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Flexible Polyurethane Foam Fabrication Operations: National Emission Standards for Hazardous Air Pollutants

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Rule Summary

This action promulgates national emission standards for hazardous air pollutants (NESHAP) for new and existing sources at flexible polyurethane foam fabrication facilities. EPA has identified flexible polyurethane foam fabrication facilities as major sources of hazardous air pollutants (HAP) emissions. These standards will implement section 112(d) of the Clean Air Act (CAA) by requiring all applicable major sources to meet hazardous air pollutant emission standards that reflect the application of maximum achievable control technology (MACT).

The primary HAP that will be controlled with this action include hydrochloric acid (HCl), 2,4-toluene diisocyanate (TDI), and hydrogen cyanide (HCN). This action will also preclude the use of methylene chloride.

EPA estimates that current HAP emissions from loop slitter adhesive users are essentially zero because of changes in adhesive composition as a result of the Occupational Safety and Health Administration (OSHA) permissible exposure limit for methylene chloride. Therefore, we do not expect any decreases from this subcategory resulting from the NESHAP. We have not promulgated any emissions limitations for existing flame lamination sources; therefore, we do not expect any emissions reductions from the baseline.

We calculate that a typical flame lamination operation emits 7.3 tons per year (tpy) of combined HCl and HCN, requirements for new and reconstructed sources would be reduce those emissions by 90 percent, for a total HAP emission reduction of 6.5 tpy from each new or reconstructed affected source.

Rule History

01/11/2021 - Proposed rule | Proposed rule edits

04/14/2003 - Final rule

08/08/2001 - Proposed rule

Additional Resources

Fact Sheet - Proposed Amendments to Air Toxics Standards for Flexible Polyurethane Foam Production and Fabrication

Public Comment Review Tool for Flex Foam Fabrication RTR modeling file(1 MB) . To use this tool, please download the file to your computer and unzip, then follow the instructions in the included PDF file.

Fact Sheets (2003 versions)


The 4/14/2003 FR final rule gives existing loop slitters 1 year after that date to comply, or by 4/14/2004. Existing flame lamination sources have no emission limit, and thus no compliance date, but should have submitted an initial notification no later than 120 days after 4/14/2003, or by 8/12/2003.