Health Product Declarations
Essential to Your Bottom Line
Robert Niven & Christie Gamble
The material manufacturing community is embracing transparency. Manufacturers are experiencing demand for documentation that discloses the environmental footprint of their products, with buzz words such as creating a PCR to conducting LCA in order to publish an EPD popping up left, right and center. But have you heard about that other three-letter acronym that’s becoming all the rage: the HPD?
An HPD, otherwise known as a Health Product Declaration, is a material transparency document that discloses any health hazards that may be associated with chemical constituents contained within a building product. Like the EPD – Environmental Product Declaration – demand for this document is being promoted through programs such as LEED version 4 and by a group of cutting-edge architectural firms paving the way in material selection based on transparency.
Affecting Product Sourcing Masonry manufacturers may have already been on the receiving end of requests to provide HPD for products, depending upon location. The HPD trend has especially caught on in major metro centers such as Chicago and Washington DC, thanks to a core group of sustainably-minded leaders in the architectural industry. Those who do not happen to be located in one of the greener cities may still have heard rumblings about how LEED is changing. It is going to affect the way the design community sources products.
Simple and Inexpensive If you are feeling overwhelmed by the changing landscape and the demand to create all these transparency documents – EPD, HPD, Declare, Cradle2Cradle to name a few – don’t worry, you are not alone! If you have been keeping up with discussions on EPD, you will know that to create an Environmental Product Declaration (EPD), you need to conduct a Life Cycle Assessment (LCA) based upon a Product Category Rule (PCR) that was developed through the industry in compliance with ISO standards. While an EPD measures environ mental impacts (such as CO2 emissions and water usage), the HPD discloses potential health hazards found in materials that compose a product (such as carcinogens and toxins). Compared to the EPD, creating an HPD is a relatively simple and inexpensive process.
CarbonCure Technologies is helping the concrete industry connect with the sustainable design community. Proprietary technology installed in existing concrete masonry production facilities upcycles waste carbon dioxide from postindustrial smokestacks into concrete products, resulting in greener, stronger concrete. Producer partners respond to material transparency demands by creating an EPD and HPD for any products made with this technology.
In partnership with Northfield, an Oldcastle company serving the greater Chicago market, CarbonCure published the concrete industry’s first HPD. CarbonCure team members are also actively engaged in the HPD Manufacturer’s Advisory Panel, which assists in the development of HPD version 2.0. While the process of creating an HPD was daunting and confusing at first, we discovered that it’s really straightforward to create an HPD for most masonry products. We are willing to share lessons learned.
The HPD is a standardized document develop ed by an independent nonprofit known as the Health Product Declaration Collaborative(hpdcollaborative.org). The HPD Collaborative seeks to make the process of creating and publishing an HPD as simple and streamlined as possible. The easiest way to create an HPD is to use the free HPD online tool on the HPD Collaborative website. The HPD Collaborative is supported by sponsors and members from manufacturing and design firms.
HPD Process After subscribing to the HPD online tool, begin collecting data. Essentially, the goal is to identify every possible ingredient that is present in products in order to determine whether there are any health hazards associated with those ingredients. Start by creating a simple spreadsheet of the materials and their respective amounts that go into the mix design. A materials list for concrete masonry might look something like this: cement, a few aggregates, perhaps an admixture or two and possibly a sealant. Identify which ingredients make up each item in the mix design.
Often, the best place to begin is with material supplier sales representatives. Request any/all information they may have on the ingredients that comprise their material. Reps should be able to provide documents such as Material Safety Data Sheet (MSDS) sheets, Material Inventory Reports, or Mill reports, and more. Internal testing can deter mine or verify raw ingredients and residuals.
Once a mix design is broken down into raw materials, conduct some simple computing to determine the relative proportion of each raw material to the overall mix. Using concrete masonry as an example, let’s say that calcium oxide is 20% of the cement and the cement is 10% of the overall mix; a quick calculation (20% x 10%) indicates that calcium oxide is 2% of the overall mix. All raw materials added together should equal 100%.
Good news – the rest is easy. Simply enter the requested information into the HPD tool. At the ingredient disclosure section, add each ingredient by searching for the material in the ingredient input section. Determining the CAS Registry number – a standardized identification number – for each ingredient makes this process easier. For example, calcium oxide has a CAS number of 1305-78-8, which can easily be identified by web-searching calcium oxide CAS.
When ingredients are entered into the HPD tool, it will instantaneously search multiple authoritative hazard lists from around the globe to determine whether the ingredient has any hazardous properties associated with it. Any hazards found will automatically be populated into the final HPD report.
Proprietary Issues and Legal Implications Under stand – ably, publishing a document that discloses the product’s precise mix design may cause concern. Fortunately, there are two ways in which the HPD mitigates that risk. First, only raw materials – such as calcium oxide or shale – are listed. There is no mention of specific brands. Secondly, the HPD allows manufacturers to disclose ingredient quantities in a range. Rather than stating that a mix is composed of 2% calcium oxide for example, it may be stated that the mix is composed of 1-10% calcium oxide.
Additionally, manufacturers have the choice to determine how deep to disclose. They may mask proprietary ingredients (so that the ingredient is screened against hazards but not identified) or list undisclosed content. This may prevent the HPD from being considered fully disclosed but is an acceptable use of the format.
Legal implications related to the HPD is a new and evolving area, so it is difficult to make definitive statements. Companies’ legal counsel have, at times, provided differing guidance. However there is quite a bit of precedent to point to, according to Donald Simon, lawyer with expertise who is helping HPD Collaborative under stand the issues for manufacturers.Manufacturer liability is most commonly based on the law of product liability and, more specifically, a failure to adequately warn of known risks associated with using the manufacturer’s product.
An HPD does not address product-level risk so it is not expected to affect manufacturer liability. Instead, an HPD discloses risks associated with product ingredients. The law assumes manufacturers know that information, so disclosing it will not increase their liability unless the information is inaccurate or misleading in a way that would cause a reasonable person to under-appreciate a known risk associated with using the product. If anything, an HPD might help reduce manufacturer liability by showing the manufacturer disclosed what it knew. Regardless of whether an HPD is issued, manufacturers rarely face claims related to the health impacts of building products because of the difficulty linking any specific illness to a specific product, except in the rare situation such as asbestos where an illness is tied exclusively to a specific product.
Both the manufacturer and consumer need to consider that the presence of a hazard is not a black or white scenario. Humans make risk assessments every day to determine how much exposure of a hazard they are comfort – able with. For example, ethyl alcohol is consider ed a BM1 category hazard (the most hazardous), yet many choose to drink a pint of beer thinking that it isn’t harmful (or at the very least, is worth the risk!). Similarly, the degree to which a person may be affected by a hazard in a building material depends on the level of exposure and on the usage or state of the building material itself. The HPD allows a manufacturer to add notes and disclosures that may explain hazar dous situations and reduce concern.
Competitive AdvantageAt the end of the day, you may be wondering whether issuing an HPD or other material transparency document is worth it. Could this be just a trend that passes through until the next new buzz word in sustainable design arrives? Those who decide to wait it out and see what happens may find they have put their company at serious risk of losing business to not only other masonry manufacturers, but also potentially other building materials.
Alternatively, manufacturers who differentiate themselves and act first to disclose health and environmental impacts may improve their relationships with developers, architects and specifiers. Some manufacturers who have published an HPD have begun seeking alternative manufacturing methodologies to improve the health profile of their products. Not only could this pursuit of innovation improve the health quality of the product itself, but it may also give the manufacturer a significant competitive advantage down the road.
LEED version 4 (v4) was officially released in November 2013. In the period between November 2013 and October 2016, new LEED projects have the option to submit under version 3 (known as LEED 2009) or v4. After October 2016, all new LEED projects must be submitted under v4. LEED v4 awards points for HPD- and EPD-issued products. Because of this demand, manufacturers who do not have the HPD and EPD available risk losing LEED projects to competitors who have issued the documents. Considering that the green building market is expected to make up 55% of the overall construction market by 2016, that’s a significant potential loss.
Material Selection Based on Transparent Disclosure A growing number of architectural firms are demanding the HPD from manufacturers, regardless of whether the project is seeking LEED certification. Industry leaders including Cannon Design, Perkins + Will, HDR and SmithGroupJJR have issued letters stating a timeframe after which only products with product content transparency will be allowed in the firm’s library and selected for inclusion on projects.
Rand Ekman, Vice President and Director of Sustainability at Cannon Design, reinforces the importance for masonry manufacturers to issue the HPD. “Cannon Design is committed to selecting materials that provide transparent information on matters related to human health and environmental impact. We not only encourage manufacturers to publish HPD, masonry included, we are developing a program to enable our designers to compare manufacturers and to purposefully select products from those who do have publicly available HPD and EPD,” Ekman declares.
With industry leaders committed to the cause, it looks like the HPD is here to stay. And now that we have hopefully demystified the process, there’s no reason for producers not to jump in feet first and create the HPD! Who knows, you may just find that your efforts will reward you with a reputation as a leader in sustainability and transparency in your region. As we all know in this industry, a little competitive edge can go a long way to improving the bottom line.
Robert Niven, is a cleantech entrepreneur inspired to find profitable and sustainable solutions for the cement and concrete sectors. He is part of the global race to develop affordable carbonnegative concrete at scale. As Founder and CEO of cleantech developer, CarbonCure Technologies, Niven has earned a reputation of uncovering innovative ways to raise profits, lower greenhouse gases and improve the material performance of concrete. His passion for developing solutions that combine sustainability and innovation has led to the development of the CarbonCure technology. He holds an MSc in Environmental Engineering from McGill University and a BSc in Chemistry from the University of Victoria. 902.442.4020 | firstname.lastname@example.org
Christie Gamble, LEED Green Associate, is sustain ability director at CarbonCure Technologies. Her mission is to educate and engage the design and development community around CarbonCure’s efforts to improve sustainability in the concrete industry. Gamble promotes trans par ency through the creation of Environmental Product Declarations (EPD) and the HPD for CarbonCure’s manufacturing partners. She is a LEED Green Associate and an active member of the HPD Manufacturers Advisory Panel developing HPD version 2.0. She earned a Bachelor of Arts from McGill University and MBA from Dalhousie University. 902.442.4020 email@example.com