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Questions and Answers on Foam Blowing Substitutes

This fact sheet provides an overview of the regulations governing the use of ozone-depleting blowing agents and their substitutes for foam manufacture. Lists of EPA accepted substitutes for foams are also available. You can also read more about EPA's Significant New Alternatives Policy (SNAP) program, which evaluates alternatives for ozone-depleting substances.

Questions on the Clean Air Act Amendments of 1990 and the Phaseout of Ozone-Depleting Substances

  1. When will the production of hydrochlorofluorocarbons (HCFCs) be
    banned?
  2. Can I use HCFCs as foam blowing agents?
  3. I have switched to a hydrofluorocarbon (HFC) blowing agent. How
    long will I be able to use it?

Questions on Section 610 Nonessential Products Ban

  1. I use an HCFC blowing agent. Am I exempt from the Nonessential Products Ban?

Questions on Section 611 Labeling

  1. What has to be labeled?
  2. What should the label say?
  3. How do I label spray foam products?

Questions on SNAP Status and Review Process

  1. What does SNAP stand for?
  2. What is EPA doing under the SNAP program?
  3. How can I get a copy of a particular SNAP rule?
  4. How does EPA decide whether a substitute is acceptable or unacceptable?
  5. Are all foam types covered under SNAP?
  6. How does EPA communicate decisions made under the SNAP program?
  7. What alternatives are suitable for my particular use?
  8. What about the use of an additive to an alternative found acceptable under SNAP?
  9. How do requirements for the Section 610 Class II Nonessential Products Ban relate to the SNAP program?
  10. Where can I obtain additional information about the SNAP program and how to make a submission for a substitute?

The Clean Air Act Amendments of 1990 and the Phaseout of Ozone Depleting Substances

  1. When will the production of hydrochlorofluorocarbons (HCFCs) be banned?
    Under the nonessential use ban, all foam products containing or manufactured with CFCs and HCFCs, except insulating foams, were banned in 1994 from sale and distribution in interstate commerce in the United States. The most commonly used HCFCs for foam blowing are HCFC-141b, HCFC-22, and HCFC-142b. EPA banned the use of HCFC-141b in 2003. EPA has also banned the use and sale of virgin HCFC-22 and HCFC-142b for foam blowing purposes as of January 1, 2010. The HCFC phaseout schedule under the Clean Air Act Amendments is found here.

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  2. Can I use HCFCs as foam blowing agents?
    No. As of March 1, 2008, the use of HCFC-22, HCFC-142b, and blends thereof are unacceptable (prohibited) as substitutes for HCFC-141b in the manufacture of commercial refrigeration, sandwich panels, slabstock, and other "pour foam" applications. EPA allowed the use of HCFC-22 and HCFC-142b in the manufacture of foam for marine applications until September 1, 2009. All other foam blowing uses of HCFC-22 and HCFC-142b are prohibited as of January 1, 2010. In addition, HCFC-124 is unacceptable as a substitute in all foam blowing end uses.

    For more information, reference SNAP Rule 13: The use of HCFC-22 and HCFC-142b in foams / listing of ozone depleting substitutes in foam blowing (Effective Date: May 29, 2007) and SNAP Rule 10: Acceptable and unacceptable substitutes for ozone-depleting substances (ODSs) in foams blowing (Effective Date: September 30, 2004).

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  3. I have switched to a hydrofluorocarbon (HFC) blowing agent. How long will I be able to use it?
    There are currently no regulations establishing a phaseout schedule on HFCs. HFCs found acceptable as a substitute for ozone-depleting blowing agents may be used. You can find lists of acceptable HFCs and read decisions regarding their use as foam-blowing agents on the SNAP program web site.

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Questions on Section 610 Nonessential Products Ban

  1. I use an HCFC blowing agent. Am I exempt from the Nonessential Products Ban?
    Maybe. Effective January 1, 1994, plastic foam products which contain or are manufactured with HCFCs were banned from sale or distribution into interstate commerce under Section 610 of the Clean Air Act. Thermal insulation foam products are, however, exempted from this ban. Foam insulation products are defined as a product containing or consisting of the following foam types:
    • closed cell rigid polyurethane foam;
    • closed cell rigid polystyrene boardstock foam;
    • closed cell rigid phenolic foam;
    • closed cell rigid polyethylene foam; and
    • when such foam is suitable in shape, thickness, and design to be used as a product that provides thermal insulation around pipes used in heating, plumbing, refrigeration, or industrial process systems.

    In addition, the use of an HCFC as a substitute for a CFC, or other foam-blowing agent as a substitute for an HCFC, must have been found acceptable under the SNAP program and must comply with any use restrictions under that program.

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Questions on Section 611 Labeling

  1. What has to be labeled?
    Since May 15, 1993, labels have been required for the following:
    • bulk containers of CFCs and HCFCs,
    • products containing CFCs (e.g. closed cell foams), and
    • products manufactured with CFCs (e.g. open cell foams).

    Products containing or manufactured with HCFCs will be subject to the labeling requirements no later than January 1, 2015.

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  2. What should the label say?
    Required label text -- "Warning: Contains [Manufactured] with [name of substance], a substance which harms public health and environment by destroying ozone in the upper atmosphere." In addition, the label must be clearly legible and conspicuous to the customer at the time of purchase.

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  3. How do I label spray foam products?
    Alternative labeling is allowed. For example, on invoices, on hang tags, etc.

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Questions on SNAP Status and Review Process

  1. What does SNAP stand for?
    EPA's Significant New Alternatives Policy (SNAP) program implements Section 612 of the Clean Air Act Amendments of 1990. The final regulation for SNAP was published in the Federal Register on March 18, 1994, (59 FR 13044). It is illegal to replace an ODS with a substitute listed by SNAP as "unacceptable." People must also obey conditions placed on various substitutes and limits placed on where they can be used. Restrictions relevant to a given substitute are described in the rule listing that substitute. The SNAP chronology lists all SNAP publications.

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  2. What is EPA doing under the SNAP program?
    Under SNAP, EPA is evaluating alternative chemicals and processes that companies want to use in place of ozone-depleting substances. This review is to ensure that the substitutes won't cause greater risk to human health and the environment than the ozone-depleting substances being replaced. A fact sheet explains the SNAP program in more detail.

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  3. How can I get a copy of a particular rule?
    All SNAP rules and Notices are available online from the main SNAP page. Hard copies of the Federal Register Notices can be ordered from the Government Printing Office Order Desk at (202) 783-3238.

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  4. How does EPA decide whether a substitute is acceptable or unacceptable?
    EPA's decision on the acceptability of new substitutes proposed by manufacturers, formulators, or users is based primarily on the potential human health and environmental risks posed by the substitutes as compared to the chemical being replaced, as well as to other substitutes available for a particular end-use. The evaluation includes atmospheric effects, health (occupational, consumer, and general population) and ecological effects, flammability, and other factors affecting the potential risk of a substitute.

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  5. Are all foam types covered under SNAP?
    No, only those which historically used CFCs or methyl chloroform as the blowing agent. SNAP specifically includes these end-uses:
    • rigid polyurethane and polyisocyanurate laminated boardstock;
    • rigid polyurethane appliance;
    • rigid polyurethane spray and commercial refrigeration, and sandwich panels;
    • rigid polyurethane slabstock and other foams;
    • polystyrene extruded insulation boardstock and billet;
    • phenolic insulation board and bunstock;
    • flexible polyurethane,
    • polystyrene extruded sheet; and
    • polyolefin.

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    How does EPA communicate decisions made under the SNAP program?
    EPA publishes decisions made under the SNAP program in the Federal Register. Several updates have been published. Both a schedule of publications and comprehensive substitutes lists are available.

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  6. What alternatives are suitable for my particular use?
    EPA reviews substitutes for their acceptability in the context of health and the environment, but it is up to the manufacturers and user industries to assess their technical viability for particular uses. Please review the lists of substitutes that are organized by end-use.

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  7. What about the use of an additive to an alternative found acceptable under SNAP?
    Under the SNAP program, changes in foam formulation needed to accommodate replacement of ozone depleting compounds are not formally subject to review. Nonetheless, the manufacturer overseeing the formulation change is required to notify the Agency if these modifications influence the human health or environmental risk characteristics associated with the substitute.

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  8. How do requirements for the Section 610 Class II Nonessential Products Ban relate to the SNAP program?
    The Class II Nonessential Products Ban is a self-effectuating provision under section 610(d) of the Clean Air Act Amendments. All aerosol products, pressurized dispensers, and foam products, except insulating foam products, containing or manufactured with HCFCs are banned from sale and distribution in interstate commerce in the United States. Banned products cannot be incorporated into larger products (i.e. packaging material). SNAP identifies which alternatives are acceptable for those end-uses exempted from the Nonessential Products Ban.

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  9. Where can I obtain additional information about the SNAP program and how to make a submission for a substitute?
    Information on submitting a substitute under SNAP can be found here. You may also contact:

    SNAP Coordinator
    U.S. EPA (6205-J)
    Washington, D.C. 20460
    TEL: 202-343-9410

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