found that CPVC pipes leach toxic chemicals such as THF, MEK, acetone and organotins (including tributyltin), into drinking water. These chemicals may cause cancer in humans.
• If approved for widespread use, the public would be exposed to CPVC leached toxins through consumption of drinking water, inhalation and skin exposure during bathing.
• CPVC pipe releases dioxin when burned. Dioxin is believed to cause cancer, and is considered one the most toxic chemicals known to science.

• Widespread use of CPVC solvents and cements will result in VOC emissions that pollute the air.
• CPVC pipe is not a recyclable plastic and is considered a "contaminant" in the waste stream.
• CPVC pipe makes residential fires, plastic incinerators and landfill fires significantly more hazardous because of the toxins they release.
• Chemicals that leach from CPVC pipe, particularly tributyltin, are toxic to many aquatic creatures and plants, endangering California's beaches and ocean.

• A National Toxicology Program study concluded a glue used to install CPVC contains chemicals known to cause cancer in animals and considered potentially carcinogenic to humans.
• A 1989 Department of Health Service study concluded that the use of CPVC solvents and cements exposes workers to harmful chemicals such as THF and MEK at levels exceeding established workplace standards.
• Recent studies have determined that, where CPVC has been approved on a limited basis, enforcement and implementation of ventilation and glove-use requirements have been virtually non-existent.

CPVC: Industry's Refusal to Conduct a Rigorous Health and Environmental Safety Study

• Past attempts at environmental review have either been abandoned, rescinded, or have uniformly failed to adequately evaluate its potential impacts.
• Industry chose to abandon the 1989 CPVC EIR after preliminary investigations revealed serious issues that required further study. The 1998 CPVC EIR was prepared by the state and then rescinded as "incomplete."
• Rather than completing a 1998 EIR, industry chose to prepare a very narrow environmental review (the 2000 Mitigated Negative Declaration) on the limited approval of CPVC. This approval restricted the use of CPVC to where building officials determine that metal pipe may fail due to corrosive water or soil conditions. CPVC is now approved for use where corrosive water and soil conditions cause copper to prematurely fail. (California Plumbing Code § 604.1.2.)
• Substantial new evidence of the potential impacts of the statewide approval of CPVC have been uncovered since the limited approval of CPVC was adopted in 2000.

• There is no evidence that approval of CPVC would help alleviate the shortage of affordable housing in California.
• Noted economist Dr. William T. Dickens studied this issue and determined that any savings from the use of plastic piping would not be passed on to homebuyers. Where the supply of housing is limited, as in California, the price of housing is determined by land prices and demand, not the cost of plumbing a house.
• Dr. Dickens also concluded that the shorter lifespan of plastic pipe versus copper pipe results in higher replacement costs for consumers.

After extensive comments identifying the risks associated with CPVC from a coalition of the Consumer Federation of California, Sierra Club, Planning and Conservation League, Communities for a Better Environment, Center for Environmental Health, California Professional Firefighters' Association and the California State Pipe Trades Council, industry is now finally preparing an EIR that will follow the law.

The decision to follow the law was a major victory for the coalition, and a reversal of the Housing and Community Development and manufacturers' original effort to proceed without preparing a thorough review of the potential hazards. The coalition commends this step and urges the state to ensure that this time the EIR provides an impartial, open and complete review of the potential impacts associated with CPVC.