FINAL

— October 10, 2014 

# Significant New Alternatives Policy Program

Foam

- Blowing Sector

Risk Screen on Substitutes in Flexible Polyurethane Foams
Substitute: trans

- 1

- C hloro

- 3,3,3

- t rifluoropro p - 1

- ene

This risk screen does not contain Clean Air Act (CAA) Confidential Business Information (CBI) and, therefore, may be disclosed to the public.



### 1. INTRODUCTION

Ozone

- depleting substances (ODS) are being phased out of product ion in response to a series of diplomatic and legislative efforts that have taken place over the past two decades, including the Montreal Protocol and the Clean Air Act Amendments of 1990 (CAAA). The U.S. Environmental Protection Agency (EPA), as authoriz ed by Section 612 of the CAAA, administers the Significant New Alternatives Policy (SNAP) Program, which identifies acceptable and unacceptable subs titutes for ODS in specific end uses based on assessment of their health and environmental impacts.

The EPA’s decision on the acceptability of a substitute is based on the findings of a screening assessment of potential human health and environmental risks posed by the substitute in specific applications. The EPA has already screened a large number of substitutes in many end uses within all of the major ODS

using sectors, including refrigeration and air conditioning, solvent cleaning, foam blowing, aerosols, fire suppression, adhesives, coatings and inks, and sterilization. The results of these risk screens are pre sented in a series of Background Documents that are available in the EPA's docket. The purpose of this risk screen is to supplement the EPA’s Background Document on the foam blowing sector (EPA 1994) (hereinafter referred to as the Background Document). This risk screen evaluates the potential use of trans

- 1

- c hloro

- 3,3,3

- trifluoropro p

- 1

- ene (hereinafter referred to as SolsticeTM 1233zd (E) )

as a blowing agent substitute in flexible polyurethane foam . SolsticeTM 1233zd(E)) presently has EPA SNAP approval for use as a blowing agent in rigid polyurethane and polyisocyanurate laminated boardstock; rigid polyurethane appliance, commercial refrigeration, spray, and slabstock; and integral skin polyurethane foams . Table 1 presents information on the proposed substitute.

Table 1 . Composition of SolsticeTM 1233zd (E)

Constituent Chemical Formula CAS Number Percent of Total (by weight)

trans

- 1

- Chloro

- 3,3,3

- trifluoroprop

- 1

- ene C 3 H 2 ClF 3 102687

- 65

- 0 >99%
Potential Impurities (maximum concentration)FINAL

— October 10, 2014 The potential risks associated with use of foam blowing agents have been examined at leng th in the Background Document. The reader is referred to this reference for a detailed discussion of the methodologies use d to conduct this risk screen. This risk scr een addresses flammability risk and assesses the impact of potential relea ses of SolsticeTM 1233zd(E) on the atmosphere and climate. O ccupational
exposure was assessed to ensure that manufacture and application of the proposed substitute in the proposed foam

- blowing end use does not pose unacceptable risk to workers. Lastly, general population exposure was assessed to ensure that the proposed substitute would not pose an unacceptable risk to the population at large. Section 2 of this report summarizes the results of the r isk screen for the proposed substitute. The remainder of the report is organized into the following sections:

 Section 3: Atmospheric Assessment

 Section 4 : Volatile Organic Compound Assessment

 Section 5 : Flammability Assessment

 Section 6 : Potential Healt h Effects

 Section 7 : Occupational Exposure Assessment

 Section 8 : General Population Assessment

 Section 9 : References



### 2. SUMMARY OF RESULTS SolsticeTM 1233zd(E) is recommended for SNAP approval as a foam

- blowing agent in flexible polyurethane. The EPA's risk screen indicates that the use of the proposed substitute will be less harmful to the atmosphere than the continued use of CFC

- 11, CFC

- 113, HCFC

- 141b , and HCFC

- 22 , as well as other commonly used blowing agents

. In addition, SolsticeTM 1233zd(E) co ntributions to volatile organic compound (VOC) emissions are not a concern as SolsticeTM 1233zd(E) is exempt under CAA regulations (40 CFR § 51.100(s)). Given that appropriate personal protective equipment (PPE) and engineering controls (e.g., exhaust venti lation, vapor

- in

- air detection systems) will be used during installation, maintenance, and disposal activities, n o significant toxicity risks to workers or the general population are expected . In addition, based on the characteristics of the proposed subst itute and the proper precautions listed in the MSDS for SolsticeTM 1233zd(E), the proposed substitute is not expected to present a significant flammability co ncern during manufacture or end use (see Section 7 ).



### 3. ATMOSPHERIC ASSESSMENT This section presents an assessment of the potential risks to atmospheric integrity posed by the use ofFINAL

— October 10, 2014 SolsticeTM 1233zd(E) in the foam blowing sector. The ozone depletion potential (ODP), global warming potential (GWP), and atmospheric lifetime (ALT) of t he proposed substitute are presented in Table 2 . As compared with ODS blowing agents currently in this end use such as CFC

- 11, CFC

- 113, HCFC

- 141b, and HCFC

- 22

, SolsticeTM 1233zd(E) is substantially less harmful to the ozone layer, has less climate impact, and a shorter atmospheric lifetime. In addition, SolsticeTM 1233zd(E) also has lower climate impact and a shorter atmospheric lifetime than those predict ed for other substitutes examined in the Background Document , as well as commonly used blowing agent HFC

- 134a

. SolsticeTM 1233zd(E) has a non

- zero ODP, but

, at 0 .00024, this value is very small when compared with continued used of HCFC

- 141b or HCFC

- 22 . A recent report by Wang et al. (2011) modeled the potential of SolsticeTM 1233zd(E) to affect the amount of ozone in the global atmosphere (tropospheric and stratospheric) . This report found that the release of all SolsticeTM 1233zd(E) , assuming it were substi tuted for all compounds it might replace and that the entire amount used were released , would have statistically zero impact on global atmospheric ozone (less than 0.01% change in total column ozone). Thus, EPA beli eves that use of SolsticeTM 1233zd(E) woul d result in substantially less harm to the climate and ozone layer than the continued use of ODS and other commonly used blowing agents

.

Table 2 . Atmospheric Impacts of SolsticeTM 1233zd(E) Compared with CFC

- 11 , CFC

- 113, HCFC

141b , HCFC

- 22, and HFC

- 134a

Chemical ODP GWP (100

- year) ALT SolsticeTM 1233zd(E) 0.000 2 4 a 1 b 26.0 days b CFC

- 11 1.0 c 4, 750 d 45 years d CFC

- 113 0.85 c 6,130 d 85 years d HCFC

- 141b 0. 12 c 725 d 9.3 years d HCFC

- 22 0.13 c 1,810 d 12 years d HFC

- 134a 0 1,430 d 12 years d

a Assuming SolsticeTM 1233zd(E) emissions occur with the same geographic distribution as the blowing agents it might replace (Wang et al. 2011 ).
b Hodnebrog, O. et al. (2013)

c WMO (2011)
d IPCC 4 th Assessment Report (Forster et al. 2007)



### 4. VOLATILE ORGANIC COMPOUND ASSESSMENT SolsticeTM 1233zd(E) is exempt from the definition of volatile organic compound (VOC) under CAA regulations (40 CFR § 51.100(s)). Therefore, environmental impacts from the release of SolsticeTM 1233zd(E) as a VOC are not a concern.



### 5. FLAMMABILITY ASSESSMENT SolsticeTM 1233zd(E) is not considered to be flammable at ambient temperatures and atmospheric pressure, but it can ignite when mixed with air under pressure and exposed to strong ignition sources; also, containers of SolsticeTM 1233zd(E) may rupture w hen exposed to heat or temperatures above the proposed substitute’s auto

- ignition temperature of 380°C (Honeywell 201 1 a ). SolsticeTM 1233zd(E) is not ex pected be used under pressure in flexible polyurethane foam

. By keeping Solstice TM 1233zd(E) away from all sources of ignition and high heat and adhering to the other precautions listed in the proposed substitute’s MSDS, S olstice TM 1233zd(E) does not pose a significant flammability risk

.
In addition, SolsticeTM 1233zd(E) is expected to be incorporated into a typical flexible polyurethane foam formulation (e.g., polyol blend or “B” component) consisting of up to 15% flame retardants and other materials (e.g., a co

- blowing agent such as CO 2 ) such that the concentration of SolsticeTM 1233zd(E) is expected to be less than 5% of the foam formulation by weight , further reducing flammability risk ( Honeywell 2011 b , Honeywell 2014)

. B y following the proper precautions specified by the proposed substitute’s MSDS, it is unlikely that SolsticeTM 1233zd(E) will pose a significant flammability risk.FINAL

— October 10, 2014 

### 6. POTENTIAL HEALTH EFFECTS To assess potential health risks from exposure to thi s proposed substitute, the submitter provided a workplace environmental exposure limit (WEEL) o f 8 00 ppm for SolsticeTM 1233zd(E) ( OARS 201 3 ). The WEEL represents the maximum 8

- hour time weighted average (TWA) at which a worker can be exposed regularly without adverse effects.

According to the MSDS, exposure to SolsticeTM 1233zd(E) through ocular or dermal absorption, inhalation, or ingestion may be harmful

. Ocular e xposures to SolsticeTM 1233zd(E) will cause serious eye irritation and may ca use frostbite through dermal exposure . In case of ocular exposure, the MSDS for SolsticeTM 1233zd(E) recommends that person(s) should immediately flush the eyes, including under the eyelids, with water for 15 minutes; should frostbite occur, affected areas should be rinsed with lukewarm
water . Medical attention should be sought if irritation develops or persists.

In the case of dermal exposure to SolsticeTM 1233zd(E) , the MSDS for SolsticeTM 1233zd(E) recommends that person(s) should immediately wash the aff ected area with water and remove all contaminated clothing to avoid irritation ; should frostbite occur, bathe ( do not rub) the affected area with lukewarm, not hot, water. If water is not available, cover the affected area with a clean, soft cloth. Medical attention should be sought if irritation develops or persists. SolsticeTM 1233zd(E) vapors are heavier than air an d cause suffocation by reducing oxygen available for breathing, causing asphyxiation in high concentrations. If person(s) are exposed to high concentrations, the person(s) will likely not realize that he/she is suffocating, but may experience central nerv ous system effects, such as drowsiness and dizziness. If SolsticeTM 1233zd(E) is inhaled, person(s) should be immediately removed and exposed to fresh air. The MSDS recommends that if breathing is difficult, person(s) should be given oxygen, provided a qual ified operator is present, an d medical attention be sought. SolsticeTM 1233zd(E) is not likely to be hazardous by ingestion; however, in case of ingestion, the MSDS recommends the person(s) drink a cup of water, if fully conscious, and consult a physician i mmediately

. D o not induce vomiting without medical advice. The EPA’s review of the human health impacts of this proposed substitute is contained in the public docket for this decision.

T he potential health effects of SolsticeTM 1233zd(E) are unlikely to occur w hen following good industrial hygiene practices and the PPE and engineering control (e.g., ventilation) recommendations outlined in the MSDS for SolsticeTM 1233zd(E) and Sections 7 and 8 of this risk screen.



### 7. OCCUPATIONAL EXPOSURE ASSESSMENT
This section discusses potential occupational exposures to SolsticeTM 1233zd(E) in the manufacture of flexible polyurethane foam

. Flexible polyurethane foam is estimated to have 100% first year losses

, and the majority of losses are anticipated to occur aft er manufacture

, during processing (Jeffs 2012)

. For flexible polyurethane foams, this would include removing the foam from its molds. However, the resulting occupational exposure during th is activity is not anticipated to present a significant concern (Jef fs 2012).

Although exposure data were not available for the manufacture of flexible polyurethane foam, i nstantaneous exposure concentrations were modeled for spray foam application s , which ha ve the highest exposure potential of all foam types

. Using HFC

- 245fa surrogate data provided by the submitter , the maximum modeled exposure for employees involved in the use of SolsticeTM 1233zd(E) for spray foams was 291 ppm , which is less than the 8

- hour WEEL for SolsticeTM 1233zd(E) (i.e., 800 ppm) (Honeywell 201 1a)

. Furthermore, given that 291 ppm was calculated from the maximum exposure concentration and that exposure concentrations over the time duration were significantly lower than the maximum recorded value, concentrations of SolsticeTM 1233zd(E) also would n ot reach or exceed the WEEL over an 8

- hour time

- weighted average. Because s pray foam applications have the highest exposure potential of a ll foamFINAL

— October 10, 2014 types , it is unlikely that the time

- weighted concentrations during manufacture and processing of flexible poly urethane foam would result in concentrations higher than those modeled for spray foam applications. Therefore, it is unlikely that the acceptable occupational exposure limit for SolsticeTM 1233zd(E) would be exceeded during the manufacture and processing of flexible polyurethane foam

. Although anticipated occupational exposures are well below the exposure limit for SolsticeTM 1233zd(E)

, e ngineering controls should be in place during manufacture and use of SolsticeTM 1233zd(E) , s uch as
vapo r

- in

- air detection system s. Adequate ventilation should always be established during any use, handling, or storage of SolsticeTM 1233zd(E)

. In addition, an eye wash and safety shower should be near the manufacturing facility and ready for use. In general, use of PPE is recommended, such as respiratory protection (a NIOSH

- approved positive

- pressure supplied

- air respirator is recommended where there is insufficient ventilation; self

- contained breathing apparatuses should be used for rescue and maint enance work in storage tanks), chemical splash goggles or face shield, impervious gloves, and chemical

- resistant boo ts and clothing (Honeywell 2011 a , OSHA 1994). Contaminated clothing is not to leave the workplace and must be cleaned before reuse (Honeywel l 2011 a )

. During handling of liquid SolsticeTM 1233zd(E) blowing agent for manufacture of flexible polyurethane foam, there is also a risk of generation of toxic decomposition products such as hydrochloric acid, hydrofluoric acid, and carbonyl halides if liquid SolsticeTM 1233zd(E) is exposed to fires or temperatures greater than 250°C. Containers of SolsticeTM 1233zd(E) should not be allowed to contact open flames, glowing metal surfaces, or electrical heating elements.

The EPA believes that if proper handlin g guidelines are followed in accordance with good industrial hygiene and manufacturing practices and the MSDS for SolsticeTM 1233zd(E) , as described above, manufacture of SolsticeTM 1233zd(E) foam does not present a significant risk to workers.



### 8. GENERAL POPUL ATION EXPOSURE ASSESSMENT SolsticeTM 1233zd(E) is not expected to cause a significant impact on human health in the general population when manufactured or used for the flexible polyurethane foam end use

. Because flexible polyurethane foams are estimated to lose 100% of the foam blowing agent during manufacturing and processing

, t he EPA does not anticipate c hronic general population exposures to SolsticeTM 1233zd(E) during the lifetime of the foam. Should releases during manufacturing operations occur, engineerin g controls should be used (e.g.

, carbon absorption scrubbers) to collect and prevent the release of the proposed substitute to the atmosphere. Furthermore, a t room temperature and atmospheric pressure , SolsticeTM 1233zd(E) is a gas. T herefore, releases to g round or surface water are not anticipated, as SolsticeTM 1233zd(E) is anticipated to dissipate into the atmosphere upon release to outside air.

Due to the low toxicity of SolsticeTM 1233zd(E) and its minimal expected release, the EPA believes that such exposures do not pose a significant toxicity risk, and SolsticeTM 1233zd(E) is not expected to cause a significant impact on human health in the general population when used as a foam blowing agent in flexib le polyurethane foams.FINAL

— October 10, 2014 

### 9. REFERENCES Forster, P., V. Ramaswamy, P. Artaxo, T. Berntsen, R. Betts, D.W. F ahey, J. Haywood, J. Lean, D.C. Lowe, G. Myhre, J. Nganga, R. Prinn, G. Raga, M. Schulz and R. Van Dorland. 2007. Changes in Atmospheric Constituents and in Radiative Forcing. In: Climate Change 2007:The Physical Science Basis. Contribution of Working Group I to the Fourth Assessment Report o f the Intergovernmental Panel on Climate Change [Solomon, S., D. Qin, M. Manning, Z. Chen, M. Marquis, K.B. Averyt, M.Tignor and H.L. Miller (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA.
Hodnebrog, Ø., Etminan, M., Fuglestvedt, J. S., Marston, G., Myhre, G., Nielsen, C. J., Shine, K. P., Wallington, T. J.: Global Warming Potentials and Radiative Efficiencies of Halocarbons and Related Compounds: A Comprehensive Review, Reviews of Geophysics, 51, 300

- 378, doi:10.1002/ rog.20013, 2013.

Honeywell, Inc. 2011 a . SNAP Submission to EPA for SolsticeTM 1233zd(E). May 13, 2011.

Honeywell, Inc. 2011 b

. Response to Incomplete SNAP Submission for SolsticeTM 1233zd(E)

. October 20, 2011.

Honeywell, Inc. 2012a. SolsticeTM 1233zd(E) Material Safety Data Sheet. February 28, 2012.

Honeywell, Inc. 2012b. Response to A Few More Questions on Foam Uses for SolsticeTM 1233zd(E). February 6, 2012.

Honeywell, Inc. 2012c. Response to Incomplete SNAP Submission for SolsticeTM 1233zd(E). January 31

, 2012.

Honeywell, Inc. 2014. Addendum to SNAP Submission to EPA for SolsticeTM 1233zd(E). March 4, 2014.

Jeffs, Mike. 2012. Personal communication between ICF International and Mike Jeffs. April 24

– 26, 2012.

Occupational Alliance for Risk Science (OARS). 2013. Workplace Environmental Exposure Level (WEEL): trans

- 1

- Chloro

- 3,3 ,3

- Trifluoropropene (1233zd(E)). Conducted for Honeywell International, 2013.

OSHA. 1994. General description and discussion of the levels of protection and protective gear. 1910.120 App B. Last updated August 22, 1994. Available at: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9767

U.S. EPA

. 1994. Significant New Alternatives Policy Technical Background Document: Risk Screen on the Use of Substitutes for Class I Ozone

- depleting Substances: Refrigeration and Air Conditioning. Stratospheric Protection Division. March, 1994.

U.S EPA

. 2011. Na tional Emissions Inventory Air Pollutant Emissions Trends Data. Accessed 23 December 2011. Updated October 2011. Available at: http://www.epa.gov/ttn/chief/trends/index.html#tables

U.S. EPA. 2012. Risk Screen on the Use of SolsticeTM 1233zd(E) in Rigid Polyurethane and Polyisocyanurate Laminated Boardstock; Rigid Polyurethane Appliance, Commercial Refrigeration, Spray, and Slabstock; Integral Skin Polyurethane . Stratospheric Protectio n Division. August 2012.FINAL

— October 10, 2014 Wang D., Olsen S., Wuebbles D. Undated. “Three

- Dimensional Model Evaluation of the Global Warming Potentials for tCFP.” Department of Atmospheric Sciences. University of Illinois, Urbana, IL. Draft Report.

Wang D., Olsen S., Wueb bles D. 2011. “Preliminary Report: Analyses of tCFP’s Potential Impact on Atmospheric Ozone.” Department of Atmospheric Sciences. University of Illinois, Urbana, IL. September 26, 2011.

WMO (Wor ld Meteorological Organization). 2011. Scientific Assessment of Ozone Depletion: 2010

, Global Ozone Research and Monitoring Project

— Report No. 52, 516 pp., Geneva, Switzerland, 2011.