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Panel: Stephen Wieroniey
Media: Brian Grossman

Spray polyurethane foam (SPF) insulation is an effective and proven building material with a 40-year track record of success. It offers exceptional thermal insulation and air sealing performance under a wide range of temperatures and plays a valuable and essential role to help California achieve the energy efficiency and climate change goals supported by Governor Jerry Brown and mandated by AB 32, SB 32 and Title 24.

The California Department of Toxic Substances Control’s (DTSC) has proposed that SPF containing unreacted MDI be nominated as a Priority Product under the Safer Consumer Products (SCP) regulation. ACC opposes DTSC’s proposal because DTSC has failed to demonstrate that SPF products present the potential for public and/or aquatic, avian, or terrestrial animal or plant organism exposure to the Candidate Chemical(s) in the product, or 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.

DTSC’s inclusion of SPF containing unreacted MDI as a Priority Product ignores the seven years of collaborative work that ACC and its member companies have conducted with the Environmental Protection Agency, National Institute for Occupational Safety and Health, Occupational Safety and Health Administration and the Consumer Product Safety Commission to share safety data and demonstrate the benefits of our products. ACC provided robust science and safety information surrounding our members’ products to DTSC, which demonstrated the important product stewardship efforts already in place. 

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