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P2 Awards, 1996 - Huls America, Inc.

Stephen L. Bearman, Ph.D.
Director of Regulatory Affairs
Huls America Inc.
P.O. Box 365, Turner Place
Piscataway, NJ 08855

Re: Recognition of Achievement in Pollution Prevention--PMN 96-167

Dear Dr. Bearman:

I am very pleased to inform you that EPA's Office of Pollution Prevention and Toxics (OPPT) is hereby recognizing Huls America Inc. for an important achievement in pollution prevention (P2). This achievement involves the new chemical substance described in premanufacture notice (PMN) 96-167 submitted to EPA pursuant to Section 5 of the Toxic Substances Control Act (TSCA).

The process for manufacturing your new chemical, generically named isophorone diurethane (PMN 96-167), represents a significant innovation in the chemistry for synthesizing isocyanates, one with important pollution prevention benefits. As part of the New Chemicals Program's P2 Recognition Program, I congratulate you for this technological innovation and for your environmental stewardship.

EPA considers your new chemical worthy of recognition because its synthesis process constitutes a non-phosgene alternative for the manufacture of isophorone diurethane. Through this substitution, your new chemical avoids the many health and environmental hazards related to the use of phosgene. In addition, the product of this environmentally friendly synthesis is a blocked isocyanate, which can be stored, handled and transported more safely than unblocked isocyanates. Although the Agency continues to have significant concerns for the potential human health effects associated with the use of isocyanates, the safety advantages of this new synthesis technology make it an outstanding example of innovative chemistry that benefits human health and the environment.

The Agency has noted that the non-phosgene synthesis for isophorone diurethane generates ammonia and would like to encourage you to recycle this byproduct as a urea starting material, if you are not currently doing so. It is our understanding that the phosgene process yields hydrochloric acid that is not amenable to recycling; thus, your new chemistry offers the potential for an additional prevention benefit if you recycle the ammonia.

EPA is also aware of another new chemical with a very similar chemistry and opportunities for pollution prevention for which Huls America submitted a premanufacture notice. Trimethylhexamethylene-urethane, the generic name for PMN 96-336, would also be manufactured via a non-phosgene process and yield a blocked isocyanate like that of PMN 96-167. Unfortunately, the Agency has not received a notice of commencement of commercial manufacture (per 40 CFR 720.102) for PMN 96-336. EPA acknowledges the potential P2 and safety advantages of the chemistry described in P-96-336 and would proceed to formally recognize the P2 benefits once manufacture commences and these benefits begin to accrue. Please notify us if the manufacturing status of this substance changes.

OPPT has instituted the P2 Recognition Program as a means to encourage innovation and further pollution prevention. In addition to formal notice by letter, EPA is considering publicly listing P2 Recognition recipients on the Internet and perhaps in other media as well. The Agency may also publish articles describing the pollution prevention benefits of specific chemicals which are the subject of a PMN. As always, confidential business information claims will limit our ability to communicate about these new chemicals and to announce, describe and promote these P2 innovations. The Agency welcomes your ideas and comments on how best to recognize and spread the word about your and other noteworthy P2 accomplishments. In this particular case, it would be helpful if you would drop the CBI claims concerning the PMN's use in a non-phosgene process to manufacture isophorone diurethane.

Please realize that New Chemicals Program reviewers often rely heavily on information manufacturers supply on the P2 page of the Premanufacture Notice to identify recognition candidates. EPA urges all submitters to provide sufficient detail in a notice so that the Agency can perform a thorough analysis of P2 claims. In essence, pollution prevention means reducing or eliminating a potential pollutant before it is created. Ideally, P2 should be accomplished through innovative chemical design or redesign. EPA advocates P2 because it makes sense -- for the environment and the economy. By not creating a pollutant, one avoids the hazards and costs associated with controlling exposures to and releases of that pollutant. In-process recycling may provide benefits similar to P2. (For more information on P2, visit EPA's Pollution Prevention homepage: http://www.epa.gov, select "Search" then type "p2home.")

Since EPA has only limited information on your P2 Recognition chemical, I ask that you keep the Agency informed of this substance's commercial success over time, any toxicity data that becomes available, and the uses you make of this P2 recognition, e.g., in product literature or advertising. Please note that under Section 5 of the Federal Trade Commission Act any marketing claims based on this letter must be accurate and not misleading. (For additional information, see "Guides for the Use of Environmental Marketing Claims" issued by the Federal Trade Commission on July 28, 1992 at 57 FR 36363, codified at 16 CFR Part 260, and reissued in October 1996. Copies of the Guide are available by calling the FTC at (202) 326-2222 or on the Internet at http://www.ftc.gov under the heading "Consumer Protection Rules and Guides" and the subheading "Environmental Marketing Guides.")

When you have new information or if you have any questions regarding the P2 Recognition Program, please contact Roy Seidenstein (202-260-2252) or Kenneth Moss (202-260-3395). You can reach Mr. Seidenstein or Mr. Moss by fax at 202-260-0118; by mail at USEPA, Office of Pollution Prevention and Toxics, MC 7405, 401 M Street, SW, Washington, DC 20460; or via e-mail at seidenstein.roy@epamail.epa.gov or moss.kenneth@epamail.epa.gov. Also, my office runs the President's Green Chemistry Challenge Awards program; your P2 Recognition PMN may be a good candidate for this award. (For information on how to apply, contact Tracy Williamson at 202-260-3960, or williamson.tracy@epamail.epa.gov.)

Again, congratulations on your pollution prevention achievement. The Agency wishes you continued success with future innovations.

William H. Sanders III, Dr. P.H., P.E.
Director, Office of Pollution Prevention and Toxics

cc: Henry Kasperzack, Vice President, Coatings and Raw Materials
     Peter Toohey, Marketing Manager


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