RE: California Department of Toxic Substances Control Proposed Regulation of Chemicals Utilized in Spray Polyurethane Foam "for Home and Building Insulation, Weatherizing and Sealing, and Roofing"
In March 2014 the California Department of Toxic Substance Control announced three priority product areas that the state will focus upon for potential rulemakings, intended to limit or potentially ban the use of those products in the state. Spray polyurethane foam was identified as one Priority Product area. Spray Polyurethane Foam Alliance (SPFA) contends that this decision to include SPF was misguided, an over-reach, and based upon information utilized by California Department of Toxic Substances Control (DTSC) that was less than accurate as presented. SPFA recognizes that the state is a very important driver for reducing environmental footprints of products and buildings, and increasing building energy efficiency. Customers from home and commercial building owners to homebuilders and architects demand the use of SPF to reach the ever-increasing energy codes in the state due to its superior product performance. SPF is a safe product that delivers, and any efforts to limit or ban its use will be a great detriment to the customers in the state, as well as the many small professional businesses that install SPF, and will be met with significant opposition by SPFA.
With industry best practices and the safe and effective installation of spray foam representing two core missions of the organization, SPFA has consistently, openly and transparently collaborated with the U.S. Environmental Protection Agency (EPA), the Occupational Safety and Health Administration (OSHA), and the National Institute for Occupational Safety and Health (NIOSH) in the safe use of spray foam ingredients and systems over the past half-decade. While SPFA understands and emphasizes that the recent DTSC announcement is not a ban of spray polyurethane foam (or the use of diisocyanates found in a multitude of consumer products), it considers the announcement unfortunate as it undermines the desire among California private and professional customers for a safe and effective building product that delivers on performance.
California has demanded increased energy efficiency performance of homes and buildings in a way that few products other than spray foam can deliver, and simultaneously initiated efforts to regulate the product in a way that may render its performance impotent.