Topic 1 – Content Accuracy Copy Copy

Content Accuracy

One of the roles of the verifiers is to ensure the content inventory has been built accurately. This role is carried out in the following ways:

TPV Role 1: Provide Desk Audit

The TPV provides a “desk audit” of product information used by the manufacturer to complete the HPD.

TPV Role Does Not Include

The TPV roles does not include providing an onsite audit of manufacturer documentation such as BOMs or batch records.

TPV Role 2: Raise Relevant Questions

The TPV uses their expertise and experience to raise relevant questions about documentation.

TPV Role Does Not Include

The TPV does not including taking documentation at face value. While staying within the scope of a desk audit, verifiers should “sniff out” inconsistencies and gaps in reporting using their expertise and industry experience.

TPV Role 3: Confirm Documentation

TPVs confirm that the HPD report is fully supported by documentation of the product’s formulation.

TPV Role Does Not Include

The TPV role does not include providing a laboratory examination of physical attributes of the product or ingredients.

TPV Role 4: Check Data Compliance

The TPV checks that any data reported as undisclosed or proprietary on the HPD are accurately represented and compliant with Standard requirements

The TPV Role Does Not Include

The TPV role does not include helping to obtain data from suppliers. If the substance was not identified by the preparer, it is not the verifier’s role to obtain it. The verifier would identify it as a corrective action and the manufacturer or preparer would be responsible to identify it.

Role 5: Confirm Undisclosed Contents

The TPV confirms the identity of undisclosed contents on the HPD, in order to verify hazard screening for those contents. This may require direct communication with suppliers, and use of nondisclosure agreements (NDAs), software tools like the Supplier HPD, or other means.