Agency Taking Comments on PU Foam as a Transport Hazmat
The Pipeline and Hazardous Materials Safety Administration is taking comments until June 28 on a petition that seeks to classify polyurethane foam and certain finished products containing polyurethane foam as hazardous materials when they're being transported. Safety of emergency responders and the public is served by this designation, NASFM says.
PHMSA has created docket number PHMSA-2006-26275 for this potential rulemaking and will accept comments via www.regulations.gov or http://dms.dot.gov. What the fire marshals' group seeks is having a North American Identification number assigned to PU foam, carriers be required to display Orange Panels with the ID number to identify the presence of PU foam for initial responders, transportation incidents involving PU foam fires be reported to PHMSA, a Safety Alert be published identifying measures initial responders can take to protect themselves and the public during incidents involving PU foam, and those measures be included in the 2008 Emergency Response Guidebook.
"PU foam, whether in bulk shipments or in finished products, is explicitly listed and controlled as a hazardous material in all phases of manufacturing, construction and more recently, consumer applications. As such, records pertaining to the hazardous nature of PU foam already are kept and reports are routinely issued by the producers of these materials. Ironically, when the risks are least manageable -- in transportation -- PU foam is not officially considered hazardous," the petition states. "Whether experienced in the real world or observed under scientific conditions, PU foam is a hazardous material. A significant and unambiguous body of scientific literature underscores the poor fire performance of these materials and products, and a preliminary review of the fire incident data found numerous transportation incidents where PU foam and such products as upholstered furniture and mattresses provided the fuel load for significant fires. These are not new observations. Smoldering and small open flame ignitions of finished products containing PU foam have long been the number-one cause of death by fire in the home."
NASFM recommends that it be placed within Class 9, which exists for unusual but clearly hazardous materials. The group recommends exempting mattresses sold after July 1, 2007, in the United States because they must comply with CPSC requirements that effectively shield PU foam from ignition sources.