Reporting Product Contents with HPDs
Working Towards a Healthier Building Materials Ecosystem
When the concept of the Health Product Declaration was first piloted in 2011, building industry leaders representing both consumer and manufacturer interests joined forces to determine a practical structure for inventorying product content and associated health hazards. The process was initiated by a diverse group of consumer representatives (designers, specifiers, contractors, building owner/operators and nonprofit workers), and was made successful with the participation of 30 product manufacturers.
The result of the 2011 Pilot was HPD version 1.0, an impartial tool for the accurate reporting of product contents and each ingredient’s relationship to the bigger picture of human and ecological health. The HPD objectively defines the critical information needed to support accurate supply chain disclosure by manufacturers and suppliers. It doesn’t state whether a product or its contents are good or bad; it aggregates information and aims to offer a context for the details that are provided.
A Flexible Reporting Tool
One of the primary aims of the Health Product Declaration is to establish clear and consistent language for product ingredient inventory and associated hazard information. While a manufacturer may elect to report on their products at differing levels of detail, the HPD’s format outlines the metrics and measures that are used in a way that reflects their relative significance.
The degree of disclosure is variable, but clear. There are three main ways to distinguish reporting in an HPD: Full disclosure of known hazards; full disclosure of intentional ingredients; and residuals disclosure to a specific level.
It is possible to have a compliant HPD without conforming to the most stringent levels of disclosure for any of these—encouraging the manufacturer to share what they can, while making the degree of disclosure readily apparent to the HPD user. For example, a compliant HPD may mask proprietary information, such as specific ingredient names or product formulas, and still provide full disclosure of known hazards.
The flexibility of the HPD can be demonstrated by exploring the core of the disclosure format: “Contents in Descending Order of Quantity.” Data entered in this section determines the type of disclosure claims that are possible. For each content line item, the HPD indexes the following eight characteristics:
- Ingredient Name and CAS Reference Number: This space allows for the actual name and CAS RN, a generic name, “Undisclosed” for proprietary purposes, or “Unknown” to reflect limitations of supply chain channels.
- Percent Weight: This is a single number or up to a 20 percent range representing the amount that the content contributes to the makeup of a product. The range may be used to mask proprietary formulas or to reflect the diversity within a single product family.
- GreenScreen Score: Increasingly used as a method to determine chemical hazards, the GreenScreen List Translator or Full Assessment score can shorthand or complement the hazard screening by the HPD’s priority hazard lists.
- Hazard Screening: The 15 hazard endpoints charted on the HPD are linked to content by one or more priority hazard lists. The HPD Collaborative draws primarily from the GreenScreen authoritative lists as a base, which relies on “national and international regulatory sources, influential NGO lists of chemicals of concern, deliberations from authoritative scientific bodies, European Risk and Hazard Phrases and government chemical classifications using the Globally Harmonized System of Classification and Labeling.” (For more information about GreenScreen, visit: www.greenscreenchemicals.org.)
- Recycled Content: When an ingredient is sourced from material previously used in other lifecycle stages there is a potential for the product to contain unknown residuals, such as batch contaminants, that are not traced or screened by the industry.
- Nanotechnology: Given that correlation between nano materials and health impacts is not yet fully understood, this indicator offers information that some consumers are tracking as a precautionary measure.
- Role: The opportunity to explain the purpose of content in a product gives context to the consumer that rationalizes its use.
- Notes: To supplement the rest of the content details, this area can include information like exposure or risk, related code requirements, or advancements underway that may not yet be available to the market. (There is also a General Notes area at the end of the HPD for details about a product as a whole.)
Through standardization of information, the HPD format outlined above can be a platform for manufacturers to better share accomplishments. Meg Bruce, western regional manager for 3form explained, “3form as a company has been working for a long time to do the right thing simply because it is the right thing. HPDs give us a way to showcase these efforts in a fact-based platform outside of marketing materials, which can be construed as green washing.”
A Path for Continuous Improvement
Regardless of whether a manufacturer has long been analyzing a product’s bill of materials against hazard lists, or if itemizing product contents is a new effort for the company, the HPD allows for documentation based on the information that can be known today.
Right now, there is no standard chain-of-custody procedure for manufacturers to record product contents. In seeking this information some manufacturers find that their suppliers are not at first willing to share details about ingredients. As such, the process of creating an HPD is beneficial beyond the act of public disclosure: by providing a standardized and straightforward approach to requests for information, it has helped manufacturers see their products in a new light and learn more about their own product.
The aggregated results in an HPD can show if a product already complies with the priorities of a segment of the market, such as LEED or the Living Building ChallengeSM. One manufacturer that participated in the 2011 Pilot said that an advantage of creating an HPD was “learning that we are actually pretty close to being able to ‘launch’ a new green product offering.”
Even in-house usage of the HPD has proven valuable, identifying contents or components that may be good targets for re-form or further research. Paul Bertram, director of environment and sustainability for Kingspan noted, “This was a pathway Kingspan Insulated Panels used and although the HPD has not yet been publically published, the analysis resulted in transitioning to the elimination of a halogenated flame retardant.”
An Opportunity for Engagement
The uptake of the Health Product Declaration by manufacturers is exciting, and can be attributed in large part to the new LEED credit and consumers’ calls for transparency. The HPD Collaborative encourages manufacturers involvement to extend beyond the use of the HPD, to help inform the evolution of the standard itself. To this end, a Manufacturers Advisory Panel was created to continue the cooperative communications born during the 2011 Pilot. Fifty three manufacturers have joined the MAP so far, and all manufacturers working on HPDs are welcome—regardless of their current position on the spectrum of disclosure.
One of the manufacturers from the 2011 Pilot described their reason for participating as “helping make transparency an industry norm by facilitating this often-difficult transition for manufacturers.” Indeed, by working together within and across industry sectors, we can achieve our common goal of a healthier materials ecosystem.