April 2 2 , 2010

Wendy Cleland

- Hamnett Director, Office of Pollution Prevention and Toxics U.S. Environmental Protection Agency Ariel Rios Building

MC

- 7401M 1200 Pennsylvania Avenue, NW Washington, DC 20460

Re: Spray Polyurethane Foam Product Stewardship Activities

Dear Ms. Cleland

- Hamnett :

I am writing to update you o n the various product stewardship activities regarding spray polyurethane foam that are being led by ACC’s Center for the Polyurethanes Industry (CPI), together with the Spray Polyurethane Foam Alliance (SPFA). If it would be helpful, we would be happy to meet with you and your staff to provide a more thorough review of these programs.

Spray polyurethane foam is a highly energy efficient product that is helping to achieve even

greater energy efficiency in residential, commercial and government buildings. Spray polyurethane foam is even being used to help keep American troops comfortable during the

temperature extr emes of Middle East deployments. W e share the Agency’s interest in the safe use and handling of this product , and that’s why we have launched a robust, multi

- dimensional product stewardship program that features worker training and testing

, consumer outreach and

education , and research to help support its continued long

- term sustainability

.

This letter updates our July 16, 2009 letter to you, where we outlined focused areas of engagement on matters involving the safe use and application of spray polyurethane foam products. Since that time, we have worked diligently with a number of EPA staff to help launch our product stewardship efforts. In particular, Carol Hetfield, Bill Hanson, and Mary Cushmac have provided invaluable leadership , focus, and assistance in helping to disseminate training and product stewardship materials

. W e greatly appreciat e their assistance.Worker Training and Testing

One of our program goals is to reach as many professional spray polyurethane foam contractors

as we ca n with core health and safety training. To do this, we are developing a program that would provide a national framework and mechanism for the delivery of a core health and safety training module and testing package (in both English and Spanish). A centra lized tracking system will allow us to be able to better understand the number of applicators and helpers completing this core training. We anticipate launching this national program in mid to late 2010. In the meantime, we conducted outreach to the entities in the value chain that package and sell

spray polyurethane foam chemical systems to contractors. To date, we have commitments from

17 entities t o work with us on this project to immediately in tegrate and/or disseminate the core training module and testing packag e into the training programs they already offer. We intend to work with OSHA to explore opportunities to further enhance the effectiveness and ready availability of worker training prog rams.

Product Stewardship / Hazard Communication Guidance Documents

In the first phase of our program, we developed and launched a series of guidance documents

and videos intended for immediate availability within the professional spray polyurethane fo am contractor community. We disseminated over 5,000 compilations of these documents in hard copy over several months. In addition, the entire compilation is available for download over the internet. We are in the process of translating all guidance docu ments into Spanish.

The second phase of our program is developing additional materials, including more detailed guidance for homeowners and those in the building and construction community seeking to install spray polyurethane foam insulation. A key docu ment under development focuses on understanding how to deliver or ask for detailed guidance on reoccupancy times (at what point after the spray polyurethane foam installation is completed is it appropriate for residents to reenter a building).

Research

We have initiated discussion on several research projects in coordination with EPA, OSHA

, NIOSH , and CPSC . The first project focuses on development of a test method to measure total isocyanates. The second focuses on development of a protocol for spray polyurethane foam emissions testing

. The third project takes a closer look at whether MDI is available in dust generated during trimming and cutting operations following spray polyurethane foam operations. We have briefed EPA’s technical staff about these important projects and the propose d timeline s for completion. We also are exploring research specific to ventilation techniques at spray polyurethane foam installation sites. We look forward to continued productive dialogue with EPA staff as additional research projects are identified an d evaluated.

Outreach

Our outreach in 2009 was highly successful. In addition to outreach in the supplier

- contractor supply chain for spray polyurethane foam, we conducted outreach at several industry trade shows

and consumer events. Outreach about the program, the importance of safe handling andinstallation, and the availability of new guidance materials reached an audience of over 38

million people in trade and business media such as Environmental Design & Construction, Yahoo News!, Spray Foam Ma gazine, Rubber World, Housing Zone, Sustainable Facility Magazine, Roofing Contractor, and PU (Polyurethanes) International.

This year, w e anticipate launch of a consumer

- facing website with substantial information

intended for consumers , “do

- it

- yourselfe rs,” and builders with questions about the safe use and application of spray polyurethane foam in the next few months. We also have contacted a number of affiliated trade organizations, including the Insulation Contractors Association of

America and the A ssociation of General Contractors of America to seek their involvement and support of the industry product stewardship effort.

Thank you for taking the time to consider this important work.

Very truly yours,

Steve Russell Vice President, P lastics Division American Chemistry Council

copy : Charles W. Kent, EPA Bill Hanson, EPA

Carol Hetfield

, EPA Mary Cushmac, EPA Daniel Almaguer, N IOSH
Janet Carter, OSHA Treye Thomas, CPSC

Neeva

- Gayle Candelori, ACC Center for the Polyurethanes Industry Kurt Riesenberg, Spray Polyurethane Foam Alliance