Emerging Best Practices for Consideration of Residuals and Impurities

Background

Consideration of Residuals and Impurities is a topic covered by Emerging Best Practices, within the HPD Open Standard.  The HPD Open Standard 2.0 revised the way Residuals and Impurities are handled in the HPD; the requirements in HPD 1.0 were found to be too onerous and not feasible for many manufacturers, products, and processes.  HPD Open Standard v2.3 updated the visual appearance of Residuals and Impurities on the HPD. The terminology “Considered” was replaced with “Completed” to clarify intentions of Residuals and Impurities reporting methodology.

Emerging Best Practices supplement the information and requirements presented in the HPD Open Standard Instructions and Format, as an official element of the HPD Open Standard.  For additional information about how Emerging Best Practices are governed as part of the HPD Open Standard, visit the Emerging Best Practices Landing Page by clicking on this link.

The HPD Open Standard v2.3 states:

2.2.1.4 Residuals/Impurities

Indication of whether residuals and impurities have been evaluated for the material or product and included in the inventory.

Manufacturers are required to report what has been done to evaluate Residuals/Impurities.  The Evaluation is performed according to the Residuals and Impurities Best Practices guidance.

• For a Basic Inventory, the Evaluation is reported for the Product, based on evaluation of the Materials/Substances reported in the Product
• For a Nested Material Inventory, the evaluation is reported for each Material reported in the Product, based on evaluation of the Materials/Substances reported in that Material

The Evaluation result for the Product (in a Basic Inventory) and for each Material (in a Nested Material Inventory) is reported with one of these statuses, or an intermediary status for Nested Materials inventories:

Completed

• “Completed” status means the manufacturer has followed the steps outlined in Residuals and Impurities Best Practices guidance to evaluate the presence of residuals and impurities in the material or product
• In addition to indicating the evaluation status, any identified residual or impurity that is known or has the potential to be present in the material or product above the Content Inventory Threshold must be listed in HPD Format Section 2: Content in Descending Order of Quantity as an individual line-item entry for the Product/Material in which it was found.
  • If the quantity of the Residual or Impurity is not known precisely, a range can be indicated for percentage weight.
  • If the manufacturer can demonstrate that an identified residual is not present at or above the indicated threshold, the residual does not need to be listed as a line-item in the inventory, but an explanation of the rationale must be provided in the Residuals and Impurities Notes [See 2.2.1.6].
  • While it is acceptable to indicate that residuals and impurities have been evaluated completely when no identified residuals are listed as line items, a thorough methodological explanation in the Residuals and Impurities Notes [See 2.2.1.6] must justify this determination.
• Explanations must be provided in Residuals and Impurities Notes, following Residuals and Impurities Best Practices guidance. If status is “Partially Completed,” explain why Evaluation was not able to be Fully Completed.

Not Completed

• Not Completed status means that either no evaluation of residuals/impurities was completed, or that an evaluation other than the Residuals and Impurities Best Practices guidance was employed.
• Provide an explanation in the Residuals and Impurities Notes, following Residuals and Impurities Best Practices guidance, for why the manufacturer has not evaluated residuals and impurities, or the basis for using a different methodology.

Please follow the links shown below to access the current versions of Residuals/Impurities guidance.  If you have need further information or have questions about Emerging Best Practices for Consideration of Residuals and Impurities, please contact us at support@hpd-collaborative.org.