WF Taylor letter

W.F. Taylor Executive Summary on Isocyanates in Urethane Flooring Adhesives U.S. EPA Methylene Diphenyl Dissocyanate (MDI) and Related Compounds Action Plan of April 2011 [RIN 2070-ZA15]

February 2012 Published by W.F. Taylor Co., Inc. 11545 Pacific Avenue, Fontana, CA 92337 (951) 360-6677 Fax: (951) 360-1177 Email: technical@wftaylor.com Mr. Robert Ddamulira Mr. Gary Liddington

Copyright Š 2012 W.F. Taylor Co., Inc. All rights reserved. No part of this executive summary may be reproduced in any form or by any means without written permission

U.S. EPA Methylene Diphenyl Dissocyanate (MDI) and Related Compounds Action Plan of April 2011 [RIN 2070-ZA15]

W.F. Taylor Executive Summary February 28th, 2012

W.F. Taylor Co. has a well-documented history of giving as much emphasis in our adhesive product development to the safety and health of our customers as to the performance excellence of our products. Indeed Taylor is the leader in creating high performance, non-hazardous products for the flooring adhesive industry. It is to this concern for the safety of our customers as well as the protection of the environment that we prepared this summary of the U.S. EPA Action Plan on Methylene Diphenyl Diissocyantes (MDI) (U.S. Environmental Protection Agency (EPA), 2011), a compound found in urethane adhesives.

Urethane adhesives are in wide use in the flooring installation industry, and are found in many stores targeting independent and general contractors as well as the DIY market segment. Of primary concern are the urethane wood flooring installation adhesives sold in these stores. It is a well-known and documented fact that these urethane wood adhesives utilize diisocyanate compounds in the curing process of their adhesives. Quoting the Overview section of the EPA Action Plan “Diisocyanates are well known dermal (skin contact) and inhalation sensitizers in the workplace and have been documented to cause asthma, lung damage, and in severe cases, fatal reactions.”

The EPA Action Plan cites grave concerns in the Consumer/General Population Exposure section regarding the exposure of this population to diisocyanates. “Unlike workers who are protected by workplace regulations and, in most cases, have access to hazard information and training for working with diisocyanates, most consumers are unaware of the potential hazards of consumer products containing uncured MDI. Consequently, incorrect use because of insufficient and inadequate hazard communication may lead to increased consumer exposure. Even if consumers are aware of the hazards, they may not take appropriate precautions. The European Union assumed that “the systematic use of PPE (personal protection equipment) by the consumer will be unlikely.” (ECB, 2005).

Concerns for potential consumer exposure to MDI-containing products ultimately resulted in a regulation requiring the inclusion of appropriate gloves and precautionary statements in consumer products containing MDI (European Union, 2009).

The EPA Action Plan Overview further states that “The Action Plan focuses on the potential health effects that may result from exposures to the consumer or self-employed worker while using products containing uncured (unreacted) dissocyanates (e.g., spray applied foam sealants, adhesives, and coatings) or incidental exposures to the general population while such products are used on or around buildings including homes or schools.”

The Scope of Review of the Action Plan points out that “Diisocyanates are potent dermal and lung sensitizers and a major cause of work-related asthma worldwide.”

The Scope of Review furthers defines that “Readily available consumer products such as adhesives (including glues) and sealants also contain diisocyanates that are not completely reacted when applied and can provide potential exposures.”

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U.S. EPA Methylene Diphenyl Dissocyanate (MDI) and Related Compounds Action Plan of April 2011 [RIN 2070-ZA15]

W.F. Taylor Executive Summary February 28th, 2012

It is well recognized that in our cost conscious economy, many consumers have turned to doing their repairs or remodels themselves instead of hiring professional contractors. This is the essence of the “Big Box” stores. The EPA Action Plan also recognizes this fact in their Uses and Substitutes Summary when they state “Consumer use of adhesives and sealants is a growth sector as noted by an industry overview of this sector in late 2009. This growth reflects increasing numbers of DIY energy-conscious homeowners doing more of their home renovation and repair work on order to save money, as well as from craftsmen and consumers generally continuing to use adhesives.”

Of additional grave concern is the exposure of members of the DIY consumer’s family to the danger of dissocyanates. This is particularly true with regards to children. To cite the Consumer/General Population Exposure section of the EPA Action Plan, “Children exposed to the same airborne concentrations of MDI as adults may receive a larger dose because they breathe more per pound body weight and per unit respiratory surface area. Additionally, children may be more highly exposed to environmental toxicants through dermal routes than adults. For instance, children may crawl, roll or sit on surfaces treated with chemicals (i.e. carpet and floors) and play with objects such as toys where residues may settle.”

“Children with asthma are an especially vulnerable population for exposure; they are more susceptible to inflammatory narrowing of the airways, which results in a proportionally greater obstruction of the smaller respiratory system.”

Based upon these very real concerns by the EPA about the diisocyanate exposure potential to the end user and ancillary personnel, we offer the following recommendations.

1. Since there are much safer alternative technologies such as modified silane (MS) chemistry and flooring adhesive products already offered in the marketplace, a move to these alternative, isocyanate free products should be made immediately. These alternative flooring products have been in wide use throughout the world for over thirty years.

2. Stronger legislation should be enacted to limit or eliminate the use of isocyanate containing flooring adhesive products.

3. The U.S. Green Building Council should eliminate the use of isocyanate containing flooring adhesives from their LEED certified buildings.

It should be recognized that investigations on exposure to certain chemicals, such as this EPA Action Plan for MDI and Related Compounds, can and often do result in the establishment of severe financial penalties for infractions. In the case of products containing diisocyanates, prudent action now to eliminate their purchase and use could save substantial penalties later.

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U.S. EPA Methylene Diphenyl Dissocyanate (MDI) and Related Compounds Action Plan of April 2011 [RIN 2070-ZA15]

W.F. Taylor Executive Summary February 28th, 2012

Bibliography U.S. Environmental Protection Agency (EPA). (2011). Methylene Diphenol Diisocyanate (MDI) and Related Compounds Action Plan [RIN 2070-ZA15]. Washington DC: U.S. Environmental Protection Agency (EPA).

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