By: Jane Martinsons, Metal Construction Association
In a recent webinar, Dr. Jim Hoff of the Center for Environmental Innovation in Roofing noted several benefits and limitations of the Health Product Declaration (HPD), and even looked beyond it to newer alternative documents.
Hoff said that on the upside, the HPD document itself is relatively simple and straightforward— “it looks like a Material Safety Data Sheet (SDS),” —and is inexpensive, especially compared to Environmental Product Declarations. Still, he noted the HPD
- uses little or no formal consensus review. “As a building envelope researcher and a longtime participant in standards processes throughout the world, I believe it certainly is a limitation to have a development process that is an ad-hoc process, developed outside a recognized consensus standard,” he said. “The development process does not include all stakeholders that are typically included in ANSI and ASTM processes. For example, building material manufacturers are not included in specific decision-making committees,” he said.
- identifies hazard without assessing risk.
- identifies chemicals of concern using many different sources with varying thresholds. Hoff cited examples of hazard warnings, such as the U.S Environmental Protection Agency’s (EPA) list of known or likely carcinogen, but also pointed to what he considers “less authoritative” warnings. For example, “California Proposition 65 includes many chemicals hazardous only as precursors or during manufacturing,” he said. “When you’re looking at materials that are key ingredients in many common roofing materials [i.e., titanium dioxide, carbon black, wood dust, and bitumen], they are not generally considered to be hazardous in their finished form.”
Other newer alternative documents may offer better information, he said. “There is a whole new generation of MSDSs that are starting in 2014 that are based on a very, very rigorous, globally harmonized system, now endorsed through international treaties and endorsed and integrated by the U.S. EPA.” The new SDSs offer hazard information in a very similar methodology to HPDs and will be available much more rapidly, he said.
Another new product is the Product Transparency Declaration (PTD), which addresses risk as well as hazard assessment. “PTDs take a look at threshold levels and paths for exposure that are important in many products,” he said. Developed by the Resilient Floor Covering Institute and submitted to become an ASTM standard, the PTD could be available to a wide variety of products, Hoff said.
Meanwhile, Hoff stressed that HPDs are included in LEED v4 and are likely to be proposed for next version of International Green Construction Code. As such, he calls on material suppliers to
- be proactive and engaged.
- develop a uniform approach and promote industry-wide initiatives to develop consistent reporting.
- use the Notes section of HPDs to explain or tell the whole story of their products.
- promote alternatives to HPDs that include risk assessment in addition to hazard identification.
For more information, contact Dr. Jim Hoff firstname.lastname@example.org.