WASHINGTON—The U.S. Environmental Protection Agency has issued action plans for two common polyurethane feedstocks, to regulate and possibly phase out their use in uncured form in spray polyurethane foam, adhesives and other products.
The action plans won't directly affect manufacturers of flexible polyurethane foam and finished polyurethane products, in whose goods the two chemicals are always cured and therefore completely safe to use. However, the documents are written vaguely enough that they could cause those manufacturers some trouble, according to polyurethane industry representatives.
Announced April 13, the EPA's action plans on methylene diphenyl diisocyanate and toluene diisocyanate are part of the agency's ongoing efforts to enhance the existing chemicals program under the Toxic Substances Control Act, according to EPA documents.
Diisocyanates react with polyols to create polyurethane polymers. They have been shown to cause severe dermal reactions, eye irritation, asthma and lung damage in workers who are repeatedly exposed to them in their uncured state, according to the EPA.
Do-it-yourselfers are increasing their use of spray polyurethane foams and sealants to make their homes more energy-efficient, and those homeowners may unwittingly be exposing themselves to diisocyanate-related risks, the agency said in an April 13 press release.
Based on its own review of hazard and exposure information from industry and elsewhere, the EPA plans to initiate rulemaking under the Toxic Substances Control Act for a Significant New Use Rule. The EPA said it will designate the use of uncured TDI and its related polyisocyanates in a consumer product as a new use requiring prior notice to the agency.
If public comments on the proposed rule indicate that uncured TDI continues to be used in consumer products, the EPA will work with industry to develop a voluntary phase-out within one year, the agency said.
If no agreement is reached, the EPA will consider rulemaking under the Toxic Substance Control Act to require exposure monitoring studies of TDI and its related polyisocyanates in consumer products.
As for uncured MDI, the EPA plans to issue a data call-in under act to determine if there are allegations of significant adverse effects, the agency said. It will also initiate and rulemaking for one-time reporting of relevant unpublished health and safety studies for uncured MDI.
Also, the EPA will consider initiating a test rule to require exposure monitoring studies on uncured MDI and its related polyisocyanates in consumer products.
In addition to issuing its action plans on uncured TDI and MDI, the EPA has posted fact sheets on spray polyurethane foam and its potential health effects on its website.
The EPA readily acknowledges that the flexible polyurethane foam mattresses and cushions manufactured by members of the Polyurethane Foam Association don't contain uncured TDI or MDI and aren't the target of the agency's action plans. But that doesn't mean the action plans aren't a concern to the PFA and its members, according to Robert Luedeka, PFA executive director.
“Their intent was not to affect us in any way, but the documents aren't written well enough,” Luedeka said.
“From a consumer standpoint, I don't know what people will make of it,” he said. “Flexible polyurethane foam is a cured product, but I don't know if people understand that.”
In any case, the PFA has read through the action plans and intends to file comments to the EPA docket, according to Luedeka. The agency has given interested parties until May 2012 to comment, he said.