Palmer International, Inc.

Title: Description of Renewable Polyol

PMN Date of Issue:11/24/2013

Revision Date: 11/24/2013 Page 1 of 5

11/24/2013 1

Subject Premanufacturing Notice for 1462343-28-7

Sponsor Palmer International, Inc

Date November 20

th, 2013

Comments Palmer is submitting pre-manufacturing notice for a polymer of cashew 

nutshell liquid, formaldehyde, diethanolamine and diisopropanolamine.

(1) Explanation

Palmer is submitting a pre-manufacturing notice to initiate the production of cashew 

nutshell liquid (CNSL), paraformaldehyde, diethanolamine and diisopropanolamine

polymer. The resulting reaction product is a low molecular weight polymer with multiple 

hydroxyl groups, known in the industry as a polyol or more specifically as a Mannichpolyol.

Such polyols find utility in polyurethane applications where they are reacted with 

polyisocyanates. Isocyanate groups react with hydroxyl groups to form urethane linkages

for form polymers. Polyurethanes are used applications such as coatings, molded flexible 

foams, rigid spray applied foam, cast elastomers, 2-part adhesives and moisture-cure 

adhesives. The Mannich type polyols are advantages in that they contain a tertiary 

amine which acts as non-fugitive catalyst for the isocyanate-alcohol reaction. The 

Mannich-type polyol therefor reacts quickly and requires little additional catalysts.

Shortly after application the CNSL-polyol is consumed by chemical reaction with the 

isocyanates. The CNSL-polyol becomes part of a fully cured, intractable thermoset.

(2) Foam Formulation.

The intended application for the new grades of CNSL / paraformaldehyde /

diethanolamine / diisopropanolamine [1462343-28-7] is as a polyol used in the 

formulation of polyurethane insulating foams. Currently the commercial polyurethane

insulating foams utilize nonylphenol Mannich reaction products such as [940912-28-7] as 

a polyol. When approved, the 1462343-28-7 would allow the replacement of the existing 

petroleum derived nonyl-phenol reaction with the renewable cashew-nutshell-liquid 

reaction product.

The polyurethane insulating foams are created by several reactions of isocyanate 

molecules occurring simultaneously. A 2-part system is used with reactive isocyanate 

containing oligomers, foaming agents and flame retardants are in one solution, termed the 

A-side. The second solution consists of a blend of oligomeric polyols, surfactants, water

(or other blowing agent) and catalysts together called the B-side. The two A & B 

components are mixed only during application. Upon mixing, several reactions take 

place within seconds forming rigid polymeric foam that fully cures with minutes.
Palmer International, Inc.

Title: Description of Renewable Polyol

PMN Date of Issue:11/24/2013

Revision Date: 11/24/2013 Page 2 of 5

11/24/2013 2

The isocyanate groups present in the A-side formula react with water from the B-side to 

form urea crosslinks and carbon dioxide gas at the same time. The urea linkages form a 

cross-linked polymer thermoset network. The CO2 generated creates gas bubbles which 

become entrapped making a foamed material. The isocyanate groups also react with OH 

groups on the oligomeric polyols of the B-side to form urethane bonds which also build 

the three-dimensional polymeric network. The surfactant serves to stabilize the water 

and polyol mixture during storage and controls the CO2 bubble size thereby controlling 

the foam structure while the polyurethane reactions occur. The polyol molecules contain 

OH groups that react with the isocyanate from the A-side and incorporate into the 

polymer foam and become intractable. The judicious selection of differing ratios of these 

ingredients can control the polyurethane foam’s flexibility, density , cure time and 

insulation properties.

Palmer’s immediate customer will formulate and blend the new CNSL-polyol into a Bside portion of a polyurethane foam formula at a single manufacturing site.

Worker Exposure Scenario:

A) Totes of CNSL-polyol are received in shipping and transported by fork truck to 

warehouse storage or production area. No exposure except in a spill event.

B) CNSL-polyol is loaded into mixing vessels via cam-lock fitted hoses via a 

pump. Operators wear PPE including gloves, safety glasses and chemicalresistant apron. Successive ingredients are charge via the same line and pump 

which is run until dry on the last charge. The same pump is then used for 

discharging to drums. Again, during drum filling the production operator must 

wear the same PPE.

C) Finished product is sample for quality control by technicians and tested in QC 

lab. Technicians wear gloves, lab coat and safety glasses.

(3) Foam Application.

The CNSL-polyol will be formulated into a B-side mixture as described and then may 

end up in one of three possible applications:

1) Application #1 is the use of the formulated, 2-part reactive polyurethane foam in 

“pour-in-place” molded or spray applications. In these industrial manufacturing 

processes the reactive A and B sides are fed from separate tanks and blended in a 

mix nozzle. The reacting liquid is either pumped into a mold or spray applied inhouse. The spray method is used for cavity filling such as in-place application of 

rigid insulation during refrigerator assembly. The mold method is used for shaped 

foam articles such as seat cushions. The images below show the type of automated 

equipment used in these applications
Palmer International, Inc.

Title: Description of Renewable Polyol

PMN Date of Issue:11/24/2013

Revision Date: 11/24/2013 Page 3 of 5

11/24/2013 3

Mold filling operation 

Enclosed and automated 

Separate A & B-side tanks and metering 

pumps.

 Worker Exposure Scenario:

D) The foam customer receives the formulated B-side containing the CNSL-polyol. 

All containers are sealed. The only risk is a spill event.

E) The production operator loads the formulated B-side containing the CNSLpolyol into a holding tank. The operator must wear safety googles, apron or 

tyvek suit and appropriate gloves.

F) During use the CNSL-polyol containing formulation is metered into a mix head 

and pumped into molds or cavities. Within minutes the chemical reaction 

consumes all the polyol. Any workers in contact with the curing foam must 

wear proper PPE including air-purifying respirator, safety glasses and gloves.

2) Application #2 is the use of the formulated, 2-part reactive polyurethane foam in 

professional contractor spray applications. The foam is used in residential and 

commercial construction to improve insulation and reduce energy use for heating 

and air conditioning. This product line is not being sold to do-it-yourself 

homeowners. In accordance with the technical data sheet, a licensed dealer is 

instructed to store both the A-Side and the B-Side drums out of direct sunlight, and 

the stored chemicals should be kept at a temperature of between 60oF and 90oF. In 

case of a chemical spill licensed dealers are instructed to call both the formulator

and Chemtrec for further instructions. The A & B side are stored separately and 

pumped via closed system to a mixer and spray head. Using high-pressure spray 

guns the reacting foam is sprayed in between the joists of walls and cures in place 

to a rigid foam. To ensure safety during this process, the dealers follow strict safety 

procedures which require the use of personal protection equipment including 

(respirator, gloves, tyvek suit, goggles). The dealers are licensed and trained in the 

use of the equipment and chemicals.
Palmer International, Inc.

Title: Description of Renewable Polyol

PMN Date of Issue:11/24/2013

Revision Date: 11/24/2013 Page 4 of 5

11/24/2013 4

During application the A-Side chemically reacts with the B-Side to form the 

finished product - rigid polyurethane spray foam. During the A-Side/B-Side 

interaction that forms the cured thermoset insulation layer, the CNSL-polyol 

becomes incorporated into the polyurethane’s carbon backbone. The incorporation 

of the polyol into the carbon backbone prevents leaching of the chemical into the 

surrounding environment. 

Some excess foam may be created during spray application since the material 

expands upon curing. After curing, this excess is trimmed and transported to the 

landfill for its ultimate disposal. General guidelines for safe sprayfoam operations 

can be found at: http://www.sprayfoam.org/index.php?page_id=220

 

Worker Exposure Scenario:

G) The foam customer receives the formulated B-side containing the CNSL-polyol. 

All containers are sealed. The only risk is a spill event.

H) The production operator loads the formulated B-side containing the CNSLpolyol into a holding tank or attaches pump hose direct to the drum. Operator 

wears PPE of safety goggles, gloves and tyvek suit.

I) During use the CNSL-polyol containing formulation is metered into a mix head 

and pumped into to a spray nozzle. The mixed and reacting A & B sides are 

sprayed on walls. Within minutes the chemical reaction consumes all the 

polyol. All workers in vicinity during the spraying of the curing foam must 

wear proper PPE including safety glasses, gloves and respirator. The respirator 

is mandatory to avoid any inhalation of liquid or aerosol spray. Note: the 

primary hazard is the A-side containing isocyanates.

Application #3 is the use of formulated 2-part polyurethane system to make foam boards. 

This application is similar to #1 in that it is done in a controlled industrial manufacturing 

setting. The difference is that foam board and laminates are manufactured continuously 

on conveyer systems with the 2 reactive sides being mixed and poured at one end and 

expanding and curing down the length of the moving conveyer belt.

 Worker Exposure Scenario:

J) The foam customer receives the formulated B-side containing the CNSL-polyol. 

All containers are sealed. The only risk is a spill event.

K) The production operator loads the formulated B-side containing the CNSLpolyol into a holding tank. The operator must wear safety googles, apron or 

tyvek suit and appropriate gloves when pumping the material into a holding 

tank.

L) During use the CNSL-polyol containing formulation is metered into a mix head 

and pumped onto a moving conveyor belt. Within minutes the chemical 
Palmer International, Inc.

Title: Description of Renewable Polyol

PMN Date of Issue:11/24/2013

Revision Date: 11/24/2013 Page 5 of 5

11/24/2013 5

reaction consumes all the polyol. Any workers in contact with the curing foam 

must wear proper PPE including safety glasses and gloves.

 

EPA Contact Log

11/24/2013 Filed PMN electronically