UN ITE D STATES ENVIRONMENTAL PROTE CTION AGENC Y WASHINGTON , D

. C

. 20460

Monica Karamagi Huntsman Insulation Marketing Manager Americas Polyurethanes 10003 Woodloch Forest Drive The Woodlands, TX 773 80
Dear Ms. Karamagi, 

## SEP 19 2012 OFFICE OF CHEMICAL SAF ETY ANO POLLUTION PREVENTION

In April 2011, EPA published action plans for methylene diphenyl diisocyanates (MDI), toluene diisocyanates (TDI), and related compounds (see http: //www.epa.gov/oppt/existingchemicals/pubs/ecactionpln.hcml ). On May 23, 2012, the Interagency Testing Committee (ITC) added 69 diisocyanates and related compounds to its Priority Testing List to provide a more comprehensive approach to assessing hazard and exposure information for diisocyanates and related compounds (see http:/ /v.rww.gpo.gov/fdsys/pkg/FR

-2012-05-23/pdf/2012-12493 .pdf ).
For the pw-poses of carrying out the Toxic Substances Control Act (TSCA), EPA is requesting information from your company relating to curing rates for polyurethane products intended to further react and thus undergo "curing" as part oftheir commercial use, such as use in adhesives , sealants, foams, and coatings

. The curing rates for these types ofproducts can affect the exposure potential for the chemicals used in these products or substances that may be formed as reaction products. We intend to use the submitted curing data as part of a quantitative exposure assessment. Specifically, EPA is requesting the following information related to MDI and TDI, as well as aliphatics , such as hexamethylene diisocyanate (HDI): 1. The curing time requ ired to chemically react all diisocyanate functional groups. 2. The amount oftime required, prior to and after a product has fully cured, to safely re-occupy or use an area where diisocyanates have been reacted (including expected exposures to diisocyanates, other formulation additives, and/or reaction products formed).
As presented in publicly available literature, MSDSs, and technical data sheets (TDS), EPA recognizes that there are varied interpretations of what "curing" means, such as definitions that incorporate performance and mechanical strength features. In the Action Plans , the Agency described curing as a completed chemical reaction when all

Internet Address (URL ) · h ttp: // www.epa .g ov Recycled/Recyclable ·Pri nted with Vegetab l e Oil Based In ks on 100% Postco n sumer. Proces s Ch l onne Free Recycled Paperofthe initially free-N=C=O groups are bound within a polymer network. For this request, the term curing refers to the process that begins when monomers and/or reactants are initially combined and react until all available isocyanate groups fully react forming a final "fully cured" product. In a fully cured product no uncured (unreacted) isocyanate functional groups should be present. Thus, the curing time would be the time it takes to reach this fully cured state.
For the studies, memos, unpublished data, or any other documents in your possession relating to curing time and re-occupancy identified above, please provide all ofthe following associated information, as avail able:

• Product type 

### (e.g., coating, sealant) and intended final use 

### (e.g

., floor coating). • The chemical composition ofthe formulated products. • Sensitivity analysis and associated supporting data showing variation in curing based on environmental conditions and other factors that influence curing such as ventilation rates, temperature, humidity, catalysts/reactants present, proportioning/mixing , application site· (indoors or outdoors) , quantity of product used, application method, and square footage covered

. • Methods and test data that show how the factors identified above influence specific curing times associated with each commercial/consumer product. • The chemical le vels measured and used to determine re-occupancy time, the exposure limits used 

### in this determination (including occupat ional and general population limits), and the environmental conditions associated with this determination

. Airborne concentrations of all diisocyanates and other chemicals that were measured and their respective concentrations over the duration oftime required for full cure, including at full cure. • Qualitative data (e .g. , surface wipe sampling) over time that indicate whether unreacted diisocyanates were present on the surface ofproducts or other hard and/or soft surfaces. • Data rela ted to all the stages before full cure as defined in this letter, outlined in MSDSs and TDSs as "tack free ," " cuttable," "expansion time," "light traffic," or "ready for use," including a description ofthe product's state. This includes data showing that 90% or some other percentage ofdiisocyanates have reacted after a certain amount oftime

. • Data related to the formation and identity ofbyproducts, particularly substances that continue to off-gas over time.
For studies that include data collection, please provide the laboratory analytical methods, instruments used for data collection/measurement, including all quality assurance /quality control measures, levels of detection or preferable levels ofquantification, sampling times and strategy, and other experimental parameters used to measure isocyanates and spreadsheets or tables of the raw data. 

### Ifyou have previously provided information to EPA regarding the information identified in this request, please send a list of the information by the title and date it was submitted to the Agency to the addresses provided below. 

### Ifyou claim data provided 

### in response to this request as Confidential Business Information (CBI), it will be handled 

### in accordance with EPA confidentiality regulations at 40 CFR Part 2 , Subpart B

. See 40 C FR 2.203(a), 41 FR 36902 (September 1, 1976). All responses that containinformation claimed as CBI must be clearly marked as such. Persons submitting information, any portion ofwhich they believe is entitled to treatment as CBI by EPA , must assert a business confidentiality claim 

### in accordance with 40 CFR 2.203(b) for each such portion. This 

### claim must be made at the time that the information is submitted to EPA. 

### Ifyou do not assert a confidentiality claim at the time of submission, the information may be made available to the public by EPA without further notice. CBI should be submitted by mail to one of the CBIspecific addresses provided below. Please do not submit informa tion that you con sider to be CBI or otherwise protected through regulations.gov or via email.
Please send your re sponse to one ofthe following addresses: By U.S. Mail: U.S. Environmental Protection Agency Leslie Cronkhite, (7405M) Chemical Control Division Office of Pollution Prevention and Toxics Office ofChemical Safety and Pollution Prevention 1200 Pennsylvania Avenue , N.W. Washington, DC 20460

For CBI sent by 

### U. S. Mail: U.S. EPA Office ofPollut ion Prevent i on and Toxics Document Control Office (7407M) Docket# EPA-HQ-OPPT-2011-0489 1200 Pennsylvania Ave. , N.W. Washington, DC 20460 By Courier: U.S. Environmental Protection Agency Leslie Cronkhite, (7405M) Chemical Control Division Office of Pollution Preventio n and Toxics Office of Chemical Safety and Pollution Prevention EPA E ast Building 1201 Constitution A venue, NW MC: 7401M Room 3166 Washington DC 20004
For CBI sent by courier: U

. S. EPA Office of Pollution Prevention and Toxics Confidential Business Information Center (CBIC) Docket# EPA

-HQ-OPPT-2011-0489 EPA East Building, Room 6428 1201**Constitutio~** Ave. Washington, DC 20004
EPA is requesting that you provide this information voluntarily; however, to the extent that EPA does not receive sufficient data in response to this letter, EPA will be exploring legal alternatives to compel submission ofthe needed information. Since EPA will be considering using its legal authorities to require submission ifnecessary , the standard for any determination ofeligibility for confidential treatment will be that which applies to information that has been submitted pursuant to a requirement by EPA. By submitting information in response to this letter, you are agreeing to this standard.
Please provide the information within sixty (60) days of receipt of this request. Additionally, EPA requests that within fifteen (15) days of receipt of this request, you provide notice as to whether or not you will submit all of the information requested. Please notify Katherine Sleasman (sleasman.katherine@,epa.gov or (202) 564

- 7716) whether you will submit all ofthe information requested and ifyou require assistance 

### in interpreting this request.

### Thank you 

### in advance for your cooperation.

# S(Dy~**0~.Jl-** Wendy Cleland-Harnnett, Director Office of Pollution Prevention and Toxics