ACC to Oppose DTSC's Priority Products Designation for Spray Polyurethane Foam Insulation

WASHINGTON, DC – March 29, 2017 – The California Department of Toxic Substances Control (DTSC) announced today its proposal to list spray polyurethane foam insulation (SPF) materials containing unreacted methylene diphenyl diisocyanates (MDI), a key component in SPF, as a Priority Product under the state’s Safer Consumer Products Program. The American Chemistry Council (ACC) released the following statement in response: 

“We are deeply disappointed by DTSC’s decision to propose SPF insulation containing unreacted MDI as a Priority Product. In the more than three years since SPF was first suggested for this program, industry has provided extensive data and science to DTSC that clearly illustrates SPF does not meet the minimum listing criteria set by the department’s own regulations.

“The SPF chemical/product combination is well-studied and controlled. There are already multiple effective state and federal regulatory controls in place to address risk of worker exposure to unreacted MDI, including workplace regulations enforced by the Occupational Safety and Health Administration (OSHA), the Environmental Protection Agency (EPA) and the Department of Occupational Safety and Health (Cal/OSHA). Moreover, California’s own public health monitoring program reports no incidence of workplace asthma related to SPF or MDI during the past decade. The existing controls, combined with industry’s extensive stewardship and training programs, render the DTSC program a duplicative exercise, and a poor use of taxpayer dollars.

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“California homeowners and builders can and should continue to rely on SPF products. SPF plays a valuable and essential role to help California achieve the energy efficiency and climate change goals mandated by AB 32, California’s landmark climate change legislation. As DTSC has learned from its analysis of SPF, there is no substitute for the multi-attribute performance of SPF and no drop-in alternative for MDI used in SPF systems currently available on the market.

“SPF is an effective and proven building material with a 40-year track record of success. Each year an estimated 10 percent of California homes are built with SPF insulation, resulting in an annual energy savings of up to $3.3 million. These savings mean that homes insulated with SPF could eliminate 800,000 metric tons of carbon dioxide emissions annually, the equivalent of removing 2,700 cars from California’s roads each year. 

“Health and safety are priorities for the polyurethanes industry. Our commitment toproduct stewardship and partnerships supports regulatory compliance and industry best practices. We have worked closely with the US EPA, National Institute for Occupational Safety and Health (NIOSH), OSHA and the Consumer Product Safety Commission (CPSC) for more than seven years to share data and improve the availability of information and resources for our members’ products. In that same spirit we will continue to provide fact-based evidence and science to DTSC to demonstrate that the chemical/product combination of SPF and MDI is not an appropriate selection for this program.”