The Health Product Declaration (HPD) Open Standard Overview: PART FIVE

The Health Product Declaration (HPD) has become a critical specification tool for LEED v4 and LEED v4.1 projects. The HPD provides two key things: a content inventory and a list of potential health hazards associated with product ingredients. However, navigating the HPD Open Standard can be daunting for building product manufacturers and suppliers. In this continuing series, we will breakdown the HPD Open Standard for building product manufacturers and suppliers.

Today we will examine Volatile Organic Compound (VOC) Content within the HPD Open Standard Section 1 Summary. According to the Environmental Protection Agency, volatile organic compounds are emitted as gases from certain solids or liquids. VOCs include several chemicals, many which may have short- and long-term adverse health effects. Concentrations of many VOCs are consistently higher indoors than outdoors.

Organic chemicals are widely used as ingredients in building products. Paints, varnishes and wax all contain organic solvents. These building products can release organic compounds while you are using them. The ability of organic chemicals to cause health effects varies greatly from those that are highly toxic, to those with no known health effect.

VOC Content

Under the Section 1 Summary within the HPD Open Standard, there are five key items for building product manufacturers to focus on. They include general information on VOCs, material VOC content, regulatory VOC content, exempt VOCs, and ultra-low VOC tints. Under the General Information section, states that VOC information must be provided for all liquid/wet- applied products.

Under the Material section, the numerical value of Actual/Material VOC content as the product is supplied must be filled in. Under the Regulatory section, the numerical value of Regulatory VOC content, also referred to as “Coating” content must be supplied. Regulatory VOC content compares regulated, or non-exempt, VOCs against non-exempt volume. Water and exempt solvents are not included.

Bottomline: Product manufacturers must use acceptable methodologies for VOC content which include the EPA Method 24 or ASTM D6886 testing or as per the guidance given in California Air Resources Board (CARB) 2007 Suggested Control Measure for Architectural Coatings or South Coast Air Quality Management District (SCAQMD) Rule 1113, Rule 1168. VOC content plays an important role not only within the HPD Open Standard but also within LEED v4 and other green building rating systems. Manufacturers are advised to have the proper VOC testing documentation for their products to fulfill LEED credits and specification requirements.

Exempt VOCs

According to the EPA, some VOCs react slowly and changes in their emissions have limited effects on ozone pollution episodes. Those VOCs, determined to have low photochemical reactivity by approved test methods, may be excluded as VOC for regulatory purposes. These determinations are made by regulation and are commonly referred to as VOC Exemptions. Note that EPA will only exempt pure compounds. While the EPA has exempted these compounds, some states and California Air Districts have to go through a rule-making to adopt these exemptions.

Several have a direct reference to the EPA exemption, so the compounds are automatically exempted in many States when EPA exempts them. California’s South Coast Air Quality Management District (SCAQMD), Bay Area AQMD, San Diego AQMD, and Sacramento AQMD have not exempted several of these compounds, and recent regulatory activities in these air districts will likely lead to the removal of several exemptions and further restrictions. If a building product contains a substance that is an exempt VOC, “Exempt VOC” must be noted in the HPD Format Section 2 Substance Notes for the corresponding substance.

Ultra-Low VOC Tints

The last item we will examine is whether there is indication for tintable products of whether ultra-low VOC tints may be available at the point of retail sale. Manufacturers must indicate “yes”, “no”, or N/A. “Yes” indicates a product is tintable and tints that meet the South Coast Air Quality Management District (SCAQMD) Super Compliant Coatings definition and/or Federal Trade Commission (FTC) guidance for VOC-free claims are offered by the manufacturer to distributors for this product, resulting in the addition of less than 10 g/L of VOC content for any combination of tints.

Bottomline: Ultra-low VOC tints involve mainly paints and coatings. Manufacturers that use a base formula that is low VOC or zero VOC, may run into trouble once they start adding pigments to the base formula. Design professionals prefer specifying paints with no or little odor. Ultra-low VOC tints provide design professionals with better options for LEED projects.

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