Section 1 - Administrative Requirements
Section 2 - Verification Process
Section 3: Verification Checklist

Topic 3 – Section 2, Contents – Items to Note Copy

Section 2, Contents - Items to Note

  • Packaging materials removed prior to use and materials used for identification only need not be included in the inventory
  • Average or typical percentages or percent by weight ranges may be included with an explanation of how this was derived in the “Other Materials Notes”
  • Percentage weight ranges for substances or materials should not exceed 20% without an explanation in the notes
  • Notes are required for “Undisclosed” materials and substances

Best Practices: Residuals & Impurities

Have they been considered?

How was this determined?

Are the proper notes added?

Whether considered or not considered is indicated, an explanation must be provided. Use the Residuals and Impurities Notes for related information.


Summary Materials or Product Notes

  • Rationale for nondisclosure of a Material Name in a Nested Materials Inventory
  • Explanation for ranges, alternates, and undisclosed material percentage
  • Explanation why “Other” is indicated in Inventory Threshold
  • When inventory data for substances in a single material are obtained at multiple threshold levels in a Nested Inventory or a product in a Basic Inventory
  • Variations among different products in a single HPD

All of these pieces are required, if applicable to the specific HPD.  If not applicable, no notes are needed.