USA Premium Foam G Series #105 thermal or sound insulation materials

The reports, as CPSC published them

1. Seen by a doctor or nurse

   Made Apr 10, 2018 · , sent to the company Apr 18, 2018 · , published by CPSC May 9, 2018

   The product, in the report: Product information is below, and further below are all the addresses and contact information for the companies involved in the sale and marketing of Tripolymer (aka USA Premium Foam). Note that the companies involved have thus far declined to provide us with basic product information such as the manufacture date and expiration of the resin or foam insulation. Tripolymer® 105, which was used at our residence for house insulation, is a Phenol-Urea-Formaldehyde foam. The foam consists of two components, (A) the resin in aqueous solution and (B) the foaming agent/catalyst. The starting resin used for the foam is made by reacting phenol to a solution of urea-formaldehyde, as evident from the patent published by C. P Chemicals Inc. in 1980 and in 1982 (see the report by Charles Wilkes attached, which contains the patent). The resin is mixed on site with the foaming agent, component B, containing acidic catalyst and surfactant (phosphoric acid and dodecyl benzenesulfonate) [3,4] in aqueous media, and compressed air. The catalyst facilitates molecular cross-linking/Curing. The initial foaming is very fast, but the foam continues to cure for 48-72 hours [5] and hardens in the places of installation. According to Tripolymer’s Material Safety Data Sheet filed in 2013 by C.P. Chemical with the Department of Labor’s Occupational Safety and Health Administration (OSHA), the name of the product that was installed in our home was Tripolymer Foam G Series # 105; it has also been referred to as Tripolymer 105 G-7, and Tripolymer 105. It was marketed and sold to us as “USA Premium Foam” by Maryland-based MBRS Group, LLC and its Ohio-based franchisor USA Insulation as “USA Premium Foam G Series # 105”. [REDACTED], who owns MBRS confirmed for us that USA Premium Foam is the same as Tripolymer 105. Owners, salesmen, and other personnel working at multiple franchisees (in various states) under the USA Insulation umbrella also confirmed for us over the phone that Tripolymer 105 is what was installed (as USA Premium Foam) in our home. A brochure that was bless by USA Insulation and that [REDACTED] provided to us in 2013 before we signed the contract in October 2013, made the following misrepresentations: “USA Premium Foam’s unique chemistry meets progressive environmental standards since it does not use or emit HCFC or Hydrocarbons and is Formaldehyde-Free”; “USA Premium Foam does not contain any petrochemical and is safe with no harmful emissions that can cause allergic reactions.” On the last page of the brochure, under the heading “Material,” the brochure makes claims about Tripolymer / USA Premium Foam and what seem to be the basis of those claims appears to be quasi-footnotes or citations of ASTM tests. The last page of the brochure states: “The insulation shall have the following physical properties: R-value of 5.1 per inch Density of .8 – 1.3lb/ft .3 Comrehessive Strength 35 psi Fire characteristics ASM E-84 Flame Spread 5 Smoke 0 Fuel 0 Thermal Conductivity c-177. @ 74 degrees Fahrenheit K factor of 0.219 BTU in/hr – ft2 F Water Vapor Transmission ASTM C – 355 Permeability – perms-in 15.5 to 16.9 Fire Hour Rating ASTM E-119 – 2 Hrs.” In addition, under the heading of “Thermal Stability” the brochure’s last page states: “There is no thermal degradation or reduction in R-value over time with USA Premium Foam.” Unfortunately, we relied on these misrepresentations in deciding to enter into a contract. In November 2013, at the time that we had our house insulated with Tripolymer 105, the manufacturer was C.P. Chemical was (and perhaps still is) owned by [REDACTED] However, in or around 2015-2016, at least some of C.P. Chemical’s intellectual property and insulation products were sold to Ohio-based FDI Enterprises LLC). C.P. Chemical’s address and phone number are: C.P. Chemical 25 Home Street White Plains, NY [REDACTED] Below is the address, phone, and new website of FDI Enterprises, LLC, which in 2015-2016 bought the intellectual property rights to Tripolymer from C.P. Chemical (we understand FDI is still owned by [REDACTED], who is also the owner of USA Insulation Enterprises Inc and other USA Insulation companies): FDI Enterprises LLC - https://tripolymer.com/ 17700 Saint Clair Ave, Cleveland, OH, 44110-2621 The address, internet site, and phone number of MBRS Group LLC, which installed the Tripolymer insulation (aka USA Premium Foam) in our house in 2013 is: MBRS Group, LLC - doing business as “USA Insulation DC Metro West”. 554 Rickenbacker Dr #1, Gaithersburg, MD 20879 [REDACTED] https://usainsulation.net/dc-metro-west/ The address of USA Insulation Enterprises Inc. (which is owned by [REDACTED] and provides support to localized USA Insulation franchisees) is: USA Insulation Enterprises Inc. 1351 East 357 St. Eastlake, Ohio 44095

   I am reporting what the Consumer Product Safety Commission (CPSC) defines as an “actual incident and injury involving an unsafe consumer product.”

   What happened to prompt my report is the installation of a phenol-urea-fomaldehyde foam insulation product, Tripolymer, in the walls of our Washington, D.C. home in November 2013.

   Once installed in our home, Tripolymer, which was marketed and sold to us as “USA Premium Foam,” made us sick and put us at risk for future cancer-related health problems by emitting dangerously high levels of formaldehyde, a carcinogen, and phenol in our home. Both formaldehyde and phenol are listed on the Clean Air Act’s List of Hazardous Air Pollutants.

   Who was using the product and how:

   In 2013 the walls of our three-story Washington, D.C. home had no insulation. We needed to insulate our house before the winter. A Gaithersburg, Maryland-based company called MBRS Group LLC (MBRS), doing business as “USA Insulation of Metro DC-West”, which was a franchisee of Ohio-based USA Insulation Franchise Corp. (USA Insulation), offered to insulate out home by injecting into our walls a foam insulation product that the salesman called USA Premium Foam (aka Tripolymer).

   MBRS offered to install the insulation in our home from the inside, through dozens of small holes that they would drill into the drywall. Given our concerns about toxins while we were trying to have another child and while we had a toddler daughter, we asked MBRS specifically whether the insulation product contained or released any formaldehyde or toxic materials. MBRS assured us during the sales pitch, as well as in the brochure they gave us, which was designed/produced by franchisor USA Insulation, that their foam insulation was “non-toxic” and “formaldehyde-free”. We signed the contract, and within about a month they arrived at our house to do the job. We asked the salesman during the sales presentation (in October 2013) whether he needed to see any architectural blueprints or drawings. He said he only needed to drill a few holes in the walls to check the depth (which we later learned was Tripolymer, manufactured by a company named C.P. Chemical). Later we learned that the manufacturer (in its specs sheet) instructed all of the dealers/installers, including MBRS, that the foam insulation should be applied in a thickness that is in accordance with architectural drawings. However, MBRS never checked or obtained our architectural drawings. Per the Washington, D.C. building code, insulation that is not installed in adherence with manufacturer’s instructions is a violation of the code.

   We also later learned that the installer or franchise operational manual (on page 18) for USA Insulation franchisees instructs installers that USA Premium Foam is “strictly to be used as cavity fill insulation.” It notes that when installed, USA Premium Foam “must be supported and enclosed on all sides in order to insure proper curing.” It also instructs the installer technicians not to inject the foam into horizontal spaces such as ceilings, and that “USA Premium Foam should not be installed in wood or steel-stud partitions or walls in basements...” All of that is relevant because our wall cavities were not enclosed on the top where the foam ended up flowing over into the horizontal ceiling cavities. Also, MBRS did not follow the instructions about the basement and proceeded to foam multiple basement walls in our house. Those are examples of the misapplication of the insulation by MBRS.

   Moreover, the contract we signed with USA Insulation/MBRS Group in October 2013 was for “up to 600 square feet” of insulation. However, according to our retired EPA expert who did the volume calculations by adding up the walls that were foamed and the space in those walls, MBRS put three times that amount in our house. They even injected insulation into walls they were not supposed to insulate, including one in the basement in between the back basement door and the bathroom. No wonder the crew told me during the installation “we’ve never put this much foam into a house this size.”

   When MBRS’ technicians came to install Tripolymer/USA Premium Foam on November 6, 2013, I asked if I needed to get out of the house and/or open up windows and crank up the exhaust ventilation to ensure good ventilation. The installers said not to open windows, as it would make their job tougher due to potential drafts, wind, and temperature change (and the effect on the foam injection process), and they told me I didn’t need to leave or go outside, as it was perfectly safe to be there for and watch the installation process. By the time they finished, the smell was overpowering and sickeningly sweet. I got a migraine that very evening. We immediately started using exhaust ventilation and opened numerous windows to try to air the house out and get rid of the overpowering sweet chemical smell (this is something we continued to do for months). Nothing worked to remediate the problem – not coffee beans, the purchase of big plants, activated carbon, etc.

   By December 2013, the smell had not gotten better or dissipated, and we were sick with various symptoms detailed elsewhere in this write-up. We asked what was in the foam that was making or could make us sick, but the owner had no answer. We asked if it there was any formaldehyde or other toxic chemicals in the insulation or potentially off-gassing, but he said no. The owner declined to provide us with the Material Safety Data Sheets (MSDS) for the insulation and its resin and other components for several days; he eventually shared one for the product, but not for the resin or other components. At first he offered to come test the air quality in our home but changed his mind. He then sent an email offering to send a crew to demolish the walls and tear out all the insulation and replace it with traditional batt insulation. But he would not provide alternative housing for us amid the demolition, and he conditioned the offer on us not going to his insurance company, and under no circumstances could we posting anything negative about the experience on [REDACTED] or similar sites. We declined the offer and were not able to reach an agreement on how to handle the problem. At no time during those negotiations in November-December 2013 did the owner volunteer that the MSDS for the resin warned that in the event of contamination, persons affected should immediately consult a doctor and get out of the contaminated area (we learned that later on our own).

   The Companies Manufacturing and Selling/Installing Tripolymer:

   During the time it was installed in our home in late 2013, Tripolymer was manufactured by C.P. Chemical, Co. Inc, based in White Plains New York, and owned at that time by [REDACTED] However, around 2016, after our house was insulated with Tripolymer (aka USA Premium Foam), the owner of USA Insulation Franchise Corp., [REDACTED], used an LLC called FDI Enterprises, LLC, based in Cleveland, Ohio, to acquire or purchase the intellectual property rights for Tripolymer and the resin and foaming agent elements that comprise it. This is according to public court records that are currently involved in an ongoing trademark lawsuit against C.P. Chemical and [REDACTED]/FDI Enterprises. The lawsuit was filed by Florida-based “Tripolymer, Inc”, which claims in the lawsuit that it was the exclusive nationwide distributor of Tripolymer.

   Multiple Complaints Filed with the CPSC: Tripolymer has been the subject of multiple complaints filed with the CPSC, including as recently as 2017 (report # [REDACTED]). Another complaint dates to 1994. These complaints have been filed by consumers claiming to have been harmed by formaldehyde emissions from Tripolymer installed in their homes. C.P. Chemical and FDI Enterprises may have violated the CPSC’s requirement that a manufacturer must report to the CPSC alleged product defects and risk of harm to consumers within a few days of becoming aware of those defects or risks of harm. C.P. Chemical, FDI Enterprises, and their distributors/installers/sellers would have been aware of those defects for some time. In 2016 we filed a legal complaint regarding these defects in D.C. Superior Court, against USA Insulation Franchise LLC, USA Insulation Enterprises , Inc., USA Insulation Franchise Corp, MBRS Group LLC, and [REDACTED], owner of MBRS. MBRS then filed a third-party suit against C.P. Chemical.

   We allege that the companies named in our legal complaint have committed violations of laws and regulations governing the manufacture and installation of Tripolymer (see attached law suit).

   Health effects: In the very first hours and days following the installation of Tripolymer (aka USA Premium Foam) in our home, and continuing for almost two months after that, up until we moved out of the house in late December 2013, we experienced migraines, nausea, skin rashes, blurred vision, sleep disturbances, memory loss, anxiety, a burning sensation in our throats and noses, and respiratory, sinus, and gastrointestinal (diarrhea) problems, among other negative health effects.

   The medical attention we have sought and received as a result of our exposure to the toxic insulation has included blood work and visits to general physicians, urgent care facilities, and doctors specializing in occupational medicine; ear, nose, and throat issues; maternal fetal medicine; pulmonology; immunology; allergies; and environmental pollutants’ impacts on children’s health. The doctors we consulted noted that the health effects we experienced are consistent with the health effects for formaldehyde and phenol exposure detailed by the Centers for Disease Control and Prevention (CDC).

   Most of the negative health effects we experienced after the exposure to the toxic insulation faded or went away soon after we moved out of the house in late December 2013. However, memory loss, sleep problems, and anxiety continue to be problems for me. They began manifesting themselves a couple of weeks after the installation of the insulation. I have consulted doctors for anxiety, sleep, and memory problems, and I am planning to continue to do that, including by seeking neural-behavioral toxicity testing. Our toddler daughter was too young for some of the relevant tests recommended by our doctors around the time of our exposure to the toxic insulation, but we will seek health monitoring/tests in the years to come. The risk of cancer and asthma will be something that requires continued medical monitoring for all of our family. Following consultations with medical professionals, my wife, my daughter, and I plan to be screened annually for nasopharyngeal cancer (by having either an indirect or direct nasopharyngoscopy or an Epstein-Barr virus serology/test), leukemia (by conducting regular blood count exams), and regular pulmonary function tests.

   Tripolymer made us so sick that we had to move out of our house at the end of 2013 and use alternative (rental) housing for several months, on the advice of medical professionals and industrial hygienists, until we had the insulation removed in September-October 2014.

   Several other people (those who entered our house between November 2013 and late 2014) were exposed to the aforementioned health risks of Tripolymer/USA Premium Foam.

   The type of product being used was Tripolymer, though it was being marketed/sold under the name USA Premium Foam. Tripolymer is a phenol-urea-formaldehyde tripolymer foam insulation product. This Tripolymer product (or an earlier iteration) was banned nationwide for about a year under action taken by the CPSC against urea-formaldehyde foam insulation products (UFFIs) in the early 1980s.

   Although the CPSC ban was eventually overturned by a judge, by 1982 the New York Times reported that there were an estimated 700 lawsuits against manufacturers, installers, and sellers of UFFIs, as well as a 2 billion dollar class action lawsuit, and many more suits were filed after 1982.

   Some manufacturers have asserted in recent years that there have been advances in the production of this type of injection foam to reduce formaldehyde emissions. However, in 2009, the Massachusetts state government and the government of Canada notified the manufacturer/owner of Tripolymer that they had tested Tripolymer 105 (the same one installed in our home). They relayed to C.P. Chemical that they considered Tripolymer to be a urea-formaldehyde foam insulation product that was not safe for consumers’ health due to its history of and potential to emit or off-gas formaldehyde (per the attached documents and our outreach to those governments). In 2011 the Connecticut government also tested Tripolymer 105 and then notified C.P. Chemical that Connecticut also prohibited the use, sale, and marketing of UFFIs, including Tripolymer. (A few years later, around 2015, Connecticut changed its law by loosening restrictions.)

   Testing Results Reveal the Danger of Tripolymer / USA Premium Foam:

   Between January 2014 and April 2015, we hired multiple licensed specialists and labs to conduct scientific tests and analysis of the air quality in our home, as well as tests of the toxic foam insulation itself. We did this in part to help medical professionals determine in early 2014 exactly what had made us sick, whether the exposure we experienced exceeded safety guideline levels established by regulatory agencies, and whether the house was safe and inhabitable again following the removal of the insulation product from September-October 2014.

   Following the installation of Tripolymer in our home, the average levels of formaldehyde measured in our home during three sets of tests between January and May 2014 by an industrial hygienist (and former EPA expert) were 158.7 parts per billion of air (ppb) during January 2014, 254 ppb during April 2014, and 225 ppb during May 2014. The levels of phenol were 19.7 ppb during January 2014, 33 during April 2014, and 15 during May 2014.

   These levels were on the borderline between what experts deem “polluted indoor conditions” and extreme conditions” (per “Formaldehyde in the Indoor Environment,” a widely cited 2010 study by [REDACTED]).

   These levels meant we were exposed to higher formaldehyde levels than professional funeral directors/embalmers are typically exposed to during an average month in an OSHA-regulated work place (and for more hours than they are typically exposed to formaldehyde), per a 2011 New York Times expose and a study published by the National Academies of Sciences, Engineering, and Medicine in 2007. It also meant we were exposed to more than the average level of formaldehyde (77 ppb) in the infamous and defectively constructed toxic trailers that were provided by the Federal Emergency Management Association (FEMA) and used to house Gulf Coast victims of Hurricane Katrina, which the CDC identified as potentially causing respiratory illnesses in the residents of those trailers.

   In the spring of 2014, air quality tests of the two adjoining row houses on either side of our home showed that those houses had normal levels of formaldehyde and phenol (nothing like the levels recorded in our home). Tests of the air outside our home also showed normal levels outside.

   Furthermore, inside the wall cavities of our home, where the foam insulation had been installed, testing of the cavity air by experts revealed that the level of formaldehyde exceeded 2000 (two thousand) ppb.

   In June 2014, further testing of our home’s air quality revealed the average level of formaldehyde in our home to be 240 ppb. The average level of phenol was 45 ppb.

   Samples of Tripolymer insulation from our home’s walls were also tested during these months. The experts found that the Tripolymer foam insulation contained a significant quantity of formaldehyde.

   In addition, in June 2014, testing of a sample of insulation foam from our home’s walls proved to be a match with the infrared (IR) chemical fingerprint for urea formaldehyde foam insulation (UFFI). UFFIs were banned nationwide by the CPSC for a time in the early 1980s and remain banned today by multiple state governments and Canada.

   In September-October 2014, 10 months after Tripolymer was installed in our home, we paid over $30,000 to have experts carefully remove the extremely brittle and often powder-like Tripolymer from the walls of our home. The specialists meticulously filmed and photographed the removal of the foam. Along with the retired EPA expert and other environmental engineers, they found it to be extremely friable, often crumbling into a baby powder-like substance in several of the walls (see attached photos).

   Following the removal, experts tested the air quality again twice, in November 2014 and one last time in April 2015. The levels of formaldehyde dropped dramatically, to 76.2 ppb and finally to 23 ppb. The levels of phenol also dropped dramatically, to 2 ppb (in November 2014) and then to 1 ppb (in April 2015).

   The Meaning of the Test Results for Consumer Safety: The testing demonstrated the following:

   • Our Home was contaminated by high levels of formaldehyde and phenol;

   • The Tripolymer / USA Premium Foam installed in our home contained formaldehyde and phenol;

   • The levels of formaldehyde recorded in our home’s air, prior to the removal Tripolymer in late 2014, far exceeded residential safety levels established by the World Health Organization (80 ppb), the Canadian government (40 ppb), and other regulatory agencies;

   • Prior to the removal of the insulation product, the air inside the wall cavities of our home (where the foam was installed), had formaldehyde levels that exceeded occupational safety levels established by the Department of Labor’s Occupational Safety and Health Administration (OSHA), for long-term and for short-term exposure. (Note: Per OSHA, the American Industrial Hygiene Association, and the Centers for Disease Control and Prevention (CDC), it would be inappropriate to apply occupational safety guidelines for formaldehyde exposure to residential settings because occupational guidelines were designed for adults, not children (such as our then-toddler daughter), and they were not intended for non-monitored exposures in a home, where exposure can far exceed the typical eight- or 10-hour workday upon which occupational guidelines are based.)

   • Over several months, until the Tripolymer / USA Premium Foam was removed in September/October 2014, the levels of formaldehyde continued to increase, not decrease, following the installation of the insulation in November 2013 (the levels increased from January to April 2014, and they increased from May to June 2014);

   • Other internal formaldehyde and phenol sources were negligible;

   • External formaldehyde and phenol sources were negligible and the formaldehyde was not coming from the adjacent row houses or from outside;

   • The testing of phenol in our home further demonstrated that the foam insulation was emitting phenol because phenol was distributed just like the formaldehyde in our home. Also, the phenol concentration was much was much higher in the foamed wall cavities compared to the rooms of our home; and by May 2014 phenol levels in the living spaces of the home were averaging 10 times the U.S. government health standards for chronic inhalation of phenol.

   • The Tripolymer / USA Premium Foam installed in our home contained free formaldehyde as shown in testing in the spring of 2014;

   • The Tripolymer / USA Premium Foam in our Home’s walls was the source of the formaldehyde contamination. This was evidenced by the fact that the wall cavities of our home had much higher formaldehyde concentrations than the rooms. Also, after removing the Tripolymer insulation in the fall of 2014, the levels of formaldehyde and phenol dropped sharply to normal (safe) levels;

   • Tripolymer / USA Premium Foam is capable of emitting formaldehyde at levels over 0.1 parts per million (or 100 ppb) of air. Our testing documented emission levels far above that level. Therefore, as required by OSHA’s Formaldehyde standard, 29 CFR 1910.1048(m)(3), the product label must include a statement that the product has formaldehyde in it. (At the time we purchased the insulation, the sellers, distributors, and installers of Tripolymer/USA Premium Foam claimed the product was “formaldehyde-free” and did not emit any toxic chemicals. The product brochures and advertising continue to make those formaldehyde-free claims today.)

   • Tripolymer/USA Premium Foam is also capable of emitting formaldehyde at levels over 0.5 ppm (or 500 ppb), since our air quality testing documented formaldehyde emissions of over 2000 ppb. Therefore, as required by OSHA, the product label must also have a list of all product health and safety hazards, and the phrase “Potential Cancer Hazard”; and

   • The website (as of April 8, 2018) for Tripolymer insulation (now owned by FDI Enterprises LLC, which is owned by [REDACTED], the owner of Ohio-based USA Insulation) should delete or correct the following claims that mislead consumers about the safety, content, and health risks of this product:

   “Safe…the foam is non-toxic.”

   “No, per current federal regulations, Tripolymer Foam Insulation does not use or contain VOCs”. ((Formaldehyde is a VOC, and our testing showed the foam itself contained significant amounts of formaldehyde.))

   “Tripolymer Foam Insulation has been tested for toxic materials as recommended by the United States Environmental Protection Agency. All tests show conclusively that Tripolymer Insulation does not contain or has undetectable levels of these substances.” ((Our testing showed the foam insulation contained detectable and even significant amounts of a toxic material -- formaldehyde.))

   Key Information on the Product:

   The Tripolymer® 105, used at our residence for house insulation, is a Phenol-Urea-Formaldehyde foam. The foam consists of two components, (A) the resin in aqueous solution and (B)the foaming agent/catalyst. The starting resin used for the foam is made by reacting phenol to a solution of urea-formaldehyde, as evident from the patent published by C. P Chemicals Inc. in 1980 and in 1982 (see the report by [REDACTED] attached, which contains the patent).

   The resin is mixed on site with the foaming agent, component B, containing acidic catalyst and surfactant (phosphoric acid and dodecyl benzenesulfonate) [3,4] in aqueous media, and compressed air. The catalyst facilitates molecular cross-linking/Curing. The initial foaming is very fast, but the foam continues to cure for 48-72 hours [5] and hardens in the places of installation.

   According to Tripolymer’s Material Safety Data Sheet filed in 2013 by C.P. Chemical with the Department of Labor’s Occupational Safety and Health Administration (OSHA), the name of the product that was installed in our home was Tripolymer Foam G Series # 105; it has also been referred to as Tripolymer 105 G-7, and Tripolymer 105. It was marketed and sold to us as “USA Premium Foam” by Maryland-based MBRS Group, LLC and its Ohio-based franchisor USA Insulation as “USA Premium Foam G Series # 105”. [REDACTED], who owns MBRS confirmed for us that USA Premium Foam is the same as Tripolymer 105. Owners, salesmen, and other personnel working at multiple franchisees (in various states) under the USA Insulation umbrella also confirmed for us over the phone that Tripolymer 105 is what was installed (as USA Premium Foam) in our home.

   In an article from 2013 entitled “Formaldehyde-based Foam Insulation Back from the Dead,” author [REDACTED], the founder of BuildingGreen.com, identifies Tripolymer as a formaldehyde-based foam insulation product that is made, distributed, and installed by companies that are actively trying to hide the fact that formaldehyde is a key intentional ingredient in their insulation product. [REDACTED] writes:

   “Back in the late 1970s and early 1980s [formaldehyde-based foam insulation] was the ultimate bad guy of the insulation world…Canada banned the product, as did the Consumer Products Safety Commission in 1982 in the U.S.—though the latter later reversed the ban a year later.”

   “The UFFI industry shrank to just seven manufacturers by 1981, then two large producers, Borden and Ciba-Geigy, ceased production. But the remaining five companies have continued to produce UFFI, though under different names. Most of those companies have gone to significant effort to avoid any association with UFFI. Among the five manufacturers of UFFI today, you will variously see the material referred to as “injection foam,” “amino foam,” “aminoplast foam,” “tri-polymer foam,” “dry-resin foam,” and various combinations thereof. The only reference you’re unlikely to see is “urea-formaldehyde,” and if you ask manufacturers what the stuff is most will go to great lengths to obfuscate their response.”

   In 1977 the National Bureau of Standards (now the National Institute of Standards and Technologies), a federal agency, issued a landmark report that featured C.P. Chemical’s insights on what can make insulation foam defective and a health threat. The report, “Urea-Formaldehyde-based Foam Insulations: An Assessment of their Properties Performance,” includes a focus on factors that increase the likelihood that the products will off-gas formaldehyde into a home and threaten the health of the residents. In the report, C.P. Chemical, the company that manufactured the Tripolymer / USA Premium Foam that was installed in our Home in November 2013, looms large. The report cites C.P. Chemical in Annex A as one of four major U.S. manufacturers of urea-formaldehyde foam insulation that were consulted extensively in order to write the report. Under section 8 on “Formaldehyde Gas” the report concludes:

   “Formaldehyde odors are caused by the presence of free formaldehyde gas. There are two sources of the formaldehyde. First, formaldehyde is present in the urea-formaldehyde-based resin and may be liberated upon foaming. Secondly, formaldehyde is liberated during hydrolysis of urea-formaldehyde-based foams which may occur under conditions of high temperature and high humidity. Factors which would increase the likelihood of liberating formaldehyde from either source will contribute to an odor problem. The major manufacturers of urea-formaldehyde based foam insulations have outlined a number of these factors which are in general related to improper manufacture or improper application of the resin. The relative significance of these factors is not known. The factors contributing to formaldehyde odor problems as described by the manufacturers [the four manufacturers consulted, including C.P. Chemical] are:

   an excessive amount of formaldehyde in the resin an excessive amount of catalyst in the foaming agent an improper ratio of resin to foaming agent excess foaming agent foaming at high humidities foaming with cold chemicals dry density of the foam exceeding manufacturers’ specifications application against recommended practice; e.g. in an air plenum or ceilings improper use or lack of vapor barriers improper venting on some constructions.”

   The report also found the following: “The foams should not be applied in attics and ceilings. This recommendation is based on properties of the foams dealing with shrinkage, resistance to high temperature and high humidity, and odor. Excessive shrinkage may occur when the foams are applied to an open cavity and dried too rapidly. Preliminary laboratory data indicate degradation of the foams when exposed to high temperature and high humidity. If free formaldehyde gas is present, being denser than air, it may tend to settle in inhabited areas.”

   It is worth noting that MBRS installed several feet of insulation in our ceilings even though we did not request that.

   Key Health Information on Formaldehyde and Phenol:

   Per the Agency for Toxic Substances and Disease Registry (ATSD), part of the Centers for Disease Control and Prevention (CDC), “formaldehyde is a highly toxic systemic poison that is absorbed well by inhalation.” Per OSHA’s formaldehyde fact sheet, “acute exposure is highly irritating to the eyes, nose, and throat and can make anyone exposed cough and wheeze. Subsequent exposure may cause severe allergic reactions to the skin, eyes, and respiratory tract…and long-term exposure to low levels in the air or on the skin can cause asthma-like respiratory problems and skin irritation…”

   Under the “Delayed Effects” section, the Medical Management Guidelines for formaldehyde, published by the CDC’s ATSDR, note that “formaldehyde poisoning can cause permanent alterations of nervous system function, including problems with memory, learning, thinking, sleeping, personality changes, depression, headache, and sensory and perceptual changes.” Per the CPSC’s “An Update on Formaldehyde,” one of the “affected areas/systems” is the neurological system, and “potential adverse health effects” include “impairments in dexterity, memory, and equilibrium.” The EPA’s guide on VOCs’ effects on indoor air quality also lists “memory impairment” as one of formaldehyde’s health effects. Under the section entitled “Follow-up,” the ATSD recommends that “Patients with symptoms of seizures, convulsions, headache, or confusion need to be followed for permanent central nervous system dysfunction with neurobehavioral toxicity testing, with particular attention to problems with memory, personality changes, and perceptual dysfunction.” Per the Toxicology Data Network of the NIH, the odor threshold of formaldehyde is between 0.05-1.0 ppm (or between 50 ppb and 1000 ppb).

   Formaldehyde is classified as a known human carcinogen by the International Agency for Research on Cancer (IARC), the National Institutes of Health (NIH), the CDC, and others. The IARC concluded, based on human exposures in the workplace, that formaldehyde can cause nasopharyngeal cancer (cancer of the nose and throat). It also found limited evidence that formaldehyde may cause other respiratory tract cancers, and a possible link with leukemia. According to the National Cancer Institute (NCI), a component of the NIH, following a series of studies conducted by the NCI, “NCI investigators have concluded that exposure to formaldehyde may cause leukemia, particularly myeloid leukemia, in humans.”

   Both formaldehyde and phenol are listed on the Clean Air Act’s List of Hazardous Air pollutants. In addition, the CDC warns that exposure to formaldehyde “may increase your chances of fertility problems or a miscarriage.”

   Per the Toxicology Data Network of the NIH, “phenol is an acutely hazardous substance due primarily to its toxicity.” Designated as “Poison B” by the U.S. Department of Transportation, phenol containers are labeled “Poison”. Per the CDC, inhalation symptoms for phenol include: Sore throat, burning sensation, cough, dizziness, headache, and nausea; “the substance may have effects on the liver and kidneys.” Per the ATSDR, “short-term exposure to phenol in the air can cause respiratory irritation, headaches, and burning eyes. People who had skin exposure to high amounts of phenol had skin burns, liver damage, dark urine, irregular heart beat, and some died. In animals, breathing air with high levels of phenol resulted in irritation of the lungs. Repeated exposures induced muscle tremors and loss of coordination. Exposure to high concentrations of phenol in the air for several weeks caused paralysis and severe injury to the heart, liver, kidneys, and lungs, and in some cases, death…Phenol has caused minor birth defects and low birth weight in animals generally at exposure levels that also were toxic to the pregnant mothers.” Warning of potential phenol exposure can come from its sickeningly sweet, acrid odor, detectable at 0.047 ppm (or 47 ppb), per the Toxicology Data Network of the NIH.

   Bought from

   MBRS Group LLC

   Bought

   Oct 14, 2013

   Where

   Washington, District of Columbia: Unspecified

   Who was involved

   Age 2, Male

   The reporter’s relation to them

   My Child

   As this report names them

   Brand USA Premium Foam G Series #105, made or sold by C. P. Chemical Company, Inc.

   How badly, in CPSC’s words

   Injury, Seen by Medical Professional

CPSC’s disclaimer

Sources