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

systems houses will require at least a year for technical development, a year for certification 

testing to U.S. Coast Guard standards, a year 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 foam is a similar process and uses similar polymers 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 manufacturers of monohull recreational 

boats less than twenty feet in length (except sailboats, canoes, kayaks, inflatable boats, 

submersibles, surface effect vessels, amphibious vessels, and race boats) to provide sufficient 

flotation foam within the boat to ensure 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 directly 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 systems 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 sufficiently to avoid 
issues with dimensional stability and field failures, and to ensure safety of the flotation foam and 

boats built with it, we expect it would take at least another two and a half to three years beyond 

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 sufficient 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 carefully and 

consult with the U.S. Coast Guard. Given that under 33 CFR 183 manufacturers 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

certification 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 separately 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 typically injected rather than sprayed.

We do not believe there is sufficient 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 carefully and consult with the U.S. Coast Guard . As January 2020 approaches, 

we will 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.