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A coalition of spray polyurethane foam manufacturers has reiterated its position that there is currently no alternative to unreacted methylene diphenyl diisocyanate (MDI ) chemicals
.
The SPF Manufacturers Coalition, organized by the American Chemistry Council (ACC), is responding to comments from advocacy groups and DTSC questioning the simplified analysis of alternatives the coalition submitted to the state's Safer Consumer Products Project last August.
appropriateness
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Ultimately, the alliance expanded on its interpretation in previous AA reports, but insisted that there was no commercial alternative to the polymeric MDI used in spray polyurethane foam formulations
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Consumer and environmental advocacy groups have urged spray urethane foam manufacturers to conduct stronger analyses, or have asked the DTSC to begin regulating spray urethane foam containing unreacted MDI after initially submitting an analysis of industry alternatives
.
The Natural Resources Defense Council commented that its own research "provides a comprehensive and accessible compendium of alternative, safer products
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In December 2019, the state agency directed the coalition to respond to concerns from all sides
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"The reported material fulfills some, but not all, of MDI-polymerized polyurethane spray foam insulation functions," the alliance said in its May 1 reply
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The coalition said it revised the redacted report to "expand existing discussions on why non-spray polyurethane foam products are not suitable alternatives
.
Future regulatory action?
Future regulatory action?The American Chemistry Council also discussed potential regulatory actions that DTSC could take in the event of a simplified analysis of alternatives
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Under the Safer Consumer Products Program, the department has the power to implement regulations after an analysis of alternatives is completed
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The plan requires manufacturers to at least inform consumers and research potential alternatives
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Manufacturers will include information on their websites and on product labels, or make them available to consumers at the point of sale for certain low-pressure spray polyurethane foam product portfolios, the American Chemistry Council said
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The coalition also said the spray polyurethane foam industry could complete a "mutually acceptable project" with the American Chemistry Council to research safer alternatives within a year of the DTSC's approval of the short report
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When DTSC deems action necessary, it can choose from a range of regulatory measures, ranging from supplemental information to use restrictions or sales bans
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The division has made spray polyurethane foam systems with unreacted MDI a priority product, effective July 1, 2018
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The ACC petitioned the country twice for the name, but lost both
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This is now being challenged in state court
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A hearing in the case is scheduled for June 26
.