I j Yn l I " p 674 7

 Campobello Rdv Mississauga, Ontario, L5N 217, Canada 

M \t I IvkllhlN C Tel: 905-3634040 • Toll Free: 800-758-7325 • Fax: 905-363-0102 

December 18, 2012 

c__ 

U.S. Environmental Protection Agency "Orn 

Leslie Cronkhite, (7405M) ^ 3r n 

Chemical Control Division _„ o. < 

CTrn 

Office of Pollution Prevention and Toxics 3£ — — Office of Chemical Safety and Pollution Prevention 

1200 Pennsylvania Aver 

Washington, DC 20460 

O C 3 

1200 Pennsylvania Avenue, N.W. o 

Dear Ms. Cronkhite, 

Re. EPA Data Request on MDI, TDI, and Related Compounds Issued September 19,2012 as 

Clarified by Email November 8,2012. 

Further to the request outlined above, I am pleased to provide a package of information 

covering the various products we sell in the US. The package contains studies, tests, TDS -

Technical Data Sheets, MSDS and evaluations performed on our products by third parties 

independent in their assessments. Thank you for giving us the opportunity to submit this 

package for review. 

Before explaining what is in the package, I feel it is important to explain the workings of our 

company, our product line and our approach to the market so that you can understand our 

approach to product stewardship. 

Icynene is a trusted brand name in spray foam for reasons that go well beyond the products we 

sell. We do not sell to distributors or wholesalers. We do not sell to the public. We sell to a 

network of licensed "Dealers"—contractors who use the Icynene brand name to bring credibility 

to their business under a signed commitment to buy low density spray foam exclusively from us 

and increasingly the agreement is being expanded to include medium density products as well. 

Our Dealers are provided with a three-day orientation to our products, Spray Foam Technology, 

Health and Safety, Building Science and Codes, and Troubleshooting. We also provide two-day 

Field Sprayer Training. We also require all site personnel take the CPI Chemical Health and 

Safety Training on line before they can access any of these resources and go on-site. We provide 

on-line webinars and field training support every time we introduce new products or new 

approvals for existing products. 

CONTAINS NO CBI 
p. 2 

We do this so dealers can represent that are part of a network of contractors with products that 

have been properly tested sold only to individuals who understand how to handle and install 

them properly. We are not in the "DIY" or unlicensed contractor sales business. 

As a recognized brand name, we are frequently called upon to look into complaints about 

products that call themselves "Icynene" but are, in fact, imposters. Given the fact that we do 

not sell through distribution, we have greater control in knowing who those imposters are. 

Particularly, with respect to High Pressure Open Cell products, our products have unique 

characteristics that allow us to perform laboratory tests to identify the vast majority of 

imposters. 

Our product line is focused on High Pressure Spray Foam. As such, our products are used in 

fixed-volume proportioner spray systems. Core products include: 

High Pressure Low Density Spray Foam (Open Cell /Water Blown) 

• Icynene LD-C-50 / LD-C-50 v2 {Icynene CLASSIC and CLASSIC MAX) 

• Icynene LD-R-50 (Icynene RENEWABLE) 

High Pressure Medium Density Spray Foam (Closed Cell/Blowing Agent Formulation) 

• Icynene MD-C-200 

High Pressure Medium Density Spray Foam (Water Blown) 

• Icynene MD-R-200 (Open Cell/Water Blown) 

• Icynene MD-R-210 (Closed Cell/Water Blown) (This product is currently being pilot 

tested to be released in 2013 and may replace MD-R-200) 

We sell other specialty products that compliment this core product line including Ignition and 

Thermal Barrier paints, as well as, Vapor Retarder Paints manufactured by others but because 

these products do not contain MDI or TDI, we have not included them in this submission. 

I also wanted to explain our naming system for products so you understand and are not 

confused by subtleties in the information I am providing. Our technical naming system is as 

follows: 

LL-TT-DDD, where 

• LL is a two letter short form used to describe the density class of the foam (either LD for 

Low Density or MD for Medium Density usually) 

• TT is a one or two letter short form used to describe a special attribute (C for 

conventional, R for Renewable etc.) 

• DD is the nominal density of the product (50 fbrH lb density,200 for 2 lb density) 

So for example, MD-C-200 is a Medium Density, Conventional Closed Cell, 2 lb density foam. 

Our Water Blown Foams all use the SAME A-side MDI. It is only the B-side resin that is different. 

Our Blowing Agent Foam (MD-C-200) is the only product with its own unique MDI. 

Page 2 of 6 
p. 3 

So in our array of MSDS sheets, you will see many different MSDS sheets for B-Side Resins and 

relatively few for A-Side MDI's. 

For more than 20 years of its 26 year history, our company sold and built its reputation on one 

Low Density, High Pressure, Open Cell, Spray Polyurethane Foam product. That product has, 

over the years, variously been called Icynene "Gold Seal", Icynene "Classic" and Icynene "LD-C50." In terms of the wording in various reports, you can substitute Icynene LD-C-50 for Gold Seal 

and the various other names that may appear in the text of older reports in particular. Just 

recently, Icynene also introduced a new product LD-C-50 v2 into the marketplace. That product 

contains almost insignificant changes in formulation (less than .6% by weight) to improve 

attributes such as shelf life and spray performance, but for the purposes of any evaluation of 

curing, off-gassing and re-occupancy time, is essentially the same product as LD-C-50. So again 

LD-C-50 and LD-C-50 v2 are synonymous. 

Naturally, because LD-C-50 is our top selling product, and because it has been around the 

longest, there are more reports, compiled over a longer period than any other product in our 

portfolio. Some reports are quite old but help to demonstrate performance over the years. 

Product development and improvement is ongoing. Our newest product, not yet released for 

full commercialization in the US is MD-R-210. When it is released, it will be the only 100% Water 

Blown, Closed Cell, Medium Density foam on the market today. Though it is preliminary, and the 

product is not yet commercialized, we wanted to provide information (limited though it may be) 

even on the revolutions in our product development pipeline, as well. 

Your request for information asked for many things. It was difficult to see whether we should 

organize the information by product or by data theme or by some other classification system. 

In the end, we chose a hybrid approach to organize the information you have requested: We 

sorted the external, third party test data and reports by product. Then we grouped the TDS and 

MSDS sheets together, based on the fact that this info was compiled based on a combination of 

internal and external testing. And finally, we added the health and safety testing in our lab and 

plant since ongoing monitoring of MDI is part of our external health and safety monitoring but 

not necessarily tied to only one specific product. 

Our submission is presented in a three ring binder (and in soft copy on a memory key stick) with 

tabs (folders) as follows: 

1. LD-C-50 Data 

2. LD-R-50 Data 

3. MD-C-200 Data 

4. MD-R-200 Data 

5. MD-R-210 Data 

6. Technical Data Sheets (All Products) 

7. Material Safety Data Sheets (All Products) 

8. In Plant Health and Safety Testing (All Products) 

Page 3 of 6 
p. 4 

A detailed table of contents lists the reports found within each tab. 

So with reference to your letter of September 19,2012,1 will attempt to point you towards the 

studies / data that provide the best answers to your questions laid out on Page 2 of that letter. 

1. Product Type: 

Our products are all intended as whole building insulation/air barrier products. They are 

applied by high pressure spray systems. 

2. Chemical composition of the formulated products: 

The major chemicals in ourformulations are listed in the MSDS sheets supplied in Tab 7 

(Folder 7). These documents list all the hazardous and reportable compounds in each 

product. If the full proprietary listing of exact mixtures is still required, EPA can contact 

Mr. Larry Genyn, VP Technology of Icynene, to release this info as Confidential Business 

Information. 

3. Sensitivity Analysis: 

All our products are proportioned on a 1:1 basis and the equipment user is given no 

flexibility adjust mixtures off-ratio. Slight off-ratio mixtures can occur if there is a large 

difference in viscosities/pressures of A-side and B-side chemicals. Processing 

instructions on our TDS sheets in Tab 6 (Folder 6) are designed to minimize / avoid this 

outcome. Installers are taught to recognize off-ratio foam and remove it if it occurs. 

There is also a financial incentive for installers to avoid off-ratio foam in that 

productivity decreases if foam is off ratio. 

Board footage yield of spray foam can vary with temperature so we typically do not 

publish such data. We indicate the user will see a range of yields usually as follows: 

LD-C-50 / LD-C-50 v2 16,000-20,000 board feet 

LD-R-50 15,000-18,000 board feet 

MD-C-200 4,000-5,000 board feet 

MD-R-200 5,000-6,000 board feet 

MD-R-210 4,500-5,500 board feet 

4. Curing Times: 

Our conclusion, based on many different tests we and others have carried out, is that 

the existence of raw, un-reacted MDI in high pressure spray foam is short lived. In the 

low density foams particularly, there is an excess of water in the mixtures (more than 3 

times the amount needed to fully react all MDI). Our monitoring of MDI in our plant 

during spray activities (see Tab 8 (Folder 8)) and reports back from other parties has 

found that MDI in the air is fully reacted within 1-2 hours. Surface wipe testing suggests 

that the existence of MDI cannot be found in as little as 5 minutes after spray (see 

SWYPES testing of MDI during/after spray of LD-C-50 in Tab 1 (Folder 1) and SWYPES 

testing of MDI during/after spray of MD-C-200 in Tab 3 (Folder 3).) 

Page 4 of 6 
p. 5 

Our high pressure products do not require atmospheric moisture to cure. In addition, 

the Open Cell products do little to limit the diffusion of moisture within the structure of 

foam, so it becomes even more likely that the MDI will cure rapidly. 

5. Re-occupancy Time: 

Several of our products were tested according to the methodology used in Canada 

outlined in CAN/ULC S774. The testing of LD-C-50 (See SRC report in Tab 1 (Folder 1)) 

pre-dates this standard and the standard was in fact developed based on the testing of 

this product. The methodology identifies 5 chemicals that are off-gassed by this product. 

We have also included the assessment of the data by a Ph.D toxicologist who concluded 

that based on the emissions a building would be suitable for occupancy within 24 hours 

and that levels of the compounds that were detected become undetectable within 30 

days. 

A similar study for LD-R-50 (See Tab 2 (Folder 2)) concluded that buildings insulated with 

that product would be suitable for re-occupancy in 12 hours. 

We have other products tested and marketed in Canada only for which we could 

provide test data, if requested. 

In general for our US products, notwithstanding the information above, we have chosen 

to follow the guidance from the American Chemistry Council, Center for the 

Polyurethanes Industry is that buildings should not be re-occupied for 24 hours. Our 

MSDS sheets for FINISHED FOAM products in Tab 7 (Folder 7) identify in Section 3, 

under the subject of Emissions, that buildings are "safe for occupancy after 24 hours". 

6. Qualitative Data: 

We have only carried out qualitative testing on our two most popular products LD-C-50 

and MD-C-200. Together these products represent more than 90% of our foam sales in 

the US. The reports can be found under Tab 1 (Folder 1) and Tab 3 (Folder 3) and are 

entitled SWYPES testing of LD-C-50 and MD-C-200. 

It is important to note we tested both uncut and cut foam and found no un-reacted MDI 

remaining approximately 5 minutes after spray. Based on this work, it does not appear 

that the act of scarfing or trimming the foam, even a few minutes after spray exposes 

more un-reacted MDI. 

7. Reaction Times: 

This data is best summarized on our TDS Technical Data Sheets in Tab 6 (Folder 6). Our 

products are generally reacted and fully expanded in less than 15 seconds. This data is 

based upon and is verified on an ongoing basis with test sprays by our quality control 

lab. 

8. Off gassing / By-products: 

The off-gassing profiles of our products are captured in a number of reports under Tabs 

1-5 (Folders 1-5). There are two methodologies that we have used to study our 

Page 5 of 6 
p. 6 

products: the Saskatchewan Research Council testing to CAN/ULC S774, as well as, the 

Berkeley Analytical methodology to CA Specification 01350. The SRC testing was 

previously discussed. The Berkeley Analytical tests are repeated every 2 years, so for 

several products you will find the results of several tests. In the most recent round of 

testing, the results were so low as to meet the requirements for School Classrooms and 

Private Offices (more confined space.) The most recent round of testing was completed 

in September for: 

• LD-C-50 

• LD-R-50 

• MD-C-200 

• MD-R-210 

All of these products met CA Specification 0135 - Schools and Offices stringent 

standards. 

On behalf of my colleagues I thank you for taking the time to review this important work. As you 

can see we have invested considerable sums of money attempting to be leaders in important 

field. We believe that SPF is an incredible material and that it offers huge potential to improve 

energy efficiency of buildings around the world. 

The key is responsible stewardship. 

We look forward to your comments and feedback. 

Yours truly, 

Page 6 of 6 
List of Reports / Table of Contents 

1. LD-C-50 

a. LD-C-50 - CHPS Testing 2010 

b. LD-C-50 - CHPS Testing 2008 

c. LD-C-50 - SRC Testing Summary 

d. LD-C-50 - SRC Testing 1994 

e. LD-C-50 - Toxicological Assessment 2010 

f. LD-C-50 - Swypes Test 2012 

2. LD-R-50 

a. LD-R-50 - CHPS Testing 2012 

b. LD-R-50 - CHPS Testing 2010 

c. LD-R-50 - SRC Testing 2009 

d. LD-R-50 - Toxicological Assessment 2009 

3. MD-C-200 

a. MD-C-200 - CHPS Tests 2012 

b. MD-C-200 - CHPS Tests 2010 

c. MD-C-200 - VOC Certificate 2010 

d. MD-C-200 - Swypes Test 2012 

4. MD-R-200 

a. MD-R-200 - CHPS Tests 2010 

b. MD-R-200 - VOC Certificate 2010 

5. MD-R-210 

a. MD-R-210 - CHPS Tests 2012 

6. Technical Data Sheets (TDS) 

a. LD-C-50 Technical Data Sheet USA 

b. LD-C-50 v2 Classic Max Technical Data Sheet 

c. LD-R-50 Technical Data Sheet 

d. MD-C-200 US Technical Data Sheet 

e. MD-R-200 Technical Data Sheet 

f. MD-R-210 Technical Data Sheet 

7. Material Safety Data Sheets (MSDS) 

a. A Side-March 7 2011 

b. LD-C-50 Resin - June 21 2012 

c. LD-C-50v2 Foam - Oct 29 2012 

d. LD-C-50v2 Resin - Oct 29 2012 

e. LD-R-50 Foam - July 9 2012 

f. LD-R-50 Resin - Oct 31 2012 

g. MD-C-200 A Side-Aug 12 2010 

h. MD-C-200 Foam - Dec 3 201 

i. MD-C-200 S Resin - Dec 13 2010 

j . MD-C-200 W Resin - Dec 13 2010 

k. MD-R-200 Foam - July 28 2009 

I. MD-R-200 Resin - July 19 2012 

m. MD-R-210 Foam-Oct272011 

n. MD-R-210 Resin - Oct 25 2011 

8. In-Plant Testing 

a. In-plant Testing - 2008 Report 

b. In-plant Testing - 2010 Report