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February 14, 2014

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.

Washin gton, DC 20460

Dear Ms. Cleland

- Hamnett:

T he Spray Foam Coalition (SFC) of the American Chemistry Council’s Center for the Polyurethanes Indu stry ( CPI) recently adopted a Code of Conduct to further the systems house member companies’ commitment to continuous improvement in health, safety and product stewardship. This is the first commitment of its kind in the spray polyurethane foam ( SPF )

indus try.

This Code demonstrates an important and continuous commitment to product stewardship that benefits the entire SPF value chain as well as everyone in the built environment. The use of SPF continues to grow and is one of the most eff ective tools to eff

iciently air seal and insulate residential and commercial buildings. The signatories, SFC members that manufacture SPF

systems

, promote worker and public health and safety with respect to their SPF products, which

include the chemicals that react to make S PF and the final SPF materials.

The SFC Code of Conduct includes commitments to leadership, communication, applicator training, education

, and research. Agreement and adherence to this code of conduct is a requirement for membership i n the Spray Foam Co alition for members that manufacture SPF

systems

.

I have attached a copy of the Code of Conduct to this letter and a question and answer document

about the Code . The Code is also posted on our public website here

.Page 2

February 14, 2014

The members of the CPI SFC look forward to our continuing discussions about SPF. Please feel free to contact me if you have any questions regarding the SFC Code of Conduct

.

Regards,

Lee Salamone

Senior Director

cc: M. Doa, EPA C. Hetfield, EPA J. Morris, EPA

A. Pfahles

- Hutchens, EPA D. Widawsky, EPASpray Foam Coalition Code of Conduct

Members of the American Chemistry Council (“ ACC ”) Center for the Polyurethan es Industry’s (“CPI”) Spray Foam Coalition (“SFC”) are the leading manufacturers of spray polyurethane foam (“SPF”) systems sold or distributed in the United States. The values of product stewardship and product safety are important to the entire SPF value chain. SFC members that manufacture SPF systems promote worker and public health and safety with respect to their products, which

include the chemicals that react to make SPF and the final SPF materials.

The SFC Code of Conduct provides a framework to drive continuous improvement in health and safety and product stewardship. Agreement and adherence to this code of conduct is a requirement for membership in the Spray Foam Coalition for companies that manufacture SPF systems (“systems house members” or “ members”). 1 This Code of Conduct will be reviewed regularly, at least annually, and revised as needed by the SFC membership. There is also a

governance process.

This Code of Conduct begins with a commitment to a culture of product safety by the members

th at manufacture SPF systems. Each systems house member will adhere to the six commitments

set forth in this Code of Conduct. Suggested practices are only examples of possible ways to

adhere to the Code of Conduct’s commitments , but should not be considered the sole or recommended means to do so, nor do they replace each systems house members’ legal obligations under federal, state and local laws and regulations. Other practices may also be used because a suggested practice may not be widely applicable to al l systems houses, and may be substituted or adapted to meet specific needs and varying factual circumstances.

1. Leadership Commitment.

Senior company leadership of the SPF business group demonstrates a culture of product safety and product stewardship th rough their words, policies and actions throughout their company and in external communications.

Suggested practices might include, but are not limited to the following:

 Developing policies, activities, and resources throughout the company to encourage

a ctive participation and communication concerning product safety and product stewardship.

 Senior leadership of the SPF business group d esignating an individual to monitor the company’s adherence to the six commitments of the SFC Code of Conduct.

 Conducting an annual internal review of the company’s adherence to the six

commitments of the SFC Code of Conduct and review ing performance with senior leadership of the SPF business group

.

1 Not al l members of the SFC are systems houses. This Code of Conduct only applies to systems house members of

the SFC.2. Commitment to Hazard Communication.

Hazard communication is the foundatio n of safe use and handling of SPF chemicals

.

Suggested practices might include, but are not limited to the following:

 Making required Safety Data Sheets (“SDS”) for products readily available.

 Providing customers with appropriate health and safety inform ation specific to each product formulation.

 Advising customers about the use of Personal Protective Equipment (“PPE”) for each type of application and each stage of the work.

3. Commitment to Applicator Training.

SPF is applied onsite, which means that professional SPF contractor s and their applicators are a key factor in the safe production and application of the final product. Systems House

Members support the safe application of SPF and provide customers with information about safe handling practices for their specific products

.

Suggested practices might include, but are not limited to the following:

 Encouraging customers to successfully complete the applicable CPI free online basic chemical health and safety training at www.spraypolyurethane.org. Co mpletion of this program can be verified by requesting the Record of Completion.

 Supporting and encouraging professional SPF contractors to seek professional certification, like that available through outside organizations, trade associations and professio nal groups

.

 Providing technical service support to customers to address their technical questions.

4. Commitment to Continuous Improvement.

To support the safe use and handling of SPF, systems house members work with customers to

address concerns related to the product and are committed to continually improving

processes. Senior leadership of the SPF business group supports processes to receive, evaluate, and communicate product safety and stewardship information about SPF and requests from value chain par ticipants.

Suggested practices might include, but are not limited to the following:

 Establishing regular communication with customers and suppliers to provide and receive feedback on SPF product safety and product stewardship.

 Having a consistent proces s in place for handling customer inquiries that outlin es how inquiries are investigated and resolved in order to promote continuous improvement.

 Making technical data sheet information on the company’s product s publicly available.5. Commitment to Educati on and Research.

Senior leadership of the SPF business group supports education and research about SPF products and processes to continually enhance their company’s understanding of the material components of their product s and the science of their applic ation and use. Systems

house m embers keep current on safety and health developments in the SPF industry.

Suggested practices might include, but are not limited to the following:

 Participating in a process individually, through trade association collaborat ion, or other programs to improve the understanding of the material components of SPF products and the science of their application and use. For example, conducting research and education about SPF either as an organization, trade association member, or th rough another

program.

 A ctively participating in CPI Spray Foam Coalition’s activities

.

 P ublicly committing to this Code of Conduct.

 Encouraging innovation through research in building sciences, new products and technologies.

6. Commitment to Report Publicl y about Commitment to the Code of Conduct.

The systems house members commit to communicate their commitment to the SPF Code of

Conduct.

Suggested practices might include, but are not limited to the following:

 Participati on in the SPF Code of Conduct prog ram is reported on the systems house member company’s and Spray Foam Coalition’s websites.

Legal Notice and Disclaimer: This Code is not intended to create constraints of any kind on the Spray Foam Coalition Systems House Members’ (“members”) commercial d ecisions regarding competitively

- sensitive topics including, but not limited to, price, discounts, or sales volume. This Code is also not intended to alter the member’s responsibility for its own safety practices and decisions. Thus, it is not a

substitu te for an individual member’s requirements, nor is it designed or intended to define or create legal rights or obligations. Each member has an independent obligation to ascertain that their actions are in compliance with their current country, federal, sta te and local laws and regulations and should consult with legal counsel concerning such matters. The Code is necessarily general in nature and members may vary their approach with respect to particular practices based on specific factual circumstances, the practicality and effectiveness of particular actions and economic and technological feasibility. The suggested practices are intended solely to stimulate thinking and provide helpful ideas on code implementation. They are in no way

meant to establish a s tandard, legal obligation or preferred option for any practice. Other approaches not described here may be just as effective or even more effective for a particular company. A member may find that one or more of these examples provide a useful approach

t hat will further its implementation efforts. If a member so chooses, it may adopt any of these examples or may modify them to fit their unique situation. It is anticipated that members will vary in their approaches as they implement the SPF Code of Condu ct, and that a “one

- size

- fits

-all” methodology is neither appropriate nor workable. In adhering to this Code of Conduct, e ach

member is encouraged to establish its own practices based on specific factual circumstances at its facilities, the practicability and effectiveness of particular actions for an individual company, and economic and technological feasibility.

Any mention of specific products, services, courses or programs in this document is for illustration purposes only and is not intended as a rec ommendation or endorsement of such products by ACC, the Center for the Polyurethanes Industry of the ACC or the Spray Foam Coalition. Items in this document may be trademarked, which may or may not be noted in this

document. Neither ACC, nor the individu al member companies of the Spray Foam Coalition or the Center for the Polyurethanes Industry of the ACC, nor any of their respective directors, officers, employees, subcontractors, consultants, or other assigns, makes any warranty or representation, either express or implied, with respect to the accuracy or completeness of the information contained in this Code; nor do the ACC, the Center for the Polyurethanes Industry of the ACC, the Spray Foam Coalition, its staff, or any member companies assume any liabi lity or responsibility for any use or misuse, or the results of such use or misuse, of any information, procedure, conclusion, opinion, product, or process disclosed in the Code. NO WARRANTIES
ARE GIVEN; ALL IMPLIED WARRANTIES OF MERCHANTABILITY OR FITNES S FOR

A PARTICULAR PURPOSE ARE EXPRESSLY EXCLUDED.

____________________________________________________________ Name (Signed)

____________________________________________________________ Name (Typed)

_________________________________________ ___________________ Title

____________________________________________________________ Company

____________________________________________________________ Date

© 201 4 American Chemistry Council

This work is protected by copyright . The American Chemistry Council, which is the owner of the copyright, hereby grants a nonexclusive royalty

- free license to reproduce and distribute this document, subject to the following limitations:

1. The American Chemistry Council assumes no responsibil ity for the accuracy, completeness, or overall quality of any alterations, abridgment, revision or other modification of this copyrighted work.

2. All copies of the work must include Legal Notice and Disclaimer.

3. Copies of the work may not be sold.Questions and Answers about the Spray Foam Coalition ’s Code of Conduct

What is the Spray Foam Coalition? The Spray Foam Coalition (SFC) supports the use of spray polyurethane (SPF) foam in U.S. building and construction applications and promotes its economic, envir onmental and societal benefits while supporting the safe manufacture, transport, and application of SPF. The SFC consists of manufacturers of SPF systems, as well as machinery and raw material suppliers. The SFC is a self

- funded part of the American Chemi stry Council’s Center for the Polyurethanes Industry and the list of members can be found here

.

What are the advantages of SPF? SPF is a spray

- applied material that is widely used to insulate buildings and seal cracks and gaps, making the building more energy efficient and comfortable. Some uses of SPF include wall insulation, roofing, sealant, insulation of tanks and vessels, and insulation of refrigerated warehouse s. SPF is applied on site by trained professional installers by combin ing two liquids to initiate a chemical reaction that creates foam insulation

.

Why did the SFC develop this Code of Conduct ? The use of SPF continues to grow and is one of the most effect ive tools to efficiently air seal and insulate buildings . The Code of Conduct further demonstrates the member companies’ commitment to the safe u s e of SPF throughout the value chain and helps provide a framework to drive the continuous improvement in

chem ical health and safety and product stewardship. This is the first commitment of its kind in the SPF industry.

What does the Code of Conduct include?

The Code of Conduct includes commitments to: leadership, communication, applicator training, continuous imp rovement, education and research, and to report publicly about their commitment to the Code of Conduct

. Agreement and adherence to this code of conduct is a requirement for membership in the Spray Foam Coalition

for members that manufacture SPF systems.

T o whom does the Code of Conduct apply?

The Code of Conduct applies to members of the Spray Foam Coalition that manufacture SPF systems. A s of February 2014 , there are 17 such members in the SFC. T his represents the vast majority of the SPF systems

houses i n the U.S. marketplace.

What if a member that manufactures SPF systems does not adhere to the Code of Conduct?

A member that manufactures SPF systems must commit to adhere to the Code of Conduct in writing. This commitment is renewed annually and the Code is reviewed by the full SFC annually as well. A member that

does not commit and adhere to the Code may not be a member of the SFC.

Where can I find more information about SPF and the Code of Conduct?

The Code of Conduct is available here

. Information about the benefits of SPF is available on www.whysprayfoam.org Guidance documents and best pract ices for using, specifying and installing SPF can be found at http://polyurethane.americanchemistry.com/Spray

- Foam

- Coalition Health and Safety Information relevant to SPF can b e found on www.spraypolyurethane.org including links to CPI’s online Chemical Health and Safety Training Program and information about the importance of using trained professional SPF installers.