americanchemistry.com®

 700 Second St., NE | Washington, DC 20002 | (202) 249.7000 

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. 

Washington, DC 20460 

Dear Ms. Cleland-Hamnett:

The Spray Foam Coalition (SFC) of the American Chemistry Council’s Center for the 

Polyurethanes Industry (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)

industry.

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 effective tools to efficiently 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 SPF 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 in the Spray Foam Coalition 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, EPA
 

Spray Foam Coalition Code of Conduct

Members of the American Chemistry Council (“ACC”) Center for the Polyurethanes 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”).1This 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 

that 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 all 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 through 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 

active participation and communication concerning product safety and product 

stewardship. 

 Senior leadership of the SPF business group designating 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 reviewing performance with senior 

leadership of the SPF business group.

 

1 Not all 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 foundation 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 information 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 contractors 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. Completion 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 

professional 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 participants. 

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 process in place for handling customer inquiries that outlines how 

inquiries are investigated and resolved in order to promote continuous improvement.

 Making technical data sheet information on the company’s products publicly available.
5. Commitment to Education 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 products and the science of their application and use. Systems 

house members 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 collaboration, 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 through another 

program.

 Actively participating in CPI Spray Foam Coalition’s activities.

 Publicly committing to this Code of Conduct.

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

technologies. 

6. Commitment to Report Publicly 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:

 Participation in the SPF Code of Conduct program 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 decisions 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 

substitute 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, state 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 standard, 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 

that 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 Conduct, and that a “one-size-fits-
all” methodology is neither appropriate nor workable. In adhering to this Code of Conduct, each 

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 recommendation 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 individual 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 liability 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 FITNESS FOR 

A PARTICULAR PURPOSE ARE EXPRESSLY EXCLUDED.

____________________________________________________________

Name (Signed)

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Name (Typed)

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Title

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Company

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Date

© 2014 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 responsibility 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, environmental 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 Chemistry 

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 warehouses. SPF is applied on site by trained 

professional installers by combining 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 effective tools to efficiently air seal and insulate

buildings. The Code of Conduct further demonstrates the member companies’ commitment to the safe use of 

SPF throughout the value chain and helps provide a framework to drive the continuous improvement in 

chemical 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 

improvement, 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. 

To whom does the Code of Conduct apply?

The Code of Conduct applies to members of the Spray Foam Coalition that manufacture SPF systems. As of 

February 2014, there are 17 such members in the SFC. This represents the vast majority of the SPF systems 

houses in 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 practices 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 be 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.