A covered facility uses methylene bis(phenylisocyanate) (MDI) as an ingredient in the making of packing foam. When blown into foam, the MDI reacts to form a polymer. This foam is then packed with metal parts and shipped from the facility. Is the facility processing or otherwise using the MDI?
The MDI would be subject to the processing threshold, since it is incorporated into a product that is further distributed in commerce. Additional information on threshold determinations can be found in the Revised 1998 EPCRA Section 313 Questions and Answers Document and Directive #7 of the Addendum to 1998 Question and Answer Document.