By Tristan Roberts, HPDC, Director of Technical and Education Programs
The HPD Open Standard is a standard specification for the accurate, reliable and consistent reporting of building product contents and associated health information.
The HPD Collaborative is engaged in an ongoing process of continuous improvement of the HPD Open Standard—in fact, we just released HPD v2.2 with important supply chain innovations!
A key area for development of the HPD is Special Conditions. These are classes of materials where the typical HPD process for inventorying ingredients and providing heath data requires some modification. For example, with mixed recycled content (think post-consumer plastic, for example), the level of variation in the substances present, and the lack of data that a manufacturer might have on that, make it difficult to follow typical HPD processes. HPD’s policy for mixed recycled content, among several other materials, was developed to accommodate this.
Another area HPDC’s staff and technical committees are working on is form-specific hazards—and we are seeking your input.
With a form-specific hazard, the mechanism of the toxicity is directly caused by the physical form of the substance rather than its chemical composition. Specifically, this HPDC policy has focused on particles of respirable size, i.e., dust. These substances come with health hazard warnings, which are associated with their particle size. However, if the particle sizes are not respirable or if particles are embedded in a bulkier material (like a building product), no risk of adverse effects is expected to the building occupant.
There are three substances that have been on the minds of our Technical Sub-Group (TSG) as we’ve developed this policy. These substances appear in hundreds of building products, from paint to wallboard to joint compound. They are:
- Carbon black (CAS RN 1333-86-4)
- Crystalline silica (CAS RN 14808-60-7)
- Titanium dioxide (CAS RN 13463-67-7)
These substances exhibit hazards in their dust form, due to dangers of inhalation, but when incorporated in a product such as paint, the inhalation danger is not relevant, except during installation and demolition.
Substances sold as liquids or non-powder solids, for example, paints, joint compounds, abrasives, and fillers, may qualify for this Special Condition provided that the substance does not volatilize, leach, emit, or abrade from the liquid or bulk material in the particle size and physical form of concern in normal use during the occupancy of the building. Manufacturers are required to provide a statement describing compliance with this policy.
HPDC is developing a modified version of the HPD content inventory and hazard screening system to more accurately characterize health information for products that meet these requirements.
HPDC would also like your input. Whether as a manufacturer or as someone who uses HPDs, are there other substances you work with or encounter that you think may also fall under this policy? Please take this brief survey to give your feedback.
The development of this policy has focused on dust hazards. However, we are aware that there may be other substances with other exposure routes that may also match the overall intent of this policy.
We are also developing specific policies for ceramics, polymers, float glass, and metal alloys, and some of the same issues come up with some of these materials. We also welcome your input on these materials, or any other issues.
That’s not all! HPDC is reviewing published Best Practices on considering residuals and impurities, and other Special Conditions. If you have reviewed or used this guidance, we would love your input!
These policies are actively being developed. To ensure that your input is considered in this round, please complete the survey by June 15, 2019. Thank you!
Tristan Roberts is Director of Technical and Education Programs for HPDC. You can reach him with comments and feedback at troberts@hpd-collaborative.org.