California to Ban HFC 134a Blow Foaming Agent in Marine Flotation Foam

California Senate Bill SB 1013 prohibits Hydrofluorocarbon (HFC) 134a and other HFCs used as the foam expansion agent in new marine flotation (buoyancy) foam beginning January 1, 2020. The prohibition applies to foam that enters into commerce in California, which includes foam manufactured out of state and brought into California.

In effect, the California regulation takes the EPA Significant New Alternative Policy (SNAP) rule that was vacated by the courts and adopts it word for word in California. NMMA originally questioned California’s authority to regulate products manufactured out of its jurisdiction where the HFC 134a is applied. 

Marine floatation foam is a closed cell foam, which based on a research study conducted by the California Air Resource Board (CARB) in 2011, seven percent of marine buoyancy foam expansion agent is emitted at the time of manufacture, less than two percent is emitted during the use phase, and the remaining approximately 90 percent foam expansion agent (HFC 134a) is emitted at the boat’s end of life. CARB uses the following study by Caleb Management Services to support the rule: https://ww3.arb.ca.gov/research/apr/past/07-312.pdf.

Due to the logistical challenges of building a boat for California only, NMMA recommends that boat builders start discussions with their foam supplier and begin transitioning to a non-HFC blowing agent.  Even if you have no plans for sales in California, Canada will be following California with a similar rule in 2021. Fortunately, suitable U.S. Coast Guard approved alternatives exist. 

If you have any questions, please contact NMMA senior vice president of environmental health and safety, John McKnight at jmcknight@nmma.org.