UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

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 SAFETY 

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 of their commercial use, such as use in adhesives, 

sealants, foams, and coatings. The curing rates for these types of products 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 required 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) · http://www.epa.gov 

Recycled/Recyclable ·Printed with Vegetable Oil Based Inks on 100% Postconsumer. Process Chlonne Free Recycled Paper 
of the 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 of the following associated 

information, as available: 

• Product type (e.g., coating, sealant) and intended final use (e.g., floor coating). 

• The chemical composition of the 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 levels measured and used to determine re-occupancy time, the exposure limits 

used in this determination (including occupational 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 of time 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 of products or other hard and/or soft surfaces. 

• Data related 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 of the product's state. This includes data showing that 90% or some 

other percentage of diisocyanates have reacted after a certain amount of time. 

• Data related to the formation and identity of byproducts, 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 of quantification, sampling times and strategy, 

and other experimental parameters used to measure isocyanates and spreadsheets or tables of the 

raw data. 

If you 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. 

If you 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 CFR 2.203(a), 41 FR 36902 (September 1, 1976). All responses that contain 
information claimed as CBI must be clearly marked as such. Persons submitting information, any 

portion of which 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. If you 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 information that you consider to be CBI 

or otherwise protected through regulations.gov or via email. 

Please send your response to one of the following addresses: 

By U.S. Mail: 

U.S. Environmental Protection Agency 

Leslie Cronkhite, (7405M) 

Chemical Control Division 

Office of Pollution Prevention and Toxics 

Office of Chemical Safety and Pollution 

Prevention 

1200 Pennsylvania Avenue, N.W. 

Washington, DC 20460 

For CBI sent by U.S. Mail: 

U.S. EPA 

Office of Pollution Prevention and Toxics 

Document Control Office (7 407M) 

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 Prevention and Toxics 

Office of Chemical Safety and Pollution 

Prevention 

EPA East 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 of the needed information. Since EPA will be considering using its legal 

authorities to require submission if necessary, the standard for any determination of eligibility 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 of the information requested and if you 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