April 22, 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 on 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 extremes of Middle East deployments. We 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. We greatly appreciate their assistance. 
Worker Training and Testing

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

as we can 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 centralized 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 to work with us on this project to immediately integrate and/or disseminate the core 

training module and testing package 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 programs.

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 foam 

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 documents 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 document 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 proposed timelines

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 and 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 and 
installation, 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 Magazine, Rubber World, Housing Zone, Sustainable Facility 

Magazine, Roofing Contractor, and PU (Polyurethanes) International.

This year, we anticipate launch of a consumer-facing website with substantial information 

intended for consumers, “do-it-yourselfers,” 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 Association 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, Plastics Division 

American Chemistry Council 

copy: 

Charles W. Kent, EPA 

Bill Hanson, EPA 

Carol Hetfield, EPA 

Mary Cushmac, EPA 

Daniel Almaguer, NIOSH

Janet Carter, OSHA

Treye Thomas, CPSC

Neeva-Gayle Candelori, ACC Center for the Polyurethanes Industry 

Kurt Riesenberg, Spray Polyurethane Foam Alliance