Sent via Email 

October 17, 2014 

Air and Radiation Docket 

Environmental Protection Agency 

1200 Pennsylvania Ave. NW 

Washington D.C. 20460 

A-And-R-Docket@epa.gov 

Re: Proposed SNAP Program Status Change Rule 

Docket ID No. EPA-HQ-OAR-2014-0198 

Dear Cindy Newberg, 

Forno Products Inc. appreciates the opportunity to submit comments in response to the Environmental 

Protection Agency's (EPA) Significant New Alternatives Policy Program (SNAP) Office's proposed change 

of listing status rule for HFC-134a. 

We strongly urge the SNAP Office to consider extending the Jan.l, 2017134a de-listing date for the 

following rigid spray foam subcategories: low pressure SPF and low pressure pour-in-place. As a 

manufacturer of these types of foams, we are deeply concerned at the lack of suitable alternative 

blowing agents for these two foam categories, as well as the short time granted for adapting to the only 

suitable alternative identified by the EPA, Solstice GBA. These foam categories possess unique technical 

and safety challenges related to reformulation, especially when one considers the stability issues of the 

only available gaseous, non-flammable HFO alternative allowed in the draft ruling. Further, the 

proposed de-listing date for HFC-134a (Jan. 1, 2017) actually becomes a Jan. 1, 2016 date for these foam 

categories because they are typically sold through distribution and require a one year shelf life. We 

strongly support the EPA's ultimate goal of HFC reduction. However, our findings show that an extension 

of time will be essential in order to surmount the extraordinary technical challenges that we face in 

reformulation. 

Blowing Agent Requirements for Low Pressure SPF & Pour-in-Place 

Low pressure SPF and pour-in-place foams require a gaseous blowing agent for proper on-ratio 

dispensing and chemical cure. The gas creates the pre-expansion of the foam, a trait required for 

applications like air sealing and insulating. Shelf lives of these products must be at least one year due to 

the fact that they are sold through distribution. Flammable blowing agents cannot be considered for 

safety reasons in these field applied products. Thus, a gaseous, low GWP blowing agent must not be 

flammable, and must not degrade during its travels through distribution. Since the blowing agent is preloaded to maintain on-ratio dispensing in field use, its degradation would produce off-ratio foams, 

creating health, safety, and product performance issues for end-users and consumers who may be in the 

vicinity of the off ratio (uncured foam). Our R&D group has reported that they see rapid blowing agent 

degradation in every formulation attempt to date with HFO Solstice GBA (Appendix). 

HFO Solstice GBA, the lone gaseous, non-flammable blowing agent allowed under the SNAP Office's 

proposed draft ruling, has been found to be highly unstable in all of our low pressure produci:s. Other 

low pressure manufacturers report the same results. This, no doubt, is due to the fact that this 
molecule, designed initially to breakdown in the atmosphere, is subject to pressures between 150-250 

psi within the cylinders containing the low pressure products. In pre-pressurized products such as low 

pressure SPF and low pressure pour-in-place foams, the well-known organic chemistry principle comes 

into play; increased pressure rapidly accelerates all chemical reactions, in this case the breakdown of 

HFO Solstice GBA in polyurethane B-side systems. Further details are contained in the following 

sections. 

Chemist's Challenge 

Solstice GBA was designed as a next generation blowing agent replacement for HFC-134a. Use of HFOs 

like Solstice GBA reduces the dependence on HFCs for low pressure foams, and decreases global 

warming potential from approximately 1400 (HFC-134a) to below 6. Solstice GBA contains a carbon 

double bond designed to enhance atmospheric degradation, thus maintaining low global warming 

potential. However, this feature, beneficial to the environment overall, presents significant technical 

challenges to the low pressure polyurethane chemist. 

As mentioned, the arrangement of atoms throughout Solstice GBA's structure is designed to enhance its 

degradation when exposed to harsh conditions (i.e. UV energy in the atmosphere). However, this 

particular double bond is also prone to attack by many of the components of standard low pressure SPF 

and pour-in-place formulations. These interactions are accelerated in pre-pressurized systems. 

Using standard low pressure SPF and pour-in-place ingredients, required for desired cured properties, 

Forno Products investigations show severe foam degradation (off-ratio, foam collapse, incomplete 

chemical cure) at the first shelf life test point of 3 months. Over this short time period, the dispensed 

foam shows severe degradation, exhibiting poor surface appearance and cell structure (See Appendix). 

This breakdown in physical properties such as closed cell content leads to further failures, including 

decreased R-Value and a decrease in performance as an air barrier. The two characteristics which set 

SPF apart from other building materials. 

HFC-134a formula replacements will have to carefully design around Solstice GBA's propensity for 

degradation and thus requires a completely new approach to formulating. The process of learning and 

combining new catalysts, flame retardants, and surfactants puts a strain on R&D's ability to develop a 

high quality product in the short time frame proposed by the draft rule. Forno Products Chemist Julie 

Shoemaker states, "The nature of this molecule presents significant and novel challenges to the 

formulators of our industry. These challenges will require significant time and resources to overcome 

and provide the customers of our Industry with a suitable replacement for the quality products that they 

are used to using in their jobs". 

Low Pressure OCF vs. Low Pressure SPF & Pour-in-Place 

While it is recognized that Solstice GBA can be stable in low pressure OCF foams, it is also known that 

OCF formulas require a completely differing set of ingredients (catalysts, flame retardants, polyols) for 

proper cure when compared to low pressure SPF and pour-in-place foams. Low pressure OCF foams are 

moisture cured, with cure times between 5- 20 minutes. Low pressure SPF and pour-in-place foams, 

however, require a 30 second- 2 minute chemical cure. These differing requirements- slow moisture 

cure vs. a very fast chemical cure- separate these product categories. Thus, low pressure OCF 

ingredients cannot be directly substituted in low pressure SPF and pour-in-place foams. They will not 

provide the required cure or end-use properties. 
Stability 

As mentioned, Solstice GSA is the only alternative allowed for low pressure SPF and pour-in-place 

systems. It repeatedly exhibits rapid degradation in low pressure systems. This chemical breakdown 

creates off-ratio dispensing or incomplete cured foam, resulting in situations which raise the possibility 

of chemical exposure to applicators and consumers. The current use of HFC-134a in low pressure foam 

systems provides a minimum one year shelf life. In fact, most 134a blown foams will still produce safe, 

quality foams long after the required one year shelf life expires. 

A critical component of our R&D efforts for new products is to eliminate any uncertainties which may 

occur in the field. The limited phase-out timeline doesn't allow us sufficient time for the extended shelf 

life studies needed to reduce potential risks, i.e. end-user exposure to uncured foam. 

Regarding the rapid degradation of Solstice GBA witnessed by low pressure manufacturers, Arkoma's 

Patent Application US 2014/0103248 A1 teaches us: 

• GC/MS results for a typical B side foam system placed in an autoclave for 24 hours@ 100'F with 

Solstice GBA show 2% degradation of the Solstice GBA (HF0-1234ze). US 2014/0103248 A1 

Examples 9 & 10, pg. 4, Table 4. 

a. Note: 100'F represents typical transport and storage conditions for low pressure SPF and 

pour-in-place products in many regions of the US. 

• This fast degradation most likely produces hydrofluoric acid (HF) as a by-product. HF corrodes 

metal. 

a. Forno's assessment of that potential situation: presence of HF will cause pressurized 

cylinder leakage, resulting in chemical exposure to unknowing distributors and end 

users. Through the years, R&D experience at Forno has shown that when HF is 

developed we can expect pin-hole corrosion to occur in the cylinder, causing the 

product to leak. This leakage is a threat to humans and the environment. 

• "Presence of alkene linkage it is expected to be chemically unstable, especially relative to HFC" 

Request for Low Pressure Subcategories and Relationship to EPA Proposed Alternatives 

We respectfully ask that the EPA SNAP Office review the CPI's submitted comments. These comments 

represent the polyurethane foam industry's collective belief that the definitions used in the ruling 

regarding rigid foam are overly broad. We request that low pressure SPF & pour-in-place foam products 

be considered separately from other rigid spray foams, and offer the following comments: 

• Suggested definition of low pressure SPF: 

o Used in thermal building insulation and air sealing. Low pressure SPF products are 

pressurized to <250 psi during manufacture and are sold in pressurized containers as 

two parts (A-side & 8-side) and are sprayed applied in the field for thermal insulation 

and air sealing of buildings. 

• Rule 20 lists eight acceptable substitutes for HFC-134a in Rigid Polyurethane Spray Foam: HFC245fa (narrow use exemption), HFC-365 mfc/HFC-227ea, C02, Water, Exxsol, ecomate, HF0-

1234ze(E), and trans-1-chloro-3,3,3 trifluoroprop-1-ene (HF0-1233zd). 

o However, the only viable option for low pressure SPF and pour-in-place foams is HFO 

Solstice GBA (HF0-1234ze). The other alternatives are not suitable to use with LP SPF 

due to use restrictions or safety considerations: low pressure foam kits need a high 

vapor pressure propellant to dispel and empty the kit; flammable options introduce too 
many additional in field risks not previously encountered with non-flammable HFC-134a 

blown systems; and water and C02 blown foams need the addition of heat and higher 

pressures to be used successfully. 

• Japan's Ministry of Economy, Trade, and Industry classifies HFO Solstice GBA (1234ze(E)) as a 

flammable gas. Honeywell has been trying to change the categorization for 8 years with no 

success. 

• Low Pressure SPF Products are sold through distribution and the methods that we use to 

transport our products to market must be considered. A typical transport run can expose the 

product to elevated temperatures (> lOO"F) which can have deleterious consequences on the 

shelf life of Solstice GBA-blown low pressure SPF & pour-in-place products. A shelf-life of one 

year is an absolute necessity in order to account for time spent in the distribution chain and 

storage by end-users prior to use. 

• Low pressure products are under constant pressure (150- 250 psi) and with additional heat 

(i.e. lOO"F) the pressure inside the kits increases, leading to pressure and thermal acceleration 

of the chemical reactions within the foam cylinders. These factors are proven to affect the 

shelf-life stability of Solstice GBA in a negative fashion. We will need additional time to test our 

products thoroughly so that we can offer our end-users safe and reliable foam products. 

• A single source supplier. If the foam industry/blowing agent manufacturers are given a 

reasonable (longer) time frame for the HFC-134a phase-down in low pressure products, an 

additional alternative blowing agent may emerge. The presence of an additional alternative 

may help ensure minimal disruptions to business, increase end-user safety, and result in the low 

pressure foam performance required by building codes, fire codes, and other specifications. 

• Normally, successful low pressure foam formulations go through years of shelf-life studies, field 

testing and external testing to ensure that a safe, quality product will be on the market. 

In conclusion, we request an additional 3 years to fully integrate a safe and effective transition. The 

proposed time frame to be compliant by January 1, 2017 will force manufacturers to launch products 

that do not go through the complete battery of tests, thus increasing risk to human health and the 

environment. The requested HFC-134a phase-out in low pressure foams would be complete by January 1, 

2020. This date would be sooner than the current EU deadline of 2021 for HFC-134a in two-component 

PUfoams. 

Sinc~~J 

Dr. Thomas Fishback 

Vice-President, Research & Development 

Forno Products, Inc. 
APPENDIX 

Compilation of Fomo Products Lab Studies on the Stability of Solstice GBA in Low Pressure SPF 

and Pour-in-Place Foam Systems 

Oct. 17, 2014 

Julie Shoemaker, Product Development Chemist 

Honeywell blowing agent Solstice GBA (HF0-1234-ze(E)) was designed as a next generation 

blowing agent replacement for HFC-134a; this blowing agent reduces the dependence on 

hydrofluorocarbons and decreases global warming potential from approximately 1600 (HFC134a) to 6 (HF0-1234-ze(E)). 

Currently, the most viable (ONLY??) replacement for HFC-134a in the low pressure spray 

polyurethane foam industry is the Honeywell Solstice GBA blowing agent. This molecule 

presents significant technical challenges to a polyurethane foam chemist or formulator based on 

the inherent structure of the molecule, which was designed to break apart in the atmosphere. 

The most significant challenge with the mol'ecuie is formulating a product that will meet the 

aggressive shelf life requirements of the low pressure spray polyurethane foam industry. Our 

products are pressurized into cylinders under a pressure of approximately 200 psi. The products 

are exposed to a large range of temperatures based on the end use application, and are 

delivered without the aid of proportioning units, etc. 

Investigations to date prove degradation of the molecule and failure of the system at the first 

time point of 3 months accelerated aging csooq. 

Over this short time period, the foam degrades and shows poor surface appearance: 
IN mAL 3 MONTH 

Additional observations include poor cell structure, a decrease in the foam rise I height and a 

decrease in the closed cell content 

INITIAL 

3 MONTH 

A breakdown in physical properties such as closed cell content lead to further failures including 

decreased R-value I k-factor and a decrease in performance as an air barrier. These are key 

performance characteristics for many applications in the industry. 
Additional failures of note include an increase in density, which results in significantly decreased 

product yields, poor compression strength, tensile strength, etc. 

Another obvious indicator of chemistry break down is a significant change in tack free time, an 

indication of improper cure (as are all of the deteriorated properties). 

A second failure of note with this molecule is an incompatibility over shelf life with the flame 

retardant, Tris (2-chloroisopropyl) phosphate (TCPP). TCPP is the most commonly used flame 

retardant and is required at loading levels of approximately 40% to meet the ASTM E84 class I 

requirement for SPF I building codes I etc. The systems tested using HF0-1234ze(E) fails when 

levels exceed much over 20% loading. 

Laboratory testing proves that a formulation must either be carefully designed around this 

known degradation to the system, or will require investigation of a completely new approach to 

flame retardancy in this industry. 

Current generation molecules like HFC-134a do not contain a carbon - carbon double bond. The 

new HF0-1234ze(E) molecule contains a double bond as it is designed for degradation to 

maintain low global warming potential. This design was to address issues in Montreal and Kyoto 

protocols. This double bond is prone to attack by many other parts of the chemistry and will 

also degrade in our pressurized systems. 

The nature of this molecule presents significant and novel challenges to the formulators of our 

industry. These challenges will require significant time and resources to overcome and provide 

the customers of our industry with a suitable replacement for the quality products they are used 

to using in their areas of expertise.