June 30, 2010 

Sara Hisel-McCoy

Acting Chief, Chemical Control Division

Office of Pollution Prevention and Toxics

U.S. Environmental Protection Agency

Ariel Rios Building

MC-7401M

1200 Pennsylvania Avenue, NW

Washington, DC 20460

Re: Proposed Action Plan for Diisocyanates

Dear Ms. Hisel-McCoy: 

Thank you for taking the time to meet with ACC’s Center for the Polyurethanes Industry, 

Diisocyanates Panel, and Aliphatic Diisocyanates Panel on June 16. This letter provides supplemental 

information as a follow up to our meeting regarding the proposed Chemical Action Plan for 

Diisocyanates.

ACC’s Center for the Polyurethanes Industry (CPI) has recently collected and collated available 

company-specific methylene diphenyl diisocyanate (MDI) exposure data for two-component lowpressure spray polyurethane foam (SPF) and insulating foam sealant (“foam in a can”) products. CPI 

collected this information as part of ongoing voluntary industry product stewardship efforts specific to 

SPF products. With respect to 2-component low pressure SPF products, all measured concentrations 

were well below the OSHA PEL (NIOSH REL) of 200 μg/m3(ceiling). With respect to insulating 

foam sealants, MDI was not detected in 13 separate samples taken from monitoring devices worn by 

applicators during application. (We are providing this information for your information, along with a 

powerpoint presentation made to EPA’s spray polyurethane foam team in December, 2009 and an 

affiliated paper, The Current MDI Industrial Hygiene Data on Spray Foam.)

At our June 16 meeting, we also reviewed some preliminary information gathered in an end use survey 

to help better inform us about the range of consumer products that may contain unreacted 

diisocyanates. This initial information served as a snapshot of uses, and suggests that the U.S. 

domestic market has a number of adhesives, glues, sealants, and coatings that may contain unreacted 

diisocyanates. The initial information also suggests that MDI is the predominant diisocyante used. 

We are continuing to work on validating our initial survey results, and if we are able to suitably 

validate the information, we will provide it to the Agency for your review. In the meantime, the initial 

survey results presented should continue to be considered preliminary. 
2

As you know, CPI has been working for the past year, together with the Spray Polyurethane Foam 

Alliance, on a broad range of product stewardship activities related to application of spray 

polyurethane foam products by professionals and consumers. Two projects are being added to this 

effort that may be of interest to EPA as it develops its action plan. The first is to update, and broadly 

disseminate through the value chain, CPI’s guidance entitled Hazard Information Relevant to Labeling

of Diphenylmethane Diisocyanate (MDI) Containing Products for the Consumer Marketplace

(attached), www.polyurethane.org/s_api/bin.asp?CID=1649&DID=10309&DOC=FILE.PDF. 

Second, we intend to offer assistance to the Consumer Product Safety Commission to update, and 

broadly disseminate, its guidance entitled Art and Craft Safety Guide (attached), 

www.cpsc.gov/cpscpub/pubs/5015.pdf.

We look forward to providing you with additional information as it becomes available. Please let us 

know if we can be of further assistance. 

Very truly yours, 

Steve Russell Rob Simon

Vice President, Plastics Division Vice President, Chemical Products & Technology

American Chemistry Council American Chemistry Council

cc: Ellie Clark, OPPT

Carol Hetfield, OPPT

Amy Breedlove, OPPT

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