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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 Industry1(CPI) and Spray 

Foam Coalition2(SFC) appreciate 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. This letter provides information specific to spray 

polyurethane foam (SPF) end uses in anticipation of regulatory action under the SNAP program.3

If additional information is required, we 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 environmental 

impacts like greenhouse gas emissions.

 

1 The Center for the Polyurethanes Industry (CPI) of the American 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 serve 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 

applications 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 raw 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 comparative 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 new 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 

commercialize 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 industry, 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 sources for data and 

information to complement 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

These categories offer a useful way to group 

SPF products for purposes of rulemaking because each product category has its own unique 

performance requirements, testing processes, applications, and formulation 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 suitability of alternative substances. 

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 components 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. 

Manufacturers are also well-positioned to explain meaningful differences between product 

formulations 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 party and internal 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-sectorleaders-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., temperature, 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 

environments of manufacturing facilities. Therefore, SPF manufacturers 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 manufacturers can also provide EPA SNAP staff with additional information and

insight into the SPF market, which may include factors that impact 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. Certain manufacturers may 

sell SPF systems through distribution. 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 

irrespective of the chemical component being replaced. Regarding the current issue, 

manufacturers will have information describing how the selection of a blowing agent may impact 

their ability 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 lowGWP 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