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Sent via Email

February 1 , 2016

Cindy Newberg, Chief

Alternatives and Emissions Reduction Branch Office of Atmospheric Programs U.S. Environmental Protection Agency 1200 Pennsylvania Ave. NW Washington, DC 20460 newberg.cindy@epa.gov

Re: Spray Polyurethane Foam End Uses under the Significant New Alternatives Policy Program

Dear Ms. Newberg:

The American Chemistry Council’s Center for the Polyurethanes Industry 1 (CPI) and Spray

Foam Coalition 2 (SFC) app reciate the continued engagement of the U.S. Environmental Protection Agency’s (EPA) Significant New Alternatives Policy (SNAP) program on regulatory issues that impact the polyurethanes industry. T his letter provide s information specific to spray polyuret hane foam (SPF) end uses in anticipation of regulatory action under the SNAP program. 3
If additional information is required, w e would be pleased to facilitate a dialogue between EPA

SNAP staff and SPF manufacturers

.

CPI and SFC members are committed to continuing the manufacture of foam products that deliver consistent performance , advance building energy efficiency, and limit env ironment al impacts like greenhouse gas emissions

.

1 The Center for the Polyurethanes Industry (CPI) of the Ame rican Chemistry Council serves as the voice of the polyurethanes industry in North America, promoting its development and coordinating with polyurethane trade associations across the globe. The polyurethane industry supports research and initiatives that s erve its communities and customers. The business of polyurethane is a $26.5 billion enterprise and a key element of the U.S. economy. The industry operates in more than 1,000 locations in the U.S. and directly employs more than 46,500. A major job

creator in the U.S., each job in the polyurethanes industry yields five more jobs indirectly for an approximate total of 235,000 jobs supported.

2 The Spray Foam Coalition (SFC) champions the use of spray polyurethane foam in U.S. building and construction applic ations and promotes its economic, environmental and societal benefits while supporting the safe manufacture, transport, and application of spray polyurethane foam. SFC consists of manufacturers of spray polyurethane foam systems as well as suppliers of ra w materials and machinery used to apply the foam.

3 CPI and SFC submitted comprehensive comments on polyurethane end uses during the notice and comment period for Rule 20 ( 40 C.F.R. Part 82, July 20, 2015) . This letter supplements our previous submission.Page 2 of 3

We understand that EPA SNAP staff is performing a more extensive comparati ve risk

assessment of blowing agents with low global warming potential (GWP) that may be candidate replacements for existing substances used in SPF products . At the same time, members of the SPF industry have advanced work to commercialize products using n ew low

- GWP substitutes

where research and development have produced technically feasible solutions

. Several of these successes were featured during a White House event last October and future plans to

commercial ize new products using low

- GWP blowing agents were also announced during the

event

. 4 Other manufacturers continue to evaluate alternative substances and conduct the necessary research and development to potentially launch new product formulations.

Given the dynamic and diverse nature of the SPF ind ustry, we urge EPA SNAP staff to consider

manufacturer

- specific data and information regarding the suitability of alternative substances. Based on their unique knowledge and experience, manufacturers are the best source s for data and

information to complem ent EPA’s work under the risk assessment and inform future regulatory

action.

SPF products can generally be grouped into three categories: two

- component, high

- pressure systems; two

- component, low

- pressure systems; and one

- component foam products. These categories were recognized in the final Rule 20

. 5 T he se categories offer a useful way to group SPF products for purposes of rulemaking because each product category has its own unique performance requirements, testing process es
, applications, and formulati on challenges regardless of the substitute chemical. Furthermore, the product categories offer EPA SNAP staff the opportunity to account for the relevant differences between product types when deciding on actions concerning the suitab ility of alternative s ubstances

.

SPF manufacturers are well

- positioned to provide EPA SNAP with information on the suitability of blowing agent alternatives for their specific formulations

. In each SPF product category,

manufacturers combine proprietary blends of chemical com ponents to create formulations with unique performance attributes. As a result, manufacturers can provide EPA SNAP staff with specific feedback on the successes and challenges of working with alternative substances

. M anufacturers are also well

- positioned t o explain meaningful differences between product

formulation s that may impact the selection of alternative blowing agents.

As we have emphasized in previous comments, replacing an SPF chemical component requires

the manufacturer to reformulate. There are typically no drop

- in replacements for SPF chemical

components . This is true regardless of the specific chemical component being analyzed for replacement. After researching and developing a candidate formulation, manufacturers must test products to third p arty and interna l standards and specifications , and regulatory requirements

.

4 White House Fact Sheet: Obama Administration and Private

- Sector Leaders Announce Ambitious Commitments and Robust Progress to Address Potent Greenhouse Gases, October 15, 2015. Available at: https://www.whitehouse.gov/the

- press

- office/2015/10/15/fact

- sheet

- obama

- administration

- and

- private

- sector

leaders

- announce

.

5 Protection of Stratospheric Ozone: Change of Listing Status for Certain Substitutes under the Significant New Alternatives Policy Program , 40 C.F.R. Part 82, July 20, 2015.Page 3 of 3

SPF products differ from other polyurethane foam systems in that the products are typically applied in the field under a wide range of environmental conditions (e.g., temperatur e, humidity). These varying environmental conditions can impact SPF product performance and present challenges to manufacturers that may not be present for products used in the controlled

environment s of manufacturing facilities. Therefore, SPF m anufacture rs must test candidate formulations under these variable conditions before commercializing a new product regardless of

the candidate chemical component being studied

. And like all testing and development issues, manufacturers are best positioned to provide EPA SNAP staff with information on the successes and challenges of developing low

- GWP formulations.

Finally, SPF manufacturer s can also provide EPA SNAP staff with additional information and insight into the SPF market, which may include factors that im pact the selection or suitability of alternative blowing agents. For example, the market channels used to sell SPF products (e.g., distribution, direct sales) may vary by system type or manufacturer. C ertain manufacturers may sell SPF systems through dist ribution. Products sold through distribution will typically require longer shelf lives as compared to products sold direct to contractors. SPF manufacturers will want to ensure new product formulations meet the demands of their preferred market channel

i rr espective of the chemical component being replaced. Regarding the current issue

, manufacturer s will have information describing how the selection of a blowing agent may impact

their abil ity to maintain existing market channels and can provide specifics on the necessary shelf lives for their products

.

CPI and SFC would be pleased to facilitate a dialogue between EPA SNAP staff and SPF

manufacturers to answer any outstanding questions regarding SPF end uses and alternative low

GWP substances. Please contact me at lee_salamone@americanchemistry.com , (202) 249

- 6604,

or Justin Koscher, justin_koscher@americanchemistry.com , (202) 249

- 6617, should any questions or information gaps arise.

Kind regards,

Lee Salamone, Senior Director

Cc: Margaret Sheppard
sheppard.margaret@epa.gov