March 9, 2010

Ms. Robin Hunt Fomo Products, Inc.

2775 Barber Road Norton, Ohio 44203

Dear Robin:

Please find enclosed the report of the industrial h ygiene evaluation conducted by Bayer MaterialScience on February 4, 2010 at your facilit y in Norton, OH. The airborne levels of 2,4- and 4,4-diphenylmethane diisocyanate (MDI) were measured during the production of one component polyurethane foam, as w ell as during the test application of one and two-component low pressure polyurethane foa m systems.

It was a pleasure being of service to you, and I’d like to express my appreciation for the cooperation that I received from your personnel. P lease feel free to contact me if you have any questions.

Sincerely,

Brian F. Karlovich, CIH, CSP Manager, Industrial Hygiene Customer Services Product Safety & Regulatory Affairs Department (412) 777-4808 FAX (412) 777-7484

cc: N.Goshen J. Chapman/DOC

Enclosure

# An Evaluation of

Airborne Methylene Diphenyl Diisocyanate (MDI)

at

Fomo Products, Inc. Norton, OH

Conducted and Reported by: B.F. Karlovich, Manager - Industrial Hygiene Custo mer Services,

Product Safety & Regulatory Affairs

Date of Evaluation: February 4, 2010 Date of Report: March 9, 2010

The testing and evaluation described in this report have been conducted as a customer service at no ad ditional charge to the Customer. As such, any information containe d in this Report has been obtained in accordance wi th industry standards and is, to the best of our knowledge, tru e and accurate, and is based only upon the conditio ns observed at the time of the evaluation. The test results, reco mmendations and/or suggestions contained in this Re port are made only as a courtesy as part of our customer service and Bayer makes no warranty, either expressed or im plied, with respect to any such test results, recommendations a nd/or suggestions.TABLE OF CONTENTS

PAGE

SUMMARY ............................................

................................................... .....................1

I. INTRODUCTION...................................

................................................... ........2

II. PROCESS OBSERVATIONS .......................... ................................................2

III. CRITERIA.....................................

................................................... ..................4

IV. SAMPLING AND ANALYTICAL TECHNIQUES............ ...........................5

V. RESULTS AND DISCUSSION ............................ ............................................6

VI. RECOMMENDATIONS...............................

................................................... .7

TABLE 1 Airborne MDI Concentrations - Personal & A rea Samples....................81 SUMMARY

On February 4, 2010 air sampling for methylene diph enyl diisocyanate (MDI) was conducted during the production of one component polyurethane foam products, as well as during the test application of both one and two component polyureth ane foam products at Fomo Products, Inc., Norton, Ohio. Both personal and area samples were collected. Sample results are

summarized in Table 1.

Personal Samples

Airborne MDI was detected in the two samples collec ted in the breathing zone of the aerosol line operator. The airborne concentrations were 15 and 2.7 ug/m 3 , with a corresponding sampling period TWA concentration of 8.8 ug/m 3 . This value does not exceed the ACGIH 8-hr. TLVTWA of 51 ug/m 3

.

Airborne MDI was not detected at or above the analy tical quantitation limit in three short-term air samples collected in the breathing zones of 1) the technical training representative during the application of the E84 Class I Refillable System in the Training Lab hood, using the “10, 10, 10” rule, 2) the product manager during the application of a two component 205 Disposable Kit in the Spray Lab hood, using the “10, 10, 10” rule, an d 3) the product manager during the application of one component HandiFoam in the Humid ity Chamber. Therefore, the OSHA PEL-C of 200 ug/m 3 was not exceeded.

Airborne MDI was identified at a level of 89 ug/m 3 in the one short-term air sample collected in the breathing zone of the product manager during th e continuous application of the 205 Disposable Kit in the Training Lab hood. However, the OSHA PEL-C of 200 ug/m 3 was not exceeded. Because the employee wore an air purifyi ng respirator during this activity, the airborne concentration to which the employee was po tentially exposed was likely less than the

measured concentration. It is of note that the loc al exhaust ventilation hood was purposely not operated during this activity.

Area Samples

Airborne MDI was identified at 3.0 and 1.1 ug/m 3 in the two samples collected near the dispensing heads of the aerosol filling station.

Airborne MDI was not identified at or above the ana lytical quantitation limit in the two area samples collected at a distance of 10 feet from spr aying activities, or in the two area samples collected beginning one hour following spraying act ivities in the Training Lab.

Recommendations based on results and observations a t the time of the evaluation appear on Page 7.2

I. INTRODUCTION

At the request of Fomo Products, Inc., the Bayer Ma terialScience (BMS) Product Safety & Regulatory Affairs Department sampled for potential airborne MDI during the manufacture of one and two component low pressure polyurethane foa m systems, as well as the test application of these systems. BMS supplies Fomo with Mondur MR Light, which contains approximately equal amounts of monomeric MDI and polymeric MDI.

II. PROCESS OBSERVATIONS

The Norton facility blends and packages various-siz ed one and two-component low pressure polyurethane foam systems. The one component syste ms dispense somewhat like a caulking, whereas the two-component systems are spray applied . The aerosol filling operation was evaluated during this investigation. In addition, air sampling was conducted during the test application of some of Fomo’s one and two-component low pressure polyurethane foam systems.

The aerosol line is highly automated and is located in a large production area (greater than 10,000 square feet with ceilings of approximately 15 feet) . Two lines, 1 and 2, are immediately adjacent to and run parallel with one another. For each lin e, a conveyor first delivers empty metal cans (typically 12 or 24 ounce) to the aerosol filling s tation, where two heads dispense MDI under low pressure into the tops of two cans for a period of about 1 to 2 seconds. Following this, the cans proceed a short distance down the line, and two add itional heads dispense polyol blend into the tops of the cans, also for a period of about 1 to 2 seconds. Heads that dispense other additives are also present and are used for certain products. Following the addition of product, valves are then automatically added to the tops of the cans. The cans then proceed to the “Gas House” where propellant is injected. Following the Gas Ho use, the conveyor delivers the cans to a station where collars are added (for products that use a gun attachment), and then to the shaker (10 to 15 shakes per can). The cans are then subme rged in a “hot bath” to increase the temperature to about 120 degrees Fahrenheit, and th en proceed through a cold bath. The cans

then move to the “Blower House” to be dried with fa st moving air. The cans then proceed along to the labeler, capper, and adapter placer, before being fitted with an outer thin plastic sleeve, which is then heated via heat gun, and then followe d up by a heat tunnel. The cans are then boxed up manually. From here, the boxes of cans pr oceed to the palletizer. The pallet with boxes of product is then shrink wrapped, at which p oint it is ready for shipment. On the day of the evaluation, the products produced included 24-o unce Window and Door, 12-ounce Straw Foam, and 12-ounce Window and Door. Approximately 14,000 cans were produced in total.

The aerosol filling station is equipped with a cano py hood; the dimensions of the hood face are approximately 4 feet by 4 feet. The face of the ho od is located about 6 feet above the floor. Smoke gun testing indicated that air was moving slo wing into the hood.

Fomo has implemented a “10, 10, 10” policy where tw o component spray polyurethane foam systems are being demonstrated for customers, or wh ere customers are being trained. The policy is reportedly used at both the Fomo facility as wel l as at customer locations. The policy is as3

follows. Spraying is permitted for no more than 10 seconds at a time; observers must be at least 10 feet away from the applicator; and there is a mi nimum 10-minute waiting period between spraying events.

On the day of the evaluation, test application of v arious Fomo products were conducted in the Training Lab, Spray Lab, and Humidity Chamber. The Training Lab is approximately 24 feet by 19 feet by 12 feet high. Two supply air diffusers are located in the ceiling. A local exhaust ventilation hood with the dimensions of approximate ly 6 feet wide, by 3 feet deep, by 6 feet high is located in the far corner of the room. Two comp onent foam kits are applied into simulated

wall cavities or onto other substrates in the hood. The hood is reportedly operated during spraying; however, Fomo chose to not operate the ho od on the day of the evaluation in order to represent worst case conditions.

The room that houses the Spray Lab is approximately 45 feet by 20 feet by 18 feet high. One supply air diffuser was observed in overhead ductwo rk. A local exhaust ventilation hood with the dimensions of approximately 10 feet wide by 5 f eet deep is present in the Spray Lab. Similar to the hood in the Training Lab, two component foam kits are applied into simulated wall

cavities or onto other substrates in the hood. The hood is reportedly operated during spraying; however, similar to the Training Lab hood, Fomo cho se to not operate the hood on the day of the evaluation in order to represent worst case conditi ons.

The Humidity Chamber is approximately 8 feet by 16 feet by 8 feet high. One supply air diffuser was observed in the ceiling. The room is reportedl y kept at a relative humidity of approximately 50 percent for the purpose of testing single-compon ent foam products.

Three employees were monitored during this investig ation, an aerosol line operator, a technical training representative, and a product manager. Th e aerosol line operator worked at both Lines 1 and 2. His primary tasks were to restock the conve yor lines with empty cans and valves, and to weigh the aerosol cans at different stages of the p rocess for quality control purposes. He wore boots, pants, a short sleeved work shirt, safety gl asses with side shields, disposable latex gloves, and earplugs.

The technical training representative demonstrated the “10, 10, 10” rule in the hood of the Training Lab. He applied a two component “E84 Clas s I Refillable System” to a cardboardlined, simulated wall assembly (2” by 4” framing) i n the hood. The E84 Class I Refillable System was equipped with a 10-inch HandiGun with a disposable tip and a Magnum hose heater (80 degrees F). Dynamic pressure at the gun was re ported to be approximately 75 pounds per square inch. The product was applied for 10 second s, and then applied for another 10 seconds 10 minutes later. The total length of the activity wa s 15 minutes. When not spraying, the employee stood at approximately the same location as when sp raying. As previously stated, the ventilation hood was not operated. The door to the Training La b was closed during the sampling period. The employee wore boots, jeans, a short sleeved shi rt, safety glasses with side shields, Duraskin disposable nitrile gloves, and disposable plastic s leeves to cover the forearms.4

The product manager conducted three separate tasks. The first task was the application of a two component “205 Disposable Kit” into cardboard boxes on the floor in the hood in the Training Lab. One entire kit was dispensed over a period of approximately 15 minutes. The ventilation hood was not operated, and the door to the room was closed. The product manager wore shoes, pants, fabric lab coat, half mask air purifying res pirator with organic vapor cartridges, disposable nitrile gloves, and safety glasses with side shield s during this activity.

The product manager’s second task was to apply a on e component “HandiFoam” with attached straw dispenser to plastic covered cardboard sheets in the Humidity Chamber. The cardboard sheets were located on a desktop about 3 feet above the floor. The foam was nearly continuously applied in a bead width of about 3/8-inch. Approxi mately one and one half cans were used over a 15-minute period. The door was closed during thi s activity. The employee wore shoes, pants, fabric lab coat, High Five disposable latex gloves, and safety glasses with side shields during this activity.

The product manager’s third task was to demonstrate the “10, 10, 10” rule in the hood of the Spray Lab. She applied the two component “205 Disp osable Kit” to a piece of cardboard on the back wall of the hood at a height of about 3 to 4 f eet above the floor. The product was applied for 10 seconds, and then applied for another 10 sec onds 10 minutes later. The total length of the activity was 15 minutes. When not spraying, she st ood at approximately the same location as during spraying. As previously stated, the ventila tion hood was not operated. She wore shoes, pants, fabric lab coat, Duraskin disposable latex g loves, and safety glasses with side shields during this activity.

III. CRITERIA

MDI

The American Conference of Governmental Industrial Hygienists (ACGIH) has adopted a Threshold Limit Value - Time Weighted Average (TLV- TWA) for 4,4’-methylene bisphenyl isocyanate (MDI) of 0.005 parts per million (ppm) (i.e., 5 parts per billion, ppb) or 51 micrograms per cubic meter of air (ug/m 3 ). This is an airborne concentration for a normal 8-hour workday and a 40-hour workweek and represents condi tions under which nearly all workers can be exposed without adverse effect. In addition, th e federal Occupational Safety and Health Administration (OSHA) has established a Permissible Exposure Limit (PEL) for 4,4’-MDI of 0.02 ppm or 200 ug/m 3 as a Ceiling (C) limit. The Ceiling limit is a co ncentration that should not be exceeded during any part of the day.

At present, neither an ACGIH TLV nor a federal OSHA PEL has been established for 2,4’-MDI or polymeric MDI. However, Bayer MaterialScience r ecommends that the exposure limits for 4,4’-MDI be used for the 2,4’- MDI isomer.

The United States Environmental Protection Agency ( EPA) has established a Reference Concentration (RfC) for 4,4’-MDI of 0.06 ppb (0.6 u g/m 3 ). The RfC is for chronic inhalation5

exposure, and represents the airborne exposure to t he human population (including sensitive subgroups) that is likely to be without an apprecia ble risk of deleterious effects during a lifetime.

IV. SAMPLING AND ANALYTICAL TECHNIQUES

Where spraying activities were conducted, samples o f airborne MDI were collected using glass impingers containing 15 milliliters of a solution o f toluene and 1-(2-pyridyl)piperazine, backed up by coated 13mm glass fiber filters mounted in Sw innex holders, and connected to A.P. Buck Basic 5 air sampling pumps. The impinger/filter sam pling trains were either attached to the workers' lapels (i.e., personal samples) or placed in the surrounding work area (i.e., area samples). All pumps were calibrated before sample collection to a sampling rate of approximately 1 Lpm using a Bios DryCal ® DC-Lite Primary Air Flow Meter. The sampling rate was reconfirmed after the sampling event, with the average value used in the sample volume calculation. Prior to mounting the filter to the S winnex holder, each filter was coated with 2 mg of 1-(2-pyridyl)piperazine and diethyl phthalate. Immediately upon completion of sampling, the impinger solution was transferred to sample bottles , and the filters were removed from the

Swinnex holders and desorbed in 2 ml of acetonitril e/dimethyl sulfoxide (90:10 v/v) solution. When airborne MDI is drawn through the impinger sol ution (and treated filter) it is converted to a stable urea derivative, which is quantitatively a nalyzed by HPLC using Bayer MaterialScience Method 1.20.0. The 13mm filters were analyzed acco rding to Bayer MaterialScience Method

1.7.7.

Where spraying activities were not conducted, sampl es of airborne MDI were collected using 1- (2-pyridyl)piperazine and diethyl phthalate-coated 13mm glass fiber filters mounted in Swinnex holders, and connected to SKC Airchek 52 air sampli ng pumps. The filters were either attached to the workers' lapels (i.e., personal samples) or placed in the surrounding work area (i.e., area samples). The 13mm filters were analyzed according to Bayer MaterialScience Method 1.7.7.

All samples collected were analyzed at the Bayer Ma terialScience Industrial Hygiene Laboratory, which is accredited by the AIHA.

Airflow

Air movement in the aerosol filling station area wa s assessed with a TelTru TM Borozin A.C. Gun (i.e., smoke gun) that uses 100% Air Test Grade Zin c Stearate as the testing powder.6

V. RESULTS AND DISCUSSION

The analytical results are presented in Table 1. N ote that the reported MDI values for the samples collected during/following spraying activit ies represent MDI found in the impinger solution only, as MDI was not identified in any of the back-up 13mm filters.

Personal Samples

Airborne MDI was detected in the two samples collec ted in the breathing zone of the aerosol line operator. The airborne concentrations were 15 and 2.7 ug/m 3 , with a corresponding TWA concentration of 8.8 ug/m 3 . This value does not exceed the ACGIH 8-hr TLV-TW A of 51 ug/m 3

.

Airborne MDI was not detected at or above the analy tical quantitation limit in the one short-term sample collected in the breathing zone of the techn ical training representative during the application of the E84 Class I Refillable System in the Training Lab hood, using the “10, 10, 10” rule. Therefore, the OSHA PEL-C of 200 ug/m 3 was not exceeded.

Airborne MDI was not detected at or above the analy tical quantitation limit in the one short-term sample collected in the breathing zone of the produ ct manager during the application of the two component 205 Disposable Kit in the Spray Lab hood, using the “10, 10, 10” rule. Similarly,

airborne MDI was also not detected at or above the analytical quantitation limit in the short-term sample collected during the application of the one component HandiFoam in the Humidity Chamber. Therefore, the OSHA PEL-C of 200 ug/m 3 was not exceeded for either of these samples.

Airborne MDI was identified at a level of 89 ug/m 3 in the one short-term sample collected in the breathing zone of the product manager during the ap plication of the two component 205 Disposable Kit in the Training Lab hood. However, the OSHA PEL-C of 200 ug/m 3 was not exceeded. Because the employee wore a half mask ai r purifying respirator during this activity, the airborne concentration to which the employee wa s potentially exposed was likely less than

the measured concentration.

Area Samples

Airborne MDI was identified at 3.0 and 1.1 ug/m 3 in the two samples collected near the dispensing heads of the aerosol filling station.

Airborne MDI was not identified at or above the ana lytical quantitation limit in the two area samples collected at a distance of 10 feet from spr aying activities, one for the E84 Class I Refillable System, and one for the 205 Disposable K it. Airborne MDI was also not identified in the two area samples collected beginning one hour f ollowing continuous 205 Disposable Kit spraying activities in the Training Lab.7

VI. RECOMMENDATIONS

The following recommendations are based on the samp ling results and observations that occurred during the day of this evaluation.

1. Should the aerosol line operator have potential han d contact with MDI, gloves made of nitrile, neoprene, butyl, or PVC are recommended.

2. The reported practice of operating the local exhaus t ventilation hoods in the Training Lab and Spray Lab when spraying two component foam prod ucts should be continued.

3. The half mask air purifying respirator observed in use during continuous 15-minute spraying of the Disposable 205 Kit in the Training Lab hood should continue to be used for this activity, particularly if the hood is not operated. However, a cartridge that will remove aerosols (P100) in addition to organic vapor s is recommended.

4. The air sampling results suggest that the observanc e of the “10, 10, 10” rule at the Fomo facility for the E84 Class I Refillable System and the 205 Disposable Kit should be effective in minimizing airborne MDI concentrations for the applicator and observers.8 TABLE 1 AIRBORNE METHYLENE DIPHENYL DIISOCYANATE (MDI ) CONCENTRATIONS

Personal & Area Samples – Fomo Products, Inc. Norton, Ohio – February 4, 2010

Sample

Number Name/

Job Description/Location Sampling

Period Sample

Volume (liters) 2,4’-MDI

(ug/m 3 ) 4,4’-MDI

(ug/m 3 ) Total MDI

(ug/m 3 ) TWA 1

(ug/m 3 )

PERSONAL SAMPLES – LONG TERM

006-1 7:04-11:08 251.3 1.51 13.1 15 8.8

006-2 Aaron Runyon, Aerosol Line Operator

11:08-15:03 242.1 ND 2 2.73 2.7

PERSONAL SAMPLES – SHORT TERM
308-1 Derrick Hyde, Technical Training Representative, Applies E84 Class I Refillable System in Training Lab Hood (“10, 10, 10”) 8:18-8:33 15.7 ND ND ND --

308-2 Sandy Gump 3 , Product Manager, Applies 205 Disposable Kit in Training

Lab Hood 8:50-9:05 15.3 17.0 71.9 89 30

308-4 Sandy Gump, Product Manager, Applies 205 Disposable Kit in Spray Lab Hood (“10, 10, 10”) 10:41-10:56 15.5 ND ND ND

442-1 Sandy Gump, Product Manager, Applies One Component HandiFoam in Humidity Chamber 9:15-9:30 15.4 ND ND ND

AREA SAMPLES

900-1 7:00-11:09 264.7 0.60 2.46 3.0 --

900-2 Aerosol Filling Station, Between Lines 1 and 2, immediately upline of dispensing heads, about 5 feet above

floor 11:09-15:03 248.7 0.40 0.68 1.1 --

531-1 On cart, 10 feet from Training Lab hood, 3 feet above floor, during E84 Class I Refillable System application (“10, 10, 10”) 8:18-8:33 15.3 ND ND ND --

308-3 On cart, 10 feet from Training Lab hood, 3 feet above floor, one hour following end of 15-minute application

of 205 Disposable Kit 10:05-10:20 15.8 ND ND ND --

531-2 On cart, 10 feet from Training Lab hood, 3 feet above floor, started at one hour following end of 15-minute application of 205 Disposable Kit 10:05-13:05 178.2 ND (<0.56 ug/m 3 ) ND

(<0.56 ug/m 3 ) ND --

309-1 On desk top, 10 feet from Spray Lab hood, 3 feet above floor, during application of 205 Disposable Kit (“10, 10, 10”) 10:41-10:56 15.5 ND ND ND --

1. Time Weighted Average (TWA) based on the combine d samples. 2. ND (Non-detectable) – concentration was less th an the analytical Limit of Quantitation (LOQ) of 0. 1 μ g/sample. For samples that were 15 minutes in duration, the corresponding total MDI concentration is of approximately <13 ug /m 3

. 3. Employee wore a half mask air purifying respira tor during this activity. Therefore, the airborne concentration to which the employee was potentially exposed was likely le ss than the concentration shown.