One of the most requested and sought-after materials transparency documents in the AEC industry is the Health Product Declaration (HPD). The HPD has become a critical specification tool for LEED v4.1 projects. The HPD consists of two primary components: a content inventory and a list of potential health hazards associated with product ingredients. The HPD Open Standard can be difficult for building product manufacturers to navigate and complete. In this continuing series, we review the HPD Open Standard and how it applies to building product manufacturers and suppliers.
In part seven of our series, we examine section 2.1.6 Preparation, Verification, and Publication. The Health Product Declaration Collaborative (HPDC) has list of List of HPDC Approved Preparers and HPDC Approved Verifiers which we will discuss. In addition, we will review the HPD published date, expiry date, archive date, and other pertinent topics. HPD verification plays a role in the new LEED v4.1 ratings system which is anticipated for a late 2020 or 2021 launch.
HPD Third-Party Verification
Within the HPD template is an indicator to show whether the HPD is third-party verified or not. Third-party verification is optional, but if “Yes,” verification must use HPDC-approved verification organizations and the Third-Party Verifier must be filled in. Only HPDC-approved third-party verifiers qualify, and the name of the verifying organization is entered into the template. Approved verification organizations are listed on the HPDC website.
Manufacturers cannot verify their own HPDs, and a verifying organization cannot verify an HPD it prepared. If a third party has not verified the HPD, “No” is indicated for Third-Party Verification. The HPDC Third Party Verification Program allows product manufacturers to work with independent verifiers to ensure that HPDs they have created are compliant with the HPD Open Standard. The Program is underpinned by the credibility of the HPD Open Standard and the expertise of the third-party verifiers.
LEED v4.1 and The Benefits of Third-Party Verification
Sometimes building product manufacturers are confused about verified HPDs and how they relate to LEED. Verified HPDs are not mandated for either LEED v4 or LEED v4.1. Unlike an Environmental Product Declaration (EPD), which has to be verified, there is no mandatory verification required for HPDs in LEED. However, verified HPDs do contribute an additional half-point in LEED v4.1.
Verified HPDs contribute to the LEED v4.1 BD+C and ID+C credit Building Product Disclosure and Optimization -Material Ingredients. The intent of the credit is “to encourage the use of products and materials for which life-cycle information is available and that have environmentally, economically, and socially preferable life-cycle impacts. To reward project teams for selecting products for which the chemical ingredients in the product are inventoried using an accepted methodology and for selecting products verified to minimize the use and generation of harmful substances. To reward raw material manufacturers who produce products verified to have improved life-cycle impacts.”
Under Option 2, a building product with a verified HPD can contribute 1.5 points if the following has been met. The product has demonstrated a chemical inventory to at least 0.01% by weight (100ppm) and at least 95% by weight of product is assessed using GreenScreen Benchmark assessment. No Benchmark 1 hazards (BM-1) are present in the end use product. The remaining 5% by weight of product not assessed has been inventoried and screened using GreenScreen List Translator and no GreenScreen LT-1 hazards are present in the end use product.
Bottom Line: Building product manufacturers should consider getting their HPDs verified to obtain an additional half point for their products. If your competitors only have HPDs, then a verified HPD gives you an advantage in the marketplace.
HPDC Approved Preparer
Within the HPD Open Standard in section 126.96.36.199 Preparer, manufacturers need to list if the HPD was prepared by the product manufacturer or a third-party organization; the manufacturer is responsible for the content in both cases. If the HPD is prepared by the product manufacturer, “Self-prepared” is inserted; if the HPD is prepared by a third party, the name of the organization is inserted.
An HPDC Approved Preparer helps the product manufacturer develop the HPD by providing technical expertise to execute the HPD as accurately and efficiently as possible. HPDC Approved Preparers can help with obtaining content information from suppliers, through independent Non-Disclosure Agreements (NDAs), when suppliers are reluctant to directly share the necessary information with manufacturers. This is a common issue and Preparers can typically navigate these complexities to help manufacturers complete their HPDs.
An HPD is considered self-published, and of equal validity, with or without the help of an HPDC approved preparer. However, an HPDC Approved Preparer can help a manufacturer increase their chances of publishing a “LEED compliant” HPD. Many manufacturers are unfamiliar with how to accurately complete an HPD, what red flags to avoid, and how to meet the LEED requirements.
Key aspects of the HPD Preparation process and how HPDC Preparers can help:
- The HPD was prepared in accordance with the HPD Open Standard
- The non-disclosed proprietary information the preparer has obtained is accurately represented
- An HPD Preparer can coordinate with an HPDC Approved Third-party Verifier to ensure an efficient verification process
Bottomline: Building product manufacturers should consider hiring an HPDC Approved Preparer to develop a “LEED compliant” HPD. In addition, an HPDC Approved Preparer provides a streamlined efficient option when many manufacturers don’t have the time or resources to tackle this type of project. Working with complicated building products with multiple chemical ingredients can be difficult and an HPDC Approved Preparer with a hard science background greatly helps.
HPD Open Standard Dates
In section 2.1.6 Preparation, Verification, and Publication, there are numerous dates to be completed by product manufacturers. The primary dates to complete are screening date, published date, expiry date, and archive date. The Screening Date indicates the date of the final screening for all substances listed in the HPD against the HPD Priority Hazard Lists to identify warnings reported in the HPD. If the HPD incorporates multiple screening dates, for example because the HPD relies on data screened by suppliers, the earliest of the screening dates must be reflected.
The Published Date must be the date when the HPD is approved for compliance with the HPDC Quality Control Protocol and Procedure for Published and published in the HPD Public Repository. The Expiry Date is the expiration date for the HPD. Finally, the Archive Date is the date the HPD was replaced by a more recent issuance. If the HPD is updated and republished, creating Issuance #2 or later, the HPD that is replaced is archived in the HPD Public Repository.
Overall, building product manufacturers should consider the advantages of hiring an HPDC Approved Preparer and/or HPDC Approved Third-Party Verifier. Most building product manufacturers develop HPDs to meet the LEED v4 MR Credit: Building product disclosure and optimization – material ingredients. Hiring professionals ensures a smooth and efficient process. ▪