Safer Consumer Products: Regulatory Responses for the Priority Product Spray Polyurethane Foam Systems with Unreacted Methylene Diphenyl Diisocyanate (MDI)
Summary
SCH Number
2025110282
Public Agency
California Department of Toxic Substances Control
(DTSC)
Document Title
Safer Consumer Products: Regulatory Responses for the Priority Product Spray Polyurethane Foam Systems with Unreacted Methylene Diphenyl Diisocyanate (MDI)
Document Type
NOE - Notice of Exemption
Received
Posted
11/7/2025
Document Description
In response to DTSC’s listing Spray Polyurethane Foam (SPF) Systems as a Priority Product, SPF Systems manufacturers submitted an Abridged Alternatives Analysis report, which requires two mandatory regulatory responses and allows DTSC to impose additional responses as necessary to address the potential health impacts caused by use of SPF Systems. Following public notice and comment on three proposed regulatory responses and consultation with SPF Systems manufacturers, DTSC has finalized the determination. The three regulatory responses require the SPF Systems manufacturers to provide information about the hazard traits and safe use of SPF Systems to consumers, require training for all applicators of SPF Systems to ensure proper protections are utilized, and establish funding for grants to research and develop safer alternatives to SPF Systems. DTSC’s Notice of Final Determination outlines all required regulatory responses and their implementation steps, as required by chapter 55 of division 4.5 of title 22 of the California Code of Regulations, section 69506.1.
Contact Information
Name
Lynn Goldman
Agency Name
Department of Toxic Substances Control
Job Title
Senior Attorney
Contact Types
Lead/Public Agency
Phone
Email
Location
Counties
Alameda, Alpine, Amador, Butte, Calaveras, Colusa, Contra Costa, Del Norte, El Dorado, Fresno, Glenn, Humboldt, Imperial, Inyo, Kern, Kings, Lake, Lassen, Los Angeles, Madera, Marin, Mariposa, Mendocino, Merced, Modoc, Mono, Monterey, Napa, Nevada, Orange, Placer, Plumas, Riverside, Sacramento, San Benito, San Bernardino, San Diego, San Francisco, San Joaquin, San Luis Obispo, San Mateo, Santa Barbara, Santa Clara, Santa Cruz, Shasta, Sierra, Siskiyou, Solano, Sonoma, Stanislaus, Sutter, Tehama, Trinity, Tulare, Tuolumne, Ventura, Yolo, Yuba
Regions
Statewide
Other Information
Statewide
Notice of Exemption
Exempt Status
Categorical Exemption
Type, Section or Code
California Code of Regulations, title 14, sections 15306 and 15322
Reasons for Exemption
These regulatory responses require SPF Systems manufacturers to update and provide information for consumers on product packaging and websites, implement and track compliance with a training program for end users of the product and fund green chemistry and engineering grants for research and development of safer alternatives.
DTSC has no evidence of potential direct or indirect physical change to the environment that would result from the required two automatic regulatory responses that are triggered by the submittal of an Abridged Alternatives Analysis Report. In addition, for the requirement that responsible entities track and ensure that users receive online training, DTSC has no evidence that this regulation would result in a change in any of the physical conditions within California, including land, air, water, minerals, flora, fauna, ambient noise, and objects of historic or aesthetic significance. DTSC received no comments during the public comment period for the Notice of Proposed Determination that indicated an adverse environmental impact from the proposed regulatory responses.
Attachments
Notice of Exemption
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