For PU marine flotation foam , we received a comment from BASF indicating that

sy stems houses will require at least a ye ar for technical development, a y ear for certification testing to U.S. Coast Guard standards, a ye ar for testing of the stability of the foam product, as well as one to two years for customer approval, given the large number of customers for this type of foam. BASF expected issues similar to those for appliance foam, such as dimensional stability and cracking, because injecting flotation f oam is a similar process and uses similar poly mers in the foam formulation. BASF asked that EPA clarify whether marine flotation foam fits under spray foam and whether this application is “exempted” or instead must transition to alternatives. EPA consulted with the U.S. Coast Guard regarding their certification process and the necessary time for manufacturers to test and certify that they meet the requirements at 33 CFR part 183 (Boats and Associated Equipment), Subparts F (Flotation Requirements for Inboard Boats, Inboard/Outdrive Boats, and Airboats), G (Flotation Requirements for Outboard Boats Rated for Engines of More than 2 Horsepower), and H (Flotation Requirements for Outboard Boats Rated for Engines of 2 Horsepower or Less), which require all manufa cturers of monohull recreational boats less than twenty

feet in length (except sailboats, canoes, kay aks, inflatable boats, submersibles, surface effect vessels, amphibious vessels, and race boats) to provide sufficient flotation foam within the boat to e n sure that the boat will not sink if the boat swamps or capsizes. This requirement allows the occupants to hold onto the boat until they can be rescued. We also met with representatives from the marine industry and heard directl y from them about the necessary steps for transition. After considering the various steps needed to complete the transition, we conclude that the need for the s ys tems houses to perfect formulations that perform similar or better than what is being used today will take additional time beyond what the Agency considered. In particular, in order to research and test foam formulations sufficientl y to avoidissues with dimensional stability and field failures, and to ensure safet y of the flotation foam and boats built w ith it, we expect it would take at least another two and a half to three ye ars bey ond the proposed date of January 1, 2017. Thus, we are establishing January 1, 2020 as the change of status date for marine flotation foam. We do not believe there is suffici ent information at this time to support a change of status date later than January 1, 2020. However, given the concern for safety associated with marine floatation foam, we will monitor the situation carefull y and consult with the U.S. Coast Guard. Given that und er 33 CFR 183 m anufacturers are required to certify to the U.S. Coast Guard that their boats have sufficient flotation to meet the regulations , EPA recognizes that the U.S. Coast Guard may be able to provide information concerning certificati on with the alternatives

. As January 2020 approaches, we will continue to consult with the U.S. Coast Guard and consider whether it is appropriate to adjust the change in status date or to otherwise modify

the SNAP listing to address any uses for which there may be technical challenges beyond January 1, 2020. We are listing this use separatel y from spray foam due to differences in the manner in which the foam is dispensed which make this use more similar to appliance foam and commercial refrigeration foam than spray foam. Our understanding is that flotation foam is ty

pically injected rather than spray ed. We do not believe there is sufficient information at this time to support a change of status date later than Januar y 1, 2020. However, given the concern for safety associated with marine floatation foam, we will monitor the situation carefully and consult with the U.S. Coast Guard . As January 2020 approaches, we will consider whether it is appropriate to adjust the ch ange in status date or to otherwise modify the SNAP listing to address any uses for which there may be technical challenges beyond January 1, 2020.