Programs Related to Spray Polyurethane Foam
Spray polyurethane foam (SPF) contains methylene diphenyl diisocyanate (monomeric MDI) and MDI-based polyisocyanates called polymeric MDI (pMDI). EPA has a number of programs that address isocyanates, including MDI and pMDI:
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- Toxic Substances Control Act (TSCA) Existing Chemicals Action Plan
On April 13, 2011, EPA released action plans to address the potential health risks of methylene diphenyl diisocyanate (MDI) and related compounds, which are used in spray polyurethane foam (SPF). Read more about these and other action plans to enhance EPA's chemical management program. The plans identify a range of actions the agency is considering under the authority of the Toxic Substances Control Act (TSCA).
- ENERGY STAR® Program
EPA is currently revising requirements for insulation manufacturers to participate in ENERGY STAR®.
- Spray foam manufacturers will need to provide:
- Clear and specific safe installation practices and personal protective equipment listed on containers.
- Specific information on chemical reactants.
- Cure times and safe re-entry times after installation.
- MSDS for chemical reactants with complete hazard information listed.
- All products must be 3rd party certified for R-values and flame/smoke spread.
- Spray foam manufacturers will need to provide:
- TSCA Section 8(e)
Toxic Substances Control Act (TSCA) Section 8(e) requires U.S. chemical manufacturers, importers, processors, and distributors to notify the EPA immediately after obtaining information on any of their chemical substances or mixtures that reasonably supports the conclusion that such substance or mixture presents a substantial risk of injury to health or the environment. Section 8(e) notices should be submitted within 30 calendar days after obtaining information that a substance or mixture presents a substantial risk.
EPA has received numerous 8(e) Notices and FYI Submissions from industry for isocyanates and other SPF compounds, though the chemical identities in many submissions are claimed as confidential business information.
- TSCA New Chemicals Program
Under the TSCA New Chemicals program, the Agency developed an Isocyanate Chemical Category profile, which contains health and safety information and recommended engineering controls and personal protective equipment to reduce inhalation and dermal exposure to isocyanates.
- Chemical Data Reporting (CDR) Rule (formerly Inventory Update Reporting)
The aim of the Chemical Data Reporting (CDR) program is to collect the highest quality screening-level, exposure-related information and to make that information available to EPA and to the public to the extent possible, (depending on the company’s data confidentiality claims). The CDR data are used to support risk screening, assessment, priority setting and management activities.
Find out more information on the following isocyanates listed in the non-confidential 2012 CDR Records in ChemView. Enter the chemical name or CAS#, select an output, then hit the “generate results” button.
Isocyanate compounds Chemical Name CAS Number Benzene, 1,1'-methylenebis[4-isocyanato- (MDI) 101-68-8 Isocyanic acid, polymethylenepolyphenylene ester (pMDI) 9016-87-9 Benzene, 1,1'-methylenebis[isocyanato- (MDI) 26447-40-5 Benzene, 1-isocyanato-2-[(4-isocyanatophenyl)methyl]- (MDI) 5873-54-1
- Design for the Environment (DfE) Automotive Refinishing Partnership
The DfE Automotive Refinishing Partnership has worked closely with businesses and career/technical schools to increase awareness of the health impacts associated with isocyanates and promote safer and more efficient practices and technologies. Best practices protect workers, students, and surrounding communities from isocyanates and other toxic chemicals. The draft report, entitled "Isocyanates Profile: Auto Refinishing Industry” discusses the use of isocyanates in the automotive refinishing industry.
- Flame Retardants Used in Flexible Polyurethane Foam
- Integrated Risk Information System (IRIS)
IRIS is a compilation of electronic reports on specific substances found in the environment and their potential to cause human health effects, and is intended for use by those without extensive training in toxicology, but with some knowledge of health sciences. Methylene diphenyl diisocyanate (monomeric MDI) and polymeric MDI (pMDI) (CAS# 101-68-8, 9016-87-9) has a report in IRIS.
The EPA IRIS Reference Concentration for Chronic Inhalation Exposure (RfC) for MDI is 0.6 micrograms per cubic meter or 0.0006 milligrams per cubic meter (mg/m3). EPA defines the RfC as an estimate (with uncertainty spanning perhaps an order of magnitude) of a continuous inhalation exposure to the human population (including sensitive subgroups) that is likely to be without an appreciable risk of deleterious effects during a lifetime.
- Toxics Release Inventory (TRI)
TRI is a publicly available EPA database that contains information on toxic chemical releases and waste management activities reported annually by certain industries as well as federal facilities. EPA compiles the TRI data each year and makes it available through several data access tools, including the TRI Explorer and Envirofacts. TRI data on diisocyanates for 2007:
TRI data diisocyanates Chemical Name Total On-site Disposal or Other Releases Total Off-site Disposal or Other Releases Total On- and Off-site Disposal or Other Releases DIISOCYANATES 675,956 796,496 1,472,453
- Risk Screening Environmental Indicators (RSEI)
RSEI, a computer-based screening tool developed by EPA, informs communities about the potential chronic health risks from industrial releases in their area by prioritizing chemicals of concern based on how hazardous they are. Diisocyanates releases and emissions from industrial facilities are reportable under TRI. Diisocyanates rank among the most toxic chemicals listed on the Toxic Release Inventory, according to RSEI analysis.
- Clean Air Act (CAA)
Four isocyanates are regulated as part of EPA’s list of 187 hazardous air pollutants (HAPs) under the Clean Air Act (CAA), including 4,4'-methylenediphenyl diisocyanate (MDI) (CAS No. 101-68-8). Under the CAA, EPA has the authority to develop technology-based national emissions standards (NESHAPs) to limit the release of specified HAPs from specific industrial sectors. EPA’s Technology Transfer Network Air Toxics website provides data on hazardous air pollutants that are known or suspected to cause serious health effects.
- National Institute for Occupational Safety and Health (NIOSH)
NIOSH has been working to prevent exposure to isocyanates as a critical step in eliminating it as an occupational health hazard. In 1996, NIOSH issued an Alert, Preventing Asthma and Death from Diisocyanate Exposure, summarizing seven reports of disease and deaths of either single individuals or of several workers following occupational exposure to diisocyanates.
NIOSH considers SPF insulation application to have similar hazards to other spray polyurethane applications with it calling for the same safety procedures and personal protective equipment as detailed in their 2006 Alert Preventing Asthma and Death from MDI Exposure During Spray-on Truck Bed Liner and Related Applications. Issued in September 2006, the Alert summarizes four case reports: one death and several incidents of asthma or other respiratory disease following exposure to methylenebis(phenylisocyanate) (MDI) during spray-on truck bed liner operations.
Numerous studies have documented that on average 5 to 15 percent of those who work with diisocyanates develop occupational asthma. In January 2008, NIOSH followed up the 2006 Alert with a poster, called “Got Everything Covered?,” that provides helpful tips on protecting workers from the hazards of isocyanate exposure during spray-on truck bed liner and related applications, such as SPF operations.
The NIOSH recommended exposure limit (REL) for methylene bisphenyl isocyanate (MDI) [0.05 mg/m3 (0.005 parts per million) as an 8-10 hour time weighted average] is intended to prevent acute and chronic health effects including irritation and sensitization of workers. However, the NIOSH REL is not intended to prevent health effects in workers who are already sensitized. There is no recognized safe level of exposure for sensitized individuals, whether it is in the workplace or other settings where exposures may occur. This is of concern because of the increased use of diisocyanates in industrial as well as consumer products.
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- Occupational Safety and Health Administration (OSHA)
The OSHA hazard communication standard (29 CFR 1910.1200) requires employers to develop a written hazard communication program to inform workers about the hazards and identities of all chemicals used in the workplace. The program must also address the measures needed to protect workers against adverse effects from the use, handling, and potential exposure to chemicals in the workplace. Learn more about hazard communication:
- OSHA Hazard Communication 2012 Final Rule and Appendices
- OSHA Hazard Communication Standard Pictograms and Hazards
- OSHA Brief of Hazard Communication Standard: Labels and Pictograms
- OSHA Brief of Hazard Communication Standard: Safety Data Sheets
- OSHA’s Hazard Communication Safety and Health Topics Website
OSHA's Respiratory Protection Standard (29 CFR 1910.134) seeks to protect workers against insufficient oxygen, harmful dusts, mists, , vapors, sprays, among other hazards, which may cause cancer, lung impairment, other diseases, or death.
OSHA's Personal Protective Equipment standards (29 CFR Subpart I) requires the use of personal protective equipment (PPE) to reduce employee exposure to hazards when engineering and administrative controls are not feasible or effective in reducing these exposures to acceptable levels and requires that, if PPE is to be used, a PPE program should be implemented.
OSHA requires engineering controls to be used whenever feasible to reduce exposures to isoycanates, which is the major component of SPF. To control chemical exposures, ventilation and containment practices should be considered. Work in "permit-required" confined spaces as defined by OSHA, which may include work in attics and crawl spaces, requires entry procedures, including an entry permit, and training for the workers.
OSHA's flammable and combustible liquids standard (29 CFR 1910.106) and OSHA’s spray finishing using flammable and combustible materials standard (29 CFR 1910.107) provide protective standards for prevention of fire-related injuries when working with flammable and combustible hazardous materials, including spray applications, in the workplace.
OSHA regulates workplace exposures of MDI. The enforceable permissible exposure limit for MDI is 0.2 mg/m3 as a ceiling limit (0.02 parts per million). The OSHA safety and health topics isocyanates page provides information on health effects and background to final rules and official letters of interpretation of the standards.
- Consumer Product Safety Commission (CPSC)
In 1992, CPSC issued the Chronic Hazard Guidelines intended to assist manufacturers in complying with the Federal Hazardous Substances Act.
The Chronic Hazard Guidelines provides guidance on:
- Determining toxicity (e.g., carcinogenicity, neurotoxicity, bioavailability)
- Acceptable Daily Intake (threshold for uptake into body)
- Assessing exposure
- Risk assessment approaches and acceptable risk
If home or building occupants have concerns that they may be exposed to residual SPF chemicals, potential off-gassing, or continue to smell odors, they should contact their contractor to ensure proper procedures and clean-up were followed. If their concerns are not resolved, affected parties should contact their local or state consumer protection office or contractors' licensing board. Consumers can also file an online Consumer Product Incident Report with the U.S. Consumer Product Safety Commission on the SaferProducts.gov website.
- Department of Energy (DOE)
The U.S. Department of Energy's (DOE's) Guidelines for Home Energy Professionals project fosters the growth of a high-quality residential energy upgrade industry and a skilled and credentialed workforce. EPA has a related document titled Healthy Indoor Environment Protocols for Home Energy Retrofits.
Toxnet links to numerous databases of the National Library of Medicine on toxicology, hazardous chemicals, environmental health, toxic releases and chemical databases and other information resources, including:
- Household Products Database contains health and safety information on a wide range of consumer products, including home maintenance and other household products, searchable by chemical category and product name
- Hazardous Substances Data Bank (HSDB), a toxicology data file that contains comprehensive, peer-reviewed toxicology data for about 5,000 chemicals, including methylene diphenyl diisocyanate (101-68-8).
- California Office of Environmental Health Hazard Assessment (OEHHA)
The California Office of Environmental Health Hazard Assessment (OEHHA) adopted new and revised Reference Exposure Levels (RELs) for toluene diisocyanate (TDI) and methylene diphenyl diisocyanate (MDI) Exit for use in the Air Toxics Hot Spots program. RELs are airborne concentrations of a chemical that are not anticipated to result in adverse noncancer health effects for specified exposure durations in the general population, including sensitive subpopulations.
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- European Union (EU)
In 2005, Belgium completed, on behalf of the European Union, a risk assessment report on methylenediphenyl diisocyanate (MDI) isomers and mixtures (PDF) (234 pp., 1.20 MB) (see p. 197 in particular). The risk assessment identifies risks to human health for both workers and consumers and the need for risk reduction measures that will ensure protection of workers and consumers from eye, skin, and respiratory tract irritation, respiratory and skin sensitization and lung effects induced by short-term repeated exposure. In the case of workers, the risk assessment assumes that in many scenarios engineering controls and use of personal protective equipment (PPE) will be used and will contribute to risk reduction. According to the risk assessment, similar assumptions cannot be made for consumer uses of MDI. The Risk Assessment also concluded that there was inadequate evidence of carcinogenicity in humans and limited evidence in experimental animals.
The EU Commission adopted amendments to Marketing and Use Directive (76/769/EEC) (PDF) (4 pp., 144 KB) on December 16, 2008, to address concerns about the use of MDI-containing consumer products that were raised in the EU Risk Assessment Report. The MDI marketing and use directive lead to Commission Regulation which amended Annex XVII of REACH (PDF) (25 pp., 835 KB,) to add a specific restriction of certain consumer uses of MDI (see #56 in Column 1). Effective December 27, 2010, all consumer products [manufactured and imported] into the EU containing concentrations of 0.1 percent or more MDI must include protective gloves which comply with certain EU safety requirements and specific warnings and use instructions.
The EU Registration, Evaluation, Authorization and Restriction of Chemical substances (REACH), went into effect in June 2007 and calls for the registration of all chemicals manufactured and imported into the EU market in quantities of one metric ton or more per year. Registration of chemicals already in commerce will be phased in over a period of 11 years and will involve an estimated 30,000 existing chemical substances. Under REACH, chemical risk assessments are conducted by manufacturers and importers, and chemical registrations are reported to the EU. This EU chemical regulation affects all global supply chains that produce and use chemicals, including U.S. exporters. Registration dossiers for chemicals produced in quantities of over 1,000 metric tons per year were required no later than November 30, 2010.
In a separate activity, as a result of a recommendation from the Technical Committee for Classification and Labelling, the EU Commission adopted amendments to its classification and labeling regulations for MDI. The European Commission, in Commission Directive 2008/58/EC, added a "limited evidence of carcinogencity" designation to its existing classification and labeling requirements for MDI, on August 21, 2008. This designation is based on limited evidence of carcinogenicity in animal studies only. Note that in conjunction with REACH, the EU also revised its classification and labeling requirements to align them with the United Nations Globally Harmonized System (GHS) . As part of Commission Regulation (EC) 790/2009 (PDF) (439 pp., 8.42 MB), the EU provided both the new (p. 32) and the old (p. 260) classification and labeling requirements for MDI. The new requirements are effective December 1, 2010.
- Organization for Economic Cooperation and Development (OECD)
Under the auspices of the OECD, the United States and other member countries have agreed to cooperatively investigate high production volume (HPV) chemicals by sponsoring the completion of screening information data sets (SIDS) for use in initial hazard assessments of the chemicals. A SIDS Initial Assessment Profile (SIAP) was prepared in November 2003 for a category of 4 MDI isomers. The SIAP recommended the MDI category for further work because of the human health concerns for local effects after repeated inhalation, irritation and sensitization.
Canada’s Occupational Health and Safety Act has regulations governing the exposure of workers to designated substances, including isocyanates, setting workplace air exposure limits.
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- SPFA Professional Certification Program
SPFA Professional Certification Program advocates best practices and safety in the installation of SPF insulation and roofing, providing a contractor international ISO-17024 standard compliant certification. Within each track (insulation or roofing) are four levels: assistant, installer, master installer, and project manager. Each level requires passage of an extensive written exam before the candidate can move on to a higher level of certification.
- Free basic online health and safety training
Free basic online health and safety training for weatherization professionals, SPF applicators and assistants who work with low pressure and/or high pressure SPF provides information about the use, handling and disposal of SPF, potential health hazards and control measures, including engineering controls and personal protective equipment (PPE).