## 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

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## 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
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## 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

– L ocal air quality

– Ecosystem effects

– Occupational & consumer health/safety 5

## 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 7

## 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, CO 2 , methyl formate, etc.

– Low - GWP fluorinated options HFO - 1234ze, - 1233zd(E) • Additional submissions under consideration, e.g. HFO 1336mzz(Z) and blends of HFC - 365mfc/HFC - 227ea 9

## 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

11Foam 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 Boardstock Foam Sheet 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? 13

## 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