United States

ENVIRONMENTAL PROTECTION AGENCY

Washington, DC 20460

AGENCY USE ONLY

OMB Control No.: 2060-0226

Expires: 8/31/2014

SNAP INFORMATION NOTICE

For Significant New Alternatives

Date of Receipt:

Date 90 Day Review Begins:

Date Review Completed:

CBI Status:

When completed send this form to:

Via US Postal Service: Via Overnight Delivery Service:

SNAP DOCUMENT CONTROL OFFICER SNAP DOCUMENT CONTROL OFFICER

OFFICE OF AIR AND RADIATION, 6205 J U.S. EPA

U.S. EPA 1310 L STREET NW

1200 PENNSYLVANIA AVE NW 10th FLOOR (MC 6205J)

WASHINGTON, DC 20460 WASHINGTON, DC 20005

Enter the total number of pages in your SNAP information Notice: 54 Document Control Number

INTRODUCTION

GENERAL INSTRUCTIONS

This form may be used to submit information under the Significant New Alternatives Policy (SNAP) program for the review of 

alternatives to class I and class II ozone-depleting substances (ODS) under section 612 of the Clean Air Act. Submitters are 

required to provide this information on new substitutes to assist the Agency in assessing the acceptability of chemicals or 

processes that are considered alternatives for ODSs. A separate notice must be filed for each alternative you are submitting.

PAPER SUBMISSIONS: All paper submissions must be provided in three complete copies. If information is to be claimed as 

confidential, all confidential information must be excised from one of the copies, which will be placed in the public docket; the 

other two copies must include the confidential material. If no claims of confidentiality are made for the submission, all copies 

must be identical.

CD-ROM SUBMISSIONS: The SNAP program also accepts submissions via CD-ROM. If information is to be claimed as 

confidential, all confidential information must be excised from one of the files on the CD-ROM, which will be placed in the public 

docket; the other file must include the confidential material. The file with the confidential material must include “contains CBI” in 

the file name.

STEP-BY-STEP INSTRUCTIONS: The Instructions for the SNAP Information Notice and TSCA/SNAP Addendum (“Instructions”)

are designed to assist applicants in completing this form. The Instructions provide step-by-step guidance on submitting a SNAP 

notice, asserting confidentiality claims, completing the notice form, sector-specific data requirements, and submitting test data 

and supplemental information.

To facilitate Agency review of alternatives, this form must be filled out as completely as possible. Please provide all information 

requested to the extent that it is known or reasonably ascertainable. Make reasonable estimates if actual data is unavailable.

TYPE OF NOTICE (Check only one box)

Select the appropriate box identifying the type of notice submitted:

Manufacturer Submission: New alternative, Substance, or Formulation___________________________________________X

Petition: New alternative, Substance, or Formulation__________________________________________________________

Petition: Revision of the Existing SNAP list__________________________________________________________________

Petition: Request to Grandfather Use of An Unacceptable Substitute_____________________________________________

Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

Previous editions are obsolete

1
Part I - GENERAL INFORMATION

You must provide the identity of the alternative chemical or

processes and the identity and percentages of all 

components in a blend and/or process, even if you claim the 

identity as confidential. You may authorize another person 

to submit the identity for you, but your submission will not be 

complete and review cannot begin until EPA receives this 

information.

Part II - ALTERNATIVE-SPECIFIC INFORMATION

 

Please indicate the sector(s) for which you are submitting 

information on the substitute by checking the appropriate 

boxes:

• Refrigeration and Air Conditioning  

• Foam Blowing X

• Solvent Cleaning  

• Fire Extinguishing 

and Explosion Prevention 

• Sterilization 

• Aerosols 

• Adhesives, Coatings, and Inks 

• Tobacco Expansion 

• Pesticides 

You may need additional copies of Part II if there are several 

manufacturing, processing, or use operations that you will 

describe in this notice. Please reproduce these sections as 

needed.

If your substitute is also subject to review under FIFRA, 

provide the FIFRA Registration Number:

_____________________________

Part III - RELEASE AND EXPOSURE DATA

Please reproduce additional copies of Part III as necessary.

Part IV - LIST OF ATTACHMENTS

Please attach additional sheets if you do not have enough space on 

the form to fully answer a question. Label each continuation sheet 

with the corresponding section heading and the question. In part 

IV, list these attachments and any test data, other data, or any 

optional information that you include in this notice.

TEST DATA AND OTHER DATA

You are required to submit all test data in your possession or 

control and to provide a description of all other data known to you if 

these data are related to the health and environmental effects of 

the manufacture, processing, distribution in commerce, use, or 

disposal of the alternative. Standard literature citations may be 

submitted if they do not appear in the open scientific literature. 

Complete test data (in English), not summaries of data, must be 

submitted if they do not appear in the open literature. The following 

are test data and other data that might be submitted (see the 

Instructions for a more complete list of data to be submitted.) 

Please indicate test data to be included in your submission notice 

by checking the appropriate boxes:

• Health Effects Data X Yes No

• Flammability Data X Yes No

• Environmental Effects 

Data X Yes No

• Environmental Fate 

Data X Yes No

• Risk Assessments X Yes No

1. Test Data Not in the Possession/

Control of the Submitter Yes X No

• Other Data X Yes No

CONFIDENTIALITY CLAIMS

Anyone submitting information must assert a claim of confidentiality at the time of submission for any data which are to be treated as 

Confidential Business Information (CBI). Substantiation of this claim must also be provided at this time. All information claimed as 

CBI will be treated in a manner consistent with 40 CFR Part 2, Subpart B. Failure to assert a claim of confidentiality at the time of 

submission may result in disclosure of information by the Agency without further notice.

To assert a claim on this form, circle or bracket the information you claim as confidential and mark the confidential box at the bottom 

of the page. Then provide substantiation of this claim on an attachment to the notice. If any information is claimed as confidential, 

you must provide a “sanitized” version of this notice, including attachments, to EPA with your submission. For additional information 

on claiming information as confidential, please see the Instructions Manual.

Information submitted as CBI may be accessed by companies designated as Authorized Representatives of the United States 

Environmental Protection Agency (EPA) under an EPA contract for the purpose of assisting EPA in the development and 

implementation of national regulations for the protection of stratospheric ozone, including the development of the SNAP program. 

These Authorized Representatives may have access to any information received by the Stratospheric Protection Division within the 

EPA Office of the Atmospheric Programs for use in reviewing the need for possible control of any substance, practice, process or 

activity that may reasonably be anticipated to affect stratospheric ozone. Access to such information is necessary to ensure that 

these companies can complete the work required by the contract.

Authorized Representatives of the Administrator are subject to the provisions of 42 U.S.C. 7414(c) respecting confidential business 

information as implemented by 40 CFR 2.301(h).

Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

Previous editions are obsolete

2
Part I - GENERAL INFORMATION

Section A - SUBMITTER IDENTIFICATION

1. (a) Person Submitting Notice (in U.S.)

Chris Martin 

_____________________________________________________________________________________________________________

Name of Authorized Official Title

Holland Applied Technologies 

___________________________________________________________________________________________________

Company/Organization

7050 High Grove Blvd. Burr Ridge, Illinois 60527 Phone: 630-325-5130 Fax: 630-325-5161

____________________________________________________________________________________________________________

Mailing Address Telephone & Fax Numbers 

chris.martin@hollandapt.com

____________________________________________________________________________________________________________

E-mail Address

(b) Agent (if applicable)

Angelina Duggan, PhD. Senior Managing Scientist

_________________________________________________________________________________________________________

Name of Authorized Official Title

Exponent, Inc Health Practice Center for Toxicology and Mechanistic Biology

______________________________________________________________________________________________________

Company/Organization

1150 Connecticut Avenue Suite 1100 Washington, DC 20036

___________________________________________________________________________________________________________

Mailing Address Telephone & Fax Numbers 

aduggan@exponent.com Fax: 202-772-4979; Cell: 646-660-2677

____________________________________________________________________________________________________________

E-mail Address

(c) Joint Submitter (if applicable)

_________________________________________________________________________________________________________

Name of Authorized Official Title

____________________________________________________________________________________________________

Company/Organization

____________________________________________________________________________________________________________

Mailing Address Telephone & Fax Numbers 

_____________________________________________________________________________________________________

E-mail Address

2. Technical Contact (in U.S.)

Angelina Duggan, PhD. Senior Managing Scientist

__________________________________________________________________________________________________________

Name of Authorized Official Title

Exponent, Inc Health Practice Center for Toxicology and Mechanistic Biology

_________________________________________________________________________________________________________

Company/Organization

1150 Connecticut Avenue Suite 1100 Washington, DC 20036

________________________________________________________________________________________________________

Mailing Address Telephone & Fax Numbers 

aduggan@exponent.com Fax: 202-772-4979; Cell: 646-660-2677

___________________________________________________________________________________________________

E-mail Address

3. If you have had a prior communication with EPA concerning this notice, note the date and type of communication (letter, phone, 

etc.) and the EPA staff person’s name:

January 14 and 16, 2014: Margaret Sheppard Telephone Conferences to discuss general SNAP application and process questions

Mark (X) if None ________________ 

Mark (X) this box if this page contains CBI __________ 

Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

Previous editions are obsolete

3
Part I - GENERAL INFORMATION (continued)

Section B - ALTERNATIVE IDENTIFICATION

1. Commercial/Trade name (s) of alternative:

Methylal

2. (a) Name of chemical(s) (preferably IUPAC nomenclature) and/or process name. For blends, provide the percent composition of each 

constituent. For powdered aerosols used in fire suppression, see page 11 of the Instructions for additional necessary composition information.

 (b) Chemical Abstracts Service (CAS) registry number and molecular formula.

 (c) For alternative processes and technologies describe the technology and provide a diagram of the system. Also provide the information 

on any chemical constituents.

 (d) If you have applied for or hold a patent on the substitute, provide the patent name, number (if available), and information on the topics 

covered in the patent.

Methane, dimethoxy-(CAS Nomenclature; CAS RN 109-87-5) is a mono constituent chemical substance that 

belongs to a class of chemicals referred to as acetals. Acetals are derived from the acid condensation of aldehydes 

and alcohols. As such, acetals are not chemically analogous to ethers.

Dimethoxymethane (EINECS 203-714-2) is the IUPAC and EU designation. The molecular formula is C3H8O2. 

Figure 1. Methylal Structure 

CAS 109-87-5

The most often used common name is methylal and this designation for CAS 109-87-5 will be used throughout 

this SNAP application. The structure of methylal (Methane, dimethoxy-) is illustrated above in Figure 1.

Other common names include: Formal; Formaldehyde Dimethyl Ether; Dimethylformal; Methylene Dimethylate; 

Methylene Dimethyl Ether; Methylene Glycol Dimethyl Ether; Formaldehyde Dimethyl; Formaldehyde 

Dimethylacetal; Anesthenyl; Bis(Methoxy)Methane; Dimethoxymethane; Dimethyl Formal Formaldehyde; 

Methyl Ketal; Methoxymethyl Methyl Ether; Formaldehyde Dimethoxy Acetal; M-222 ; Methyl Formal ; HSDB 

1820

The CAS IES Report is included as Attachment 1. 

3. Generic name:

If the name of the substitute is declared Confidential Business Information, provide a generic name.

None

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Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

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4. Specific End-Use (a) Describe each end-use that may be reasonably anticipated for the alternative. Be sure to provide a broad description 

(e.g., terpene-based semi-aqueous solvent cleaner for electronic parts, or HFC substitute refrigerant for centrifugal chillers). For a list of end 

uses, see Appendix A to the Instructions, beginning on p. 23. If the alternative is a refrigerant, indicate whether it is a candidate for use in 

retrofits of existing equipment, for use in new equipment only, or both.

 (b) Identify the ODS and the quantity of substitute needed to replace it for each end use in pounds (i.e., the replacement ratio).

[Current and Proposed Use CBI Has Been Removed]

EPA and international regulators have mandated the replacement of ODS substances such as, CFC-11, CFC-12, 

CFC-113, CFC-114, HCFC-141b, HCFC-142b and HCFC-22. Since methylal does not contain any halogen 

atoms, it is therefore by definition not classified as an ozone depleting substance. As such, methylal is a suitable

replacement for the ODS chemicals, such as HCFC-141b, that were previously used as blowing agents in the 

preparation of polyurethane foams. 

Methylal has already been approved by the United Nations Development Program (UNDP) as a potential 

replacement of HCFC-141b (refer to Attachment 2a (the summary report) and 2b (the full report and analysis)): 

Methylal as Blowing Agent in the Manufacture of Polyurethane Foam Systems (March 2012). 

[Current and Proposed Use CBI Has Been Removed]

(b) HCFC-141b can be generally replaced by approximately 70% of methylal (i.e., 100 lbs of HCFC-141b can be 

replaced by 70 lbs of methylal). This is linked to the difference in molecular weight. But this is not a strict 

percentage because it can vary from one formulation to the other.

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Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

Previous editions are obsolete

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Part I - GENERAL INFORMATION (continued)

Section B - ALTERNATIVE IDENTIFICATION (Continued)

As a result of its in-depth project assessment, UNDP (2012, Attachment 2a) concluded the following; key points 

have been bolded:

“As a result of the project, it can be concluded that methylal can serve as a feasible 

alternative blowing agent to replace HCFC-141b in PU foam applications...The final project 

report also provided recommendations for setting up the technological process of using methylal 

as a blowing agent to ensure safety and environmental considerations. The use of methylal 

instead of HCFC-141b will have a significant positive impact on climate: methylal’s GWP is 

negligible compared to the GWP for 725 HCFC -141b (IPCC Fourth Assessment Report, 

2007). The project also considered cost of conversion and found them to be similar to the use of 

HCFC-141b. However, the costs will depend on the local economic and market conditions.”

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OMB Control No.: 2060-0226

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5. Impurities

 (a) Identify each impurity that may reasonably be anticipated to be present in the chemical alternative as manufactured for commercial 

purposes. If there are unidentified impurities, enter “unidentified.”

 (b) Provide the CAS Registry Number for each impurity if available.

 (c) Estimate the maximum weight percentage of each impurity. If there are unidentified impurities, estimate their total weight 

percentages.

Methylal will be manufactured at the Lambiotte & Cie S.A. plant at Grand ‘Rue 79 B-6724, Marbehan, Belgium 

and imported into the United States. 

Methylal is generally manufactured through an acid-catalyzed dehydration reaction that includes two molar 

equivalents of methanol and one molar equivalent of formaldehyde. Formaldehyde is produced from the 

oxidation of methanol which is derived from natural gas, an abundant substance in nature. The overall reaction 

sequence of the production process is indicated below in Figure 2. Unlike hydrocarbon blowing agents (e.g., 

pentane and or cyclopentane), the production of methylal does not consume non-renewable oils. 

Figure 2. Methylal Production Process 

Natural Gas Synthesis gas CH3-OH

 [O] Methylal

 

 CH2O

It should also be noted that biosourced methanol, albeit more expensive, is now also available. Therefore,

methylal could, in the future, be prepared from biosourced methanol if the economics eventually become more 

attractive.

[Manufacturing CBI Has Been Removed]

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Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

Previous editions are obsolete

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6.Byproducts:

 (a) Describe any byproducts or degradation products resulting from the manufacturer, processing, use or disposal of the chemical alternative 

or chemicals used in the new alternative. If there are unidentified byproducts/ degradation products enter “unidentified.” 

 (b) Provide the CAS Registry Number for each byproduct or degradation product if available.

 (c) Indicate where the byproduct/degradation product is formed (e.g. during manufacturing, during use, in case of fire, etc.) and the amount 

or rate at which it is formed.

a) There are no identified by-products or degradation products that would result from either the 

manufacturing process or the use of methylal as a PU blowing agent under the conditions recommended 

by Lambiotte. 

b) Not applicable

c) In case of severe fire or combustion, methylal would produce non-noxious substances, i.e., carbon 

dioxide and water. Methylal is thermally stable for 7 days at 200° (Attachment 2b UNEP, 2012 page 

17).

d) Methylal is also stable against peroxide formation, since there is no need to blanket the chemical with an 

inert gas. Experimental results confirm there is no formation of peroxides after 1143 days. Refer to 

information in Attachments 3ga and 3gb. 

e) [Manufacturing CBI Has Been Removed]

Mark (X) this box if this page contains CBI __________ 

Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

Previous editions are obsolete

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Part II - ALTERNATIVE-SPECIFIC INFORMATION1, 2,3

Section A - PHYSICAL AND CHEMICAL PROPERTIES – See Appendix B to the Instructions to see which 

properties apply to which uses.

1. Molecular weight 76.09 2. Physical state at 20 oC Clear Liquid

3. Melting point at 1 atm. pressure o C -95.38 (EPI SuiteTM calculation) 4. Boiling point at 101.3 hPa 42.3 oC

5. Specific gravity (relative density) 0.861 g/mL @20 oC 6. Odor Threshhold N/D mg/m3

7. Solubility using solvent @ temperature oC g/L Miscible with alcohol, ether and oils

8. Solubility in water @ temperature 323,000 mg/L @ 16 oC (32% by 

weight; solubility of water in methylal is 4% by weight

9. Partition coefficient Log Kow 0.00 (experimental) Log K

Log Kow -0.19 (calculated)

10. Vapor pressure @ 20o C 40,000 Pa 

(Also provide vapor pressure-temperature curve for refrigerants.)

11. Critical temperature 

215.2 oC

12. Critical 

Pressure 

psi

13. Are spectra attached? Yes refer to Attachment 3 14. Disassociation constant in water pKa 3.1

15. Particle size distribution: N/A 16. Volatilization from soil: N/D

17. Volatilization from water: Henry’s Database (EPI SuiteTM) 0.000173 

atm-m3/mole 

18. Viscosity @ 20 oC 0.325 mPa.s

19. pH@concentration: N/D 20. Thermal conductivity (for foam blowing 

agents

See Table 3 below:

λ (10-2, W/m.K) = 1.45; T (oC) = 41.85

λ (10-2, W/m.K) = 2.0390; T (oC) = 109.85

21. Adsorption coefficient: Not Determined 22. Flammability limits (LFL, UFL) 2.2

(or 71 g/m3)-19.9 % (or 630 g/m3 vol)

23. Flash point: -30.5 oC @101.3 hPa 24. Heat of combustion: 

ΔfH°gas = 348.2 ± 0.79 kJ/mol3

25. Maximum pressure rise: Illustrated in Attachment 2b on page 71/105. 26. Maximum rate of pressure rise: Illustrated in 

Attachment 2b on pages 71/105.

27. Other (specify) GWP: Negligible 

Not corrosive; not oxidizing; no chemical explosive chemical groups

Auto Ignition: 235 oC

1 The data entered into the Part II Section A table above are derived from the calculations and experimental data 

included in the EPA publically available model EPI SuiteTM 4.1 calculations (Refer to Attachment 4a (ultimate 

degradation) and 4b (primary degradation). 

2 Physicochemical data are included in Attachment 4 Methylal EpiSuite 4.1 Calculations and Attachment 5

Lambiotte Dimethoxymethane Chemical Safety Assessment Report on pages 1-4. 

3 Methylal National Institute of Standards and Technology Material Measurement Laboratory 

http://webbook.nist.gov/cgi/cbook.cgi?ID=C109875&Mask=1F.

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OMB Control No.: 2060-0226

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28. Flammability: Provide any information on flammability concerns. For example, if any abatement techniques are being used 

to minimize the risks associated with flammable substances or mixtures, detail those techniques below. If a substitute is 

flammable, an assessment of overall risk in each end-use may be required. For flammable refrigerants, provide a fault tree 

analysis for each end use. 

For flammable foam blowing agents used in spray foam, provide a training program that addresses flammability concerns 

specific to this substitute. (See Appendix B to Instructions for sector-specific data requirements for flammable substances).

Methylal has been classified as a flammable liquid Class II (highly flammable) due to its having a flash point of -

30.5 oC and a boiling point of 42.3 oC. See Attachment 5: Methylal CSR (11-20-2012), Pages 3 and 4. 

However, with a boiling point of ca 42.3 oC and vapor pressure (44.0 kPa at 20o

C and 126.3 kPa @ 50oC), the 

physicochemical properties of methylal are also ideal for its intended use as a foam blowing agent. Overall, 

methylal is less flammable than blowing agents such as n-pentane, isopentane and methyl formate all of which are 

flammable liquid Class I. 

The suitability of replacement blowing agents is generally classified according to their boiling points. Table 3

below compares the boiling points of various chemicals that are currently or previously used as foam blowing 

agents. The values reported below are from various publically available sources. 

Table 3 Comparison of Methylal Boiling Point with Other Blowing Agents

Product Structure Boiling Point o

C

Cyclopentane (CH2)5 49

Methylal CH3-O-CH2-OCH3 42.3

Methylene Chloride CH2Cl2 40

HFC-365-mfc CF3CH2CF2CH3 40

n-Pentane CH3-(CH2)3-CH3 36

Methyl Formate CH3-O-CH=O 31.5

HCFC-141b CH3-CCl2F 32

Isopentane CH3-CH(CH3)-CH2-CH3 28

HFC-245fa CF3-CH2-CHF2 15

HFC-134a CH2F-CF3 -26

Liquid Carbon Dioxide CO2 Gas

Training program for use of methylal as a blowing agent: 

On the basis of the acute, subchronic repeat dose toxicology and mutagenicity testing provided in Part 3 Section A, 

it can be concluded that methylal is can be used safely by workers with proper personal protective equipment and 

ventilation. Thus, ensuring the safe use of methylal as a foam blowing agent is contingent on providing workers with 

specific information about its flammability and most especially how to minimize the risk of fires. This information 

is included in the MSDS (refer to Attachment 7) and is also reviewed in Section E Occupational Exposure at EndUse. In addition, the UNDP (Attachment 2b, 2012 page 73/105) has provided recommendations for systems houses 

that process pure grade methylal and for downstream users that process polyol and or isocyanate blends. The 

UNDP’s complete assessment of methylal’s flammability is included on pages 60-73/105 of Attachment 2b. 

. 

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10
The UNDP (Attachment 2b, 2012 on page 73/105) has concluded that:

“Methylal as a pure liquid is very flammable and requires proper safeguards. The risk of 

detonation or explosion is, however, remote because of its low heat of combustion....

Table 4 illustrates the comparative heats of combustion of methylal with other blowing agents and ethanol in its 

capability to replace HCFC-141b. UNDP (2012, Attachment 2b, page 70/105) also provided the following 

comments regarding combustibility and its suitability to replace HCFC-141b. 

“Combustability - a blowing agent is commonly stored and processed as a liquid but turns into a 

gas as part of a foam expansion, due to exothermic reaction between water and isocyanate (and to 

a lesser extent polyol and isocyanate), expanding the still liquid reaction mixture and filling the 

generated foam cells. Addressing the combustibility of a blowing agent as a liquid is equally 

important as of a gas. For instance, HCFC-141b is not flammable as a liquid but its vapors may 

still burn. As it easily generates vapors at ambient conditions, it should also be tested for gaseous 

flammable properties. HCFC-141b is therefore frequently listed in an MSDS as “moderately” 

flammable or simply “yes”3

. Methylal is on the other side, (is) even as a liquid flammable (which 

does not necessarily imply explosive). Its burning potential is very much like alcohol [ethanol],

i.e., it burns with low energy, blue flame and its energy of combustion is very low much - more 

like HCFC-141b than pentanes...”

Table 4 Heat of Combustion for Methylal and Other Blowing Agents

Substance Heat of Combustion (kcal/g) Comments

HCFC-141b 1.9 --

Methylal 6.1 --

Ethanol 7.1 --

Pentane (Commercial Mix) 11.5 Cyclopentane estimated to be 10% lower

1. Panov, GE, and Polozkov, V.T., “Flammable Substances, Encyclopedia of Occupational Health and Safety, 3rd edition, International 

Labor Office Geneva, pages 881-883 (1983). 

As noted above, the application of methylal in spray foams (which provide insulation on roofs and in walls) 

necessitates a special training program to address flammability concerns. Lambiotte has not developed a specific 

training program for the use of methylal in spray foam applications. But, it should be taken into consideration that 

the risk of flammability in spray foam applications may be reduced by either increasing the amount of water (that 

results in a decrease in the amount of methylal) or by blending methylal with HFC-245fa or HFC-365mfc/HFC227fa. 

[Reduced Flammability CBI Has Been Removed]

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11
Highly viscous polyols (unless made less viscous in system formulations) do not provide good quality polyurethane 

foams. Table 5 demonstrates that increasing the content of methylal provides a decrease in viscocity of the methylal 

polyol mixture. 

Table 5 Reduction in Polyol Viscosity by Increasing the Concentration of Methylal

The flash point depends on the viscosity and /or the nature of the polyol. Polyols of higher viscosities give higher 

flash points, but are undesirable for manufacturing polyurethane. Blending methylal with polyols results in both a 

decrease of polyol viscosity and for the mixture higher a closed cup flash point compared to neat methylal. Table 6

below indicates that blends of various polyols with methylal have a high closed cup flash point. Polyols of higher 

viscosities give higher flash points and as such, may have a more dramatic effect in reducing the potential for 

methylal flammability. However, polyols of even of low viscosity, that include 8% of methylal, do not ignite in the 

presence of a flame. 

Table 6 Closed Cup Flash Point Reduction with Blends of Polyol and Methylal 

Blend % (w/w) Flash point (closed cup) (°C) Abel IP 170 Flash Point Analyzer)

Polyol Methylal Polyol (visco 

at 22°C : 930 

mPa.s) 

Tercarol 

8092 

(viscosity at 

25°C: 14500 

mPa.s) 

Terate 2033 Terate 2541 Terate 7541 

100 0

99.5 0.5 >70.0

99 1 48

98.5 1.5 39.0 58.0 56.0 47.0

98 2.0 25.5 45.0 53.0 37.0 35.5

96 4 9.0 31.5

Blends of polyols with very high amounts of methylal, i.e., ~ 10% which is above the quantity usually used for foam 

production, show as illustrated in Table 7 below (UNDP, 2012 Attachment 2b), a low tendency for combustion. In 

Europe, this point is very important for systems houses because European legislation states that, if the flash point of 

a blend is between 21°C and 55°C, and the blend does not contribute to the combustion, the substance does not need 

to be labelled as flammable. The EU ANNEX VI: General Classification and Labelling Requirements for 

Dangerous Substances And Preparations is included as Attachment 6, refer specifically to Pages 7-8. 

Generally, it is the specific polyol system formulations that will be sold to customers to use in the manufacture of 

polyurethanes with specific isocyanates and not as the unformulated neat methylal. As such, polyol systems 

formulations will have controlled flammability and are not labeled as flammable. 

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Composition % w/w Viscosity (mPa.s)

Polyol Methylal Tercarol 8092 

(at 20°C)

Polyol 

(visco at 22°C : 

930 mPa.s)

100 0 21840 930

98 2 8740 700

96 4 4566 500

94 6 3183 380

92 8 1416 300

90 10 448 235

85 15 361 140

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However, neat methylal may also be sold to producers (in lesser quantities) of finished polyurethane products. That 

is, manufacturers of polyurethane products that do not buy polyol process system formulations, but produce both the 

polyurethane process formulations and finished polyurethane in the same manufacturing facility. Methylal for these 

polyurethane manufacturers will be labeled as flammable. However, neat methylal drums should be grounded to 

prevent ignition from electrical sparks.

Table 7 Reduction in Combustibility for Blends of Polyol and Methylal

Blend % (wt/wt) Combustion Description (in the presence of a flame)

Polyol Methylal

98 2 No ignition

96 4 No ignition

94 6 No ignition

92 8 No ignition

90 10 Single ignition of the vapors; no further ignition in the 

presence of a flame

88 12 Ignition of the vapors; can be repeated, but is selfextinguishing

86 14 Continuous burning

• Methylal is also miscible with pre-polymer isocyanates products (e.g., Suprasec 5025 Isocyanate). Thus, 

alternatively, in some cases, methylal may be sold mixed with isocyanate and then reacted with a polyol. 

The methylal-isocyanate mixtures are also not labeled as flammable. Table 8 illustrates that closed cup 

flash points of blends of isocyanate with a low percentage of methylal are high with a low risk of 

flammability. 

Table 8 Closed Cup Flash Points with Blends of Isocyanate and Methylal

Product Closed Cup Flash Point OC

Suprasec 5025 Isocyanate Methylal

99.5 0.5 > 70.0 

99.0 1.0 46.0 

98.5 1.5 29.0 

98.0 2.0 23.0 

97.5 2.5 18.0 

97.0 3.0 12.0 

96.5 3.5 8.0 

96.0 4.0 4.0 

To summarize, the above data in Tables 7 and 8 confirm that the risk of methylal flammability can be significantly 

reduced and controlled for its use as a foaming agent during the reaction of polyols with isocyanate to prepare 

polyurethanes.

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1. Ozone-depletion potential (ODP):

 (a) Provide the 100 year ODP of the alternative relative to CFC-11, if known. If the substitute is a blend, provide the ODPs of the 

individual constituents. Reference the source for each ODP.

 (b) Provide any additional data on the ODP of the alternative (e.g. atmospheric lifetime, chlorine or bromine loading potentials). Reference 

the source of this information and attach any supporting documentation.

Methylal does not contain any halogen (F, Cl, Br) atoms and therefore is not designated as either a Class I or 

Class II Ozone Depleting Substance (ODS).

 

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Part II - ALTERNATIVE-SPECIFIC INFORMATION (Continued)

Section B - ATMOSPHERIC INFORMATION

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2. Global Warming Characteristics:

 (a) Provide the alternative’s atmospheric lifetime and global warming potential (GWP) relative to carbon dioxide over 100-year time 

horizon, and 20-year or 500-year time horizon, if known. Reference the most recent assessment report of the Intergovernmental Panel on

Climate Change (IPCC AR4). Alternate sources may include the 2010 World Meteorological Organization (WMO) Scientific Assessment of 

Ozone Depletion or the peer-reviewed literature. If the substitute is a blend, provide the GWPs of the individual constituents and an estimate 

of the blend at its nominal composition.

 (b) If known, provide the alternative’s expected impact on energy efficiency relative to the substance it is replacing (e.g. +/- X%) and results 

of any testing or modeling done (both theoretical and actual testing). Energy efficiency information is particularly useful for refrigerants and 

foams.

 (c) For GWP values that do not come from AR4 or WMO 2010, provide any available additional data on the atmospheric lifetime and GWP 

of the alternative, including infrared absorption spectrum and infrared absorption capacity. Reference the source of this information. 

Table 9 illustrates the Global Warming Potential (GWP) for various blowing agents reported in the 2013 

Intergovernmental Panel on Climate Change (IPCC) Report, http:/www.ipcc.ch/pdf/special-reports/sroc/sroc0. 

It is generally accepted that the GWP of methylal is comparable to n-pentane, iso-pentane and methyl formate. 

Thus, the GWP for methylal should also be considered to be negligible. 

Table 9 Comparative GWP for Blowing Agents

Product 100 Year GWP

HCFC-141-b 725

HFC-365mfc 794

n-Pentane -

Iso-Pentane -

Cyclopentane 11

Methyl Formate -

Carbon Dioxide 1

Methylal negligible

The GWP depends on the following factors and is adversely impacted (correlates) with a large infrared absorption 

and a long atmospheric lifetime

• The degradation of organic chemicals released in the atmosphere starts with their reaction with the 

hydroxyl radical. The reaction of hydroxyl radicals with methylal is slow. This rate is 14 times slower 

than expected by calculation if methylal is considered to be an ether type chemical.

• The degradation of organic chemicals released in the atmosphere is initiated by the reaction with 

hydroxyl radical. Atmospheric OH Rate Constant is expressed as OH/cm3

/molecule-sec. The Syracuse 

University Research Corporation (SRC) database (http://library.syr.edu/databases/?type=11) reported 

that Atmospheric OH Rate Constant for methylal (4.6 +/- 0.1 10-

12) is in line with n-pentane (3.94x10-12), 

and iso-pentane (3.94x10-12). 

• The atmospheric degradation of methylal has been investigated to its decomposition to CO2 and H2O. 

The major intermediate atmospheric degradation products that have been identified are dimethyl 

carbonate and methoxy methylformate. The intermediate potential production of formaldehyde is a 

minor product. If emitted into air, methylal will migrate to the upper ozone forming layer of the 

atmosphere where it would only make a moderate contribution to the formation of tropospheric ozone. 

Methylal therefore has a low Photochemical Ozone Creation Potential (POCP). 

Table 10 illustrates a comparison of Maximum Incremental Reactivity (MIR) data of methylal with pentanes. 

Overall, the MIR reflects the potential increase in ozone formation per unit weight of a compound when added to 

the atmosphere. As noted in Table 10, methylal has a relatively lower Maximum Incremental Reactivity (MIR), 

0.94, in comparison to other pentane blowing agents which indicates a lower potential to produce ozone in the 

atmosphere (: http://www.arb.ca.gov/consprod/regs/2012/4mirtable50411.pdf). 

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Table 10 Comparative Methylal MIR with Pentanes 

Product MIR Percent Increase

Methylal 0.94 -

n-Pentane 1.31 + 35%

Iso-Pentane 1.45 + 55%

Cyclopentane 2.39 + 154 %

Part II - ALTERNATIVE-SPECIFIC INFORMATION (continued)

Section C - OTHER STATUTES AND STANDARDS

1. Describe whether and how the manufacture, use, and disposal of the alternative is regulated under other environmental regulatory statutes

such as those listed below. List any concentration-based or other numerical standards to which the alternative is subject under the standards 

and regulations.

The following is based on internet searches and MSDS citations

The Clean Air Act (CAA) other than Title VI: Not listed as a hazardous air pollutants or Class I or II ODP.

The Clean Water Act (CWA): Not listed as a Hazardous Substance under the CWA.

The Safe Drinking Water Act (SDWA): Not listed under SDWA.

The Resource Conservation and Recovery Act (RCRA) : Not listed.

The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA): No restrictions or registrations.

The Toxic Substances Control Act (TSCA) : Included on the Inventory.

The Comprehensive Environmental Response, Compensation and Liability Act (CERCLA): Not listed; no

assigned RQ.

The Emergency Planning and Community Right to Know Act (EPCRA or SARA Title III): No assigned TPQ; 

CAS # 109-87-5: immediate, fire, reactive.

State and local laws: Found on the following state right to know lists: California, New Jersey, Pennsylvania, 

Minnesota, Massachusetts.

Other applicable environmental federal, state, and local laws not mentioned above: 

California Prop 65: No Significant Risk Level (not listed).

Not considered highly hazardous by OSHA.

Section 313: Not reportable under Section 313.

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2. Describe whether and how occupational, consumer, or general population exposure to the alternative is regulated under 

health and safety related statutory authorities, such as those implemented by the Food and Drug Administration (FDA), the 

Occupational Safety and Health Administration (OSHA), the Department of Transportation (DOT), and state and local laws. 

List any concentration-based or other numerical standards to which the alternative is subject under the above statutes and 

regulations. Also list any other standard-setting organizations such as the National Fire Prevention Association (NFPA) the 

American Society of Heating, Refrigerating, and Air Conditioning Engineers (ASHRAE), or Underwriters Laboratories (UL) 

that will evaluate the substitute from a health and safety perspective.

Dimethoxymethane (Methylal) (CAS Number: 109-87-5):

FDA: Threshold of Regulation (TOR): Food Contact Substance, 

http://www.accessdata.fda.gov/scripts/fdcc/?set=TOR&id=2009-002

Use 

Limitations 

For use as a chain transfer agent in the polymerization of polyoxymethylene copolymers in the 

manufacture of repeat use food-contact articles, at temperatures below 250°F, and in contact with all food 

types, except those containing more than 15% alcohol. 

NLB TOXNET: http://toxnet.nlm.nih.gov/cgi-bin/sis/search/a?dbs+hsdb:@term+@DOCNO+1820

OSHA: 8 hr Time-Weighted avg: 1,000 ppm (3,100 mg/cu m)

[29 CFR 1910.1000 (7/1/90)] **PEER REVIEWED** (ToxNET)

Threshold Limit Values:

8 hr Time Weighted Avg (TWA): 1000 ppm.

[American Conference of Governmental Industrial Hygienists TLVs and BEIs. Threshold Limit Values for Chemical 

Substances and Physical Agents and Biological Exposure Indices. Cincinnati, OH, 2008, p. 39] **QC REVIEWED** 

Excursion Limit Recommendation: Excursions in worker exposure levels may exceed 3 times the TLV-TWA for no more 

than a total of 30 minutes during a work day, and under no circumstances should they exceed 5 times the TLV-TWA, 

provided that the TLV-TWA is not exceeded.

[American Conference of Governmental Industrial Hygienists TLVs and BEIs. Threshold Limit Values for Chemical 

Substances and Physical Agents and Biological Exposure Indices. Cincinnati, OH, 2008, p. 5] **QC REVIEWED** 

NIOSH Recommendations:

10 hr Time-Weighted avg: 1,000 ppm (3,100 mg/cu m).

[NIOSH. NIOSH Pocket Guide to Chemical Hazards. DHHS (NIOSH) Publication No. 94-116. Washington, D.C.: U.S. 

Government Printing Office, June 1994., p. 198] **QC REVIEWED** 

DOT: 

Hazard Class: 3 3

UN Number: UN1234

Packing Group: II

State and Local Laws:

Found on the following state right to know lists: California, New Jersey, Pennsylvania, Minnesota, Massachusetts.

California Prop 65: No Significant Risk Level: not listed.

National Fire Prevention Association (NFPA): No citation found for methylal

American Society of Heating, Refrigerating: No citation found for methylal

Air Conditioning Engineers (ASHRAE): No citation found for methylal

Underwriters Laboratories (UL): No citation found for methylal

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Part II - ALTERNATIVE-SPECIFIC INFORMATION (continued)

[Section D - COST AND AVAILABILITY OF THE ALTERNATIVE

Estimate the cost per pound for the substitute chemical. For alternative processes and technologies, describe installation costs associated with 

the alternative. Please describe the information used as the basis for this cost estimate.

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More detail on the specific product improvements are included below:

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3. Describe any new equipment and use profiles that will be necessary in order to use the substitute. If retrofitting of existing equipment is 

required, detail changes in technologies needed to use the alternative and address any materials compatibility issues. Provide information on 

each end-use and capital costs associated with the substitute or alternative process. Include cost of equipment and/or any new materials, 

equipment lifetime, changes in labor and energy costs.

The 2012 UNDP Report (Attachment 2a,b): Methylal As a Blowing Agent in the Manufacture of Polyurethane 

Foam Systems (An Assessment For Application in MLF Projects) provides an in depth assessment for replacing 

high GWP HFCs (such as, HCFC-141b) and hydrocarbons high in investment costs with methylal . UNEP 

concluded that the methylal produced by Lambiotte is commonly available and not incumbered by intellectual 

property or patent restrictions to use in PU foam applications. Additionally, the use of methylal as a blowing 

agent, and alternative to replace the high GWP HFCs (such as HCFC-141b), in PU foam applications is feasible. 

UNEP considered and provided the following in their assessment as summaries and in attachments to the Report

• Health, safety and environmental considerations 

• Process capability, including stability, compatibility shipping and storage

• System composition information

• Overview of physical properties obtained from trials for different applications

• Indicative conversion costs

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Part III - RELEASE AND EXPOSURE DATA

The following data has also been summarized and cited in the 2012 UNDP Report Methylal As a Blowing Agent 

in the Manufacture of Polyurethane Foam Systems (Attachments 2a and 2b) and the Lambiotte Methylal 

Chemical Safety Report (Attachment 5). 

The UNDP (2012, 2a) provided the following overall summary conclusions in its health, safety and environment 

assessment:

• Methylal does not create incremental health concerns;

• Methylal does not pose an environmental hazard;

• Methylal shipments and storage in its pure form must comply with its flammability status;

• While on downstream level, safety concerns may be mitigated through preblending, methylal still 

requires safety measures

− In fully formulated systems <2% methylal (polyols) or <2% methylal (isocyanates) the use of 

methylal requires no special safety considerations;

− Systems containing 2-5 php methylal need individual consideration and above that level, compliance 

with the Globally Harmonized System (GHS) category 2 or 3 is required;

− Local regulations are also to be complied with.

Section A - TOXICITY AND HAZARD INFORMATION

For chemical alternatives and for chemicals used with alternative processes, summarize below (and attach supporting information on) the 

acute and chronic toxicity of the substitute and of its constituent chemicals on any organism (e.g. human and/or other mammals, fish, wildlife, 

and plants), if available. Include any data on impurities and degradation products if known. Also include information on any permissible 

exposure limits (PELs), occupational exposure limits (OELs), or Acceptable Exposure Limits (AELs) that have been set for the substitute for 

use in the workplace. In addition, please attach a copy of any hazard warning statement, label, material safety data sheet, or other information 

which will be provided to any person who is reasonably likely to be exposed. (See Pgs. 16-17 of the Instructions for sector-specific 

requirements for toxicity testing).

A recent Lambiotte MSDS is included as Attachment 7. 

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PART III RELEASE AND EXPOSURE DATA 

-Section B - ENVIRONMENTAL RELEASE AND DISPOSAL AT MANUFACTURE

For each manufacturing site (for manufacturing of substitutes and/or products containing substitutes):

 (a) Identify all site locations (i.e., name and address) for each chemical manufacturing process.

 (b) Identify all site locations for manufacturing of products using substitutes (e.g., refrigerators containing the substitutes).

 (c) Identify the points of release and/or exposure during the manufacture of: (i) the substitute and/or (ii) products containing 

the substitutes.

 (d) Provide information on the magnitude of release if available, along with the media to which the substitute is released 

(e.g., indoor air, outdoor air, water, land).

This section is non-applicable because as noted previously, methylal will be manufactured at the Lambiotte &Cie 

S.A. plant at Grand ‘Rue 79 B-6724 Marbehan Belgium and imported into the United States in either 55 gallon 

drums or Totes. Distribution and the U.S. sales, for foam blowing and other applications, are managed by Holland 

Applied Technologies, 7050 High Grove Blvd. Burr Ridge, Illinois 60527 

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Section C- OCCUPATIONAL EXPOSURE AT MANUFACTURE

manufacturing site (manufacturing of substitutes and/or products containing substitutes):

 (a) Describe the activities in which workers may be exposed to chemicals at the manufacturing facility. Answer items (b) through (g) for 

each activity.

 (b) Describe any protective equipment and engineering controls used to protect workers (e.g., goggles, gloves, chemical hoods).

 (c) Indicate the physical form of chemicals at the time of handling/exposure (e.g., solid, liquid, gas).

 (d) Estimate average and maximum numbers of workers involved in each activity.

 (e) Estimate average and maximum duration of activity for any worker, in terms of (1) hours/day and (2) days/year.

 (f) Enter the contact pathway (e.g., ingestion, inhalation, dermal).

 (g) Estimate the average and high-end exposure concentrations (separated by a /), being sure to provide units of measure.

[Occupational Exposure at Manufacture CBI Has Been Removed]

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Section D - ENVIRONMENTAL RELEASE AND DISPOSAL IN END-USE

For each end-use of a substitute (end-uses using the substitute in products and/or processes):

 (a) Provide the estimated amount (in kg/day) of each chemical released to the environment (e.g., as a solid waste or wastewater effluent) at 

the point of, or subsequent to, the end-use at a site using the substitute (e.g., in products containing the substitute and processes using the 

substitute).

 (b) Identify the media (indoor air, outdoor air, land, water) to which the chemical will be released from that release point.

 (c) Describe the control technology used to limit release; estimate the amount released to the environment with the control technology in 

place to limit release. If the substitute is to be disposed of, indicate the method and location of disposal.

 (d) Are releases covered under RCRA? If so, identify the RCRA hazardous waste codes.

 (e) Identify the approximate number of sites expected to use the substitute.

 (f) Provide information on recycling of the substitute. Describe any associated costs and equipment.

[Environmental Release and Disposal in End-Use CBI Has Been Removed]

 

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 Part III - RELEASE AND EXPOSURE DATA (continued)

Section E - OCCUPATIONAL EXPOSURE AT END-USE

For all end-use scenarios of the substitute (end-uses utilizing the substitute in products and/or processes):

 (a) Describe the activities in which workers may be exposed to chemicals at the end-use (i.e., during installation, maintenance, inspection, 

servicing, or use). Answer items (b) through (g) for each activity.

 (b) Describe any protective equipment or engineering controls used to protect workers (e.g., goggles, gloves, chemical hoods).

 (c) Indicate the physical form of chemicals at the time of handling/exposure (e.g., solid, liquid, gas).

 (d) Estimate average and maximum numbers of workers involved in each activity.

 (e) Estimate average and maximum duration of activity for any worker, in terms of (1) hours/day and (2) days/year.

 (f) Enter the contact pathway (e.g,. ingestion, inhalation, dermal).

 (g) Estimate the average and high-end exposure concentrations (separated by a /), being sure to provide units. Personal monitoring data 

may be required for some end uses (see pgs. 17-18 of Instructions)

____________________________

[Occupational Exposure at End-Use CBI Has Been Removed]

Personal protection (also refer to MSDS) 

• Respiratory protection: Where excessive vapor may result, wear an appropriate NIOSH and OSHA approved 

mask and or respirator.

• Hand protection: In case of repeated or prolonged contact wear gloves.

• Skin protection: No special clothing/skin protection equipment is recommended under normal

• conditions of use.

• Eye protection: Goggles.

• Ingestion: When using, do not eat, drink or smoke.

• Industrial hygiene: Local exhaust and general ventilation must be adequate to meet exposure

• standards.

• TLV-TWA [ppm]: 1000

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The typical formulations to which methylal – polyol formulators may be exposed are reported below in Tables 19 

and 20. The methylal-polyol blowing agent formulations are also compared to comparable/analogous HCFC 141b 

blowing agent formulations. In the methylal – polyol blowing agent formulations methylal concentrations range 

from 8% in typical rigid foam formulations to 2.74% in flexible molded formulations. Note that in each case the 

amount of methylal by weight is significantly lower that of HCFC-141b which is 14.52 and 3.65% respectively. The 

UNEP Report (Attachment 2b) provides specific product application formulations that compare the percent in 

formulations for both methylal and HCFC-141b. The maximum concentration cited is for the “Pour in Place” 

formulation in which the amount of methylal is listed to be 10.5% in the formulation and the amount of HCFC-141b 

is listed to be 14.6%. The information in Table 19 highlights the reduce volume for volume use of methylal 

compared to HCFC-141b. 

Table 19. Typical Rigid Foam Formulation

Table 20. Typical Flexible Molded Foam Formulation

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Questions e and g

It is likely that no more than 1 or 2 workers per site would be involved either in the transfer of methylal to prepare 

polyol-methylal formulations (System Houses) or the transfer of methylal polyol blowing agent formulations 

(Downstream End-Users) to react with isocyanate in the manufacture of a particular rigid or flexible polyurethane 

foam product. As previously noted in this SNAP the following are the current EPA worker exposure Federal 

guidelines:

OSHA: 8 hr Time-Weighted avg: 1,000 ppm (3,100 mg/cu m)

[29 CFR 1910.1000 (7/1/90)] **PEER REVIEWED** (ToxNET)

Threshold Limit Values (TLV)

8 hr Time Weighted Avg (TWA): 1000 ppm.

[American Conference of Governmental Industrial Hygienists TLVs and BEIs. Threshold Limit Values for Chemical Substances 

and Physical Agents and Biological Exposure Indices. Cincinnati, OH, 2008, p. 39] **QC REVIEWED** 

Excursion Limit Recommendation: Excursions in worker exposure levels may exceed 3 times the TLV-TWA for no more than a 

total of 30 minutes during a work day, and under no circumstances should they exceed 5 times the TLV-TWA, provided that the 

TLV-TWA is not exceeded.

[American Conference of Governmental Industrial Hygienists TLVs and BEIs. Threshold Limit Values for Chemical Substances 

and Physical Agents and Biological Exposure Indices. Cincinnati, OH, 2008, p. 5] **QC REVIEWED** 

NIOSH Recommendations:

10 hr Time-Weighted avg: 1,000 ppm (3,100 mg/cu m).

[NIOSH. NIOSH Pocket Guide to Chemical Hazards. DHHS (NIOSH) Publication No. 94-116. Washington, D.C.: U.S. 

Government Printing Office, June 1994., p. 198] **QC REVIEWED** 

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Section F - CONSUMER EXPOSURE

For each end-use of a substitute (end-uses where a consumer might be exposed):

 (a) Identify the potentially exposed consumer population (e.g,. indoor residents).

 (b) Identify the exposure medium (e.g., air).

 (c) Enter the contact pathway (e.g,. ingestion, inhalation, dermal).

 (d) Describe the exposure point of concentration. Provide (1) average and (2) high-end concentration estimates, including units of measure.

[Consumer Exposure CBI Has Been Removed]

Mark (X) this box if this page contains CBI __________

Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

Previous editions are obsolete

47
Part III - RELEASE AND EXPOSURE DATA (continued)

Section G - GENERAL POPULATION EXPOSURE (optional)

For manufacturing of substitutes and products containing substitutes:

 (a) Identify and number potential general population exposure points.

 (b) For each exposure point described in (a), identify the potentially exposed population (e.g., residents at the fenceline to the 

manufacturing facility).

 (c) Identify the contact pathway (e.g., ingestion, inhalation, dermal).

 (d) Identify the exposure medium (e.g., air, water).

 (e) Enter the exposure point concentration (mg/m3 or ppb). Provide (1) average and (2) high-end estimates.

Refer to Section F

Mark (X) this box if this page contains CBI __________

Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

Previous editions are obsolete

48
Part IV - LIST OF ATTACHMENTS

List below any attachments that complete the responses to the questions on this form or that provide additional information that may assist 

EPA’s review of the alternative under Section 612 of the Clean Air Act. Also, provide citations for information already submitted to EPA as 

part of past regulatory and information activities, as well as for other information that could not be included with this submission. If you have 

attached continuation pages, describe the Part, Section and question number being continued. Attach additional pages if necessary. Mark (X) 

in the CBI box next to any attachment that contains information you claim as confidential.

Attachment Name Question # Number of 

Pages

CBI

#1 CAS IES Report Part 1; Sec B 

(2a)

4

#2a UNDP (2012a) Methylal As Blowing Agent in The Manufacture of 

Polyurethane Foam Systems – Report Summary

#2b UNDP (2012b) Methylal As Blowing Agent in The Manufacture 

of Polyurethane Foam Systems – Full Report and Analysis

Part 1; Sec B (5) 112

[Attachment CBI Has Been Removed] Part 1; Sec B (5) 37 X

# 4a Methylal EPISuiteTM4.1 Calculations – Ultimate Fugacity

#4b Methylal EPISuiteTM4.1 Calculations – Primary Fugacity

Part 2 Section A 7

[Attachment CBI Has Been Removed] Part 2 Section A 640 X

#6) EU ANNEX VI: General Classification and Labelling 

Requirements for Dangerous

Substances And Preparations

Part 2 Section A 

28. Flammability

21

#7) Methylal MSDS Part 3 Section A 10

[Attachment CBI Has Been Removed] Part 3 Section A 26 X

#9) Weaver FL, Hough AR, Highman B, Fairhall LT [1951]. The 

toxicity of methylal. Br J Ind Med 8:279-283

Part 3 Section A 6

[Attachment CBI Has Been Removed] Part 3 Section A 25 X

Mark (X) this box if this page contains CBI __________ 

Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

Previous editions are obsolete

49
[Attachment CBI Has Been Removed] Part 3 Section A 22 X

[Attachment CBI Has Been Removed] Part 3 Section A 34 X

[Attachment CBI Has Been Removed] Part 3 Section A 491 X

[Attachment CBI Has Been Removed] Part 3 Section A 157 X

[Attachment CBI Has Been Removed] Part 3 Section A 36 X

[Attachment CBI Has Been Removed] Part 3 Section A 56 X

Mark (X) this box if this page contains CBI __________ 

Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

Previous editions are obsolete

50
[Attachment CBI Has Been Removed] Part 3 Section A 30 X

[Attachment CBI Has Been Removed] Part 3 Section A 40 X

[Attachment CBI Has Been Removed] Part 3 Section A 14 X

[Attachment CBI Has Been Removed] Part 3 Section A 9 X

[Attachment CBI Has Been Removed] Part 3 Section A 7 X

[Attachment CBI Has Been Removed] Part 3 Section A 8 X

[Attachment CBI Has Been Removed] Part 3 Section A 10 X

[Attachment CBI Has Been Removed] Part 3 Section A 4 X

Mark (X) this box if this page contains CBI __________ 

Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

Previous editions are obsolete

51
[Attachment CBI Has Been Removed] Part 3 Section A 14 X

[Attachment CBI Has Been Removed] Part 3 Section A 25 X

[Attachment CBI Has Been Removed] Part 3 Section A 68 X

[Attachment CBI Has Been Removed] Part 3 Section A 18 X

[Attachment CBI Has Been Removed] Part 3 Section A 8 X

[Attachment CBI Has Been Removed] Part 3 Section A 6 X

[Attachment CBI Has Been Removed] Part 3 Section A 31 X

[Attachment CBI Has Been Removed] Part 3 Section A 4 X

Mark (X) this box if this page contains CBI __________ 

Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

Previous editions are obsolete

52
[Attachment CBI Has Been Removed] Part 3 Section A 12 X

[Attachment CBI Has Been Removed] Part 3 Section A 19 X

[Attachment CBI Has Been Removed] Part 3 Section A 11 X

[Attachment CBI Has Been Removed] Part 3 Section A 19 X

#37) ECOSAR Modeling Part 3 Section A 3

[Attachment CBI Has Been Removed] Part 3 Section D 44 X

Mark (X) this box if this page contains CBI __________ 

Form 1265-07 (Revised 09/2011) 

OMB Control No.: 2060-0226

Previous editions are obsolete

53