Stakeholder Workshop: 

Foams Sector 

April 26, 2013

U.S. Environmental Protection Agency
Introduction

• Why foams, why now?

– Second sector in series of stakeholder 

workshops

• Goals of Meeting

– Present and future for sector transitions

– Inform the SNAP team and Vintaging Model

– Two-way dialogue

2
Scope of Meeting

• Foam Blowing Agents Sector – Implementing 

Montreal Protocol & Clean Air Act

• Significant New Alternatives Policy (SNAP) 

Program

– Regulatory update

• HCFC Product Labeling

• Vintaging Model

– How we collect and use information

• Discussion

3
Selected Milestones

• 1973: Rowland and Molina began studying CFC effects on 

the atmosphere

• 1978: U.S. bans CFC propellants

• 1987: Montreal Protocol signed

• 1990: Clean Air Act amended

• 1993: HCFC phaseout framework established

– Worst-first: HCFC-141b in 2003; HCFC-22, -142b in 2010

• 1994: Nonessential products ban takes effect, most foam 

products containing, or manufactured with CFCs & HCFCs 

banned from sale and distribution in the United States

– Sell-through and limited exemptions apply

– HCFC exception for foam insulation product:

• Closed cell rigid polyurethane; polystyrene; phenolic; and 

polyethylene solely for thermal insulations around pipes

• 2004 & 2007: SNAP bans on HCFCs for foam blowing 4
Identifying Safer Alternatives

Significant New Alternatives Policy (SNAP) Program 

• Evaluates substitutes that reduce overall risk to human health 

& environment in industrial sectors

– Aerosols, Foams, Refrigeration and A/C, Solvents, 

Fire Suppression, Adhesives, coatings & inks, etc.

• 400+ substitutes reviewed considering: 

– Ozone-depleting potential

– Global warming potential

– Flammability

– Toxicity

– Local air quality

– Ecosystem effects

– Occupational & consumer health/safety

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SNAP Listings

• SNAP lists alternatives as acceptable, unacceptable, or 

acceptable with conditions for use

• Alternatives include:

– Alternative chemicals/blends 

– Alternative technologies (e.g., thermoelectric)

• Next generation alternatives

– Many climate-friendly options

• Currently SNAP has approximately 25 active submissions 

– Numbers have been higher in recent years, particularly for foams, 

air-conditioning, and refrigeration

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Why is SNAP So Busy Now?

• Opportunities to protect ozone layer & climate 

system

– Climate-friendlier solutions being developed and deployed

– Corporate commitments to sustainability

• Montreal Protocol milestones help drive technology

– 2010, 2013 and 2015 are all milestone years 

• Other global, regional & domestic activities, such as:

– North American Amendment proposal to address HFCs 

under the Montreal Protocol

– EU F-gas rule

– Australian synthetic gas levy 

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HCFC Product Labeling

• As of January 1, 2015 any product manufactured with 

or containing an HCFC must be labeled 

– WARNING: [Contains / Manufactured with] [name of HCFC], a 

substance which harms public health and environment by 

destroying ozone in the upper atmosphere

• Foams imported after 2014 and products 

incorporating foams manufactured/imported after 

2014

– Any product containing closed cell foam blown with an HCFC must 

be labeled as a “product containing” HCFCs

– Any product that contains open cell foam blown with an HCFC

must be labeled as a “product manufactured with” HCFCs

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Effect of Title VI Rules

• SNAP, Nonessential and CAA 605(a) together means there 

is no longer domestic use of HCFC-22, -141b, and -142b

– Imported foam insulation as part of a larger product is still permitted, 

e.g. refrigerators 

– However, January 1, 2015 imported products with HCFCs would be 

labeled (CAA 611) 

• Multiple options acceptable under SNAP

– Vary somewhat by end use

– Include HFCs such as HFC-134a, HFC-245fa, HFC-365mfc

– Non-fluorinated options: hydrocarbons, water, CO2, methyl formate, 

etc.

– Low-GWP fluorinated options HFO-1234ze, -1233zd(E)

• Additional submissions under consideration, e.g. HFO1336mzz(Z) and blends of HFC-365mfc/HFC-227ea

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U.S. EPA Vintaging Model

• What? Tracks U.S. types of equipment and useful life 

practices (“end-uses”) of ODS and substitutes

• Where? Major Sectors: Aerosols, Foams, Solvents, Fire 

Protection, Refrigeration/AC

• When? Tracks chemical from when first produced and placed 

into equipment or product (“consumption”) through servicing 

and use until finally recycled/released to atmosphere 

(“emissions”)

• Who? EPA tool developed with input from industry 

– Other data sources (some CBI)

• Why? Consumption and emissions of ODS and substitutes

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Vintaging Model – Uses

• Analysis of HCFC phaseout & servicing needs

– Estimated needs and available supplies (MP cap, 

recoverable)

• Projections of consumption and emissions for 

alternatives (i.e., HFCs)

– What if scenarios

• Reporting for international regimes

– Consumption and emissions

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Foam Blowing Fire Protection Solvents Aerosols Ref/AC

ODS Substitutes

Flexible

Polyurethane

Extruded Polystyrene

Phenolic

PU/PIR Boardstock

Total Flooding

Streaming

Metered Dose

Inhalers (MDIs)

Non-Medical

Dusters

Deodorants

Metals

Electronics

Precision

Polyolefin

Rigid PU

Commercial Refrigeration

Integral Skin

Slabstock/Moulded

Sheet Foam Boardstock Foam

Domestic

Refrigeration

Spray Foam

One Component

Slabstock Domestic Refrigerator/

Freezer Insulation

Continuous &

Discontinuous

Panels

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Discussion Questions: Sector 

Transitions

• In the early/mid 1990s, given the nonessential products ban 

and CFC phaseout, companies transitioned to various 

options, many were non-fluorinated 

– Since then, additional alternatives have been listed - have you 

transitioned again? Into/out of F-gas options? 

– Do you anticipate transitioning again as next-generation low-GWP 

alternatives become available?

• Are additional sector transitions expected?

– Transition within the current suite of alternatives?

– Should SNAP anticipate additional foam submissions?

• New molecules?

• Additional blends?

• Alternatives currently used internationally such as methylal?

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Additional Discussion 

Questions

• What are the current barriers to transition?

• What benefits have you seen from making the 

transition? 

– Decreased cost? Support sustainability goals? Better for 

the environment, performance?

• What additional information can be provided by 

individual companies or by trade associations to 

inform the Vintaging Model? 

– Data on specific end-uses

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Discussion