SPRAYFOAM Professional - Summer 2017 - 38

SPFA ISSUE ALERT

CALIFORNIA DTSC
ANNOUNCES NEXT
REGULATORY STAGE FOR SPF
O

n March 24, 2017 the California
Department of Toxic Substances
Control (DTSC) announced the next
phase of its Safer Consumer Products
regulations targeting Spray Polyurethane
Foam (SPF), or more specifically as the
regulation cites, Spray Polyurethane
Foam Systems with Unreacted Methylene
Diphenyl Diisocyanates, as a Priority
Product. This effort began in 2014
with three product areas listed as draft
Priority Products, and took several years
to progress.
The SPF industry comprised of SPFA,
the American Chemistry Council (ACC),
manufacturers, distributors and contractors, along with supporting industries
such as the California Homebuilders
(CBIA) expressed disappointment and
opposition to the selection of SPF from
the outset, along with the belief that
DTSC did not have proper authority,
research, or basis for the selection, and
insisted that SPF be removed from consideration. The initial findings of DTSC
were significantly flawed, and while corrections and redactions were made over
time, SPF remains the subject of this regulatory initiative. SPFA along with many
entities submitted comments during the
initial process, found here: http://www.
dtsc.ca.gov/SCP/upload/SPFA-DTSCFinal-Comments-SCP.pdf.
SPFA opposes DTSC's proposal on the
basis that DTSC has failed to demonstrate
that SPF products present the potential
for widespread and significant adverse
health impacts as required by its own
regulations. This chemical/product combination is well-studied and is already
subject to robust regulatory controls and
stewardship programs, and has been the
subject of seven years of cooperation
between the SPF industry and the U.S.
38 SPRAYFOAM PROFESSIONAL |

Summer 2017

Environmental Protection
Agency (EPA).
The next stage of this
regulation is the currently
active comment-submission
period running March 24
- May 16, 2017. This stage
would require SPF manufacturers to perform excessively costly Alternative
Assessments looking for
alternatives to MDI. In the supporting
documents for this action, DTSC does
not provide the necessary evidence that
indicates a need to force manufacturers
to search for alternatives and provides
incomplete information about the economic impact of this proposed rule.
The Department has not demonstrated that SPF products meet the
requirements for listing as they do not
present the potential for "significant or
widespread" adverse impacts. Potential
exposures to MDI during application are
brief. Worker protection requirements
exists (and are enforced) to protect applicators and those at the job
site from potential exposure.
DTSC has not presented
any evidence of increasing
asthma rates associated
with SPF in California and
the industry is not aware of
any such evidence.
Not only does the SPF
industry in California provide jobs and taxes to the
state, but SPF is critical to
the state's energy efficiency
and greenhouse gas reduction goals. SPF increases
energy efficiency, provides
cost savings on heating and
cooling bills to the state's

citizens and helps
decrease the level of
harmful carbon dioxide emissions entering
the environment.
Those who work
with SPF are trained,
skilled technicians who
take their jobs seriously.
They are proud of their
qualifications and
safety records. The health and safety of
SPF workers and consumers have always
been top priorities for the industry. There
are extensive health and safety efforts
in place for SPF products, but DTSC has
not fully considered these programs in its
proposal. Comprehensive product stewardship programs provide a wealth of
information about how to handle and
install SPF safely. Resources on safety
and personal protection for installers,
as well as best practices and training
for users of all SPF products, are readily available in English and in Spanish.
continued on page 42



Table of Contents for the Digital Edition of SPRAYFOAM Professional - Summer 2017

Sprayfoam 2017 Wrap Up
How SPF and Hvac Contractors Should Work Together
Bringing Spray Foam to Social Media
2017 SPFA Contractor Awards
California STSC Announces Next Regulatory Stage for SPF
Engaged Employees Make or Break Your Business
Ask the Expert
Executive Director’s Corner
President’s Post
Foam Business News
SPFA Today – Membership News & Numbers
Legislative Update
Calendar of Events
Index of Advertisers | Advertisers.com
SPRAYFOAM Professional - Summer 2017 - Intro
SPRAYFOAM Professional - Summer 2017 - cover1
SPRAYFOAM Professional - Summer 2017 - cover2
SPRAYFOAM Professional - Summer 2017 - 3
SPRAYFOAM Professional - Summer 2017 - 4
SPRAYFOAM Professional - Summer 2017 - 5
SPRAYFOAM Professional - Summer 2017 - 6
SPRAYFOAM Professional - Summer 2017 - Executive Director’s Corner
SPRAYFOAM Professional - Summer 2017 - 8
SPRAYFOAM Professional - Summer 2017 - President’s Post
SPRAYFOAM Professional - Summer 2017 - 10
SPRAYFOAM Professional - Summer 2017 - 11
SPRAYFOAM Professional - Summer 2017 - Foam Business News
SPRAYFOAM Professional - Summer 2017 - 13
SPRAYFOAM Professional - Summer 2017 - SPFA Today – Membership News & Numbers
SPRAYFOAM Professional - Summer 2017 - 15
SPRAYFOAM Professional - Summer 2017 - Sprayfoam 2017 Wrap Up
SPRAYFOAM Professional - Summer 2017 - 17
SPRAYFOAM Professional - Summer 2017 - 18
SPRAYFOAM Professional - Summer 2017 - 19
SPRAYFOAM Professional - Summer 2017 - Legislative Update
SPRAYFOAM Professional - Summer 2017 - 21
SPRAYFOAM Professional - Summer 2017 - 22
SPRAYFOAM Professional - Summer 2017 - 23
SPRAYFOAM Professional - Summer 2017 - How SPF and Hvac Contractors Should Work Together
SPRAYFOAM Professional - Summer 2017 - 25
SPRAYFOAM Professional - Summer 2017 - 26
SPRAYFOAM Professional - Summer 2017 - 27
SPRAYFOAM Professional - Summer 2017 - 28
SPRAYFOAM Professional - Summer 2017 - 29
SPRAYFOAM Professional - Summer 2017 - 30
SPRAYFOAM Professional - Summer 2017 - Bringing Spray Foam to Social Media
SPRAYFOAM Professional - Summer 2017 - 32
SPRAYFOAM Professional - Summer 2017 - 33
SPRAYFOAM Professional - Summer 2017 - 2017 SPFA Contractor Awards
SPRAYFOAM Professional - Summer 2017 - 35
SPRAYFOAM Professional - Summer 2017 - 36
SPRAYFOAM Professional - Summer 2017 - 37
SPRAYFOAM Professional - Summer 2017 - California STSC Announces Next Regulatory Stage for SPF
SPRAYFOAM Professional - Summer 2017 - Engaged Employees Make or Break Your Business
SPRAYFOAM Professional - Summer 2017 - 40
SPRAYFOAM Professional - Summer 2017 - Ask the Expert
SPRAYFOAM Professional - Summer 2017 - Index of Advertisers | Advertisers.com
SPRAYFOAM Professional - Summer 2017 - cover3
SPRAYFOAM Professional - Summer 2017 - cover4
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