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Please refer to attached letter.




Tip Top Roofing Comment







Please see attached documents opposing the prioritization of spray polyurethane foam systems with unreacted MDI.




Lorenz-Fine Comment Letter
Lorenz-Appendix A
Lorenz-Appendix B
Lorenz - St. Francis Square







Please see attached letter in opposition to DTSC pushing formal listing of SPF systems.




SPFA DTSC Comment J2017







Please read attached document submitted by ICAA.




ICAA Comment on Proposed Listing







Please see attached for detailed comments. We appreciate this opportunity to submit comments on behalf of the Natural Resources Defense Council (NRDC), Communications Workers of America (CWA), Californians for a Healthy And Green Economy (CHANGE), Center for Environmental Health (CEH), Environmental Working Group (EWG) and Worksafe. We have no financial interest in any of the chemicals or products that may be affected by the subject matter of these comments.
We are in strong support of the listi
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Comments from NRDC et al







The Healthy Building Network strongly supports the California Department of Toxic Substances Control decision to list Spray Polyurethane Foam (SPF) Systems With Unreacted Methylene Diphenyl Diisocyanates (MDI) as a Priority Product. Our comments in support of this decision are attached.




HBN submission on DTSC SPF as Priority Product







Comments are provided in the attached letter with attachments.




Icynene Comments
Supporting Documentation







June 6, 2014
Submitted online via CalSAFER

Comments on the Listing of Spray Polyurethane Foam (SPF) Systems with Unreacted Methylene Diphenyl Diisocyanates (MDI) as a Priority Product

BizNGO is pleased to submit comments to the California Department of Toxic Substances Control on the Listing of Spray Polyurethane Foam (SPF) Systems with Unreacted Methylene Diphenyl Diisocyanates (MDI) as a Priority Product.

BizNGO is a unique collaboration of over 650 participants from businesses, health care
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BizNGO_SPF_MDI_comments







Please see attachment




SWD Urethane Comments Re DTSC Proposal







Attached you will find the American Chemistry Council’s comments in response to DTSC’s proposed Listing Spray Polyurethane Foam Systems with Unreacted Methylene Diphenyl Diisocyanates as a Priority Product rulemaking under the Safer Consumer Products (SCP) program. Please contact me if you have any questions.




ACC Comments - DTSC Proposed Listing of MDI in SPF (R-2016-04)







Dow's comments exceed the character limit and will be attached as a PDF.

In addition, they will be emailed to:
Barbara Lee, Director, Department of Toxic Substances Control
Meredith Williams, Deputy Director, Safer Products and Workplaces Program
Karl Palmer, Chief, Safer Products and Workplaces Program




Dow SPF Product Stewardship letter to CA DTSC







Please see my attached letter regarding my OPPOSITON to DTSC’s listing of Spray Polyurethane Foam as Priority Product under SPC Program.




Rescind DTSC Listing of SPF as a Priority Product







Please find attached the North American Insulation Manufacturers Association's ("NAIMA") comments on DTSC's proposed listing of "Spray Polyurethane Foam Systems with Unreacted Methylene Diphenyl Diisocyantates as a Priority Product - DRN: R-2016-04; File No.: Z-2017-0307-02.




NAIMA Comments







Please see my attached letter regarding the DTSC's prioritization of Spray Polyurethane Foam with Unreacted MDI.





Barrier Roofing and Coatings Comment on SPF







Please see the attached document.




OHCC experiences







Please find the attached comments to DTSC opposing prioritization of spray polyurethane foam systems with unreacted MDI.





General Coatings opposition to listing of SPF with MDI







Please refer to attached letter.




BRS Roofing comment







Dear dr. Gress

The MeldpuntPURslachtoffers (http://www.meldpuntpurslachtoffers.nl/) is foundation representing victims of Spray Foam insulation in the Netherlands representing over 200 reports of health complaints after SPF installation. As a response to these complains, the Dutch government requested the industry for self-regulation resulting in guidelines similar to what is found on the EPA website, but less stringent: For instant in Holland the guideline for re-entry time is 2h instead i
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I appreciate the DTSC deeply for finally approaching the issue of isocyanates in various products. Be it sprays, coatings, foam insulation etc. there are toxic substances in these every day items. The people who use and apply these items to homes, cars, any new construction are at risk of disease if they come in contact with these substances. There are various products available on today's market now. PPG has partnered with Hybrid Coating Technologies Inc and developed isocyanate free polyuretha
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SPF coalition comments.




CBIA - SPF coalition comments







Yes, I support adding spray polyurethane foam systems containing unreacted methylene diphenyl
diisocyanates to the Priority Products list so that there can be stricter regulations around using this type of product.
These chemicals are known to be toxic to people and the environment.










Please refer to attachment.




ACC Request for CEQA NOE







Please see attachment.




GCMC Comment about citation







GCMC and Armstrong Roofing are petitioning DTSC to reconsider listing spray polyurethane foam with unreacted MDI as a Priority Product. The report states that SCP does not provide adequate documentation in support of listing SPF as required in the SCP regulations. The specific focus of the 2015 report is the use of SPF as a roofing material, which is described in detail, and questions about the types of products excluded from the definition of the Priority Product. There are also recommendati
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GCMC and Armstrong Roofing Commentary on Proposed Listing of SPF with unreacted MDI







Please refer to attached document requesting comment period extension.




Accella Request to Extend Comment Period

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