Success
through
Innovation.
Creating
New
Technologies
for
Urethane
Chemical
Systems
and
Equipment.
www.
foamsupplies.
com
foam
supplies,
inc.

Home
Office:
4387
North
Rider
Trail
*
Earth
City,
MO
63045­
1103
Texas
Office:
590
Benjamin's
Way
*
Lewisville,
TX
75057
314­
344­
3330
*
800­
325­
4875
*
Fax:
314­
344­
3331
972­
436­
7008
*
800­
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4875
*
Fax:
972­
436­
0243
January
12,
2004
Ms.
Suzanne
Kocchi
EPA
VIA
EMAIL:
kocchi.
suzanne@
epamail.
epa.
gov
Dear
Suzie,

As
we
have
been
discussing
the
demand
for
HCFC­
141b
in
the
urethane
foams
sector,
I
have
come
up
with
a
few
facts
and
opinions
that
may
interest
you.
These
are
the
basis
for
my
support
to
EPA's
proposed
use
ban
to
culminate
the
phase­
out
of
141b
(
65
FR
42653).

First,
in
the
face
of
the
impending
production
ban
of
HCFC­
141b
scheduled
for
01­
01­
2003,
Foam
Supplies,
Inc.
chose
to
convert
to
alternative
blowing
agents
early,
mostly
HFC­
134a.
Thus,
we
had
successfully
eliminated
any
need
for
141b
prior
to
that
date.
If
a
small
business
such
as
ours
could
do
it,
I
don't
see
why
the
larger
corporations
cannot.

Secondly,
most
of
my
competitors
are
the
four
major
global
isocyanate
producers.
For
the
past
6­
8
months,
we
have
received
numerous
phone
calls
from
their
existing
customer
base
with
an
interest
in
our
new
product,
ecomate.
This
interest
is
generated
largely
by
the
message
from
their
current
suppliers
about
stockpiled
141b.
They
have
been
given
deadlines
for
switching
over
to
alternative
products.
Some
were
told
they
would
have
to
convert
by
the
end
of
2003.
Others
would
receive
extensions
to
finish
qualifying
anywhere
from
January
30,
2004
to
June
30,
2004
but,
all
were
told
that
stockpiles
are
dwindling
and
the
end
is
near.
In
light
of
this,
it
does
not
appear
that
there
is
going
to
be
much
need
for
the
141b
beyond
that
point.

Thirdly,
we
still
see
competition,
on
occasion,
offering
141b­
blown
systems
to
customers
but,
it
has
invariably
been
only
to
new
customers,
on
a
short­
term
basis,
or
to
customers
outside
the
U.
S.

Finally,
FSI
has
developed
and
qualified
a
new
blowing
agent
known
as
ecomate.
ecomate
is
a
non­
ODP,
non­
GWP
alternative
blowing
agent
which
received
SNAP
approval
on
August
21,
2003.
It
has
been
tested
in
field
and
laboratory
situations
sideby
side
with
the
other
primary
HCFC­
141b
alternatives
and
has
proven
to
be
comparable
to
all
of
them
in
every
physical
property
category
including
thermal
efficiency
and
dimensional
stability.
While
we
have
converted
a
number
of
facilities
over
to
ecomate
in
2003,
we
have
qualified
but
not
switched
over
many
others.
We
have
been
told
repeatedly
that
there
are
only
one
or
two
reasons
for
delaying
the
change.
Number
1,
they
are
waiting
for
the
finalization
of
VOC­
exempt
status
for
ecomate,
which
we
are
expecting
to
be
published
any
day.
Number
2,
they
don't
have
to
switch
because
of
the
availability
of
systems
containing
HCFC­
141b.
They
have
a
comfort
level
with
the
product
they
are
using
and
as
long
as
they
can
use
it,
they
will.

For
all
of
these
reasons,
FSI
supports
EPA's
effort
to
finalize
its
decision
on
the
use
of
HCFC­
141b
in
foam
products.

Sincerely,

Tim
Kalinowski
President
