Toluene Diisocyanate (TDI) Action Plan Summary
- What chemicals are addressed in the action plan?
- Why is EPA concerned about these chemicals?
- What action is EPA taking?
What chemicals are addressed in the action plan?
This action plan addresses EPA’s review of Toluene Diisocyanate (TDI) and related compounds, CASRNs 101-68-8, 5873-54-1, 2536-05-2, 26447-40-5, 9016-87-9, 17589-24-1, 31107-36-5, and 25686-28-6.
EPA has developed a separate Action Plan for Methylene Diphenyl Diiscyanate (MDI) and its related compounds. TDI is chemically similar to MDI and presents similar hazard and exposure concerns, but is reportedly used in a different range of products.
Why is EPA concerned about these chemicals?
Diisocyanates are well known dermal and inhalation sensitizers in the workplace and have been documented to cause asthma, lung damage, and in severe cases, fatal reactions. Worker exposures are already subject to protective controls in occupational settings, but EPA is concerned about potential health effects that may result from exposures to the consumer or self-employed worker while using products containing uncured TDI and its related polyisocyanates (e.g., spray-applied sealants and coatings) or incidental exposures to the general population while such products are used in or around buildings including homes or schools.
What action is EPA taking?
Based on EPA’s screening-level review of hazard and exposure information, including information from industry indicating uncured TDI and its related polyisocyanates are used only in industrial products and not in consumer products, EPA intends to:
- 1. Initiate rulemaking under TSCA section 5(a)(2) for a Significant New Use Rule (SNUR) designating the use of uncured TDI and its related polyisocyanates in a consumer product as a new use requiring prior notice to the Agency.
- If, however, public comments on the proposed SNUR indicate there are ongoing uses of uncured TDI in consumer products, since ongoing uses are by definition not new, EPA intends to consider working with industry to develop a voluntary phase-out of such uses within one year, to be followed by a SNUR.
- If voluntary phase-out is not agreed upon, or is not completed as agreed upon, EPA intends to consider initiating rulemaking under TSCA section 4 to require exposure monitoring studies on TDI and its related polyisocyanates in consumer products.
- 2. Issue a data call-in under TSCA section 8(c) to determine if there are allegations of significant adverse effects and initiate a TSCA section 8(d) rule for one-time reporting of relevant unpublished health and safety studies.
- 3. Consider initiating a TSCA section 4 test rule to require exposure monitoring studies in representative locations where commercial products with uncured TDI would be used.
- 4. Consider initiating rulemaking under TSCA section 6 to regulate commercial uses of uncured TDI products in locations where the general population could be exposed.
- 5. Consider identifying additional diisocyanates and their related polyisocyanates that may be present in an uncured form in consumer products that should be evaluated for regulatory and/or voluntary action.
Download the complete Toluene Diisocyanate (TDI) Action Plan (PDF), (16 pp., 67 KB, About PDF)