1. It is assumed in a typical disposal protocol that the Contractor disposing of the foam insulation can identify the chemicals normally used in processing foam, can distinguish foam that is not fully reacted, and has the training and experience necessary to perform this type of disposal work.
  2. Disposal should be performed as required by the local waste management regulations.  Fully-cured or “hardened” foam typically can be disposed of in the same manner you would dispose of other construction wastes, but this should be verified before starting the Work.
  3. Foam that is fully reacted can be collected in filter bags or waste containers compliant with the local waste removal requirements and per the manufacturer’s recommendations for proper disposal as recommended in their “finished product” MSDS.
  4. Foam that is not fully reacted or when un-mixed liquid raw foam chemicals are present, personnel not involved in the disposal should be directed away from the immediate area and those workers designated for the disposal work should put on the appropriate PPE.  Any chemicals and/or “wet” foam material should be handled in the same manner as the manufacturer recommends in the A-side and B-side product MSDSs for disposing of spills or unused raw materials.  Note that these recommendations should generally comply with the United States, the Environmental Protection Agency’s (EPA) Resource Conservation and Recovery Act (RCRA); however, in compliance with the testing methods in the EPA’s Code of Federal Regulations (CFR) for the Protection of the Environment, 40 CFR Part 261, neither the “A” side or “B” side, nor any foam products, would typically be expected to possess the characteristics of a hazardous waste when disposed of in its original purchased form, pMDI is not a listed hazardous waste under RCRA.  States and localities may have additional requirements, so contractors should check and understand federal, state, and local requirements before proceeding with disposal of un-reacted waste components.

Caution: While handling un-reacted waste, all personnel should wear appropriate personal protective equipment (PPE) at all times.