California DTSC Corrects Misinformation About SPF
California DTSC Corrects Misinformation About SPF
SPFA Pleased with Corrections, but Continues to Represent Industry in the Fight to De-list the Product Completely from the Agency Process Aimed at Potential Product Regulation
The Spray Polyurethane Foam Alliance (SPFA), a leading voice representing spray polyurethane foam industry contractors, manufacturers and the complete product value chain, is pleased to announce that the California Department of Toxic Substances Control (DTSC) has completed corrections to the public documents distributed by the agency as part of the Safer Consumer Products Priority Products Initiative. Corrections completed by the DTSC include the deletion, or adjustment, of inaccurate facts about the spray polyurethane foam (SPF) product, its chemical components and safety. The SPFA, along with partner organizations representing a resolute coalition of homebuilders, building performance professionals and systems manufacturers, had previously made requests to the Department in person during a series of public workshops and in submitted letters, as part of the formal process surrounding the state’s Priority Products Initiative.
As part of the DTSC’s corrections, changes have been made to the publicly distributed Priority Product Profile for SPF, in addition to the scope of the Department’s activity. Corrections include:
-- The Department has altered the definition of "Spray Polyurethane Foam Systems", narrowing it to include only pressurized two-component systems utilized to make SPF. Additionally, the definition includes two-component systems marketed for insulation and roofing applications, however now excludes roof coatings.
-- The Department has excluded one-component spray polyurethane foam systems sold in cans from the official Scope of Products being evaluated.
-- The DTSC has removed HDI and TDI, isocyanates utilized in some elastomeric roof coatings but not in the A-side of SPF systems, from the scope of the Chemicals of Concern documentation.
-- The Department has deleted certain reference documents from the Priority Product File.
-- The DTSC revised the contentious and incorrect statement found on page 6 of the Product Profile that read "diisocyanates are the leading attributable cause of asthma in the workplace" to state "exposure to diisocyanates in the workplace can cause asthma." SPFA has long contended that California’s own CDC data (p. 104) tracking all of the sources of Occupational Asthma, indicates the incorrectness of their statement.
"The SPFA is pleased that these critical changes were completed to these public documents, as the facts put forth in the initial documents were grossly incorrect and have caused irreparable harm to our members and the building industry in the state of California," said Kurt Riesenberg, executive director of the SPFA. "However, the SPFA and its members believe that spray polyurethane foam was unjustly selected for the Safer Consumer Products Initiative because it is not a consumer product, but rather a professionally installed product, and because the information used by the DTSC in the selection process was so faulty. Furthermore, any safety concern surrounding the installation of SPF is a worker issue and is already being addressed by US OSHA under the Isocyanates National Emphasis Program. It is for these reasons that the SPFA believes it should be de-listed from the DTSC Priority Products Initiative process altogether."
Next steps in the Department’s Priority Products evaluation process include the establishment of the Final Priority Product List, an Alternatives Analysis and a Regulatory Response (which could range among a number of rules and regulations regarding the use of SPF in California). The SPFA will actively participate in the process at all stages on behalf of its member constituents and the spray polyurethane foam industry at-large.
"Our members in California continue to face unwarranted scrutiny because of the inclusion of SPF in the Priority Products Initiative and the SPFA will continue to fight to have it removed," added Riesenberg. "The process has not only damaged the business of our California members, but it has called into question the state of California’s ability to achieve its stated net-zero energy goal by 2020. Spray polyurethane foam outperforms competing building materials in energy efficiency, but is being simultaneously promoted and persecuted by two sides of the same state that needs it to achieve this aggressive energy goal."