June 30 , 2010

Sara Hise l

- 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 Pan el on June 16

. This letter provides supplemental

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

.

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

company

- specific methyl ene diphenyl di isocyanate (MDI) exposure data for two

- component low

pressure 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, a ll measured concentrations were well below the OSHA PEL (NIOSH REL) of 200 μ g/m 3 (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

di isocyanates. This initial information served as a snapshot of uses, and suggests that the U.S. domestic market has a number of adhesives, glues, sealan ts, and coatings that may contain unreacted

di isocyanates . The initial information also suggests that MDI is the predominant di isocyante used. We are continuing to work on validating our initial survey results, and if we are able to suitably

validate the inf

ormation, 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 Spr ay Polyurethane Fo am A lliance

, 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.polyuret hane.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 a s it becomes available. Please let us

know if we can be of further assistance.

Very truly yours,

Steve Russell Rob Simon Vice President, P lastics Division Vice President, Chemical Products & Technology American Chemistry Council American Chemistry Council

cc: Ellie Clark, OPPT Carol Hetfield, OPPT Amy Breedlove , OPPT

A t t a c h m e n t s