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 spray 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 important 

areas including 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 either online or in an 

instructor-led capacity. This training program, focused on the health and safety aspects of highpressure spray foam, is available free of charge at www.spraypolyurethane.org. Since the initial

launch of the program, we have upgraded the capabilities of the program 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 training 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 

applicator 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. 
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In order to increase the reach of the program, this 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 lowpressure, two-component spray polyurethane. The video, “Working Safely with Low-Pressure 

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

weatherization 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 practices. 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 professional 

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 program 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 professionals, 

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 Hetfield, 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 website 

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 of 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 Design for 

Environment website.

In addition to webinars, 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 circulation of this publication 

was 14,000.
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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 

depicts 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 proper 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

was 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 

products 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 materials, 

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 completed 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 Emissions Testing Project (ASTM Committee D22.05 work item WK30960) is 

well underway. We have developed a research framework to evaluate emissions generated from 

SPF after application to help better understand potential occupant exposure to SPF chemicals 

following application. This project utilized the same generic formulation as the Ventilation 

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 ASTM 

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 research and who reviewed and provided thoughtful feedback and 

suggestions on the research questions and protocols. We look forward to providing information 

to EPA and others as this work progresses in 2012.
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Looking Ahead

We anticipate that 2012 will continue 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