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"
As a leading voice for the spray polyurethane foam industry, the Spray Polyurethane Foam Alliance (SPFA) is aware of, and disappointed, by the March 13, 2014 announcement by the California Department of Toxic Substances Control (DTSC) regarding the Department’s draft regulation on the use of spray polyurethane foam (SPF) insulation and roofing.
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.