Thank you for the opportunity to speak at today's hearing. I am Mike Krupa, one of the Technical 

Managers at BASF Corporation. BASF supplies chemicals that are used to make polyurethane 

foams for insulation and other markets affected by the proposed HFC changes. HFCs are used as 

blowing agents and act as the main component to improve insulation properties of the foam. We 

have been involved in all of the previous blowing agent changes as directed by the Montreal 

Protocol. During all of the blowing agent changes, a great deaf of formulation work is always 

necessary. In almost every case, a change in the blowing agent requires a major formulation 

change to provide a product that works for our customers. The previous changes from CFCs to 

HCFCs and then to HFCs was not easy and did not occur without a lot of challenges. There was a 

lot of cost incurred due to trials, production runs, and higher levels of scrap until the formulations 

could be optimized for each customer. 

We are also concerned about the availability of the new blowing agents. HFO products are 

available from Arkoma and Honeywell with another product from DuPont pending TSCA approval. 

These manufacturers can comment on commercial status and quantities of available products. The 

indications that we have been given are that the available supply as of 1 January 2017 will be 

insufficient to meet the needs of the affected industries. The alternative low GWP blowing agents 

that are readily available right now are either flammable or do not provide adequate insulation 

properties. There is a large capital investment and several years to implement flammable blowing 

agents for a customer that does not currently have that capability. 

Timing is our most important concern. The time required to affect the changes discussed here is 

significant. We estimate that simply introducing and qualifying new products at each of our affected 

customers will take a full yeaDto complete. Thii doi'S nat i~clud8 tAo tiffle to deoelo~ Rew ~r:gducti· 

·tAat vaFies witA gnd_,,se application and elewi1 19 iiiQi'Rt :l1g1ce WAICfi Will take at leset 1 year to 

GeFRI'fele. Many of our customers require agency approval certifications to sell products requiring a 

flammability rating. These approvals are granted by UL (Underwriter's Laboratories) and FMGiobal 

(Factory Mutual Insurance Company). As the change in blowing agent is wide spread, affecting 

multiple industries, UL and FMGfobal are likely to run into serious capacity constraints regarding 

their ability to provide individual product certifications per customer. As the process is often iterative, 

these delays will have a compounding effect on the industry's ability to change all product 

formulations in l~]i th1m J ~rs' tim~. 

·f'. '- rTw t;me ~e . 

We have already implemented low GWP blowing agent changes at some of our largest customers. 

These conversions took approximately 5 years to complete. Conversions at our small customers will 

likely be last. We simply do not t'l.ave .the time or resources to ensure a smooth transistion to the ,. l., v r --t, me f<1.,.., t., 

new blowing agents. ' B ased 'upon the information presented here and what we have learned from 

our industry partners, BASF would suggest that a delay in the implementation of the proposed rule is 

necessary. We would support a scheduled phase out of1HFCj 34a and HFC 245fa as blowing nJ t:·tV'//'1!. r f /J-m. 

agents for non-spray polyurethane foams effective January 1, 2020.