I'm grasping for one last point here.  

The reference manual says you can get 1/2 a product if:  The manufacturer has screened the product to at least 1,000 ppm and has provided a publicly available inventory meeting the requirements of Option 1 and completed a detailed action plan to mitigate or reduce known hazards using the principles of green chemistry.

What if the HPD says that there are zero hazards to mitigate or reduce?  Wouldn't that mean that they don't need an action plan?  So, therefore I can get 1/2 a product?

I know this probably won't fly - but I just might try it, and list it in the special circumstances area.