CHAPTER 3

Chapter 3.0 Creating an HPD–Process Recommendations

This chapter of the Guide outlines a process that you can use as the basis for organizing the tasks involved in creating an HPD. This is only a suggestion and each HPD and manufacturer is different. Since the understanding of these process steps is evolving, this Guide provides an overview and a link to the HPDC website where this growing body of knowledge will able to evolve.

3.1   Overview of the Process

Each manufacturer will use different methods, based on the product and processes used to create it. The process outlined below and in this chapter provides general guidelines to be modified and expanded as needed.

3.2   Getting Started – Initial Decisions

If you are already creating and publishing HPDs for your products – congratulations on participating in disclosure, transparency, and the movement toward healthier products and projects! 

If you are still wondering whether to create HPDs for your products, consider these benefits:

• Many leading architecture firms and influential owners now require material disclosure for products prior to considering them for inclusion in their libraries and projects. HPDs provide a format for disclosure directly or for providing data to other reporting tools.
• HPDs are used by projects to achieve LEED material disclosure and optimization credits – your product will stand out if it has a LEED-compliant HPD.
• HPDs are used to document WELL and Living Building Challenge projects and can exchange data with the Declare program, Portico, and Cradle to Cradle. You can save significant time, energy and money by documenting data with the HPD for use in these other reporting tools.
• Consumer demand for ingredient information is increasing across a wide range of consumer products. Some home improvement stores are prohibiting specific chemicals in specific products in reaction to these trends. HPDs provide a means for reporting this information.
• The information gathered for your HPD can help you get out ahead of future risks. You can identify ingredients that could prove problematic in the future and start now to design them out or to find alternatives. Given some lead time, you can seek suppliers that offer more acceptable alternatives or encourage them to develop such alternatives.
• It’s the right thing to do. Taking the first step toward learning about potential hazards in your ingredients, by creating HPDs, is a first step in seeking safer alternatives and improving your products and making them more attractive to those that specify or purchase them.

Now that you have decided to create an HPD, how do you get started? There are a few initial decisions that are necessary.

Decide whether to create your HPD in-house or with a consultant

The HPD Open Standard was designed to be usable by manufacturers, without requiring you to hire outside consultants. In some cases, though, it makes sense to get help. There are third party preparers who are recognized by HPDC and can be depended upon to provide quality services; there are other consultants as well who offer these services. Here are a few questions to help you think about this issue:

• Do you have an employee who has time to devote to this effort? For a simple product with a small and cooperative supply chain, an HPD can be created fairly quickly. However, if all of your employees are already very busy, you might not be able to support the effort in-house.
• How quickly do you need to get the HPD created? Are there project teams demanding an HPD now for a project submittal? Can you fit this into your regular workload and still meet these requests?
• Do the available employees have the needed expertise and knowledge of the product to enable them to gather and process the data accurately? Are they familiar with suppliers and can they work effectively with them if data must be requested from them?
• Do you want to devote staff time to learning about HPDs as an investment in creating future HPDs? Or, if it’s unlikely that additional HPDs will be created, does this investment still make sense?
• How complex – and known to you – is your supply chain? For complex products there can be a multi-tiered, complicated supply chain that you will need to work with to determine the contents of your products at the level of homogeneous materials and/or substances. This information generally is not the same as what is in your Bill of Materials (BOM) for the product. The work required to complete an HPD will vary significantly, based on these variables.
• Finally, do you have suppliers that will not release information to you about ingredients? If so, a third party working under a Non-Disclosure Agreement might be an effective way to obtain that data and enable you to create a LEED-compliant HPD. LEED allows withholding of the name and identifier of proprietary ingredients, as long as they are characterized (role and amount in the product) and screened for hazards. Third party preparers can arrange this.

You can revisit this decision as the work on the HPD progresses. At any point, you may decide that a consultant would be helpful in:

• Scoping the HPD
• Planning and organizing data collection
• Approaching suppliers
• Evaluating data received from suppliers
• Other tasks involved in creating an HPD.

Determine disclosure goals or requirements

Why are you creating this HPD? How will it be used? Are there outside requirements it must meet? The answers will help you make important decisions. Here are a few reasons for creating HPDs:

• Your company supports disclosure and transparency and wants to demonstrate leadership by providing the information that you have available.
• Your company wants to market its products as compliant with LEED, WELL, Portico, etc. In this case, you need to be very familiar with the requirements of these programs. The HPDC website has guidance for using HPDs in various systems. This guidance was developed in collaboration with the sponsors of these systems – USGBC, GBCI, International WELL Building Institute, Google, and so forth. This guidance is updated as the programs evolve.
• Your company plans to pursue Declare labels or Cradle to Cradle certification and wants to avoid redundant forms for data submittal. The HPD Open Standard was developed with the Harmonization Task Group and continues to strive for harmonization with all potential users of HPD data. Your company can complete an HPD and can share the data automatically with several other programs, saving you time, money, and potential errors.

As work progresses on your HPD, you might find that you have to revise your goals. For example, you might learn that your product cannot meet the LEED Material Ingredients credit Option 2, which requires inventory reported to 100 ppm and no GreenScreen Benchmark-1 or List Translator-1 scores. But, the product could still qualify under Option 1, which rewards disclosure rather than optimization.

Decide on inventory method and threshold

Early in the process, you will need to decide on what inventory method and threshold(s) to use. As described earlier in this Guide, there are three methods for creating an HPD inventory:  Nested Materials Inventory with Material-level Thresholds, Nested Materials Inventory with Product-Level Threshold, and Basic Inventory Method. Once you select a method and start creating your HPD in the HPD Builder, you will not be able to change to another method.

Each approach has advantages. Advantages of Nested Materials Inventories include:

• Allows supplier data to be updated without changing the entire HPD.
• For products with many variations, you can switch out just the component that changes without requiring recalculation of the entire HPD.
• For complex products that you assemble, you can build the HPD component by component from supplier data.
• Identifies the specific material(s) that contain hazards so alternatives can be sought.
• More closely matches your existing ordering and recordkeeping systems.
• Nested inventories with material-level thresholds provide the most rigorous reporting.

The advantages of Basic Inventories include:

• Easy for simple products with few ingredients.
• Enables you to avoid reporting small quantities of substances that would be required under material-level thresholds.

3.3   Gathering Data

The HPD contains information on the contents of your product “as it is delivered to the job site.” 

• In some cases, for fairly simple products, this information may be found on a Bill of Materials (BOM).
• In many other cases, homogeneous materials and/or substances, which are the reported in an HPD, are lower level inputs into the materials in your product BOM. So, you will need to gather this information from your supply chain rather than your direct suppliers.
• Another consideration in gathering data for your HPD is whether the inputs (which are reported on a BOM) are transformed at the chemical level during your manufacturing processes. If so, you will need to report these process outcome level ingredients – not simply inputs. You might not have an exact breakdown of the ingredients and their quantities in the final product, as delivered, if you have not had that final product tested and characterized.

The following is a suggested outline of a process for gathering and assembling the information you will need to create your HPD. Each manufacturer will need to tailor these steps to your own systems and products. As more is learned about what works best, HPDC will add examples.

Gather In-House Information

Once preliminary decisions outlined in the previous section have been made, the first step is to gather available in-house information.

• Determine hierarchy of product: assembly, part/component, subcomponent, material, substance. This is useful in identifying and organizing data to be gathered and gaps in that data. Determine the suppliers you will need to contact to determine information at the homogeneous material and/or substance level that is not already available to you from your direct supplier list.
• Create an Inventory of product contents – materials and substances – of available information based on this hierarchy (many use a spreadsheet to organize this information). Include “intentionally added ingredients” and “residuals and impurities” as defined in the Standard. The contents should be “as delivered to the job site” if possible. Sources can include certificate of analysis and results of product testing; bill of materials; MSDS/SDS, TDS, etc. for final product and each ingredient (material/substance); shipping receipts, etc. Note that just because an ingredient in the product is used for a certain reason (i.e. is an “active” ingredient), that doesn’t mean that the ingredient is composed only of the active substance. There are usually other substances present in the ingredient (e.g. fillers, modifiers, etc.). For example, when a paint manufacturer gives a formulation, it usually states that there is x% TiO2. However, that is referring to the % TiO2 ingredient used, not the actual amount of TiO2 in the pigment product (which can vary greatly depending on the supplier and product).
• Use the process outlined in “Best Practices” on the HPDC website to identify residuals and impurities in your product.
• If you are using the Nested Material Inventory method you must include all materials and, for each material list data specified in the Standard.
• For both Nested Material Inventory method and Basic Inventory method, you must list all substances that are above the threshold selected, as specified in the Standard.
• Check to determine if any materials or substances might be considered Special Conditions by HPDC and if so, go to “Emerging Best Practices:  Special Conditions” to learn how to handle these materials or substances. Examples include materials without CAS RNs such as biological or geological materials.
• Identify materials/substances that are trade secrets and should be reported as proprietary.

In addition to the Content Inventory, the HPD requires that you include the following information that you will need to gather:

• VOC content for all liquid/ wet applied products
• Any additional certifications.

Contact suppliers with requests for missing information

Consider the best approach for each supplier, as they will differ in their ability and willingness to provide information. You might also need to bring in outside consultants to help with this process.

• Try to give suppliers adequate time to gather and provide the information. In the case of a multi-tiered supply chain, work with your direct supplier(s) to understand what is going to be required on their end to provide the level of information that an HPD requires.

• Be specific. Tell them exactly what you need; include definitions, thresholds, and any other information that will increase the likelihood that you will get the data you need. Don’t expect them to respond to your request that they give you “data needed to meet LEED v4 credit requirements” – be explicit.

• Tell them why this is important – that an HPD could enhance use of the product and sales volume, which is in the best interest of the supplier as well as the manufacturer.

• Make sure you get a contact person in case you have additional questions about the information provided.
• Send a material content data request form or spreadsheet including request for missing data: product name/ID, supplier name, complete inventory of intentional ingredients [substance name, CAS RN, % by weight in supplier’s product, role in product] residuals/impurities [substance name, CAS RN, % by weight/ppm/ppb, expected/known source, name of disclosing contact with signature and date]
• Be prepared to sign Non-Disclosure Agreements (NDAs) with suppliers as necessary. Some suppliers will only work through a third party under an NDA. In this case, if you are not already working with a third-party preparer, check the HPDC website for a list of preparers working with HPDs (coming soon).
• Use supplier-provided data to fill in the gaps in the Inventory. Assess completeness and whether you are ready to proceed.

HPDC is developing a “Supplier HPD” that will assist in this process. Look for this in 2019.

3.4   Creating an HPD using the HPD Builder online tool

Once you decide you are ready to proceed to creating your HPD, you first must decide what tool you will use. HPDC provides the HPD Builder, a web-based system, which is an authoritative method to create HPDs for your products. The HPD Open Standard supports other tools and platforms that would like to support HPD creation, but currently almost all HPDs are currently produced using the HPD Builder.

To use this tool, start by creating an account in the HPD Builder. There are two options for accessing the Builder:

• Your company can become a member of the HPDC and have unlimited use of the Builder or
• Your company can use the Builder on a per-use basis, purchasing one or more HPD bundle packs that contain five “tokens” for creating HPDs.

Visit the HPDC website to learn more about membership and HPD bundle pack.

If you are looking at tools or providers other than the HPD Builder, note that it is the responsibility of the tool provider to ensure that their tools are in full compliance with the requirements of the most current version of the HPD Open Standard, and fully up-to-date with Emerging Best Practices guidance for that version. If you have any questions on this, contact support@hpd-collaborative.org.

The HPD Builder has specific advantages:

• It provides an information management tool for creating, managing, printing and publishing your HPDs.
• It is guaranteed to be compliant with the current version of the HPD Open Standard and updated with the latest Emerging Best Practice guidance.
• It provides significant online guidance and format checking while you are creating HPDs.
• It does an automated hazard screening and hazard warning reporting, that complies with the HPD Open Standard.
• It does an automated completeness check, which finds inconsistencies with the Standard and reminds you if you have not filled in a required data element.
• It provides you with the option to perform an automatic LEED Pre-Check to indicate consistency with LEED v4 Material Ingredient credit requirements.
• It provides for automated publishing, and management of your HPDs, in the HPD Public Repository
• It links electronically with an increasing number of other tools, standards, and certifications to provide for automated data exchange of information in your HPDs. This feature is controllable by you, so that you can exchange date with only those tools and systems of your choosing.

The HPD Builder is a lot like a web-based income tax preparer. It walks you through the HPD, step by step, and gives you the instructions you need as you need them. It’s also a good idea to have the HPD Open Standard open as you go through the Builder. The Builder includes excerpts from the Instructions that apply to each section of the Builder, but additional detail is provided in the Standard Instructions as well as guidance in handling specific variations.

3.5   Communicating with Design Teams and the Public

Once you have completed your HPD, how can you make sure design teams know about it? Some suggestions include:

• HPD Public Repository. The HPD Public Repository is the authoritative source and archive for all published HPDs. Your completed HPD will be held in the HPD Public Repository as a PDF file, once you have “published” it through the Builder or have uploaded a PDF version to the Repository. Once an HPD is published in the Repository, it is considered to be “public.” HPDC also offers automated data exchanges between the Repository and third-party libraries, so these published HPDs have more ways of getting accessed. For example, the Mindful Materials database pulls in HPDs directly from the HPD Public Repository.

• Company Website. Highlight your commitment to disclosure and transparency on your own website. Let project teams know which of your products have HPDs available and where to find them. We recommend linking fro your website to the HPD Public Repository to make sure that you are providing the most up-to-date published versions.
• Sales reps. Train your sales reps so they can promote your company’s commitment to disclosure and healthier products, present your HPDs, and explain their value to customers. For example, having LEED-compliant HPDs  can be an important selling point. This Guide can help reps understand HPDs and the LEED guidance on the HPDC website can help them point out the specifics in an HPD that make it LEED compliant. The more knowledgeable they are, the more effective they will be in promoting this new aspect of your products. Since this is new territory for them, provide time for them to learn about HPDs and consider holding internal lunch and learns for your sales staff. HPDC’s website provides useful materials for further training your team.
• “Lunch and learn” for customers. You might already offer this type of program to familiarize customers with your products – you can add HPDs to these presentations or offer more in-depth lunch and learns on the health aspects of your products and what you are doing about this topic. Check the HPDC website for resources that might be useful for incorporating HPD topics in these sessions.
• Advertising. Product advertising often highlights features that relate to sustainability, environmental performance, and health. In publications targeted to the green building market, advertising often includes LEED, WELL and other compliance. If you want to use the HPD logo in your advertising, please contact us at support@hpd-collaborative.org for more information.

• Conferences and trade shows. In your booth at trade shows and exhibits, you can highlight your HPDs. If you are an HPDC member, you can display a member sign. HPDC provides “HPDC Member” signage for use in your booth or other events. Please contact us at support@hpd-collaborative.org for more information on booth signage and logo usage. Further, manufacturers are presenting their experiences and accomplishments in regular sessions, reaching a new audience. These sessions are particularly effective when you can tell a story about your journey to disclosure and transparency, what it means to your company, what barriers you encountered and overcame. Team with users of your products to tell a more complete story. These presentations and discussions can contribute to a more positive, constructive relationship with your customers.

3.6   Tips for Success in Creating your HPD

The following tips were gathered from companies successful in creating HPDs.

Where can I get help or answers to questions while I am creating an HPD?

HPDC provides resources to help you find answers to your questions. For questions about the Standard, data requirements, and the Format:

• The HPD Open Standard is the authoritative source for specification of data requirements in the HPD. It provides detailed explanations of each data field, including variations that are acceptable. The Standard is available for free download.
• This Manufacturer’s Guide provides advice on completing an HPD. It does not provide the complete and detailed specification that is in the Standard.
• The FAQs on the HPDC website provide answers to questions. It is searchable and organized into categories.
• If you do not find an answer to your question, you can submit a “ticket” to request assistance. In the Support Portal, go to Tickets and New. This system enables us to track all inquiries and ensures a timely response. Be as specific as possible.

What are projects looking for? How can we make our HPD stand out?

Project teams will have different reasons for asking for and looking at your HPDs. Understanding those reasons will make sure your HPDs meet their expectations.

• If project team users are planning to use the HPD to meet requirements of a particular certification system, make sure you know which one and the details. For example, if they are trying to achieve the LEED Disclosure and Optimization credit, you need to know if they are trying to achieve Option 1 and/ or Option 2. The requirements are different for the two Options within that credit.
• All users want a complete HPD that is reported in compliance with the requirements in the HPD Open Standard. If you are preparing HPDs in-house, someone in your organization needs to be very familiar with the Standard. There is a Checklist in the Standard that can be useful in ensuring completeness.
• If you have reports, studies, or additional certifications that explain the contents of your product, especially the hazards it contains, include reference to those reports, studies, or additional certifications in Notes sections. Don’t just include a vague statement that “there is no risk of exposure to this hazard” – provide links to evidence. This provides credibility.
• Provide explanations for anything else that might raise a question – why do you provide ranges for amounts of some substances rather than a fixed quantity? Why were you not able to consider residuals and impurities in some materials?
• Consider Third Party Verification of your HPD. As more HPDs appear on the market and are used more frequently by designers, there is demand for higher quality of information, which is achieved with third-party review.

How can we avoid problems with reviews and rejection of HPDs by LEED reviewers?

Each version of the HPD has become easier for reviewers to review. The requirements have been clarified and the relationships between the data fields on the HPD and the LEED requirements have been clarified. If you have HPDs created with version 1.0 or 2.0 that have been rejected, create new HPDs with version 2.1.1. This new version has several built in advantages for LEED compliance:

• The Builder conducts a “completeness” check automatically to notify you if a data field has not been filled in.
• The Builder can do a Pre-Check of LEED compliance – this is an optional mechanical check that identifies any fields that have been left blank or are not completed in accordance with LEED requirements (such as threshold level or Characterized/ Screened/ Identified). It does not check the quality of the data in those fields, but it provides a preliminary check. If you run the Pre-Check and learn that your HPD does not meet the requirements, you can go back and see if items can be completed or corrected. If you are not able to meet the requirements, you can publish your HPD without disclosing the results of the Pre-Check.
• Definitions of data field requirements have been clarified.

HPDC’s third party verification program is available. This program provides an additional check on your HPD.

How can I work with my suppliers to obtain their data?

This can be the most difficult part of creating an HPD. Suppliers can be reluctant to provide the information, claiming that it’s proprietary. A few successful strategies are:

• Talk to the supplier to find out exactly why they won’t provide the data – that will help you figure out the best strategy.
• If they are willing to provide the data to you but not to allow it to be published, assure them that you can enter the identifying data, such as name and CAS RN, but then define that item as proprietary so the identifying information will not appear but the hazards resulting from screening will appear. If you want your HPD to be LEED compliant, this is allowed – name and CAS RN can be withheld as long as role, amount, and hazards are listed.
• If they are not willing to provide the data to you, ask if they are willing to provide it to a third party who can create your HPD under a Non-Disclosure Agreement for that information. Third Party Preparers serve this role, as well as assisting in creation of the HPD.
• Look for a new “Supplier HPD” in 2019 from HPDC. This will provide a much easier process for suppliers.

What are Special Conditions and do they apply to my product?

If you find that it is difficult or impossible to complete the HPD due to specific aspects of your product – for example, use of materials that do not have CAS RNs to enable identification and screening – check the Special Conditions section of the HPDC Best Practices website. “Special Conditions” reflect the fact that some materials and substances cannot be identified or screened using current HPD methods. For example, there are some materials that lack CAS RNs, such as biological and geological materials, and some materials are highly variable, such as mixed recycled content. As of the release of HPD Open Standard 2.1.1, HPDC has specific Special Conditions guidance for: 

• biological materials
• geological materials
• mixed recycled content
• electronics

HPDC is also developing guidance for:

• float glass
• form specific hazards
• metal alloy materials
• mixed hardware
• reaction products
• ceramics
• defined substances without an identifier
• material with a CAS RN but no molecular structure.

Specific best practices will be posted to the website as they are approved.

Can I get my HPDs third party verified? Should I?

Third party verification is a process in which an objective outside party reviews your HPD and verifies specific data. This process is used in many reporting systems, and HPDC developed a third-party verification program that is consistent with the ISO 17065 standard. A few key facts about HPDC’s third-party verification program:

• It is a “desk audit.” It does not independently run laboratory tests or assess ingredients of your product. Instead, it checks data such as making sure the content inventory matches other documentation (e.g., Bills of Materials), and that undisclosed substances have been properly screened.
• It checks compliance with the HPD Open Standard but does not check compliance with the LEED v4 Material Ingredients credit.
• Third-party verifications are performed by organizations that have met standards established by HPDC.
• Work of the verifiers is audited by HPDC to ensure quality.

Third-party verifications give your customers more confidence in the HPD and its information. Some programs require verification or give “extra credit” for verified HPDs.

Do I need an outside consultant to help me prepare my HPD?

The HPD Open Standard was designed to be usable by manufacturers, without requiring you to hire outside consultants. In some cases, though, it makes sense to get help. There are third-party preparers who are recognized by HPDC and can be depended upon to provide quality services. Here are a few questions to help you think about this issue:

• Do I have an employee who has time to devote to this effort? For a simple product with a small and cooperative supply chain, an HPD can be created fairly quickly. However, if all of your employees are already stretched, you might not be able to support the effort in-house.
• How quickly do I need to get the HPD created? Are there project teams demanding an HPD now for a project submittal? Can we fit this into our regular workload and still meet these requests?
• Do the available employees have the needed expertise and knowledge of the product to enable them to gather and process the data accurately? Are they familiar with suppliers and can they work effectively with them if data must be requested from them?
• Do I want to devote staff time to learning about HPDs as an investment in creating future HPDs? Or, if it’s unlikely that additional HPDs will be created, does this investment still make sense?
• Finally, do I have suppliers that will not release information about ingredients? If so, a third party working under a Non-Disclosure Agreement might be an effective way to obtain that data and enable you to create a LEED-compliant HPD. LEED allows withholding of the name and identifier of proprietary ingredients, as long as they are characterized (role and amount in the product) and screened for hazards. Third party preparers can arrange this.

What are the HPD Builder and HPD Public Repository APIs? How can they benefit my company?

An Application Program Interface or “API” is a mechanism for sharing of data among systems and tools. HPDC has implemented an API for the Builder and an API for the Repository.

• The HPD Builder API is a mechanism for sharing the data elements in a manufacturer’s HPD Builder account with selected other systems and tools. Participation is at the option of, and completely controlled by, the manufacturer, through an interface in the HPD Builder system. If you choose to participate, you will be able to export data from your HPD Builder files to those applications you select. In some cases, the HPD Builder will also accept data from other applications, in which case you will export that data from your account in the other participating application to the HPD Builder. The data to be shared, as to its update frequency and content, is totally controlled by the manufacturer, within the parameters of the participating application. Since each participating application is different, manufacturers should consult the HPD Builder application for additional information, or contact HPDC Staff with questions.
• Once a manufacturer “publishes” an HPD to the Repository (whether automated via the HPD Builder, or manually via the Repository), the completed HPD PDF becomes a publicly available document, and is automatically made available via two access methods:

1. HPD Public Repository – direct access. A web-based search/download capability, for individual users. This capability is available, at no-charge via the HPDC website.
2. HPD Public Repository – access via a participating library/directory. An electronic data exchange capability has been implemented by HPDC with participating libraries/directories, such as Mindful Materials. This interface enables libraries and directories to electronically upload HPDs from the Repository, and display completed HPDs for use on these libraries and directories. 

What’s the best way to “publish” my HPD?

The HPD Public Repository is the authoritative place to publish your HPD. To have the status of “Published,” a completed HPD must appear in the HPD Public Repository. It may also appear on manufacturer websites, and in other public directories, but will not be officially “published” if not in the Repository. If you use the HPD Builder, you can automatically publish HPDs to the Repository, from the Builder, and also manage your published HPDs from your Builder account. Manual upload of completed HPDs to the HPD Public Repository is also provided.

Should I worry about legal questions?

American Institute of Architects published a white paper on legal concerns for architects that is helpful in addressing many common questions. You should consult with your own legal team on specific concerns. The broad adoption of the HPD Open Standard, with over 4,200 HPDs publishes by close to 500 manufacturers (as of December 2018), is evidence that manufacturers are able to find ways to address legal questions and participate.

What are some common mistakes and how can they be avoided?

The following are mistakes that can affect how project teams can use your HPD:

• Use MSDS/SDS to identify contents. If the only information you have on contents of your product come from an MSDS or SDS, use them. However, be aware that thresholds used in MSDS and SDS do not meet LEED requirements. Further, these sources do not report many types of ingredients that are required for an HPD.
• Assuming your Bill of Materials will contain the required content list. For more complex products with mutli-tiered supply chains, the Bill of Materials generally will not have the required detail. Be sure to understand the depth and breadth of your supply chain and allow adequate time and resources to obtain needed data.
• Other failure to report all contents. You must report all materials in the product, if you are preparing a Nested Inventory, and all substances above the stated threshold (per product or per material).
• Use of incorrect CAS RN. Use of an incorrect CAS RN will result in inaccurate hazard screening. You must use the most applicable CAS RN for the substance; there might be several variations of the substance and it is important for you to identify the one used in your product.
• Threshold doesn’t meet requirements for reporting (LEED, Portico, C2C). It’s important to understand how your HPDs will be used so that you can meet all of the applicable requirements. Choosing an incorrect threshold can result in an HPD that is non-compliant with the requirements.
• Failure to list VOC content for wet-applied products. VOC content must be listed for all liquid/ wet applied products.

Finally, it’s important to take the first step – create your first HPD. Remember that HPDs simply report your information – they do not rank or rate your product. Even if you can’t get information on all contents, you are indicating to your customers and your employees that your company is part of the movement toward greater transparency and healthier products. As you gain more experience with creating and using HPDs, develop your data sources within your supply chain – and – most importantly – work with and gather feedback from project teams – you can update your HPDs to make them more complete. And, you can also begin to use the information in your HPDs to give your own product development teams insights into ingredients that you may want to improve.