Presented by:

Carol Hetfield, Environmental 

Protection Agency 

Katherine Sleasman, 

Environmental Protection 

Agency 
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Presentation Outline 

 EPA’s Concern for Isocyanates, SPF and other 

Polyurethane Products

 Partnerships & Stewardship Goals 

 Challenges & Progress

 Background on TSCA Isocyanates Action Plans

 Other Activities

 Information Gathering Approaches

 Voluntary Information Request Letter on Curing Rates of PU 

Products

 Test Method Development 

 Significant New Use Rule (SNUR)

 Summary

 Information Sources

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Prevention & Toxics
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EPA’s Concerns for Isocyanates and 

Polyurethane Products 

 SPF and other polyurethane products can be mixed, 

applied, and/or manufactured on-site in a home, school, 

or other buildings.

 Diisocyanates in vapors, aerosols, and dust can cause:

 Asthma, respiratory & breathing problems, 

 Skin, eye, and dermal irritation,

 Sensitization, and

 Can trigger severe asthma attacks in sensitized 

persons, even at very low levels. 

 Amine catalysts, flame retardants, blowing agents and 

other ingredients or reaction products, such as aldehydes, 

may also cause health and environmental effects.

EPA Office of Pollution Prevention & 

Toxics
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Partnerships 

 Federal Partnership:

 US Environmental Protection Agency

 Occupational Safety and Health Administration

 National Institute for Occupational Safety and Health

 The Consumer Product Safety Commission (CPSC)

 The Agency for Toxic Substances and Disease Registry (ATSDR)

 Engagement with Industry Representatives:

 American Chemistry Council (ACC) 

 ACC’s Center For Polyurethanes Industry (CPI)

 Spray Polyurethane Foam Alliance (SPFA), representing applicators

 Individual Chemical and Polyurethane Product Manufacturers

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Stewardship Goals

• Avoidance of misleading or deceptive marketing claims.

• Communication of hazards, as well as benefits of SPF. 

 Develop & adopt practices to prevent harmful exposures:

 Ensure workers are trained on hazards, processing and 

equipment, curing rates, performance, as well as 

communicating with others.

 Ensure worksite isolated and restricted to workers 

wearing appropriate personal protective equipment 

(PPE).

 Provide guidance on safe re-occupancy times and 

ventilation.

 Address research needs and data gaps.

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Toxics
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Challenge – Misleading and/or 

Deceptive Marketing Claims 

 “No off—gassing,” “non—toxic,” “green,“ 

“environmentally friendly,” “plant-based,” “made from 

soy beans,” etc.

 Little may be revealed about chemical ingredients and 

potential hazards/risks.

 DIY programs showing improper protection.

 On-line videos showing untrained/unprotected 

application of products.

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Progress in Addressing Misleading 

Marketing Claims

 US Federal Trade Commission (FTC) Green Guides

 Enhanced Energy Star Residential Insulation Partnership 

Requirements:

 Clear and specific safe installation practices and PPE.

 Documentation for performance and environmental claims.

 Safety Data Sheets on chemical reactants with hazard information listed.

 Safe re-entry times for other workers and home occupants after installation.

 Industry guidance -

 http://www.spraypolyurethane.org/ GreenMarketingClaims

 Guidance for Videos or Images Showing Spray Polyurethane Foam (SPF) Application

 Guidance on OSHA’s Revised Communication Standard: Globally Harmonized System (GHS) 

of Classification and Labeling of Chemicals AX500 January 2013;

 Hazard Information to Consider when Labeling of Diphenylmethane Diisocyanate (MDI), 

polymeric MDI and Isocyanate-terminated MDI prepolymers Containing Products for the 

Consumer Marketplace.

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Challenge –Hazard Communication

 Availability of Safety Data Sheets (SDSs).

 Hazard and exposure control information may vary.

 Recommendations on respiratory protection, including 

guidance on protection for “adjacent workers.”

 Although adequate ventilation described as needed, little 

guidance on what constitutes adequate ventilation and 

methods.

 Identification that skin contact may cause an allergic 

reaction and sensitization.

 Identification that dust can be generated during cutting 

or abrasive processes.

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Progress in Addressing Hazard 

Communications

 Federal – US EPA Spray Polyurethane Foam website, 

OSHA’s Green Jobs site and National Emphasis Program, 

NIOSH ALERTS, numerous resources and information 

pages across federal Agency websites on isocyanates 

and other chemical hazards (see resources).

 Industry - Product stewardship activities: 

 Fact sheets, technical bulletins, websites & portals, see 

http://spraypolyurethane.org/default.aspx

 Other - Spray Foam Magazines, industry newsletters, blogs, 

Green Building webinars, technical panels at conferences, goals 

in product sustainability standards.

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EPA’s Approach to Best Practices 

 Identify established practices for engineering or process 

efficiencies & control technologies to reduce exposures and 

environmental releases,

 Review existing worker training materials & practices 

addressing the use of PPE and control technologies, and 

 Solicit recommendations for innovative practices from 

industry and field experts, capturing the following:

 Identify job related tasks. 

 Safe work practice(s). 

 Exposure reduction/prevention potential of the safe work practice.

 Other relevant information (i.e., pros and cons) associated with the 

safe work practice. 

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EPA Guidance

 Checklists for installers and communicating with 

homeowners.

 Ventilation Guidance for SPF Applications/Automotive 

Shops.

 Self-evaluation tool for contractors of practices and 

strategies to protect workers and promote the safe use 

of polyurethane products.

• Periodic assessment tool of their current practices and identify 

areas for improvement.

• Includes the following:

 Over 175 Activities (safer workplace practices). 

 Potential for exposure & impact on worker exposure.

 Four key-operation phases: on-going, pre-application, application, 

EPA Office of Pollution and post-application.

Prevention & Toxics
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Challenge - Training

 Ensure that all workers receive comprehensive training on 

hazards, curing rate, performance, equipment and 

processing, as well as communicating with others, 

including homeowners.

 Ensure premises are restricted to workers wearing 

appropriate personal protective equipment (PPE).

 Innovative solutions to prevent chemical migration 

should continue to be developed and shared to ensure 

industry-wide practice.

 Ensure homeowners, teachers and students, and the 

general public are not exposed to hazardous chemicals 

during and after polyurethane product applications.

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Prevention & Toxics
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Progress in Training

 Industry – ACC’s on-line H&S training & testing courses:

 Low Pressure SPF Chemical Health and Safety Training

 High Pressure SPF Chemical Health and Safety Training

 See http://spraypolyurethane.org/SPF-Chemical-Health-andSafety-Training

 SPFA certification and accreditation program: 

 SPF Professional Certification Program (PCP) for assistants, 

installers, master installers, program managers, and field 

examiner, see 

http://www.sprayfoam.org/index.php?page_id=4557

 Training courses at conferences/conventions 

 Chemical or Product Manufacturer-Contractor training

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MDI and TDI Action Plans 

 Diisocyanates:

 Recognized as dermal and inhalation sensitizers

 May cause asthma, lung damage, and in severe cases, fatal 

reactions

 EPA is concerned about potential exposures to 

consumers and/or those commercial workers not 

covered under OSHA regulations, and the general 

population that could result from the use of products 

containing unreacted MDI, TDI, and related 

compounds. 

 e.g., application of spray-applied sealants and coatings when 

such products are used in or around buildings such as homes 

or schools

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Summary of MDI & TDI Action 

Plans

 Based on EPA’s screening-level review of hazard and 

exposure information EPA will consider the following 

actions: 

 Initiate TSCA section 8(d) reporting for unpublished health 

and safety studies. 

 Consider initiating a TSCA section 4 test rule to require 

exposure monitoring studies.

 Initiate rulemaking under TSCA section 5(a)(2) for a 

Significant New Use Rule (SNUR) designating certain uses of 

TDI in a consumer product as a new use requiring prior 

notice to the Agency. 

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Other Potential Regulatory Actions 

 Consider issuing a data call-in under TSCA section 8(c) 

Allegations of Adverse Effects 

 Consider TSCA section 6 action that gives EPA the 

authority to protect against unreasonable risk of injury to 

health or the environment -

 If EPA finds that there is a reasonable basis to conclude that the 

chemical's manufacture, processing, distribution, use or disposal 

presents an unreasonable risk.

 Actions could include but are not limited to: prohibiting or limiting 

manufacture, processing, or distribution in commerce of a chemical; 

requiring warnings and instructions with respect to use, distribution, or 

disposal; and/or, recordkeeping requirements.

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Information Request Authority 

 For the purposes of carrying out TSCA, EPA requested companies 

voluntarily provide certain information 

 EPA specifically requested information in their possession on the curing 

time required to chemically react all diisocyanate functional groups, and 

 The amount of time required to safely re-occupy or use an area where 

diisocyanates have been reacted

 The Agency is reviewing the information to determine what it tells 

us about consumer and worker exposure to polyurethane products. 

 EPA received the following types of data as a result of our request 

including: 

 Formulation Data

 Safety Data Sheets

 Industrial Hygiene Studies 

 Curing information

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Test Methods to Measure Emissions

 Need methods and data that paint the picture of “source-toexposure,” over the product life-cycle capturing “normal” cure 

phase emissions as a benchmark for evaluating emissions and 

off-spec conditions, wherein –

 A methodology is a tool that industry uniformly uses to evaluate 

product formulations, providing reliable data to better assess the 

potential for exposures. 

 EPA’s Office of Research and Development is developing test 

methods and protocols to generate reliable data to fill 

knowledge gaps, including 

 What is emitted and for how long and factors that may impact 

emissions? 

 This work supports the ASTM Committee D 22.05 SPFI emissions 

test method development task.

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Prevention & Toxics
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Significant New Use Rules (SNURs)

 TSCA section 5(a) authorizes EPA to determine that a use of a 

chemical substance is a “significant new use.” EPA must make this 

determination by rule after considering all relevant factors, including

 The projected volume of manufacturing and processing of a chemical substance.

 The extent to which a use changes the type or form of exposure of human beings 

or the environment to a chemical substance

 The extent to which a use increases the magnitude and duration of exposure of 

human beings or the environment to a chemical substance

 The reasonably anticipated manner and methods of manufacturing, processing, 

distribution in commerce, and disposal of a chemical substance

 A SNUR requires that manufacturers and processors of the chemical 

subject to the SNUR notify EPA at least 90 days before beginning any 

activity that EPA has designated as a "significant new use”

 EPA will designate certain uses of TDI and TDI related compounds in 

consumer products as a new use requiring prior notice to the Agency. 

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Summary

 The SPF industry needs to ensure:

 There is comprehensive and clear hazard communication for all SPF 

users – applicators, assistance, other trades, do-it-yourselfers, 

consumers, and other decision-makers (i.e., building managers, etc.).

 Consumers need clear hazard and use warnings, such as through 

product labeling and communications with commercial contractors.

 The work site is restricted to only those wearing appropriate personal 

protective equipment.

 Quality control - avoid installation of off-spec, poor performance 

polyurethane materials. (see saferproducts.gov for complaints of offgas persistence). 

 Guidance is provided on re-occupancy time & long-term ventilation 

(H-VAC) needs.

 Marketing claims are accurate and balanced.

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Prevention & Toxics
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Where to Get More Information?

 EPA’s DfE SPF website: http://www.epa.gov/dfe/pubs/projects/spf/

spray_polyurethane_foam.html

 NIOSH Alert on Spray-on Truck Bed Lining Operations http://www.cdc.gov/niosh/docs/2006-

149/default.html

 OSHA’s isocyanates: http://www.osha.gov/SLTC/isocyanates/index.html

 OSHA’s Green Jobs Hazards: http://www.osha.gov/dep/greenjobs/index.html

 EPA’s Action Plan and docket: 

http://www.epa.gov/opptintr/existingchemicals/pubs/actionplans/mdi.pdf

 FTC Green Guides: http://www.ftc.gov/os/2012/10/greenguides.pdf

 American Chemistry Council Center for the Polyurethanes Industry 

http://www.spraypolyurethane.org/

 Spray Polyurethane Foam Alliance: http://www.sprayfoam.org/

 International Research Conference (Isocyanates & Health: Past, Present, & Future, April 2013, 

Bolger Center in Potomac, MD), http://www.isocyanates2012.org/content/home.cfm

 ASTM Methods (D22.05) for measuring chemical emissions from Spray Polyurethane Foam.

 Project Coordinators: Carol Hetfield; 202-564-8792; hetfield.carol@epa.gov

& Katherine Sleasman; 202-564-7716; sleasman.katherine@epa.gov

EPA Office of Pollution Prevention & 

Toxics