EPA Comments May 22, 2015

This is written regarding the EPA August 6, 2014 proposed rulemaking, “Protection of Stratospheric 

Ozone: Change of Listing Status for Certain Substitutes Under the Significant New Alternatives Policy 

Program”, which would restrict many commonly used hydrofluorocarbons (HFCs). In particular these 

comments below regard polyurethane spray foam insulation.

Thank you for the opportunity to present information to you that is vital to our industry. The issue is 

more complex than at first glance and not just one insulation versus another or one blowing/expanding 

agent against another based on pure preference. It is about energy usage and efficiency and what is 

feasible with regards to the timetables to bring viable products to market in a manner that provides 

ample time for safe and proper development while protecting jobs and business growth. It is really 

about risk and reward. Does speeding up the elimination of HFCs in spray foams by two years offer a 

huge impact. And does that justify the risk of job loss, expense, potential for rushing and not doing the 

job right, and potential for economic impact such that home owners and building owners don’t insulate 

or insulate less efficiently so that energy usage is higher and thus carbon footprint is higher.

The main point is that polyurethane spray foam insulation is the most efficient and energy saving 

insulation on the market. Studies are proven showing 40% savings in energy consumption versus other 

conventional insulations. That means less carbon footprint which pleases the environmentally 

conscious. And it means energy savings, putting more money in consumers pockets to spend on other 

things which strengthens the economy. Doesn’t that lead one to think that it is important to get it right 

from a safety and performance standpoint to continue such gains. Allow us as an industry the 

reasonable timeframe to bring new products to market and do the job right. 

Polyurethane foam insulation has been around since the 1970’s but its huge impact is still in its infancy 

having been truly geared for residential and commercial buildings only over the last 10-12 years. It has 

had a great impact and has tremendous potential for reducing our energy consumption per capita. Don’t 

let it get derailed or embroiled in manufacturers’maneuvering and manipulating the political and public 

emotional opinion.

Existing blowing agents are proven and have gone through the very onerous and complete testing 

process to insure proper performance and safety regarding exposure and fire. Next generation blowing 

agents are on the horizon and will come in time. It is the timing that is of question. The existing 

timetable to eliminate HFC’s provides adequate time for research, development, testing, field trials, and 

full implementation. But rather than rush and push arbitrary deadlines, we implore you to act such that 

proper testing is done to insure that the right and best alternatives are allowed to come to market. 

Currently, the next generation of blowing agents are in testing and each of us as manufacturers of spray 

foam systems are at different stages of development. Typical catalysts and surfactants do not work well 

with these next generation materials and shelf life is not adequate, less than half the needed time for 

the manufacture to end-use cycle. There are currently two molecules by three different manufacturers 
in progress. One is currently available in small quantities with true viability a year away. It appears at 

this time to be the least compatible with other components in the blended system. The other molecule 

thus far appears to be more compatible and offers better performance and its full production is 18-24 

months away and even then supply may be limited by plant size.

At this point in time there just is not enough data by the formulators like us (who actually put the raw 

materials together in viable commercial products)to chart an absolute best path. Insulation saves energy 

big time and that means it is very important to get it right. Allow us that time please.

There are numerous polyurethane foam manufacturing companies and many, many more distributors 

and contractors employed in this industry. Most are small to medium sized companies. They are hardworking, tax- paying people who contribute to the economy as so many people do. But our industry has 

a unique position at this time in that it can greatly impact energy reduction and environmental impact 

especially if we are allowed to develop systems in a methodical, scientific method with a reasonable 

timetable allowing us to do it right. Because doing it right means decades of insulation and energy 

saving performance in homes and commercial buildings, including schools and hospitals, which is 

indeed a big environmental impact.

Thank you for your consideration of our input regarding this important topic.

Sincerely,

Mac Hess

President & C.E.O. 

Premium Spray Products, Inc.

Marietta, GA

770-528-9556

1255 Kennestone Circle Marietta, GA 30066 Phone: 770-528-9556 www.premiumspray.com