Product Transparency Declarations
The other development that healthcare designers will find useful is the Product Transparency Declaration (PTD). This document is intended to disclose the known ingredients of a product specified for a project, and provide design professionals, contractors and building occupants with additional information that is helpful in assessing those ingredients’ health risks. PTDs include additional information regarding recycled content and VOC analysis from a finished building perspective, as well as a section that covers various product certifications like EPDs, multiple attribute standards and LCAs.
The overall goal of Product Transparency Declarations is threefold:
- to provide a simpler, less expensive way to determine ingredient and exposure information in an easy-to-use and understandable format;
- to focus on the need of a specifier to determine if the ingredients in a building product will potentially expose building occupants or installers to harmful ingredients; and
- to ensure that the information is based on an authoritative list and regulatory program(s) that have hazard-exposure triggers and labeling requirements.
The stakeholders behind the development of PTDs have committed to putting the format through the ANSI consensus process to ensure that all industry stakeholders have an opportunity to participate in its further development. This will allow different manufacturers across different fields, design professionals and building rating entities to come together to develop a common standard for PTDs, and will benefit design professionals by ensuring consistent reporting and formatting of the requested data.
HPDs and PTDs: What’s the Difference?
HPDs require a manufacturer to state the actual percentage or percentage ranges of each ingredient in a finished product. Manufacturers must also include the percentage of an ingredient if it varies over time and describe why the ranges vary.
This type of information is unnecessary in determining whether an ingredient in a product is listed as a hazard. There are over more than 30 chemical lists referenced in HPDs; however, most of them carry no authoritative backing. PTDs, on the other hand, use six well-recognized regulatory sources—among them, OSHA’s Hazard Communication Standard 2010 and California’s Proposition 65, both of which relate to exposure and require warning labeling based upon exposure levels.
Neither OSHA nor Prop 65 are intended as “de-selection listings,” but lists that address a level of exposure and labeling relevant to the hazard. For example, wood dust is considered a carcinogen by Prop 65; however, if a wood product is manufactured and installed properly, wood dust is not a concern within a finished building space. If those working in a manufacturing facility or installing a finished wood product on a job site follow the appropriate procedures and use protective equipment, then a product is not a health risk within that space.
I’ve received calls and emails from association representatives, speakers, manufacturers, standard developers and design professionals trying to sort through the maze of environmental product information that is applicable to healthcare projects. Understanding that EPDs, LCAs and multiple attribute certifications are available in the marketplace and growing based upon the development of standards and green building rating systems is a step toward desired transparency.
However, HPDs or PTDs have to be considered in conjunction with considerations of potential liability on the side of a design firm. If a firm requests and accepts an HPD that includes hazardous ingredients, the firm accepts the responsibility for either evaluating the hazardous ingredients or sharing this information with their clients. One of the attorneys on the EBN webcast “Increased Transparency, Increased Liability for Designers” mentioned that designers do not have the technical knowledge to determine if there is a health risk from product ingredients. Therefore, the development of PTDs that include the exposure/risk concept may be a better direction for firms evaluating transparency related to health hazards when balanced with a firm’s liability risk.
In 2014, the updated ASHRAE 189.1 Standard for the Design of High-Performance Green Buildings Except Low-Rise Residential Buildings and the ASHRAE 189.3 Proposed Standard for the Design, Construction and Operation of Sustainable High Performance Health Care Facilities are anticipated for publication. Similar to ASHRAE 189.1, it is the goal of industry stakeholders for 189.3 to become the healthcare alternative path of compliance to the International Green Construction Code (IgCC).
In regards to licensing, the Facility Guidelines Institute is finalizing a sustainability white paper in collaboration with the ASHE Sustainability Committee referenced within the 2014 “Guidelines for Design and Construction of Hospital and Outpatient Facilities.” Sustainability information is also provided within the brand new 2014 “Guidelines for Design and Construction of Residential Health, Care, and Support Facilities,” including references to the “Senior Living Sustainability Guide®”.
From both a building code and licensing code perspective, it is anticipated that product transparency, EPDs, LCAs and multiple attribute certifications will be addressed and continue to develop as HPDs and PTDs evolve, continuing to impact the evaluation and specification of sustainable products in healthcare environments.
Jane Rohde is the founding Principal of JSR Associates, Inc. located in Ellicott City, Md. She champions a global cultural shift toward de-institutionalizing senior living and healthcare facilities through person-centered principles, research and advocacy, and design of the built environment. Rohde speaks internationally on senior living, aging, healthcare, evidence-based design and sustainability.
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