Option 1 requirements state that for the HPD to be applicable, the “HPD standards for the 1,000-ppm level must be attained and the appropriate box on the summary page checked”. However, after reviewing several HPDs, it's apparent that the 1,000 ppm level of disclosure can be attained either through the “Measured 1,000 ppm” or “As per MSDS (1,000 ppm)”. Is anyone able to provide clarity as to whether either method of disclosure is acceptable to meet the credit requirements? Or how either method of disclosure to the 1,000 ppm level differs from the other?
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- As reported by suppliers on MSDS: Fully disclose all residuals that exist in the product based on current MSDS requirements. It is acceptable to rely on MSDS disclosure from suppliers rather than perform direct measurements. Residuals that are identified as health hazards as per CFR 1910.1200 are disclosed at 0.1% (1000 ppm) for carcinogens and at 1% (10,000 ppm) for all other substances.
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