1

The views expressed in this paper are solely those of the author and do not represent the policies of the U.S. EPA. Mention of 

trade names of commercial products should not be interpreted as an endorsement by the U.S. EPA 2

These comments are those of the CPSC staff and have not been reviewed or approved by, and may not necessarily reflect the 

views of, the Commission.

Lessons Learned from the Federal Partners Workgroup on 

Spray Polyurethane Foam (SPF)

KATHERINE SLEASMAN1

U.S. Environmental Protection Agency (EPA)

1201 Constitution Ave., NW

Washington, DC 20460

MELANIE BIGGS2

Consumer Product Safety Commission (CPSC)

5 Research Place 

Rockville, MD 20850

ABSTRACT

In 2009, the Environmental Protection Agency (EPA) convened a multiagency collaboration with the Occupational Safety 

and Health Administration (OSHA), the National Institute for Occupational Safety and Health (NIOSH), and the Consumer 

Product Safety Commission (CPSC)(collectively, “the Federal Partners”) to evaluate and address potential exposures to 

isocyanates and other chemicals during installation of spray polyurethane foam (SPF) insulation and air sealants in homes 

and schools. Commercial and Do-It-Yourself (DIY) applicators, as well as building occupants, are often unaware of 

inhalation and dermal hazards. Applicators and others at the work site may not wear adequate personal protective equipment 

(PPE). Building occupants, who remain on the premises during the operations or re-enter (re-occupy) the site before the 

product is fully cured, may be at risk. For several years, the federal agencies have been working with the polyurethanes

industry to ensure accessible hazard communication, PPE, applicator, assistant, weatherization training, and best workplace 

practices to prevent exposure to isocyanates and other SPF chemicals. In addition, the Federal Partners, in collaboration with 

other organizations, have identified critical information gaps and research needs to assess and measure exposures during use 

and curing of SPF products. This paper will discuss the progress of the SPF workgroup efforts to work with industry to 

establish best practices and encourage research on exposure to the chemicals emitted during and after the application of SPF. 

INTRODUCTION/BACKGROUND

Spray polyurethane foam (SPF) insulation used in homes, schools, and other public buildings is a potential source of 

exposure to a complex and varied mixture of chemical substances. SPF is formed by a chemical reaction of two component 

parts, commonly referred to as Side A and Side B. Side A contains methylene diphenyl isocyanate (MDI), consisting of 

monomeric MDI, as well as higher molecular weight oligomers; and Side B contains polyols and a mixture of other 

chemicals, including catalysts, flame retardants, blowing agents, and surfactants. Polyurethane polymers are formed by 

reacting di- or polyisocyanates with polyols. Depending on the polyurethane product being produced, the polyol side 

includes a complex proprietary formulation of polyols, flame retardants, surfactants, cross-linking agents, chain extenders, 

catalysts, blowing agents, pigments, fillers, or other ingredients [1]. These chemicals may continue to emit at different rates 

after application, depending on the extent of the reactions, and may lead to adverse health effects if re-occupancy occurs 

before the product is fully cured. SPF ingredients are recognized as presenting respiratory hazards in the workplace, and 

when SPF insulation and sealants are applied on-site in a home or school, those same concerns could apply to other trade 

workers and consumers [2].The magnitude and extent of exposures to SPF emissions is also highly variable and depends on 

many factors, such as formulation, environmental conditions, and method of application. Thus, exposures to chemicals 

emitted from SPF through vapors, aerosols, particulates, and dust, during and after product application, are possible both 

short and long term. Over the past several years, to address potential exposure to workers and consumers, the Federal 

Partnership and each of its member agencies, including EPA, CPSC, OSHA, and NIOSH have achieved many of the 

workgroup’s goals in supporting exposure reduction to various chemicals in SPF.
ENVIRONMENTAL PROTECTION AGENCY (EPA)

EPA’s mission is to protect workers and consumers from the risks associated with chemicals under the authority of the 

Toxic Substance Control Act (TSCA). The law’s goal is to ensure that chemicals sold and used in the United States do not 

pose an unreasonable risk to human health and the environment. The law covers production and distribution of commercial

and industrial chemicals. TSCA allows EPA to establish reporting, record keeping, testing, and control-related requirements

for new and existing chemicals. Under this law’s authority, EPA published an Action Plan on isocyanates in 2011, continues

to review isocyanates through the New Chemicals’ program, and requested information from the polyurethane industry on 

the “curing” of polyurethane products. EPA also relies on the authority of the Pollution Prevention Act (PPA) to focus

industry, government, and public attention on cost-effective changes in production, operation, and raw materials use. Source 

reduction promotes practices that reduce the generation and use of hazardous substances before recycling, treatment, or 

disposal. EPA and the Federal Partners have continued to work with industry to develop best practices for application of 

SPF, and the Office of Research and Development (ORD) has been developing methods to measure emissions of 

isocyanates and other chemicals from SPF as part of the ASTM Indoor Air Subcommittee D.22.05 on Spray Polyurethane 

Foam (SPF) Insulation. Furthermore, under the authority of the Clean Air Act (CAA) and TSCA, EPA reviews and approves 

the blowing agents used in SPF. EPA also initiated voluntary programs under the CAA for insulation materials. 

EPA’s New and Existing Chemicals Program

Under EPA’s New Chemicals Program, EPA groups chemicals with shared chemical and toxicological properties into 

categories for premanufacture notice (PMN) reviews to facilitate the risk assessment decision process. EPA categories 

include isocyanates, aldehydes, amines, and anionic surfactants. EPA considers all PMNs, including substances that fall 

within such categories, on a case-by-case basis, by examining structural and physical-chemical properties and the Structure 

Activity Relationship (SAR) to support concerns for health or environmental effects [3]. For any new chemical substance, if 

EPA determines, under TSCA section 5(e), that the substance “may present an unreasonable risk of injury to health or the 

environment,” the PMN substance can be subjected to appropriate control actions and/or testing. This “may present” finding 

is developed through the application of category-based and/or case-by-case assessment of hazard endpoints and exposure 

assessments. For example, under the New Chemicals Program, the isocyanates’ structure and health hazards are welldefined to use for assessment by the Agency. Isocyanates are defined as any molecular structure containing two or more 

isocyanate groups R-(N=C=O). Members of the class include new isocyanate monomers, as well as new oligomers, 

polymers, prepolymers, or reaction products of existing isocyanate monomers. Most new chemical isocyanates of concern 

are polymers or oligomers containing well-known diisocyanate monomers, such as toluene diisocyanate (TDI) or 4,4'-MDI,

because they are potential dermal and respiratory sensitizers and can cause pulmonary toxicity [4]. 

As described under the category, an industrial hygiene (IH) and safety program should be followed to protect workers in 

workplaces where individuals handle isocyanates, coatings, or other formulations. Important components of this program 

should include: hazard communication and training on safe handling practices; use of efficient and well-maintained 

application equipment, engineering controls and PPE; and housekeeping procedures, including spill-prevention and cleanup 

practices. There should also be means to measure airborne levels of polyisocyanates and isocyanates. During spray 

applications, workers should take precautions to avoid breathing vapors, mists, or aerosols [4]. For example, In2015, EPA 

issued a Significant New Use Rule (SNUR) under the New Chemicals Program to mitigate worker and consumer exposures

to isocyanates. This rule outlines that any use of isocyanates in a consumer product must be reviewed by the New Chemicals 

Program, workers must have respiratory protection where they are “reasonably likely to be exposed” via inhalation routes, 

and any use involving an application method that generates a vapor, mist, or aerosol must be reviewed through the New 

Chemicals Program [5]. 

Under EPA’s Existing Chemicals Program, EPA addressed its concerns regarding these compounds in the Action Plans on 

MDI, TDI, and related compounds, published in 2011. The Action Plans list a variety of regulatory and risk management 

actions the Agency could consider under TSCA sections 4, 5, and 6 to collect information and mitigate risks associated with 

isocyanates. The Action Plans were based on EPA’s initial review of readily available use, exposure, and hazard information 

on isocyanates. EPA considered which of the various authorities provided under TSCA and other statutes might be 

appropriate to address potential concerns with isocyanates. The Action Plans described the courses of action the Agency 

planned to pursue in the near term to address its concerns. They did not constitute a final Agency determination or other 

final Agency action. Regulatory proceedings indicated by the Action Plan included appropriate opportunities for public and 

stakeholder input [2]. As a result of the Action Plans, EPA proposed a SNUR for TDI and related isocyanates in 2015,

designed to mitigate consumer exposures [6]. 
Additionally, under EPA’s Existing Chemicals program, in September 2012, EPA requested information, from nine 

domestic manufacturers and processors of polyurethane chemicals, related to curing rates for polyurethane products 

intended to react further, and thus, undergo "curing" as part of their commercial use, such as use in adhesives, sealants, 

foams, coatings, and SPF. The curing rates for these types of products can affect the exposure potential for chemicals that 

may be formed as reaction products. Specifically, EPA requested information related to isocyanates. EPA wanted to know 

the curing time required to chemically react all isocyanate functional groups and the amount of time required, before and 

after a product has fully cured, to reoccupy a structure safely where these products have been used. This request included

expected exposures to isocyanates, other formulation additives, and/or reaction products formed. In response to this request 

on curing, EPA received IH studies, proprietary information on formulations, and a risk assessment related to re-occupancy. 

However, despite the information assembled, uncertainty remains around curing time, the identification of other chemicals 

that may be emitted from SPF during and after curing, and the consumer re-occupancy. For data received specific to SPF, 

chamber study results were submitted that tested for only a limited set of volatile organic compounds (VOCs) based on the 

California 01350 standard and ASTM Standard Guide D 5116-06 [7]. Emission testing regarding when the consumer could 

reoccupy the structure was rarely addressed in manufacturer’s responses. Additionally, there was only one human health risk 

assessment specific to consumers regarding re-occupancy for consumers. This assessment based its conclusion on a limited 

set of VOCs and recommended a re-occupancy time of 2 hours for foam insulation [8 and 9]. 

EPA Best Practices

EPA maintains a robust website on SPF to help inform workers and consumers [1]. EPA developed a best practices tool kit 

to educate professional SPF applicators on potential hazards and assist them in following workplace precautions to prevent 

exposure to isocyanates and other potentially harmful chemicals. To accomplish this goal, EPA worked in partnership with 

the Federal Partners, chemical and equipment suppliers, and other interested parties to identify cost-effective practices and 

technologies. The development of technical facts sheets, case studies, and outreach materials to promote implementation of 

best health and safety practices was derived from the best practices work on automotive refinishing, which also involved 

exposure to isocyanates, as well as organic solvents, lead, and hexavalent chromium.

In 2011, EPA developed guidance on ventilation principles and design considerations for SPF applications. As advised by 

EPA, when installing SPF, proper ventilation and controls must be implemented to protect the health of workers and 

occupants. Employing ventilation techniques during application, such as using local and general ventilation systems, can 

protect the applicant’s health. Additionally, proper ventilation from efficiently supplied fresh air to the application area must 

be implemented after installation to protect the health of other trade workers and occupants from potentially harmful 

emissions of SPF chemicals (Figure 1). General exhaust ventilation systems typically consist of an exhaust fan, which pulls 

air out of the room and discharges it outdoors. General exhaust ventilation, also known as “dilution ventilation,” dilutes 

contaminated air by mixing it with cleaner room air. However, general exhaust systems are not recommended as the sole 

source of ventilation when hazardous vapors or mists are present because they do not immediately remove contaminants.

For an SPF installation, a local exhaust system would be appropriate during the application process to capture vapors, mists,

dusts, and particulates at the source because they are emitted during the spraying and trimming processes. When designing a 

ventilation system, it is important to consider these factors: (1) the work space, room, or enclosure to be exhausted; (2) the 

exhaust system, including a hood or exhaust vent, ductwork, and fan that captures contaminants at the source and transports 

them to a location outside the building away from HVAC air intakes and occupied areas; and (3) getting fresh air to the 

room or work area that replaces the exhausted air. Ventilation combined with use of PPE will result in less worker exposure 

to the SPF chemical mixture. Following application, general ventilation is appropriate to ventilate the entire work area and 

building before other workers or occupants enter the area; however, other workers entering the space may still need PPE to 

prevent exposure [10, 11, 12, and 13].
Figure 1. Diagram of air flow [1].

Carefully observing best practices and controls to prevent exposures during SPF installation in commercial or residential 

settings is paramount because application and production is occurring on site. Use of proper PPE, containment, ventilation, 

and proper clean-up practices are also important in these settings. 

Recent IH studies have incorporated EPA’s ventilation guidance and PPE requirements to analyze their effectiveness using a 

generic SPF formulation and commonly used SPF formulations [13]. Three generic formulations of SPF were created by the 

polyurethanes industry for ventilation research and to evaluate methods to support proposals and standards under

consideration by the ASTM Indoor Air Subcommittee D.22.05. The generic formulations do not belong to any one

manufacturer/formulator but have the performance characteristics of typical 0.5-pound (open-cell foam), 2-pound (closedcell foam), and two component kit SPF formulations [14]. In 2010, the ASTM D22.05 subcommittee initiated work on SPF

insulation emissions to standardize spraying and sample preparation for SPF titled, “Standard Practice for Spraying, 

Sampling, Packaging, and Test Specimen Preparation of Spray Polyurethane Foam (SPF) Insulation for Testing of 

Emissions Using Environmental Chambers (D7859).” To evaluate the impact of changes in ventilation rates on the 

concentration of SPF chemical vapor and particulates emitted during SPF application, various industry studies have been 

conducted. The studies have analyzed emissions from the chemicals in the generic formulation and commonly used 

formulation [13], including MDI; catalysts, such as dimethylethanolamine (DMEA) and N,N,N’; -

trimethylaminoethylethanolamine (TMAEEA); flame retardants, such as tris-(chloro-2-propyl) phosphate (TCPP); blowing 

agents, including 1,1,1,3,3-Pentafluoropropane (HFC-245fa); and VOCs through field sampling, spray booths, and small 

environmental chambers. Samples were taken during and after application for 4, 12, and 24 hours, to determine possible 

exposures to workers and other trades. The studies concluded that ventilation and proper PPE for the applicator, and 

possibly other trades, is vital for protection during and after application [11, 12, and 13]. 

EPA developed checklists to describe safer work practices and strategies for helping to protect workers and building 

occupants and to promote the safe use of SPF insulation. To develop the checklist, EPA conducted a comprehensive 

literature review and had a series of targeted interviews with SPF applicators, trade associations, and industry 

representatives. The self-evaluation checklist is a tool to help evaluate current practices and technologies used by 

manufacturers and processors to identify areas where they should make improvements to protect workers and 

residents/building occupants from potential exposures to isocyanates, amines, flame retardants, blowing agents, aldehydes, 

and other substances generated during SPF application. The checklist is designed to serve as a resource for manufacturers 

and processors to review, evaluate, and improve their work practices on a regular basis. Continuous improvement and 

adoption of the safer work practices identified by use of this tool will help reduce worker exposures over time [1].
Significant New Alternatives Policy (SNAP) Program 

Blowing agents used in SPF and other polyurethane products previously consisted of chlorinated volatiles, such as 

trichlorofluoromethane (CFC-11) and other CFCs (chlorinated fluorocarbons). These were commonly used until the late 

1990s when CFCs were phased out due to concerns about protecting the ozone layer and ozone depletion potential. 

Following the phase-out, EPA created the Significant New Alternatives Policy (SNAP) Program under section 612 of the 

CAA amendments. SNAP evaluates alternatives to ozone-depleting substances. Substitutes are reviewed on the basis of 

ozone depletion potential, global warming potential (GWP), toxicity, flammability, and exposure potential [15]. EPA also 

conducts a PMN review, evaluating health and environmental hazards, under Section 5 of TSCA for any substance that is 

considered a new chemical, including blowing agents [3]. As of October 2014, EPA has approved blowing agents for use in 

rigid polyurethane foam. Some of the same blowing agents are also commonly used in SPF [16], such as HFC-245fa, which 

has a GWP of 950−1020 (100-year time horizon) [17]. However, the next generation of SPF blowing agents have recently 

been approved under the SNAP program [17 and 18].

Energy Star Residential

ENERGY STAR is a voluntary program established by EPA in 1992, under the authority of the CAA. Under Section103(g) 

of the Clean Air Act, EPA is authorized to “conduct a basic engineering research and technology program to develop, 

evaluate, and demonstrate non–regulatory strategies and technologies for reducing air pollution.” In 2005, Congress enacted 

the Energy Policy Act. Section 131 of the Act amends Section 324 of the Energy Policy and Conservation Act, and 

“established at the Department of Energy and EPA a voluntary program to identify and promote energy-efficient products 

and buildings to reduce energy consumption, improve energy security, and reduce pollution through voluntary labeling or 

other forms of communication about products and buildings that meet the highest energy efficiency standards.” The 

ENERGY STAR program has encouraged the adoption of energy-efficient products, practices, and services through 

partnerships, objective measurement tools, and consumer education. Through Energy Star’s Residential Program, insulation 

materials are evaluated. EPA recently revised requirements for residential insulation manufacturers to participate in 

ENERGY STAR. As noted in the requirements, insulation manufacturers need to provide clear and specific safe installation 

practices and PPE, safe reentry (re-occupancy) times for home occupants after installation, and SDSs for chemical reactants 

with complete hazard information listed. In addition, all products must be third party certified for R-values and fire 

resistance [19].

Indoor airPLUS

EPA also created Indoor airPLUS to help builders meet the growing consumer preference for homes with improved indoor 

air quality. Indoor airPLUS builds on the foundation of EPA's ENERGY STAR requirements for new homes and provides 

additional construction specifications to provide comprehensive indoor air quality. Construction specifications include 

installation of moisture control systems, conditioning systems, combustion-venting systems, radon-resistant construction, 

and low-emitting building materials [20]. The program released its guidance document titled, “Healthy Indoor Environment 

Protocols for Home Energy Upgrades,” in 2011, to provide guidance on improving and maintaining good air quality in the 

home. The document specifically addresses best practices for worker installation of SPF to ensure good air quality in homes

[21].

CONSUMER PRODUCT SAFETY COMMISSION (CPSC)

CPSC’s mission is to protect the public from unreasonable risks of injury and death associated with the use of consumer

products. Among others, its authorities include the Consumer Product Safety Act (CPSA), Federal Hazardous Substances 

Act (FHSA), and the Consumer Product Safety Improvement Act of 2008 (CPSIA), which amended the CPSA. 

Federal Hazardous Substances Act (FHSA)

Under the FHSA (15 U.S.C. 1261), product manufacturers must determine whether their products are hazardous substances 

and if so, their products must be properly labeled. The FHSA defines a hazardous substance as a substance that is, among 

other characteristics, toxic, corrosive, or an irritant and may cause substantial illness during any reasonably foreseeable 

storage, handling, or use. Household products, including those used or stored in a garage, shed, carport, or other building 

that is part of the household, are covered. The FHSA requires hazardous substances to bear labeling that alerts consumers to 

the potential hazards that those products present and tells them what they need to do to protect themselves and their children 

from those hazards. 
Amines Study 

CPSC’s interest concerning SPF focuses on the health hazards and the synergistic and/or cumulative exposures from 

the various chemical ingredients used in SPF products. CPSC, has received 40 incident reports from homeowners 

from 2005 to the present, after SPF was installed in their home by a contractor or by themselves. These incidents 

include lingering odors in the house; respiratory-related problems (i.e., asthma, coughing); irritation (e.g., eyes, 

throat); and headaches. In some instances, residents moved out of their homes due to the severity of health effects they

reportedly experienced. Homeowners are urged to file an online Consumer Product Incident Report with CPSC on the 

Saferproducts.gov website if they are experiencing adverse health effects believed to be due to SPF insulation.

Initially, CPSC staff focused attention on the isocyanates in SPF as the chemicals potentially causing these reported 

health effects. The constituents that make up Side A have generally been considered to present the greatest possible 

health hazard due to the well-known potential of isocyanates to produce respiratory and dermal sensitization 

(isocyanates are believed to be a leading cause of work-related asthma) [22]. However, isocyanates are very reactive

and may not be available for exposure. Therefore, the odors and adverse health effects identified after SPF installation 

may not be due to the isocyanates but to the chemicals making up the Side B, such as amine catalysts. Documented 

worker exposures to airborne concentrations of amine catalysts may result in irritation of the respiratory system, skin,

and eyes. Inhalation exposure may also cause a reversible effect known as glaucopsia, “bluehaze,” or “halovision” in 

the eyes. The health effects described in owner complaints were similar to those associated with amine exposure; 

therefore, CPSC staff believed the odors identified after SPF was installed may be due to the amine catalysts in Side B.

However, exposure limits are not yet established for the majority of the amine catalysts used in SPF systems [14]. 

When SPF is applied according to the manufacturer’s instructions, the foam achieves a tack-free state within a few 

minutes of application. Depending on the characteristics of the foam, such as the composition of the Side B chemicals, 

the heat dissipated during the exothermic reaction, and ambient conditions (temperature and humidity), it can take 

additional hours or days before the foam is fully cured and the optimum physical properties of the foam are achieved

[23]. Because some of the compounds and reaction by-products (i.e., aldehydes) in SPF are expected to exist 

unreacted in the foam during this curing time (e.g., certain catalysts and blowing agents), they may potentially be 

emitted from the installed foam and cause the noted health effects.

Therefore, CPSC staff chose five amine catalysts representative of those used in SPF in the United States and assessed 

their available toxicological and exposure data. This assessment was completed to determine what health effects could 

occur from exposure to the amine catalysts present in the three generic SPF formulations developed by the ASTM 

Indoor Air Subcommittee D.22.05 mentioned above. The assessment concluded that observed consumer effects are

similar to those discussed for amine exposure in both laboratory animals and workers; and therefore, some of the

described health effects may be due to exposure to amines from SPF . However, SPF is a complex mixture of MDI or 

MDI-based isocyanates, polyols, catalysts, blowing agents, fire retardants, and/or surfactants; therefore, amines may

not be the only chemical class producing the reported adverse health effects. To determine exposure limits for 

consumers, CPSC staff suggested that industry and the Federal Partners perform exposure studies by varying exposure 

times and distances from spray sources. These results would provide additional exposure data to make determinations

of potential health effects for consumers from SPF [14]. 

Exposure Assessment Study

CPSC initiated an Interagency Agreement (IAG) with the National Institute of Standards and Testing (NIST) in 2013 to 

understand what compounds in SPF may be causing adverse health effects in consumers. The primary objectives of this 

study are to develop robust methods for testing SPF emissions and to identify and quantify the compounds released from 

SPF applied in residential settings. This IAG contributes to the development of voluntary standards in the ASTM Indoor Air 

Subcommittee D.22.05 on SPF Insulation, especially WK4029, a New Test Method for Estimating Chemical Emissions 

from Spray Polyurethane Foam (SPF) Insulation Using Micro-Scale Environmental Test Chambers [24]. This research 

found the release of a flame retardant (TCPP) from SPF that was sprayed 1.5 years ago in the NIST Net Zero Energy 

Residential Test Facility (NZERTF) [25]. These data are the first to examine emissions from SPF after prolonged curing. 

Eventually, these data and methods will aid in determining the compounds that may cause adverse health effects in 

consumers and the factors that may cause elevated releases of these compounds.
NATIONAL INSTITUTE FOR OCCUPATIONAL SAFETY AND HEALTH (NIOSH)

NIOSH’s mission is to provide leadership in conducting occupational safety and health research to prevent work-related 

illness, injury, disability, and death and developing and providing worker education and training. NIOSH led the 

development of methods for determining airborne isocyanate exposures for the total reactive isocyanate group (TRIG), the 

issuance of several Alerts on the prevention of asthma and death from diisocyanate exposure, health hazard evaluations on 

isocyanates. In addition, NIOSH collaborated with the Agency of Toxic Substances Disease Registry (ATSDR) to 

investigate community exposure to isocyanates.

DAN Method

NIOSH and the University of Massachusetts-Lowell have developed a unique analytical method that can be used to 

adequately assess the reactivity of the TRIG. Some methods measure oligomeric isocyanates in addition to diisocyanate 

monomers, even though analytical standards are not generally available for oligomeric species (NIOSH Method 5525, HSE 

Method MDHS 25/4). Individual isocyanate species in the sample produce peaks in the chromatogram, and these peaks can 

be summed to give a measure of Total Reactive Isocyanate Group (TRIG), which is the basis of the isocyanate Occupational 

Exposure Limits (OEL) in some countries [26]. In SPF products, MDI monomer is the major isocyanate species in the 

formulation. However, the fast-curing nature of the SPF means that MDI monomer and other oligomers present in the 

original isocyanate formulation are rapidly converting to intermediate isocyanate species. Established chromatographic 

methods are not suited for measurement of these intermediate species. Summation of many peaks in a chromatogram is 

labor intensive for samples containing complex isocyanate mixtures. Moreover, not all isocyanate species in a sample elute 

from the column or produce a measurable peak in the chromatogram. A sampling and analytical method based on 

derivatization with the reagent 1,8-diaminonaphthalene (DAN) is fundamentally different than conventional 

chromatographic isocyanate analysis methods [22]. Like conventional methods, isocyanate species react with DAN upon 

sampling. However, rather than analyzing this derivatized isocyanate mixture, the mixture is treated with acid to catalyze an

intramolecular cyclization that converts all DAN-derivatized isocyanate groups to a single molecule of 1H-perimidin-2(3H)-

one (perimidone). This reaction is shown in Figure 2.

NH2

NH2

N

NH2

H

N

H

H

N

+

R NH2 +

acid

DAN

perimidone

R

N

C

O

C O

C

O

N

H

Step 1 R

Step 2

Figure 2 Reaction of DAN with isocyanates to yield the analyte perimidone

The DAN method has been shown to measure isocyanate groups accurately in aromatic isocyanate products (MDI- and TDIbased products) [27]. The method is particularly suitable for measuring isocyanates in SPF because of the rapid curing of 

this material and the generation of intermediate isocyanate species. In a simulated spray of SPF insulation, side-by-side air 

sampling using NIOSH Method 5525 impingers and DAN impingers found approximately tenfold higher TRIG levels with 

the DAN impinger [28]. Future investigation with the DAN method will include measurement of residual isocyanates on 

surfaces and in dust, the distinction between extractable isocyanate and chemically bound isocyanate, and the extent/rate of 

curing of SPF.
NIOSH Alerts on Isocyanates 

A NIOSH Alert in 1996, described seven cases of isocyanate exposure, which revealed potentially serious respiratory 

diseases after exposures to isocyanates involving spray painting, spills, foam operation, application of roofing foam, wood 

product manufacturing, and coal mining. The Alert is intended to reduce the potential for exposed workers due to the 

adverse health effects. These case studies show the examples of isocyanate-induced asthma, respiratory disease, and death.

The incidents resulting in death were attributed to worker exposures. One death was attributed to exposure to two 

component polyurethane paint with TDI. The other death was a result of prolonged and chronic exposure to MDI while 

working in a foam operation facility that manufactured artificial plants, with poor ventilation. In another incident, two police 

officers developed asthma-like symptoms after a truck carrying TDI spilled on a highway. Evidence of occupational asthma 

was also reported in spray painting operations and in wood products manufacturing. Furthermore, coal miners were exposed 

to MDI in rock glues resulting from improper application and were using air-purifying respirators as opposed to supplied-air 

respirators, which resulted in respiratory disease. In an incident involving SPF application to a school roof, school staff was

exposed to isocyanates resulting in asthmatic reactions.

As a result of the reported incidents, NIOSH recommends product substitution to less hazardous materials, closed systems 

and ventilation to minimize exposure; worker isolation to inhibit other trades from entering the work area; and wearing PPE. 

However, as recommended by NIOSH, respiratory protection should not be used as the primary source of exposure 

reduction to isocyanates, and only the most protective respirators should be worn for potent sensitizers and carcinogens,

such as a self-contained breathing apparatus. Any respiratory program should also adhere to NIOSH and OSHA 

requirements, which include training and medical surveillance; fit testing; environmental monitoring; maintenance and 

inspection; proper storage; and written operating procedures. Any potential worker exposure to isocyanates must be 

communicated to the worker through labeling and training on the SDS. In addition, medical monitoring and incident 

reporting of isocyanate worker exposure should also be established [29].

NIOSH also published an Alert in 2006 on the use of spray application of isocyanates for truck-bed liners. The Alert 

concluded that isocyanates can cause contact dermatitis, skin and respiratory tract irritation, immune sensitization, and 

asthma [30].

Health Hazard Evaluations (HHE)

NIOSH’s Health Hazard Evaluations (HHE) are conducted to learn whether workers are exposed to hazardous substances

based on requests from workers. For an HHE, NIOSH conducts an investigation or refers the incident to a more appropriate 

agency. During the investigation, NIOSH will first discuss the worker exposure situation with the employee or employer 

and, if necessary, perform a site visit. The site may include a tour of the workplace, interviews, medical testing, or record 

review of exposure and health of the workers. Then, NIOSH will draft a written report of its findings and recommendations 

that the employer is required to distribute to its employees [31]. In 2003, a HHE spray foam application for isocyanates was 

published from a request by the United Union of Roofers, Waterproofers and Allied Workers in Philadelphia, PA. The 

request involved employee exposures to MDI during the spray application of polyurethane foam, and exposures to VOCs 

during a rubber roofing membrane installation and spray gun cleaning. Employees had reported respiratory symptoms, such 

as difficulty breathing, coughing, chest tightness, and skin irritation. NIOSH investigators concluded that a health hazard 

existed from exposure to MDI during the polyurethane foam application, and recommendations were provided to reduce 

exposures to roofers during the spraying of MDI-containing foam, including use of PPE [32]. 

Biomonitoring and Fence line Exposure to Isocyanates 

In the mid-1990s, ATSDR, NIOSH, and the North Carolina Department of Health and Human Services conducted an 

investigation into community exposure to TDI near a manufacturing facility using polyurethanes. The study evaluated 

whether residents near the facility had increased asthma, antibodies specific to TDI, and whether there were detectable TDI 

levels in the air. However, even though the residents living near the facility had higher rates for asthma than the residents

living farther away from the facility it was not statistically significant, and symptom prevalence varied between the two 

communities. This may warrant further investigation into nonoccupational exposure to understand why community 

exposures were not notably different. The study also revealed the lack of biomarkers for isocyanates. Of the more than 300 

participants that provided blood samples, only one had a specific antibody for TDI. For other isocyanates, MDI and HDI 

were prevalent in both communities. This suggests isocyanate exposure from other sources, such as SPF or other 

polyurethane products[33]. 
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA)

OSHA’s mission is in the development of safety and health standards, the enforcement of standards, assistance to States, and 

providing research, training, education, and information. OSHA oversees that employers meet their responsibilities for 

hazard communications, worker training, and the use of appropriate engineering and/or administrative controls, and PPE, 

when necessary. SDSs are a critical aspect of hazard communication. OSHA recognizes that there may be current 

deficiencies and inconsistencies in SDS preparation and use. OSHA published the Hazard Communication Standard (HCS 

2012) on March 26, 2012. The HCS 2012 aligned with the provisions of the United Nations’ Globally Harmonized System 

of Classification and Labeling of Chemicals (GHS). OSHA also initiated a National Emphasis Program (NEP) in 2013, to 

identify and reduce or eliminate the incidence of adverse health effects associated with occupational exposure to 

isocyanates, and developed a website on green jobs.

Green Jobs

OSHA launched an interactive website on Green Jobs; “green jobs” are broadly defined by OSHA as jobs that help the 

environment. One of the key green job workforce areas is weatherizing, insulating, and sealing, which are an important part 

of energy efficiency and conservation programs. There are various types of weatherizing, insulating, and sealing products that 

include blow-in and spray-on applications. However, the application or installation of these products may require a certain amount 

of training to apply these materials to product specifications and to achieve proper weatherization. The materials used in these 

types of applications can include, but are not limited to: blow-in, fiberglass and cellulose; spray-on, SPF, spray polystyrene, and 

spray latex sealant. The OSHA site guides users through an understanding that although weatherization applications and materials 

have some benefits, all weatherization applications and materials have some hazards. The hazard information and solutions 

common to all these applications and materials include: confined spaces, falls, electrical, medical and first aid, ventilation, proper 

PPE and respiratory protection [34]. 

OSHA National Emphasis Program (NEP) and Hazard Communication 

The Isocyanates NEP was developed in 2013 to focus OSHA resources on the workplace health issue of occupational 

exposure to isocyanates. The NEP combines enforcement and outreach efforts to raise awareness of employers, workers, and 

safety and health professionals of the serious health effects associated with occupational exposure to isocyanates. Workers 

in a wide range of industries are exposed to isocyanates known to be associated with work-related asthma. Isocyanate 

exposure could result from activities involving painting, blowing foam insulation, and the manufacture and thermal 

degradation of many polyurethane products, such as polyurethane foam, insulation materials, surface coatings, car seats, 

furniture, foam mattresses, under-carpet padding, packaging materials, shoes, laminated fabrics, polyurethane rubber, and 

adhesives. The NEP began in June 2013, and will expire in June 2016; and during the course of the program, OSHA will 

randomly choose sites for inspections that target multiple polyurethane industries with a focus on general industry, 

maritime, and construction based on information from NIOSH’s HHEs, sampling data, known overexposures, and worker 

compensation data. Sites may also be selected based on a complaint, referral, or where potential worker exposure to 

isocyanates is suspected. OSHA will evaluate inhalation, dermal, and other routes of occupational exposure to isocyanates,

using the established permissible exposure limits (PELs), recommended exposure limits (RELs) by NIOSH, or OELs by the 

American Conference of Industrial Hygienists (ACGIH). During the inspection, OSHA will collect air and wipe samples, 

request the site’s hazard communication program, and assess PPE. This instruction supersedes all Regional and Local 

Emphasis Programs specifically addressing occupational exposure to isocyanates [35].

In 2012, OSHA revised their HCS to align with the GHS. The revision to HCS provides a coherent approach to classifying 

chemicals and communicating hazard information on labels and SDS [36]. The standard classifies the potential hazards of 

chemicals and requires that employers communicate information concerning hazards and appropriate protective measures to 

employees, including developing and maintaining a written hazard communication program for the workplace, which

includes lists of hazardous chemicals present; labeling of containers of chemicals in the workplace; labeling containers of 

chemicals being shipped to other workplaces; preparation and distribution of SDS to employees and downstream employers; 

and development and implementation of employee training programs regarding hazards of chemicals and protective 

measures. As a result of the new GHS requirements, the Center for Polyurethane Industry (CPI) and the Spray Polyurethane 

Foam Alliance (SPFA) developed a guidance document titled, “General Hazard Communication Guidance for Spray 

Polyurethane Foam (SPF) Insulation Application.” The guide serves as an outline for manufacturers and processors to 

considerto develop a hazard communication program to comply with 29 CFR 1910.1200 [37.
COLLABORATION BETWEEN THE FEDERAL PARTNERS AND INDUSTRY 

Since the creation of the Federal Partnership, the workgroup has identified the critical research needs to assess and measure 

exposure. These needs have been explored through the International Isocyanates & Health Conference and in the ASTM 

D22.05 Committee’s Symposium on SPF insulation. 

International Isocyanates & Health Conference 

An international conference on isocyanates and health was held in April 2013, where academics, industry, federal agencies, 

worker representatives, clinicians, and others convened to answer questions about whether there are health effectsrelated to 

isocyanate exposure? How can isocyanate occupational exposures be measured and reduced, especially among workers in 

less-regulated, often small-scale enterprises in the United States and around the world? Can consumers also experience 

health effects from exposures to various household and do-it-yourself products? 

The conference included plenary overviews and discussions, along with oral and poster presentations. The specific research 

findings covered six thematic areas:

• Worker and consumer exposure issues;

• Toxicity testing, animal models, and biomarkers;

• Human cancer risk;

• Environmental exposure and monitoring;

• Respiratory epidemiology and disease; and

• Occupational health surveillance and management.

The identification of these themes and research priorities was derived from discussions with all stakeholders from meetings, 

targeted surveys, feedback from the conference’s abstract presenters and invited speakers, and peer-reviewed input. During 

each of the presentations, the current state of the science was discussed, along with knowledge gaps and research priorities 

to help understand worker and consumer exposures. For instance, under the area of worker and consumer exposures, the

major areas of research needs and priority areas were product testing and exposure characterization, hazard/risk 

communication, and prevention of exposure and disease. For toxicity, biomarkers, and cancer risks, it was demonstrated that 

there should be more research into modeling to investigate dose and routes of exposure for both animal and non-animal 

modeling, validation of biomarkers, and identification of populations at risk and mechanistic data to understand causes of 

cancer.

Improvements in environmental exposure and monitoring were also presented. A variety of research needs were discussed to 

understand worker exposure, including: air and dermal sampling; analytical methods; direct reading monitors; co-exposures 

for both respiratory and dermal contact; and measurements of degradation and emissions.

Finally, knowledge of respiratory epidemiology, disease, and occupational health surveillance were discussed, including the 

need for additional epidemiology studies on workers to understand risk, biomarkers, and health effects, improved diagnostic 

tests, and better surveillance procedures to institute workplace controls and management. As a result of the conference, it 

was recommended that a working group composed of all stakeholder groups continue to collaborate to address gaps and 

facilitate funding needs, along with the suggestion that all stakeholders continue to promote best practices [38]. 

EPA, CPSC, the National Institute for Standards Technology (NIST), and Industry – ASTM Indoor Air 

Subcommittee D.22.05 on SPF Insulation 

Since 2010, the ASTM Subcommittee D.22.05 on indoor air has been working collaboratively to create standardized 

methods for measuring chemical emissions from SPF insulation. D22.05 is focused primarily on developing methods to 

measure SPF emissions using micro- and small-scale chambers. These methods could be used for screening for emissions 

from SPF in residential or commercial buildings and for identifying the production of off-specification foam.

The final and proposed standards considered by the D22.05 subcommittee include:

• Standard Practice for Spraying, Sampling, Packaging, and Test Specimen Preparation of Spray Polyurethane Foam

(SPF) Insulation for Testing of Emissions Using Environmental Chambers (D7859);

• Test Method for Estimating Emissions of MDI from Spray Polyurethane Foam (SPF) Insulation using Emission 

Cells or Micro-Scale Environmental Test Chambers (WK43872);
• Test Method for Measuring Chemical Emissions from Spray Polyurethane Foam (SPF) Insulation Samples in a

Large-Scale Spray Booth (WK 46527);

• Test Method for Determination of Vapor-Phase Organic Compounds Emitted from Spray Polyurethane Foam

(SPF) Using Sorbent Tubes Analyzed by Thermal Desorption Gas Chromatography and Mass Spectrometry

(WK40292), and

• New Test Method for Estimating Chemical Emissions from Spray Polyurethane Foam (SPF) Insulation Using

Micro-Scale Environmental Test Chambers (WK40293)

The list of proposed and final standards represents the issues raised by the committee and the range of compounds of interest 

that include isocyanates, blowing agents, amine catalysts, flame retardants, and aldehydes. The ongoing work of ASTM 

D22.05 aims to develop consensus methods to answer fundamental questions, such as: What is emitted? What is the time 

course of emissions? What factors impact emissions and potential exposures? How useful are emission factors developed in 

micro chambers for predicting concentrations in full-scale environments? To answer some of these questions, the 

subcommittee held a symposium in April 2015. The Symposium on Developing Consensus Standards for Measuring 

Chemical Emissions from Spray Polyurethane Foam (SPF) will result in publication of Selected Technical Papers (STP) in 

2016. 

The objective of the symposium was to provide a forum for the exchange of ideas from SPF manufacturers, federal agencies, 

indoor air quality professionals, testing labs, air quality consultants, instrument vendors, and other stakeholders. The following 

mutual areas of interest to the Federal Partners, the SPF industry, and other stakeholders were the focus of this symposium,

representing a continued dialog between federal agencies and the SPF industry:

• research and method development for measuring potential SPF emissions of semi-volatile organic compounds

(SVOCs) and VOCs from SPF raw materials including isocyanates, blowing agents, amine catalysts, and flame 

retardants, and from potential reaction or byproducts that may or are anticipated to be formed;

• federal and other governmental agencies’ regulatory approaches and supporting investigation, assessment, and

research needs;

• modeling, scaling up from lab to large-scale chambers or buildings;

• international perspective on regulation and testing of SPF insulation emissions;

• industry perspective/needs and product stewardship activities;

• field investigations or large-scale chamber/spray booth studies to evaluate emissions or ventilation rates, and

• application of the knowledge from product emissions data/research to practice (e.g., stewardship commitment,

green building practices, codes for residential ventilation and global leadership).

EPA is investigating research needs and approaches for the ASTM Committee to measure MDI. EPA and CPSC, through

NIST, are investigating chamber methods used to measure chemicals in SPF, including amine catalysts and flame retardants.

CPSC, through NIST, is evaluating emissions of the flame retardant TCPP and other Side B chemicals using the generic 

formulations from high- and low-pressure foams and foams sprayed in the NIST NZERTF [24]. Eventually, these data and 

methods will aid in determining the compounds that may cause health effects in consumers and the factors that may cause 

elevated releases of these compounds [25]. EPA is evaluating approaches to identifying emissions from MDI through microsmall-, and full-scale chambers to characterize emissions over time, for up to several hundred hours post-application of SPF. 

Continued research into MDI emission will hopefully predict potential exposures in the real environment [22]. 

Industry Reviews

EPA and other Federal Partners have also engaged in SPF industry conferences and provided courtesy reviews on CPI’s and 

the Spray Polyurethane Foam Alliance’s (SPFA) fact sheets, training materials, websites, and original research. 

CONCLUSIONS

The Federal Partner’s workgroup on SPF represents a model for understanding both worker and consumer exposures to a 

complex set of chemicals used in the application of SPF. The coordination between the federal agencies and industry is 

exemplified in the recent ASTM D22.05 (Committee on Indoor Air) symposium and in the International Isocyanate 

conference. The continuing efforts made by industry to understand worker exposure should be a model on how other 

chemical industries’ exposure assessments should be conducted. However, without the continued presence of the federal 

agencies investigating exposures and requesting information from industry, this type of collaboration would not have been 

possible. Transparency and continued discussions with the federal agencies and industry is of the utmost importance to 

protect workers and consumers from the chemicals in SPF. 
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ACKNOWLEDGEMENTS

We would like to thank the Environmental Protection Agency and the Consumer Product Safety Commission for the support 

of this work and Carol Hetfield of the EPA, Robert Streicher of NIOSH, Michael Babich of CPSC, Dustin Poppendieck of 

NIST, and Janet Carter and Sven Rundman of OSHA for their review and expertise. We would also like to thank Andrea 

Pfahles-Hutchens, Charles Bevington, Kristie Eglsaer, Doug Anderson, and Mary Cushmac (retired) of the EPA for their 

continued commitment to the Federal Partners Workgroup, as well as Lynn Wilder of ATSDR, Kathy Ernst (retired) and 

Dan Almaguer of NIOSH, Dr. Dhimiter Bello of the University of Massachusetts Lowell, and Dr. Carrie Redlich of Yale

University. 
BIOGRAPHIES 

Katherine Sleasman

Katherine Sleasman works on policy issues related to a variety of chemicals including 

isocyanates, methylene chloride, trichloroethylene, and perfluorinated chemicals as well as 

substantial risk information under the Toxic Substance Control Act Section 8(e). She received her 

B.A. in Environmental Studies from the George Washington University and her M.S. in 

Environmental Studies from Florida International University in Miami. Her graduate thesis work 

focused on water quality management in the Florida Keys and was published in Ocean and 

Coastal Management and the Water Policy journal. Prior to joining the Office of Pollution 

Prevention and Toxics, she was an Oak Ridge Institute for Science and Education fellow at 

EPA’s Office of Wastewater Management. 

Melanie Biggs, Ph.D

Melanie Biggs works on chemical-related issues for various consumer products. She received 

her B.S. in Bioengineering from Western New England University, her M.S. in Toxicology from 

Northeastern University, and her Ph.D in Toxicology from the University of North Carolina. Her 

graduate thesis work focused on the mechanisms of obesity with respect to the epidermal growth 

factor and a high-fat diet. 

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