November 26, 2013 

Katherine Sleasman 

Office of Pollution Prevention and Toxics 

Chemical Control Division

Existing Chemicals Branch 

1200 Pennsylvania Ave. NW

EPA East, Room 4410G 

Washington, DC 20460

Sleasman.Katherine@epamail.epa.gov

Re: Toluene Diisocyanate (TDI) And Related Compounds Action Plan, 

RIN 2070-ZA15, April 2011

Dear Ms. Sleasman, 

I am writing on behalf of the International Sleep Products Association (ISPA), the trade association for the mattress 

industry, regarding potential efforts by the Environmental Protection Agency (EPA) to expand the scope of the TDI 

Chemical Action Plan. Currently the TDI Action Plan states that the Agency “intends to initiate a rulemaking under TSCA 

section 5(a)(2) for a SNUR, designating the use of uncured TDI and its related polyisocyanates in a consumer product as a 

new use.” EPA’s recent presentation at the September 2013 Polyurethanes Technical Conference stated that EPA will 

“initiate a rulemaking under TSCA section 5(a)(2) for a SNUR designating certain uses of TDI in a consumer product as a 

new use require prior notice to the Agency.” It appears that EPA is potentially expanding the scope of the TDI Action 

Plan from uncured diisocyanates in consumer products to finished and cured consumer products. 

By way of background, TDI is an ingredient used to make some types of flexible polyurethane foam which is used in 

many applications, including in the upholstery and support layers of most mattresses manufactured today in the United 

States and around the world. My organization represents mattress manufacturers and suppliers of components and 

services used by mattress producers. Our members are in the business of making and selling to consumers products 

that help them get the safe and restful sleep they need to lead a full and productive life. We take seriously our 

obligation to make products that meet all consumer safety and applicable standards. In addition, mattress 

manufacturers select materials that are safe for the workplace and the environment. 

In so doing, the industry carefully examines our products and materials to determine whether they affect consumer, 

workplace or environmental safety. As a result, the materials that the U.S. mattress industry uses to make new 

mattresses undergo a battery of tests before they are used to manufacture new products that are sold to consumers. 

Moreover, in the 1990s, the industry worked with scientific and technical experts to develop standards that could be 

used to determine whether certain mattress materials emit volatile organic compounds (VOCs). Specifically, that effort 

resulted in ASTM Standard 6177-97, Standard Practice for Determining Emission Profiles of Volatile Organic Chemicals
Emitted from Bedding Sets, and ASTM D 6178-97, Standard Practice for Estimation of Short-term Inhalation Exposure to 

Volatile Organic Chemicals Emitted from Bedding Sets. Those standards underwent extensive third party and peer 

review and are used today. Applying them to test mattresses sold in the market at that time confirmed that they were 

not emitting harmful VOCs. 

Flexible polyurethane foam used in mattresses sold in the United States is safe for the workers that assemble 

mattresses, the consumers that use our products, and the environment. More specifically, the research shows that TDI 

is fully reacted in the foam curing process and that “... sleeping on a PU foam mattress does not pose TDI-related health 

risks to consumers” (Arnold et. al).

1

 As a result, consumers that sleep on mattresses containing flexible polyurethane 

foam simply are not exposed to detectable levels of TDI. 

Please contact me should you have any questions.

Sincerely,

Ryan Trainer

President

International Sleep Products Association

 

1

Arnold SM; Collins MA; Graham C; Jolly AT; Parod RJ; Poole A; Schupp T; Shiotsuka RN; Woolhiser MR. 

Risk assessment for consumer exposure to toluene diisocyanate (TDI) derived from polyurethane flexible foam

Reg. Toxicol. Pharmacol., Vol. 64, (3), Dec., 2012, 504-15.