RICHARD A. D’AUTILIO General Manager Consumer & Construction Division
March 23, 2012 Re:
EPA Chemical Action Plan
To:
All Bostik Hardwood Customers and Sales Representatives
In April 2011, the Environmental Protection Agency (“EPA”) released a Chemical Action Plan with respect to products containing a chemical substance known as “MDI” and the potential exposure to this substance by consumers and self-employed individuals. In February 2012, The American Chemistry Association hosted a meeting with EPA and various industry members in order to consider and discuss next actions to ensure consumer safety with the many products that contain MDI. Along with such other industry leaders as Bayer, BASF, and Dow, Bostik was an active participant in the February 2012 meeting, consistent with Bostik’s commitment to such matters and proactive approach to the health and safety of consumers and others who use its products. Bostik’s polyurethane wood flooring adhesive products contain extremely minimal quantities of residual MDI (0.1% to 1.0%), with very low volatility. Data Bostik has developed with an independent third party establish that these products do not result in any detectable exposure of MDI to applicators, others in the vicinity, or those present after application has been completed. Unfortunately, a competitor of Bostik, which appears just to have discovered EPA’s Plan nearly a year after its issuance, has begun an aggressive marketing campaign to attempt to exploit the Plan for commercial advantage. The competitor has issued a collection of marketing documents that misstate and mischaracterize the facts and expressly make clear the competitor’s commercial bias and motivation to ensure that “this opportunity should be worked and blitzed to its utmost.” Notably, this competitor, apparently focused on marketing, rather than safety, did not participate in the February 2012 meeting and therefore lacks even a fundamental understanding of the true facts regarding EPA’s thinking on the issues as communicated and discussed at the meeting. Nor does the competitor evince any understanding regarding the actual properties of Bostik’s products, which are demonstrably safe. If you have received and have concerns about the competitor’s strategic marketing set of documents, we would be happy to answer any questions you may have. We would specifically like to bring the following to your attention:
Bostik’s polyurethane flooring adhesive products have been used safely by many thousands of applicators and other users for the last 18 years, when Bostik first introduced these products.
Bostik’s polyurethane wood flooring adhesive products contain extremely minimal quantities of residual MDI (0.1% to 1.0%), with very low volatility.
The impressions the competitor has attempted to create notwithstanding, Bostik’s hardwood adhesives do not contain Toluene Diisocyanate (TDI), a far more volatile substance than MDI.
In conjunction with one of its raw material suppliers, Bostik performed environmental chamber tests following ASTM D5116-06 as a guide to simulate a representative flooring installation in a controlled, but realistic indoor environment. The simulation was done both at zero cure time and 24 hours after installation. The test was run at both 73 F and 100 F. The result of the testing was that no airborne monomeric MDI was detected.
The main exposure concern with monomeric MDI is through inhalation; however, monomeric MDI has very low vapor pressure and is difficult to detect at room temperature for trowel applied products, such as Bostik’s hardwood flooring adhesives. The monomeric MDI exists in the uncured product in the unopened bucket. Monomeric MDI is highly reactive with water, so once the adhesive is exposed to atmospheric moisture or moisture from the wood and subfloor, the trace amounts of MDI are further reduced and believed to be non-detectable once the adhesive cures.
The competitor has issued a purported “Executive Summary” of EPA’s April 2011 Chemical Action Plan giving the false impression that EPA is primarily concerned with polyurethane wood flooring adhesive products, such as Bostik’s. This is far from the case. EPA’s main area of concern is with products such as spray foam technologies and not on low monomer containing products such as Bostik’s hardwood flooring adhesives. EPA’s April 2011 15-page report references “foam” or “foams” 30 times. In contrast, the words “floor” or “flooring” appear in the actual Plan but six times, most in contexts that do not appear to be related to hardwood flooring adhesives, and there are no specific references in the Plan to hardwood flooring adhesives.
The competitor is urging customers to switch to its competing hardwood flooring adhesives in order to “save substantial penalties later.” There is no basis whatsoever for any concerns about such fines, and the competitor’s indications to the contrary are nothing but an unsubstantiated marketing ploy irresponsibly designed to create fear in the industry.
There is no indication that EPA intends to ban polyurethane adhesive products that contain MDI. To the contrary, at the February 15 meeting, EPA indicated that it will continue to investigate the exposure potential for MDI in products 2
(potentially through testing during actual application uses) and then will make recommendations for Best Practices around labeling for proper protection and handling during and after products are applied.
Bostik already engages in such Best Practices and takes good product stewardship and protection of users very seriously. Like other responsible manufacturers of adhesives, regardless of their chemistry, Bostik provides instructions and precautionary warnings on product labels and elsewhere on how its products can be used safely. For example, all pails of Bostik wood flooring adhesive carry the following statements, which users are advised to follow: o “Warning: Inhaling vapors harmful. May cause allergic skin reaction. Skin, eye, and throat irritant. Harmful if swallowed. See additional cautions on back panel.” o “Warning: This product is irritating to the eyes and skin. Causes respiratory tract irritation and may cause allergic skin reaction.” o “Precaution: Wash hands after handling and before eating. Use with adequate ventilation. Wear appropriate protective equipment to avoid contact with skin and eyes.”
The performance values, such as toughness, durability, and adhesion, of polyurethane adhesives and sealants are well recognized in the market, and Bostik’s products are not only demonstrably safe, as described above, but also demonstrably effective, as Bostik’s customer’s have experienced. Bostik always has our customers’ safety in mind when formulating, as well as, labeling our products, and we will continue to offer high value, high quality, and safely used products to the industry. Please feel free to contact me if you have any remaining questions or concerns. Sincerely,
Richard A. D’Autilio General Manager Bostik, Inc. Consumer & Construction Division
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