PFA Position Paper on Proposed EPA TDI New Use Regulation
Trade Association Takes Position on Proposed EPA TDI New Use Regulation:
No Risk of Exposure to TDI From Cured Flexible Polyurethane Foam Products.
Polyurethane Foam Association document cites scientific studies, research journals and government agencies to clarify proposed EPA Significant New Use Rule
(Loudon, TENN, January 23, 2015) – In an effort to clarify the U.S. Environmental Protection Agency’s (EPA) recently proposed Significant New Use Rule (SNUR), the Polyurethane Foam Association (PFA) has prepared a position paper that explains why there is no risk of exposure to Toluene Diisocyanate (TDI) to consumers using finished products that may contain flexible polyurethane foam (FPF) such as mattresses, upholstered furniture, pillows, and car seats.
Robert Luedeka, PFA executive director explains, “The recent EPA proposal to regulate new uses for TDI in consumer products may be confusing to some readers. While TDI is used as a basic raw material in the manufacture of flexible polyurethane foam (FPF), the TDI raw material is reacted in the foaming process, becoming a harmless polymer. After foam has been produced, including a cure cycle, numerous tests show that there is no remaining TDI available for possible exposure. While the EPA document clearly states that cured polyurethane foam products are not expected to provide opportunity for exposure, the language in the document may be confusing and should be clarified for those who are not familiar with polyurethane foam production and foam products.”
“Part of the confusion may come from the fact that there are many types of polyurethane products. Some polyurethanes, such as certain glues, adhesives and coatings, may involve “2-part” components that are mixed and chemically reacted when used by consumers. Some of these component parts may contain raw diisocyanates. Use of TDI in 2-part consumer products is rare, as TDI is a known irritant and there are reports of some people developing asthma-like symptoms as a result of exposure. Special precautions are needed where there is potential for TDI exposure. However, the type of soft, flexible, polyurethane foam used to cushion mattresses, furniture and car seats is an entirely different type of polyurethane product. In this application, there are no raw materials available in cured foam products and no potential for contact with TDI,” Luedeka emphasized.
To provide an easy-to-understand reference, PFA has developed a position paper, “What Regulators Need to Know,” summarizing scientific research, along with a chart which explains the important differences between three families of polyurethane foam products.
To read the complete position paper, visit www.pfa.org/issues.