Introducing
Declarations
New Tool Facilitates Informed Choices in Building Design
BY CATHERINE BOBENHAUSEN, JOEL ANN TODD, AND WENDY VITTORI
Health Product
The Health Product Declaration (HPD) Open Standard is a leading tool for reporting and disclosing the contents of building products and associated health information. Akin to, but more detailed and comprehensive than, a Safety Data Sheet (SDS), the HPD helps architects and building design teams make informed choices and avoid inherent chemical hazards. By providing for a single reporting standard that is open for everyone to use, it also reduces the burden for manufacturers, who to date have been fielding a host of unique requests from designers regarding the composition of their products.
As of November 1, design teams pursuing LEED certification for their new buildings will register them under LEEDv4, which rewards (but doesn’t mandate) selecting products whose manufacturers have publicly available HPDs. HPDs are also recognized in Google’s Healthy Materials Program’s Portico database, in the DELOS WELL Building Feature 97, and other similar tools.
The HPD initiative is managed and supported by the HPD Collaborative (HPDC), a nonprofit member organization representing a broad cross-section of building industry participants. HPDC collaborates with organizations such as Clean Production Action, Healthy Building Network, the International Living Future Institute (ILFI), and the Cradle to Cradle Products Innovation Institute (C2CPII). HPD reports can feed into Google’s Portico tool and Cradle to Cradle assessments, and can also provide inventory to support ILFI’s Declare labels.
Completing an HPD is the first step in subsequent product assessment and optimization efforts. The long-term goal is to spur building owners and designers to work with manufacturers to help our industry develop more products, and to know more about the materials used in the products they specify. As they become more informed, product specifiers and buyers will be better able to find products with reduced chemical footprints that have equal or better performance. Witness PROSOCO, the waterproofing manufacturer, which developed phthalate-free coatings first for the Bullitt Center in Seattle, a Living Building Challenge project, and has gone on to make this safer formulation standard in its product lines. HPD VS. SDS An SDS is a document that provides information on the properties of specific types of hazardous chemicals and how they affect health and safety in the workplace, consistent with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS). For chemical manufacturers and importers based in the United States, OSHA’s hazard communication standard requires SDSs to report potential hazardous chemicals present at or above specific cut-off values or concentrations. The reporting threshold for reproductive toxicants, carcinogens, and category 1 mutagens is 1,000 ppm. For all other hazard categories, the threshold is 10,000 ppm.
For these chemicals, SDSs list key employee-relevant data such as physical and chemical properties, safe handling and storage, incompatibilities, stability/reactivity, first aid, and measures for fighting fires and responding to accidental releases.
By comparison, HPDs go beyond the workplace to provide a more comprehensive understanding of a product’s health attributes. The HPD Open Standard development process is relatively flexible and can incorporate current information. The process enables users of HPDs to have a constructive dialogue with manufacturers about their needs for information and how these can be best reflected in HPDs. As a voluntary standard, HPDs allow manufacturers to disclose information to the level they choose or based on the information they have, ranging from minimal requirements to full disclosure and transparency. Some areas in which the information in HPDs goes beyond SDSs include items of particular interest to designers, such as VOC emissions from the finished product, whether ultra-low VOC tints are available (for paints, for example), whether nanomaterials are in the product, the presence of recycled content, and how the product’s contents have scored on hazard assessments.
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While SDSs require disclosure only of contents that meet certain hazard and threshold requirements, HPDs require basic characterization of all contents, encouraging and supporting disclosure down to 100 ppm of each material.
The HPD Open Standard defines the HPD’s six sections. The Summary section highlights the product’s contents, their hazards, and key reporting elements such as thresholds per material, as decided by the manufacturer. For example, manufacturers can choose to report contents at concentrations down to a specific level (100 ppm or 1,000 ppm), per GHS SDS, or according to other criteria.
The second section, Content in Descending Order of Quantity, is the heart of the HPD report. It inventories the contents in the product, their associated hazards based on assessments, and other relevant information.
Other sections include Certifications and Compliance, which indicates, for example, VOC content and emissions certification; Accessories, which explains what’s needed to install or maintain the product; General Notes, which provides explanations and commentary from the manufacturer, including exposure and risk assessment statements; and References, which incorporates information such as links to hazard lists used in the HPD report.
While SDSs require disclosure only of contents that meet certain hazard and threshold requirements, HPDs require basic characterization of all contents, encouraging and supporting disclosure down to 100 ppm of each material for all contents. While the substance ID may be withheld for some proprietary contents, the role, percentage, hazards, and other characteristics are still required.
An important distinction is that SDSs are not required for items that are “articles.” As defined by 29 CFR 1910.1200(c), an article is a manufactured item whose function is based in whole or in part on its specific shape or design, and which, under normal conditions of use, doesn’t release more than minute or trace amounts of a hazardous chemical or pose a physical hazard or health risk to employees. By contrast, HPDs represent voluntary content disclosure for what would be, in SDS parlance, an article. One HPD can conceivably cover product assemblies composed of hundreds of substances, coatings, and fastening systems generated by multiple suppliers. UNDER THE HOOD The HPD Open Standard is a publicly available, voluntary technical specification that references standard definitions and nomenclature from the European Chemicals Agency (ECHA), the Restriction of Hazardous Substances Directive (RoHS), and the International Union of Pure and Applied Chemistry (IUPAC). The standard requires disclosure of the role, percentage, and health hazards associated with all contents at the selected threshold of reporting.
HPDs make use of “GreenScreen for Safer Chemicals Hazard Assessment Guidance,” a project of the organization Clean Production Action. GreenScreen, which references revision 4 of GHS, evolved from work on EPA’s Design for the Environment (DfE) program. The HPD Open Standard identifies a minimum set of “Priority Hazard Lists” against which contents are required to be screened for health and environmental hazards. These lists are primarily based on criteria developed for GreenScreen.
HPDs report chemical-specific results of two types of hazard assessments: the GreenScreen List Translator and the GreenScreen full assessment. The List Translator is a streamlined approach to hazard assessment that characterizes hazards for substances based on whether they appear on authoritative and screening lists. The full assessment is a more advanced, comprehensive review of all available information, including measured data from toxicological studies in the scientific literature, estimated data from suitable analogs and models, and hazard lists. Full assessments are ultimately used in generating a final GreenScreen Benchmark Score. The Benchmark classifications have the following implications for decision making:
  • Benchmark 1: avoid, chemical of high concern
  • Benchmark 2: use, but search for safer substitutes
  • Benchmark 3: use, but still opportunity for improvement
  • Benchmark 4: prefer, safer chemical
Additionally, there is BM-U, which is “Benchmark Unspecified.” This is due to insufficient data.
Even though advanced and useful in making informed decisions, the GreenScreen Benchmark score for a chemical is still a high-level indicator of hazard. A fuller understanding of the specific hazards associated with the chemical requires input from an industrial hygienist or toxicologist. A Benchmark Score must be used in conjunction with all available information, full documentation, and in consideration of other variables such as exposure pathways to workers, users, recyclers, and the environment.
There are only three possible GreenScreen List Translator scores, each of which relates to GreenScreen Benchmarks. A score of LT-1 (likely Benchmark 1) means there is clear agreement among authoritative lists that the substance is a chemical of high concern and may be considered equivalent to a GreenScreen Benchmark 1. Chemical hazard ratings that are based on a specific (for example, respirable) form can be resolved for exceptions (for example, non-particle forms) by using the GreenScreen full assessment.
A score of LT-P1 (possible Benchmark 1) frequently means that the chemical appears on a list that does not translate directly to a single Benchmark score, and that Benchmark 1 is included in the range of possible Benchmark scores.
A score of LT-UNK (unknown Benchmark) indicates that a chemical is present on a GreenScreen Specified List but there is insufficient information to classify the hazard as LT-1 or LT-P1. This does not mean that the substance is without hazards. It might represent a moderate hazard; alternatively, it might represent a high hazard but only for a health impact that doesn’t automatically rate a Benchmark 1. (The effects that automatically generate a GreenScreen Benchmark 1 are cancer, mutagenicity, endocrine activity, and reproductive or developmental toxicity.) An LT-UNK score might also mean simply that the chemical has not yet been well tested and scrutinized by the authoritative listing agencies. This score should be considered an indication that the substance warrants a full assessment.

An additional designation in the HPD, “NoGS,” indicates that the chemical isn’t identified on any GreenScreen List Translator lists. Again, lack of listing does not indicate that the chemical is safe.

Where to Find HPDs Just as with SDSs, manufacturers retain HPDs on their websites, the logical first place to find them. The HPD Public Repository, introduced in October 2016, is the authoritative source for HPD reports that have been made public. HPD reports included in the HPDC Repository are not reviewed or verified by HPDC. The HPDC Repository is open and free of charge.
Prior to the launch of the HPD Public Repository, the HPD Library developed by SmithGroupJJR had served the industry as the largest publicly accessible collection of HPDs. It is continuing as a complementary resource that will draw upon the HPDs in the Repository and provide additional analysis and decision-support features that are useful to product selection and specification activities.
BuildingGreen’s Designer Pages contains collections of HPD reports, including both LEEDv4-compliant and non-compliant reports as determined by BuildingGreen. They are available to BuildingGreen members.
Mindful Materials, created by HKS Architects, provides information about product contents where designers search for it most often: on resource library shelves. It has expanded to a repository for HPD reports and other disclosure information.
THE INDUSTRIAL HYGIENIST’S ROLE In the process of completing HPDs, industrial hygienists can support manufacturers by engaging in discussion with upstream suppliers and raw materials suppliers, first discovering, then helping reduce and eliminate, chemicals with known hazards, or finding alternatives with safer profiles. This exploration can lead to internal discussions with chemists in the R&D department. Industrial hygienists can introduce chemists to the proactive approach outlined in California’s Safer Consumer Product legislation, which asks whether a particular chemical is necessary, whether a safer alternative exists, and whether regrettable substitutes have been avoided.
Industrial hygienists can also integrate insight from HPDs and all of the customary tools of their profession, including SDSs, which provide other helpful information such as vapor pressure, odor threshold, GHS classifications, exposure thresholds, and safe handling for field-applied products, as well as the emissions test reports referenced in the HPD. Working with the client owner and design team, industrial hygienists can reach out to manufacturers to express the client’s goals and discuss plans for innovative products. Industrial hygienists are the liaison with the manufacturer’s environmental health and safety, regulatory affairs, and R&D departments, delving into the composition of building materials and assemblies, internal testing and reporting methods, and options for inherently safer material choices.
Often, clients or design teams will have policies related to acquiring HPDs from manufacturers and implementing preferences for manufacturers that participate in transparency and disclosure programs. HPDs are a good foundation for addressing the health-related attributes of products directly with product manufacturers. HPD reports provide a common language and database of information to support these discussions, and industrial hygienists can help address specific chemical issues on behalf of their client or design team. The HPD Collaborative’s recently released “The Health Product Declaration Project Team User Guide” offers practical information to the design community on how to use HPDs. DISCLOSURE VS. OPTIMIZATION Industrial hygienists must also understand the market drivers for these documents. For example, in LEEDv4, HPDs can be used for either disclosure or optimization. For LEEDv4 Material Ingredient Reporting, the project must use at least 20 different permanently installed products from at least five different manufacturers, and the end-use product must have a published, complete HPD with full disclosure of known hazards in compliance with the HPD Open Standard.
For a project to meet LEEDv4 Material Ingredient Optimization, products that have fully inventoried chemical contents to 100 ppm and no Benchmark 1 hazards must account for at least 25 percent of the total value of permanently installed products. If any contents are assessed with the GreenScreen List Translator, these products are valued at 100 percent of cost, and if all contents have undergone a full GreenScreen assessment, these products are valued at 150 percent of cost.
Keep in mind that LEEDv4 supports public disclosure of HPDs. Sometimes product manufacturers are constrained in disclosing product contents by supplier contracts that either do not provide this information or do not allow for disclosure. The HPD Open Standard provides a method to create and use HPD reports in this circumstance. If concerns are raised about non-disclosure agreements (NDA) or proprietary formulas, contents can be declared proprietary and the substance name/CAS RN can remain undisclosed as long as role, amount, and hazards are disclosed. This type of disclosure will also be accepted by the LEEDv4 Material Ingredients credit.
The industrial hygienist’s role in this LEEDv4 process is technical and supportive of design teams and clients, who are often unfamiliar with the nuances of chemistry and toxicology. Most of the HPDs on the market today are targeted toward the Material Ingredient Reporting part of the LEEDv4 credit, with incremental progress towards Material Ingredient Optimization. It is in this middle ground that the industrial hygienist’s perspective can be helpful in comparing product attributes. CATHERINE BOBENHAUSEN, Authorized GreenScreen Practitioner, is senior industrial hygienist with Vidaris, Inc. and a Health Product Declaration Collaborative Technical Committee member. She can be reached at cbobenhausen@vidaris.com. JOEL ANN TODD is the director of Technical and Education Programs of the Health Product Declaration Collaborative. She can be reached at jtodd@hpd-collaborative.org. WENDY VITTORI is the executive director of the Health Product Declaration Collaborative. She can be reached at wdvittori@hpd-collaborative.org.
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Although the print version of The Synergist indicated The IAQ Investigator's Guide, 3rd edition, was already published, it isn't quite ready yet. We will be sure to let readers know when the Guide is available for purchase in the AIHA Marketplace.
 
My apologies for the error.
 
- Ed Rutkowski, Synergist editor
Disadvantages of being unacclimatized:
  • Readily show signs of heat stress when exposed to hot environments.
  • Difficulty replacing all of the water lost in sweat.
  • Failure to replace the water lost will slow or prevent acclimatization.
Benefits of acclimatization:
  • Increased sweating efficiency (earlier onset of sweating, greater sweat production, and reduced electrolyte loss in sweat).
  • Stabilization of the circulation.
  • Work is performed with lower core temperature and heart rate.
  • Increased skin blood flow at a given core temperature.
Acclimatization plan:
  • Gradually increase exposure time in hot environmental conditions over a period of 7 to 14 days.
  • For new workers, the schedule should be no more than 20% of the usual duration of work in the hot environment on day 1 and a no more than 20% increase on each additional day.
  • For workers who have had previous experience with the job, the acclimatization regimen should be no more than 50% of the usual duration of work in the hot environment on day 1, 60% on day 2, 80% on day 3, and 100% on day 4.
  • The time required for non–physically fit individuals to develop acclimatization is about 50% greater than for the physically fit.
Level of acclimatization:
  • Relative to the initial level of physical fitness and the total heat stress experienced by the individual.
Maintaining acclimatization:
  • Can be maintained for a few days of non-heat exposure.
  • Absence from work in the heat for a week or more results in a significant loss in the beneficial adaptations leading to an increase likelihood of acute dehydration, illness, or fatigue.
  • Can be regained in 2 to 3 days upon return to a hot job.
  • Appears to be better maintained by those who are physically fit.
  • Seasonal shifts in temperatures may result in difficulties.
  • Working in hot, humid environments provides adaptive benefits that also apply in hot, desert environments, and vice versa.
  • Air conditioning will not affect acclimatization.
Acclimatization in Workers