ACC: Spray Foam Coalition responds to California DTSC’s notice on SPF Abridged AA Report

The California Department of Toxic Substances Control (DTSC) on 30 June 2020 issued a “notice of deficiency” on the Abridged Alternative Analysis Report on Two-component Low- and High-pressure Spray Polyurethane Foam Systems Containing Unreacted Methylene Diphenyl Diisocyanates (MDI).

The American Chemistry Council (ACC) issued the following statement in response, which may be attributed to Lee Salamone, Senior Director, ACC Center for the Polyurethanes Industry (CPI).

“ACC is disappointed by DTSC’s decision to issue a ‘notice of deficiency’ on the Abridged Alternative Analysis Report (the Report). The Report concludes that there are no technically or economically feasible alternatives to spray polyurethane foam (SPF) systems containing unreacted MDI — a position that the industry has maintained since this process started in 2014. It is important to note that a ‘notice of deficiency’ represents another step in the regulatory process and is not a final decision on the safety of SPF or on the Report. Accordingly, the ACC Spray Foam Coalition (SFC) will coordinate with regulated entities as they revise their company-specific reports and resubmit for consideration. Californians can continue to rely on SPF to meet their energy efficiency needs.

“Health and safety are top priorities for the SPF industry. SPF insulation is well-studied and is subject to robust regulatory controls and stewardship programs. It is an effective and proven building material with a 40-year track record of success when installed by a trained professional contractor.

“SPF insulation offers exceptional thermal insulation and air sealing performance. California is a leader in climate policy and should promote SPF as one solution to climate change. Using SPF to insulate and air seal buildings can help California meet its energy efficiency and climate change goals, as well as move the state forward on its strategic plan for zero net energy buildings.”