EPA's Chemical Action Plans (CAP) for MDI and TDI

摘要

In April 2011, the U.S. Environmental Protection Agency (EPA) released two chemical action plans (CAPs), one for MDI and one for TDI. Although not a regulatory action, the EPA has issued a number of action plans to outline potential regulatory and other actions that it is considering with respect to certain chemicals. The EPA's action plans for MDI and TDI express a particular interest in consumer products that may contain "uncured" MDI or TDI. These consumer products include glues, sealants and spray foam insulation, to which consumers may be exposed. This is in stark contrast to other fully cured consumer products made with polyurethanes, such as bowling balls and mattresses. While the action plans signify a new approach taken by the EPA with respect to only a handful of chemicals, the plans suggest a variety of potential approaches intended by the agency to prevent potential consumer exposure to diisocyanates from uncured polyurethane products. Some of the EPA's approaches could include voluntary agreements or programs within the industry. These programs may include requests for data from the industry and/or exposure monitoring and testing required by regulation and/or regulated product labeling. Whichever approach is taken, it will impact makers of polyurethanes and products that contain polyurethane. This paper will describe the EPA CAP and the American Chemistry Council's (ACC) engagement with respect to the CAP.