What type of information is important to specifiers of building materials?
In following the standard of care expected of them, design professionals, including architects, interior designers and other material specifiers, need to ensure that the products and materials they choose for a building project are selected based on meeting multiple requirements. These typically include: (1) durability and performance, (2) applicable code requirements, guidelines, and industry standards, (3) appropriate and recommended use applications, (4) initial purchase costs, (5) long- term operating and maintenance costs, (6) life-cycle costs, (7) environmental impacts, (8) maintenance considerations, and (9) health impacts of building occupants. Designers and specifiers continually seek information on material and product attributes to ensure they and their clients are well informed for making the very best choices.

What is the purpose of a Product Transparency Declaration?
The Product Transparency Declaration (PTD) (1) provides specifiers with a list of product ingredients in the building product and (2) helps specifiers know whether any ingredients are present at levels requiring a warning notification to product installers and/or building occupants due to ingredient(s) exposure from the building product.

What information is provided in the Product Transparency Declaration?
By completing a PTD, the manufacturer reports a list of ingredients and CASRN nomenclature along with an indication of whether the ingredient is included on six widely recognized lists and is subject to hazard communication requirements. Ingredients classified as potential carcinogens, mutagens, or reproductive toxins are reported to a minimum 1,000 ppm (0.1%) threshold or lower if required by OSHA’s hazard communication standard. Other ingredients (whether or not hazardous) are disclosed to a 10,000 ppm (1.0%) threshold. In addition, manufacturers will indicate whether the ingredient level in the product triggers a warning label or exposure notification.

  • Ingredient Disclosure: While there are many lists available in the public purview, the PTD focuses on six recognized lists. The six lists include: 1) the International Agency on the Research of Cancer Terminology (IARC) carcinogens and probable and possible carcinogens; 2) the known or reasonably anticipated carcinogen lists from the National Toxicology Program Report on Carcinogens; 3) the primary requirements of California Proposition 65 listings for substances known to cause cancer or reproductive toxicity; 4) the persistent, bioaccumulative or toxic substances on USEPA’s Toxic Release Inventory; 5) OSHA Carcinogen List, and 6) REACH Substances of Very High Concern. In addition, the manufacturer will identify whether four heavy metals are added as functional ingredients.
  • Warning Notifications: In addition to listing the product ingredients, the PTD asks the manufacturer to disclose if the product, as provided to the job site purchaser, needs to carry a warning label or notification because one or more ingredients exceeds the trigger exposure level identified under (1) OSHA HCS 2012 standard and (2) California Proposition 65.
  • Volatile Emissions: Manufacturers are asked to disclose whether products with volatile ingredients comply with appropriate VOC emission testing, including California’s emission testing for CA Specification 01350, the California Airborne Toxic Control Measure related to composite wood; and South Coast Air Quality Management District requirements for adhesives, sealants, and architectural coatings. Manufacturers are also asked to provide information on TVOC emissions (Total Volatile Organic Compounds)

What is the difference between a Product Transparency Declaration (PTD) and a Health Product Declaration (HPD)? While there have been some recent attempts at promoting ingredient disclosure based on the hazards of pure chemicals, no version of existing product declarations provides meaningful information to the specifier about the potential exposure levels or related hazard for ingredients in the final building product as offered to the building & construction market.

The Product Transparency Declaration was designed to meet this specific need in an easy to understand format. The PTD identifies intentionally-added ingredients, their presence on six recognized lists, the OSHA hazard communications standard, and the associated warning notification for potential adverse exposure based on regulatory requirements. Thus, the PTD provides the specifier with a warning about whether the level of an ingredient within a product delivered to the job site could pose a potential exposure hazard to building occupants or installers.

In contrast, the proposed use of the current version of the Health Product Declaration (HPD) requires the disclosure of ingredients listed on one or more of over 30 separate lists, most developed for very different goals than exposure warning. As an example, the EPA’s TSCA Work Plan Chemicals List is a candidate list of chemicals for EPA evaluation and study about the appropriateness for an EPA risk assessment under its toxics substances chemical management regulatory program, which some have mislabeled as a “chemicals of concern”? list. Other HPD lists identify chemicals for ecological impacts (i.e., global warming, ozone depletion) which are not related to human exposures from building materials and are covered in Environmental Product Declarations.

The purpose of the Product Transparency Declaration is to help specifiers focus on ingredients in products that could potentially cause an adverse human health exposure because of release from or contact with the building product under conditions of normal use for both the building occupant and installer of building products.

How does a Product Transparency Declaration assist specifiers? The PTD addresses the informational needs of the specifier with the disclosure of intentionally-added ingredients, including metals; identification of six recognized lists, and OSHA hazard communications standard; and awareness about whether the ingredient level triggers an exposure warning notification based on content in the building material or product.

As an example, titanium dioxide (TiOâ‚‚) is used in linoleum, other flooring and many common building materials is bound in the product and used as a whiting pigment (also used in paints, white ‘cool”? roofs and toothpaste). TiOâ‚‚ in its dry particulate form, is listed by the International Agency for Research on Cancer (IARC) as “possibly carcinogenic”? to humans. TiOâ‚‚ is also a listed chemical under California Proposition 65 when the dry particulate form is both of respirable size particles and expected to become airborne. Using an HPD, the linoleum manufacturer would list the ingredient TiO2 and the box for “cancer”? would be checked when a manufacturer uses the automated HPD form, since the hazard warning is automatically filled in based on the name and CASRN. In contrast, using the PTD, the linoleum manufacturer would list the ingredient TiO2, check the box for the IARC listing, AND provide the specifier with notification about the exposure warning, if the exposure trigger for the ingredient is exceeded in the building material. In the TiO2 example, an exposure warning may not be warranted if the chemical is bound and no airborne exposure to the dry particulate form of TiO2 is possible. Thus, specifiers using the PTD are better able to discern the actual exposure potential in the building product.

This example is not unique. Building products offered for a project often contain ingredients that are bound into the building product with varying exposure potentials ranging from none to measured concentrations. Thus, the PTD represents an improvement in marrying ingredient disclosure with exposure and risk warning labelings.

Where can I obtain a Product Transparency Declaration?
Product Transparency Declarations are published voluntarily by product manufacturers and are verified with the signature of a responsible company official. Using the PTD, manufacturers assure awareness of the ingredients in the product as well as any potential exposure which may be harmful to building occupants or installation workers.

Regulatory references include:

  • IARC – International Agency on the Research of Cancer Terminology
    Group 1 – Carcinogenic to Humans
    Group 2A – Probably Carcinogenic to Humans
    Group 2B – Possibly Carcinogenic to HumansSource:
  • NTP – National Toxicology Program – Known Human Carcinogen and Reasonably
    Anticipated CarcinogenSource:
  • OSHA – Occupational Safety and Health Administration – Hazardous Communication Standard as amended by OSHA HSC 2012. Source:
  • Prop 65 – California Proposition 65 – Known to cause cancer or reproductive toxicitySource:
  • USEPA TRI – Toxic Release Inventory – Persistent, bioaccumulative and toxic (PBT) chemicals- Known persistent, bioaccumulative, and toxic chemicals and compounds.
  • REACH Substances of Very High Concern -Candidate List of Substances of Very High ConcernSource:
    In addition to the six lists, the four metals selected for disclosure are based upon RoHS. Source:

PTD Submission Form and Guide
The PTD Submission Form is a tool that building product manufacturers use to submit their product ingredient information. The PTD Form Guide provides detailed information on the procedures for completing the PTD Submission Form.

The downloadable PTD Submission Form can be accessed at the following link:

The PTD Submission Form Guide can be accessed at the following link: