Presented by:

Carol Hetfield, Environmental 

Protection Agency 

Katherine Sleasman, 

Environmental Protection 

Agency 
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Presentation Outline 

 EPA’s Concern for Isocyanates & Polyurethane 

Products

 Partnerships 

 Stewardship Goals 

 Challenges & Progress

 Background on TSCA Isocyanates Action Plans

 Other Activities

 Information Gathering Approaches

 Voluntary Information Request Letter on Curing Rates of PU 

Products

 Test Method Development 

 Significant New Use Rule (SNUR)

 Federal Agency Coordination

 Summary

 Information Sources

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Prevention & Toxics
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EPA’s Concerns for Isocyanates and 

Polyurethane Products 

 Many polyurethane products are mixed, applied, and/or 

manufactured on-site in a home, school, or other buildings.

 Isocyanates are recognized as leading attributable cause of 

occupational asthma.

 Diisocyanates in vapors, aerosols, and dust can cause:

 Asthma, respiratory & breathing problems, and in severe 

cases fatal reactions have been reported (see NIOSH ALERTS), 

 Skin, eye, and dermal irritation,

 Sensitization (potent inhalation & dermal sensitizers), and

 Can trigger severe asthma attacks in sensitized persons, even 

at very low levels. 

 Amine catalysts, flame retardants, blowing agents and other 

ingredients or reaction products, such as aldehydes, may also 

cause health and environmental effects.

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Partnerships 

 Federal Partnership:

 US Environmental Protection Agency

 Occupational Safety and Health Administration

 National Institute for Occupational Safety and Health

 The Consumer Product Safety Commission (CPSC)

 The Agency for Toxic Substances and Disease Registry (ATSDR)

 Engagement with Industry Representatives:

 American Chemistry Council (ACC) 

 ACC’s Center For Polyurethanes Industry (CPI)

 Spray Polyurethane Foam Alliance (SPFA), representing applicators

 Individual Chemical and Polyurethane Product Manufacturers

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Stewardship Goals

• Avoidance of misleading and/or deceptive marketing claims.

• Accurate & comprehensive communication of hazards, as well 

as benefits of polyurethane products. 

 Develop & adopt practices to prevent harmful exposures:

 Ensure workers are trained on hazards, processing and 

equipment, curing rates, performance, as well as 

communicating with others.

 Ensure worksite isolated and restricted to workers wearing 

appropriate personal protective equipment (PPE).

 Provide guidance on safe re-occupancy times/ventilation.

 Address research needs and data gaps on different types of 

polyurethane product formulations and applications.

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Challenge – Misleading and/or 

Deceptive Marketing Claims 

 “No off--gassing”, “non—toxic”, “green“,

“environmentally friendly”, “plant-based”, “made from 

soy beans”, etc.

 Little is revealed about chemical ingredients and 

potential hazards/risks.

 DIY programs showing improper protection.

 On-line videos showing untrained/unprotected 

application of products.

 Lack of balance between potential performance benefits 

and hazards.

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Prevention & Toxics

KAS1
Slide 6

KAS1 Check spelling

Katherine Sleasman , 5/2/2012
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Progress in Addressing Misleading 

Marketing Claims

 US Federal Trade Commission (FTC) Green Guides, see 

http://www.ftc.gov/os/2012/10/greenguides.pdf

 As part of the its Green Guides compliance program, FTC recently took 

action against companies for making false environmental marketing claims. 

The proposed consent orders prohibit the companies from making claims 

unless the representations are true and supported by competent and 

reliable scientific evidence.

 Enhanced Energy Star Residential Insulation Partnership Requirements 

(see separate slide).

 Industry guidance - see http://www.spraypolyurethane.org/ 

GreenMarketingClaims ; and, http://spraypolyurethane.org/Guidancefor-Videos-or-Images-Showing-SPF-Application

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Challenge – Deficiencies in Hazard 

Communication

 Hazard and exposure control information varies widely.

 Availability of Safety Data Sheets (SDSs) – some on-line, others 

made available only after request by federal Agency.

 Recommendations on respiratory protection vary, while only a few 

mention the possible need for protection for “adjacent workers.”

 Indicate that adequate ventilation is needed but provide little 

guidance what constitutes adequate ventilation and methods.

 Few SDSs mention that skin contact may cause an allergic reaction 

and sensitization.

 Several SDSs mention that dust can be generated during cutting or 

abrasive processes, however, hazards are identified as “mechanical 

irritation.”

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Progress in Addressing Hazard 

Communications

 Federal – US EPA Spray Polyurethane Foam website, 

OSHA’s Green Jobs site and National Emphasis Program, 

NIOSH ALERTS, numerous resources and information 

pages across federal Agency websites on isocyanates 

and other chemical hazards (see resources).

 Industry - Product stewardship activities: 

 Fact sheets, technical bulletins, websites & portals, see 

http://spraypolyurethane.org/default.aspx

 Other - Spray Foam Magazines, industry newsletters, blogs, 

Green Building webinars, technical panels at conferences, goals 

in product sustainability standards.

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Why Best Practices are Important

 Airborne contaminants may be generated during 

application processes, including 

 Vapors, aerosols, and mists generated during spraying.

 Dusts/particulates during trimming/cutting/grinding.

 Vapors also emitted during curing process. 

 Workers and others in the area can breath harmful 

airborne contaminants or get them on the skin/eyes.

 Best Practices can help reduce exposures to 

contaminants. 

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EPA’s Approach to Best Practices 

 Identify established practices for engineering or process 

efficiencies & control technologies to reduce exposures and 

environmental releases,

 Review existing worker training materials & practices 

addressing the use of PPE and control technologies, and 

 Solicit recommendations for innovative practices from 

industry and field experts, capturing the following:

 Identify job related tasks. 

 Safe work practice(s). 

 Exposure reduction/prevention potential of the safe work practice.

 Other relevant information (i.e., pros and cons) associated with the 

safe work practice. 

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EPA Guidance

 Checklists for installers and communicating with 

homeowners.

 Ventilation Guidance for SPF Applications/Automotive 

Shops.

 Self-evaluation tool for contractors of practices and 

strategies to protect workers and promote the safe use 

of polyurethane products.

• Periodic assessment tool of their current practices and identify 

areas for improvement.

• Includes the following:

 Over 175 Activities (safer workplace practices). 

 Potential for exposure & impact on worker exposure.

 Four key-operation phases: on-going, pre-application, application, 

EPA Office of Pollution and post-application.

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Challenge - Training

 Ensure that all workers receive comprehensive training on 

hazards, curing rate, performance, equipment and 

processing, as well as communicating with others, 

including homeowners.

 Ensure premises are restricted to workers wearing 

appropriate personal protective equipment (PPE).

 Innovative solutions to prevent chemical migration 

should continue to be developed and shared to ensure 

industry-wide practice.

 Ensure homeowners, teachers and students, and the 

general public are not exposed to hazardous chemicals 

during and after polyurethane product applications.

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Prevention & Toxics
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Progress in Training

 Industry – ACC’s on-line H&S training & testing courses:

 Low Pressure SPF Chemical Health and Safety Training

 High Pressure SPF Chemical Health and Safety Training

 See http://spraypolyurethane.org/SPF-Chemical-Health-andSafety-Training

 SPFA certification and accreditation program: 

 SPF Professional Certification Program (PCP) for assistants, 

installers, master installers, program managers, and field 

examiner, see 

http://www.sprayfoam.org/index.php?page_id=4557

 Training courses at conferences/conventions 

 Chemical or Product Manufacturer-Contractor training

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Challenge - Assessing Exposures

 Data are needed to accurately assess the potential for 

exposures with variable applications & product 

formulations:

 Measuring total isocyanates exposure during application

 Measuring indoor air emissions/off-gassing of isocyanates and 

other polyurethane product ingredients (amines, SVOCs, flame 

retardants, etc.) and reactants.

 Answering the questions:

 When can other trade workers, building occupants, residents, 

and school children safely re-enter the premises after product 

application or installation?

 What are post-occupancy ventilation (H-VAC needs)?

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Progress in Addressing Exposure 

Assessment Needs & Data Gaps

 Comparative study to validate total reactive isocyanate groups (TRIG) 

monitoring method.

 Developing ASTM Methods (D22.05) for measuring chemical 

emissions from Spray Polyurethane Foam (see next slide).

 Evaluating the impact of incremental changes in ventilation rates on 

the concentration of Spray Polyurethane Foam vapor & particulates 

emitted. Included the development of a generic formula for 

evaluating Spray Polyurethane Foam emissions. 

 Evaluating dust from trimming operations. 

 International Research Conference (Isocyanates & Health: Past, 

Present, & Future, convened in April 2013, at the Bolger Center in 

Potomac, MD), see 

http://www.isocyanates2012.org/content/home.cfm

 Curing letter data submissions – see separate slide

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MDI and TDI Action Plans 

 Diisocyanates:

 Recognized as dermal and inhalation sensitizers

 May cause asthma, lung damage, and in severe cases, fatal 

reactions

 EPA is concerned about potential exposures to 

consumers and/or those commercial workers not 

covered under OSHA regulations, and the general 

population that could result from the use of products 

containing unreacted MDI, TDI, and related 

compounds. 

 e.g., application of spray-applied sealants and coatings when 

such products are used in or around buildings such as homes 

or schools

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MDI Action Plan

 Based on EPA’s screening-level review of hazard and 

exposure information EPA will consider the following 

actions: 

 Initiate TSCA section 8(d) reporting for unpublished health 

and safety studies for uncured MDI. 

 Consider initiating a TSCA section 4 test rule to require 

exposure monitoring studies in representative locations 

where commercial products are installed, including on-site 

application of insulation, sealants, coatings, and adhesives, 

and, exposure monitoring studies representatives of 

polyurethane products installed in the home (i.e., 

insulation) or used by the consumer (i.e., foam mattresses). 

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TDI Action Plan 

 Based on EPA’s screening-level review of hazard and 

exposure information EPA will consider the following 

actions: 

 Initiate rulemaking under TSCA section 5(a)(2) for a Significant 

New Use Rule (SNUR) designating certain uses of TDI in a 

consumer product as a new use requiring prior notice to the 

Agency. 

 Initiate a TSCA section 8(d) rule for reporting of unpublished 

health and safety studies.

 If information indicates further actions are warranted, EPA 

would then consider initiating a TSCA section 4 test rule to 

require exposure monitoring studies in representative 

locations where commercial products would be used.

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Other Potential Regulatory Actions 

 Consider issuing a data call-in under TSCA section 8(c) 

Allegations of Adverse Effects 

 Consider TSCA section 6 action that gives EPA the 

authority to protect against unreasonable risk of injury to 

health or the environment -

 If EPA finds that there is a reasonable basis to conclude that the 

chemical's manufacture, processing, distribution, use or disposal 

presents an unreasonable risk.

 Actions could include but are not limited to: prohibiting or 

limiting manufacture, processing, or distribution in commerce of 

a chemical; requiring warnings and instructions with respect to 

use, distribution, or disposal; and/or, recordkeeping 

requirements.

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Information Request Authority 

 For the purposes of carrying out TSCA, EPA requested 

companies voluntarily provide certain information to 

the Agency -

 EPA specifically requested information on the curing time 

required to chemically react all diisocyanate functional groups, 

and 

 The amount of time required to safely re-occupy or use an 

area where diisocyanates have been reacted

 The Agency is reviewing the information to determine 

what it tells us about consumer and worker exposure 

to polyurethane products. 

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Types of Information or Data Received 

from the Information Request 

 EPA received the following types of data as a result of 

our request including: 

 Formulation Data

 Safety Data Sheets

 Industrial Hygiene Studies 

 Curing information

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Challenge – Development of Test 

Methods to Measure Emissions

 Need methods and data that paint the picture of “source-toexposure”, over the life-cycle of the polyurethane product. 

 Recognize as complex undertaking and its important to keep 

that in mind as develop specific test systems and protocols to 

address aspects of the larger goal. 

 Need multiple approaches to characterize stage-specific 

emissions for the product(s). 

 Need to develop/demonstrate methods that capture the 

“normal” cure phase emissions because that is a benchmark for 

evaluating emissions and off-spec conditions, wherein –

 A methodology is a tool that industry uniformly uses to evaluate 

product formulations, and 

 Federal and/or state Agencies have access to data to better assess 

the potential for exposures, including modeling exposures under 

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Progress - Test Methods Development

 EPA’s Office of Research and Development is developing test 

methods and protocols to generate reliable data to fill knowledge 

gaps related to polyurethane products, including

 What is emitted and for how long? 

 What factors impact emissions? 

 This work supports the ASTM Committee D 22.05 Spray

Polyurethane Foam Insulation (SPFI) emissions test method 

development task, which is a component of a broader strategy to 

develop test methods specific to SPFI, as well as tool and models 

to relate product emissions to potential exposures.

 Test method development could be used in exposure monitoring 

studies for uncured diisocyanates to allow for better 

understanding of potential exposures in uncontrolled settings.

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Significant New Use Rules (SNURs)

 TSCA section 5(a) authorizes EPA to determine that a use of a 

chemical substance is a “significant new use.” EPA must make this 

determination by rule after considering all relevant factors, including 

those listed in TSCA section 5(a)(2), i.e., 

 The projected volume of manufacturing and processing of a chemical substance.

 The extent to which a use changes the type or form of exposure of human beings 

or the environment to a chemical substance

 The extent to which a use increases the magnitude and duration of exposure of 

human beings or the environment to a chemical substance

 The reasonably anticipated manner and methods of manufacturing, processing, 

distribution in commerce, and disposal of a chemical substance

 A SNUR requires that manufacturers and processors of the chemical 

subject to the SNUR notify EPA at least 90 days before beginning any 

activity that EPA has designated as a "significant new use”

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Proposed SNUR for TDI 

and Related Compounds 

 The Action Plan covered toluene diisocyanates (TDI) 

and TDI-related compounds, and stated that EPA 

would initiate a rulemaking under TSCA section 5(a)(2) 

for a Significant New Use Rule (SNUR) designating 

certain uses of TDI in consumer products as a new use 

requiring prior notice to the Agency. 

 EPA plans to issue a proposed SNUR for TDI and 

related compounds in 2014. 

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Federal Agency Coordination

 Since 2009, these federal agencies have pursued actions 

related to workers and consumers: 

 On June 25, 2013, US OSHA announced a three year National 

Emphasis Program on isocyanates that will focus outreach efforts 

and inspections on specific hazards for workplaces, construction, 

and maritime industries. OSHA is also revisiting isocyanate PELs.

 On June 24, 2013, NIOSH published a request for information on 

TDI and other TDI-based isocyanate products to develop a Criteria 

Document to establish an updated Recommended Exposure Limit 

(REL) for TDI.

 On April 23, 2013, CPSC announced new guidance to clarify the 

definition of “strong sensitizer” under the Federal Hazardous 

Substances Act (FHSA), which would require cautionary labeling. 

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Summary

 The CASE industry needs to ensure:

 There is comprehensive and clear hazard communication for all CASE 

users – applicators, assistance, other trades, do-it-yourselfers, 

consumers, and other decision-makers (i.e., building managers, etc.).

 Consumers need clear hazard and use warnings, such as through 

product labeling and communications with commercial contractors.

 The work site is restricted to only those wearing appropriate personal 

protective equipment.

 Quality control - avoid installation of off-spec, poor performance 

polyurethane materials. (see saferproducts.gov for complaints of offgas persistence). 

 Guidance is provided on re-occupancy time & long-term ventilation 

(H-VAC) needs.

 Marketing claims are accurate and balanced.

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Where to Get More Information?

 EPA’s DfE SPF website at http://www.epa.gov/dfe/pubs/projects/spf/

spray_polyurethane_foam.html

 NIOSH Alert on Spray-on Truck Bed Lining Operations at 

http://www.cdc.gov/niosh/docs/2006-149/default.html

 OSHA’s isocyanates website at http://www.osha.gov/SLTC/isocyanates/index.html

 OSHA’s Green Jobs Hazards website at http://www.osha.gov/dep/greenjobs/index.html

 EPA’s Action Plan website for MDI: 

http://www.epa.gov/opptintr/existingchemicals/pubs/actionplans/mdi.pdf

 Docket MDI http://www.regulations.gov/#!docketDetail;rpp=10;po=0;D=EPA-HQ-OPPT2011-0182

 American Chemistry Council—Center for the Polyurethanes Industry website at 

http://www.spraypolyurethane.org/

 Spray Polyurethane Foam Alliance’s website at http://www.sprayfoam.org/

 Project Coordinators: 

 Carol Hetfield; 202-564-8792; hetfield.carol@epa.gov

 Katherine Sleasman; 202-564-7716; sleasman.katherine@epa.gov

EPA Office of Pollution Prevention & 

Toxics
Thank You