What’s Your Secret Ingredient? HPDs Want to Know.
The exact mix of ingredients in Coke wouldn’t be so secret if The Coca-Cola Co. had to fill out one of the new Health Product Declaration forms that building product manufacturers are facing. And many manufacturers are voicing concern that their own proprietary formulations might be forced down the disclosure path posed by HPD.
The HPD is a standardized format for reporting a building product’s contents and how each ingredient affects human and ecological health. Launched in 2012, it is an initiative of Healthy Building Network and Building Green, and is managed by the HPD Collaborative.
In addition to concerns over disclosing proprietary information, AAMA members have noted that the current HPD tool doesn’t present the product information in an architectfriendly format and that the integration of HPDs into green ratings and specs could have major negative ramifications.
The HPD Collaborative does acknowledge that a number of limitations, including intellectual property concerns, make full disclosure challenging for some. In such cases, the HPD may still be used to communicate “what is known about the product and the status of efforts for further disclosure,” according to the Health Product Declaration Standard.
There also is confusion regarding the role of HPD and Life Cycle Analysis. HPD is not a full LCA in that it does not address the potential health impacts of substances used or created during manufacture but which do not appear in the final product. HPDs are instead said to be complementary to the LCA methodology upon which most Environmental Product Declarations are based. These include information not in HPDs such as the environmental impact of raw material acquisition, energy use, emissions and waste generation.
A free online template at www.hpdcollaborative.org lists instructions for creating a product HPD. In essence, it requires disclosure of the different intentional ingredients, residual ingredients and their associated hazards:
- Intentional Ingredients Disclosure: Each discrete chemical, polymer, metal or other substance added to the product during manufacture and that cumulatively comprises 99 percent by weight of the total product must be listed. This includes additives such as dyes, flame retardants, biocide, binder or applied coatings. For wet-applied products or interior finish materials, the total VOC content also must be indicated.
- Residuals Disclosure: Known trace substances remaining in the product from manufacturing steps such as monomers, catalysts or contaminants also must be listed.
- Accessory Materials: Items recommended or required for installation such as adhesives, fasteners or field coatings, or for maintenance, must be listed in a separate section.
- Hazard Disclosure: The HPD process references 32 “authoritative” chemical hazard lists against which ingredients must be screened. The lists were selected from a wide range of sources such as the EPA, United Nations, states of Washington and California, U.S. Department of Health and Human Services, OSHA, CDC and Canadian and EU groups.
Both intentional and residual disclosures must include a GreenScreen rating. This refers to the GreenScreen for Safer Chemicals method for comparative assessment to identify chemicals of “high concern” for human and environmental health, and for finding “safer” alternatives. The GreenScreen List Translator,―an abbreviated, automated online version of the full GreenScreen method,―is intended to save time otherwise spent in searching the hazard lists individually.
While publishing a HPD report is voluntary from a regulatory stance, the architectural community is beginning to request them. Some are telling manufacturers that if they do not have HPDs by the end of 2014, their products will not be specified. This, in effect, makes HPD mandatory, depending on who one sells to.
The trend is magnified by the fact that the U.S. Green Building Council is now offering up to two materials and resources credits in its LEED v.4 for the disclosure and avoidance of the listed “hazardous” ingredients via HPD and GreenScreen. Given the tendency for some activists to questionably label certain fenestration materials as hazardous, we should stay vigilant and weigh in to avoid misrepresentation of our products. Otherwise, our secret ingredients could be tainted.