How are residuals and impurities treated in HPD 2.0 vs. HPD 1.0?
HPD 1.0 required disclosure of all intentionally added ingredients. In HPD 1.0, the manufacturer selected a threshold for disclosure of residuals and impurities. The thresholds allowed were: measured to 100 ppm, measured to 1000 ppm, reported by suppliers on MSDS, predicted from process chemistry, and other. Only residuals that trigger a GreenScreen Benchmark 1 or Possible Benchmark 1 had to be disclosed.
Manufacturers reported problems and some confusion with these requirements in HPD 1.0. Some thought the thresholds applied to intentionally added ingredients as well as residuals. Further, methods for measuring residuals are not fully developed and vary across industries, so this requirement was difficult to achieve.
HPD 2.0 addresses these issues and revises the way intentionally added ingredients and residuals are reported.
In HPD 2.0, manufacturers must report whether residuals and impurities are considered for the material and included in the inventory. Options are either “Considered” or “Not Considered.” When Residuals/Impurities are “Considered,” the manufacturer has taken steps to understand what residuals and impurities may be present in the material and disclose that information on the HPD. The term “Considered” is used, rather than “Included,” to address currently unavoidable variability in methodology and rigor due to industry sector differences in knowledge about residuals and impurities in materials used. Whether “Considered” or “Not Considered” is indicated, an explanation must be provided as described in the HPD Open Standard instructions [see section 220.127.116.11 Residuals/ Impurities in the HPD Open Standard, September 10, 2015 for more detailed information].
In HPD 2.0 all materials must be reported and substances within materials must be reported based on thresholds. The thresholds in HPD 2.0 do not apply to residuals and impurities. The manufacturer sets a threshold for reporting of substances within each material; substances above the threshold must be reported [see section 18.104.22.168 in the HPD Open Standard, September 15, 2015]. The exception to this is the Basic Inventory, in which a threshold is set for the entire product and substances above that threshold must be listed [see section 3.6 in the HPD Open Standard, September 10, 2015].