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November 26 , 2013

Submitted via Electronic Mail

Katherine Sleasman Office of Pollution Prevention and To xics Chemical Control Division, Existing Chemicals Branch 1200 Pennsylvania Ave. NW EPA East, Room 4410G Sleasman.Katherine@epamail.epa.gov

Re: Toluene Diisocyanate ( T DI) And Related Compounds Action Plan, RIN 2070

- ZA15, April 2011

Dear Ms. Sleasman,

The American Chemistry Council Diisocyanates Panel (“Panel”) 1 is pleased to have the opportunity to submit information to the Environmental Protection Agency related to t he Toluene Diisocyanate ( T

DI) And Related Compounds Action Plan issued in April 2011. The purpose of this document is to address potential Agency questions regarding TDI in fl exible polyurethane foam (FPF) and to establish

, based on the published data, that FPF does not contain unreacted TDI that can be transferred via the air or by direct contact with the product to a consumer

. Therefore, consumer products such as mattresses made of FPF, when used as intended, are not expected to expose the consumer to unreacted TDI

.

In the TDI Action Plan issu ed in April 2011, EPA stated that the Agency “intends to initiate rulemaking under TSCA section 5(a)(2) for a SNUR, designating the use of uncured TDI and its related polyisocyanates in a consumer product as a new use.” EPA also stated : “ [t] his Action Plan focuses on the potential health effects that may result from exposures to the consumer or self

- employed worker while using products containing uncured (unreacted) diisocyanates (e.g., spray applied sealants and coatings) or incidental exposures to the gen eral population while such products are used in or around building s, including homes or schools.” EPA further stated : “ [o] ther polyurethane products, such as mattresses, pillows, and bowling balls, are considered completely cured products before they are sold. Completely cured products are fully reacted and therefore are considered to be inert and non

- toxic (Krone & Klinger, 2005). This Action Plan focuses on concerns for unreacted, uncured products.” [emphasis added]

However, i n a recent presentation you made on behalf of EPA at the September 2013 Polyurethanes Technical Conference

, the presentation stated that EPA will “ initiate a rulemaking under TSCA section 5(a)(2) for a Significant New Use Rule (SNUR) designating certain us es of

1 The Panel includes U.S. manufacturers of TDI and/or MDI: B ASF Corporation, Bayer Material Science, The Dow Chemical Company, and Huntsman Corporation.Page 2 of 15

TDI in a consumer product as a new use requiring prior notice to the Agency.” Based on what was presented at the September 2013 Conference, it appears that EPA is now expanding the focus from products containing unreacted isocyanates to include finis hed and cured consumer products. If this is indeed the case, it could be a significant departure from EPA‟s original intent outlined in the April 2011 TDI Action Plan.

The following bullets summarize the Panel‟s general commen ts based on the published d ata regarding TDI in FPF. A number of studies leading to these conclusions are described in gre ater detail in the attached Q&A document.

 No “ free TDI ” has been detected in emission testing of commercial FPFs

.

 There have been publications using extraction testing protocols that reported values attributed to “ free TDI ” in commercial FPFs. Concurrent extraction/derivitization protocols cannot discriminate between “ free TDI ” , dimer, biuret or allophanate. In addi tion, these extraction protocols themselves are not considered to be representative of consumer use.

 Using conservative, accepted risk analysis protocols, no risk of consumer exposure has been demonstrated for the use of TDI in FPF.

 Since the odor threshold range for TDI is generally accepted as 50

- 100 ppb (parts per billion), it is extremely unlikely that “free TDI” could contribute to consumer odor

concerns.

 Countless polyurethane products made possible with diisocyanates chemistr y are important to America‟s economy, particularly in the FPF sector

. Because FPF production uses TDI , the potential economic and job impact s are paramount.

The Panel urges the Agency to consider our comments as it determines next steps with the TDI Acti on Plan

. The Panel looks forward to meeting with EPA to discuss developments under the TDI Action Plan

. In the meantime, please contact me at (202) 249

- 6721 or sahar_osman

sypher@americanchemistry.com if you have any questions or need additiona l information

. Sincerely, 

# Sahar Osman

- Sypher

Sahar Osman

- Sypher Director , Diisocyanates Panel

cc: Wendy Cleland

- Hamnett Leslie Cronkhite Maria Doa

Attachment: Q&A on TDI from Flexible Polyurethane Foam in Bed MattressesPage 3 of 15 ATTACHMENT:

Q&A on TDI from Flexible Polyurethane Foam in Bed Mattresses

Summary

The purpose of this document is to address potential Agency questions and to establish

, based on the published data, that flexible polyurethane foam (FPF) does not contain unreacted TDI that can be transferred via the air or by direct contact with the product to a consumer

. Therefore, consumer products such as mattresses made of FPF , when used as intended, are not expected to expose the consumer to unreacted TDI . A number of studies leading to these conclusions are briefly summarized below and described in greater detail in the Q&A document that follows this summary

. Reports of “free TDI ” being extractable and measured in foam samples even several years post

production were followed by rigorous analytical investigations to improve understanding of these findings. These subsequent analytical studies confirmed that measurable amounts of TDI can b e extracted from FPF . Using several combinations of extraction solvent/derivatizing agents and physical extraction procedures, the pattern of TDI measurements from sequential extractions of the same foam sample was best explained by mechanisms other than the presence of “free” TDI. The non

- homogeneous nature of FPF matrix is expected to contain chemical moieties such as TDI dimers, biurets and allophanates. The presence of such chemical compounds being extracted by the solvents also can lead to a subsequ ent reaction with the amine

- based derivatizing agent to yield false positive results for “free” TDI. This circumstance does not allow for a definitive distinction between any extracted TDI monomer and an analytical signal derived from a dimer, biuret or a llophanate. Studies to date reporting the presence of “free TDI ” in FPF are encumbered by the necessary use of a solvent for the extraction phase, followed by a derivatizing agent, and thus do not lead to definitive results. Another set of investigators followed a different approach

- a more direct assessment of hypothetical consumer exposure and potential health implications.

A risk assessment of a simulated use by a consumer of a FPF product was considered. The simulation involved a consumer sleeping on a mattress made of FPF . The determination of exposure to the individual relied on experiments measuring the emission of TDI from a sample of FPF and separate measurements simulating direct skin contact. The tests results indicated no measureable emiss ion or migration of TDI from the FPF samples tested. Complementary information required for a risk assessment is an estimate of hazard. The known health effects associated with TDI were used for this assessment. Further, a number of conservative

, (health protective) assumptions were used such as direct contact of a person‟s skin to a foam mattress with no intervening fabric. A comparison of hypothetical exposure to thresholds not expected to induce the known health hazards of TDI resulted in marg ins of safety ranging from 200 to 3 million, well over the acceptable margin of safety of 1.

In conclusion, a generalization of these findings from the analytical chemistry and risk assessment perspectives indicates that a realistic scenario depictin g the use of a mattress (a relatively large FPF article) does not support a TDI

- based health risk to the general public.Page 4 of 15 Questions and Answers

Q1. Is there “free TDI” in the flexible polyurethane foam used in bed mattresses?

A1. Once the foam has been manufactured and incorporated into mattresses for sale to

consumers , TDI monomer is no longer available . Scientists have tried to remove TDI from the foam using air extraction and solve nt extraction. There was no TDI measured with air extraction. Solvent e xtraction sometimes results in measurable TDI readings. S cientists knowledgeable about polyurethane foam chemistry reviewed the findings , and concluded that polyurethane foam may be broken down by the extraction solutions used and thus contribute to the TD I readings measured.

Discussion
Understanding the answer to this question necessarily involves a discussion of the nature of flexible polyurethane foam (FPF), the various techniques one might use to assess the presence of “free TDI” in it, and the purpose for which the question was asked.
Isocyanate groups in foam

- The FPF used in mattresses is made from the reaction of TDI with polyols (long chained polymers similar to glycols) and water in the presence of catalysts (a mixture of amines) and other compon ents (auxiliary blowing agents, flame retardants, surfactants, colorants). Residual levels of TDI in freshly

- produced FPF would be expected, but will be reduced to very low levels after the post production cure period [Dieterich et al., 1993]. As the polyurethane polymer chain develops, it also is possible that some unreacted “isocyanate groups” (i.e.,

- N=C=O) will remain attached to the polymer chain. These “bound isocyanate groups” can be measured on polymer chains near the foam surf

ace by infrared techniques [Van Gheluwe et al., 1987] or visualized by introducing colorimetric reagents that react with isocyanate groups into the foam [Krone et al., 2003].
Measuring TDI in foam

- Only a few studies report attempts to evaluate the level of “free TDI .” One of two approaches were taken in these studies: (1) emission to air [Hugo et al., 2000], or (2) extraction with organic solvent [Conte and Cossi, 1981; Jedrzejczak and Gaind, 1993; Krone et al., 2003; Gagné et al., 2003; Vangronsveld et a l. , 2013a]. Key aspects of these studies are summarized in Table 1 and the study results are discussed in the paragraphs following.
In the emission study, emission testing of a commercial foam three days post

- production by passing air through the foam mat rix showed no detectable TDI emitted (detection limit ~ 0.1 ppb v/v in air, which corresponded to 0.4 ng/g FPF).

The first four studies which determined solvent extractable TDI varied in the solvent used, severity of extraction conditions, and the analyt ical technique used. Extractable TDI results from two of these four studies [Conte and Cossi, 1981; Jedrzejczak and Gaind, 1993] were below detection limits for FPF samples that were older than the usual one to three

- day post production curing period. On e of the two studies that did detect extractable TDI in FPF samples beyond the post production curing period was the study with the lowest detection limits [Gagné et al ., 2003]. For two of the three FPF samples in the studyPage 5 of 15

very low levels (3

- 17 ng/g FPF) that would have been below the detection limits of the other studies were reported, and no detectable TDI was reported in the third FPF sample. The remaining study [Krone et al., 2003] is notable for reporting detectable quantities of extractable TDI (3

- 2 0 μg/g FPF) in all three FPF samples tested, which ranged in age from 1

- 30 years.
Because of the variable results reported in the literature, the fifth solvent extraction study listed in Table 1 was carried out to compare different solvents and derivatizat ion agents in determining extractable TDI from an FPF that was expected to contain residual TDI

monomer (made with a high ratio of TDI to polyol) [Vangronsveld et al., 2013a]. The study looked at 6 solvent / derivatization agent combinations with a single r epresentative foam. Results for total extractable TDI varied by a factor of 7, and showed unusual behavior with some solvents (e.g., increasing extractable TDI with successive serial extractions).
False positive TDI measurements from extractions

– The beh avior seen in Vangronsveld et al. , 20 1 3a results indicates that more than simple solvent extraction was occurring. Further insight can be gained from a detailed consideration of the chemistry of FPF formation.

In polyurethane flexible foam production

, three poorly

- miscible liquids are dispersed into each other: TDI, water and polyether polyol (with a mean molecular weight about 3000

– 6000 g/mol). In the beginning of the reaction, there are three different liquid phases [Hager et al., 1994]. When the c onsumption of isocyanate functional groups reaches about 50%, solid structures start to precipitate, and the further reaction of isocyanate groups proceeds with an initial half

- life of about three days [Elwell et al., 1994; Hauptmann et al., 1981]. The fin al flexible foam has three different solid phases: hard segments, soft segments, and “urea balls.” Hard segments are formed by urethane structures which are cross

- linked hydrogen bonds from the one urethane

- group N

- H to the next urethane group C=O, and

so ft segments are made up of the polyols chains [McClusky et al., 1994]. Urea balls are a consequence of the poor miscibility of TDI in water mentioned earlier: TDI droplets in water rapidly form a polyurea shell that slows down further reaction of the TDI c ore, similar to reactions reported at the interphase between TDI and water [Brochhagen and Grieveson, 1984; Yakabe et al ., 1999]. As a result, some unreacted TDI may remain trapped in the polyurethane foam structure after the initial formation reaction. Since TDI is a reactive molecule, this residual TDI has a high likelihood of undergoing further reactions. Reaction with ambient moisture can lead to formation of more polyurea, but reaction with the polyurea already present may also form dimers [Arnold e t al., 1957], biurets [Joel et al., 1982] and allophanates [Lapprand et al., 2005]. See Figure 1 below.

The hard segments and urea balls present in FPF can be swollen by strong polar solvents such as dimethylformamide ( DMF ) and dimethyl sulfoxide (DMSO) [A rmistead et al. ,1988], thus providing amine derivatizing agents better access to residual unreacted TDI trapped in these structures, as well as to the dimers, biurets and allophanates present. Dimers, biurets and allophanates also react with amines, givin g the same derivatives as “free TDI.” Dimers react comparatively rapidly [Saunders and Hardy, 1953]. The reaction rate of biurets and allophanates with secondary amines increases directly with the polarity of the organic solvent used and with temperature [ Joel and Weiler, 1980].Page 6 of 15

Polar organic solvents, therefore, have two effects when used in methods for the determination of residu al TDI in flexible foam. First , they make any entrapped TDI more accessible for the reaction with the am ine derivatizing agent. Second , they accelerate the reaction of biurets and allophanates with the same derivatizing agent, producing the same derivative as with TDI. Because of these effects, measurements of TDI derivatives resulting from polar organic solvent extraction methods actually indicate the sum of a ny residual TDI monomer (“free TDI ” ), and TDI derived from dimers, biurets and allophanates by reaction with the derivatizing agent.

Production of TDI from cleavage of biurets and allophanates was further investigated in

ano ther study [Schmidtkunz, 2012]. In this work, the reaction of a TDI biuret containing no TDI monomer with a solution of each of three isocyanate derivatizing agents (two secondary amines and ethanol) over a period of 96 hours showed detectable levels of 2 ,4

- TDI derivative which increased steadily over the course of the experiment for the two amines, but not for ethanol. The author concludes that amines react with biurets and allophanates to produce the same analyte as TDI does while alcohols do not. The a uthor further comments that it is well known in the literature that biurets and allophanates are prone to cleavage by nucleophiles (such as amine derivatizing agents)

. Consumer exposure to TDI bioavailable from foam

– In conducting an exposure risk assessment for a component in a product, the first step is measuring or estimating the likely exposure level. An exhaustive extraction of the component out of the product is sometimes used to provide an extreme case, maxi mum estimate of potential exposure. However, a more realistic exposure estimate can be made by conducting experiments that simulate the most challenging case of actual use conditions. This is the approa ch taken, for example, by the U.S. Food and Drug Adm inistration when evaluating polymers intended for food contact use. Polymer formulations intended for use in food containers are subjected to immersion in “food simulating solvents” (e.g., 10

- 50% ethanol in water, corn oil) and the highest anticipated pro cessing temperatures to see how much monomer is available to migrate into the food [US FDA, 2007].

Because of the information on exhaustive solvent extraction with TDI and FPF discussed earlier, such exposure simulating tests to measure TDI available from FPF for consumer exposure have been developed [Vangronsveld et al., 2013b]. The testing involves measuring the emission of TDI to air from an FPF test sample (simulating consumer inhalation exposure) and the migration of TDI to a surface in contact with the foam surface (simulating consumer dermal exposure) over a period of 8

- 24 hours. In the study, a representative foam was tested that had detectable levels of solvent

- extractable TDI; emission and migration testing of the FPF showed no detectable TDI at detection limits of 0.005 ng/cm 2 FPF surface for emission testing and 0.16 ng TDI/cm 2 FPF contacted for migration testing.Page 7 of 15



### Table 1. Extractable TDI from flexible polyurethane foam: comparison of studies in the literature

Study Extraction type / Analysis description Extracted TDI found (μg TDI/g foam) Detection limit

(μg TDI/g foam)

Hugo et al. air extraction / amine derivatization & HPLC

- UV ND* 0.0004

Conte and Cossi, 1981 solvent extraction(o

- dichlorobenzene)/ GC

- FID ND 5000

Jedrzejczak and Gaind, 1993 solvent extraction (methanol)/ alcohol derivatization & GC

- NCI

- MS ND 0.01

Krone et al.

, 2003 solvent extraction (dimethyl sulfoxide [DMSO])/ amine derivatization & HPLC

- UV/FL 3000

– 20,000 3

Gagné et al.

, 2003 solvent extraction (toluene)/ amine derivatization & HPLC

- CIS

- MS/MS ND

- 17 0.0001

Vangronsveld et al.

, 2013a solvent extraction (toluene, DMSO, dichloromethane, ethanol)/ alcohol or amine derivatization & HPLC

- ESI

- MS/MS 660

- 4500 10

- 50

*ND

– none detected at detection limit listedPage 8 of 15



### Figure 1. Reactions consuming free TDI in flexible foams. Formation of dimers (1), biurets (2) and allophanates (3)Page 9 of 15

Q2. What about reports by some researchers of “free TDI in 30

- year old foam”?

A2. There is only one report of “free TDI in 30

- year old foam” in the literature [Krone et al., 2003]. Since the isocyanate groups on TDI are quite reactive, they would be expected to react with water in the air over a 30

- year timeframe. Scientists knowledgeable about polyurethane foam chemistry reviewed the findings and concluded that the TDI det ected from the foam probably resulted from break down of the foam by the extraction solutions used.

Discussion As noted in the answer to Q1 above, there are several studies in the literature reporting attempts to determine TDI in foam by solvent extractio n. Two of these studies detected no extractable TDI, one reported very low levels (below the detection limit of the first two studies), and one compared different extraction solvents and derivatizing agents using a foam produced with the intention of havi ng measureable levels of residual TDI. Krone et al. is notable for reporting the highest extractable TDI levels of the four and also for reporting finding extractable TDI in foam as old as 30 years old.

Residual levels of TDI in freshly

- produced FPF would be expected, but will be reduced to very low levels after the post production cure period [Dieterich et al., 1993]. As the polyurethane polymer chain develops, it is also possible that some unreacted “isocyanate groups” (i.e.,

- N=C=O) will remain att ached to the polymer chain. These “bound isocyanate groups” can be measured on polymer chains near the foam surface by infrared techniques [Van Gheluwe et al., 1987] or visualized by introducing colorimetric reagents that react with isocyanate groups into the foam as done by Krone et al . However, such “bound isocyanate groups” are not available for inhalation or dermal absorption by consumers since they are connected to the polymer matrix itself. Van Gheluwe observed that the bound isocyanate groups decli ne slowly over time as a result of reaction with atmospheric moisture diffusing into the foam, but reach a steady state value about a week after foam production.

Extractable TDI from foam was reported by Krone et al. both qualitatively using colorimetri c surface wipes treated with a reagent that reacted with isocyanate groups to give a red color, and quantitatively by extraction of foam samples with DMSO and an amine derivatizing agent after they had been frozen with dry ice and ball

- milled. As describe d in considerable detail in the answer to Q1 above, FPF contains species which are known to undergo cleavage reactions with nucleophiles (such as the amine derivatizing agent used) to yield TDI. In addition, polar solvents such as DMSO have been shown to accelerate these reactions [Joel and Weiler, 1980]. Also, the manufacturer of the colorimetric surface wipes specifies wetting the surface to be wiped with mineral oil to promote transfer of isocyanate species from the surface to the wipe. In the Krone et al. study, the authors instead used acetone, a polar solvent, in order to transfer the colorimetric reagent into the foam to visualize polymer

- bound isocyanate groups. As with DMSO, acetone would be expected to promote false positive isocyanate readings on the wipe from the foam component cleavage reactions described above.Page 10 of 15

From the above considerations, it is highly likely that the extractable TDI reported by Krone et al. from 30

- year old consumer foam are false positives resulting from the action of the extraction and derivatization system on species known to be present in the foam. Additionally, the aggressive workup and extraction procedures used in the quantitative de termination do not represent the situation encountered by consumers in actual use of polyurethane foam articles.

Q3. Has anyone assessed the health risk from exposure to TDI for people who sleep on a polyurethane mattress?

A3. Yes. Based on measurement s of emission and migration of TDI from flexible polyurethane foam [Vangronsveld et al., 2013a], a risk assessment for a person sleeping for a lifetime on a bare foam mattress has been published [Arnold et al., 2012]. The risk assessment shows that sleepi ng on a polyurethane foam mattress does not pose any health risks related to TDI exposure.

Discussion As discussed in the earlier question related to TDI in flexible polyurethane foam (Q1), the most appropriate exposure measurements to use as a starting p oint for risk assessment are those which represent the upper

- bound values for exposure in actual use conditions. Emission to air from foam and migration to a surface in contact with foam are such “upper

bound real” exposure measurements for the use scenar io of sleeping on a mattress. In their study

, Vangronsveld et al. tested a representative foam that had detectable levels of solvent

- extractable TDI; emission and migration testing of the foam showed no detectable TDI at detection limits of 0.005 ng/cm 2 foam surface for emission testing and 0.16 ng TDI/cm 2 foam contacted for migration testing.

Since these results were below detection limits, Arnold et al. began by assuming a value of 50% of the detection limit value from the Vangronsveld et al. study as the basis for calculating the exposure level for risk assessment. The parameters of the exposure scenario model (e.g., hours of exposure, room size, mattress size, room ventilation rate) were established using widely

- accepted values where available. By a pplying the TDI emission and migration values to the exposure scenario model, the authors were able to calculate inhalation and dermal exposure concentrations. They then established benchmarks for key

non

- cancer toxicological endpoints (i.e., sensitizatio n, irritation, respiratory tract effects). Dividing the respective non

- cancer toxicological benchmarks by the calculated inhalation and dermal exposure concentrations, the authors calculated a “margin of safety” for each benchmark. The margins of safety r anged from 200 to 3 million, well over the target margin of safety of 1. Although available data indicate that TDI is not a carcinogen [Prueitt et al. , 2013], a theoretical total excess cancer risk of 1x10 - 7 was calculated, which is at least an order of ma gnitude below the typical excess cancer range targeted by regulatory agencies (1x10 - 6 to 1x10 - 4 ). Based on this assessment, the authors conclude that sleeping on a PU foam mattress for a lifetime does not pose TDI

- related health risks to consumers.

In or der to assist flexible foam manufacturers in conducting such a risk assessment on their range of foam products, an information package is available that includes the proceduresPage 11 of 15

for conducting emission and migration testing and calculation spreadsheets for determining the margin of safety of the results [Spence, 2012].

Q4. New bed mattresses sometimes have a noticeable odor; if I smell an odor does it mean I’m being exposed to TDI?

A4. The odor is not from TDI.

Discussion While the FPF used in mattresses is made from the reaction of TDI, in addition to polyols (long chained polymers similar to glycols) and water in the presence of catalysts (a mixture of amines) and other components (auxiliary blowing agents, surfactants, c olorants), the detected odors are not from TDI. This statement can be made because the odor threshold range for TDI is generally accepted as 50

- 100 ppb (parts per billion) [Allport et al.

, 2003] and investigations of TDI emission from mattresses conducted by Battelle for the California Air Resources Board detected no TDI emissions at a detection limit of 0.14 ppb [Kelly et. al., 1999]. Additional support for the lack of TDI emissions from the FPF used in mattresses is the emission study noted in the answer to Q1 above [Hugo et. al., 2000] where no T DI emissions to air from such a foam were detected at a detection limit of 0.1 ppb.

Economic Impact of TDI in the Polyurethanes Industry

Countless polyurethane products made possible with diisocyanates chemistry are important to America‟s economy, particularly in the furniture and bedding, building and construction, and transportation sectors. Diisocyanates chemistry can help consumers and businesses save money through improved energy efficiency and performance of a wide range of products that use polyurethane materials.

Here are a few facts regarding the importance of TDI to our economy. In 2012, United States demand for TDI was at 478 mi llion pounds. Flexible foam slabstock production consumed the majority of that demand at 325 million pounds (68%), followed by flexible foam molded at 75 million pounds ( 16%). See Table 2 for U

. S

. TDI demand by product type. Within the flexible foam slabst ock production, the mattress sector consumes the majority of TDI at 12 7 million pounds (39%), followed by the furniture sector at 69 million pounds (21%) . See Table 3 for U

. S

. flexible foam slabstock TDI consumption [ CPI, 201 3 ].

To meet this demand, produ ction of TDI in the United States employs thousands of workers in facilities across the nation. When you consider that polyurethane production uses TDI, the potential economic and job impact becomes even more significant. The polyurethanes industry operates in 935 locations in the United States, directly generating $19.7 billion in output and 37,700 jobs. Indirectly, the polyurethanes industry supports an additional $40.1 billion in output and supports nearly 165,000 additi onal jobs. In total, the polyurethanes industry supports about 202,600 jobs and $59.9 billion in output. In addition, polyurethane products are used in industries generating $245.5 billion in output and employin g nearly 1 million workers [ACC, 2012].Page 12 of 15



### Tabl e 2: U

. S

. Demand for TDI by Product Type , 2012 (Mlbs)

Table 3: U

. S

. Flexible Foam Slabstock TDI Consumption, 2012 (Mlbs) Flexible Foam Slabstock , 325, 68% Flexilbe Foam Molded, 74.7, 16% Coatings , 35.3, 7% Binders , 5.8, 1% Elastomers, 12.3, 3% Adhesives, 25.1, 5%

Flexible Foam Slabstock Flexilbe Foam Molded

Coatings

Binders

Elastomers

Adhesives

Furniture, 69.3, 21%

Transportation , 46.4, 14%

Bedding

- Mattress, 126.6, 39% Bedding

- Others, 14.7, 5% Packaging, 9.1, 3% Textiles & Fibers, 10.3, 3% Foam Scrap ,

35.2, 11% Others , 12, 4% Furniture

Transportation

Bedding - Mattress

Bedding - Others

Packaging

Textiles & Fibers

Foam Scrap

OthersPage 13 of 15

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