Certification under LPC is valid for 3 years, at which time, the manufacturer must demonstrate maintenance or improvement on any of the areas identified in their initial certification to maintain their status.
The two different pathways outlined in the certification requirements therefore have two different recertification processes:
Pathway 1: Preapproved Optimization Pathway
For the manufacturer to continue to pursue the pre-approved program pathway at recertification (3 years after certification), their certification for that program must continue to be valid at an approved level, or higher at the time of recertification.
Pathway 2: LPC Transparent Material Health Pathway
Those manufacturers who pursue the pathway outlined in the Transparent Material Health Guide must work with the approved Material Health Assessor (MHA) leading up to recertification to demonstrate that a product meets any continuous improvement requirements.
As noted above, initial certification allows 5% of the product to be unassessed (100% of the product is still required to be inventoried and show Red List compliance per the Red List Imperative). By recertification, the manufacturer should have worked with the MHA to assess the remaining 5% of the product to achieve 100% assessed at a 100 ppm threshold. If the manufacturer is unable to assess the remaining 5% a request to use RL-020 Continuous Improvement for Assessment may be considered.
The MHA is required to revisit any chemical assessments made over 5 years ago and determine whether the assessments are still valid or whether updates are required (i.e. a new GreenScreen is needed, or polymer data may need to be confirmed). If a substance has been recently reviewed by the MHA and they are confident that the results of that assessment stand, they should take that into account and focus efforts on new substances or truly out-of-date reviews.
For more information, review the Transparent Material Health Guide.
