americanchemistry.com ® 700 Second St., NE | Washington, DC 20002 | (202) 249. 7000 December 16, 2011

Wendy Cleland

- Hamnett Director, Office of Pollution Prevention and Toxics Office of Chemical Safety and Pollution Prevention U.S. Environmental Protection Agency

MC

- 7401 M Ariel Rios Building 1200 Pennsylvania Avenue, N.W. Washington , DC 20460

Re: Center for the Polyurethanes Industry Spray Polyurethane Foam Product Stewardship

Activities

Dear Ms. Cleland

- Hamnett:

I am writing to provide you with an update on important developments in the product stewardship activities regarding sp ray polyurethane foam that continue to be led by the American Chemistry Council’s ( ACC ) Center for the Polyurethanes Industry (CPI) in cooperation with the Spray Polyurethane Foam Alliance (SPFA). This letter provides information on three importan t
areas i ncluding worker training and testing, outreach

, and research.

Worker Training and Testing

Since the launch of the online CPI Spray Polyurethane Foam Health and Safety Training program this time last year, over 3,300 individuals have taken the training e ither online or in an

instructor

- led capacity. This training program , focused on the health and safety aspects of high

pressure spray foam

, is available free of charge at www.spraypolyurethane.org . Since the initial launch of the program , w e have upgraded the capabilities of the prog ram to include a dedicated landing page so users can access the training site directly from a link on another site and we completely automated the instructor

- led portion of the tr aining to facilitate the ability to create classes, download materials and upload testing results to the website. A simple search feature on the training website enables employers, contractors, customers and others to verify that a SPF applicat or completed the safety training.

Completion of the CPI SPF Health and Safety Training program has been made a prerequisite for the accreditation courses offered by SPFA and has been incorporated into the training programs at many systems houses as well.Page 2

americanchemistry.com ® 700 Second St., NE | Washington, DC 20002 | (202) 249.7000 In order t o increase the reach of the program, th is training was provided to participants at the February meeting of the Spray Polyurethane Foam Alliance and at the September meeting of

Insulation Contractors Association of America (ICAA).

In November of this year, CPI released a new guidance video for professional installers of low

pressure, two

- component spray pol yurethane

. The video, “Working Safely with Low

- Pressure Spray Polyurethane Foam Insulation,” runs approximately nine minutes and is targeted to

weatheri zation professionals and spray foam contractors applying low

- pressure SPF. It includes information about the chemicals used to make SPF, personal protective equipment (PPE), appropriate places to install SPF, job site preparation, cleanup, and safety pract ices. The video complements the extensive high

- pressure SPF health and safety training program and other free

resources that CPI has made available to those using spray foam. The video is available for viewing or download at www.spraypolyurethane.org in the Weatherization section.

Finally, CPI has begun development of an online training module for professional low

- pressure

spray foam installers that is modeled on the existing program for high

- pressure profes sional spray foam installers. Through the Research Foundation for Health and Environmental Effects

, a 501(c)(3) tax

- exempt organization established by ACC , CPI applied for and won a Susan

Harwood Grant from OSHA to develop an online training p rogram on hazard communications for weatherization professionals pertaining to low

- pressure spray polyurethane foam. Training

, provided in both English and Spanish, will include a web

- based program targeting professional s, contractors, and applicators who work with low

- pressure two

- component kits/systems. The anticipated completion date is September 2012.

We appreciate the valuable feedback and interaction from EPA staff and other federal agencies, coordinated by Carol H etfield, during the development and promotion of our training efforts. We

have reviewed all of the feedback they provided on the training modules and incorporated suggestions from the federal agencies into updated materials that will be posted on the web si te and will serve as the basis for the Spanish translation of the training program that we will

undertake in 2012

.

Outreach

Much of the outreach efforts in 2011 were focused on promotion of the free training program and

video . These efforts consisted o f multiple introductory webinars for spray foam manufacturers

, interested government representatives and spray foam contractors . Staff and members of stakeholder groups promoted the training and added links from their websites to the www.spraypolyurethane.org website to facilitate access to the training program. We are grateful to EPA for highlighting the availability of this resource to the public on its D esign for

Environment website.

In ad dition to web inars, press releases, a promotional video and hundreds of emails to weatherization contractors, stakeholder groups, and others, a feature article about the training

program appeared in Spray Foam magazine in February 2011. The circulatio n of this publication
was 14,000.Page 3

americanchemistry.com ® 700 Second St., NE | Washington, DC 20002 | (202) 249.7000 In May, CPI promoted the release of a new 5

- page downloadable document ( Guidance for Videos or Images Showing SPF Application ) providing guidance for manufacturers, marketers, contractors and others to use when developing visual media (photos, videos, graphics, etc.) that depict s SPF application so proper health and safety measures can be shown . This document can now be used as the basis for individual outreach to anyone whose advertising or images do not

show the prope r use of Personal Protective Equipment in association with SPF application.

We were pleased that EPA was able to participate in the CPI 2011 Technical Conference in Nashville, TN

, where EPA’s Ventilation Guidance for Spray Polyurethane Foam Application

w as presented as both a paper and a poster. Carol Hetfield, Kristie Friesenhahn, and Katherine Sleasman of EPA, as well as Kathy Ernst and Dave Marlowe of NIOSH, were able to attend the conference, meet with manufacturers and suppliers of spray foam and other polyurethane product s and hear technical updates presented during the sessions. Their collective participation

in the CPI conference is the most valuable kind of outreach available.

Research

CPI is working on the development of research and testing projects for SPF raw mat erials, engineering practices, and analytical methods.

CPI’s Ventilation Research Project is researching the impact of changes in ventilation rates on the concentration of SPF chemical vapor and particulates emitted during SPF application. We have comple ted Phase I testing for spray equipment and the development and testing of a generic

SPF formulation . Phase II, monitoring chemical emissions during SPF application under

controlled environmental conditions

, has been developed and will be ready for launch early in

2012 . SPFA has agreed to provide a skilled, trained spray foam contractor to participate in this project. Phase III will likely be focused on field testing to verify the results derived from the spray booth application.

CPI’s Product E missions T esting Project (ASTM C ommittee D22.05 work item WK30960) is well underway. We have developed a research fram ework to evaluate emissions generated from SPF after application to help better understand potential occupant exposure to SPF chemicals following ap plication. This project utilized the same generic formulation as the Ven tilation Research Project. Preliminary results were presented at an ASTM Workshop on October 31

, 2011, and we will continue to develop a workable test method for submission to the AST M standards development process. EPA is one of many stakeholders involved in the ASTM

Committee concerned with this work item.

CPI has benefitted from the involvement of EPA staff and staff from NIOSH

, who participated in updates on the status of the rese arch and who reviewed and provided thoughtful feedb ack and suggestions on the research questions and protocols. We look forward to providing inf ormation

to EPA and others as this work progresses in 2012

.Page 4

americanchemistry.com ® 700 Second St., NE | Washington, DC 20002 | (202) 249.7000 Looking Ahead

We anticipate that 2012 will contin ue to be an active year with many product stewardship activities around spray polyurethane foam. We look forward to continuing our productive dialogue and relationship with EPA and other federal agencies in 2012 starting at the SPFA convention in February and continuing with our participation with EPA and SPFA at the Good Jobs Green Jobs conference also in February.

Thank you for taking the time to consider these important efforts.

Regards,

Lee Salamone

Senior Director

Copy: Janet Carter, OSHA Kathy Ernst, NIOSH Matt Gillen, NIOSH Oscar Hernandez, EPA Carol Hetfield, EPA David Marlowe, NIOSH Kurt Riesenberg, SPFA Robert Streicher, NIOSH Treye Thomas, CPSC