On April  13 the U.S. EPA published  chemical action plans for methylene diphenyl diisocyanate (MDI) and toluene diisocyanate (TDI).  Both plans highlight EPA’s concern with the release of “uncured” diisocyante and the potential health effects to consumers and self-employed workers.  Included among the categories of products the agency identified as having the potential to expose consumers to uncured material were adhesives, coatings, spray foams and sealants.

In both plans EPA expresses initial interest in gathering information on studies related to consumer exposure to uncured diisocyanates for either compound.  With regard to TDI, the agency took the action a step further with the expressed intention of  initiating a rulemaking under Section 5(a)(2) of the Toxic Substances Control Act (TSCA) that would require filing a significant new use rule (SNUR) for any new or existing consumer product releasing uncured TDI and its related polyisocyanates. If SNURs are filed indicating ongoing uses of uncured TDI in consumer products, EPA expressed its intention to work with industry to develop a voluntary phase-out of such uses within one year.

ASC has begun organizing member companies to develop response to both plans and will be work with a coalition of other associations to assist in providing any information requested by the agency.

US EPA TDI CAP Plan - April 2012

US EPA MDI CAP Plan - April 2012

MDI & TDI Executive Briefing - April 2012

EPA MDI CAP Web Page
http://www.epa.gov/oppt/existingchemicals/pubs/actionplans/mdi.html

EPA TDI Chemical Action Plan
http://www.epa.gov/oppt/existingchemicals/pubs/actionplans/tdi.html

TOLUENE DIISOCYANATE (TDI)

ALERT! ASC alert announcing CPI MDI/TDI webinar on August 26 addressing TSCA Sections 8 (c ) and 8(d).

August 26th CPI Slide presentation detailing requirements of TSCA Sections 8(c) and 8(d) and relationship to MDI-TDI CAP Plan.

ALERT! ASC alert announcing Environment Canada to Hold Webinar on Next Phase of Chemicals Management Plan.

For further information on the Government Relations issues, please contact Mark Collatz, ASC's Director of Government Relations, at (301) 986-9700 ext. 112.