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Federal Express 

April 28, 2015 

Document Control Office (7 407M) - Room 6428 

(202) 564-8930 

OPPT 

U.S. EPA Confidential Business Information Center (CBIC) 

1201 Constitution Ave., NW 

Washington, DC 20460-0001 

Ladies and Gentlemen: 

CBIC Control Number 

364852·1 

Re: Proposed Significant New Use Rule Toluene Diisocyanates (TDI) and Related 

Compounds, 80 FR 2068 (January 15, 2015); Docket ID: EPA-HQ-OPPT-2011-0976 

[ ] company that manufactures 2,4-toluene diisocyanate (CASRN 584-

84-9), 2,6-toluene diisocyanate (CASRN 91-08-7), toluene diisocyanate unspecified isomers 

(CASRN 26471-62-5) (these three substances hereafter referred to as TDI). [ ] 

manufactures TDI for distribution in commerce, primarily for industrial and commercial use, 

[ ] . [ 

] 

These comments will: 

1) inform the U.S. EPA of [ ] existing manufacture, processing, use and 

distribution of TDI, including distribution to consumers; 

2) provide industrial hygiene monitoring and [ ] data supporting a conclusion of low 

exposure; 

3) seek clarity on compliance requirements. 

1. Existing Manufacture, Processing, Use and Distribution of TDI 

Manufacture of TDI 

[ 

Processing of TDI 

[ 

Use of TDI by BASF and Third Parties 

[ ] 

Distribution of TDI 

[ 

2. Industrial Hygiene and [ 1 Data 
.. 

3. Compliance Requirements Associated with the Proposed SNUR 

The proposed SNUR does not prohibit the manufacture of TDI, however, 40 CFR 721.5(a)(1) 

states that a manufacturer or importer of TDI who distributes the substance in commerce for a 

new use must first file a SNUN. [ ] 

Further, 40 CFR 721.5(a)(2) states a manufacturer who does not engage in a new use, but 

distributes a SNUR substance in commerce must file a SNUN unless it notifies recipients of the 

SNUR. [ ] 

40 CFR 721 .5(b) also states that manufacturers who distribute a SNUR substance in 

commerce to recipients that it knows will engage in a new use to file a SNUN. [ ] 

Best Regards, 
LIST OF ATTACHMENTS 

1) [ 

2) Commercial Distribution 

3) [ ] 

4) [ ] 

5) [ ] 

6) EPA-HQ-OPPT-2011 -0976-0002 

7) Isocyanate Testing During Spray Roof Application [ 

8) Test Data 
Attachment 1 
Attachment 2 
Attachment 3 
Attachment 4 
Attachment 5 
Attachment 6 

EPA-HQ-OPPT-2011-0976-0002 copy obtained from docket 
Interoffice 

Date: May 27, 2009 

To: 

From: 

Subject: Isocyanate testing during [ 

Revised April 2015* 

] Roof Application at [ 

Executive Summary 

Industrial hygiene air monitoring was conducted at [ 

May 4, 2009 to assess airborne concentrations of [ 

] facility on April 29 and 

] TOI during application of a 

[ ] roof system. 

Testing was performed during [ ] application of three spray top coatings: 

[ ]. The [ ] coatings were identified as containing up to [ 

TDI and [ ] containing up to [ ] . 

Results from the monitoring indicate 

• 

Recommendations 

• The personal protective equipment protocols in use at the time by the sprayer were 

appropriate for isocyanate protection and should be continued. Others on the roof 

near the spray operation should follow similar protocols. 

. [ ]. 

• Conduct sampling to evaluate solvent emissions from spray coat systems. 

• Advise facility maintenance engineers to close off air intakes and exhausts 

necessary to prevent vapors from being drawn into building. 
Introduction and Scope 

At the request of [ ] isocyanate exposure assessment was conducted during 

a spray roofing system application that included [ ] TDI. 

Personal breathing zone samples were taken of the spray applicator while area samples 

were taken directly downwind at ground level approximately 30 feet from the building. 

Site Conditions 

The [ ] facility shut off air intakes and exhausts near the spray area and closed 

the parking lot to the south which was generally downwind. Otherwise, normal operations 

were conducted. 

The weather conditions on day one included light rain in the morning with clearing by late 

afternoon. Winds ranged from 5- 15 mph in the early afternoon to less than 5 mph in the 

evening. Sampling during [ ] application occurred in the afternoon while the 

[ ] tests occurred in the evening when the winds had calmed. 

The weather conditions on day two were sunny with winds ranging from 5- 15 mph in the 

early afternoon to less than 5 mph in the evening. [ ] testing also 

occurred in the evening when the winds had calmed and temperature were above 60°F. 

Regulated Limits 

The Occupational Safety & Health Administration (OSHA) specifies a ceiling limit of 20 

parts per billion (ppb) for both isocyanates while the American Conference of 

Governmental Industrial Hygienists (ACGIH) has established a Threshold Limit Value (TLV) 

for both isocyanates of 5 ppb as an 8-hour Time-Weighted Average (TWA). 

Methodology 

Sampling was performed using SKC AirCheck Hi-Flow pumps to collect personal breathing 

zone and area samples of isocyanate aerosol and vapor. The pumps were calibrated to a 

flow-rate of approximately 1.0 Llminute using a BIOS dry piston calibrator. The average 

flowrate before and after sampling was used to calculate air volumes. 

The samples were collected on 13 mm glass fiber filters impregnated with 1-(2-pyridyl) 

piperazine (1 ,2 PP). As soon as a sample was collected, the filter was removed from the 

cassette with tweezers and placed in a vial containing two milliliters of a solution containing 

90% acetonitrile and 10% dimethylsulfoxide. 
The vials along with a blank filter in a vial of solution were shipped to [ ] lab. The 

samples were analyzed using a modified version of OSHA Method 47 at this American 

Industrial Hygiene Association (AIHA) accredited laboratory. The concentrations reported 

in ppb include the vapor and aerosol form of the isocyanates. 

Observations 

1) Solvent odors were evident on the roof, inside the building and downwind outside 

the building during spraying. A slight negative pressure relative to outdoors existed 

inside the building. 

2) Solvent thinning of the coatings using xylene was performed. Grounding and 

bonding of solvent transfer equipment was lacking. 

3) Roofing personnel working near the spray applicator did not follow same PPE 

protocol as the spray applicator. Wind direction occasionally shifted and roof 

equipment (HVAC, etc.) created turbulent wind currents. 

Results 

The [ ] result for the [ ] while applying the [ ] urethane foam was below 

the OSHA ceiling limit of 20 ppb. The area sample taken approximately 30 feet downwind 

was non-detect. Continuous spraying over an entire shift could result in a sprayer exposure 

at or above the ACGI H TL V of 5 ppb. The sprayer used appropriate PPE to prevent overexposure to [ ]. 

Table 1: [ 1 Results 

Sample ID Date Type Material Sprayed Result (ppb) 

04/29/09 Area *NO @ 0.22 ppb 

04/29/09 Personal 6.8 

All TDI results were below detection limits. 

Table 2· . TDI Results 

Sample ID Date Type Material Applied 2,4TDI 2,6TDI 

Result (ppb) Result (ppb) 

04/29/09 Area NO @ 0.21 NO @ 0.53 

04/29/09 Personal NO@ 0.32 NO@ 0.81 

05/04/09 Area NO@ 0.40 NO@ 0.99 

05/04/09 Personal NO @ 0.43 NO @ 1.1 

05/04/09 Area NO@ 0.49 NO@ 1.2 

05/04/09 Personal NO@ 0.42 NO@ 1.1 .. *NO = Not Detected at spec1f1ed detect1on hm1t. 
Conclusions and Recommendations 

1) The results indicate TDI was not detectable when applying any of the 

[ ] coatings containing [ ] TDI and the [ 

containing ] TDI. 

2) [ 

3) The personal protective equipment protocols in use at the time were appropriate for 

isocyanate protection and should continue. Others personnel on the roof near the 

[ ] operation should follow similar protocols. 

4) It is recommended that additional sampling be conducted to evaluate TDI exposure 

when spraying the [ ] and repeat sampling for all coatings to 

increase statistical validity of the dataset. 

5) It is also recommended that further evaluation of solvent emissions from [ 

systems be performed to determine nuisance, industrial hygiene, safety and 

environmental impacts related to solvent usage in these systems. 

6) Instruction should be provided to building maintenance personnel regarding proper 

building pressurization and precautions necessary for air intakes and exhausts to 

prevent vapor entrainment during [ ] operations. 

7) Grounding and bonding of solvent transfer should be initiated and enforced. It would 

be preferable that no solvent be added to the [ ] formulations. 
Attachment 8 

Test Data