MEMORANDUM
To:
Margaret
Sheppard
From:
Lauren
Flinn,
Sarah
Percy,
Mark
Wagner
Date:
May
12,
2004
Re:
Evaluation
of
Ecomate
®
Flammability
Safety
Program
(
EPA
Contract
Number
68­
D­
00­
266,
WA
3­
04
Task
02)

Foam
Supplies,
Inc.
(
FSI)
submitted
a
request
on
April
1,
2004,
to
have
Ecomate
®
approved
for
use
as
a
blowing
agent
in
spray
foams.
Ecomate
®
has
previously
been
approved
for
all
foam
applications
except
spray
foams
because
of
its
flammability.
Therefore,
the
flammability
of
Ecomate
®
,
as
well
as
FSI's
safety
program,
outlined
in
their
report
"
Safe
Handling
Recommendations
for
Ecomate
®
spray
foam
systems,"
are
assessed
here.
It
is
recommended
that
Ecomate
®
be
approved
for
use
in
spray
foam
systems
provided
the
recommendations
included
in
the
report
are
incorporated
into
their
safety
program.

Please
contact
Mark
Wagner
at
202­
862­
1155
to
discuss.

Evaluation
of
Ecomate
®
Flammability
and
Safety
Program
FSI's
original
submission
(
4/
1/
2004)
provides
test
results
showing
that
the
concentration
of
Ecomate
®
,
which
has
an
LEL
of
45,000
ppm1,
rarely
reaches
levels
higher
than
23
ppm
during
use.
Test
results
did
show
that
two
inches
above
an
open
blending
drum,
the
concentration
of
Ecomate
®
reached
at
least
20%
of
its
LEL2,
and
could
have
reached
100%
of
its
LEL.
3
This
test
also
showed
that
six
inches
above
the
drum,
the
concentration
of
Ecomate
®
was
0%
of
the
LEL.

While
these
tests
suggest
that
the
flammability
of
Ecomate
®
will
rarely
present
a
hazard,
a
safety
plan
is
still
necessary
because
of
the
high
flammability
of
Ecomate
®
and
the
variability
of
its
use.
In
order
to
determine
if
FSI's
safety
program
for
Ecomate
®
is
sufficient,
it
was
compared
to
Exxon
Mobil
Chemical's
safety
program
for
Exxsol
®
,
a
pentane
hydrocarbon­
based
rigid
spray
foam
system
which
has
already
been
approved
by
EPA's
SNAP
program.
The
attached
table
compares
the
safety
plans
for
Ecomate
®
and
Exxsol
®
(
see
Attachment
A).
Based
upon
this
comparison,
Ecomate
®
is
recommended
for
SNAP
approval
as
spray
foam.
However,
based
upon
previous
safety
suggestions4
for
industries
that
use
hydrocarbon
blowing
agents,
the
following
improvements
to
the
safety
plan
for
Ecomate
®
are
proposed:

1
NIOSH.
Documentation
for
Immediately
Dangerous
to
Life
or
Health
Concentrations
(
IDLHs).
Available
at
http://
www.
cdc.
gov/
niosh/
idlh/
107313.
html
2
Industrial
Hygiene
Assessment
for
Foam
Supplies,
Inc.
Foam
Supplies
Inc.
SNAP
submission,
Attachment
C.
3
Personal
communication
between
Tim
Kalinowski
of
Foam
Supplies
and
Margaret
Sheppard,
EPA.
Email,
April
26,
2004.
4
ICF
2003.
Safety
training.
Memorandum
prepared
by
ICF
for
EPA
(
Attachment
B).
 
Require
labeling
of
all
containers
as
combustible.
 
Require
that
regulations
regarding
transport
of
combustible
materials
be
followed.
 
Provide
minimum
storage
room
size
and
require
use
of
gas
monitors
with
alarms
where
drums
are
stored.
 
Require
that
fire
suppression
systems
be
in
place
in
all
storage
and
work
areas.
 
Require
use
of
portable
gas
monitors
during
indoor
applications
and
during
outdoor
applications
where
areas
of
minimal
ventilation
are
present.
 
Implement
a
plan
for
clean
up
of
spills.
 
Require
use
of
classified
electrical
equipment.
 
Require
contractors
to
provide
worker
training
and
to
develop
site
specific
safety
plans.
Attachment
A
Ecomate
®
Exxsol
®
LEL
=
4.5%,
UEL
=
23%
(
1,
p.
5)
LEL
=
1.4%,
UEL
=
8.7%
(
2,
p.
3)

Proper
Labeling
 
In
most
cases,
systems
will
be
labeled
as
combustible
liquids
 
Drums
are
labeled
as
flammable
(
3)

Separate
Storage
 
Adhere
to
local
codes
for
storage
of
combustible
liquids
(
1,
p.
6)

 
Do
not
vent
drum
in
enclosed
space
(
1,
p.
6)
 
Safe
storage
required
in
a
protected
area
(
3)

 
Storage
trailer
should
be
ventilated
and
monitored
with
an
LEL
monitor
with
an
audible
alarm
(
3)

Use
of
Certified
Shippers
 
No
mention
of
transportation
rules
in
FSI's
literature,
but
they
can
be
found
in
other
manufacturers'
MSDSs
for
methyl
formate
(
4)
 
Describe
federal
regulations
that
requires
vehicles
carrying
hazardous
material
must
by
placarded
unless
is
it
carrying
less
than
1001
lbs
(
3)

Spillage
Cleanup
 
No
mention
in
FSI's
literature,
but
information
on
cleanup
can
be
found
in
other
manufacturers'
MSDSs
for
methyl
formate
(
4)
 
Spills
must
be
contained
and
cleaned
using
a
non­
combustible
absorbent
such
as
polypropylene
pads,
sand,
activated
charcoal,

or
vermiculite.
The
proper
government
authorities
may
need
to
be
notified
depending
on
the
size
of
the
spill
(
3)

Worker
Training
 
"
Safe
Handling
Recommendations
for
Ecomate
®
spray
foam
systems"
(
1)

 
Require
reading
of
the
MSDS5
and
an
OSHA
approved
safe
handling
pamphlet
(
1,
p.
6)

 
Provide
list
of
companies
where
further
safety
information
can
be
obtained
(
1,
Appendix
A,
B)
 
"
Exxsol
®
Blowing
Agents:
The
Compelling
Case
for
Pentane
Hydrocarbon­
Based
Rigid
Spray
Foam"
(
2)

 
Training
required
by
urethane
foam
system
supplier
or
distributor
prior
to
using
system
(
2,
p.
4)

 
Safety
video
(
2,
p.
4)

Adequate
Ventilation
 
Required
when
working
in
an
enclosed
space
(
1,
p.
14)

 
For
consistent
indoor
applications,
recommended
regular
air
sampling
by
a
qualified
industrial
hygienist
to
determine
proper
ventilation
type
(
1,
p.
7)

 
For
exterior
applications
identified
as
having
areas
of
potential
concern,
portable
fume
meters
may
be
utilized
but
should
not
replace
appropriate
ventilation
(
1,
p.
7)
 
Vapor
monitoring
and
positive
ventilation
in
interior
applications
essential
(
2,
p.
2)

 
Exterior
applications
generally
have
sufficient
ventilation
to
reduce
the
build
up
of
flammable
vapors,
but
vapor
concentration
at
the
work
area
should
be
monitored
(
3)

Flames
 
No
smoking
or
use
of
open
flames
around
systems
using
or
storing
Ecomate
®
(
1,
p.
6)
 
Eliminate
sources
of
ignition
by
using
classified
electrical
equipment
(
non­
sparking
motors
heaters,
switches,
safety
light
fixtures,
hoses)
and
preventing
smoking
(
3)

Grounding
 
Ground
pumps
&
drums
prior
to
placing
pump
in
drum
(
1,
p.
6)

 
Ground
before
opening
or
hooking
up
to
container
(
1,
p.
6)

 
Ground
containers
when
transferring
materials
(
1,
p.
6)
 
All
equipment
inside
trailer
and
the
trailer
itself
must
be
grounded
(
3)

 
Drums
should
be
grounded
(
3)

Fire
Suppression
 
No
mention
 
ABC
fire
extinguishers
required
by
industry
regulations
(
3)

References:

(
1)
Foam
Supplies,
Inc.
"
Safe
Handling
Recommendations
for
Ecomate
®
spray
foam
systems."

(
2)
Exxon
Mobile
Chemical.
"
Exxsol
®
Blowing
Agents:
The
Compelling
Case
for
Pentane
Hydrocarbon­
Based
Rigid
Spray
Foam."

(
3)
Exxon
Mobile
Chemical.
Safety
Guidelines
for
Exxsol
®
Blowing
Agent
Based
Rigid
Polyurethane
Spray
Systems.

(
4)
MSDS
from
Matheson
Tri­
Gas,
Inc.
for
Methyl
Formate.
Available
at
http://
hazard.
com/
msds/

5
FSI's
MSDS
for
Ecomate
could
not
be
located
on
the
Internet.
Attachment
B
DRAFT
MEMORANDUM
To:
Cc:
Margaret
Sheppard
Suzanne
Kocchi,
Anhar
Karimjee
From:
Mollie
Barwis,
Iliriana
Mushkolaj,
Pam
Mathis,
Hugh
McAdams,
Mark
Wagner
Date:
May
29,
2003
Re:
Safety
training
(
EPA
Contract
No.
68­
D­
00­
266,
WA
No.
2­
04,
Task
2)

The
purpose
of
this
draft
memorandum
is
to
outline
steps
needed
to
prepare
and
conduct
a
safety
training
program
for
industries
that
use
hydrocarbon
blowing
agents,
as
well
as
ways
to
promote
the
safety
training
among
these
industries.
The
draft
memorandum
will
be
supplemented
with
information
on
a
safety
program
developed
by
Exxon
Mobil
when
documents
become
available.

Please
contact
Iliriana
Mushkolaj
(
862­
2955)
or
Mark
Wagner
(
862­
1155)
with
any
questions
or
comments.

1.
Safety
Measures
for
Use
of
Pentane
in
Spray
Foam
Systems
Hydrocarbons
are
SNAP
approved
alternatives
to
ozone­
depleting
foam
blowing
agents.
They
are
halogen
free
and
hence,
have
zero
ozone
depleting
potential
(
ODP)
and
low
global
warming
potential
(
GWP).
Hydrocarbons
are
currently
being
used
in
extruded
polystyrene,
polyurethane,
and
polyolefin
non­
insulating
foam
end­
uses.
Cyclopentane
is
a
leading
alternative
blowing
agent
candidate
for
insulating
foams
because
of
its
high
boiling
point
and
other
physical
properties
that
are
similar
to
CFC­
11
(
EPA,
1994).

Hydrocarbons
are
volatile
organic
compounds
(
VOCs)
and
may
contribute
to
the
formation
of
ground­
level
ozone,
or
smog,
in
the
lower
atmosphere.
Any
use
of
hydrocarbon
blowing
agents
is
subject
to
federal,
state
and
local
restrictions
that
apply
to
VOCs
(
EPA,
1994).

Conversion
of
foam
blowing
agents
to
hydrocarbons
may
require
major
capital
investment
to
ensure
worker
safety
from
fire
hazards.
Safety
measures
for
the
use,
handling,
and
storage
of
hydrocarbons
should
be
considered
by
both
the
manufacturers
of
foam
systems
and
the
contractors
that
use
them.
Such
safety
measures
include:

Foam
system
manufacturers
 
Proper
labeling;
 
Separate
storage;
 
Adequate
ventilation;
 
Use
of
certified
shippers;
 
Proper
warehousing;
and
 
Worker
training.
Attachment
B
Contractors
 
Proper
labeling;
 
Proper
storage;
 
Safe
handling
of
storage
vessels;
 
Safe
transport
of
storage
vessels
to
the
jobsite;
 
Worker
training;
 
Proper
use
of
spray
machine;
 
No
smoking;
 
Safe
handling
of
open
containers;
 
Safe
application
of
spray
foam;
and
 
Safe
handling
of
empty
pentane
system
vessels.

In
addition,
the
producers
of
blowing
agent
systems
should
provide
safety
information
to
their
customers
(
i.
e.,
the
foam
system
manufacturers).
For
example,
Exxon
Mobil,
a
formulator
of
pentane
systems,
has
developed
a
safety
brochure
that
they
provide
to
customers
that
purchase
pentane.

2.
Steps
Needed
to
Prepare
and
Conduct
a
Safety
Program
The
Spray
Polyurethane
Foam
Division
(
SPFD),
with
the
help
of
their
parent
organization,
Exxon
Mobil,
and
the
systems
houses
should
develop
a
safety
program
for
contractors.
In
turn,
each
contractor
should
develop
their
own
safety
program.
The
systems
houses
could
also
help
with
a
training
program,
as
originally
requested
during
the
SNAP
approval
process.

Information
about
safety
training
should
already
exist
(
i.
e.,
Material
Safety
Data
Sheets)
and
could
be
used
with
minor
modification.
For
example,
the
paint/
coatings
industry
has
a
long
history
of
spraying
flammable
agents,
and
the
safety
information
they
developed
could
be
modified
and
used
in
the
foam
industry.

It
should
be
noted
that
many
contractors
already
work
with
flammable
materials,
such
as
those
that
work
with
the
coatings
that
get
applied
to
the
foam.
Ensuring
worker
health
and
safety
in
this
industry
did
not
prove
to
be
as
difficult
as
projected
by
suppliers
or
contractors.

3.
Hurdles
Several
difficulties
constrain
the
assurance
of
proper
safety
in
foam
industries
that
use
hydrocarbon
blowing
agents.
Specifically,
the
following
issues
must
be
overcome:

 
The
commercial
drivers
license
(
CDL)
is
more
expensive
than
freight
costs
for
flammables;
 
New
spray
machines
and
truck
set
ups
may
be
required.
The
current
truck
set
ups
are
not
explosionproof
 
Negative
press
was
generated
after
Central
Coatings
performed
an
experiment
that
intentionally
created
fire,
and
published
the
event
in
newspapers
around
the
world;
 
Systems
houses
are
not
explosion­
proof;
and
 
New
burn
testing
must
be
conducted.

References
EPA,
1994.
SNAP
Final
Rule.
Last
accessed
05/
21/
03
at:
http://
www.
epa.
gov/
ozone/
snap/
regs/
59fr13044.
html
