Vol. 58 No. 90 Wednesday, May 12, 1993 p 28094 (Proposed Rule)
Vol. 58 No. 90 Wednesday, May 12, 1993 p 28094 (Proposed Rule)
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ENVIRONMENTAL PROTECTION AGENCY
40 CFR Part 82
[FRL-4625-7]
Protection of Stratospheric Ozone
AGENCY: Environmental Protection Agency (EPA).
ACTION: Notice of proposed rulemaking.
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
SUMMARY: This action proposes the U.S. Environmental Protection
Agency's (EPA) program for evaluating and regulating substitutes
for the ozone-depleting chemicals being phased out under the
stratospheric ozone protection provisions of the Clean Air Act
(CAA). In section 612 of the amended CAA, the Agency is authorized
to identify and restrict the use of substitutes for Class I
and II ozone-depleting substances where other alternatives exist
that reduce overall risk to human health and the environment.
EPA is referring to the program that would provide these
determinations
as the Significant New Alternatives Policy (SNAP) program. The
intended effect of this action is to expedite movement away
from ozone depleting compounds.
In this Notice of Proposed Rulemaking (NPRM), EPA is both
issuing preliminary decisions on the acceptability of certain
substitutes and introducing its plan for administering the SNAP
program. To arrive at determinations on the acceptability of
substitutes, the Agency completed a cross-media analysis of
risks to human health and the environment from use of various
substitutes in different industrial applications. This analysis
is summarized in today's proposal, and covers substitutes in
the refrigeration, foam blowing, solvents cleaning, fire
extinguishing,
tobacco puffing, adhesives, coatings and inks, aerosols and
sterilants sectors. These sectors comprise the principal industrial
sectors that historically consume large volumes of ozone-depleting
compounds.
DATES: Written comments or data provided in response to this
document must be submitted by June 21, 1993. Any data submitted
can be designated as Confidential Business Information. (See
Section V.C. for more detail.). EPA will conduct a public hearing
on this NPRM on May 28, 1993 beginning at 9 a.m. The record
of this hearing will remain open for 30 days after the hearing
for the submission of rebuttals and other supplementary material.
ADDRESSES: Written comments and data should be sent to Docket
A-91-42, Central Docket Section, South Conference Room 4, U.S.
Environmental Protection Agency, 401 M Street, SW., Washington,
DC 20460. The docket may be inspected between 8 a.m. and 3:30
p.m. on weekdays. As provided in 40 CFR part 2, a reasonable
fee may be charged for photocopying. To expedite review, a second
copy of the comments should be sent to Drusilla Hufford,
Substitutes
Analysis and Review Branch, Stratospheric Protection Division,
Office of Atmospheric Programs, Office of Air and Radiation,
401 M Street, SW., 6205J, Washington, DC 20460. Information
designated as Confidential Business Information (CBI) under
40 CFR, part 2, subpart B must be sent directly to the contact
person for this notice. However, the Agency is requesting that
all respondents submit a non-confidential version of their comments
to the docket as well.
The public hearing on this NPRM will be held at the EPA
auditorium
in Washington, DC. Please call the contact person listed below
for details regarding the public hearing.
FOR FURTHER INFORMATION CONTACT: Drusilla Hufford at (202) 233-
9101, Substitutes Analysis and Review Branch, Stratospheric
Protection Division, Office of Atmospheric Programs, Office
of Air and Radiation, Washington, DC.
SUPPLEMENTARY INFORMATION:
I. Overview of This Action
This action is divided into eleven sections, including this
overview:
I. Overview of This Action
II. Background
A. Regulatory History
B. Subgroup of the Federal Advisory Committee
III. Section 612 Program
A. Statutory Requirements
B. Guiding Principles
C. Implementation Strategy
IV. Scope of Coverage
A. Definition of Substitute
B. Who Must Report
V. Information Submission
A. Overview
B. Information Required
C. Submission of Confidential Business Information
VI. Effective Date of Coverage
A. General Provisions
VII. Notice, Review, and Decision-Making Procedures
A. Substitutes Reviewed under SNAP Only
B. Joint Review of New Substitutes under SNAP and TSCA PMN
Program
C. Joint Review of Substitutes under SNAP and FIFRA
D. Shared Statutory Authority with the Food and Drug
Administration
VIII. Petitions
A. Background
B. Content of the Petition
C. Sufficiency of Data
D. Criteria for Evaluating Petitions
E. Petition Review Process
F. Critical Use Exemption Petitions
IX. Preliminary Listing of Substitutes
X. Additional Information
XI. References
Appendix A to the preamble
Class I and Class II Ozone-Depleting Substances
Appendix B to the preamble
Preliminary Listing Decisions
Appendix C to the preamble
Data Confidentiality Claims
II. Background
A. Regulatory History
The stratospheric ozone layer protects the earth from dangerous
ultraviolet (UV-B) radiation. Depletion of stratospheric ozone
allows more UV-B radiation to penetrate to the earth's surface.
Increased radiation, in turn, has been linked to higher incidence
of certain skin cancers and cataracts, suppression of the immune
system, damage to crops and aquatic organisms, and increased
formation of ground-level ozone. Further, increased radiation
can cause economic losses from materials damage such as more
rapid weathering of outdoor plastics. (See 53 FR 30566, August
12, 1988, for more information on the effects of ozone depletion.)
In response to scientific concerns and findings on ozone
depletion, the United States and twenty-three other nations
signed the Montreal Protocol on Substances that Deplete the
Ozone Layer on September 16, 1987. The original agreement set
forth a timetable for reducing the production and consumption
of specific ozone-depleting substances, including CFC-11, CFC-
12, CFC-113, CFC-114, CFC-115, Halon-1211, Halon-1301, and Halon-
2402. EPA implemented the original Protocol through regulations
allocating production and consumption allowances equal to the
total amount of production and consumption granted to the United
States under the Protocol. (See final rule promulgated on August
12, 1988; 53 FR 30566.)
The parties to the Montreal Protocol met in London June 27-
29, 1990 to consider amendments to the Protocol. In response
to scientific evidence indicating greater than expected
stratospheric
ozone depletion, the Parties agreed to accelerate the phase-
out schedules for the substances already controlled by the
Protocol.
They also added phase-out requirements for other ozone-depleting
chemicals, including methyl chloroform, carbon tetrachloride,
and other fully-halogenated chlorofluorocarbons (CFCs).
On November 15, 1990, the President signed the Clean Air
Act Amendments of 1990. Title VI, section 604 of the amended
CAA requires a phase-out of CFCs, halons, and carbon tetrachloride
by 2000, which is identical to the London Amendments, but with
more stringent interim reductions. Title VI also differs from
the London Amendments in mandating a faster phase-out of methyl
chloroform (2002 instead of 2005), a restriction on the use
of hydrochlorofluorocarbons (HCFCs) after 2015, and a ban on
the production of HCFCs after 2030. In Title VI, section 602,
the CFCs, halons, carbon tetrachloride, and methyl chloroform
are defined as Class I substances; HCFCs are referred to as
Class II substances. Appendix A lists the Class I and Class
II substances identified in the CAA.
In addition to the phase-out requirements, Title VI includes
provisions to reduce emissions of Class I and Class II substances
to the "lowest achievable level" in all use sectors and to maximize
the use of recycling and recovery upon disposal (section 608).
It also requires EPA to ban nonessential products containing
ozone-depleting substances (section 610); establish standards
and requirements for the servicing of motor vehicle air
conditioners
(section 609); mandate warning labels on products made with
or containing Class I or containing Class II substances (section
611); and establish a safe alternatives program (section 612).
The development and implementation of the safe alternatives
program under section 612 is the subject of this action.
In October 1991, the National Aeronautics and Space
Administration
(NASA) announced several new findings documenting ozone depletion
over the last decade that was more severe than had previously
been predicted by atmospheric modeling or measurements. In
particular,
NASA found 2.9 per cent ozone depletion over the northern mid-
latitudes over the past decade in summertime-the first time
a trend showing ozone depletion had been detected in the U.S.
during that time of year, when risks from depletion are greatest.
Partly in response to these findings, on February 11, 1992,
President Bush announced an accelerated phase-out schedule for
Class I substances as identified in the CAA. This schedule has
recently been published in the Federal Register (58 FR 15014;
March 18, 1993). The President also ordered an accelerated review
of substitutes that do less damage to the ozone layer than ozone-
depleting compounds. The existence of the expedited phase-out
schedule and the President's directive regarding alternatives
adds a new urgency to EPA's effort to review and list substitutes
for Class I and II substances under section 612.
B. Subgroup of the Federal Advisory Committee
In 1989, EPA organized the Stratospheric Ozone Protection
Advisory Committee (STOPAC) in accordance with the requirements
of the Federal Advisory Committee Act, 5 U.S.C. App. section
9(c). The STOPAC consists of members selected on the basis of
their professional qualifications and diversity of perspectives
and provides representation from industry, academia, Federal,
state, and local government agencies, non-governmental and
environmental
groups, as well as international organizations. Since its
formation,
the STOPAC has provided advice and counsel to the Agency on
policy and technical issues related to the protection of
stratospheric
ozone.
In 1991, the Agency asked STOPAC members to participate in
subgroups to assist in developing regulations under Title VI
of the CAA. EPA established a subgroup of the standing STOPAC
to guide the Agency specifically on development of the safe
alternatives program. To date, the subgroup on safe alternatives
has met twice. At the first meeting in May 1991, subgroup members
reviewed a detailed description of EPA's plans for implementing
section 612. At this meeting, there was general agreement on
the need to issue a request for data to provide the general
public with an opportunity to furnish the Agency with information
on substitutes. The group also agreed on the need to review
substitutes as quickly as possible to avoid any delay in industry's
efforts to phase out of ozone-depleting substances.
At the second meeting of the subgroup, in July 1991, subgroup
members provided EPA with comments on a draft of the Advance
Notice of Proposed Rulemaking (ANPRM), which was prepared in
response to the conclusions of the first meeting. The comments
focused primarily on the draft discussion of EPA's plans for
implementing section 612 and refinements to a list of preliminary
substitutes that the Agency intended to review. Based on comments
received from the subgroup and other offices within EPA, a final
ANPRM was prepared which was published in the Federal Register
on January 16, 1992 (57 FR 1984; January 16).
III. Section 612 Program
A. Statutory Requirements
Section 612 of the Clean Air Act authorizes EPA to develop
a program for evaluating alternatives to ozone-depleting
substances.
EPA is referring to this new program as the Significant New
Alternatives Policy (SNAP) program. The major provisions of
section 612 are:
Rulemaking-Section 612(c) requires EPA to promulgate rules
by November 15, 1992, making it unlawful to replace any Class
I or Class II substance with any substitute that the Administrator
determines may present adverse effects to human health or the
environment where the Administrator has identified an alternative
that: (1) Reduces the overall risk to human health and the
environment,
and (2) is currently or potentially available.
Listing of Unacceptable/Acceptable Substitutes-Section
612(c) also requires EPA to publish a list of the substitutes
prohibited for specific uses. EPA must publish a corresponding
list of acceptable alternatives for specific uses as well.
Petition Process-Section 612(d) grants the right to any
person to petition EPA to add a substance to or delete a substance
from the lists published in accordance with section 612(c).
The Agency has 90 days to grant or deny a petition.
90-day notification-Section 612(e) requires EPA to require
any person who produces a chemical substitute for a Class I
substance to notify the Agency not less than 90 days before
new or existing chemicals are introduced into interstate commerce
for significant new uses as substitutes for a Class I substance.
The producer must also provide the Agency with the producer's
unpublished health and safety studies on such substitutes.
Outreach-Section 612(b)(1) states that the Administrator
shall seek to maximize the use of Federal research facilities
and resources to assist users of Class I and II substances in
identifying and developing alternatives to the use of such
substances
in key commercial applications.
Clearinghouse-Section 612(b)(4) requires the Agency to
set up a public clearinghouse of alternative chemicals, product
substitutes, and alternative manufacturing processes that are
available for products and manufacturing processes which use
Class I and II substances.
B. Guiding Principles
EPA has followed several guiding principles in developing
the SNAP program:
(1) Evaluate substitutes within a comparative risk framework.
The Agency's risk evaluation examines risks of substitutes using
risks from continued use of ozone-depleting compounds as well
as risks associated with other substitutes as reference points.
This evaluation will consider factors such as effects due to
ozone depletion as well as effects due to direct toxicity across
all substitutes. Other risk factors considered include effects
on water and air quality, direct and indirect contributions
to global warming, and occupational health and safety. Where
such effects could be of concern, the evaluation will screen
these effects. However, EPA does not believe that a numerical
scheme producing a single index to rank all substitutes based
on risks is appropriate. A strict quantitative index would not
allow for sufficient flexibility in making appropriate risk
management decisions that consider issues such as the quality
of information supporting the decision, the degree of uncertainty
in the data, the availability of other substitutes, and economic
feasibility.
(2) Do not require that substitutes be risk-free to be
considered
"safe". Section 612(c) requires the Agency to publish a list
of safe alternatives where the Agency has identified unacceptable
substitutes. The Agency interprets this as a mandate to identify
substitutes that reduce risks when compared to use of Class
I or II compounds or to other substitutes for Class I or II
substances, rather than a mandate to list as acceptable only
those substitutes with zero risks. In keeping with this
interpretation,
the Agency believes that a key goal of the SNAP program is to
promote the use of substitutes for Class I and II chemicals
that minimize risks to human health and the environment relative
to other alternatives. In some cases, this approach may involve
designating a substitute as acceptable even though the compound
may be toxic, or pose other environmental risk of some type.
(3) Restrict only those substitutes that are significantly
worse. As a corollary to the point above, EPA does not intend
to restrict a substitute if it poses only marginally greater
risk than another substitute, all things considered. Drawing
fine distinctions concerning the acceptability of substitutes
would be extremely difficult given the variability in how each
substitute can be used within a specific application and the
resulting uncertainties surrounding potential health and
environmental
effects. The Agency also does not want to intercede in the market's
choice of available substitutes, unless a substitute has been
proposed or is being used that is clearly more harmful to human
health and the environment than other alternatives.
(4) Evaluate risks by use. Section 612 requires that substitutes
be evaluated by use. Environmental and human health exposures
can vary significantly depending on the particular application
of a substitute. Thus, the risk characterizations must be designed
to represent differences in the environmental and human-health
effects associated with diverse uses.
(5) Provide the regulated community with information as soon
as possible. The Agency recognizes the need to provide the
regulated
community with information on the acceptability of various
substitutes
as soon as possible. Given this need, EPA has decided to expedite
the review process by conducting initial risk characterizations
for the major substitutes now known to the Agency. The results
of the risk characterizations will be used, as discussed in
the previous section, to propose determinations regarding the
acceptability of the substitutes.
(6) Do not endorse products manufactured by specific companies.
While the goal of the SNAP program is to identify acceptable
substitutes, the Agency will not issue company-specific product
endorsements. In some cases, the Agency may base its analysis
on data received on individual products, but the addition of
a substitute to the approved list based on that analysis does
not represent a preference for that company's product over
comparable
products offered by other manufacturers.
(7) Defer to other environmental regulations when warranted.
In some cases, EPA and other federal agencies have developed
extensive regulations under other statutes or other parts of
the CAA that address any potential cross- or inter-media transfers
that may result from the use of alternatives to Class I and
II substances. For example, ceasing to use an ozone-depleting
compound may in some cases entail increased use of chemicals
that increase tropospheric air pollution. These chemicals, such
as volatile organic compounds (VOCs) or hazardous air pollutants
(HAPs), are already regulated under other sections of the CAA,
and determinations under the SNAP program will take these existing
regulations into account. Where necessary, the Office of Air
and Radiation will confer with other EPA program offices or
federal agencies to ensure that any regulatory overlap is handled
efficiently.
C. Implementation Strategy
Implementation of the SNAP program is directed towards
fulfilling
the general policy contained in section 612 of identifying
substitutes
that can serve as replacements for ozone-depleting substances,
evaluating their effects on human health and the environment,
and encouraging the use of those substitutes believed to present
low risks to human health and the environment. Implementation
of this policy involves three key activities. The first is to
develop, promulgate, and administer a regulatory program for
identifying and evaluating substitutes. The second activity
is to undertake a review of the existing substitutes based on
criteria established for the program and then to publish a list
of acceptable and unacceptable substitutes by application. The
third activity is to review additional substitutes as they are
developed to allow their timely introduction into the marketplace.
To expedite implementation of the SNAP program, EPA has
developed
not only a process for examining the alternatives, as discussed
in today's proposal, but has completed an initial analysis of
many key substitutes based on the criteria being proposed. Section
IX summarizes the results of this initial assessment. More detail
on the steps leading up to today's proposal and the anticipated
implementation of the SNAP program is given below.
1. Issue ANPRM and Request for Data
In January of this year, EPA published in the Federal Register
an Advance Notice of Proposed Rulemaking (ANPRM) and Request
for Data (57 FR 1984; January 16, 1992). The ANPRM described
in general terms EPA's plans for developing the SNAP program
and solicited public comment on the Agency's planned approach.
The ANPRM also included an appendix listing substitutes that
the Agency planned to include in its initial substitute
determinations.
The ANPRM invited industry to submit information on these
substitutes
and to identify additional alternatives to be considered in
the SNAP program.
The Agency received approximately one hundred comments from
industry, trade groups, and other federal agencies. These comments
contained information on potential substitutes for ozone-depleting
chemicals, as well as comments on the SNAP program as described
in the ANPRM. In some cases, the information provided on
substitutes
did not contain sufficient data for the Agency to immediately
incorporate these alternatives into the risk characterizations.
The Agency is working now to gather additional information on
these alternatives to ensure that they can be included in the
list of reviewed substitutes in the final rule.
Comments on the SNAP program itself focused primarily on
issues such as effective dates, small uses, the desirability
of assured minimum periods of use for substitutes, how mixtures
will be handled by the SNAP program, and how specific the lists
of "acceptable" and "unacceptable" substances will be. These
comments, and the Agency's response to them, are addressed in
later sections of today's proposal.
2. Develop Preliminary Determinations on Substitutes
To arrive at its SNAP determinations, the Agency has been
collecting and evaluating information on substitutes since the
President's signing of the Clean Air Act Amendments in November
1990. In some cases, this information has been furnished directly
by companies manufacturing, selling, or using the substitutes.
In others, the Agency has initiated its own studies to
characterize,
for example, worker exposures where toxicity was anticipated
to present a potential problem. Response to the request for
data in the January ANPRM augmented the Agency's available data,
both by helping to identify substitutes that merit consideration
in the SNAP program and by providing additional information
on substitutes already under consideration.
There are, however, still omissions in the Agency's list
of substitutes under consideration. In some cases, engineering
and use profile data are missing; in others, information on
potential market applications may not yet be available. The
Agency today is repeating the data request issued in the ANPRM,
and is encouraging companies that manufacture substitutes to
provide information.
3. Publish Proposed SNAP Process and Proposed Determinations
This NPRM represents the third implementation step, which
is to describe the proposed structure and process for administering
the SNAP program and to propose determinations on the acceptability
of key substitutes. The notice also contains the proposed
regulatory
language that will serve as the legal basis for administering
and enforcing the SNAP program.
EPA believes that notice-and-comment rulemaking procedures
are necessary to establish these regulations governing the SNAP
program. EPA further believes that rulemaking is also required
to place any substance on the list of prohibited substances,
to list a substance as acceptable only under certain conditions,
or to remove a substance from either the list of prohibited
or acceptable substitutes. EPA requests comment, however, on
the need to remove a substance from the list of acceptable
substitutes
through rulemaking.
EPA does not believe that rulemaking procedures are required
to list alternatives as acceptable with no limitations. Such
listings do not impose any sanction, nor do they remove any
prior license to use a substance. Consequently, once this rule
is promulgated, EPA will be adding substances to the list of
acceptable alternatives without first requesting comment on
new listings.
Because EPA's SNAP regulations are not yet final, however,
manufacturers and users may have additional information that
could help EPA in making this first round of SNAP determinations.
Recognizing this, EPA has elected to propose the list of acceptable
alternatives identified in this notice, and to request public
comment on these listings. This should not in any way be taken
as a precedent for future listings of acceptable substitutes.
Once the SNAP program regulations are finally adopted and EPA
has received SNAP notices from manufacturers and users, EPA
will add substances to the list of acceptable substitutes without
notice-and-comment procedures.
Any approvals or prohibitions on substitutes described in
this notice are preliminary and will not be final until the
SNAP program is promulgated. Even though they are preliminary,
the Agency is issuing the SNAP decisions now because many companies
are awaiting Agency guidance before switching out of
ozone-depleting
substances. The Agency believes that by publishing these
preliminary
determinations, it has met the intent of section 612 to inform
the public of Class I and II substitutes believed to present
minimal risks to human health and the environment. Moreover,
given the accelerated pace of the phase-out of Class I compounds,
the Agency wants to encourage the earliest possible shift to
the alternatives identified on today's list of acceptable
substitutes.
The Agency may revise these decisions in the future as it
reviews additional substitutes and receives more data on
substitutes
already covered by the program. However, EPA expects future
changes to the SNAP lists to be minor, and thus not to represent
an undue burden on the regulated community. The principal types
of changes the Agency expects to make in the future would be
to add new substitutes or sectors to the lists, rather than
to change a substitute's approval status. Further, once a
substitute
has been finally placed on either the acceptable or the
unacceptable
list, EPA will conduct notice-and-comment rulemaking to
subsequently
remove a substitute from either list, as described below in
Section VII. Again, the Agency requests comment on whether formal
rulemaking is necessary to remove a substance from the acceptable
list.
4. Issue Final Regulation
As discussed above, the final rule will promulgate the SNAP
process and the first set of determinations on SNAP substitutes.
The final regulation will address comments that the Agency receives
on today's NPRM, and will also incorporate any further data
on substitutes that are received during the comment period.
5. Maintain and Update SNAP Determinations
Three mechanisms exist for revising or expanding the list
of SNAP determinations published in the final regulation. First,
under section 612(d), the Agency will review and either grant
or deny petitions to add or delete substances from the SNAP
list of acceptable or unacceptable alternatives. Section VIII
of this notice presents EPA's proposed method for handling
petitions.
The second means of revising or expanding the list of SNAP
determinations is through the notifications, which must be
submitted
to EPA 90 days before introduction of a chemical into interstate
commerce for significant new use as an alternative to Class
I or Class II substances. These 90-day notifications are required
by section 612(e) of the CAA and by EPA regulations today proposed
to be issued under sections 114 and 301 of the Act to implement
section 612(c). In Section VII, this notice discusses the Agency's
proposed approach for processing these notifications, including
a proposed strategy for integrating the SNAP notifications with
other chemical review programs already being implemented by
EPA under authorities provided in the Toxic Substances Control
Act (TSCA) and the Federal Insecticide, Fungicide, and Rodenticide
Act (FIFRA). Other parts of this action also explain how the
Agency will address the overlap between SNAP regulations and
regulations issued under other titles of the Clean Air Act.
Finally, the Agency believes that section 612 authorizes
it to initiate changes to the SNAP determinations independent
of any petitions or notifications received. These amendments
can be based on new data on either additional substitutes or
on characteristics of substitutes previously reviewed.
6. Perform Outreach and Operate Clearinghouse
Outreach and the clearinghouse comprise the technical assistance
component of the SNAP program. The purpose of this effort is
to provide information for companies to use in selecting among
the approved substitutes. Section VII.A.3.f. describes the Agency's
proposed approach for establishing the clearinghouse and performing
outreach.
IV. Scope of Coverage
A. Definition of Substitute
1. Statutory Language
Based on the language of section 612(a) of the CAA, the Agency
is proposing in the SNAP program to define a "substitute" as
any chemical, product substitute, or alternative manufacturing
process, whether existing or new, that could replace a Class
I or Class II substance. While subsequent subsections of section
612 refer only to "substitute substances" or "substitute
chemicals,"
EPA is proposing a definition that interprets these provisions
as incorporating the general definition of substitute presented
in 612(a). The Agency believes that this definition is consistent
with the overall intent of section 612 and is necessary to enable
EPA to identify and analyze the universe of substitutes for
Class I and II substances.
Section 612(c) prohibits users from replacing Class I or
II substances with any substitute substance which the Administrator
determines may present adverse effects to human health and the
environment, where the Administrator has identified an alternative
to such replacement that (1) reduces overall risk to human health
and the environment, and (2) is currently or potentially available.
EPA believes that in addition to authorizing the Agency to ban
the use of a given substitute substance, section 612 confers
the legal authority to allow the use of a substance only under
certain use conditions, such as with mitigation measures. EPA
only intends to use this authority where a viable substitute
exists, but would otherwise have to be disallowed because of
risk associated with its uncontrolled use. EPA anticipates imposing
use conditions only in the rare instances where clear regulatory
gaps exist, and where an unreasonable risk exists in the absence
of any condition.
In imposing conditions, EPA does not intend to preempt other
regulatory authorities, such as those exercised by the Occupational
Safety and Health Administration (OSHA), or other standard setting
bodies. Rather, EPA hopes to fill existing regulatory gaps during
the interim period of substitution away from ozone-depleting
compounds, and provide the needed margin of protection to human
health and the environment until other regulatory controls or
standards are developed under appropriate authorities. Once
existing gaps are filled, EPA will rescind any conditions which
have become redundant. The mechanism for informing the public
of this change will be the quarterly Federal Register notices
updating the status of the SNAP lists. These are discussed further
below in section VII.A.
The Agency, however, requests comment on the general issue
of the need for use conditions. In particular, EPA requests
comment on whether section 612 in fact confers upon the Agency
the authority to go beyond the listing of acceptable and
unacceptable
alternatives and to set such use conditions. Further, EPA requests
comment on the capability and practicality of EPA enforcing
use conditions which may, for example, closely resemble workplace
safety standards, which are typically within the enforcement
purview of other regulatory authorities.
EPA also requests comment on whether, when an unreasonable
risk might exist due to a gap in regulatory coverage, the
appropriate
means to address these risks is through the existing regulatory
framework of other federal authorities. For example, rather
than using EPA's use conditions to address existing gaps in
workplace safety standards, EPA could refer the matter to the
appropriate OSHA authorities and request appropriate action
to mitigate an otherwise unreasonable risk.{1}
³{1} 29 U.S.C. 654, OSHA General Duty Clause, requires
³that each employer "shall furnish to each of his
employees
³employment and a place of employment which are free
from
³recognized hazards that are causing or are likely to
³cause death or serious physical harm to his employees.
³* * *"
Alternatively, where the length of time required to address
a problem under another authority may be unacceptably long given
the nature of the risk, there may be cases in which EPA would
simply consider unacceptable the use of a given substitute,
pending the development of a regulatory framework to control
the risk it poses in its use as a substitute for an ozone-depleting
compound.
Section 612(e) makes clear that a chemical can be a substitute
whether it is existing or new. Also, the language in section
612(c) clearly states that a substitute may be "currently or
potentially available." The Agency is proposing to define as
potentially available any alternative that the Agency reasonably
believes to be technologically feasible and economically viable,
even if not all testing has yet been completed and it is not
yet produced and sold in commercial quantities. EPA solicits
comment on this approach.
The language included in section 612 is written broadly to
allow for an all-encompassing evaluation of substitutes that
will be introduced as replacements for ozone-depleting chemicals.
However, additional clarification is presented below to further
explain the Agency's definition of a "substitute" based on section
612.
2. Additional Clarification
a. Chemicals Already Listed as "Existing" under TSCA. Many
commenters have expressed the view that any compound already
existing (e.g., listed on the TSCA inventory, either through
the grandfathering provisions or by undergoing new-chemical
review under section 5 of TSCA) is not subject to review under
section 612. Nothing on the face of section 612(c), however,
suggests that any "new" compound can be considered a substitute
for purposes of that subsection. Moreover, section 612(e)
explicitly
requires producers of chemicals, both "new and existing," to
notify the Agency before introducing such chemicals into interstate
commerce for significant new uses as Class I alternatives. In
addition, section 612(c) requires the Agency to produce lists
of acceptable and unacceptable substitutes, without regard to
the status of each chemical, whether new or existing.
These interrelated provisions of section 612 serve as the
basis for the Agency's belief that all substitutes, whether
"new or existing" chemicals, are subject to SNAP review. This
regulatory purview would thus necessarily extend to those chemicals
already listed on the TSCA inventory. EPA believes SNAP review
is critical given the differing statutory objectives of TSCA
and the CAA, and the new and expanded applications of many existing
chemicals as Class I and Class II replacements, which could
alter existing release and exposure profiles.
b. Expanded Use of Existing Alternatives. There has also
been some question regarding whether an existing alternative
already being sold commercially (e.g., use of semi-aqueous cleaners
in the electronics industry) would be subject to review under
section 612. The Agency believes that they would. Because of
the phase-out, uses of existing substitutes can be expected
to increase significantly beyond current consumption. This
increased
use could translate into greater releases and risks, and existing
substitutes are therefore subject to SNAP approval where their
use could significantly expand to new users or product lines.
Users should note that preliminary SNAP determinations discussed
in Section IX of this action demonstrate that with few exceptions,
all substitutes already on the market meet the conditions for
SNAP approval.
c. Authority to Review Substitutes for Class II Compounds.
Section 612(c) authorizes the Administrator to prohibit the
use of substitutes for Class II, as well as Class I substances,
and requires the Agency to compile lists of substitutes for
Class II as well as Class I compounds upon making the requisite
findings. This is in part because of the considerable overlap
in sectors that use Class I and II substances. More importantly,
this mirrors the statute's general emphasis on moving away from
Class I compounds in a way that does not create new and unintended
environmental problems. Clearly, for the same reasons Class
I substitutes require review, Class II substitutes should also
be reviewed.
To obtain the data necessary to analyze Class II substitutes,
the Agency is proposing to use statutory authority provided
in sections 114 and 301 of the CAA with 612(c). These sections
together authorize the Administrator to promulgate regulations
needed to require companies to provide information EPA may
reasonably
require to identify acceptable and unacceptable substitutes
for Class II substances. EPA proposes to exercise this authority
so that Class I and Class II substitutes are subject to the
same information reporting requirements and listing process.
d. Designation of Class I and Class II Chemicals as Substitutes.
EPA believes that the review authority under section 612 extends
also to use of Class I and Class II chemicals as substitutes,
even though these chemicals are subject to the phase-out provisions
of the CAA. While some comments received by the Agency in response
to the ANPRM question EPA's authority under section 612 to review
Class I and Class II chemicals as substitutes (e.g., methyl
chloroform used to replace CFC-113), it is clear that these
compounds can be used as substitutes for other Class I and II
substances in certain applications. Since section 612 authority
extends to "any" substitutes, they are subject to review under
the SNAP program just as any other substitute. Given the potential
for the Class I and Class II chemicals to continue depleting
stratospheric ozone and thus affect human health and the
environment,
a close examination of these alternatives in the context of
both their effect on the environment and the availability of
other substitutes for particular uses is warranted under section
612.
e. Alternative Substances and Manufacturing Processes. Section
612(c) broadly charges EPA to identify alternatives to ozone-
depleting substances. For example, EPA believes that alternative
substances can include no-clean fluxes for solvent cleaning,
substituting for solvents using Class I or II compounds. Several
commenters disagree with this interpretation of the language
in section 612. However, EPA believes it appropriate to consider
substitute substances in its reviews under the SNAP program,
since many of these alternatives are viable substitutes and
could reduce overall risks to human health and the environment.
Similarly, new production techniques and/or processing equipment
are important developments that can minimize environmental
releases.
Accordingly, alternative manufacturing processes will also be
examined under section 612 in the context of use and emissions
of substitutes. Section 612's reference to "alternative", instead
of "alternative substance", or "alternative chemical", implies
a statutory intent that "alternative" be read broadly.
EPA will encourage, where appropriate, alternative processes
that reduce environmental and human health effects. In many
applications, reliance on alternative processes and/or equipment
may be associated with the use of substitute chemicals. In these
instances, EPA encourages the filing of joint submissions where
information is provided by both the chemical manufacturer and,
for example, an equipment manufacturer. Such joint filings will
provide the most comprehensive data on an alternative and its
effect on human health and the environment.
f. Feedstock Substitutes. Other commenters have questioned
the applicability of section 612 to substitutes that could replace
Class I chemicals which are used solely as intermediates in
the production of other chemicals. To the extent that any feedstock
substitutions occur, the Agency believes that there will be
no incremental risk to human health and the environment. This
is because intermediates are used as inputs in production of
other compounds, and as a result are largely consumed in the
chemical manufacturing process. For instance, in analyzing uses
of carbon tetrachloride as a feedstock, the Agency determined
that greater than 99 per cent of this chemical was consumed
in the production process. The Agency is therefore proposing
that feedstock substitutes be exempt from reporting and review
under section 612.
g. Second-Generation Substitutes. A key issue is whether
there exists a point at which an alternative should no longer
be classified as a Class I and Class II substitute as defined
by section 612. The Agency believes that as long as Class I
and Class II chemicals are being used, any first-generation
substitute designed to replace these applications is subject
to the regulatory provisions implemented under section 612.
However, the Agency is proposing today that second-generation
replacements, if they are replacing non-ozone depleting first-
generation alternatives, are exempt from reporting requirements
under section 612. Other regulatory programs (e.g., other sections
of the CAA, or section 6 of TSCA) exist to ensure protection
of human health and the environment in these situations.
Several commenters agreed with the need to exempt second-
generation substitutes. On the other hand, EPA is proposing
that second-generation substitutes replacing first-generation
substitutes that deplete stratospheric ozone (e.g., HCFCs) should
be bound by the same notification and review requirements under
section 612 as first-generation substitutes.
For example, if a hydrofluorocarbon (HFC) is introduced as
a first-generation refrigerant substitute for either a Class
I (e.g., CFC-12) or Class II chemical (e.g., HCFC-22), it is
subject to review and listing under section 612. However, future
substitutions to replace the HFC would be exempt from reporting
under section 612 because the first-generation alternative did
not deplete stratospheric ozone. However, if a Class I (interim
only) or Class II chemical is used as a first-generation substitute
(e.g., use of HCFC-141b as a transitional replacement in foam
blowing), the second-generation substitute is still subject
to review under section 612 because it is replacing a Class
I or II chemical.
h. Formulation Changes Accompanying the Use of Class I and
Class II Substitutes. In general, the Agency believes that changes
in formulation needed to accommodate replacement of Class I
and II compounds are not subject to the provisions of section
612. Such auxiliary changes may be necessary, for example, when
a new blowing agent in foam blowing necessitates the replacement
of the catalyst formerly used in conjunction with the Class
I blowing agent.
This position was also supported by comments received in
response to the ANPRM. However, if the potential SNAP notice
submitter has reason to believe that such changes will
significantly
influence the environmental and human health risk characteristics
associated with the use of any Class I or Class II substitute,
this must be communicated to the Agency. Alternatively, if EPA
has reason to suspect such concerns may exist, it may request
the review of any such changes in formulation in connection
with review of substitute compounds.
B. Who Must Report
1. General Provisions
As required by section 612(e), anyone who produces a substitute
for a Class I substance must provide the Agency with that person's
unpublished health and safety studies on the substitute, as
well as notify the Agency at least 90 days before introducing
the substitute into interstate commerce for significant new
use as an alternative. Also, as discussed in section IV.A.2.c
of this notice, pursuant to sections 114, 301 and 612(c), producers
of Class II substitutes must abide by the same reporting
requirements.
Under the authority of sections 114, 301(a) and 612(c), EPA
is proposing that in certain cases, formulators or end-users
of substitutes could be considered to be producers and would
therefore be subject to reporting requirements. This approach
is discussed in the following section, IV.A.2.j.(2). To analyze
alternative substitutes under section 612(c), the Agency finds
it necessary under section 301(a) to require all producers of
substitutes, whether a chemical manufacturer, formulator, or
end-user, to submit information under section 114 describing
such substitutes. With respect to substitutes for both Class
I and II substances, EPA needs all of the types of information
described below, not just health and safety studies. This is
needed to allow EPA to fully analyze the overall risks to human
health and the environment presented by alternative substitutes,
as required by section 612(c).
2. Designated Submitters
a. Chemical Manufacturers. Chemical manufacturers making
a substitute for direct commercial sale are required to notify
the Agency about the existence of that substitute. This requirement
is especially applicable to chemical manufacturers that have
developed new compounds for specific, targeted uses as substitutes
for Class I or II substitutes. For instance, if a chemical
manufacturer
intends to market a new chemical as a substitute foam blowing
agent to companies that manufacture insulation products, that
manufacturer would be required to notify the Agency about the
existence of the substitute. The reporting requirement would
also apply to chemical manufacturers that intend to sell an
existing chemical to a particular user group.
b. Formulators. A formulator is a person or organizational
entity engaged in the preparation or formulation of a substitute,
after chemical manufacture of the substitute or its components,
for distribution or use in commerce. Formulators usually only
sell substitutes based on existing chemicals, since they do
not ordinarily possess chemical manufacturing capabilities.
Chemicals used in such substitutes are frequently in common
use and have already been approved for general use through other
chemical review programs such as under TSCA or FIFRA.
However, to the extent that these formulators can be considered
to be directly responsible for production of the substitute,
for example by offering a tailored formulation or blend for
an industrial cleaning process, these formulators would be subject
to reporting requirements as outlined in this proposal. In such
cases, the formulator is best suited in the manufacture-to-use
chain to present information on how substitutes based on existing
chemicals are or could be used.
In cases where the manufacturer of a chemical is also the
formulator, the manufacturer would then be responsible for meeting
reporting requirements on the chemical. Similarly, if an end-
user has developed a process to replace an ozone-depleting
compound,
this end-user would be required to provide EPA with information
on the substitute.
The simplest approach to allocating responsibility for reporting
requirements would be to place the reporting burden in all cases
on chemical manufacturers. However, the Agency believes that
the approach outlined above provides the best correlation between
burden for reporting and benefit from securing approval for
a substitute. For instance, it would be inappropriate to require
a manufacturer of a chemical in wide-spread industrial use to
report on every possible application for that chemical as a
substitute. The Agency requests comment on this aspect of the
proposed reporting requirements.
c. End-users. In general, end-users of substitutes will not
be obligated to meet the reporting requirements discussed in
this proposal, except in rare cases where the end-user and the
producer of the substitute are one and the same company and
the company intends to sell that substitute into inter-state
commerce. While the Agency expects that this situation will
occur only seldom, it has already received notice from several
large companies who developed a substitute for use in their
own manufacturing process and subsequently decided to offer
that substitute for commercial sale. The Agency hopes that
evaluating
and listing such substitutes will help provide other potential
end-users with information on viable substitutes, rather than
stifling research and development innovations by end-users.
The Agency solicits comment on this aspect of today's proposal.
3. Exemptions from Reporting
The Agency has identified several situations in which
notification
under the provisions of section 612(e) will not be required.
These exemptions from reporting are discussed below.
a. Substitutes Already Listed by EPA. As part of today's
proposal, the Agency has already completed a preliminary review
of several Class I and Class II alternatives and has proposed
that these substitutes be either acceptable or unacceptable.
In preparing these proposed determinations, the Agency evaluated
information either on file or supplied in response to the ANPRM
published in the Federal Register on January 16, 1992. The
preliminary
substitutes list and the supporting risk screen are described
in more detail in Section IX. No submission is needed for those
substitutes and applications already proposed as acceptable
in today's NPRM.
Any specific comments on the proposed substitute determinations
found in this action should be provided to the Agency, along
with any supporting information, during the comment period.
If information is not received by the Agency during the comment
period, a formal submission to add substitutes will be required
once the final rule is promulgated.
b. Small Sector and Application Use. Most ozone-depleting
substances have been or are currently used in large industrial
sectors such as refrigeration or fire extinguishing. However,
there are also numerous small uses of Class I or II substances
that fall outside of these major use sectors. Most of these
small uses of ozone-depleting compounds are for solvents in
applications other than industrial cleaning operations, such
as solvents used as book preservers, drilling and machining
coolants, extraction or bearer media, or mold release agents.
While small-use applications for Class I and Class II compounds
are varied and numerous, in the aggregate these small uses do
not contribute substantially to ozone depletion. The Agency
estimates that across all sectors, including the solvents sector,
these varied but small volume uses comprise in aggregate at
most seven per cent of total U.S. consumption of ozone-depleting
substances.
Because the potential for adverse effects on human health
and the environment is related to the aggregate amount of ozone-
depleting material consumed in an end-use or sector, the Agency
proposes to focus the SNAP determinations on large-volume
applications
in major use sectors. Given the breadth of EPA's required "overall"
risk assessment, the imposition on small sectors, and on small
uses within any sector, of a full SNAP submission for each small
use seems unjustified by the potential for risk posed by these
small uses.
Moreover, a key policy interest of EPA's in designing and
implementing the SNAP program is promoting the quickest possible
shift from the phase-out compounds into alternatives posing
lower overall risk. The speed and orderliness of this shift
depends in part on clear early determinations from EPA on the
acceptability of key substitutes. Focusing the SNAP program
on all possible substitutes in every conceivable use could diminish
EPA's ability to provide an early and clear message on those
substitutes which constitute the bulk of the problem SNAP is
aimed at ameliorating.
Accordingly, eight major industrial use sectors are covered
in today's proposal. They are refrigeration, foam blowing, fire
extinguishing, solvent cleaning, adhesives, coatings, and inks,
aerosols, sterilization, and tobacco puffing. Analysis of
substitutes
in a ninth sector, pesticides, will be completed, and the resulting
decisions will be added to the SNAP determinations in the final
rule. EPA does not plan to add sectors other than the nine
principal
sectors listed above to the formal analyses performed under
SNAP, unless the Agency in future receives additional data
indicating
that inclusion of additional sectors is warranted based on the
potential for high risks to human health and the environment.
Further, the Agency does not plan individual analyses of
all small uses within major industrial sectors. Specifically,
EPA is today proposing not to review any uses of substitutes
of less than 10,000 lbs per year within a sector as defined
in the SNAP determinations. Companies producing, formulating
or using substitutes for ozone-depleting compounds in annual
quantities under 10,000 lbs per year need not notify EPA of
their activities under SNAP. However, the Agency encourages
companies to maintain documentation describing the basis for
their view that any substitute being used meets this small use
definition. This documentation could be necessary in the event
the Agency receives a petition to add such substitutes to its
evaluation.
The Agency's decision to focus the SNAP program on high-volume
sectors does not imply the complete absence of any risk from
use of substitutes in small use applications. Instead, the Agency
believes that focusing the listing decisions on the largest
sectors and uses will allow the Agency to target its regulatory
efforts to those applications that offer the maximum risk reduction
potential. If other sectors are subsequently added to the Agency's
analysis, the Agency will provide notice in the Federal Register
of the need to furnish the Agency with data on substitutes.
The Agency requests comment on this approach to small sectors
and small uses within all sectors of substitutes for
ozone-depleting
compounds. In particular, EPA requests comment and data on risks
associated with small sector and small volume uses.
c. Test Marketing. Use of alternatives for the sole purpose
of test marketing is exempt from any reporting requirements
under section 612. However, once a company decides to sell an
alternative as a Class I or II substitute, it must provide the
Agency with notification at least 90 days prior to the introduction
of the substitute into interstate commerce for significant new
use as a substitute for a Class I or Class II chemical.
For new substitute chemicals that are being test marketed,
the producer must abide by the provisions of section 5(h)(1)
of TSCA, which authorizes the EPA, upon application, to grant
exemptions from TSCA-reporting requirements, provided that test
marketing will not present an unreasonable risk to human health
or the environment. When submitting the TSCA application, it
would also be advantageous if the producer would notify EPA's
Office of Air and Radiation; however, such notification is not
mandated under section 612.
d. Research. Substitutes manufactured or imported solely
for research and development are exempt from notification
requirements
under section 612. Several commenters, including Federal agencies
involved in research on CFC-related substitutes, support this
exemption. Amounts used in research are assumed to be the minimum
necessary for reasonable scientific experimentation. For new
chemicals, the provisions of section 720.36 of the PMN rule
(40 CFR Part 720) are in effect. The Agency solicits comment
on appropriate use levels to allow in research applications.
e. Second-Generation Substitutes. As discussed in section
IV.A.2.h., substitutes replacing first-generation alternatives
that are not ozone-depleting chemicals are exempt from any
additional
reporting and review under section 612. However, if the second-
generation substitute is replacing a compound that contributes
to stratospheric ozone depletion (e.g., a HCFC), information
must be submitted to the Agency for review under the SNAP program.
f. Formulation Changes. As discussed in section IV.A.2.i.,
the Agency is proposing that changes in formulation that accompany
the use of substitutes for Class I and Class II substances need
not be reviewed under section 612. The Agency believes that
other regulatory mechanisms (e.g., TSCA) are available for
examining
and controlling, as needed, any adverse environmental and human
health effects associated with subsequent formulation
modifications.
However, the manufacturer overseeing the formulation change
is required to notify the Agency if these modifications may
significantly influence the environmental and human health risk
characteristics associated with the Class I or Class II substitute.
Also, the Agency reserves the right to examine formulation changes
if a problem appears to exist.
g. Substitutes Produced for Export. Substitute manufacturers
producing solely for export and use by non-U.S. entities outside
the U.S. are not subject to the requirements of section 612.
EPA believes that its authority under section 612 extends only
to use of substitutes in areas under the jurisdiction of the
United States government, regardless of their place of manufacture.
This exemption does not apply to substitutes introduced as
replacements
for Class I and II chemicals offered for sale or use at offshore
U.S. installations (e.g., U.S. military bases located in foreign
countries) that are subject to the legal provisions of section
612, since 612(c) applies to use rather than to manufacture
of substitutes.
h. Substitutes Used as Feedstock. The Agency is proposing
to exempt substitutes used as feedstock from the reporting and
review requirements of section 612. Because feedstock chemicals
are largely consumed as intermediates, except for trace amounts,
the Agency does not believe that such substitutions would cause
any increase in ozone depletion or other adverse effects on
human health and the environment.
V. Information Submission
A. Overview
To develop the list of unacceptable and acceptable substitutes
as required by section 612(c), the Agency must assess and compare
the "overall risks to human health and the environment" posed
by use of substitutes, and this assessment must be performed
in the context of particular applications. This "overall"
examination
will consider a wide range of health and environmental factors.
In the section that follows, the Agency presents information
that will be required in the SNAP program notice to help EPA
evaluate Class I and Class II substitutes. A copy of the
notification
form can be obtained from the SNAP coordinator at the address
listed in the beginning of this action.
B. Information Required
1. Name and description of the substitute. The substitute
should be identified by its (1) commercial name, (2) chemical
name, (3) trade name(s), (4) identification numbers (e.g., Chemical
Abstract Service (CAS) registry, National Institutes of
Occupational
Safety and Health Registry of Toxic Effects of Chemical Substances
(NIOSH RTECS), EPA hazardous waste identification number, OHM-
TADS, DOT/UN/NA/IMCO shipping, HSDB, National Cancer Institute
(NCI), (5) chemical formula, and (6) chemical structure.
2. Physical and chemical information. Key properties needed
to characterize the substitute are: molecular weight; physical
state; melting point; boiling point; density; odor threshold;
solubility; partition coefficients (Log Kow, Log Koc); vapor
pressure; and Henry's Law Constant.
3. Substitute applications. Identification of the applications
in which the substitutes are likely to be used is required.
It is essential to provide a complete list of potential uses
because the substitute listing required by section 612(c) is
specific to application.
4. Process description. For each application identified,
the Agency requires descriptive data on processing, including
in-place pollution controls. Such information will be used to
characterize workplace and environmental releases and exposures.
5. Ozone depletion potential. The predicted ozone depletion
potential (ODP) of substitute chemicals is required. The submitter
should also provide sufficient supporting documentation-either
a citation or the background information used to develop the
ODP. For purposes of calculating ODP, the Agency recommends
the methodology used in the most recent Scientific Assessment
of Ozone Depletion: 1991, which was prepared for the United
Nations Environment Programme. [1]
6. Global warming potential. The Agency requires data on
the total global warming potential (GWP) of the substitute in
its particular application (e.g., as a refrigerant, foam blowing
agent, etc.). The total GWP considers both direct and indirect
effects. Direct effects means the direct global warming effects
of using a substitute. The Agency is requesting that all GWPs
be referenced to CO2 using the methodology recommended by the
Intergovernmental Panel for Climate Change (IPCC).[2] Indirect
effects explicitly consider the effect on global warming arising
from changes in energy consumption associated with the use of
a substitute (e.g., an alternative refrigerant). This latter
measure can be identified as changes in energy efficiency or
demand resulting from use of the substitute relative to that
of the substance being replaced.
7. Toxicity data. To assess the overall risks to human health
and the environment, information is required on the acute and
chronic toxicity effects of a substitute chemical, its impurities,
and its degradation products on any organism (e.g., humans and
other mammals, fish, wildlife, and plants). To characterize
the risk to humans, the Agency is requesting a minimum submission
of the following mammalian tests: a range-finding study that
considers the appropriate exposure pathway for the specific
use (e.g. inhalation, oral, etc.), and a 90-day subchronic repeated
dose study in an appropriate rodent species (for example, rats
or mice). For substitutes that are being evaluated as fire
suppressants,
a cardiotoxicity study, usually in the dog, is also required.
Additional mammalian toxicity tests will be identified by EPA
on a case-by-case basis depending on the particular substitute
and application being evaluated. To sufficiently characterize
aquatic toxicity, both acute and chronic toxicity data for a
variety of species are required. The Agency is proposing a minimum
aquatic data set to be submitted as described in "Guidelines
for Deriving Numerical National Water Quality Criteria for the
Protection of Aquatic Organisms and Their Uses," which is available
through the National Technical Information Service (#PB 85-227049).
Other relevant hazard information and data summaries, such
as the Material Safety Data Sheets, must also be submitted.
Submission of the actual toxicity studies is recommended; however,
it is not necessary to submit these reports if they have been
supplied to the Agency as part of other regulatory submissions.
If the actual studies are not submitted, however, the submitter
must provide sufficiently clear references or citations that
the Agency can locate the studies without delay. As discussed
below in Section V.C.3., data concerning the objectives,
methodology,
results or significance of any toxicity, metabolism, translocation,
or persistence test for a substitute and its degradation products
cannot be held as CBI where such data are also submitted under
TSCA and FIFRA. The Agency is proposing that submitters providing
information on new chemicals for joint review under the TSCA
and SNAP programs adhere to the TSCA minimum testing requirements
described in TSCA section 4.
8. Environmental Fate and Transport. Where available, EPA
requests information on the environmental fate and transport
of substitutes. Such data shall include information on
bioaccumulation,
biodegradation, adsorption, volatility, transformation, and
other data necessary to characterize a substitute's movement
and reaction in the environment.
9. Flammability. Data on the flammability of a substitute
chemical or mixture are required. Specifically, data on flash
point and flammability limits are needed, as well as information
on the procedures used for determining the flammability limits.
For substitutes that will be used in consumer applications,
documentation of testing results conducted by independent
laboratories
(e.g., Underwriters Laboratories) should be submitted where
appropriate. Detail on any suggested abatement techniques to
minimize the risks associated with the use of flammable substances
or blends should also be provided. The Agency recognizes that
many promising alternatives may be considered marginally flammable,
but can be used safely and effectively.
10. Exposure data. The submitter must provide modeling or
monitoring data on exposures associated with the manufacture,
formulation, transport, and use of a substitute. Descriptive
process information for each substitute application, as required
above, will be used to develop exposure estimates where exposure
data are not readily available. Depending on the application,
exposure profiles will be needed for workers, consumers, and
the general population.
11. Environmental release data. Data on emissions from the
substitute application and equipment, as well as pollutant releases
or discharge to all environmental media (ambient air, surface
and groundwater, hazardous/solid waste) are needed to complete
the risk characterization. Submitters should provide information
on release locations, if known. Any information on any pollution
controls that are used or could be used in association with
the substitute (e.g., emissions reduction technologies, wastewater
treatment, treatment of hazardous waste) and the costs of such
technology is also requested.
12. Replacement ratio for a chemical substitute. The Agency
also requires information on the replacement ratio for a chemical
substitute versus the Class I or II substances being replaced.
The term "replacement ratio" refers to how much more or less
of the substitute chemical is needed to substitute for the original
ozone-depleting compound being replaced. This ratio will affect
the estimated incremental cost and environmental effects associated
with use of the substitute.
13. Required changes in technology. Data on any changes in
technology needed to use the alternative are required. Such
information should include a description of whether the substitute
can be used in existing equipment-with or without some retrofit-
or only in new equipment. Data on the cost (capital and operating)
and estimated life of the technology modifications should also
be submitted. These economic data are essential to understanding
the near-term potential of using an alternative.
14. Cost of substitute. The Agency requires data on the expected
average cost of the alternative. The cost of the substitute
can be expressed, for example, in terms of $/pound (for a chemical
substitute) or as incremental capital and operating costs
associated
with a retrofit or new equipment. In addition, information is
needed on the expected equipment life for an alternative
technology.
Other critical cost considerations should be identified, as
appropriate. For example, it is important to understand the
incremental costs associated with losses or gains in energy
efficiency associated with use of a substitute relative to current
experience with existing substances.
15. Availability of substitute. The Agency needs to understand
the extent to which a substitute is already commercially available
or the date on which it is expected to become available. The
timing of availability is an important factor in assessing the
overall health and environmental effects of the substitute.
16. Anticipated market share. Data on the anticipated near-
term and long-term (over the next ten years) nationwide substitute
sales is also required. This information can be presented in
several ways, for example: a percentage of existing nationwide
use of Class I or Class II chemicals in a particular application;
number of units/products to be produced; or pounds of substitute
sold. This information is required to assess the potential effects
of a substitute related to total consumption and environmental
releases.
17. Applicable regulations under other environmental statutes.
The submitter is required to provide information on whether
the substitute(s) are regulated under other statutory authorities,
in particular the Clean Water Act, Safe Drinking Water Act,
the Resource Conservation and Recovery Act, the Federal
Insecticide,
Fungicide, and Rodenticide Act, the Toxic Substances Control
Act, the Comprehensive Environmental Response, Compensation
and Liability Act, the Emergency Planning and Community Right-
to-Know Act, as well as other titles of the CAA. The Agency
will evaluate substitutes under the SNAP program subject to
existing regulatory constraints.
18. Information already submitted to the Agency. Individuals
may have already submitted information being required in the
SNAP program notice to the Agency as part of past regulatory
and information-gathering activities. In this case, to minimize
reporting burden, the submitter should provide the following
information to help EPA locate the data already maintained at
EPA: type of information submitted; the date of submission;
the EPA office to which the data were sent; description of the
regulatory program; and a document-control number, if assigned
(e.g., a PMN number). If the submitter cannot provide references
for data sent previously to the Agency, he or she should include
all required information in the SNAP notice. To facilitate review,
reports already submitted to the Agency as part of other regulatory
submissions should be resubmitted if the original information
was claimed as CBI.
19. Information already available in the literature. If any
of the data needed to complete the SNAP program notice are
available
in the literature, the submitter should provide the Agency with
references for such information. Failure to provide the Agency
with an accurate and complete citation may delay review of the
notice. Additionally, submitters are encouraged to provide copies
of any literature to expedite review, particularly if the citation
is from a source not readily available. Any references from
sources in foreign languages should be translated into English
prior to submission.
All submissions must be provided in three complete identical
copies. If information is to be claimed as confidential, all
confidential information must be excised from the third copy,
which will be placed in the public docket. When portions of
a submission are claimed as confidential, the first two copies
will include the confidential material. If no claims of
confidentiality
are made for the submission, the third copy should be identical
to the other two. (See below, as well as Appendix C, for further
guidance on handling of confidential information under SNAP.)
C. Submission of Confidential Business Information
1. Clean Air Act Provisions
Anyone submitting information for which Confidential Business
Information (CBI) status is requested must assert a claim of
confidentiality at the time of submission. Failure to assert
a claim of confidentiality at the time of submission may result
in disclosure of the information by the Agency without further
notice. Further, it should be noted that information which is
publicly available (e.g., in journals, trade magazines, product
literature, etc.) cannot be claimed as CBI. Therefore, requesting
CBI status for such information could delay review under section
612. All claims of confidentiality will be treated in a manner
consistent with 40 CFR part 2, subpart B.
2. Substantiation of Confidentiality Claims
At the time of submission, EPA requires a substantiation
of any confidentiality claims. In making these claims, the
following
provisions apply:
-The specific information to which the claim applies must be
clearly marked in the body of the study as subject to a claim
of confidentiality;
-A Supplemental Statement of Data Confidentiality Claims must
be submitted, identifying each section claimed confidential
and describing in detail the basis for the claim. (A list
of points to address in such a statement is included in Appendix
C);
-The Supplemental Statement of Data Confidentiality Claims must
be signed and dated and must include the typed name and title
of the official who signed it.
The submitter should be advised that under the Clean Air Act
section 114(c), emissions data may not be claimed as confidential.
Moreover, there are further instances in which confidentiality
assertions may later be reviewed even when confidentiality claims
are received. These are provided in the provisions of 40 CFR
part 2, subpart B. The submitter will be contacted as part of
this evaluation process. However, if required substantiation
is not provided along with the submission of information claimed
as confidential, EPA may make the complete submitted information
available to the public without further notice to the submitter.
3. Confidential Provisions for Toxicity Data
In the event that toxicity or health and safety studies are
listed as confidential, the submitter should be advised that
this information cannot be maintained as confidential where
such data is also submitted under TSCA or FIFRA, because of
specific disclosure provisions in those statutes. However, any
information other than emissions data contained in the toxicity
study that is not relevant to the effects of a substance on
human health and the environment (e.g., discussion of process
information, proprietary blends) can be maintained as confidential
subject to the provisions of 40 CFR, part 2, subpart B. The
Agency is therefore requesting that submitters not identify
the following information as confidential when submitting
information
under TSCA or FIFRA: all information concerning the objectives,
methodology, results, or significance of any toxicity test or
experiment performed on or with a substitute or its degradation
products; any information concerning the effects of the substitute
on any organism (e.g., fish, wildlife, humans and other mammals)
or the environment (e.g., studies related to persistence,
translocation,
and fate); and pharmacokinetics/metabolism studies.
4. Federal Register Requirements
As discussed below in Section VII.A.3., the Agency intends
to publish quarterly notices in the Federal Register updating
the list of acceptable and unacceptable alternatives. The Agency
is proposing that if the name of a specific chemical contained
in any studies supporting such notices must be maintained as
confidential, the submitter and the Agency will together develop
a generic name that will protect the proprietary nature of the
chemical, but will provide sufficient detail for the public
to evaluate the health and safety studies. If appropriate, the
submitter may reference any generic names identified for use
in the PMN program.
VI. Effective Date of Coverage
A. General Provisions
In general, EPA's rules listing substitutes as unacceptable
become effective thirty days after final rulemaking. However,
EPA is authorized to permit the continuation of activities
otherwise
restricted where the balance of equities supports such
grandfathering.
Consequently, where appropriate, EPA may grandfather uses of
particular substitutes by setting the effective date of
unacceptability
listings at some future date.
The United States District Court for the District of Columbia
Circuit has established a four-part test to judge the
appropriateness
of Agency grandfathering (see Sierra Club v. EPA, 719 F.2d 436
(D.C. Cir. 1983)). This test involves balancing the results
of four analyses, including whether the new rule represents
an abrupt departure from previously established practice, the
extent to which a party relied on the previous rule, the degree
of burden which application of the new rule would impose on
the party, and the statutory interest in applying the new rule
immediately. In each rulemaking listing a substitute as
unacceptable
where grandfathering seems appropriate, EPA will conduct these
four analyses and weigh their results. Where the balance of
equities favors grandfathering, EPA will set a delayed effective
date for such listings.
In keeping with the discussion above, then, for restrictions
on use of unacceptable substitutes, the Agency will in selected
cases set the effective date differently for each banned
substitute.
The effect of this will be in these selected cases to tailor
the implementation dates to individual applications. EPA will
establish these effective dates in the rulemakings on each
substitute
to be banned.
Setting effective dates for specific chemicals and uses will
allow the Agency to avoid penalizing those who in specific
applications
may have already invested in good faith in alternatives the
SNAP program ultimately prohibits. For example, the Agency in
this action is proposing to find unacceptable the use of HCFC-
141b in certain solvent applications. New information on
stratospheric
ozone depletion has increased concern over possible adverse
human health and environmental effects, and the Agency's
unacceptable
determination in the case of HCFC-141b reflects these increased
concerns. However, the Agency recognizes that some solvent users
may have switched to HCFC-141b in good faith, expecting that
this substitute would sufficiently lower the risk of ozone
depletion
relative to earlier materials. To provide for these users, the
Agency is today proposing a tailored effective date for certain
uses of HCFC-141b. See the listing determination narrative
discussion
in Section IX, as well as the listing tables in Appendix B,
for a full discussion of HCFC-141b and associated effective
dates. Finally, to balance the desire not to penalize those
who switched early in good faith with the need to avoid creating
an incentive for continued investment in alternatives the Agency
wishes to discourage, the longer-term effective dates discussed
above will affect only existing equipment.
Until the Agency reaches a final decision restricting the
use of a substitute, vendors are not barred from selling such
substitutes. However, manufacturers, formulators, users or other
individuals involved in sale or use of a substitute are still
required to notify the Agency of any sale or use of a Class
I or Class II substitute as required by the SNAP program.
This action includes a proposed list of acceptable substitutes
and a proposed list of banned substitutes. The list of restricted
substitutes becomes binding 30 days after the date of publication
of the final rule. In contrast, the list of acceptable substitutes
is not binding, but rather is furnished for the purpose of
assisting
users in understanding the full range of available, acceptable
substitutes in each application. Before issuing the final rule,
the Agency hopes to supplement the list of acceptable substitutes
with substitutes not yet on the proposed list.
As noted above, the Agency does not believe determinations
that substitutes are acceptable need be made through rulemaking.
Consequently, EPA believes that it is within its discretion
to supplement the list of acceptable substitutes upon making
determinations consistent with the criteria to be established
in this rulemaking. In the interest of informing users as soon
as possible of acceptable substitutes, EPA expects to add to
the list of substitutes those substitutes for which it can make
such a determination during the pendency of the rulemaking,
consistent with the criteria promulgated.
The Agency therefore encourages vendors and users of substitutes
to use this opportunity to provide EPA with information necessary
to issue a SNAP determination. Many potential users of substitutes
have asserted that they want the benefit of EPA's SNAP
determinations
when transitioning out of Class I and Class II compounds. In
addition, vendors of substitutes have also claimed they will
derive significant benefits from having their substitutes added
to the SNAP lists of approved substitutes, where possible.
VII. Notice, Review, and Decision-Making Procedures
The purpose of this section is to summarize the proposed
procedures for submitting the required information to the Agency,
and the steps EPA will take in reviewing SNAP program submissions,
and making determinations based on them. This section focuses
on three procedures, summarized in Exhibit 1, depending on the
nature of the submission received by the Agency. Some substitutes
may already have received approval or may not need approval
under other environmental statutes, especially TSCA and FIFRA.
These substitutes, in consequence, would only require review
under the SNAP program. Section VII.A. discusses the submission
and review process for alternatives that fall into this category
in greater detail. In other cases, a substitute will require
approval under section 612 as well as relevant provisions of
TSCA and FIFRA. In these cases, any substitute that is a new
chemical (i.e., not currently listed on the TSCA inventory)
must be submitted to the Agency for review under the SNAP program,
as well as the PMN program. Section VII.B. describes steps for
this review in more detail. For alternatives to Class I and
Class II chemicals that will be used in pesticide products,
the substitute manufacturer will need to file notification jointly
with EPA's Office of Pesticide Programs (OPP) and EPA's SNAP
program. Section VII.C. discusses the latter procedure. EPA
has coordinated closely with each of these regulatory programs
to establish a joint review process that will ensure consistency
in the final decisions, while minimizing the time for review,
the reporting burden, and the costs for the submitter and the
Agency.
A. Substitutes Reviewed Under SNAP Only
1. Applicability
Sections IV and V describe the conditions dictating review
under the SNAP program only and the general reporting requirements
under section 612. If any of these conditions are met and the
substitutes are not exempt from the process as described in
section IV.B.3., Exemptions from Reporting, a SNAP notice must
be submitted.
See the accompanying hardcopy volume for non-machine-readable
data that appears at this point.
2. Pre-Notice Communication
Prior to submitting the SNAP notice, each submitter is
encouraged
to contact EPA's SNAP Coordinator to discuss the notification
process. Among other things, the SNAP Coordinator will: (1)
assist the potential submitter in determining whether a SNAP
notice is needed; (2) answer questions regarding how to complete
a submission; (3) provide all necessary forms and guidance manuals;
(4) serve as the initial point of contact when the notice is
submitted; and (5) assign a SNAP program tracking number to
the notice once it is received by the Agency. A copy of the
SNAP program notice may be obtained from the SNAP Coordinator.
Specific data requested are described in Section V.
3. Processing of Completed SNAP Submission
a. 90-Day Review Process. As required under section 612(e),
a manufacturer of a substitute for a Class I chemical must provide
the Agency with notification at least 90 days prior to introducing
into commerce any new or existing chemicals for significant
new uses as Class I alternatives. The same requirements apply
to manufacturers of substitutes for Class II substances, although
in this case the Agency is drawing on general authorities contained
in sections 114 and 301 in order to fulfill the purpose of section
612(c). EPA intends to review these chemicals within a 90-day
period to ensure prompt response for manufacturers initiating
production of substitutes. EPA's 90-day review period for SNAP
submissions will begin once EPA receives a submission that includes
data that are adequate, as described in Section V.B. above.
If a submission does not include adequate data, EPA may return
the submission to request specific additional information. Section
114 and in the case of petitions section 612(d) authorizes EPA
to require manufacturers to support their SNAP submissions with
data adequate to facilitate EPA's review.
b. Initial Receipt of the SNAP Submission. (1) Letter of
Receipt. The SNAP Coordinator will send a letter of receipt
to the submitter once the Agency receives the SNAP submission.
(2) Initial Review of Submission. Once received, the SNAP
Coordinator will review the notice to ensure that basic information
necessary to process the submission is present (i.e., name of
company, identification of substitute, etc.). A more detailed
review of supporting technical data will then ensue, as well
as an examination of the substantiation provided for any claim
for confidentiality of information. The 90-day review period
will not commence until EPA judges the submission complete,
although manufacturers may begin marketing chemicals 90 days
after submitting their notification to EPA. Once the data
supporting
the SNAP notice are deemed adequate, the SNAP Coordinator will
assign to the SNAP notice a tracking number, and EPA's formal
90-day review period will begin.
c. Determination of Data Adequacy. As mentioned above, as
part of reviewing the SNAP submission, the Agency will complete
a determination of the scientific and technical adequacy of
the data supporting the application. The Agency will issue this
determination within 15 working days after receipt of the
application.
Any time information is not adequate to allow the Agency to
reach a SNAP determination, EPA will contact the submitter and
request the missing data. EPA believes it appropriate and
authorized
under section 114 to place the burden on the submitter to provide
all data needed to complete the review of the SNAP notice.
Depending
on the type of information needed and the time necessary to
compile and submit the requested data to the Agency, EPA may
suspend or extend the review period. This will not affect the
ability of a manufacturer to begin marketing a chemical 90 days
after notifying the Agency.
In a few cases, the Agency and the submitter may disagree
on a schedule for furnishing additional data EPA deems necessary
to determine the acceptability of the substitute. If in these
cases EPA has reason to believe that such substitute may be
unacceptable, the Agency may exercise the option of proposing
to list the substitute as unacceptable until the necessary data
are provided, due to the uncertainty of the risks associated
with use of the substitute.
d. Availability of New Information During Review Period.
If critical new information becomes available during the review
period that may influence the Agency's evaluation of a substitute,
the submitter must notify the Agency about the existence of
such information within ten days of learning of such data. The
submitter must also inform the Agency of new studies under way,
even if the results will not be available within the 90-day
review period. The Agency may extend or suspend the review period
depending on the type of information at issue and the stage
of review.
e. Completion of Detailed Review. Once the submission is
found to be supported by adequate data, the Agency will commence
a detailed evaluation of the notice. As this review proceeds,
the Agency may contact the submitter for additional information
to assist in the evaluation. This will ensure that the review
is completed quickly and that it reflects the best available
information. Final decisions will be based on the detailed analysis
completed during this stage of review.
f. Vendor Lists. The Agency will use the SNAP determinations
to compile a list of vendors for the convenience of potential
users. Companies could then ask EPA to review their specific
substitute, to ensure that it is covered by the listing decisions
on approved substitutes, and to add the company to the vendor
list. The Agency believes that specific information on vendors
of acceptable substitutes would be useful to companies switching
out of Class I and Class II compounds. The Agency solicits comment
on this aspect of today's proposal.
g. Communication of SNAP Determination. (1) SNAP Determinations
on 90-Day Notifications. EPA's determinations on SNAP submissions
that come as a result of the 90-day notification requirement
will take the form of either adding substances to the list of
acceptable substitutes or of proposing to add them to the list
of unacceptable substitutes. The former, as discussed in greater
detail below, will be listed in a quarterly update of SNAP
determinations
which EPA will publish in the Federal Register. The latter will
be made final through rule-making under section 307(d).
(2) Communication of SNAP Determination to the Submitter.
Once review has been completed, the submitter will be notified
in writing of the determination under SNAP. At this time, the
submitter will also be informed if any conditions are attached
to the approval of a substitute. Companies may continue
uninterrupted
sale or manufacture of their substitutes until the Agency places
a substitute on the list of unacceptable substitutes as a result
of rulemaking. Sale or manufacture may continue if the Agency
fails to reach a decision or notify the submitter of that decision
within 90 days of initial notification of EPA.
(3) Communication of SNAP Determination to the Public (a) Federal
Register Notice
To provide the public with updated information on SNAP
determinations,
the Agency is proposing to publish in the Federal Register a
complete list of the acceptable and unacceptable alternatives
that have been reviewed to date. This list will be published
four times each year and will include recent decisions made
under the SNAP program. In addition to the quarterly publications,
the Agency will communicate decisions through a clearinghouse
and various outreach programs, as discussed in the next section,
as well as through the stratospheric ozone program hotline,
which the Agency has already established.
(b) Outreach and Clearinghouse
Section 612(b) requires the Administrator to assist users
in identifying alternatives to Class I and II compounds. The
Agency has long operated an outreach program for users of ozone-
depleting compounds, and this new mandate along with the
accelerated
phase-out of Class I and II substances adds impetus to these
efforts.
Section 612(b)(4) requires the Agency to maintain a public
clearinghouse of alternative chemicals, product substitutes,
and alternative manufacturing processes that are available as
replacements for Class I and Class II chemicals. The clearinghouse
will distribute information on those substitutes that are approved
under the SNAP program. For the convenience of companies wishing
to identify substitutes with low relative environmental risks,
the Agency will maintain a list of vendors selling substitutes
that meet EPA's criteria for approval, as discussed in section
VII.A.3.f.
In addition, the Agency is proposing to enter data on
substitutes
into the Pollution Prevention Information Exchange System (PPIES)
database, which is maintained by EPA's Office of Research and
Development. This database contains information on numerous
pollution prevention options for a wide variety of industrial
sectors and chemicals. PPIES can also be accessed from a variety
of other pollution prevention databases maintained by other
Federal agencies and industry. The Agency requests comment on
this proposed approach to providing the public with information
on available alternatives.
4. Decision-Making Framework
a. Decisions by Substitute and Use. As required by section
612(c), the Agency must publish a list of substitutes prohibited
under the SNAP program and a list of acceptable alternatives
for particular applications. Given that environmental exposure
and risk profiles can change significantly from one application
to the next, it is essential to evaluate and list substitute
decisions in the context of their intended use. The Agency has
initially identified a number of use sectors by which to list
substitutes, and Section IX provides preliminary risk management
decisions for many substitutes in each of the principal use
sectors. Other substitutes in each of these sectors exist as
well, and these substitutes will be covered in subsequent analyses
undertaken in the SNAP program.
In listing the substitutes, the Agency will be as specific
as possible, by providing exact chemical names of substitutes.
The Agency anticipates two possible exceptions to this practice.
The first is where release of the chemical identity of a substitute
constitutes release of proprietary information. In that event,
the Agency will report generic chemical names based on chemical
classes as described in Section V.C. The other exception would
be in cases where the Agency believes that a more general
categorization
is needed to account for the diversity of possible chemicals
used in a particular set of substitutes. For example, in the
solvents cleaning sector, many substitutes are formulations
composed of compounds drawn from several categories of chemicals.
In this case, the toxicity profile of each chemical is similar
to those of other chemicals in that class. Yet for most
substitutes,
a broad chemical classification (e.g., aromatic hydrocarbons,
or HCFCs) is not specific enough because of differences among
chemicals belonging to each of these groups. Thus, where
appropriate,
EPA will provide a more specific description of the substitute
by application.
b. Decision Categories. Under section 612, the Agency has
considerable discretion in the risk management decisions it
can make in SNAP. The Agency has identified several possible
decision categories, as described below. However, these types
of risk management decisions should not be construed as comprising
all possible options that the Agency will exercise under section
612. Depending on the particular characteristics of the submission,
alternative approaches may be warranted.
(1) General Acceptance. Where the Agency has reviewed a
substitute
and found no reason to prohibit its use, it will list the
alternative
as acceptable for the applications listed. Where appropriate,
the Agency may provide some additional comment (e.g., general
recommendations encouraging recapture and recycling). However,
these comments are not conditions for use of the substitute.
(2) Approval Subject to Conditions. After reviewing a notice,
the Agency may determine that a substitute is acceptable only
if certain conditions are met. The Agency cannot predict at
this time all necessary restrictions, but already anticipates
some conditions based on substitute reviews already completed.
For example, the Agency may impose conditions on the use
of a substitute and require recycling equipment to limit workplace
and ambient releases or require use of other control practices
within a certain application. Alternatively, EPA may approve
a compound not for general use, but for use only in certain
narrow applications. Clearly, any limitations imposed will depend
on the risks involved and the substitute and application in
question. To provide adequate opportunity for comment by the
regulated community, EPA will complete notice-and-comment
rulemaking
before promulgating any finding to approve a substitute subject
to a condition on use.
In implementing its use of conditions, the Agency has sought
to avoid overlap with other existing regulatory authorities.
EPA has taken a number of steps to mitigate this potential for
duplication. First, EPA intends to limit the use of conditions
to cases in which clear regulatory gaps exist. Second, these
existing regulatory gaps must render the use of a substitute
an unreasonable risk in the absence of any additional controls.
Third, in the limited cases in which conditions may be necessary,
the Agency will impose them only after going through formal
notice-and-comment rulemaking. Finally, the Agency intends to
withdraw existing conditions when they are superseded by
appropriate
regulatory controls under other authorities.
The Agency, however, requests comment on the general issue
of the need for use conditions. In particular, EPA requests
comment on whether section 612 in fact confers upon the Agency
the authority to go beyond the listing of acceptable and
unacceptable
alternatives and to set such use conditions. Further, EPA requests
comment on the capability and practicality of EPA enforcing
use conditions which may, for example, closely resemble workplace
safety standards, which are typically within the enforcement
purview of other regulatory authorities.
EPA also requests comment on whether, when an unreasonable
risk might exist due to a gap in regulatory coverage, the
appropriate
means to address these risks is through the existing regulatory
framework of other federal authorities. For example, rather
than using EPA's use conditions to address existing gaps in
workplace safety standards, EPA could refer the matter to the
appropriate OSHA authorities and request appropriate action
to mitigate an otherwise unreasonable risk.{2}
³{2} 29 U.S.C. 654, OSHA General Duty Clause, requires
³that each employer "shall furnish to each of his
employees
³employment and a place of employment which are free
from
³recognized hazards that are causing or are likely to
³cause death or serious physical harm to his employees.
³* * *"
Alternatively, where the length of time required to address
a problem under another authority may be unacceptably long given
the nature of the risk, there may be cases in which EPA would
simply consider unacceptable the use of a given substitute,
pending the development of a regulatory framework to control
the risk it poses in its use as a substitute for an ozone-depleting
compound.
For example, in this action, EPA has proposed conditions
on the acceptability of certain halon substitutes when used
as total flooding agents in normally occupied areas. EPA has
imposed these conditions because of the risk of cardiotoxic
levels of exposure to personnel in areas where substitute agents
may be discharged in the event of fire. Existing OSHA standard
1910.160 applies certain general controls to the use of fixed
extinguishing systems in occupied workplaces, whether gaseous,
dry chemical, water sprinklers, etc., and EPA has not reproduced
those. These include, for example, the requirements for discharge
and pre-discharge alarms, and availability of Self Contained
Breathing Apparatus (SCBA) for emergency entry into an area
where agent has been discharged.{3}
³{3} 29 CFR 1910.160(b) includes general provisions to
³ensure the safety of all fixed extinguishing systems.
³Paragraph (c) stipulates requirements for systems with
³"potential health and safety hazards to employees" such
³as might be posed by gaseous agents.
³ (b)(3) ``The employer shall provide a distinctive
alarm
³or signaling system * * * capable of being perceived
³above ambient noise or light levels * * * to indicate
³when the extinguishing systems is discharging.
Discharge
³alarms are not required on systems where discharge is
³immediately recognizable.''
³ (b)(4) ``The employer shall provide effective
safeguards
³to warn employees against entry into discharge areas
³where the atmosphere remains hazardous to employee
safety
³or health.''
³ (b)(5) ``The employer shall post hazard warning or
³caution signs at the entrance to, and inside of, areas
³protected by fixed extinguishing systems which use
agents
³in concentrations known to be hazardous to employee
safety
³and health.''
³ (b)(6) ``The employer shall assure that fixed systems
³are inspected annually * * * to assure that the system
³is maintained in good operating condition.''
³ (b)(10) ``The employer shall train employees
designated
³to inspect, maintain, operate, or repair fixed
extinguishing
³systems. * * *''
³ (b)(17) ``The employer shall provide and assure the
³use of personal protective equipment needed for
immediate
³rescue of employees trapped in hazardous atmospheres
³created by an agent discharge.''
³ (c)(3) ``On all total flooding systems the employer
³shall provide a pre-discharge employee alarm * * *
which
³will give employees time to safely exit from the
discharge
³area prior to system discharge.''
While section 1910.162 can apply generally to gaseous agents,
it includes cardiotoxic levels specific to Halon 1301. Section
1910.162 paragraphs (b)(5) and (b)(6) provide alternative workplace
requirements based on specific design concentrations of Halon
1301. (These design concentrations are not identified as the
cardiotoxic NOAEL or LOAEL, so one cannot generalize a rule
for use with alternative agents.) For this reason, EPA is concerned
that halon substitute agents could be used in the absence of
enforceable compound-specific cardiotoxic exposure levels. Should
OSHA create compound-specific cardiotoxicity values to be applied
to the use of halon substitutes as gaseous total flooding agents
in occupied spaces, these conditions would no longer be necessary
and EPA would rescind them.
However, EPA is also aware that existing OSHA regulations
may provide adequate coverage against exposure to toxic levels
of agents or their decomposition products. Section 1910.162
(b)(3) states, "(t)he employer shall assure that employees are
not exposed to toxic levels of gaseous agent or its decomposition
products," and paragraph (b)(4) states, "(t)he employer shall
provide a distinctive pre-discharge employee alarm * * * when
agent design concentrations exceed the maximum safe level for
employee exposure." EPA invites comment on the adequacy of 1910.162
(b)(3) to provide workplace protection against toxic exposures
to agents that differ from Halon 1301.
(3) Substitutes Pending Completion of Review. The Agency
will describe submissions for which it has not yet reached a
final decision as pending. For all substitutes in the pending
category, the Agency will contact the submitter to determine
a schedule for providing the missing information if the Agency
needs to extend the 90-day review period. EPA will use the
authority
under section 114 to gather this information, if necessary.
(4) General Prohibition. The Agency has the authority under
section 612(c) to prohibit the use of a substitute believed
to present adverse effects to human health and the environment
where alternatives that reduce overall risk are available. The
Agency will only use this provision where it has identified
other substitutes that are currently or potentially available
and that have lower overall risks. Substitutes will be listed
as unacceptable through the rulemaking process.
(5) Prohibition with Limited Exemptions for Critical Uses.
In some applications, even though the Agency restricts the use
of a substitute based on the potential for adverse effects,
it may be necessary to grant a limited number of exemptions
because of the lack of alternatives for specialized uses within
the general application area. The Agency will refer to such
exemptions as "critical use exemptions." For example, the Agency
could list a substitute as generally unacceptable for solvent
applications, but allow for limited exemptions for critical
uses within the sector of solvent cleaning. These critical use
exemptions will be granted only for the period necessary to
develop and implement alternatives not yet available.
At this time, the Agency cannot know and list all critical
use applications that will be exempted. Section VIII.F. discusses
the petition process for critical use exemptions in more detail.
Critical use exemptions will be granted through notice-and-comment
rulemaking.
c. Time Certainty of Decisions. In response to the ANPRM,
several comments suggested that the Agency establish assured
minimum periods of use for substitutes listed as acceptable.
For example, one commenter recommended that the Agency consider
any substitute decision, once made, valid for a minimum of fifteen
years before making any changes. Clearly, there are advantages
to having a guaranteed period within which a substitute can
be used without concern for future changes in the acceptability
of a substitute. In particular, such certainty would encourage
reduced reliance on Class I chemicals in the near term.
Despite this benefit, the Agency believes that providing
time certainty to its decisions on balance could discourage
continued research on substitutes. In addition, the Agency believes
that in certain limited cases, new data on previously approved
or disapproved substitutes may warrant changes to an existing
SNAP determination. Such changes, however, will only be considered
in cases where new information indicates a need to reassess
the risk of a previously evaluated substitute. For example,
new toxicity data may become available that point to a dramatically
different hazard profile for a chemical, and which changes the
risk the substitute poses to human health and the environment
relative to other substitutes. Similarly, if the Agency previously
listed a high-risk substitute as acceptable only because no
other alternative exists for a specific end-use, this determination
may be subject to change if a new substitute with demonstrably
lower overall risks becomes available.
In such instances, which the Agency expects will occur
infrequently,
EPA will provide consideration for companies who earlier made
a switch to a substitute believed to be acceptable. In particular,
the Agency proposes to examine capital expenditures made by
affected industries to manufacture and use a substitute when
it evaluates whether the availability of another alternative
should render the first alternative unacceptable.
d. Implications of Other Regulatory Requirements. The Agency
is proposing that the SNAP program in evaluating substitutes
take into consideration the regulatory requirements of other
environmental and health protection statutes (e.g., the Clean
Water Act or the Occupational Safety and Health Act). By
considering
existing regulatory constraints, the Agency's evaluation of
alternatives will explicitly recognize compliance with provisions
designed to reduce workplace and environmental releases. However,
it will not be possible to factor in regulatory requirements
that are still under development (e.g., more stringent requirements
to control volatile organic compounds and hazardous air pollutants
under Title I and Title III of the CAA). Clearly, in these
instances,
a substitute, although approved, must comply with all future
regulations. Should future regulations severely limit the
availability
of the only substitute for a prohibited substance, EPA would
reconsider the advisability of keeping that substance on the
list of unacceptable substitutes.
Several commenters felt that the goal of section 612 was
to encourage use of substitutes for Class I and Class II chemicals
by relaxing regulatory requirements in other areas. The Agency
does not believe that it was the intent of Congress to use the
authority under section 612 to compromise existing regulatory
requirements. Instead, EPA intends to evaluate substitutes in
the framework of protection provided by current regulatory
standards.
5. EPA-Generated Review of Substitutes
In addition to notices received under section 612 for substitute
review, the Agency is authorized by section 612(c) to add or
delete alternatives to the list of reviewed substitutes on its
own initiative. EPA has many efforts under way to identify and
communicate the availability of promising new alternatives.
These include support for research efforts to study and focus
attention on future substitutes, involvement in the United Nations
Environment Programme biannual assessment of technologies for
key sectors currently using ozone-depleting chemicals, and
technology
transfer projects with industry, other Federal agencies, and
developing nations. Based on information available through these
activities, EPA may initiate review of new substitutes under
section 612. In each case, the next planned quarterly Federal
Register notice updating the status of SNAP determinations will
inform the public that EPA is initiating a review, subject to
the provisions discussed in this proposal. Similarly,
determinations
ultimately reached as a result of these internally-generated
reviews will be publicly noticed every three months.
B. Joint Review of New Substitutes under SNAP and TSCA PMN
1. Applicability
Any potential SNAP submitter who intends to introduce a new
chemical (i.e., a chemical not currently included in the TSCA
inventory) as an alternative for a Class I or Class II chemical
must undergo review not only under section 612, but under section
5 of TSCA (the Premanufacture Notice program) as well. Because
of the overlap in statutory authority, the Agency has established
a joint review process between the SNAP and TSCA Premanufacture
Notice (PMN) programs. This process has been structured to minimize
reporting burden and to ensure consistency in decisions between
the two programs. The following sections describe the joint
review and decision-making process in more detail.
2. Data Submission Requirements and Process
a. SNAP and PMN Forms. The Agency has reviewed the data
submission
needs for the SNAP and PMN programs and found significant overlap.
In general, the Agency has identified only a few additional
data elements beyond those already required by the PMN program
that should be included for review under the SNAP program. These
elements are:
Ozone depletion potential.
Global warming potential.
Explicit quantification of the cost of using the substitute,
including:
-Chemical replacement data
-Chemical cost data
-Incremental equipment expenditures (either new or retrofit)
needed to use substitute
-Information on the cost implications of changes in energy
consumption
(e.g., from the use of a less or more energy-efficient
refrigerant)
Documentation of testing results, where available, regarding
the flammability of substitutes that will be used in consumer
applications.
Given this overlap, the Agency is proposing that a submitter
requesting a review under both the SNAP and PMN programs provide
the above information by following these steps:
Complete the PMN form (EPA Form 7710-25) following the
Instructions Manual currently available through the TSCA Assistance
Information Service.
Indicate on page 11 of the PMN form, "Optional Pollution
Prevention Information," that the chemical to be reviewed is
also to be considered under the SNAP program.
Complete a SNAP addendum that requests information only
on those items listed above. (The addendum can be obtained from
the SNAP Coordinator.)
The completed PMN form (EPA Form 7710-25) will remain the
basis for all information needed to complete review of the new
chemical under section 5 of TSCA. The completed PMN form and
the SNAP addendum together will comprise the data submission
for section 612 review and listing decisions for new chemicals.
This approach is intended to minimize the reporting burden on
submitters.
The Agency will modify the PMN Instructions Manual in the
future to provide more explicit direction on how to complete
the SNAP addendum. A SNAP submitter may also consult the SNAP
Guidance Document, which will be available for potential submitters
at the time the SNAP program is promulgated. Any questions
regarding
the completion of these forms can be directed to either the
PMN pre-notice coordinator or the SNAP Coordinator.
b. Submission of Completed Forms. Both the PMN and SNAP programs
have a review period of 90 days, subject to suspensions and
extensions described in Section VII.A. for the SNAP program
and in the Preamble to the PMN final rule (40 CFR 720.75). To
ensure that new chemical submissions are reviewed and decided
on jointly, the Agency encourages submitters to provide both
the PMN form and SNAP addendum to the PMN and SNAP coordinators.
Failure to provide both programs with the requested information
at the same time could result in delays in the review of a
submitter's
notice seeking approval of a new chemical as a CFC substitute
approved by EPA where it would result in delay of EPA's approval
under the PMN program.
c. Procedures for Handling Confidential Business Information.
The Agency recognizes that, where appropriate, information
submitted
to the PMN and SNAP programs may need to be confidential. EPA
is proposing that all CBI submitted as part of the joint PMN/SNAP
review be maintained and treated in a manner consistent with
TSCA requirements. Confidentiality claims will be processed
and may be reviewed in a manner consistent with 40 CFR part
2, subpart B. This approach is being proposed because the majority
of data provided to SNAP under the joint review process will
come from the PMN form. Submitters should note that while TSCA
and CAA may have different language describing CBI handling
procedures, there is no substantive difference in how CBI is
maintained under the two statutes.
3. Joint Review of New Substitutes Under PMN and SNAP
a. Preparation of Public Docket and Federal Register Notices.
Once the letter of receipt has been issued, the PMN program
will prepare a public docket and Federal Register notice, as
described in the Preamble to the final rule for the PMN program
(40 CFR
720. 75). The PMN program manager will consult with the SNAP
Coordinator in preparing the notice. The Agency is proposing
this approach for joint PMN/SNAP reviews because it believes
it will reduce the reporting burden imposed on manufacturers.
b. Joint Review Process. EPA is proposing to complete joint
evaluations of new chemicals serving as Class I or Class II
substitutes under section 5 of TSCA and section 612 of the CAA.
This joint review process will be coordinated to ensure that
there is consistency in the final decisions made under the PMN
and SNAP programs. To ensure agreement in the decisions, Agency
offices will work in concert to develop toxicity, exposure,
and risk profiles for those substitutes and applications that
come under joint TSCA and CAA review authority. The Agency will
also coordinate its review of the completeness of the information
supplied and subsequent data requests to minimize the reporting
burden on the submitter.
Submitters should note that Agency decisions to restrict
production of particular chemicals under TSCA will, in the case
of joint PMN/SNAP applications, also have the effect of restricting
production of substitutes undergoing review under the SNAP program.
However, companies that produce substitutes only being reviewed
under the SNAP program are not required to cease production
during the SNAP review period.
As part of the review, the PMN and SNAP programs will work
to arrive at a consistent decision regarding the new chemical
under review. Consequently, listing decisions under SNAP will
reference any conditions also incorporated into the PMN review
(e.g., submission of additional toxicity information, restrictions
on use, etc.).
If a substitute meets the conditions for general PMN approval
but not for SNAP approval, the company may produce and market
the substance in question. However, EPA will commence a rulemaking
to prohibit as unacceptable the description or use of the
substitute
as an EPA-approved Class I or II substitute. If the chemical
fails to meet the conditions for PMN approval, the submitter
is barred from producing the chemical and consequently also
from marketing the product as a CFC substitute. Submitters should
note, however, that the CAA section 612 places considerable
emphasis on identifying and promoting the use of substitutes
which, relative to others, reduce overall risks to human health
and the environment. To the extent a substitute offers such
risk reduction, EPA under the CAA will make every effort to
facilitate production and use of that alternative.
c. Communication of Decision. The PMN program will use the
existing TSCA regulatory framework for communicating decisions
to submitters of the decision on the new substitute. The SNAP
program will provide public notice of decisions regarding the
acceptability or unacceptability of a substitute following the
process described in Section VII.A.3.h. EPA will contact the
submitter to determine how best to list the substitute under
the SNAP program if necessary to protect the confidentiality
of the alternative.
C. Joint Review of Substitutes Under SNAP and FIFRA
1. Background on Use of Ozone-Depleting Chemicals in Pesticides
Certain pesticides are formulated with Class I and Class
II chemicals. The most prominent example is the use of methyl
chloroform (1,1,1-trichloroethane) as an inert ingredient.
Pesticide
products that contain Class I and Class II compounds must be
reformulated as these chemicals are phased out of production
under the Clean Air Act. This section describes how the Agency
proposes to handle reviews of these changes.
2. Applicability
Any new pesticide or amendment of an existing formulation
is already subject to Agency approval under current provisions
of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA),
P.L. 100-460, 100-464 to 100-526, and 100-532. However, as of
the effective date of the SNAP program, new pesticides or
formulation
changes based on Class I or Class II substitutes will also be
subject to review under section 612 of the CAA. These authorities
apply in all cases where a manufacturer amends a pesticide product
to replace chemicals being phased out under section 602. Similarly,
registrations of new pesticide products will also be subject
to SNAP review if the new formula contains chemicals functionally
replacing Class I or II compounds.
3. Review Responsibilities Under FIFRA and CAA/SNAP
In general, review responsibilities for pesticide products
under the CAA SNAP program will focus on a substance's ozone
depletion and global warming potential. The FIFRA reviews will
address factors commonly examined during pesticide amendments
and registrations. The two program offices responsible for these
reviews will coordinate their efforts at critical junctures
and share pertinent data to ensure appropriate technical
consideration
of the substitute.
4. Data Submission Requirements and Process
a. Preparation of Applications. The Agency has reviewed the
data submission needs for the SNAP and FIFRA pesticide
amendment/registration
process and found no significant overlap. Because there is so
little overlap, the Agency is proposing that a submitter requesting
review under both SNAP and the Office of Pesticide Programs'
pesticide amendment/registration process submit all information
ordinarily required for the OPP process as well as a fully
completed
SNAP submission form. A copy of the FIFRA form should be submitted
to the OPP, and a copy of the SNAP form should be submitted
to the SNAP Coordinator. The SNAP form can be obtained from
the SNAP Coordinator. For further guidance, SNAP submitters
may also consult the SNAP Guidance Document, which will be
available
for review at the time the SNAP program is promulgated.
If a registrant is submitting an amendment to a product
registration
under FIFRA that currently contains a Class I or II substance,
he or she should note in Section II ("Amendment Information")
of the FIFRA form that the amendment was prompted by the CAA
production phase-out. Similarly, if a registrant is submitting
an application for a new pesticide registration that would
otherwise
have been based on a Class I or II compound, he or she should
note in Section II of the FIFRA form that the registration includes
a Class I or II substitute.
The submitter should also identify in Section II both the
substitute chemical and the Class I or II compound it is replacing.
Further, if a registrant is aware that a particular chemical
intended for use as a Class I or Class II substitute in a pesticide
formulation has already been approved through earlier SNAP/FIFRA
determinations, the registrant should also reference the relevant
part of the prior review. This additional information will allow
EPA to identify quickly those registrants whose proposed
substitutes
have already been the subject of listing determinations under
SNAP, and thereby streamline the SNAP review.
b. Review of Applications. When the Agency receives the FIFRA
application and SNAP submission, it will log each into the relevant
tracking systems: the Office of Pesticide Program's (OPP) tracking
system for the FIFRA application and the SNAP tracking system
for the SNAP submissions. If the FIFRA application is identified
in Section II as a Clean Air Act substitution, the FIFRA program
coordinator will contact EPA's SNAP coordinator to establish
whether the substitute has been the subject of any prior SNAP
reviews. If the registrant's substitute is on the list of
unacceptable
substitutes, EPA will notify the registrant that the amendment
request cannot be granted. If the registrant's substitute is
on the list of acceptable substitutes, EPA will proceed with
the standard FIFRA application review. If a chemical substitute
is not listed under existing SNAP determinations but is a
substitute
for an ozone depleting compound, EPA will inform the registrant
of the need for a SNAP review.
5. Communication of Decision. Once the EPA review is complete,
the Agency will notify the registrant whether the new formulation
or proposed formulation change is acceptable. At the same time,
the Agency will amend the SNAP determinations to reflect these
findings and will publish the revised determinations in the
next quarterly Federal Register notice. Submitters should note
that, because of the shared authority to review substitutes
under both SNAP and FIFRA, formulators may not sell amended
or new formulations until they have received FIFRA approval.
D. Shared Statutory Authority With the Food and Drug Administration
The Federal Food, Drug and Cosmetic Act (FDCA), 21 U.S.C.
321, provides for the safety and effectiveness of drugs and
therapeutic devices, the purity and wholesomeness of foods,
and the harmlessness of cosmetics. Under this statute, the Food
and Drug Administration (FDA) regulates the packaging of food
products and incidental additives and requires predistribution
clearance of medical devices.
As defined in the FDCA, medical devices can include any devices,
diagnostic products, drugs, and drug delivery systems. Devices
covered under this jurisdiction are subject to review under
the FDCA. Some medical devices and food packaging currently
contain Class I or II compounds. The Agency is proposing that
such products be exempt from further review for human health
effects under the SNAP program where FDA approval of such effects
is required before a product can be introduced into commerce.
EPA will rely in its SNAP determination on FDA's conclusions
regarding health effects. The Agency believes this exemption
is justified because of the higher burden of proof placed on
submitters under the FDCA. However, the Agency will continue
to evaluate all other environmental effects of the proposed
substitute, and will consult with the FDA to determine the
appropriate
course of action.
VIII. Petitions
A. Background
1. Role of Petitions
Section 612(d) in the CAA explicitly states that "any person
may petition the Administrator to add a substance . . . or to
remove a substance from either of such [prohibited or safe use]
lists." The petition provision serves two principal needs. The
first is to permit the appeal of existing Agency determinations
under the SNAP program. The second is to provide a mechanism
for individuals and organizations to bring to the Agency's
attention
new information on substitutes that could affect existing listing
determinations or result in new ones.
The opportunity for outside parties to comment on existing
listing decisions is an important aspect of the petition process.
As discussed in the section on notifications, companies that
produce substitutes must submit specific data on the substitutes
to the Agency for review. However, organizations and private
citizens other than those required to submit SNAP notices may
have additional information about existing substitutes or
information
on new substitutes not yet reviewed by the Agency. To ensure
that the SNAP determinations are based on the best information
on substitutes, it is essential that the Agency offer a means
for such information to be incorporated into the SNAP analyses
on a continuing basis.
Before individuals, organizations, or companies may initiate
court action against EPA for the purpose of changing the lists
of acceptable or unacceptable substitutes, they must first exhaust
all administrative remedies for receiving such relief, including
remedies like the petition process described in this section.
2. Types of Petitions
Four types of petitions exist:
(1) Petitions to add a substitute not previously reviewed
under the SNAP program to the approved list;
(2) Petitions to add a substitute not previously reviewed
under the SNAP program to the prohibited list;
(3) Petitions to delete a substitute from the approved list
and add it to the prohibited list; and
(4) Petitions to delete a substitute from the prohibited
list and add it to the approved list.
Petitioners should note that the first type of petition is
comparable to the 90-day notifications, except that the latter
are submitted by substitute producers prior to the introduction
into interstate commerce of the substitute for a significant
new use as a Class I or Class II substitute. The first type
of petition, by contrast, would be initiated by entities other
than the company responsible for the substitute. Companies that
manufacture, formulate, or use a substitute themselves and want
to have their substitutes added to the approved list should
submit information on the substitute under the 90-day review
program.
3. Basis for Petition
A petitioner may submit a petition for several reasons,
including:
Availability of information on substitutes or applications
not covered in the existing SNAP determinations;
New toxicity data on a substitute;
New technologies or practices that reduce exposures to
a substitute previously prohibited under SNAP due to toxicity
concerns; or
Requests for approval for specialized uses for a prohibited
substitute where no other technologically viable substitute
can be found in a particular niche use.
All of the above are examples of valid justifications for
submitting
a petition. Other bases for petitioning the Agency may exist
as well, and all petitions with adequate supporting data will
receive equal consideration under the SNAP program.
4. Nature of Response
The Agency will only review and grant or deny petitions based
on the industrial use category identified in the petition. For
example, simply because the Agency ultimately deletes a substitute
from the list of approved substitutes for solvents cleaning
does not mean the substitute is from then on prohibited for
use as a refrigerant. A similar caveat applies for petitions
on uses within industrial sectors. If a substitute, for instance,
is approved for a specific application within a use sector,
it will not automatically be approved for all other applications
in that sector.
B. Content of the Petition
A petition must contain the information described in Section
V.B. of this notice, which lists the items to be submitted in
a 90-day notification. Information requirements for petitions
and 90-day notifications are the same, since the Agency will
be applying equal rigor to analyses of petitions submitted by
outside parties as to notifications received from the producing
companies themselves. As with SNAP submissions, the Agency will
issue a determination on the completeness of the petition within
15 days of receiving the petition.
For petitions, the Agency also requires the following
information:
Action requested: A brief statement describing the type
of petition; and
Rationale: A brief summary of the basis for the petition
and the data that support the petition.
Specifically for petitions that request approval for substitutes
on "critical use" grounds, the Agency proposes to require
additional
information documenting a company's efforts to find and implement
substitutes. This information is discussed below.
For petitions that request a re-examination of a substitute
previously reviewed under the SNAP program, the submitter may
reference the prior submittal rather than submitting separate
information. In this case, the petitioner should specifically
summarize in the rationale for the petition any new or additional
data.
C. Sufficiency of Data
Petitioners should be aware that insufficient data may prevent
the Agency from reaching a speedy decision on whether to grant
or deny a petition. EPA will not consider a petition "received"
for the purposes of triggering the 90-day review prescribed
by section 612(d) until the submission includes as much of the
information needed to rule on the petition as the petitioner
can reasonably be expected to obtain. As provided in section
612(d), any petition must "include a showing by the petitioner
that there are data on the substance adequate to support the
petition." Petitioners may provide citations to scientific
literature,
where appropriate. However, submitters are advised that furnishing
copies of supporting articles, reports, or letters will expedite
the review process.
Any time the Agency receives a petition with insufficient
data, EPA will not commence review until the petitioner submits
the missing information to the best of the petitioner's ability.
To the extent the petitioner does not have the required
information,
EPA may also seek data from sources other than the petitioner,
including manufacturers or users of products that contain the
substitute. As with the 90-day SNAP notices, EPA may also decide,
based on preliminary information, to propose to list the substitute
in question as unacceptable pending the receipt of additional
data. In such cases, section 612(d) explicitly provides that
"the Administrator shall use any authority available to the
Administrator, under any law administered by the Administrator,
to acquire such information." These authorities include section
114 of the CAA as well as information collection provisions
of other environmental statutes. Where EPA cannot obtain sufficient
data, the Agency may deny the petition for lack of adequate
technical support.
D. Criteria for Evaluating Petitions
In evaluating petitions, the Agency will follow the same
criteria as for review of pre-commercialization notices. This
will ensure that both petitions and notifications are judged
by the same standards.
E. Petition Review Process
1. Petition Submittals. Today's proposal describes a generic
petition process. Petitions should be sent to the docket number
listed in the beginning of this action as well as to the SNAP
staff.
2. Petition Reviews
When the Agency receives a petition, it will log the petition
into the SNAP petition tracking system. If the petition concerns
a substitute previously either approved or restricted under
the SNAP program, the Agency will as a courtesy contact the
manufacturer of that substitute. Decisions to remove any
substitutes
from either list will be made as a result of notice-and-comment
rulemaking. The Agency requests comment on whether notice-and-
comment rulemaking procedures are required when removing a
substitute
from the acceptable list.
As explained above, the Agency will grant or deny the petition
within 90 days of receiving a complete application. If the Agency
grants a petition to either add a substance to the list of
unacceptable
substitutes or remove a substance from this list, this decision
will be formally promulgated as a rulemaking. Otherwise, responses
to petitions including explanations of petition denials will
be noticed in the next 3-month Federal Register notice updating
the SNAP determinations. Regardless of the nature of the final
determination, the Agency will inform petitioners within 90
days whether their request has been granted or denied.
If a petition is denied, the Agency will publish in the Federal
Register an explanation of the determination. If a petition
is granted, the Agency will publish the revised list incorporating
the petition decision within 6 months of reaching a determination.
Where EPA must complete rulemaking to alter the lists, the statute
requires EPA to propose, take comment on, complete final action,
and publish the revised lists within six months of the grant
of the petition.
F. Critical Use Exemption Petitions
In some cases, it may be necessary to allow limited exemptions
for specialized uses of a substitute that has been designated
as an unacceptable for a broad application within a sector.
For example, even though the Agency may restrict the general
use of a compound, it could still grant exemptions for use of
that compound in specific applications where it can be demonstrated
that no other substitute exists. The Agency will refer to such
petitions as critical use exemptions. EPA believes that it will
receive few such requests for exemptions, since the Agency is
not proposing broad restrictions unless other alternatives exist
for the application in question.
These petitions are in a special category, since they are
based on a claim that a particular substitute should be exempted
from broad regulatory restrictions because no other substitute
exists that meets performance or safety standards. The Agency
can either grant the critical use exemption based on information
independently collected, or it can base the exemption on a petition
from a vendor or end user. Any exemptions will be granted for
specific uses, and companies will not have to apply for exemptions
on a company-by-company basis.
Section 612 provides the Agency with the authority to grant
such exemptions. In section 612(c), the Clean Air Act states
that "it shall be unlawful to replace any Class I or Class II
substance with any substitute substance which the Administrator
determines may present adverse effects to human health or the
environment, where the Administrator has identified an alternative
to such replacement that-(1) reduces the overall risk to human
health and the environment; and (2) is currently or potentially
available." As a result, the Agency is not authorized to restrict
use of a substitute if that substitute is the only currently
or potentially available alternative to the Class I or Class
II substance.
However, in publicizing critical use exemptions for niche
applications, the Agency will encourage other companies or vendors
to challenge each critical use exemption. It is EPA's hope that
this may bring to light new alternatives or processes of which
the petitioner and EPA are unaware, and that these new alternatives
may pose lower overall risks than the substances which have
been the subject of the critical use exemption. If an exemption
is revoked based on the availability of a new, lower-risk
alternative,
companies that have made investments in technology which was
earlier deemed a "critical use" may be granted permission to
extend their use for a limited period of time.
If this approach to critical use exemption petitions is adopted
in the final rule, the Agency will issue guidance describing
additional documentation petitioners should include. This
information
could include descriptions of:
Substitutes examined and rejected;
Process or product in which the critical use substitute
is needed;
Reason for rejection of other alternatives, e.g., performance,
technical or safety standards; and/or
Anticipated date other substitutes will be available and
projected time for switching.
In addition to this basic information, the guidance will
also include specific data for critical use petitions in each
sector.
For example, to evaluate critical use applications for solvent
cleaning substitutes, the Agency will also need information
on the soils to be removed, the substrate, and the type of part
being cleaned. This information is requested not only to aid
the evaluation of the petition, but also so that the Agency
can help the petitioner identify other potential alternatives.
As noted previously, critical use exemption petitions will be
processed through notice-and-comment rulemaking.
IX. Preliminary Listing of Substitutes
A. Overview
This section presents EPA's proposed listing decisions for
Class I chemical substitutes in the following applications:
refrigeration, foam blowing, solvent cleaning, fire extinguishing,
sterilants, aerosols, tobacco expansion and adhesives, coatings
and inks. Parts D through J below present a detailed discussion
of the proposed substitute listing determinations for each of
the major use sectors. Tables that summarize the key proposed
listing decisions in this section are included in Appendix B.
As discussed earlier in this action, the Agency is proposing
to exclude substitutes in other applications from the listing
decisions.
To develop the lists of unacceptable and acceptable substitutes,
EPA conducted screens of health and environmental risks posed
by various substitutes for Class I compounds in each use sector.
These screens are presented in individual background documents
entitled "Risk Screen on the Use of Substitutes for Class I
Ozone-Depleting Substances" for each use sector. Based on these
analyses, EPA classified as "unacceptable" only uses of substitutes
that pose significantly higher human health and environmental
risks than those risks that would accrue through either continued
use of the Class I substances themselves or through use of other
available substitutes.
The assessments presented in the background documents are
screens of the comparative risks posed by use of substitutes,
not assessments or rankings of the absolute risks associated
with use of each substitute. Designating a substitute as
"acceptable"
does not imply the absence of risks for that substitute, but
rather that the substitute in question is believed to present
lower overall risks than the Class I compound it is replacing.
For instance, in some cases, ozone-depleting substances can
be replaced by chemicals with known toxicity or ability to
contribute
to ground-level ozone formation. The Agency's risk screen analyzes
these effects, and the SNAP determinations describe as "acceptable"
those substitutes for which any risks from replacements would
be small compared to aggregate risks from other existing, similar
sources or for which such risks could be managed by developing
and implementing appropriate regulatory controls.
The risk characterization does not at present include assessment
of the environmental transformation products of the substitutes.
Research efforts of the Agency in cooperation with the Alternative
Fluorocarbons Environmental Acceptability Study (AFEAS) are
in progress and are intended to define the chemical, biological
and photochemical sinks for these substances in the biosphere.
Ultimately, these research activities will contribute to the
development of ecological risk assessment for substitutes.
Additionally, in cases where the Agency has proposed listing
a substitute as unacceptable, it has assessed-as required in
section 612-the availability of other substitutes and concluded
that alternatives were currently or potentially available. This
assessment includes a review of the affordability of other
available
substitutes.
As a rule, the Agency did not evaluate the technical performance
of a substitute, since the purpose of the SNAP program is to
examine environmental effects of substitutes identified as being
of commercial interest regardless of technical acceptability.
However, in certain sectors, performance of the substitute does
pertain directly to environmental or health effects. For example,
in refrigeration, the ability of a refrigerant replacement to
serve as a coolant will directly influence the substitute's
energy efficiency, which in turn will affect the substitute's
environmental effects. Similarly, in fire extinguishing, the
ability of a substitute to put out fires and thereby save human
lives will directly affect a substitute's health effects. Further,
in the case of critical use exemption petitions, the Agency's
decision to grant or deny such a petition may hinge on questions
of technical performance. For example, in the case of certain
specialized solvents, some substitutes otherwise considered
unacceptable may require critical use exemptions because they
are the only available substitute offering performance
characteristics
deemed essential in a certain application. In cases such as
these, the SNAP analyses do consider the performance of a
substitute.
EPA's evaluation of each substitute in each end use is based
on the following types of information and analyses:
Atmospheric effects are assessed by predicting ozone depletion
and global warming. Ozone depletion is based on market penetration
of a substitute and is measured in terms of cumulative Clx loadings
and its effect in terms of increased incidence of skin cancer
cases and skin cancer mortalities. Changes in global temperatures
may result from releases of the substitutes themselves or from
changes in fossil fuel use due to increases or decreases in
energy efficiency resulting from production or use of the
substitutes.
The model used by the Agency to determine these effects-the
Atmospheric Stabilization Framework model-has been used by the
Agency in calculating the benefits from the phase-out of Class
I substances. This model was peer-reviewed in connection with
this earlier analysis. Although scientific studies have pointed
to the possibility of ecological effects due to ozone depletion,
such as crop damage, the scope of existing studies is limited
and therefore these effects were not considered as part of this
analysis. As the sophistication of analyses on this topic advances,
the Agency will include estimates of ecological effects in its
modeling of atmospheric impacts.
Exposure assessments are used to estimate concentration
levels of substitutes to which workers, consumers, the general
population, and environmental receptors may be exposed, and
over what period of time. These assessments are based on personal
monitoring data or area sampling data if available. Otherwise,
exposures are assessed using measured or estimated releases
as inputs to mathematical models. Exposure assessments may be
conducted for many types of releases, including releases in
the workplace and in homes, releases to ambient air and surface
water, and releases from the management of solid wastes.
Toxicity data are used to assess the possible health and
environmental effects from exposure to the substitutes. If
Occupational
Safety and Health Administration (OSHA)-approved or EPA-wide
health-based criteria such as Permissible Exposure Limits (PELs;
for occupational exposure), inhalation reference concentrations
(RFCs; for noncarcinogenic effects), or cancer slope factors
(for carcinogenic risk) are available for a substitute, exposure
information is combined with this toxicity information to determine
whether there is reason for concern. Otherwise, toxicity data
are used in conjunction with existing EPA guidelines to develop
health-based criteria for interim use in these risk
characterizations.
Flammability is examined as a possible safety concern for
workers and consumers. EPA assesses flammability risk using
data on flash point and flammability limits (e.g., OSHA
flammability/combustibility
classifications), test data on flammability in consumer
applications
conducted by independent laboratories (e.g., Underwriters
Laboratories),
and information on flammability risk minimization techniques.
Some of the proposed substitutes are volatile organic compounds
(VOCs), chemicals that increase tropospheric air pollution by
contributing to ground-level ozone formation. Local and nationwide
increases in VOC loadings from the use of substitutes is also
evaluated.
In conducting these assessments, EPA made full use of previous
analyses performed by the Agency, including the 1990 interim
hazard assessments and supporting documentation. These analyses
were modified in some cases to incorporate more recent data
or to accommodate different analytical approaches as needed.
Where possible, EPA incorporated data submitted in response
to the ANPRM; EPA will continue to review data provided in these
submissions between proposal and promulgation of the SNAP
rulemaking.
Finally, these analyses assume that the regulated community
complies with applicable requirements of other statutes and
regulations administered by EPA (e.g., recycling requirements
promulgated under the CAA) and other Federal agencies (e.g.,
any enforceable occupational exposure limits set by OSHA).
Where further data become available at a later date that
would help characterize the risks of substitutes, the Agency
will incorporate this data into its risk screens. For example,
as mentioned above, the risk screen does not at present include
assessment of the environmental transformation products of
substitutes.
Research efforts of the Agency in cooperation with the Alternative
Fluorocarbons Environmental Acceptability Study (AFEAS) are
in progress and are intended to define the chemical, biological
and photochemical sinks for these substances in the biosphere.
Ultimately, these research activities will contribute to the
development of more complete ecological risk assessments for
substitutes. However, the Agency generally does not believe
that a more detailed characterization of risks would lead to
a different listing decision for individual substitutes, since
the critical comparison for policy purposes remains the adverse
effects posed by continued use of a Class I compound.
The Agency requests comment on its application of the proposed
decision criteria in the listing determinations proposed today,
which include acceptable and unacceptable substitutes by sector.
EPA further solicits additional information on substitutes.
However, the decisions included in today's proposal will not
be final until the SNAP program is promulgated.
It should be noted that the listing of acceptable and
unacceptable
substitutes is an on-going process. Thus, if a company is not
yet able to provide the Agency with the information needed to
complete a review of a substitute, a review can be completed
in the future, when data become available. Once this rule is
promulgated, the substitute may be submitted to the Agency for
review as part of the formal SNAP program, as discussed in Sections
IV through IX of today's proposal.
B. Format for SNAP Determinations
Sections D through J below present the proposed decisions
on acceptability of substitutes that EPA has made based on
available
information and the proposed evaluation criteria (see Section
V of today's proposal). These sections describe the application
(e.g., industrial-process refrigeration), the substitutes
evaluated,
the proposed decision (i.e., acceptable or unacceptable) and
associated rationale, conditions for use of the substitute,
and any general comments.
In most cases, the application descriptions have been written
broadly to encompass numerous industrial uses. Based on discussions
with industry, the Agency felt that this approach was preferable
to listing substitutes by narrowly-defined applications, which
would increase needlessly the number of SNAP notices that would
be received by the Agency. The objective of section 612 is to
ensure that replacements of Class I and Class II substances
with available substitutes will reduce adverse effects on human
health and the environment. In general, the Agency can look
at exposures from very broad classifications of use (e.g., metals
cleaning) and perform the screening analysis to ensure that
this statutory objective is being met. It is not necessary or
helpful, for example, to list acceptable substitutes by each
specific type of metal being cleaned in the solvents sector.
This is especially true when conservative assumptions used in
the screening analysis demonstrate the acceptability of a wide
range of alternatives. EPA requests comment on the descriptions
of industrial applications and solicits comment and data, in
particular, on those instances where more detail may be needed.
Where possible, the substitutes presented in sections D through
J have been identified by their chemical name. Generally speaking,
EPA has not listed substitutes by product or company name in
order to avoid implied endorsement of one substitute over another.
However, there are two instances in which specific chemical
names have not been included. First, where proprietary blends
have been identified as substitutes, the Agency has worked with
the manufacturers to identify generic ways in which the substitute
could be listed. Before a user invests in a substitute in these
categories, they may wish to contact the SNAP coordinator to
confirm that the substitute they intend to use has been reviewed
and approved by EPA. However, if a potential user identifies
the substitute by a product name that EPA has on record, but
has not included on the list for the reasons stated above, EPA
will confirm the listing of the substitute without violating
any proprietary business information provided in confidence
to the Agency. The Agency requests comment on this proposed
approach for listing and disseminating information on confidential
substitutes.
The second situation in which EPA does not anticipate listing
specific chemicals arises in the solvent-cleaning sector, primarily
for aqueous and semi-aqueous cleaners. In this area, numerous
cleaning formulations exist and are comprised of a wide variety
of chemicals. As discussed in the section below on solvent-cleaning
alternatives (see Section IX. F.), the Agency performed its
screening assessment by identifying representative chemicals.
These were then used to screen a wide variety of chemicals grouped
into categories of solvent-cleaning constituents (e.g.,
saponifiers,
surfactants, etc.). Rather than require users to compare the
toxicity of chemicals in the formulations they wish to use to
this set of reference chemicals, the Agency is proposing to
use its risk screen to establish a list of common types of
chemicals
found in cleaning formulations. This list could then be used
by companies as guidance on the types of chemicals expected
to be found in a cleaning formulation.
EPA proposes this strategy for listing acceptable aqueous
and semi-aqueous cleaners for several reasons. First, it should
minimize the need to submit SNAP notices for blends of compounds
that are combinations of the chemicals on the cleaning formulation
components list. Second, it will allow EPA to avoid listing
proprietary formulations. The Agency requests comment on the
usefulness of this proposed approach for listing aqueous and
semi-aqueous cleaners.
Any conditions for use included in listing decisions are
part of the decision to identify a substitute as acceptable.
Thus, users would be considered out of compliance if using a
substitute listed as "acceptable" without adhering to the
conditions
EPA has stipulated for acceptable use of the alternative. The
conditions, if any, are listed when it is clear that a substitute
can only be used safely if certain precautions are maintained.
As noted previously, listing of substitutes as approved subject
to conditions will be done through rulemaking.
The comments contained in the table of listing decisions
found in summary form in Appendix B are intended to provide
additional information on a substitute. Since comments are not
part of the regulatory decision, they are not mandatory for
use of a substitute. However, EPA encourages users of approved
substitutes to apply any comments in their use of these
substitutes.
In many instances, the comments simply allude to good operating
practices that have already been identified in existing industry
and/or building-code standards. Thus, many of the comments,
if adopted, would not require significant changes in existing
operating practices for the affected industry.
C. Decisions Universally Applicable
Recently, the Agency has become aware of substitute mixtures
that are being marketed as replacements for both Class I and
Class II chemicals. In situations where these mixtures are a
combination of Class I and Class II chemicals, they may serve
as transitional chemicals because they offer environmental
advantages
in that they have a lower combined ODP than use of a Class I
compound by itself. However, where EPA has identified an
alternative
in addition to the Class I and Class II mixture and that
alternative
reduces overall risk to human health and the environment, such
mixtures shall be unacceptable.
There have been a few instances in which mixtures of Class
I and Class II chemicals have been marketed as replacements
for Class II chemicals. Because the ODP of these alternatives
is clearly higher than the Class II substances, the Agency is
proposing to prohibit the use of any Class I and Class II mixture
as a replacement for a Class II chemical. Where the Agency is
aware of specific mixtures falling into this category, they
are listed by individual use sector below. The remainder of
this section presents the initial listing decisions for each
of the following end use sectors:
D. Refrigerants
E. Foam Blowing
F. Solvents Cleaning
G. Halons
H. Sterilants
I. Aerosols
J. Tobacco Expansion
K. Adhesives, Coatings and Inks
D. Refrigerants
1. Overview
The refrigeration industry was the first to make widespread
use of CFCs after this class of chemical compounds was discovered
in the 1930s. In 1990, refrigeration and air conditioning accounted
for almost 22 per cent of the total use of Class I substances
in the United States. Over 500 million pieces of refrigeration
and air conditioning equipment use these chemicals as the working
fluids in a vapor compression cycle.
Many Class I substances exhibit desirable thermophysical
properties for use in refrigeration cycles. They are relatively
nontoxic, nonflammable, and inexpensive to produce; all these
characteristics have contributed to their appeal as refrigerants.
CFC-12 is the most widely used refrigerant, with applications
in mobile air conditioners (MACs), household refrigerators and
freezers, various appliances, chillers, retail food refrigeration
equipment, cold storage warehouses, refrigerated transport systems,
and industrial equipment. CFC-11 is most commonly used to provide
cooling for large buildings, while CFC-115, as a component in
the refrigerant blend R-502, is used for low temperature
applications.
CFC-113 and CFC-114 are used in special application chillers.
Of the Class II controlled substances, HCFC-22 is the
refrigerant
of choice in small to medium air conditioning systems, and some
types of retail food and industrial process refrigeration systems.
Chillers used for commercial air conditioning can be categorized
by cooling capacity. The lowest cost options for capacities
below 200 tons are usually reciprocating chillers operating
with HCFC-22. These chillers are usually air-cooled. Water cooling
requires the use of cooling towers and a ready supply of water.
There is a greater range of options for air conditioners
in the cooling capacity range of 150 to 1200 tons. Low-pressure
centrifugal chillers using HCFC-123 are available for this
capacity.
In addition, screw and centrifugal chillers using higher pressure
refrigerants such as HCFC-22 or HFC-134a are also available
for these capacities.
For chiller cooling capacities above 1200 tons, high-pressure
centrifugal chillers currently dominate the market. At least
two manufacturers offer factory-packaged HCFC-22 centrifugals
up to roughly 2000 tons. Field-erected systems are available
in larger sizes. Multiple low-pressure HCFC-123 centrifugals
are also an option.
Alternative substances, such as lithium bromide/water absorption
chillers, are also available with cooling capacities up to 1500
tons or more. These systems use heat, usually from steam or
natural gas, to power the refrigeration cycle. Ideal applications
are those where waste heat above 200 degrees F is available to
power
the chiller. Another application is for heat recovery when a
great deal of heat below 150 degrees F is required and there is a
significant
cooling load. Still another application, mainly for cold storage
warehouses, involves lowering the pressure at which natural
gas travels through pipelines at pressure drop stations to achieve
cooling of a transfer medium, such as methanol/water or ethylene
glycol.
EPA has divided the refrigeration and air conditioning sector
into the following general end uses:
commercial comfort air conditioning (chillers)-centrifugal,
reciprocating, and screw chillers used to provide air conditioning;
residential refrigerators;
residential freezers;
residential dehumidifiers used to control the humidity
in homes;
cold storage warehouses-public and private facilities used
to store meat, produce, dairy products, frozen foods, and other
perishable goods;
commercial ice machines-equipment used to produce ice for
commercial purposes;
industrial process refrigeration systems used in the chemical,
pharmaceutical, petrochemical, and other manufacturing and food
processing industries, as well as industrial ice machines and
ice rinks;
transport refrigeration, including refrigerated ship holds,
trucks and truck trailers, railway freight cars, and shipping
containers;
retail food refrigeration, including equipment found in
supermarkets, convenience stores, restaurants, hotel and
institutional
kitchens, and other food service establishments;
mobile air conditioning used to control passenger compartment
humidity and temperature in cars, trucks, buses, planes and
other vehicles;
residential and commercial air conditioning and heat pumps-
window units, packaged terminal air conditioners, central air
conditioners, direct expansion commercial air conditioners,
and heat pumps.
Industry has invested heavily in the search for suitable
alternative refrigerants that exhibit the favorable characteristics
of the controlled substances, but that do not contribute to
stratospheric ozone depletion or global warming. The
hydrochlorofluorocarbons
(HCFCs) and hydrofluorocarbons (HFCs) have received the most
attention, along with expanded use of traditional refrigerants
such as ammonia and hydrocarbons. In some cases, the most promising
solution appears to be a blend of refrigerants. The 1991 report
by UNEP's Refrigeration, Air Conditioning, and Heat Pumps Technical
Options Committee contains detailed information about the status
of alternative refrigerants in various applications.
Clearly, an important role will be played by blends of
refrigerants.
There are currently multiple blends in various stages of research,
testing and market development, and as the search for optimal
replacements continues, the number of blends will increase.
Because of the impossibility of performing full SNAP analyses
for all possible blends in all conceivable permutations, the
Agency, between proposal and issuance of the final rule, will
explore ways to streamline EPA's consideration of substitute
refrigerant blends under the SNAP program.
One issue which EPA will be investigating further with respect
to refrigerant blends is differential fractionation which may
result in flammability and energy efficiency problems. For example,
in a centrifugal chiller system equipped with a flooded evaporator
(liquid refrigerant is situated on the outside of tubes through
which water is flowing), the evaporator may act as a distillation
device for the blend. The higher-pressure components may boil
first and change to vapor, while the lower-pressure components
remain as a liquid. This process artificially lowers the
refrigerant
pressure in the evaporator which, in turn, reduces the efficiency
and capacity of the chiller. Similar reductions also can occur
when using a low refrigerant velocity blend shellside in a
condenser.
In this situation, the low-pressure components condense first,
leaving the vapor "rich" in high pressure components and causing
an increase in condensing pressure.
The section which follows discusses specific determinations
on individual substitutes by application. Appendix B at the
end of this notice summarizes in tabular form the Agency's proposed
determinations on substitutes in the refrigerants sector, which
are presented here in narrative form. These proposed determinations
are based on the risk screen described in the draft background
document entitled "Risk Screen on the Use of Substitutes for
Class I Ozone-Depleting Substances: Refrigerants".
2. Alternative Refrigerants
a. Hydrochlorofluorocarbons. EPA believes that
hydrochlorofluorocarbons
(HCFCs) have a potentially important role to play as transitional
refrigerants, both in retrofit applications and in new equipment.
HCFCs have the disadvantage that they contribute to the destruction
of stratospheric ozone, although to a much lesser extent than
CFCs. Use of HCFCs until safer alternatives are available will
allow industry to move away from CFC refrigerants more rapidly.
EPA believes that this approach will have environmental and
health benefits over one that allows continued use of CFCs until
equipment that uses other alternatives is available.
HCFCs are chemically similar to CFCs except that they contain
hydrogen in addition to chlorine and fluorine. Because their
thermophysical properties are, in many cases, similar to CFCs,
equipment designed to use CFCs can sometimes be retrofitted
to operate with HCFCs. HCFC-22 has been used as a refrigerant
for many years. It is the primary refrigerant used in small
to medium sized air conditioners, and has found increasing
application
in medium temperature retail food refrigeration systems. HCFC-
123 holds promise as the primary replacement for CFC-11 in low
pressure centrifugal chillers. HCFC-124 has potential applications
in blends as a refrigerant in chillers and other refrigeration
equipment.
Because they contain hydrogen, the HCFCs break down more
easily in the atmosphere, and therefore have lower ODPs. They
also have global warming potentials lower than the CFCs. Production
of HCFCs is controlled by the Clean Air Act and was initially
scheduled to be phased out by 2030. EPA, however, is reexamining
these dates in response to new data indicating greater risks
of ozone depletion. Based on these new concerns, EPA may propose
an earlier phase-out for some of the HCFCs, particularly those
with higher ozone-depleting potentials.
As noted above, EPA believes that HCFCs will play an important
role as transitional refrigerants. There are clear environmental
and health benefits to be gained by allowing their use until
better substitutes are developed. Future EPA analysis under
the SNAP program will focus on HCFC-22 applications and
substitutes.
b. Hydrofluorocarbons. Hydrofluorocarbons (HFCs) do not contain
chlorine and do not contribute to destruction of stratospheric
ozone. HFCs have zero ODPs, but some HFCs contribute to global
warming. Their general use is one or more years away in some
applications; in other applications, the shift to their use
has already begun. Although a few HFCs have been in use for
some time (HFC-152a is a component in the azeotropic blend CFC-
500 used in smaller tonnage reciprocating equipment and large
tonnage centrifugal equipment), the potential for HFCs as a
replacement for CFCs has grown rapidly over the last several
years. HFC-134a and HFC-152a hold the most promise as currently
available replacements for Class I and Class II refrigerants
and development of HFC-32 as a possible alternative has progressed.
c. Hydrocarbons. Since hydrocarbons do not contain chlorine
or bromine, they do not contribute to ozone depletion. They
degrade in the lower atmosphere, contributing to smog, but not
significantly to global warming.
Propane, ethane, propylene, and to some extent butane are
used as refrigerants in specialized industrial applications,
primarily in oil refineries and chemical plants, where they
are frequently available as part of the process stream and where
their use contributes only slightly to the incremental risk
of fire or explosion. These systems are designed to meet rigid
requirements for reliability, durability, and safety. ASHRAE
Standard 15, "Safety Code for Mechanical Refrigeration," and
Standard 34, "Refrigerants," are incorporated into building
codes in most of the U.S. These standards limit use of flammable
refrigerants in many applications. Hydrocarbon refrigerants
are also used in limited applications in some small appliances.
d. Ammonia. Ammonia has been used as a refrigerant in vapor
compression cycles for more than 100 years. It is by far the
refrigerant of choice in the meat packing, chicken processing,
dairy, frozen juice, brewery, cold storage, and other food
processing
and industrial applications. It is also widely used to refrigerate
holds in fishing vessels. Industrial process refrigeration
equipment
uses rotary screw or reciprocating compressors. Ammonia is mainly
used when moderate to low temperatures are required. Ammonia
has a characteristic pungent odor, excellent refrigerant
properties,
no long term atmospheric drawbacks, and is low in cost. However,
it is moderately flammable and toxic, although it is not a
cumulative
poison. OSHA standards specify a 15 minute short-term exposure
limit of 35 ppm for ammonia.
e. Perfluorocarbons. Perfluorocarbons (PFCs) are fully
fluorinated
compounds, unlike CFCs, HCFCs, or HFCs. The principal environmental
characteristic of concern for these compounds is that they have
extremely long atmospheric lifetimes, often orders of magnitude
longer than the CFCs. These long lifetimes cause the PFCs to
have very high global warming potentials. Technology for
containment
and recycling of PFCs is commercially available and is recommended
by manufacturers to offset any possible adverse environmental
effects. An important advantage of the PFCs is that, unlike
CFCs or HCFCs, they do not contribute to ozone depletion. In
addition, these chemicals are nonflammable, essentially nontoxic,
and they are exempted from Federal VOC regulations since they
do not contribute to ground-level ozone formation.
Under Section 612, the Agency has completed an analysis showing
the global warming that might be expected from atmospheric
emissions
of these compounds. The Agency further anticipates that additional,
more detailed analysis of the environmental effects of PFCs
will show that in widespread use, these compounds would pose
higher overall risk relative to other available alternatives.
Due to these concerns, the Agency has found acceptable only
certain narrowly defined uses of perfluorinated compounds. EPA
has described these limited acceptable uses as specifically
as possible. The Agency requests comment on whether further
narrative is needed to adequately describe these uses. Further,
users should be aware that, because of the environmental concerns
detailed above, any uses of PFCs outside those described herein
should be submitted for future review and approval under SNAP.
f. Absorption refrigeration systems. Absorption refrigeration
systems are the only major existing alternative to systems based
on vapor compression cycles. Ammonia is also used in absorption
refrigeration and air conditioning systems. Small ammonia
refrigeration
units are popular in recreational vehicles and in some household
applications as they need no electrically driven mechanical
compressor, relying instead on a propane flame as an energy
source. Small refrigerators using absorption technology are
produced for use in hotel rooms, where the focus is on their
silent operation rather than the lack of a suitable supply of
electricity. Small absorption systems use hydrogen to maintain
a system pressure high enough to allow the ammonia refrigerant
to evaporate at low pressure and temperature (and condense at
room temperature), and are constructed to withstand high internal
operating pressures. The absorption mechanism itself is a sealed
unit, which usually needs no servicing over its operating life.
Commercial ammonia absorption systems are used for air
conditioning
comfort cooling, particularly where waste heat is available.
As with all chillers, these produce chilled water, which is
circulated to the space being cooled. Lithium bromide is also
used in commercial absorption systems, where it serves as an
absorber. Such systems operate at very low pressure to allow
water to act as a refrigerant. Lithium bromide is a relatively
nontoxic, nonflammable, nonexplosive, chemically stable compound.
Both types of absorption chiller systems have been traditional
competitors of electrically driven CFC chillers.
g. New technologies. Chlorine has been proposed as a Class
I substitute refrigerant for use in chlorine liquefaction, a
processing step in the manufacture of the chemical. When chilled
below its boiling point, chlorine can be stored as a liquid
at atmospheric pressure, a method that for safety reasons is
preferable to storing the chemical as a pressured gas at ambient
temperatures. Compatibility of the refrigerant with liquid chlorine
is critical because of chlorine's high reactivity; CFC-12 has
been widely used because it is does not react with chlorine.
Chlorine compressors would be specialized units made to resist
chemical attack by liquid and gaseous chlorine. Because a chlorine
refrigeration system would use part of the process stream as
the refrigerant, the proposed use of chlorine as a refrigerant
is analogous to that of hydrocarbon refrigerants in the oil
and gas industry. EPA has determined that if the refrigeration
system is placed so that any leakage or losses of chlorine would
be contained and neutralized by the process safety mechanisms,
chlorine can be used safely in these specialized applications.
3. Preliminary Listing Decisions
a. General Conditions. (1) The use of HCFCs is acceptable.
This determination shall not be considered to release any user
from conformance with all other regulations pertaining to Class
II substances. These include: (a) the prohibition against venting
during servicing under section 608, which was effective July
1, 1992; (b) recycling requirements under section 608 once they
are promulgated; (c) section 609 regulations in the case of
motor vehicle air conditioners; and (d) the production phase-
out of Class II substances under section 605, which is currently
being revised as part of EPA's efforts to accelerate the phase-
out of ozone-depleting chemicals.
(2) The use of HFCs is acceptable. This determination shall
not be considered to release any user from conformance with
the venting prohibition under section 608(c)(2), which takes
effect November 15, 1995, at the latest.
b. Acceptable Substitutes. Substitutes are listed as acceptable
by end use. Accordingly, the following list of acceptable
substitutes
are only approved for those end uses explicitly identified as
acceptable. These substitutes are not identified as acceptable
alternatives in any other end use described in this section
until and unless a determination of acceptability has been made
for any other end use. EPA recommends that the users of HCFCs,
HFCs and any other alternative refrigerants adhere to the
provisions
of ASHRAE Standard 15-Safety Code for Mechanical Refrigeration,
and ASHRAE Standard 34-Number Designation and Safety Classification
of Refrigerants.
(1) HCFC-123 is acceptable as a substitute for CFC-11 in
centrifugal chillers, both in new equipment and in retrofits.
HCFC-123 is also acceptable as a substitute for CFC-12 and CFC-
500 in new centrifugal chillers. As noted above, users of HCFC-
123 should adhere to ASHRAE Standards 15 and 34. EPA worker-
monitoring studies of HCFC-123 show that 8-hour TWA can be kept
within 1 ppm (less than the interim OEL of 10 ppm) when recycling
and ASHRAE standards are followed.
(2) HCFC-22 is acceptable for use in new equipment in the
following end uses:
As a substitute for CFC-11 in centrifugal chillers;
As a substitute for CFC-12 in centrifugal chillers,
reciprocating
chillers, cold storage warehouses, residential dehumidifiers,
residential freezers, commercial ice machines, industrial process
refrigeration equipment, refrigerated transport equipment, retail
food systems, vending machines, and water coolers;
As a substitute for CFC-500 in centrifugal chillers,
dehumidifiers
and refrigerated transport systems;
As a substitute for CFC-502 in cold storage warehouses,
residential freezers, commercial ice machines, industrial process
refrigeration systems, refrigerated transport systems, and retail
food systems.
HCFC-22 is acceptable for use in existing equipment, or
retrofits,
in the following end uses:
As a substitute for CFC-12 in cold storage warehouses,
industrial process refrigeration equipment, retail food systems,
and vending machines;
As a substitute for CFC-502 in cold storage warehouses,
industrial process refrigeration equipment, retail food systems
and refrigerated transport systems.
HCFC-22 is already used in a variety of air conditioning
and refrigeration end uses. As a result, it is more widely
available
than any of the HFC substitutes.
(3) HCFC-22/HFC-152a/HCFC-124 blend is acceptable as a
substitute
for CFC-12 in retrofits of cold storage warehouses, residential
dehumidifiers, residential freezers, residential refrigerators,
commercial ice machines, industrial process refrigeration
equipment,
refrigerated transport systems, retail food systems, vending
machines, water coolers, and mobile air conditioners. Although
the blend is acceptable in these end uses, the extent to which
retrofit changes are required varies by equipment. HCFC-22/HFC-
152a/HCFC-124 blend is acceptable as a substitute for CFC-500
in retrofits of centrifugal chillers, residential dehumidifiers
and refrigerated transport. As with all blends, precautions
must be taken during recycling to avoid mixing with other
refrigerants.
(4) HFC-124 is acceptable as an alternative to new and retrofit
CFC-114 centrifugal chillers in all applications.
(5) HCFC-22/Propane/HFC-125 blend is acceptable as a substitute
for CFC-500 in refrigerated transport, both in new equipment
and in retrofits. This blend is also acceptable as a substitute
for CFC-502 in cold storage warehouses, industrial process
refrigeration,
refrigerated transport, and retail food equipment, both in new
equipment and in retrofits. Flammability has been studied and
shown to be controllable. As with all blends, care must be taken
in recycling to avoid mixing with other refrigerants.
(6) HFC-134a is acceptable for use in new equipment in the
following end uses:
As a substitute for CFC-11 in centrifugal chillers;
As a substitute for CFC-12 in household refrigerators;
cold storage warehouses, residential dehumidifiers, residential
freezers, commercial ice machines, industrial process
refrigeration,
centrifugal chillers, reciprocating chillers, refrigerated
transport,
retail food, vending machines, water coolers, and mobile air
conditioners;
As a substitute for CFC-500 in centrifugal chillers,
dehumidifiers,
and refrigerated transport; and
As a substitute for CFC-502 in industrial process refrigeration
and refrigerated transport.
HFC-134a is acceptable for use in existing equipment, or
retrofits, in the following end uses:
As a substitute for CFC-12 in centrifugal chillers,
reciprocating
chillers, cold storage warehouses, residential dehumidifiers,
industrial process refrigeration equipment, refrigerated transport
systems, retail food systems, vending machines, and mobile air
conditioners;
As a substitute for CFC-500 in centrifugal chillers and
refrigerated transport systems; and
As a substitute for CFC-502 in industrial process refrigeration
equipment, and refrigerated transport systems.
HFC-134a is potentially the most versatile substitute identified
to date as it may be possible to use it in a broad range of
applications. However, HFC-134a may be less energy efficient
than HCFC-22 in some end uses;
(7) HFC-152a is acceptable as a substitute for CFC-12 in
new household refrigerators and residential freezers.
(8) Ammonia is acceptable for use in new equipment in the
following end uses:
As a substitute for CFC-11 in centrifugal chillers;
As a substitute for CFC-12 in centrifugal chillers, cold
storage warehouses, commercial ice machines, industrial process
refrigeration equipment, and retail food systems;
As a substitute for CFC-500 in centrifugal chillers; and
As a substitute for CFC-502 in cold storage warehouses,
retail food systems, commercial ice machines, and industrial
process refrigeration equipment.
(9) Butane is acceptable for use in new equipment as a
substitute
for CFC-12 in industrial process refrigeration equipment. EPA
recommends but does not require that butane only be used at
industrial facilities which manufacture or use hydrocarbons
in the process stream.
(10) Chlorine is acceptable for use in new equipment as a
substitute for CFC-12 in industrial process refrigeration
equipment,
and as a substitute for CFC-502 in new industrial process
refrigeration
equipment. EPA recommends but does not require that chlorine
only be used at industrial facilities which manufacture or use
chlorine in the process stream.
(11) Propane is acceptable for use in new equipment as a
substitute for CFC-12 in industrial process refrigeration
equipment.
EPA recommends but does not require that propane only be used
at industrial facilities which manufacture or use hydrocarbons
in the process stream.
(12) Lithium bromide is acceptable for use in absorption
refrigeration systems. It is acceptable as a substitute for
CFC-11, CFC-12 and CFC-500 in new centrifugal chillers.
(13) High to Low Pressure Stepdown Process is acceptable
for use in energy recovery systems as a substitute for CFC-12
in new cold storage warehouse equipment.
(14) HCFC-142b is acceptable as a substitute for CFC-114
in new centrifugal chillers.
c. Unacceptable Substitutes. (1) HCFC-22/HCFC-142b/CFC-12
blend is proposed unacceptable in all HCFC-22 refrigeration
and air conditioning end uses. Because this blend contains CFC-
12 (which has an ODP 20 times that of HCFC-22), it poses a greater
risk to stratospheric ozone than the use of HCFC-22 alone.
(2) HCFC-141b is proposed unacceptable as a substitute for
CFC-11 in new centrifugal chillers. Flammability may be an issue.
Further, this material is not generally available in new equipment.
Finally, the material has a high ozone depletion potential.
(3) HCFC-22/HCFC-142b/Isobutane blend is proposed as
unacceptable
for use as a substitute for CFC-12 in retrofits of mobile air
conditioners. Flammability may be an issue, and the Agency's
final determination in this case will depend on receiving adequate
data on flammability and likely fractionation through permeable
hoses. Submission of information from industry groups, such
as from the Society for Automotive Engineers, for example,
regarding
refrigerant retrofit guidelines for specific equipment in motor
vehicle air conditioners, would help EPA evaluate such issues
as flammability and the effect of blends on recycling and recovery
efforts.
(4) Hydrocarbon Blend A is proposed as unacceptable for use
as a substitute for all CFC-12 refrigeration uses. Flammability
may be an issue. The Agency's final determination will depend
on receiving adequate data on factors such as flammability and
materials compatibility.
EPA has not found any other substitutes to be unacceptable
but may do so at a later date based on new data.
E. Foams
1. Overview
Foam plastics accounted for approximately 18 per cent of
all U.S. consumption of ozone-depleting chemicals on an ODP-
weighted basis in 1990. Five Class I chemicals-CFC-11, CFC-12,
CFC-113, CFC-114, and methyl chloroform-are used as blowing
agents in foam production. These five compounds are used in
a wide variety of applications.
The manufacture of foam plastics relies on the use of gas
or volatile liquid blowing agents to create bubbles, or cells,
in the plastic foam structure. Suitable blowing agents must
conform to a number of criteria. They must be soluble in liquid
but not in solid plastic, possess a suitable boiling point and
vapor pressure, and they must not react with plastic. In addition,
blowing agents with low thermal conductivity are desirable for
use in insulating foams. CFCs possess these desirable properties,
and hence have found widespread use as blowing agents in many
foam plastics.
Some foam plastics are characterized by a structure of closed
cells that traps the blowing agent, while others have open cells
that allow the blowing agent to escape. Although some rigid
polyurethane packaging foams are open celled, most rigid foams
have closed-cell structures. Many of these closed-cell, rigid
foams are excellent insulating materials, because the blowing
agent trapped within the cells can serve as a thermal insulator.
Flexible foams, on the other hand, generally have open cells
and are poor thermal insulators.
Foam plastics manufactured with CFCs fall into four major
categories: Polyurethane, phenolic, extruded polystyrene, and
polyolefin. Historically, CFC-11 and CFC-113, which remain in
a liquid state at room temperature, have been used as blowing
agents in polyurethane and phenolic foams. CFC-12 and CFC-114,
which have lower boiling points than CFC-11 and CFC-113 and
are gases at room temperature, are used in polyolefin and
polystyrene
foams. In addition to CFCs, methyl chloroform is used as a blowing
agent in some flexible polyurethane foams.
The major applications for foams are cushioning, packaging,
and thermal insulation. In general, cushioning and packaging
foams include flexible polyurethane foams, polyurethane integral
skin foams, polyolefin foams, and polystyrene sheet foams, while
insulating foams include rigid polyurethane foams, polystyrene
insulation board, and phenolic insulation board. However, some
rigid polyurethane foams and extruded polystyrene board have
non-insulating uses in flotation and packaging products, and
certain polyolefin foams have thermal insulating applications.
Due to the wide variety of end uses that foams represent,
the Agency has decided to divide its analysis of foam plastics
into the following ten distinct end-use sectors:
rigid polyurethane laminated boardstock;
rigid polyurethane appliance;
rigid polyurethane spray and commercial refrigeration,
and sandwich panels;
rigid polyurethane slabstock and other foams;
polystyrene extruded insulation board;
phenolic insulation board;
flexible polyurethane;
polyurethane integral skin;
polystyrene extruded sheet; and
polyolefin.
The SNAP determinations proposed today distinguish between
these ten end-use sectors because the mix of potential alternatives
to Class I blowing agents is different for each.
Rigid polyurethane foams, which serve primarily as insulation
for appliances, buildings, and refrigerated transport containers,
rely heavily on the use of CFC-11 as a blowing agent. These
foams also find use as pipe and tank insulation and as flotation
material. The low thermal conductivity of CFC-11 endows many
rigid polyurethane foams with excellent thermal insulating
qualities.
Moreover, low toxicity, low flammability, and compatibility
with key materials have made CFC-11 the blowing agent of choice
in most rigid polyurethane applications.
Extruded polystyrene insulation board, which has traditionally
used CFC-12 as a blowing agent, serves as insulation for roofs,
walls, and floors in residential and agricultural buildings,
as insulation against frost heave in roads and railways, and
as the insulating core material in sandwich panels.
Phenolic insulation board, a closed-cell insulating foam
that relies primarily on a blowing agent mixture of CFC-113
and CFC-11 for its manufacture, accounts for only a small
proportion
of the total CFC consumption in foam plastics. Closed-cell phenolic
foam serves mainly as building insulation. The foam's primary
use is as roof insulation, although it also finds use as wall
insulation in commercial applications and as sidewall sheathing
in residential applications.
CFC-11 use was, at one time, prevalent in flexible polyurethane
foams. However, the period between 1986 and 1990 saw a decrease
of over 90 per cent in the use of CFC-11 as an auxiliary blowing
agent in flexible polyurethane foams. The reduction in CFC-11
use has, to some extent, been compensated for by an increase
in methylene chloride use. Polyurethane flexible slabstock foam
is an open-celled flexible foam manufactured in a variety of
densities and degrees of firmness that finds use in many cushioning
applications. Polyurethane flexible molded foam, which is also
open-celled, serves primarily as cushioning in motor vehicles.
The production of integral skin foams, which has also
traditionally
relied on CFC-11 as a blowing agent, has seen a reduction in
CFC-11 consumption in recent years. Integral skin foams combine
a flexible, semi-rigid, or rigid foam core with a tough outer
skin. The skin results from the tendency of physical blowing
agents such as CFC-11 to condense at the mold surface during
manufacture. Rigid integral skin foams have applications in
products such as computer cabinets, skis, and tennis rackets,
while uses for semi-rigid integral skin foams include steering
wheels, head rests, arm rests, office furniture, and certain
other minor applications.
Extruded polystyrene sheet foam, which traditionally used
CFC-12, has already switched to non-CFC alternatives. Extruded
polystyrene sheet serves as food packaging in items such as
meat trays, egg cartons, and clam-shell containers. The foam
also finds use as loose fill packaging material and as art board.
Traditionally, CFC-114 and CFC-12 have been the main blowing
agents used in the production of extruded polyolefin foams,
although some CFC-11 has been used as well. Polyolefin foams
include products manufactured from either polyethylene or
polypropylene
resins. Extruded polyethylene sheet products serve primarily
as protective packaging for furniture, electronics, and other
goods. Extruded polyethylene planks are mainly used as packaging
for electronics and other high-value goods but have a number
of other applications in areas such as military packaging,
flotation,
construction, and aircraft seating. Extruded polypropylene sheet
serves as packaging in applications such as interleaving,
protective
furniture covering, and protective wrap for delicate food items.
2. Alternative Blowing Agents
The foam industry in the U.S. has been successful in
identifying,
developing, and introducing substitutes for CFC blowing agents.
However, the choice of future alternatives for CFCs will depend
on a number of factors. These include toxicity, flammability,
environmental concerns, and, in the case of insulating foams,
the insulating efficiency of alternatives.
Toxicity concerns associated with the use of alternative
chemicals relate to the exposure of workers and consumers to
the chemicals or to the decomposition products these chemicals
may form slowly over time in foam products. The likely degree
of human health risk associated with an alternative depends
not only on the nature of a substitute chemical but also on
the chemical composition, manufacturing process, and product
applications that characterize the foam end-use sector into
which that substitute will be introduced.
Flammability concerns, like toxicity concerns, have to do
with possible danger to workers and consumers. Such danger includes
possible ignition of materials during manufacturing, storage,
or transportation and the fire hazard posed by the final product.
Alternatives to CFCs have varying degrees of flammability. As
in the case of toxicity, however, the composition, production
processes, and end-use applications that characterize each foam
type will dictate the potential risks associated with flammability.
In addition to posing toxicity and flammability risks,
alternatives
may have deleterious effects on the environment. Such deleterious
effects may include stratospheric ozone depletion, global warming,
and contribution to smog formation. HCFCs have, in varying degrees,
the potential to deplete ozone; both HCFCs and HFCs have global
warming potential; and various potential alternatives, especially
hydrocarbons, are volatile organic compounds (VOCs) that contribute
to the formation of ozone, or smog, in the lower atmosphere.
The use of alternative blowing agents can have an adverse
effect on the insulating capability of foam products. Based
on initial tests, for example, the replacement of CFCs with
HCFCs in insulating foams reduced insulating efficiency. However,
formulation changes and modifications to the foam technology
have yielded HCFC-blown products with insulating efficiency
equivalent to CFC-blown products. In fact, most efforts to replace
CFC blowing agents in insulating foams over the near term involve
HCFCs, although HFCs and hydrocarbons may serve as alternatives
in a limited number of applications.
In the flexible and packaging foam sectors, there has already
been widespread movement away from CFCs to alternative, non-
HCFC auxiliary blowing agents and production processes. Water,
which generates CO2, is the primary blowing agent for flexible
polyurethane foams. Auxiliary blowing agents like CFC-11, methylene
chloride or acetone confer certain desirable physical
characteristics,
such as softness or low density, to the finished product. This
trend away from use of CFCs is likely to continue in light of
EPA's proposed regulations under section 610 of the CAA that
would, beginning on November 15, 1993, ban the sale of CFCs
in flexible and packaging foams. Also, beginning on January
1, 1994, section 610 bans sale of noninsulating foams manufactured
with Class II substances. Foam used in food packaging must in
addition meet the regulatory requirements of the FDA.
a. Hydrochlorofluorocarbons. Hydrochlorofluorocarbons (HCFCs)
and HCFC blends have been, and will continue to be, important
as transitional alternatives to CFC blowing agents, particularly
in insulating foams. Two HCFCs, HCFC-123 and HCFC-141b, can
serve as virtual drop-in replacements for CFC-11 in many end-
use applications. Because of toxicity, the resultant low interim
occupational exposure level (OEL), and the lack of commercial
availability of HCFC-123, HCFC-141b represents the more likely
short-term possibility for replacing CFC-11 in several insulating
foam sectors. As a result, the Agency has determined that HCFC-
141b, despite its relatively high ODP of 0.11, represents an
important transitional alternative to CFC-11. Other HCFC
alternatives
are HCFC-22 and HCFC-142b. Although these compounds are
commercially
available and have lower ODPs than HCFC-141b, each has a boiling
point significantly lower than CFC-11. As a result, conversion
to HCFC-22 or HCFC-142b from CFC-11 generally entails significant
investment in technical and process modification. HCFC-22 and
HCFC-142b do, however, present viable, near-term alternatives
to CFC-12 in extruded polystyrene foams.
The continued availability of HCFCs, even those with relatively
high ODPs, is necessary to ensure the continued replacement
of CFC blowing agents with alternative compounds in the short
term. Production of HCFCs is controlled by the Clean Air Act
and under section 605 is scheduled for phase-out by 2030. However,
due to new data concerning greater risks of ozone depletion,
EPA has proposed an accelerated phase-out schedule. Given the
technical and safety concerns associated with many non-HCFC
alternatives, however, disallowing the interim use of HCFCs
in all foam sectors, including the use of HCFC-141b and HCFC-
22, would have adverse effects on human health and the environment.
Additional restrictions on HCFC use may be made subject to
final promulgation of section 610 for non-essential uses. Section
610 states that after January 1, 1994, it shall be unlawful
for any person to sell or distribute, or offer for sale or
distribution,
in interstate commerce, any plastic foam product which contains,
or is manufactured with, a Class II substance. Section 610(d)(2)
authorizes EPA to grant exceptions to the Class II ban for foam
insulation products, or foam used for motor vehicle safety in
accordance with section 103 of the National Traffic and Motor
Vehicle Safety Act on federal motor vehicle safety standards.
b. Hydrofluorocarbons. Hydrofluorocarbons (HFCs) represent
a zero-ODP alternative to CFC blowing agents in many sectors.
From the standpoint of stratospheric ozone depletion alone,
HFCs are preferable to HCFCs as alternative blowing agents.
However, other considerations such as flammability and cost
may limit the feasibility of HFC alternatives, especially over
the short term. Moreover, the relatively high thermal conductivity
of HFCs is likely to hamper the insulating capabilities of HFC-
blown foams. This, in turn, could result in energy efficiency
losses.
Two HFCs, HFC-134a and HFC-152a, are under consideration
as substitutes in a number of applications. Because both compounds
have boiling points that are significantly lower than that of
CFC-11, significant technical and process modifications would
be required to introduce them as replacements for CFC-11. The
HFCs hold more promise as near- or intermediate-term alternatives
for CFC-12 in extruded polystyrene foams, particularly in extruded
polystyrene sheet foams. However, issues such as flammability,
cost, commercial availability, and the solubility of HFCs in
polystyrene polymer remain of concern for extruded polystyrene
foams.
Both HFC-134a and HFC-152a have significantly higher thermal
conductivities than do any of the CFCs. Although formulation
changes and process modifications can be introduced to increase
the thermal insulating efficiency of HFC-blown foams, it is
unlikely that such changes can compensate fully for the disparity
in thermal conductivity between HFCs and CFCs, especially in
the near term. As a result, conversion to HFCs would likely
lead to the production of foams with lower insulating efficiency
and, possibly, to a reduction in the energy efficiency of
buildings,
appliances, refrigerated transport containers, and other insulated
items.
Even if technical difficulties and problems associated with
thermal conductivity can be overcome, the commercial availability
and cost of HFC-134a, and the flammability of HFC-152a, remain
of concern. Conversion to HFC-152a may entail significant capital
investment in order to ensure worker safety against fire hazards.
Moreover, in the case of insulating foams, manufacturers will
need to guarantee that foams blown with HFC-152a meet the building
code requirements that apply to the flammability of building
materials.
The Agency has determined that, although HFCs represent an
attractive alternative to CFC blowing agents in the intermediate
and long term, HFC-134a and HFC-152a are unlikely to replace
CFCs to a significant extent in the short term, especially in
insulating foams.
c. Hydrocarbons. Like HFCs, hydrocarbons represent a zero-
ODP alternative to CFC blowing agents in many sectors. From
the standpoint of ozone depletion potential and global warming
potential alone, hydrocarbons are preferable to HCFCs as
alternative
blowing agents. However, other considerations such as flammability
and concerns over ground-level air pollution may limit the adequacy
of hydrocarbons as alternatives, especially over the short term.
Moreover, the relatively high thermal conductivity of hydrocarbons
is likely to hamper the insulating capabilities of hydrocarbon-
blown foams. This, in turn, could result in energy efficiency
losses.
Hydrocarbons have significantly higher thermal conductivities
than do any of the CFCs. Although formulation changes and process
modifications can be introduced to increase the thermal insulating
efficiency of hydrocarbon-blown foams, it is unlikely that such
changes can compensate fully for the disparity in thermal
conductivity
between hydrocarbons and CFCs, especially in the near term.
As a result, conversion to hydrocarbons would likely lead to
the production of foams with lower insulating efficiency and,
possibly, to a reduction in the energy efficiency of buildings,
appliances, refrigerated transport containers, and other insulated
items.
Conversion to hydrocarbons may entail significant capital
investment in order to ensure worker safety against fire hazards.
Moreover, in the case of insulating foams, manufacturers will
need to guarantee that foams blown with hydrocarbons meet the
building code requirements that apply to the flammability of
building materials.
Hydrocarbons are VOCs that contribute to the formation of
ozone, or smog, in the lower atmosphere. Any use of hydrocarbon
blowing agents is subject to the federal and regional restrictions
that apply to VOCs, and conversion to hydrocarbons could involve
the capital investment necessary to comply with these restrictions.
Hydrocarbons have proven effective as replacements for CFCs
in many noninsulating foams. However, the Agency believes that,
although hydrocarbons have the potential to replace CFC blowing
agents in insulating foams, they are unlikely to replace CFCs
in insulating foams over the short term.
d. Other. Two other blowing agents, methylene chloride and
acetone, have proven effective as substitutes for CFC-11 in
flexible polyurethane foams. Methylene chloride, which already
serves as an auxiliary blowing agent for most grades of flexible
polyurethane foam, is commercially available, has relatively
low cost, and provides a technically feasible alternative to
CFC-11. However, because of concerns over its high toxicity,
methylene chloride use is restricted in several states and
localities;
and is subject to review under Title III of the CAA.
Acetone, when used as a blowing agent, is capable of yielding
all grades of flexible polyurethane foam. It can serve as an
alternative blowing agent where methylene chloride use is
infeasible.
Acetone is a VOC and must be controlled as such. In addition,
plant modifications may be necessary to accommodate acetone's
flammability.
The AB Technology is a commercially available and technically
feasible process for replacing CFCs or other auxiliary blowing
agents for most conventional flexible foam grades. AB Technology
employs formic acid in conjunction with water as the blowing
agent for producing flexible polyurethane foam. The process
is based on using the reaction of formic acid with an isocyanate
to produce carbon monoxide in addition to the water/isocyanate
reaction normally used to generate carbon dioxide gas for the
expansion of foam. OSHA has set a permissible exposure level
(PEL) for carbon monoxide of 35 ppm of a time weighted average
with a ceiling not to exceed 200 ppm.
Carbon dioxide (CO2) is an acceptable substitute for all
foam end-uses. One hundred percent CO2 blowing is achieved by
further increasing the water content in the foam formulation,
thereby eliminating the need for a physical blowing agent. CO2
blends acceptable as long as the other constituents of the blend
are acceptable under SNAP.
3. Primary Listing Decisions
a. Acceptable Substitutes
(1) Polyurethane, Rigid Laminated Boardstock. (a) HCFC-123
HCFC-123 is acceptable as an alternative blowing agent to
CFC-11 in rigid polyurethane laminated boardstock foam. From
the standpoint of technical feasibility, HCFC-123 represents
a viable alternative to CFC-11 as a potential blowing agent.
More specifically, the physical properties, thermal conductivity,
and aging of foams blown with HCFC-123 are similar to those
blown with CFC-11. As a result, HCFC-123, which has an ozone
depleting potential significantly lower than that of CFC-11,
has the potential to replace CFC-11 in many applications.
Nonetheless,
availability of HCFC-123 is limited at present, and furthermore
industry may be unable to meet the relatively low interim OEL
of 10 ppm set by the manufacturer. However, recent worker
monitoring
studies indicate that an interim OEL of 10 ppm can be achieved
through the use of increased ventilation, good housekeeping
and work practices, and dust collection. HCFC-123 is subject
to the phase-out of Class II compounds under section 605 of
the CAA.
(b) HCFC-141b
HCFC-141b is acceptable as an alternative to CFC-11 in rigid
polyurethane laminated boardstock foam. Although its ODP of
0.11 is relatively high, HCFC-141b, because it can serve as
a virtual drop-in substitute for CFC-11, offers almost immediate
transition out of CFCs in this sector. Not only does HCFC-141b
offer a technically feasible alternative to CFC-11, but it is
currently available or will soon be available in sufficient
quantities to meet industrial demand. The Agency has proposed
restricting the use of HCFC-141b in the proposed accelerated
phase-out of HCFCs in light of its relatively high ODP and the
fact that other zero-ODP substitutes should be available by
the phase-out dates. HCFC-141b is currently subject to the phase-
out of Class II compounds under section 605 of the CAA.
(c) HCFC-22
HCFC-22 is acceptable as a substitute for CFC-11 in rigid
polyurethane laminated boardstock foam. HCFC-22 offers an
alternative
with significantly less potential to deplete ozone than CFC-
11. Foams blown with HCFC-22 have been developed that have thermal
insulating capabilities equivalent to foams blown with CFC-11.
However, technical problems remain. New laminate materials may
be needed to counteract the solvent characteristics of HCFC-
22, and significant process changes would be necessary to
accommodate
the low boiling point of HCFC-22. HCFC-22 is subject to the
phase-out of Class II compounds under section 605 of the CAA.
(d) HCFC-142b
HCFC-142b is acceptable as a substitute for CFC-11 in rigid
polyurethane laminated boardstock foam. HCFC-142b offers an
alternative with significantly lower potential to deplete ozone
than CFC-11. Nevertheless, certain technical problems persist.
Namely, plant modifications are required to allow use of blowing
agents like HCFC-142b that have low boiling points, and the
compound's chemical and physical characteristics may lead to
rapid aging of the foam. Finally, the use of HCFC-142b results
in potentially significant losses in thermal insulating efficiency.
HCFC-142b is subject to the phase-out of Class II compounds
under section 605 of the CAA.
(e) HCFC-22/HCFC-141b
The HCFC-22/HCFC-142b blend is acceptable as a substitute
for CFC-11 in rigid polyurethane laminated boardstock foam.
Because both components of the blend are commercially available
in large enough quantities to meet industry demand, it offers
a near-term vehicle for replacing CFC-11 in laminated boardstock
foams. HCFC-22 has an occupational exposure limit of 250 ppm,
whereas HCFC-141b has an OEL of 1000 ppm. Use of the blend,
because of its HCFC-141b component, will be restricted under
the proposed accelerated phase-out of HCFCs, since other non-
ODP substitutes should become available. The HCFC-22/HCFC-141b
blend is presently subject to the phase-out of Class II compounds
under section 605 of the CAA.
(f) HCFC-22/HCFC-142b
The HCFC-22/HCFC-142b blend is acceptable as a substitute
for CFC-11 in rigid polyurethane laminated boardstock foam.
The blend offers an alternative with significantly less potential
to deplete ozone than CFC-11. Nevertheless, certain technical
problems persist. Namely, plant modifications are required to
allow use of blowing agents like HCFC-22 and HCFC-142b that
have low boiling points, and the blend's chemical and physical
characteristics may lead to rapid aging of the foam. Finally,
use of the blend results in potentially significant losses in
thermal insulating efficiency. The HCFC-22/HCFC-142b blend is
subject to the phase-out of Class II compounds under section
605 of the CAA.
(g) HCFC-141b/HCFC-123
The HCFC-141b/HCFC-123 blend is acceptable as an alternative
to CFC-11 in rigid polyurethane laminated boardstock foam. As
noted above, HCFC-141b, because of its commercial availability
and ability to serve as a virtual drop-in substitute for CFC-
11, offers an immediate opportunity to replace CFC-11. HCFC-
123, although it has the technical requirements necessary to
replace CFC-11, suffers from limited availability and concerns
over whether the interim OEL can be met. The HCFC-141b/HCFC-
123 blend offers an opportunity to use HCFC-123 while at the
same time allaying those concerns to some degree. Moreover,
because the ODP of HCFC-123 is lower than that of HCFC-141b,
the blend has a lower ODP than HCFC-141b alone. Nevertheless,
the blend, because of the HCFC-141b component, is subject to
the proposed accelerated phase-out of HCFCs. The HCFC-141b/HCFC-
123 blend is also currently subject to the phase-out of Class
II compounds under section 605 of the CAA.
(h) HFC-134a
HFC-134a is acceptable as a substitute for CFC-11 in rigid
polyurethane laminated boardstock foam. HFC-134a offers the
potential for a non-ozone-depleting alternative to CFC-11 blowing
agents in rigid polyurethane laminated boardstock foams. The
use of HFC-134a as a blowing agent in rigid polyurethane laminated
boardstock foams is currently not commercially feasible. Plant
modifications may be necessary to accommodate the use of HFC-
134a because its boiling point is lower than that of CFC-11.
In addition, there are concerns over commercial availability,
the cost of HFC-134a is likely to be high, and the use of HFC-
134a may cause significant increases in thermal conductivity,
with a concomitant loss in the insulating capacity of foams
blown with HFC-134a.
(i) HFC-152a
HFC-152a is acceptable as a substitute for CFC-11 in rigid
polyurethane laminated boardstock foam. HFC-152a offers the
potential for a non-ozone-depleting alternative to CFC-11 blowing
agents in rigid polyurethane laminated boardstock. The use of
HFC-152a as a blowing agent in rigid polyurethane laminated
boardstock foam is currently not commercially feasible, and
there are concerns over the potential for significant increases
in thermal conductivity. Process changes may be necessary to
accommodate the use of HFC-152a, and plant modifications may
be necessary to manage its flammability. Also, foams blown with
HFC-152a will need to conform with building code requirements
that relate to flammable materials.
(j) Hydrocarbons
Hydrocarbons are acceptable as substitutes for CFC-11 in
rigid polyurethane laminated boardstock foam. Of the hydrocarbons,
pentane has the greatest potential as a replacement for CFC-
11 in this sector of the foam industry. However, the use of
pentane as a blowing agent in rigid polyurethane laminated
boardstock
foam is currently not commercially feasible. Moreover, extensive
plant modifications may be necessary to accommodate the use
of pentane and other hydrocarbons. In addition, these materials
pose flammability concerns. Further, there is a potential for
significant increases in thermal conductivity that could reduce
insulating capacity; studies suggest that pentane could increase
thermal conductivity by 15 to 20 per cent over CFC-11, for example.
Foams blown with hydrocarbons will need to conform with building
code requirements that relate to flammable materials. Finally,
pentane and other hydrocarbons are VOCs and must be controlled
as such under Title I of the CAA.
(k) 2-Chloropropane
2-Chloropropane is acceptable as a substitute for CFC-11
in rigid polyurethane laminated boardstock foam. At present,
because 2-chloropropane is a proprietary technology, its commercial
availability may be limited. Moreover, 2-chloropropane is flammable
and its use may require extensive modification of existing
equipment.
(l) Carbon Dioxide
Carbon dioxide is acceptable as a substitute for CFC-11 in
rigid polyurethane laminated boardstock foam.
(2) Polyurethane, Rigid Appliance Foam (a) HCFC-123
HCFC-123, for the reasons described and with the caveats
outlined in the section on rigid polyurethane laminated boardstock,
is acceptable as an alternative to CFC-11 in rigid polyurethane
appliance foam.
(b) HCFC-141b
HCFC-141b, for the reasons described and with the caveats
outlined in the section on rigid polyurethane laminated boardstock,
is acceptable as an alternative to CFC-11 in rigid polyurethane
appliance foam.
(c) HCFC-22
HCFC-22, for reasons described and with the caveats outlined
in the section on rigid polyurethane laminated boardstock, is
acceptable as a substitute for CFC-11 in rigid polyurethane
appliance foam.
(d) HCFC-142b
HCFC-142b is acceptable as a substitute for CFC-11 in rigid
polyurethane appliance foam. HCFC-142b offers an alternative
with significantly less potential to deplete ozone than CFC-
11. Nevertheless, certain technical problems persist. Namely,
plant modifications are required to allow the use of blowing
agents like HCFC-142b that have low boiling points. HCFC-142b
is subject to the phase-out of Class II compounds under section
605 of the CAA.
(e) HCFC-22/HCFC-142b
The HCFC-22/HCFC-142b blend is acceptable as a substitute
for CFC-11 in rigid polyurethane appliance foam. The blend offers
an alternative with significantly less potential to deplete
ozone than CFC-11. Foams blown with the blend have been developed
that have thermal insulating capabilities equivalent to foams
blown with CFC-11. However, technical problems remain. New plastic
materials may be needed for appliances to counteract the solvent
characteristics of HCFC-22, and significant process changes
would be necessary to accommodate the low boiling point of the
HCFC-22/HCFC-142b blend. The blend is subject to the phase-out
of Class II compounds under section 605 of the CAA.
(f) HCFC-22/HCFC-141b
The HCFC-22/HCFC-141b blend is acceptable as a substitute
for CFC-11 in rigid polyurethane appliance foam. Because both
components of the blend are commercially available in large
enough quantities to meet industry demand, it offers a near-
term vehicle for replacing CFC-11 in rigid appliance foams.
Use of the blend, because of its HCFC-141b component, will be
restricted under the proposed accelerated phase-out of HCFCs,
since other non-ODP substitutes should become available. The
problem of toxic decomposition byproducts, although present,
is controllable. However, new plastic materials may be needed
for appliances to counteract the solvent characteristics of
HCFC-22, and some process changes may be necessary to accommodate
the low boiling point of HCFC-22. The HCFC-22/HCFC-141b blend
is presently subject to the phase-out of Class II compounds
under section 605 of the CAA.
(g) HCFC-123/HCFC-141b
The HCFC-123/HCFC-141b blend, for the reasons described and
with the caveats outlined in the section on rigid polyurethane
laminated boardstock, is acceptable as an alternative to CFC-
11 in rigid polyurethane appliance foam.
(h) HFC-134a
HFC-134a, for the reasons described and with the caveats
outlined in the section on rigid polyurethane laminated boardstock,
is acceptable as an alternative to CFC-11 in rigid polyurethane
appliance foam.
(i) HFC-152a
HFC-152a, for the reasons described and with the caveats
outlined in the section on rigid polyurethane laminated boardstock,
is acceptable as an alternative to CFC-11 in rigid polyurethane
appliance foam.
(j) Hydrocarbons
Hydrocarbons are acceptable as substitutes for CFC-11 in
rigid polyurethane appliance foam. Hydrocarbons offer the potential
of a non-ozone-depleting alternative to the use of CFC-11 blowing
agents in rigid polyurethane appliance foam. However, the use
of hydrocarbon blowing agents in rigid polyurethane appliance
foams is currently not commercially feasible. Moreover, extensive
plant modifications may be necessary to accommodate the
flammability
of hydrocarbons. In addition, the potential for significant
increases in thermal conductivity may reduce insulating capacity.
Foams blown with hydrocarbons must conform with building code
requirements that relate to flammable materials. Hydrocarbons
are VOCs and will be subject to control as such under Title
I of the CAA.
(k) Carbon Dioxide
Carbon dioxide is acceptable as a substitute for CFC-11 in
rigid polyurethane appliance foam.
(3) Rigid Polyurethane Commercial Refrigeration Foam, Spray
Foam, and Sandwich Panels (a) HCFC-123
HCFC-123, for the reasons described and with the caveats
outlined in the section on rigid polyurethane laminated boardstock,
is acceptable as an alternative to CFC-11 and CFC-12 in rigid
polyurethane commercial refrigeration foam, spray foam, and
sandwich panels.
(b) HCFC-141b
HCFC-141b, for the reasons described and with the caveats
outlined in the section on rigid polyurethane laminated boardstock,
is acceptable as an alternative to CFC-11 and CFC-12 in rigid
polyurethane commercial refrigeration foam, spray foam, and
sandwich panels.
(c) HCFC-22
HCFC-22 is acceptable as a substitute for CFC-11 and CFC-
12 in rigid polyurethane commercial refrigeration foam, spray
foam, and sandwich panels. HCFC-22 offers an alternative with
significantly less potential to deplete ozone than either CFC-
11 or CFC-12. However, significant process changes would be
necessary to accommodate the low boiling point of HCFC-22. HCFC-
22 is subject to the phase-out of Class II compounds under section
605 of the CAA.
(d) HCFC-142b
HCFC-142b, for the reasons described and with the caveats
outlined in the section on rigid polyurethane laminated boardstock,
is acceptable as an alternative to CFC-11 and CFC-12 in rigid
polyurethane commercial refrigeration foam, spray foam, and
sandwich panels.
(e) HCFC-22/HCFC-142b
The HCFC-22/HCFC-142b blend, for the reasons described and
with the caveats outlined in the section on rigid polyurethane
laminated boardstock, is acceptable as an alternative to CFC-
11 and CFC-12 in rigid polyurethane commercial refrigeration
foam, spray foam, and sandwich panels.
(f) HFC-134a
HFC-134a, for the reasons described and with the caveats
outlined in the section on rigid polyurethane laminated boardstock,
is acceptable as an alternative to CFC-11 and CFC-12 in rigid
polyurethane commercial refrigeration foam, spray foam, and
sandwich panels.
(g) HFC-152a
HFC-152a, for the reasons described and with the caveats
outlined in the section on rigid polyurethane laminated boardstock,
is acceptable as an alternative to CFC-11 and CFC-12 in rigid
polyurethane commercial refrigeration foam, spray foam, and
sandwich panels.
(h) Hydrocarbons
Hydrocarbons, for the reasons described and with the caveats
outlined in the section on rigid polyurethane laminated boardstock,
are acceptable alternative blowing agents for CFC-11 and CFC-
12 in rigid polyurethane commercial refrigeration foam, spray
foam, and sandwich panels.
(i) Carbon Dioxide
Carbon dioxide is an acceptable alternative blowing agent
for CFC-11 in rigid polyurethane commercial refrigeration foam,
spray foam, and sandwich panels.
(4) Polyurethane Slabstock and Other Foams (a) HCFC-123
HCFC-123 is acceptable as an alternative to CFC-11 in rigid
polyurethane slabstock and other foams. From the standpoint
of technical feasibility, HCFC-123 represents a viable alternative
to CFC-11 as a potential blowing agent. More specifically, the
physical properties, thermal conductivity, and aging of foams
blown with HCFC-123 are similar to those blown with CFC-11.
As a result, HCFC-123, which has an ozone depleting potential
significantly lower than that of CFC-11, has the potential to
replace CFC-11 in many applications. Nonetheless, commercial
availability of HCFC-123 is limited at present, and it is unclear
that industry can meet the relatively low interim OEL of 10
ppm set by the manufacturer. Nevertheless, recent worker monitoring
studies indicate that an interim OEL of 10 ppm can be achieved
through the use of increased ventilation, good housekeeping
and work practices, and dust collection. Certain slabstock and
other foams manufactured with HCFC-123 may be subject to the
January 1, 1994 ban on Class II substance use in noninsulating
foams. HCFC-123 is subject to the phase-out of Class II compounds
under section 605 of the CAA.
(b) HCFC-141b
HCFC-141b is acceptable as an alternative to CFC-11 in rigid
polyurethane slabstock and other foams, provided that these
foams are used for insulating or flotation purposes. Although
its ODP of 0.11 is relatively high, HCFC-141b, because it can
serve as a virtual drop-in substitute for CFC-11, offers almost
immediate transition out of CFCs in this sector. Not only does
HCFC-141b offer a technically feasible alternative to CFC-11,
it is currently available in sufficient quantities to meet the
demands of industry. The Agency will be proposing to restrict
the use of HCFC-141b in the accelerated phase-out of HCFCs because
other non-ODP substitutes should become available. The problem
of toxic decomposition byproducts, although present, is
controllable.
With the exception of flotation foams, EPA believes that HCFC-
141b is not acceptable for use in noninsulating applications,
such as rigid polyurethane packaging or floral foams. The Agency
has decided to allow the use of HCFC-141b in rigid polyurethane
flotation foams until January 1, 1994, the effective date of
the section 610 ban on Class II noninsulating foams manufactured
with HCFCs becomes effective. HCFC-141b is also subject to the
phase-out of Class II compounds under section 605 of the CAA.
(c) HCFC-22
HCFC-22 is acceptable as a substitute for CFC-11 in rigid
polyurethane slabstock and other foams. HCFC-22 offers an
alternative
with significantly less potential to deplete ozone than either
CFC-11 or CFC-12. However, significant process changes may be
necessary to accommodate the low boiling point of HCFC-22. Certain
slabstock and other foams manufactured with HCFC-22 may be subject
to the January 1, 1994 ban on Class II substance use in
noninsulating
foams. HCFC-22 is subject to the phase-out of Class II compounds
under section 605 of the CAA.
(d) Hydrocarbons
Hydrocarbons, for the reasons described and with the caveats
outlined in the section on rigid polyurethane laminated boardstock,
are acceptable alternative blowing agents for CFC-11 and CFC-
12 in rigid polyurethane slabstock and other foams.
(e) Carbon Dioxide
Carbon dioxide is an acceptable alternative blowing agent
for CFC-11 and CFC-12 in rigid polyurethane slabstock and other
foams.
(5) Extruded Polystyrene Insulation Board. (a) HCFC-22
HCFC-22 is an acceptable alternative blowing agent for CFC-
12 in extruded polystyrene boardstock foam. HCFC-22 offers an
alternative with significantly less potential to deplete ozone
than CFC-12. HCFC-22, however, has a relatively high permeation
rate out of polystyrene thus affecting insulation performance.
HCFC-22 is subject to the phase-out of Class II compounds under
section 605 of the CAA.
(b) HCFC-142b
HCFC-142b is an acceptable alternative blowing agent for
CFC-12 in extruded polystyrene boardstock foam. HCFC-142b offers
an alternative with significantly less potential to deplete
ozone than either CFC-11 or CFC-12. HCFC-142b is subject to
the phaseout of Class II compounds under section 605 of the
CAA.
(c) HCFC-22/HCFC-142b
The HCFC-22/HCFC-142b blend is acceptable as a substitute
for CFC-12 in extruded polystyrene boardstock foam. The blend
offers an alternative with significantly less potential to deplete
ozone than CFC-12. The blend is subject to the phase-out of
Class II compounds under section 605 of the CAA.
(d) HFC-134a
HFC-134a is acceptable as a substitute for CFC-12 in extruded
polystyrene insulation board foam. HFC-134a offers the potential
for a non-ozone-depleting alternative to CFC-12 blowing agents
in extruded polystyrene insulation board. HFC-134a, because
of its low flammability and encouraging performance in
toxicological
testing, exhibits definite advantages from the standpoints of
environmental risk and worker and consumer safety. However,
HFC-134a has relatively high thermal conductivity and cost.
In addition, the compound has poor solubility in polystyrene
polymer, which could limit its usefulness as an alternative
blowing agent from a technical standpoint.
(e) HFC-152a
HFC-152a is acceptable as a substitute for CFC-12 in extruded
polystyrene insulation board foam. HFC-152a offers the potential
for a non-ozone-depleting alternative to CFC-12 blowing agents
in extruded polystyrene boardstock. However, the high flammability
of HFC-152a when combined with its properties of high thermal
conductivity, low solubility in polystyrene polymer, and high
permeability through polystyrene limit the extent to which HFC-
152a is likely to replace CFC-12. Plant modifications may be
needed to accommodate the flammability of HFC-152a, and foams
blown with HFC-152a will need to conform with building code
requirements that relate to flammable materials.
(f) Hydrocarbons
Hydrocarbons are acceptable as substitutes for CFC-12 in
polystyrene insulation board foam. Of the hydrocarbons, pentane,
isopentane, butane, and isobutane have been demonstrated as
feasible blowing agents in polystyrene. In fact, hydrocarbons
have been used for years in the manufacture of extruded polystyrene
sheet products. However, hydrocarbons have several disadvantages
as blowing agents in extruded polystyrene boardstock. Replacement
of CFC-12 blowing agents with hydrocarbons is likely to reduce
significantly the insulating efficiency of extruded polystyrene
boards. Moreover, hydrocarbon-blown foams cannot presently attain
the thickness that CFC-blown foams do. Controlling the flammability
of hydrocarbons entails significant investment in plant conversion
to accommodate them as alternatives to CFC-12. Also, foams blown
with hydrocarbons will need to conform with building code
requirements
that relate to flammable materials. Finally, hydrocarbons are
VOCs and must be controlled as such under Title I of the CAA.
(g) HCFC-22/Hydrocarbons
Blends of HCFC-22/hydrocarbons, for the reasons described
and with the caveats outlined above for HCFC-22 and hydrocarbons,
are proposed as acceptable substitutes for CFC-12 in extruded
polystyrene boardstock foam.
(h) Carbon Dioxide
Carbon dioxide is an acceptable alternative blowing agent
for CFC-12 in extruded polystyrene boardstock foam.
(6) Phenolic Insulation Board. (a) HCFC-141b
HCFC-141b, for the reasons described and with the caveats
outlined in the section on rigid polyurethane laminated boardstock,
is acceptable as an alternative to CFC-11 and CFC-113 in phenolic
insulation board.
(b) HCFC-142b
HCFC-142b, for the reasons described and with the caveats
outlined in the section on rigid polyurethane laminated boardstock,
is acceptable as an alternative to CFC-11 and CFC-113 in phenolic
insulation board.
(c) HCFC-22
HCFC-22, for the reasons described and with the caveats outlined
in the section on rigid polyurethane commercial refrigeration
foams, spray foams, and sandwich panels, is acceptable as an
alternative to CFC-11 and CFC-113 in phenolic insulation board.
(d) HCFC-22/HCFC-142b
The blend HCFC-22/HCFC-142b, for reasons described above
and with the caveats outlined above for HCFC-22 and HCFC-142b,
is acceptable as an alternative to CFC-11 and CFC-113 in phenolic
insulation board.
(e) Hydrocarbons
Hydrocarbons, for the reasons described and with the caveats
outlined in the section on rigid polyurethane laminated boardstock,
are acceptable alternatives to CFC-11 and CFC-113 in phenolic
insulation board.
(f) HCFC-22/Hydrocarbons
HCFC-22/Hydrocarbon blends are acceptable a substitute for
CFC-11 and CFC-113 in phenolic insulation board.
HCFC-22/hydrocarbon
blends offer an alternative with significantly less potential
to deplete ozone than either CFC-11 or CFC-113. However, extensive
plant modifications may be necessary to accommodate use of these
blends. In addition, there are concerns about the potential
for significant increases in thermal conductivity resulting
from the replacement of CFC-11 and CFC-113 with a blend. Also,
foams blown with hydrocarbons will need to conform with building
code requirements that relate to flammable materials. Hydrocarbons
are VOCs and must be controlled as such under Title I of the
CAA, and HCFC-22 is subject to the phase-out of Class II compounds
under section 605 of the CAA.
(g) 2-Chloropropane
2-Chloropropane is acceptable as a substitute for CFC-11
and CFC-12 in phenolic insulation board. At present, because
2-chloropropane is a proprietary technology, its commercial
availability may be limited. Moreover, 2-chloropropane is flammable
and its use may require extensive modification of existing
equipment.
(h) Carbon Dioxide
Carbon dioxide is an acceptable alternative blowing agent
for CFC-11 and CFC-12 in phenolic insulation board.
(7) Flexible Polyurethane Foam. (a) Methylene Chloride
Methylene chloride is acceptable as a blowing agent in flexible
polyurethane foams, provided that it is used in accordance with
relevant OSHA standards and that its use meets future ambient
air controls for hazardous pollutants under Title III of the
CAA. Methylene chloride is already used as an auxiliary blowing
agent in the manufacture of most flexible polyurethane slabstock
foams and has proven adequate in yielding foams of many densities
and degrees of softness. Replacement of CFC-11 or methyl chloroform
blowing agents with methylene chloride can reduce the potential
for stratospheric ozone depletion resulting from the production
of flexible polyurethane foams.
Nevertheless, there is widespread concern over the potential
health and safety hazards that methylene chloride poses. In
fact, due to these concerns, some local and regional restrictions
apply to the use of methylene chloride. To assess these risks
in the application under discussion, EPA used data collected
by the Occupational Safety and Health Administration (OSHA)
for the proposed revision of the permissible exposure level
(PEL) for methylene chloride. The Agency's estimate for total
population risk for methylene chloride was based on average
plant emissions derived from OSHA's values, and while not
negligible,
was within the range of existing Agency decisions on acceptable
risk. The Agency solicits comment on risks associated with the
use of methylene chloride in open-cell foam blowing. For further
detail, refer to the background document entitled "Risk Screen
on Use of Substitutes for Class I Ozone-Depleting Substances:
Foams".
In light of toxicity concerns, the Agency has decided to
allow the use of methylene chloride subject to existing or future
restrictions. Methylene chloride use must meet all future ambient
air controls for hazardous air pollutants under Title III of
the CAA. In addition, use of the compound must conform to all
relevant workplace safety standards; OSHA has proposed permissible
exposure levels (PELs) for methylene chloride of 25 ppm on a
time-weighted average (TWA).
(b) Acetone
Acetone is acceptable as a blowing agent for flexible
polyurethane
foams, provided that it is controlled as a VOC under Title I
of the CAA. In those areas where methylene chloride use is deemed
unacceptable, acetone may provide another non-ODP alternative
to CFC-11 and methyl chloroform. All grades of flexible
polyurethane
foam produced with CFCs can be produced using acetone as an
auxiliary blowing agent. Acetone does not have an ozone depletion
potential, its global warming potential is negligible.
Nevertheless,
acetone is highly flammable and its use requires special
precautions
to ensure adequate ventilation. In addition, the compound may
be subject to controls as a VOC under Title I of the CAA.
(c) HCFC-123
HCFC-123, for the reasons described and with the caveats
outlined in the section on rigid polyurethane laminated boardstock
is acceptable as a blowing agent in flexible polyurethane foams.
(d) HFC-134a
HFC-134a is acceptable as a substitute for CFC-11 in flexible
polyurethane foam. HFC-134a offers the potential for a non-ozone-
depleting alternative to CFC-11 blowing agents in flexible
polyurethane
foam. The use of HFC-134a as a blowing agent in flexible
polyurethane
foams is currently not commercially feasible. Plant modifications
may be necessary to accommodate the use of HFC-134a because
its boiling point is lower than that of CFC-11. In addition,
the cost of HFC-134a is high compared to CFC-11.
(e) HFC-152a
HFC-152a is acceptable as a substitute for CFC-11 in flexible
polyurethane foam. HFC-152a offers the potential for a non-ozone-
depleting alternative to CFC-11 blowing agents in flexible
polyurethane
foam. Process changes may be necessary to accommodate the use
of HFC-152a, and plant modifications may be necessary to manage
its flammability.
(f) AB Technology
AB Technology is acceptable as an alternative process in
flexible polyurethane foams, provided that it is used in accordance
with relevant OSHA standards. The AB Technology generates carbon
monoxide as the chemical blowing agent. Actions to insure the
safety of workers from exposure to elevated levels of carbon
monoxide should be taken, particularly at the latter phases
of production where ventilation is generally not as efficient
as on the foam line. OSHA has set a permissible exposure level
(PEL) for carbon monoxide of 35 ppm on a time-weighted average
(TWA) with a ceiling of 200 ppm.
(g) Carbon Dioxide
Carbon dioxide is an acceptable alternative process in flexible
polyurethane foams.
(8) Polyurethane Integral Skin Foams. (a) HCFC-123
HCFC-123 is acceptable as an alternative to CFC-11 in integral
skin foams. From the standpoint of technical feasibility, HCFC-
123 represents a viable alternative to CFC-11 as a potential
blowing agent in integral skin foams. More specifically, the
physical properties and aging of foams blown with HCFC-123 are
similar to those blown with CFC-11. As a result, HCFC-123, which
has an ozone depleting potential significantly lower than that
of CFC-11, has the potential to replace CFC-11 in many integral
skin applications. Nonetheless, commercial availability of HCFC-
123 is limited at present, and it is not clear that industry
can meet the relatively low interim OEL of 10 ppm set by the
manufacturer. Nevertheless, recent worker monitoring studies
indicate that an interim OEL of 10 ppm can be achieved through
the use of increased ventilation, good housekeeping and work
practices, and dust collection. The use of HCFC-123 is subject
to the provisions of section 610 of the CAA, which bans the
use of Class II substances in noninsulating foams after January
1, 1994. The ban does not apply to certain integral skin foams
used to provide for motor vehicle safety. HCFC-123 is subject
to the phase-out of Class II compounds under section 605 of
the CAA.
(b) HCFC-141b
HCFC-141b is acceptable as an alternative to CFC-11 in integral
skin foams used for automotive safety, although its use will
be subject to the proposed accelerated phase-out of HCFCs. Although
its ODP of 0.11 is relatively high, because it can serve as
a virtual drop-in substitute for CFC-11, HCFC-141b offers almost
immediate transition out of CFC-11 in integral skin foams. Not
only does HCFC-141b offer a technically feasible alternative
to CFC-11, but it is currently available in sufficient quantities
to meet the demands of industry. The Agency has chosen to restrict
the use of HCFC-141b in light of the fact that other non-ODP
substitutes should become available. Section 610 of the CAA,
which bans the use of Class II substances in noninsulating foams
after January 1, 1994, excludes certain automotive safety foams
from the ban. The allowable use of HCFC-141b shall be limited
to those integral skin foams excluded from the ban under section
610. HCFC-141b is currently subject to the phase-out of Class
II compounds under section 605 of the CAA.
(c) HCFC-22
HCFC-22 is acceptable as a substitute for CFC-11 in integral
skin foam, although its use will be subject to the proposed
accelerated phase-out of HCFCs. HCFC-22 offers an alternative
with significantly less potential to deplete ozone than CFC-
11. However, process changes may be necessary to accommodate
the low boiling point of HCFC-22. The use of HCFC-22 in integral
skin foams shall be subject to section 610 of the CAA, which
bans the use of Class II substances in noninsulating foams after
January 1, 1994. The ban does not apply to certain foams used
to provide for motor vehicle safety. HCFC-22 is also subject
to the phaseout of Class II compounds under section 605 of the
CAA.
(d) HCFC-22/HCFC-141b
HCFC-22/HCFC-141b blend, for reasons described and with the
caveats outlined above for HCFC-22 and HCFC-141b, is an acceptable
substitute for CFC-11 in integral skin foam used for automotive
safety.
(e) HFC-134a
HFC-134a is acceptable as a substitute for CFC-11 in
polyurethane
integral skin foam. HFC-134a offers the potential for a non-
ozone-depleting alternative to CFC-11 blowing agents in
polyurethane
integral skin foam. The use of HFC-134a as a blowing agent in
flexible polyurethane foams is currently not commercially feasible.
Plant modifications may be necessary to accommodate the use
of HFC-134a because its boiling point is lower than that of
CFC-11. In addition, the cost of HFC-134a is high compared to
CFC-11.
(f) HFC-152a
HFC-152a is acceptable as a substitute for CFC-11 in
polyurethane
integral skin foam. HFC-152a offers the potential for a non-
ozone-depleting alternative to CFC-11 blowing agents in
polyurethane
integral skin. Process changes may be necessary to accommodate
the use of HFC-152a, and plant modifications may be necessary
to manage its flammability. Also, foams blown with HFC-152a
will need to conform with any requirements that relate to flammable
materials.
(g) Hydrocarbons
Hydrocarbons are acceptable as substitutes for CFC-11 in
integral skin foams. Hydrocarbons offer the possibility of a
non-ODP replacement for CFC-11 in integral skin foams. However,
the use of hydrocarbon blowing agents in integral skin foams
is not commercially feasible at present. Moreover, extensive
process modifications would be necessary to accommodate the
flammability of hydrocarbons and to make the necessary technical
and process modifications. Also, foams blown with hydrocarbons
will need to conform with any requirements that relate to flammable
materials. Hydrocarbons are VOCs and must be controlled as such
under Title I of the CAA.
(h) Methylene Chloride
Methylene chloride is acceptable as a blowing agent in integral
skin foam. See methylene chloride discussion under Polyurethane
Flexible Foams for additional details on toxicity.
(i) Carbon Dioxide
Carbon dioxide is acceptable as a blowing agent in integral
skin foams.
(9) Extruded Polystyrene Sheet Foam. (a) HFC-134a
HFC-134a is acceptable as a substitute for CFC-12 in extruded
polystyrene sheet foam. HFC-134a offers the potential for a
non-ozone-depleting alternative to CFC-12 blowing agents in
polystyrene sheet foam.
(b) HFC-152a
HFC-152a is acceptable as a substitute for CFC-12 in extruded
polystyrene sheet foam. HFC-152a offers the potential for a
non-ozone-depleting alternative to CFC-12 blowing agents in
extruded polystyrene sheet foams. The compound is commercially
available and its low molecular weight suggests that its blowing
efficiency will be double that of CFC-12. Plant modifications
may be needed to accommodate the flammability of HFC-152a.
(c) Hydrocarbons
Hydrocarbons are acceptable as substitutes for CFC-12 in
extruded polystyrene sheet foam. Hydrocarbons offer the potential
of a non-ozone-depleting alternative to the use of CFC-12 blowing
agents in extruded polystyrene sheet. At present, pentane and
butane are used extensively as blowing agents in extruded
polystyrene
sheet. These compounds are widely available at low cost and
offer excellent solubility with the polystyrene polymer. However,
extensive plant modifications may be necessary to accommodate
the use of hydrocarbons in place of CFC-12. In addition,
hydrocarbons
are VOCs and will be subject to control as such under Title
I of the CAA.
(d) Carbon Dioxide
Carbon dioxide is acceptable as a substitute for CFC-12 in
extruded polystyrene sheet foam.
(10) Polyolefin Foams. (a) HCFC-22
HCFC-22 is acceptable as a substitute for CFC-11, CFC-12,
and CFC-114 in polyolefin foams. HCFC-22 offers an alternative
with significantly less potential to deplete ozone than CFC-
11, CFC-12, or CFC-114. The use of HCFC-22 in polyolefin foams
may be restricted under section 610 of the CAA, which bans the
use of Class II substances in noninsulating foams after January
1, 1994. HCFC-22 is subject to the phase-out of Class II compounds
under section 605 of the CAA.
(b) HCFC-142b
HCFC-142b is acceptable as a substitute for CFC-11, CFC-12,
and CFC-114 in polyolefin foams. HCFC-142b offers an alternative
with significantly less potential to deplete ozone than CFC-
11, CFC-12, or CFC-114. The use of HCFC-142b in polyolefin foams
may be restricted under section 610 of the CAA, which bans the
use of Class II substances in noninsulating foams after January
1, 1994. HCFC-142b is subject to the phase-out of Class II
compounds
under section 605 of the CAA.
(c) HCFC-22/HCFC-142a
HCFC-22/HCFC-142a blends are acceptable, for reasons described
and the caveats outlined above, as a substitute for CFC-11,
CFC-12 and CFC-114 in polyolefin foam.
(d) HFC-134a
HFC-134a is acceptable as a substitute for CFC-11, CFC-12,
and CFC-114 in polyolefin foams. HFC-134a offers the potential
for a non-ozone-depleting alternative to CFC-11, CFC-12, and
CFC-114 in polyolefin foams. HFC-134a, because of its low
flammability
and encouraging performance in toxicological testing, exhibits
definite advantages from the standpoints of environmental risk
and worker and consumer safety.
(e) HFC-152a
HFC-152a, for the reasons described and with the caveats
outlined in the section on extruded polystyrene sheet foam,
is acceptable as an alternative to CFC-11, CFC-12, and CFC-114
in polyolefin foams.
(f) Hydrocarbons
Hydrocarbons are acceptable as substitutes for CFC-11, CFC-
12, and CFC-114 in polyolefin foams. Use of hydrocarbon blowing
agents in polyolefin foams is not now commercially feasible.
Extensive plant modifications may be necessary to accommodate
hydrocarbon use due to flammability and technical considerations.
Finally, hydrocarbons are VOCs and must be controlled as such
under Title I of the CAA.
(g) HCFC-22/Hydrocarbons
HCFC-22/hydrocarbons blends, for the reasons described and
with the caveats outlined above, are acceptable substitutes
for CFC-11, CFC-12 and CFC-114 in polyolefin foams.
(h) Carbon Dioxide
Carbon dioxide is acceptable as a substitute for CFC-11,
CFC-12, and CFC-114 in polyolefin foams.
b. Proposed Unacceptable Substitutes. The final listing of
a foam blowing agent as unacceptable in a specific foam use
sector constitutes a ban on the use of that alternative to Class
I or Class II compounds in commerce. The Agency solicits comments
on these proposed decisions. These decisions will be effective
30 days after publication of the final rule.
(1) Rigid Polyurethane Slabstock and Other Foams (Rigid
Polyurethane
Packaging Foams). (a) HCFC-141b
The use of HCFC-141b (or blends thereof) is proposed
unacceptable
as an alternative blowing agent in rigid polyurethane packaging
foams with the exception of insulating and flotation foams.
HCFC-141b has an ODP of 0.11, almost equivalent to that of methyl
chloroform, a Class I substance. The Agency believes that non-
ODP alternatives, or alternatives with lower ODPs, are sufficiently
available to render the use of HCFC-141b unnecessary in this
application.
(2) Flexible Polyurethane Foams. (a) HCFC-141b
The use of HCFC-141b (or blends thereof) is proposed
unacceptable
as an alternative blowing agent in flexible polyurethane foams.
HCFC-141b has an ODP of 0.11, almost equivalent to that of methyl
chloroform, a Class I substance. The Agency believes that non-
ODP alternatives are sufficiently available to render the use
of HCFC-141b unnecessary in this application.
(3) Integral Skin Foams. (a) HCFC-141b
Use of HCFC-141b (or blends thereof) is proposed unacceptable
as an alternative blowing agent in integral skin foams, except
where used for the purpose of motor vehicle safety. HCFC-141b
has an ODP of 0.11, almost equivalent to that of methyl chloroform,
a Class I substance. The Agency believes that non-ODP alternatives,
or alternatives with lower ODPs, are sufficiently available
to render the use of HCFC-141b unnecessary in this application.
However, the use of HCFC-141b will be allowed in those integral
skin automotive foams excluded from the ban on noninsulating
foams under section 610 of the CAA.
(4) Polyolefin Foams. (a) HCFC-141b
The use of HCFC-141b (or blends thereof) is proposed
unacceptable
as an alternative blowing agent in polyolefin foams. HCFC-141b
has an ODP of 0.11, almost equivalent to that of methyl chloroform,
a Class I substance. The Agency believes that non-ODP alternatives,
or alternatives with lower ODPs, are sufficiently available
to render the use of HCFC-141b unnecessary in this application.
F. Solvents Cleaning
1. Overview
On an ozone-depletion weighted basis, solvents constitute
approximately 15 per cent of the chemicals targeted for phase-
out under the Montreal Protocol. In the U.S., the two Class
I chemicals used as industrial solvents are CFC-113 (C2F3Cl3-
trifluorotrichloroethane) and methyl chloroform (C2H3Cl3-1,1,1-
trichloroethane). The SNAP determinations proposed today focus
on substitutes for these chemicals when used as industrial cleaning
solvents, since this application comprises the largest use of
CFC-113 and methyl chloroform (MCF).
Other cleaning applications for CFC-113 and MCF exist as
well, such as in dry cleaning of textiles. In addition, these
solvents are used as bearer media (such as lubricant carriers),
mold release agents, component testing agents, coolants, or
in other non-cleaning applications. For the reasons described
earlier in this Preamble, the Agency proposes to exclude
substitutes
for these smaller uses from the SNAP determinations. As a result,
the Agency is not at this time issuing any determinations on
acceptability of such substitutes, and will neither approve
nor restrict their uses.
The three major cleaning applications that use CFC-113 and
MCF are metals cleaning, electronics cleaning, and precision
cleaning. Metals cleaning applications usually involve removing
cutting oils and residual metal filings. This sector relies
principally on MCF as a cleaning solvent. In contrast, the
electronics
industry uses principally CFC-113, for instance, to remove flux
residues left after mounting parts on printed circuit boards.
Precision cleaning also uses mostly CFC-113. This last application
comprises a broad category of industrial cleaning operations
and can cover uses ranging from cleaning pacemakers to cleaning
direct access storage devices on computers.
Appendix B at the end of this Preamble lists in tabular form
the Agency's proposed determinations on substitutes in the cleaning
sector. These proposed determinations are based on the risk
screen described in the draft background document entitled "Risk
Screen on the Use of Substitutes for Class I Ozone-Depleting
Substances: Solvent Cleaning." The table also includes as "pending"
a number of substitutes that the Agency will issue determinations
on in the next round of SNAP analyses. This table was compiled
in part based on information on substitutes that companies
submitted
to the Agency in response to the January 16, 1992, Advance Notice
of Proposed Rulemaking. In some cases, the Agency did not have
adequate engineering or environmental information on these
substitutes
to permit a SNAP determination. Vendors or users of cleaning
substitutes not described in Appendix B should submit information
on these uses, so that the Agency can issue a SNAP determination.
In general, the solvents cleaning industry has been extremely
successful at finding non-ozone-depleting alternatives to cleaning
with CFC-113 and MCF. Numerous alternatives are already
commercially
available, and ongoing research and development promises to
generate additional innovative solutions. The most creative
approaches focus on changing the manufacturing process to remove
the cleaning stage altogether. This change, in which producers
rely on "no-clean" technologies, embodies one of the success
stories in the search for alternatives-a pollution prevention
approach that relies on cutting out the manufacturing step that
creates the environmental problem rather than simply transferring
the pollutants from one medium to another. The electronics industry
in particular has many such cleaning alternatives that eliminate
the need for CFC-113 and MCF. In metals cleaning, few "no-clean"
alternatives are currently available, since the manufacturing
process is so heavily dependent on the use of oils as lubricants.
However, no-clean approaches and products, such as vanishing
oils, are being developed for cleaning metal parts and may soon
be more broadly available.
Finding alternatives for CFC-113 and MCF in precision cleaning
has been more difficult. Here, the industry has tried where
possible to find and implement other cleaning options, but in
some cases currently available alternatives simply do not meet
the performance or safety criteria that would permit them to
be used successfully.
2. Alternatives in Solvents Cleaning
a. Hydrochlorofluorocarbons (HCFCs) HCFC-141b or HCFC-141b
blends with alcohols are the principal HCFC alternative solvents
to CFC-113/MCF cleaning. These alternatives can be used in vapor
degreasing equipment, principally for electronics or precision
cleaning, and in some cases existing CFC-113 or MCF equipment
can be retrofitted for use with HCFC-141b alternatives. From
an environmental standpoint, the critical characteristic of
HCFC-141b is that it has a relatively high ODP-0.11-the highest
of all the HCFCs.
Another HCFC, HCFC-123, is generally not considered to have
widespread application as a cleaner. Although this HCFC has
the capacity to remove many soils, it is such an aggressive
cleaner that it frequently degrades the surface of the part
being cleaned. Additionally, toxicity concerns have limited
commercial interest in HCFC-123 as a cleaning substitute. The
Agency is currently investigating whether industry exposure
standards for HCFC-123 can be met, and has therefore listed
this chemical as "pending" approval.
HCFC-225, a third HCFC, is widely viewed as having potential
as a cleaner, especially for precision cleaning. However, this
chemical is not yet in widespread production or use. Further,
HCFC-225 is still undergoing toxicity testing. Preliminary findings
suggest that of the two HCFC-225 isomers, HCFC-225ca and HCFC-
225cb, toxicity concerns associated with the ca-isomer may limit
its commercial viability.
b. Semi-Aqueous Cleaning. Semi-aqueous cleaning is an
alternative
for cleaning in all three cleaning sectors. This process employs
hydrocarbon/surfactant cleaners either emulsified in water
solutions
or applied in concentrated form and then rinsed with water.
Since both approaches involve water as part of the formulation,
the process is commonly referred to as "semi-aqueous." The
principal
categories of chemicals used in this process are terpenes,
petroleum
distillates, or alcohols. Surfactants are sometimes added to
the formulation to increase wetting, emulsification and rinsing
properties. Within each category of compounds, formulators draw
from a wide variety of specific chemicals. For example, even
though terpene-based cleaning often uses d-limonene, other terpene
cleaners formulated with terpineols or terpinenes exist. A similar
range of choices is available when selecting the surfactant.
To characterize environmental releases, EPA developed model
processes intended to represent generic semi-aqueous cleaning
scenarios. The purpose of developing the model processes was
to portray the average use scenario, rather than to depict specific
examples of cleaning applications. An extensive discussion of
various semi-aqueous cleaning processes may be found in the
Industry Cooperative for Ozone Layer Protection (ICOLP) documents
on the subject.
c. Aqueous Cleaning. Aqueous cleaning, unlike semi-aqueous
cleaning, uses water as the primary solvent. This process is
used mostly for metals cleaning, but companies are beginning
to explore options using these substitutes in other cleaning
applications.
In aqueous cleaning, detergents and surfactants are combined
in water with a variety of additives such as organic solvents
(e.g., high-boiling point alcohols), builders, saponifiers,
inhibitors, emulsifiers, Ph buffers and antifoaming agents.
Builders such as alkaline salts usually make up a large portion
of the formulation (other than water), and they are often used
in blends of several chemicals. Surfactants comprise the other
major portion; these chemicals are chosen for their detergent,
emulsification or wetting properties.
The cleaning process is comparable to that used in semi-aqueous
applications and consists of combinations of a wash phase, a
rinse phase, and a drying phase. An important difference is
that the wash tank is frequently heated to improve soil removal.
The final step, drying, can be accomplished by use of heat or
a drying agent.
A critical feature of aqueous cleaning, as with semi-aqueous
cleaning, is the wide variety of chemicals chosen for the
formulations.
For each cleaning need, a vendor can tailor a formulation to
the soils and parts-a process that produces innumerable
combinations
of chemicals in different concentrations. To capture this
diversity,
the Agency has chosen to adopt a screening approach that parallels
the methodology described in the section on semi-aqueous cleaners.
d. Organic Solvents. Organic solvents can be used to replace
CFC-113 and MCF in certain cleaning operations. The classification
of organic solvents typically includes conventional organic
solvents such as alcohols, ethers, esters and ketones. These
compounds are commonly used in solvent tanks at room temperature,
although the solvents can also clean in in-line systems or be
heated to increase solvency power. If heated, the solvents must
be used in equipment designed to control vapor losses.
These solvents, unlike Class I and II compounds, do not
contribute
to stratospheric ozone depletion, and generally have short
atmospheric
lifetimes. Yet many of the organic solvents are regulated as
VOCs because they can contribute to ground-level ozone formation.
In addition, certain of the organic solvents are toxic to human
health and are subject to workplace standards set by OSHA.
e. Other Chlorinated Solvents. In addition to MCF and CFC-
113, the three other commonly used chlorinated solvents are
trichloroethylene ("TCE"), methylene chloride ("meth"), and
perchloroethylene ("perc"). Unlike MCF and CFC-113, these
chlorinated
solvents have very short atmospheric lifetimes and are not
considered
to contribute to ozone depletion. However, all three have known
toxicity problems and are regulated as Hazardous Air Pollutants
under Title III of the Clean Air Act. They are also subject
to stringent workplace standards set by the Occupational Health
and Safety Administration. Additionally, TCE and perc exhibit
photochemical reactivity, and are regulated as smog precursors.
The phase-out of CFC-113 and MCF has prompted a renewed interest
in meth, TCE, and perc, despite these toxicity concerns. The
three solvents are mostly viewed as potential metal cleaning
substitutes, especially since they can be used in conventional
vapor degreasing equipment. In fact, these three solvents were
the preferred industrial solvents until concerns about their
toxicity and anticipated lowering of the Occupational Safety
and Health Administration (OSHA) Permissible Exposure Limits
(PELs) resulted in a switch by some users to MCF.
In response to such concerns, equipment vendors have now
developed processes for using these solvents that significantly
limit their emissions. The availability of such equipment has
prompted environmental agencies in other western countries,
such as Germany, to relax restrictions on the use of these
chemicals.
Such equipment, although expensive, can now be purchased in
the United States.
f. No-Clean Alternatives. No-clean alternatives involve the
use of fluxes or cutting oils that need not be removed after
the manufactured part is fully formed. It offers an efficient
solution to the cleaning problem, since it sidesteps the cleaning
process altogether. Water-removable products are products where
the soils or fluxes can be removed using water as opposed to
other types of solvents. In electronics cleaning, where these
two approaches are in more widespread use, no-clean or water-
removable alternatives rely either on special fluxes or on a
soldering process that eliminates or reduces the residues otherwise
removed through the cleaning step.
g. Perfluorocarbons. Perfluorocarbons (PFCs) are fully
fluorinated
compounds, unlike either CFCs, HCFCs or HFCs. These compounds
are being discussed as part of innovative cleaning processes
to replace ozone-depleting solvents. These processes would use
an aqueous or solvent cleaner bath with a PFC vapor zone for
rinsing and/or drying. Although these processes have the technical
potential to meet a number of cleaning needs, the expense of
the PFCs may limit wide-spread commercial interest in processes
that use these compounds.
The principal environmental characteristic of concern for
the PFCs is that they have extremely long atmospheric lifetimes,
often orders of magnitude longer than the CFCs. Environmental
concerns associated with use of PFCs are discussed in the
refrigerants
chapter. Technology for containment and recycling of PFCs is
commercially available and is recommended by manufacturers to
offset any possible adverse environmental effects.
h. Monochlorotoluene/chlorobenzotrifluorides. Monochlorotoluene
and chlorobenzotrifluorides are of commercial interest as solvent
substitutes in a variety of cleaning applications. These compounds
can be used either in isolation or in various mixtures, depending
on desired chemical properties. The Agency recently received
information on these formulations, and will issue a SNAP
determination
for these substitutes in the next set of listing decisions.
i. Volatile Methyl Siloxanes. Cyclic and linear volatile
methyl siloxanes (VMSs) are currently undergoing investigation
for use as substitutes for Class I compounds in electronics
and precision cleaning. Because of their chemical properties,
these compounds show promise as substitutes for cleaning precision
guidance equipment in the defense and aerospace industries.
In addition, the volatile methyl siloxanes have high purity
and are therefore relatively easy to recover and recycle. In
the cleaning process using VMS, the fluids are used to clean
parts in a closed header system using a totally enclosed process.
The parts are drained and then dried using vacuum baking.
j. Supercritical Fluid Cleaning, Plasma Cleaning, UV-Ozone
Cleaning. Supercritical fluid cleaning, plasma cleaning, UV-
ozone cleaning are all three high-technology methods of cleaning
parts. These substitutes are mostly of interest for cleaning
electronic parts or for precision cleaning.
k. Brominated Hydrocarbons. The Agency recently received
notification that brominated hydrocarbons can be used as substitute
cleaning agents, and will issue a SNAP determination on these
chemicals in the next set of listing decisions.
3. Preliminary Listing Decisions
a. Acceptable Substitutes. (1) Metals Cleaning.-(a) Semi-
Aqueous/Aqueous Processes. Semi-aqueous and aqueous processes
are approved as substitutes in metals cleaning. The determinations
in this action cover semi-aqueous processes using terpenes,
petroleum distillates, and alcohols.
To complete its modeling of the ability of aqueous and semi-
aqueous substitutes to replace CFC-113 and MCF in existing
applications,
the Agency examined their ability to meet the cleaning requirements
posed in the metals cleaning sector. Each of these alternatives
has the potential to service as much as 70 percent of the metals
cleaning market. To date, companies have shown the greatest
interest in aqueous cleaners for metals cleaning, which is why
the Agency has made every effort to include review of this option
in its first round of SNAP determinations.
The concern with the water-based processes has historically
been the potential for adverse effects on aquatic life following
discharge of wastewaters to surface water bodies. Examples of
these effects include death to aquatic microorganisms, fish
teratogenicity, or ecosystem effects such as inhibition of algal
growth or bioconcentration. In this case, the Agency wanted
to ensure that, in restricting the use of CFC-113 and methyl
chloroform, it would not simply be replacing risks from air
emissions with equal risks from contaminated water effluent.
To complete its risk analysis for the aqueous and semi-aqueous
cleaners, the Agency developed a screening methodology designed
to characterize risks presented by typical processes using these
cleaners. The diversity of chemicals used in aqueous and semi-
aqueous cleaning formulations turned this exercise into a complex
undertaking. To complete its screen, the Agency projected
concentrations
in water for the "worst" or most toxic chemical that could be
used in the water-based processes. These concentrations were
based on the maximum possible concentration in the formulation
and case studies documenting actual release profiles for several
sample processes. The predicted concentrations obtained using
this approach were then compared with toxicity values for this
"worst" chemical.
The risk screen performed by the Agency did show a potential
for adverse effects on aquatic life due to the inherent toxicity
of chemical constituents in the cleaners. These findings point
to the need to control unnecessary and irresponsible discharge
of these chemicals.
However, the Agency believes that most risks presented by
use of water-based processes can be controlled by adhering to
requirements for wastewater treatment imposed by municipal or
state authorities. In addition, the screen performed by the
Agency that indicated the possibility of risks to aquatic life
is likely to have overstated potential risks. For example, the
screen did not account for several complex biological processes,
including biodegradation and volatization. The Agency is developing
scientific studies to address these factors, and believes that
once these factors are incorporated that the risk screen will
demonstrate clearly that the water-based processes present
acceptable
risks to aquatic life.
The Agency believes that this approach to screening risks,
although it does not examine the toxicity of each chemical and
mixture or project exposures for each possible process, provides
adequate perspective on the risks of these compounds compared
with risks from the CFCs. The Agency solicits comment on this
approach and data that could help refine the analysis of individual
chemicals and mixtures. For example, the Agency's analysis did
not specifically examine risks from mixtures of various chemicals
where there could be synergistic effects. Although the Agency
does not anticipate that such data would change the decision
to list these substitutes as acceptable, the Agency hopes that
a better understanding of ecological effects of such substitutes
will enhance its ability to assist users in choosing among
substitutes
and among formulations.
In an effort to further assist users in choosing substitutes
with low environmental impacts, the Agency is currently developing
a list of chemicals commonly used in the types of cleaners deemed
acceptable under the SNAP program. The Agency encourages companies
to ensure that substitutes sold as CFC-113/MCF replacements
be formulated based on this list.
In addition, the Agency urges companies to adopt closed-loop
recycling and recovery systems wherever possible to limit discharge
of these chemicals. Users should also note that EPA is preparing
new effluent guidelines under the Clean Water Act for this
industry.
These guidelines, expected to be issued by 1994, will address
any remaining, uncontrolled risks deriving from the use of water-
based cleaners in this industry.
(b) Organic Solvents. Organic solvents are acceptable
substitutes
for CFC-113 and MCF in the metals cleaning sector. Although
these compounds can be toxic to human health, and are considered
VOCs, the Agency's risk screen shows that these risks can be
addressed through existing regulatory controls. In occupational
settings where toxicity is a concern, such as for acetone or
for certain ketones, OSHA has set Permissible Exposure Limits
designed to control any risks.
Similarly, controls exist for sources of VOC emissions, and
the Agency's analysis indicates that increased use of the organic
solvents would increase VOC levels in the troposphere by only
very small amounts.
(c) Other Chlorinated Solvents. Trichloroethylene (TCE),
perchloroethylene (perc) and methylene chloride (meth) are all
acceptable substitutes for CFC-113 and MCF in the metals cleaning
sector. These alternatives have the chemical properties to meet
the cleaning needs of up to 80 percent of the metals cleaning
sector, although the Agency anticipates that the actual market
share for the non-ozone-depleting chlorinated solvents will
not expand to the maximum extent feasible.
Because of the high toxicity of these compounds, they have
the potential to pose risks to workers and residents in nearby
communities. However, the Agency's analysis of use of these
compounds as cleaning agents indicates that these risks can
be controlled by adhering to existing regulatory standards.
OSHA has determined, for instance, that it is possible to use
these solvents in a manner that minimizes risks to workers.
To reach this conclusion, OSHA conducted extensive analyses
of the toxicity and technical feasibility of using
perchloroethylene,
trichloroethylene, or methylene chloride (54 FR 2329-2984, January
19, 1989, and 56 FR 57036-57141, November 7, 1991). OSHA found
that the new Permissible Exposure Limit (PEL) of 50 ppm for
trichloroethylene was feasible in metal cleaning operations
(54 FR 2433) and after conducting an extensive study of metal
degreasing control technologies, NIOSH concluded that an exposure
limit of 25 ppm for TCE could also be achieved. More recently,
in its proposed standard for methylene chloride, OSHA found
that a PEL of 25 ppm is technically feasible during metal cleaning
operations with the use of appropriate local exhaust ventilation
and work practices.
Additionally, the Agency is in the process of addressing
residual risks to the general population under Title III of
the new Clean Air Act. Title III requires EPA to establish Maximum
Achievable Control Technology (MACT) standards for use of Hazardous
Air Pollutants (HAPs). All three non-OD chlorinated solvents
are listed as HAPs, and the Agency expects to issue MACT rules
governing their use as solvent cleaning agents by 1994.
The Agency also believes that risks from waste generation
due to use of these solvents are unlikely to be significantly
different from risks of waste disposal of spent CFC-113 and
methyl chloroform. The risks from spent cleaning solvents derive
in large part from the soils removed in the cleaning process.
Since the composition of the soils would not change as a result
of substitution, risks are also not expected to increase
significantly.
The Agency also notes that the voluntary "33/50" program
is encouraging companies to decrease emissions of TCE, perc,
and meth, in addition to 14 other specific chemicals. Participating
companies voluntarily commit to decreasing emissions 33 per
cent by the end of 1992 and 50 per cent by the end of 1995,
using pollution prevention strategies. The Agency is committed
in the long term to urge companies to participate in pollution
prevention programs such as "33/50", and continue to find new
ways to use and emit less polluting and lower toxicity compounds.
The Agency requests comment on the decision to list these compounds
as acceptable substitutes for CFC-113 and MCF.
(2) Electronics Cleaning (a) Semi-Aqueous/Aqueous Cleaners
In the area of electronics cleaning, semi-aqueous and aqueous
cleaners were deemed to be acceptable substitutes. The
justification
for this determination is described in the section on metals
cleaning. In this case, the Agency estimated that up to eighty
per cent of the cleaning market could be captured by semi-aqueous
processes and that up to 60 per cent of the market could be
served by aqueous cleaners.
As in metals cleaning, the Agency urges companies to adopt
pollution prevention practices and to formulate cleaners based
on the cleaner constituent list.
(b) No-Clean Substitutes. No-clean processes are acceptable
substitutes for ozone-depleting chemicals used in electronics
cleaning. The Agency's analysis estimates that, over time, as
much as seventy per cent of the electronics cleaning market
could switch to no-clean processes-a projection that is borne
out by the high degree of interest shown by electronics companies
in these substitutes.
Concerns for risks deriving from use of no-clean processes
focus primarily on worker safety. To examine these risks, the
Agency looked at critical factors that distinguish no-clean
processes from conventional electronics assembly. These differences
center on changes in the proportions of chemicals used in
formulations,
rather than on differences in the identity of chemicals selected.
The analysis determined that occupational risks deriving from
these differences are already well-documented and controlled,
for example, through requirements specified on key Materials
Safety Data Sheets and existing workplace regulations implemented
by OSHA.
Additionally, the shifts in proportions of chemicals used
in the formulation result in less waste than is normally generated
through the traditional manufacturing process, resulting in
a lower probability of adverse effects to the general population.
The Agency also investigated the production of waste before
and after the actual cleaning process and found that waste
generation
at these points in the production process would not be affected.
(c) Organic Solvents. Organic solvents are acceptable
substitutes
for CFC-113 and MCF in the electronics cleaning sector. The
Agency's justification for this decision is described in the
section on acceptable substitutes for metals cleaning.
(d) Other Chlorinated Solvents. Trichloroethylene (TCE),
perchloroethylene (perc) and methylene chloride (meth) are all
acceptable substitutes for CFC-113 and MCF in the electronics
cleaning sector, for the reasons described in the metals cleaning
discussion. Although these solvents have not received as much
commercial interest for electronics cleaning as for metals cleaning
applications, the Agency did receive a request to review and
approve these chemicals for electronics cleaning.
Although the Agency's risk screen focused on use of these
chemicals in metals cleaning operations, the screen suggests
that release profiles for these chemicals in electronics cleaning
will be either the same or lower. As a result, the Agency has
reached the same conclusion in the metals cleaning analysis,
namely that any risks due to the inherent toxicity of these
chemicals could be controlled by existing and future regulatory
standards.
However, the Agency has received some indication from industry
experts that these solvents do not fill any special cleaning
niche for the electronics industry. Based on a desire to control
any unnecessary use of chemicals with such high inherent toxicity,
the Agency requests comment on the availability of other
alternatives
and on whether there is a genuine need to use these chemicals
in electronics cleaning applications.
(e) Perfluorocarbons. Use of perfluorocarbons (PFCs) in spot-
free cleaning and drying of high-performance computer components
is an acceptable substitute in cases where no other alternative
exists that meets performance or safety standards. This would
not include defluxing of printed circuit boards or cleaning
of standard metal parts, since many other viable alternatives
exist for these applications.
Global warming concerns associated with PFC use are discussed
in the refrigerants chapter. Despite these concerns, the Agency
has listed this niche application as an acceptable use of
perfluorocarbons
because it is aware that, for certain computer components, a
PFC-based process may be the only viable process available to
replace use of Class I or II compounds.
For example, in manufacture of certain direct access storage
devices (DASDs) for computers, spot-free cleaning and drying
using PFCs appears at the present time to be the only cleaning
process that yields the necessary product performance (as opposed
to cosmetic appearance). To make the technical improvements
demanded of the storage devices, such as faster access times
and higher recording densities, companies have been required
to use magnetically superior materials. These materials are
extremely prone to corrosion from water and are vulnerable to
any contamination introduced in the manufacturing process, such
as organic or particulate matter. Consequently, the storage
device itself must be a miniature "clean room" if it is to perform
correctly. Manufacturers of some DASDs can use water-based cleaners
in much of the production process, but may need to rely on the
PFCs as water-displacement agents to achieve the required high
degree of cleanliness while protecting the water-sensitive
materials
in the device.
Another example of components where PFC-based cleaning may
be necessary is data storage media.
In cases where users must rely on PFCs due to lack of other
options, they should make every effort to:
Adopt closed systems and recover, recycle and destroy where
possible
Reduce emissions to a minimum through conservation practices
that address idling losses, liquid dragout, and operator variables
Continue to search for long-term alternatives.
Examples of appropriate measures to reduce emissions include
freeboard chillers, welded piping, and programmable handling
devices. The Agency believes that it is reasonable to expect
users to achieve favorable CFC/PFC replacement ratios since
PFCs have relatively higher boiling points. In addition, the
high price of PFCs makes additional containment cost-effective.
Prospective users should also note that companies investigating
PFC use currently contend that within 3-8 years, it will be
possible to replace the PFCs in cleaning equipment with other
chemicals that have zero ozone depletion potential and very
low global warming potential. As a result, they view use of
the PFCs as an important but transitional solution to their
cleaning needs. If PFCs are chosen, it is important for users
to begin working with chemical manufacturers to start testing
and qualifying these new materials to help speed conversion
when the chemicals become commercially available.
In addition to the case cited earlier, the Agency is examining
other possible necessary uses for PFCs as rinse agents to follow
a water-free cleaning process or as drying or rinsing agents
to follow a water-based cleaning process. Parts typically cleaned
in these applications are characterized by vulnerable substrates,
complex geometries, and exceptionally stringent cleanliness
standards and include:
Precision mechanical or electro-mechanical parts such as
gyroscopes and accelerometers with complex structures and capillary
spaces that could trap water or solvent residue
Plastic parts with embedded iron or parts made from steel,
lead or other materials subject to corrosion, oxidation or other
damage from water (e.g., gallium arsenide, silicon nitride or
magnesium parts)
Plastic parts for the medical industry where extremely
rigorous standards of cleanliness are necessary to ensure patient
survival (e.g., kidney dialysis, implants, etc.)
Electro-optical devices for weapon-targeting systems
Ceramic or other porous materials for military, medical,
safety or other high-value products, where any conductive residue
could interfere with the component's performance
Temperature-sensitive materials that cannot maintain component
integrity at aqueous drying temperatures (e.g., where loss of
dimensional stability is at issue)
High-performance analytical devices where any residue could
interfere with equipment accuracy.
The Agency solicits comment on the need to use PFCs in these
applications or in any other specialized cleaning applications.
In addition, the Agency seeks comment on the availability,
performance,
and economic feasibility of any cleaning alternatives that would
eliminate the need for PFCs in these applications.
(f) Supercritical Fluid Cleaning, Plasma Cleaning, UV-Ozone
Cleaning. Supercritical fluid cleaning, plasma cleaning, UV-
ozone cleaning are all approved as substitutes in electronics
cleaning. The Agency did not identify any environmental issues
associated with use of these substitutes. Ozone is hazardous
to human health, however, the Occupational Safety and Health
Administration has already set standards for use of this compound
in the workplace.
(3) Precision Cleaning. (a) Semi-Aqueous/Aqueous Processes.
Semi-aqueous and aqueous processes are approved for precision
cleaning. The reasons for this decision are the same as those
described in the metals cleaning section. Each of these
alternatives
has the potential to service approximately 65 per cent of the
precision cleaning market. This figure may overestimate the
technical potential for water-based processes in this sector,
since industry feedback indicates that this end use sector faces
the greatest technical constraints in implementing new cleaning
alternatives.
The Agency did not specifically examine risks from water-
based processes used in precision cleaning. Instead, the analysis
assumed that these risks would be either comparable to or less
than risks associated with use of water-based processes for
electronics cleaning.
(b) Other Chlorinated Solvents. These alternatives, for reasons
described in the section on metals cleaning, are deemed acceptable
substitutes for precision cleaning. For the analysis of risks
from these substitutes in the precision cleaning end use sector,
the Agency made the same assumptions as in its analysis for
electronics cleaning applications of water-based processes,
namely that exposures would be equal or less than exposures
in the metals cleaning sector. Consequently, the Agency believes
that risks would also be either equal or less.
(c) Organic Solvents. Organic solvents are acceptable
substitutes
for CFC-113 and MCF in the precision cleaning sector. The Agency's
justification for this decision is described in the section
on acceptable substitutes for metals cleaning.
(d) Perfluorocarbons. Use of perfluorocarbons (PFCs) in spot-
free cleaning and drying of high-performance computer components
is an acceptable substitute in cases where no other alternative
exists that meets performance or safety standards. This would
not include defluxing of printed circuit boards or cleaning
of standard metal parts. While the Agency is concerned about
increased uses of PFCs due to global warming concerns as discussed
in the refrigerants chapter, it believes that cases exist where
a PFC-based process may be the only process available to replace
use of Class I or II compounds. These cases are discussed in
the section on acceptable substitutes for electronics cleaning.
(e) Supercritical Fluid Cleaning, Plasma Cleaning, UV-Ozone
Cleaning. Supercritical fluid cleaning, plasma cleaning, UV-
ozone cleaning are all approved as substitutes in precision
cleaning. The Agency did not identify any environmental issues
associated with use of these substitutes. Ozone is hazardous
to human health, however, the Occupational Safety and Health
Administration has already set standards for use of this compound
in the workplace.
b. Proposed Unacceptable Substitutes
(1) Metals Cleaning. (a) HCFC-141b and its Blends
HCFC-141b and its blends are proposed to be prohibited as
substitutes for CFC-113/MCF in metals cleaning, with limited
critical use exceptions for CFC-113 replacements. The proposed
effective date for this prohibition is 30 days after the date
of the final rule for new equipment and as of January 1, 1996,
for existing equipment. As discussed earlier in this action
in Section VI.A., the Agency is authorized to grandfather existing
uses from a proposed prohibition where appropriate under the
four-part test established in Sierra Club v. EPA, supra.
The Agency has conducted the four analyses required under
this test, and it has concluded that the balance of equities
favors a grandfathering period of two years for existing equipment
in this application. The prohibition proposed in this action
clearly represents a departure from previously established
practice,
as use of the substitute was allowed previously. Existing users
of HCFC-141b who switched from Class I substances into this
solvent invested in this substitute on the assumption that it
would be a sufficient improvement. Prohibiting their use of
the substitute immediately would impose a severe economic burden
on these users. These factors taken together outweigh any statutory
interest in applying the new rule immediately to existing users.
This is especially true since the restriction applies immediately
to new equipment using HCFC-141b, which creates no incentive
for continued investment in equipment using HCFC-141b in this
application.
The Agency's basis for proposing to restrict use of HCFC-
141b is that this compound has a comparatively high ODP-0.11.
This is the highest ODP of all the HCFCs; in fact, the ODP for
141b is nearly equal to the ODP for MCF (0.12). For this reason,
the Agency proposes not to grant any exceptions for replacing
MCF with 141b, since using 141b in place of MCF would negate
the environmental benefits that the phase-out was designed to
achieve.
To analyze the impacts from use of 141b as a CFC-113
replacement,
the Agency estimated 141b use over time in each of the cleaning
end uses, and projected health effects due to ozone depletion
with the help of the Atmospheric Stabilization Framework model.
The modeling period starts in 1990 and measures health effects
expected for people born before 2030.
The findings of this modeling show adverse health effects
of the magnitude commonly associated with the use of
ozone-depleting
compounds. For example, in the case of metals cleaning, the
Agency projected that use of HCFC-141b to replace MCF where
technically feasible could yield approximately 40,000 additional
skin cancer cases and approximately 1,000 additional skin cancer
fatalities compared to use of non-ozone-depleting substitutes.
The Agency believes that these figures and the availability
of superior substitutes as described in the section on acceptable
substitutes justify the proposal to list 141b as an unacceptable
substitute. The Agency believes that, in almost all applications,
other solvent cleaning substitutes are available that meet industry
performance and safety criteria. To reach its decision on 141b
use, the Agency also took into account the cost of other
alternatives.
The analysis suggested that, although 141b can be used with
modification to existing equipment, the capital costs for the
retrofit and the materials costs in combination would be so
high as to render other alternatives comparatively affordable,
even though they require new equipment.
Readers should note that 141b will be restricted as a substitute
only where other alternatives exist to CFC-113 for the application
in question. Several companies have already contacted the Agency,
indicating that they have tested available alternatives to CFC-
113, and that in some cases only HCFC-141b meets performance
or safety criteria. The most commonly cited reasons for needing
to use HCFC-141b are either applications where a non-flammable
solvent is required for cleaning operational equipment or where
sensitive parts could be destroyed by use of other cleaning
processes.
For these applications of 141b, which the Agency refers to
as "critical uses," users may receive an exemption from the
SNAP restrictions. Procedures for receiving a critical use
exemption
are described in Section VIII.F. of today's Preamble. Companies
interested in these exemptions who believe they may qualify
are encouraged to review this section. Companies who have already
notified the Agency and requested permission for continued use
of 141b will be contacted after this proposal so that the Agency
can issue a formal critical use determination.
Companies should note that uses of 141b in existing solvent
cleaning equipment would be permitted to continue until two
years after the date of the final rule, as discussed above.
The Agency solicits comment on the proposed effective date.
The Agency believes that the decision to restrict 141b use
as a CFC-113/MCF substitute for metals cleaning will have little
effect on industry since few vendors of HCFC 141b have been
selling 141b as a metals cleaning substitute. Companies in this
end use sector that want to replace CFC-113 with 141b and feel
they qualify for an exemption should review the section referenced
above. The Agency expects to receive few such petitions, however,
since most metals cleaning is currently performed with MCF.
(2) Electronics Cleaning. (a) HCFC-141b and its Blends
HCFC-141b and its blends are proposed to be prohibited as
substitutes for CFC-113/MCF in electronics cleaning, with limited
critical use exceptions for CFC-113 replacements. The reasons
for this prohibition are the same as those for the decision
on 141b as a metals cleaning substitute. As in the metals cleaning
sector, the Agency proposes to grant limited critical use
exemptions
to this prohibition. The proposed effective date for this
prohibition
is 30 days after the date of the final rule for new equipment
and January 1, 1996 for existing equipment. As discussed earlier
in this action in Section VI.A., the Agency is authorized to
grandfather existing uses from a proposed prohibition where
appropriate under the four-part test established in Sierra Club
v. EPA, supra.
The Agency has conducted the four analyses required under
this test, and it has concluded that the balance of equities
favors a grandfathering period of two years for existing equipment
in this application. The prohibition proposed in this action
clearly represents a departure from previously established
practice,
as use of the substitute was allowed previously. Existing users
of HCFC-141b who switched from Class I substances into this
solvent invested in this substitute on the assumption that it
would be considered an acceptable substitute. It would impose
a severe economic burden on these users to prohibit their use
of the substitute immediately, with no provision of time to
allow them to recover their investment in existing equipment
or acquire new equipment in a timely fashion. These factors
taken together appear to outweigh any statutory interest in
applying the new rule immediately to existing users, especially
since the restriction would apply immediately to new equipment
using HCFC-141b, which would serve to prevent further ozone
depletion from use of HCFC-141b in this application.
As with metals cleaning applications for 141b, the Agency
modeled potential 141b use in electronics cleaning applications
over time, and projected health effects due to ozone depletion
with the help of the Atmospheric Stabilization Framework model.
For electronics cleaning, the maximum market penetration for
141b as a replacement for CFC-113 is 90 per cent. With this
penetration, the model predicted approximately 400 additional
skin cancer fatalities and 30,000 additional skin cancer cases
compared to uses of non-ozone-depleting substitutes.
(3) Precision Cleaning. (a) HCFC-141b
For the same reasons described in the section on metals
cleaning,
HCFC-141b and its blends are proposed to be prohibited as
substitutes
for CFC-113/MCF in precision cleaning, with limited critical
use exemptions for CFC-113 replacements. The proposed effective
date for this prohibition is 30 days after the date of the final
rule for new equipment and as of January 1, 1996, for existing
equipment. As discussed earlier in this action in Section VI.A.,
the Agency is authorized to grandfather existing uses from a
proposed prohibition where appropriate under the four-part test
established in Sierra Club v. EPA, supra.
The Agency has conducted the four analyses required under
this test, and it has concluded that the balance of equities
favors a grandfathering period of two years for existing equipment
in this application. The prohibition proposed in this action
clearly represents a departure from previously established
practice,
as use of the substitute was allowed previously. Existing users
of HCFC-141b who switched from Class I substances into this
solvent invested in this substitute on the assumption that it
would be considered an acceptable substitute. It would impose
a severe economic burden on these users to prohibit their use
of the substitute immediately, with no provision of time to
allow them to recover their investment in existing equipment
or acquire new equipment in a timely fashion. These factors
taken together outweigh any statutory interest in applying the
new rule immediately to existing users, especially since the
restriction would apply immediately to new equipment using HCFC-
141b, which would serve to prevent further ozone depletion from
use of HCFC-141b in this application.
In the case of precision cleaning uses of HCFC-141b, the
Agency's modeling of 141b use as a CFC-113 replacement projected
approximately 5,000 additional skin cancer cases when compared
to use of non-ozone-depleting substitutes.
As in the case of other cleaning applications, the Agency
proposes to prohibit substitutions of 141b to replace MCF, since
these compounds have nearly identical ODPs. Here again, Agency
will propose to grant a limited number of critical use exemptions.
Companies in this sector wishing to replace CFC-113 with 141b
that may qualify for an exemption should review the section
in today's Preamble on critical use exemption petitions. The
Agency expects most requests for permission to use 141b will
come from this end use sector, and has already received a number
of inquiries from companies that either use or want to use 141b
as a substitute for cleaning with CFC-113.
G. Halons
1. Overview. Halons are gaseous or easily vaporizable
halocarbons
used primarily for putting out fires, but also for explosion
protection. The two halons used most widely in the United States
are Halons 1211 (chlorodifluorobromomethane) and 1301
(trifluorobromomethane).
Halon 1211 is used primarily in streaming applications in which
it is manually dispensed through a nozzle from a hand-held or
portable extinguisher. Halon 1301 is used in total flooding
and explosion protection applications in which a predetermined
quantity of the gas is dispensed into a fixed location in order
to achieve a specific extinguishing concentration of gas.
The principal use for Halon 1211 is in handheld extinguishers
in fixed facilities such as homes, offices, and military and
government buildings. A small percentage of handheld 1211
extinguishers
are also used on aircraft in accordance with FAA regulations.
Portable systems are used by military and commercial "crash/rescue"
teams at airports. In order to evaluate 1211 substitutes in
the variety of applications described above, the Agency has
divided streaming applications into three categories: residential,
commercial/industrial, and military. This subdivision of the
sector allows the Agency to properly account for differences
in the types of fires likely to be encountered and in the types
of proposed extinguishers.
Halon 1301 systems are used in combination with automatic
fire detection equipment as total flooding agents in contained
areas. Most Halon 1301 total flooding systems are used to protect
electronics facilities, such as computer rooms and
telecommunications
switching facilities. Halon 1301 is also used to protect oil
production facilities, records storage facilities, aircraft
cargo bays, flammable liquid storage facilities, laboratories,
public places such as libraries, museums, shopping malls and
tourist facilities, and much more.
Halon total flooding systems are particularly important in
protecting normally unoccupied facilities, where typically no
personnel are present to detect and extinguish fires. Halon
total flooding systems are also used in occupied areas in which
large numbers of workers or large capital investments may be
at risk. In this latter case, precautions must be taken to avoid
exposing occupants to toxic levels of extinguishant. Typically,
these chemicals are used in conjunction with fire detection
devices, alarm devices to warn occupants of impending discharge,
as well as manual abort mechanisms to delay discharge until
occupants are evacuated or to prevent accidental discharges.
Some systems also incorporate a `lockout' mechanism to prevent
discharge of agent in the event personnel must enter the area
in an emergency. Some occupational or military settings involve
flammable liquids or vapors (Class B fires) where the speed
of the potential fire event precludes evacuation prior to
discharge.
The design of a system that reacts quickly to the threat of
fire or explosion must consider the effects of human exposure
to the fire suppression agent.
Halon 1301 can also be used in explosion protection applications
which include explosion inertion and explosion suppression.
In inertion, the atmosphere is filled with an explosion protection
agent at the concentration needed to prevent an explosion. The
inerting agent must disperse uniformly and remain at the required
concentration for a specified amount of time. Effective inertion
systems require the timely detection of conditions likely to
cause an explosion. In suppression, an agent is discharged to
mitigate an explosion, or deflagration, that has already begun.
The agent must surround the expanding fireball at a specified
concentration. Both inertion and suppression require rapid
discharge
of agent, often without providing time for evacuation of personnel.
Again, possible exposure of occupants to toxic levels of the
compound must be carefully controlled and balanced against the
risk of explosion.
Some limited use of Halon 2402 also exists in the United
States, but only as an extinguishant in engine nacelles (the
streamlined enclosure surrounding the engine) on older aircraft
and in the guidance system of Minuteman missiles. Halons also
find limited application in other use sectors such as plasma
etching. Decisions proposed in this notice do not address these
other sectors, but instead focus on fire protection applications
which comprise the vast majority of halon applications.
Halons are used in a wide range of fire protection applications
because they combine five characteristics. First, they are highly
effective against solid, liquid/gaseous, and electrical fires
(referred to as Class A, B, and C fires, respectively). Second,
they are clean agents; that is, they dissipate rapidly, leaving
no residue and therefore do not cause "secondary damage" to
the property they are protecting. Third, halons do not conduct
electricity and can be used in areas containing live electrical
equipment. Fourth, halons are gaseous substances that can penetrate
in and around physical objects to extinguish fires in otherwise
inaccessible areas. Finally, halons are generally safe for limited
human exposure when used with proper exposure controls.
Despite these advantages, halons are among the most ozone
depleting chemicals in use today. Halon 1301 has an estimated
ODP of 16; Halon 1211 has an estimated ODP of 4. Thus, while
total halon production (measured in metric tons) comprised just
2 per cent of the total production of Class I substances in
1986, halons represented 23 per cent of the total estimated
ozone depletion potential of CFCs and halons combined. Halons
therefore make up the largest use sector in terms of ozone
depleting
potential.
The greatest releases of halon into the atmosphere occur
not in extinguishing fires, but during testing and training,
service and repair, and accidental discharges. Data generated
as part of the Montreal Protocol's technology assessment indicate
that only 15 per cent of annual Halon 1211 emissions and 18
per cent of Halon 1301 emissions occur as a result of use to
extinguish actual fires. These figures indicate that significant
gains can be made in protecting the ozone layer by revising
testing and training procedures and by limiting unnecessary
discharges through better detection and dispensing systems for
halon and halon alternative systems. Additional information
on specific halon uses can be found in the Montreal Protocol
1991 Assessment or in other background material in the public
docket. The initial determinations found in this section are
based on the risk screen described in the draft background document
entitled "Characterization of Risk from the Use of Substitutes
for Class I Ozone-Depleting Substances: Fire Extinguishing and
Protection (Halon Substitutes)."
2. Substitutes for Halons. The fire protection community
has made considerable progress in identifying and developing
substitutes for halons in fire protection applications. Several
manufacturers have submitted information regarding substitute
streaming and total flooding agents, and the National Fire
Protection
Association (NFPA) has initiated efforts to develop standards
for their use in total flooding scenarios. In addition,
manufacturers
are seeking Underwriters Laboratories (UL) and Factory Mutual
(FM) certification for systems employing the new agents. The
Agency's review of halon substitutes is intended not to replace,
but to complement the guidance of the fire protection community
in directing the transition away from halons to substitutes
that are less destructive to the stratosphere.
Most recent efforts to develop substitutes for halon have
focused primarily on halocarbon chemicals. These are considered
potential "replacements" for halon because they possess halonlike
properties (gaseous, non-conducting) and because they can be
used on Class A, B, and C fires. These halocarbon replacements
can be distinguished by the mechanism by which they extinguish
fires. Chemical action agents, like halons, suppress fires by
interfering with the free radical chain reactions that sustain
a fire. Physical action agents cool, dilute, or smother the
fire (separating the air and fuel). In general, chemical action
agents are much more effective fire suppressants than physical
action agents.
Halocarbons represent only a portion of agents available
for fire protection. Water mist or fog is a newly developing
technology that uses fine water droplets to suppress and extinguish
fires. Studies indicate that water mist can be used in a wide
variety of applications for occupied and unoccupied areas including
electronics, machinery spaces, enclosed spaces, etc. Several
other "alternative" agents such as water, carbon dioxide, foam,
and dry chemicals are already in widespread use as fire
extinguishants
and can be expected to find limited use as substitutes for halon.
Unlike some halocarbons, these alternative agents are not effective
against all types of fire. They do not all have the same
penetration
capability, nor are they all non-conducting and non-toxic. Thus,
each can be used only in specified applications as directed
by manufacturers and by fire protection authorities such as
the NFPA. However, these alternatives should seriously be
considered
as appropriate replacements to halons where systems are being
redesigned.
Substitutes for halons, whether other halocarbons or
alternatives
such as water, must meet four general criteria. They must be
effective fire protection agents, have an acceptable environmental
impact, have low toxicity, and they must be relatively clean
or volatile. In addition, they must be commercially available
as a halon replacement in the near future.
The halon sector requires special evaluation of consumer
and worker exposures to discharges of halon substitutes during
fire emergencies and accidental discharges. In these acute,
episodic exposures to the halon substitutes, cardiac sensitization
is of particular interest. The term cardiac sensitization refers
to an increased susceptibility of the heart to adrenaline (or
other catecholamines) which may result in potentially fatal
heart arrhythmias.
Human heart arrhythmias and sudden deaths resulting from
overexposure to CFCs, halons, and other halogenated hydrocarbons
have been documented in workplace settings, and in volatile
substance abuse (i.e. glue-sniffing). Several studies involving
human exposure in a laboratory setting establish the potential
significance for human health of animal data on cardiac
sensitization.
(See the background document "Characterization of Risk from
the Use of Substitutes for Class I Ozone-Depleting Substances:
Fire Extinguishing and Protection" for more details.) Evaluating
the safety of potential halon substitutes requires the measurement
of the No-Observed-Adverse-Effect-Level (NOAEL) and the Lowest-
Observed-Adverse-Effect-Level (LOAEL) of cardiac sensitization
in an appropriate species, usually the dog. The Agency uses
the NOAEL value as the basis to ensure protection to the worker
population.
The determination of the safety of either a flooding or
streaming
agent substitute is also dependent on a number of other related
factors. For total flood systems, the magnitude of exposure
will depend on the design concentration of the flooding agent
(as determined by the substitute's extinguishing concentration
plus 20 percent, as specified by NFPA guidelines) and the length
of time it takes a person to evacuate the area in which the
agent is released. Because total flood systems are designed
to achieve a uniform concentration of agent within a space,
the magnitude of exposure is independent of the size of space,
size of fire, or proximity of person to the fire. In assessing
exposure and consequent use restrictions, the design concentration
of a total flood substitute is compared to its cardiotoxic NOAEL
and LOAEL levels. Generally, if the design concentration is
higher than the agent's NOAEL level, conditions are placed on
the use of the agent to ensure human safety. For example, if
the NOAEL is 1 percent and the LOAEL is 2.5 percent, but the
substitute requires 4 percent concentration to extinguish a
fire, all personnel must be evacuated from an area before the
concentration exceeds the 2.5 percent LOAEL. If there is a
possibility
that someone must enter a room while the agent is likely to
exceed the NOAEL level, Self Contained Breathing Apparatuses
(SCBA) must be worn in accordance with OSHA safety requirements.
In contrast, exposure to substitute streaming agents can
be expected to vary greatly depending on the amount of agent
released, the time needed to extinguish a fire, the size of
the room or enclosure in which a fire occurs, the size of the
fire, the proximity of the person to the point of discharge
of the agent, the rate at which fresh air infiltrates the space,
and the air exchange rate near the fire. Assessment of exposure
in streaming applications is much more complicated and requires
development of a model and testing of the values assumed for
the variables described above. The resulting modeled peak exposure
rate is compared to the NOAEL in our assessments. For some proposed
substitutes, the Agency requires personal monitoring data in
order to complete the assessment.
Evaluating halon substitutes also requires assessing the
efficacy of substitute agents. The efficacy of a fire protection
agent can be measured by the extinguishing concentration required
to put out a burning fire. With substitutes for handheld
extinguishers
and for total flood systems on weight-constrained systems (such
as aircraft and space systems), designers are also concerned
with the weight of substitute required to replace the halon.
This factor is referred to as the weight equivalency ratio and
relates the number of pounds of substitute required to replace
each pound of halon to achieve the same fire extinguishing
capability.
In other applications, such as with existing equipment, required
storage volume for a substitute is of greatest concern. This
quantity can be measured by the storage volume equivalency ratio
which is defined as the ratio of the storage volume of substitute
to the storage volume of halon required to achieve the same
fire extinguishing capability. These three measures will be
used throughout this proposed rule to evaluate halon substitutes.
After concluding the analysis of alternatives to halon, the
Agency in some cases proposes to approve the use of an agent
contingent on certain conditions. In implementing its use of
conditions, the Agency has sought to avoid overlap with other
existing regulatory authorities. EPA has taken a number of steps
to mitigate this potential for duplication. First, EPA intends
to limit the use of conditions to cases in which clear regulatory
gaps exist. Second, these existing regulatory gaps must render
the use of a substitute an unreasonable risk in the absence
of any additional controls. Third, in the limited cases in which
conditions may be necessary, the Agency will impose them only
after going through formal notice-and-comment rulemaking. Finally,
the Agency intends to withdraw existing conditions when they
are superseded by appropriate regulatory controls under other
authorities.
The Agency, however, requests comment on the general issue
of the need for use of conditions. In particular, EPA requests
comment on whether section 612 in fact confers upon the Agency
the authority to go beyond the listing of acceptable and
unacceptable
alternatives and to set such use conditions; and on the capability
and practicality of EPA enforcing use conditions which may,
for example, closely resemble workplace safety standards which
are typically within the enforcement purview of other regulatory
authorities.
EPA also requests comment on whether, when an unreasonable
risk might exist due to a gap in regulatory coverage, the
appropriate
means to address these risks is through the existing regulatory
framework of other federal authorities. For example, rather
than using EPA's use conditions to address existing gaps in
workplace safety standards, EPA could refer the matter to the
appropriate OSHA authorities and request appropriate action
to mitigate an otherwise unreasonable risk.{4}
³{4} 29 USC 654, OSHA General Duty Clause, requires
that
³each employer "shall furnish to each of his employees
³employment and a place of employment which are free
from
³recognized hazards that are causing or are likely to
³cause death or serious physical harm to his employees.
³* * * "
Alternatively, where the length of time required to address
a problem under another authority may be unacceptably long given
the nature of the risk, there may be cases in which EPA would
simply consider unacceptable the use of a given substitute,
pending the development of a regulatory framework to control
the risk it poses in its use as a substitute for an ozone-depleting
compound.
Finally, EPA requests comment on the use of conditions where
no regulatory gap, per se, exists, but where the use of an
alternative
poses risk to the public. By imposing such conditions, EPA would
be establishing a new regulatory framework where one did not
previously exist. For example, explosion inertion agents are
not currently regulated by OSHA or any other regulatory body.
However, design concentrations for systems protecting from
explosion
of various gases or flammable liquids may expose personnel to
cardiotoxic levels of inertion agents. While the Agency is not
currently proposing to place conditions for the use of alternatives
in occupied areas, it may do so in the final rule subject to
public comment as well as further analysis with agencies such
as OSHA and OMB. EPA could place a condition for use of alternative
agents in occupied areas which would identify the cardiotoxic
LOAEL and would prohibit design concentrations that exceed that
level.
The primary candidate substitutes for halons in fire protection
applications are discussed below by category. No SNAP submissions
have been received for substitutes to replace halons in explosion
suppression applications. However, in the listing decisions,
explosion suppression is included with the explosion inertion
decisions. The Agency is requesting comment on this.
a. Brominated Hydrofluorocarbons.-Brominated hydrofluorocarbons
(HBFCs) are an effective halon substitute. Because these substances
contain bromine, they act as chemical action agents in the same
manner as the halons. In fact, some HBFCs are more effective
than Halons 1211 and 1301 in specific applications. For this
reason, HBFCs can replace Halons 1211 and 1301 on nearly a one-
to-one basis and appear to have significant applicability in
existing systems. However, the presence of bromine also means
that these agents have higher ozone-depleting potentials than
other halon substitutes.
At this time, only one HBFC, HBFC-22B1, is expected to be
commercially available in the near term. Extinguishment testing
indicates that HBFC-22B1 can replace Halon 1211 at a ratio of
1.08 by weight, making it a substitute for handheld extinguishers.
HBFC-22B1 can also replace Halon 1301 at a ratio of 1.4 by weight
and 1.3 by storage volume, making it technically suitable for
use in existing total flood systems.
HBFC-22B1 can, however, serve only as an interim substitute
for halons. The substance has an estimated ODP of 0.74 and will
soon be added to the list of Class I substances in accordance
with section 602(d) of the Clean Air Act. Under the Montreal
Protocol, production of HBFC-22B1 is required to be completely
phased out by January 1, 1996. In addition, this agent was
submitted
to the Agency as a Premanufacture Notice (PMN) and is presently
subject to requirements contained in a Toxic Substance Control
Act (TSCA) section 5(e) Consent Order and associated Significant
New Use Rule (40 CFR 721.1296). The provisions of today's proposed
rule do not supersede those of the TSCA regulations presently
in effect, and readers should note that, at present, the terms
of the TSCA requirements are more restrictive than the provisions
of this rule.
b. Hydrochlorofluorocarbons
A number of hydrochlorofluorocarbons (HCFCs) have also been
suggested as halon replacements. These include HCFC-22, HCFC-
123, and HCFC-124. These HCFCs are effective fire-fighting agents,
but because they are physical action agents, they are considerably
less effective than halons or HBFCs and thus exhibit high
extinguishing
concentrations. Further, although the ozone depletion potential
of HCFCs is considerably lower than that of either halons or
HBFCs, they are listed as Class II chemicals under the Clean
Air Act and their production will be phased out. As a result,
these chemicals can serve only as interim halon substitutes.
HCFC-22 has been suggested as a total flooding agent. HCFC-
22 has a low acute toxicity, but its ODP (0.05) is higher than
other candidate HCFCs. The extinguishing concentration is 11.6
percent, the highest of the candidate HCFCs, while its
cardiotoxicity
LOAEL is 5.0 percent. It also is somewhat inferior in terms
of weight and storage volume equivalents. For these reasons,
this compound is unlikely to be used as a single agent.
HCFC-123 is being considered as a streaming agent to replace
Halon 1211. Because of its relatively high effectiveness, HCFC-
123 could replace Halon 1211 at a ratio of 1.8 by weight-a figure
considerably better than that of most other streaming substitutes.
HCFC-123 has the lowest ODP of all the HCFCs proposed as halon
substitutes, and its global warming potential (GWP) is half
that of other proposed HCFC substitutes. However, HCFC-123,
has a cardiotoxic level of 2.0 percent in the dog, with no effect
apparent at 1.0 percent. Potential users have expressed concern
about using HCFC-123, or blends containing HCFC-123 as the primary
constituent, in small enclosed areas. However, actual exposures
were assessed using personal monitoring, and the Agency concludes
that likely exposure levels do not exceed safe levels.
HCFC-124 is being considered as both a total flooding agent
and a streaming agent, both alone and in blends. HCFC-124
demonstrates
average performance compared to other halon substitutes as a
fire extinguishant and has relatively low ODP and GWP values.
Testing indicates that the substance may be lethal at levels
ranging from 24 percent to 36 percent. Cardiotoxicity occurs
in the dog at 2.5 percent with no effect apparent at 1.0 percent.
Potential users express concerns regarding exposures in small
enclosed spaces.
c. Hydrofluorocarbons. Hydrofluorocarbons (HFCs) have also
been suggested as halon substitutes. HFCs are physical action
agents and are less effective than halons or HBFCs. Due to their
reduced efficacy, considerably larger storage volumes are required
for use in fire protection systems. Their great advantage over
halons, HBFCs, and HCFCs is that HFCs have an ozone depletion
potential of zero. However, when exposed to fires, HFCs potentially
decompose into greater amounts of hydrogen fluoride (HF) than
do HCFCs, depending on the number of fluorines in the molecule.
Discharge of these chemicals onto a fire must be rapid to prevent
the buildup of large amounts of these decomposition products.
In addition, some HFCs can potentially contribute to global
warming. The Agency examines the atmospheric lifetime and global
warming potential (GWP) of each substitute to establish a risk
balanced listing decision. If an agent's atmospheric lifetime
or GWP is unusually large relative to other available substitutes,
the use of these agents may be allowed only for specific limited
uses to prevent widespread adoption.
HFC-23, HFC-32, HFC-125, HFC-134a, and HFC-227ea have all
been proposed as total flooding agents. HFC-227ea has also been
proposed as a streaming agent. Required extinguishing
concentrations
vary from 5.9 percent for HFC-227ea to 12.4 percent for HFC-
23. Required storage volumes will vary from 2.5 to 4.5 times
that required for 1301. Weight equivalency ratios compared to
1301 vary from 1.1 for HFC-32 to 2.65 for HFC-125. All have
low acute toxicity levels.
Not all of these substances have been fully investigated
for commercialization. Specifically, HFC-32 is considered flammable
with a flammability range that is very large, and would probably
require blending with another material to make a nonflammable
mixture.
d. Perfluorocarbons.-Perfluorocarbons (PFCs) are effective
fire protection agents, having the lowest required extinguishing
concentration of any of the suggested substitutes other than
HBFCs. However, these compounds have high molecular weights
which create weight and storage replacement ratios that are
somewhat higher than the HCFCs and many of the HFC candidates.
Two PFCs have been submitted as halon replacements: perfluorobutane
(FC 3-1-10) as a total flood replacement for Halon 1301, and
perfluorohexane (FC 5-1-14) as a Halon 1211 replacement primarily
for USAF flightline applications.
As discussed in the section on refrigerants, PFCs are of
concern due to long atmospheric lifetimes and their potential
to contribute to global warming. The intent of SNAP is to reduce
the overall risk to health and the environment. Since there
is no other regulatory authority controlling the emissions of
such long-lived agents, the Agency intends to take conservative
decisions regarding substances with the potential to cause
significant
environmental, and ultimately human health, impacts. Therefore,
the Agency is proposing to prohibit discharge testing and training
with these agents, and to require recapture and recycling in
order to minimize emissions of these agents. Eighty to eighty-
five percent of all halon emissions are due to testing, training,
leakage and accidental discharge, and it is likely that such
emission patterns will occur with the alternative agents as
well. In addition, the Agency proposes to allow use of PFCs
only for applications involving critical military uses, the
protection of public safety or national security, or life support
functions. The Agency invites comment about the niche these
agents can best serve in light of the fact that the Agency seeks
to prevent their widespread use. The Agency specifically invites
comment on the cost of these restrictions and benefits in terms
of reduced potential for global warming.
e. Chlorofluorocarbons.-Chlorofluorocarbons (CFCs) have also
been proposed as halon alternatives, either individually or
in blends. However, since production of CFCs is to be phased
out by the end of 1995, sufficient quantities of recycled CFC
would have to be available for halon applications, making it
improbable that significant shifts to these compounds will occur.
CFCs are relatively effective fire extinguishants and have well-
understood toxicity characteristics. While CFCs deplete
stratospheric
ozone, their ODPs are significantly lower that those of Halons
1211 and 1301.
f. Blends.-A number of manufacturers have proposed proprietary
blends of chemicals for fire protection applications. These
blends combine a variety of CFCs, HCFCs, HFCs, PFCs, inert gases,
and other additives to achieve desired levels of effectiveness,
toxicity, and decomposition products. Most of these blends have
non-zero ODPs and GWPs. Toxicity varies with the exact composition
of the blend.
Where possible, the Agency has examined both the blend and
its individual constituents. Characteristics of the overall
combination, in some cases, were examined to estimate a weighted
average of the characteristics of the individual components.
g. Non-halocarbon Alternative Agents. Non-halocarbon alternative
agents such as CO2, dry chemical, foams, inert gas blends and
water that are currently in widespread use may also be used
as substitutes for halon. However, as noted above, these agents
are not as widely applicable as are the halons and must be used
in end uses recommended by the manufacturers and approved by
standard-setting entities such as the NFPA.
CO2 can be used as a streaming or a total flooding agent.
In the past, CO2 systems were used in many of the applications
now served by halons. As a total flooding agent, CO2 has an
extinguishing concentration ten times that of Halon 1301 and
requires 1.4 times the storage volume required by 1301 systems;
it is also an asphyxiant in the concentrations required for
total flooding. Streaming CO2 extinguishers must also be larger
and heavier than 1211 extinguishers and have no Class A fire
rating. Additionally, depending on the exposure characteristics
discussed above, CO2 may reach dangerous levels in small areas.
One manufacturer has developed a blend of CO2 mixed with
inert gases as a Halon 1301 substitute in total flood systems.
This agent would not be considered a `drop in' replacement due
to its high extinguishing concentration. As it is a non-reactive,
non-halocarbon substance, and thus is not carcinogenic, mutagenic
or teratogenic, the toxicity and cardiotoxicity tests normally
applied to halon substitutes do not apply here. Rather, this
agent is a potential asphyxiant. It is designed to decrease
the oxygen level to 12 to 14 per cent, at which combustion cannot
be supported. OSHA requires oxygen levels to be at least 19.5
per cent for human safety. It has been suggested that this
particular
blend increases breathing rates, thus making the oxygen deficient
atmosphere breathable for short periods of time. Data submitted
by the manufacturer was peer-reviewed by pulmonary, cardiac,
and stroke specialists. All have agreed that the blend does
not pose significant risk to the working population and may
even pose less risk than does exposure to halocarbon agents.
Dry chemical extinguishers are suitable for Class A, B, and
some Class C fires. Total flooding systems using dry chemical
are rare, but some "localized applications" exist around deep
fat fryers and textile machines. Generally, dry chemical
extinguishers
are more effective than halons, but dry chemical is not a clean
agent and cannot be used without potentially damaging precision
machinery and other equipment.
Water is an effective fire protection agent that can be used
with either total flooding or streaming systems. Water is primarily
a Class A fire extinguishant, but can be used against Class
B when applied as a fine mist. Water also produces a cooling
effect that prevents re-ignition. Water, typically cannot be
used against Class C electrical fires and may cause considerable
secondary damage in some applications. However, a promising
new technology incorporates fine water droplets to create a
water mist or fog. It has been suggested that water mist systems
are safe for use on Class A and B fires, and even on Class C
electrical fires without causing secondary damage.
Foams are extremely effective in extinguishing flammable
liquids (Class B fires) and to some degree against Class A fires.
Portable and handheld systems are available for use as streaming
agents, but high- and medium-expansion foams are also marketed
for total flooding applications in inaccessible areas (such
as between floors or in marine machinery spaces). Use of high-
and medium-density foams can be dangerous in large, cluttered
or hazardous enclosures in which people might be present, but
foams are not typically considered toxic. Nevertheless, foams
can cause secondary damage and, due to their water content,
cannot be used with electrical fires. They do not penetrate
as well as gaseous agents.
3. Preliminary Listing Decisions
In order to evaluate the acceptability of proposed halon
substitutes, the Agency divided the fire protection sector into
six end-uses: (1) Residential/Consumer Streaming Agents, (2)
Commercial/Industrial Streaming Agents, (3) Military Streaming
Agents, (4) Total Flooding Agents for Occupied Areas, (5) Total
Flooding Agents for Unoccupied Areas, and (6) Explosion Inertion.
The table in Appendix B provides a summary of decisions by end
use.
For some substitutes, data required by the Agency to complete
a risk assessment is not yet available or has not been submitted
to the Agency as requested. As a result, not all candidate
substitutes
have been fully evaluated by the Agency. Those substitutes which
the Agency is currently reviewing, but for which a final
determination
cannot yet be made, are listed as pending in the table in Appendix
B. The Agency will make every effort to evaluate these chemicals
before promulgation of the final rule.
a. Acceptable Substitutes.-(1) Streaming Agents: Consumer
Applications.
(a) HBFC-22B1. HBFC-22B1 is proposed acceptable as a streaming
agent in consumer applications for nonresidential uses only.
Given the potential market penetration and the high ODP of HBFC-
22B1, use of HBFC-22B1 in consumer applications was estimated
to cause unacceptable damage to the ozone layer and an excessively
high number of skin cancer cases and deaths. The total estimated
skin cancer cases and fatalities from the use of 22B1 as a halon
1211 replacement in all uses including consumer uses is
approximately
30,000 and approximately 600, respectively. In light of the
availability of other fire protection agents with lower associated
risks, the Agency determined that the risks posed by HBFC-22B1
were too large to justify widespread use in the consumer sector.
In addition to concern about its ODP, use of HBFC-22B1 in
residential applications may present exposure risks of
cardiosensitization.
To assess this risk, the Agency modeled the peak concentration
of HBFC-22B1 that would be expected if such an extinguishant
were used to suppress a kitchen fire and estimated the decline
from the peak. Such analysis indicated that peak concentrations
of HBFC-22B1 would exceed 3300 ppm. This is in excess of NFPA
ceilings for exposure.
Because of its effectiveness, the Agency is approving use
of HBFC-22B1 as a streaming agent only for nonresidential uses
only. However, it can only be considered a transitional agent,
because it will be phased out as a Class I substance in accordance
with the Clean Air Act and with the requirements of the Montreal
Protocol.
This agent was submitted to the Agency as a Premanufacture
Notice (PMN) and is presently subject to requirements contained
in a Toxic Substance Control Act (TSCA) section 5(e) Consent
Order and associated Significant New Use Rule (40 CFR 721.1296).
Under the terms of the Consent Order, it may be used only for
outdoor automotive and marine applications. In addition, to
ensure safe use, the sale of this product is restricted to a
size discouraging residential use, with a minimum UL rating
of 5BC. The unit must be properly labeled indicating that
residential
use is prohibited due to danger of cardiotoxicity; indicating
proper space volume restrictions limiting exposure to 1 per
cent; and indicating proper evacuation and reentry requirements.
In addition, the agent may only be sold in rechargeable units
to encourage reuse and recycling and to discourage the potential
for the agent to escape to the atmosphere through improper
disposal.
(b) HCFC-123. HCFC-123 is acceptable as a streaming agent
for consumer applications. Because of its relatively high
effectiveness,
HCFC-123 could replace Halon 1211 at a ratio of 1.8 by weight-
a figure considerably better than that of most other streaming
substitutes. HCFC-123 has the lowest ODP of all the HCFCs proposed
as halon substitutes, and its global warming potential (GWP)
is half that of other proposed HCFC substitutes. However, since
HCFC-123, has a cardiotoxic level of 2.0 per cent in the dog,
with no effect apparent at 1.0 per cent, potential users have
expressed concern about using HCFC-123 or blends containing
HCFC-123 as the primary constituent. However, actual exposures
were assessed using personal monitoring devices, and the Agency
concludes that likely exposure levels from its use as a streaming
agent do not exceed safe levels.
(c) [HCFC Blend] B
[HCFC Blend] B is acceptable as a streaming agent for consumer
applications.-This blend consists largely of HCFC-123, therefore,
as with HCFC-123, it has been shown in tests to have a relatively
high effectiveness with a weight equivalency ratio to Halon
1211 of 1.8-a figure considerably better than that of most other
streaming substitutes. HCFC-123 has the lowest ODP of all the
HCFCs proposed as halon substitutes, and its global warming
potential (GWP) is half that of other proposed HCFC substitutes.
While HCFC-123 has a cardiotoxic level of 2.0 per cent in the
dog, with no effect apparent at 1.0 per cent, actual exposures
from use of this blend as a streaming agent were assessed using
personal monitoring devices. The Agency concludes that likely
exposure levels do not exceed safe levels.
(d) [CFC-Blend]
[CFC-Blend] is acceptable as a streaming agent for
nonresidential
consumer use.-While [CFC-Blend] contains CFCs, its overall ODP
is 0.95, which is less than one-fourth that of Halon 1211. [CFC-
Blend] is the most effective of all other halon substitutes
except for HBFC-22B1 and HCFC-123, and does not pose the exposure
risk of HBFC-22B1 in certain scenarios. [CFC-Blend] is generally
considered non-toxic but in light of its high ODP relative to
other substitute agents and the large potential market for
consumer/residential
extinguishers, alternative agents such as water and dry chemical
are considered sufficient for residential uses. In addition,
this substitute will be phased out by December 31, 1995.
(e) Dry Chemical
Dry chemical extinguishers are approved for use in residential
streaming applications as a Halon 1211 substitute.-Dry chemical
extinguishers can be used as a substitute for Halon 1211 in
most residential applications. While dry chemical extinguishers
can be used on Class A, B, or C fires depending upon the type
of powder used, they do not always penetrate well around obstacles,
they do not inhibit re-ignition of fires, they do not cool
surfaces,
they can cause secondary damage, and discharge in confined spaces
can result in temporary loss of visibility. Dry chemical
extinguishers
should be used only in accordance with manufacturer's guidelines
and with relevant NFPA standards.
(f) Carbon Dioxide
Carbon Dioxide extinguishers are approved for use in residential
streaming applications as a Halon 1211 substitute.-Carbon dioxide
can be used as a direct substitute for Halon 1211 in specified
applications. Carbon dioxide systems have no rating versus Class
A fires and so must be used in conjunction with another type
of extinguisher to ensure that all possible fire scenarios can
be appropriately handled. In addition, discharge of carbon dioxide
into confined spaces may result in CO2 concentrations above
the Immediately Dangerous to Life and Health (IDLH) level. Areas
into which carbon dioxide is discharged should be immediately
evacuated and ventilated. Carbon dioxide extinguishers should
be used only in accordance with manufacturer's guidelines and
applicable NFPA standards.
(g) Water
Water extinguishers are approved for use in residential
streaming
applications as a Halon 1211 substitute. Users should be aware,
however, that water extinguishers cannot act as a substitute
for Halon 1211 in all applications. Water is primarily a Class
A (solid) fire extinguishant and should not be used with Class
B (flammable liquid) or C (electrical) fires. Water may damage
objects onto which it is discharged. Water extinguishers should
be used only in accordance with manufacturer's guidelines and
with NFPA standards.
(h) Foam
Foam extinguishers are approved for use in residential streaming
applications as a Halon 1211 substitute. Foam extinguishers
cannot be used as a substitute for halon in all applications.
Portable foam extinguishers are intended primarily for use on
flammable liquid fires and are somewhat effective on Class A
fires. Foams can also cause secondary damage on objects onto
which it is discharged. Foam extinguishers should be used in
accordance with manufacturer's guidelines and with NFPA standards.
(2) Streaming Agents: Commercial/Industrial Use
(a) HBFC-22B1
HBFC-22B1 is approved for use as a streaming agent in
commercial/industrial
applications. Despite its high ODP, this chemical will enable
industry to more rapidly shift away from 1211 extinguishants
which have an even higher ODP. Moreover, as the chemical will
be phased out as a Class I substance on January 1, 1996, only
limited use is expected to be made of this substitute.
Worker exposure may be a concern in small office areas, but
in larger offices, modeling efforts indicate that HBFC-22B1
can be used safely. In most office/industrial fire scenarios,
proper procedures should be in place regarding the operation
of the extinguisher and ventilation of extinguishment areas
after dispensing the extinguishant to minimize concerns about
exposure.
This agent was submitted to the Agency as a Premanufacture
Notice (PMN) and is presently subject to requirements contained
in a Toxic Substance Control Act (TSCA) section 5(e) Consent
Order and associated Significant New Use Rule (40 CFR 721.1296).
Under the terms of the Consent Order, to ensure safe use, the
sale of this product is restricted to a size discouraging
residential
use, with a minimum UL rating of 5BC. The unit must be properly
labeled indicating that residential use is prohibited due to
danger of toxicity, listing proper space volume restrictions
limiting exposure to 1 per cent, and indicating proper evacuation
and reentry requirements. In addition, the agent may only be
sold in rechargeable units to encourage reuse and recycling
and to discourage the potential for the agent to escape to the
atmosphere through improper disposal. EPA invites comment on
these use restrictions.
(b) [CFC-Blend]
[CFC-Blend] is acceptable as a streaming agent for use in
commercial/industrial streaming applications. While [CFC-Blend]
contains CFCs, its overall ODP is 0.95, which is less than one-
fourth that of Halon 1211. [CFC-Blend] is the most effective
of all other halon substitutes except for HBFC-22B1 and HCFC-
123, and does not pose the exposure risk of HBFC-22B1 in certain
scenarios. [CFC-Blend] is generally considered non-toxic and
could serve as a transitional substitute in many streaming
applications,
but will be phased out by December 31, 1995.
(c) HCFC-123
HCFC-123 is acceptable as a streaming agent for
commercial/industrial
applications.
Because of its relatively high effectiveness, HCFC-123 could
replace Halon 1211 at a ratio of 1.8 by weight-a figure
considerably
better than that of most other streaming substitutes. HCFC-123
has the lowest ODP of all the HCFCs proposed as halon substitutes,
and its global warming potential (GWP) is half that of other
proposed HCFC substitutes. However, since HCFC-123, has a
cardiotoxic
level of 2.0 percent in the dog, with no effect apparent at
1.0 percent, potential users have expressed concern about using
HCFC-123, or blends containing HCFC-123 as the primary constituent.
However, actual exposures were assessed using personal monitoring
devices, and the Agency concludes that likely exposure levels
from its use as a streaming agent do not exceed safe levels.
(d) [HCFC Blend] B
[HCFC Blend] B is acceptable as a streaming agent for
commercial/industrial
applications.
This blend consists largely of HCFC-123, therefore, as with
HCFC-123, it has been shown in tests to have a relatively high
effectiveness with a weight equivalency ratio to Halon 1211
of 1.8-a figure considerably better than that of most other
streaming substitutes. HCFC-123 has the lowest ODP of all the
HCFCs proposed as halon substitutes, and its global warming
potential (GWP) is half that of other proposed HCFC substitutes.
While HCFC-123 has a cardiotoxic level of 2.0 percent in the
dog, with no effect apparent at 1.0 percent, actual exposures
from use of this blend as a streaming agent were assessed using
personal monitoring devices. The Agency concludes that likely
exposure levels do not exceed safe levels.
(e) Dry Chemical
Dry Chemical, for the reasons described and with the limitations
suggested in the section on consumer streaming applications,
are approved for use as a commercial/industrial streaming agent.
(f) Carbon Dioxide
Carbon Dioxide, for the reasons described and with the
limitations
suggested in the section on consumer streaming applications,
is approved for use as a commercial/industrial streaming agent.
(g) Water
Water, for the reasons described and with the limitations
suggested in the section on consumer streaming applications,
is approved for use as a commercial/industrial streaming agent.
(h) Foam
Foams, for the reasons described and with the limitations
suggested in the section on consumer streaming applications,
is approved for use as a commercial/industrial streaming agent.
(3) Streaming Agents: Military Applications (a) HBFC-22B1
(a) HBFC-22B1
HBFC-22B1 is approved for use as a streaming agent in military
applications. Despite its high ODP, HCFC-22B1 will enable the
military to more rapidly shift away from 1211 extinguishants
which have an even higher ODP. Moreover, as this chemical will
be phased out under the Montreal Protocol (with possible essential
use exemptions) as a Class I substance on January 1, 1996, only
limited use is expected to be made of this substitute.
Worker exposure may be a concern in small, enclosed areas,
but in larger areas and outdoor areas, modeling efforts indicate
that HBFC-22B1 can be used safely. In most realistic fire
scenarios,
proper procedures should be in place regarding the operation
of the extinguisher, workers will be properly trained in fire-
fighting procedures, and ventilation of extinguishment areas
can be expected after dispensing the extinguishant.
This agent was submitted to the Agency as a Premanufacture
Notice (PMN) and is presently subject to requirements contained
in a Toxic Substance Control Act (TSCA) section 5(e) Consent
Order and associated Significant New Use Rule (40 CFR 721.1296).
Under the terms of the Consent Order, to ensure safe use, the
sale of this product is restricted to a size discouraging
residential
use, with a minimum UL rating of 5BC. The unit must be properly
labeled indicating that residential use is prohibited due to
toxicity; indicating proper space volume restrictions limiting
exposure to 1 percent; and indicating proper evacuation and
reentry requirements. In addition, the agent may only be sold
in rechargeable units to encourage reuse and recycling and to
reduce the potential for the agent to escape to the atmosphere
through improper disposal.
(b) HCFC-123
HCFC-123 is acceptable as a streaming agent for military
applications.
Because of its relatively high effectiveness, HCFC-123 could
replace Halon 1211 at a ratio of 1.8 by weight-a figure
considerably
better than that of most other streaming substitutes. HCFC-123
has the lowest ODP of all the HCFCs proposed as halon substitutes,
and its global warming potential (GWP) is half that of other
proposed HCFC substitutes. However, since HCFC-123 has a
cardiotoxic
level of 2.0 percent in the dog, with no effect apparent at
1.0 percent, potential users have expressed concern about using
HCFC-123, or blends containing HCFC-123 as the primary constituent.
However, actual exposures were assessed using personal monitoring
devices, and the Agency concludes that likely exposure levels
from its use as a streaming agent do not exceed safe levels.
(c) [HCFC Blend] B
[HCFC Blend] B is acceptable as a streaming agent for military
applications.
This blend consists largely of HCFC-123, therefore, as with
HCFC-123, it has been shown in tests to have a relatively high
effectiveness with a weight equivalency ratio to Halon 1211
of 1.8-a figure considerably better than that of most other
streaming substitutes. HCFC-123 has the lowest ODP of all the
HCFCs proposed as halon substitutes, and its global warming
potential (GWP) is half that of other proposed HCFC substitutes.
While HCFC-123 has a cardiotoxic level of 2.0 percent in the
dog, with no effect apparent at 1.0 percent, actual exposures
from use of this blend as a streaming agent were assessed using
personal monitoring devices. The Agency concludes that likely
exposure levels do not exceed safe levels.
(d) FC 5-1-14
FC 5-1-14 is acceptable in streaming applications for military
flightlines, inside military aircraft, and in military computer
and telecommunication facilities.
Due to the long atmospheric lifetime of FC 5-1-14, the Agency
urges that the chemical be used only in those instances in which
a viable alternative is not available. The Agency proposes that
the only acceptable uses involve national security or public
safety where no other substitute has been proven to be as
effective.
For example, military flightlines are ground-based operations
which typically involve fuel spills and fires in engine nacelles.
Flightlines require a clean agent that is capable of extinguishing
three-dimensional fires, and that is non-corrosive and leaves
no residue in order to leave engines intact. These are typically
smaller, easily contained fires. Crash Rescue Vehicles may have
a combination of agents available, but agents such as foam are
usually used for larger fires.
The Agency proposes to permit use of this agent in operational
military electronics facilities such as computer and
telecommunication
rooms, which are critical to national security or public safety.
In order to reduce emissions of FC 5-1-14 into the atmosphere,
the Agency is proposing to require that FC 5-1-14 not be used
in system discharge tests or for training. In addition, the
Agency is proposing to require that FC 5-1-14 be recovered before
servicing and recycled for later use.
In most streaming applications, the Agency believes that
alternatives to FC 5-1-14 exist. These include the halocarbon
replacements identified above as well as alternative agents
such as water, CO2, foam, and dry chemicals. Users should attempt
to use these other agents before deciding on a FC 5-1-14 system.
(e) [CFC-Blend]
[CFC-Blend] is acceptable as a substitute to Halon 1211 for
use in military streaming applications. While [CFC-Blend] contains
CFCs, its overall ODP is 0.95, which is less than one-fourth
that of Halon 1211. [CFC-Blend] is the most effective of all
other halon substitutes except for HBFC-22B1 and HCFC-123, and
does not pose the exposure risk of HBFC-22B1 in certain scenarios.
[CFC-Blend] is generally considered non-toxic and could serve
as a transitional substitute in many streaming applications
until it is phased out on December 31, 1995.
(f) Dry Chemical
Dry chemical, for the reasons described in the section on
consumer streaming applications, is approved for use as a military
streaming agent.
(g) Carbon Dioxide
Carbon Dioxide, for the reasons described and with the
limitations
suggested in the section on streaming applications, is approved
for use as a military streaming agent.
(h) Water
Water, for the reasons described and with the limitations
suggested in the section on streaming applications, is approved
for use as a military streaming agent.
(i) Foam
Foams, for the reasons described and with the limitations
suggested in the section on streaming applications, is approved
for use as a military streaming agent.
(4) Total Flooding Agents: Occupied Areas
In analyzing the acceptability of substitutes for occupied
total flooding applications, the Agency considered cardiotoxicity
one of the primary decision variables. Current limitations on
use of Halon 1301 in total flooding applications assure that
these uses do not pose a cardiotoxic risk to personnel, if flooding
does not exceed the design concentration. Halon 1301 has a
cardiotoxic
NOAEL of 7.5 percent, and a LOAEL of 10.0 per cent; its required
extinguishing concentration for total flooding is only 2.6 percent,
according to testing results. OSHA promulgated a safety and
health standard governing fire protection systems used at all
workplaces (29 CFR 1910 Subpart L) which is designed to limit
employee exposures to toxic levels of gaseous agents used in
fixed total flood systems. In addition to alerting employees
of impending system discharge by suitable alarms (Section
1910.160),
the standard requires that employees be provided sufficient
time to leave before system discharge if the discharge is designed
to exceed 10 percent (Section 1910.162). For Halon 1301, the
standard prohibits the use of halon concentration greater than
7 percent (the cardiotoxic NOAEL) where egress cannot be
accomplished
in less than 1 minute and prohibits the use of concentrations
greater than 10.0 percent (the cardiotoxic LOAEL) where egress
requires more than 30 seconds. In addition, if there is a
possibility
that someone must enter a room while an agent is likely to exceed
the NOAEL level, Self Contained Breathing Apparatuses (SCBA)
must be worn.
Since most of the proposed substitutes for use in normally
occupied areas pose a risk of cardiotoxic exposure, EPA has
concluded that their use must be governed by conditions similar
to those for Halon 1301. While the OSHA regulation section 1910.160
generally applies to all fire protection systems, section 1910.162
addresses specific allowable concentrations only for halon.
While it is not the intent of EPA to preempt OSHA regulation
in this area, the Agency is seeking to ensure public safety
until OSHA develops appropriate regulations for the new substitute
gaseous agents. Therefore, while all agents used in normally
occupied areas must meet OSHA regulations under section 1910.160,
the Agency is setting conditions for use in normally occupied
areas similar to those found in the OSHA regulation section
1910.162.
For example, in this action, EPA has proposed conditions
on the acceptability of certain halon substitutes when used
as total flooding agents in normally occupied areas. EPA has
imposed these conditions because of the risk of cardiotoxic
levels of exposure to personnel in areas where substitute agents
may be discharged in the event of fire. Existing OSHA standard
1910.160 applies certain general controls to the use of fixed
extinguishing systems in occupied workplaces, whether gaseous,
dry chemical, water sprinklers, etc., and EPA has not reproduced
those. These include, for example, the requirements for discharge
and pre-discharge alarms, and availability of Self Contained
Breathing Apparatus (SCBA) for emergency entry into an area
where agent has been discharged.{5}
³{5} 29 CFR 1910.160(b) includes general provisions to
³ensure the safety of all fixed extinguishing systems.
³Paragraph (c) stipulates requirements for systems with
³"potential health and safety hazards to employees" such
³as might be posed by gaseous agents.
³ (b)(3) ``The employer shall provide a distinctive
alarm
³or signaling system * * * capable of being perceived
³above ambient noise or light levels * * * to indicate
³when the extinguishing systems are discharging.
Discharge
³alarms are not required on systems where discharge is
³immediately recognizable.''
³ (b)(4) ``The employer shall provide effective
safeguards
³to warn employees against entry into discharge areas
³where the atmosphere remains hazardous to employee
safety
³or health.''
³ (b)(5) ``The employer shall post hazard warning or
³caution signs at the entrance to, and inside of, areas
³protected by fixed extinguishing systems which use
agents
³in concentrations known to be hazardous to employee
safety
³and health.''
³ (b)(6) ``The employer shall assure that fixed systems
³are inspected annually * * * to assure that the system
³is maintained in good operating condition.''
³ (b)(10) ``The employer shall train employees
designated
³to inspect, maintain, operate, or repair fixed
extinguishing
³systems. * * *''
³ (b)(17) ``The employer shall provide and assure the
³use of personal protective equipment needed for
immediate
³rescue of employees trapped in hazardous atmospheres
³created by an agent discharge.''
³ (c)(3) ``On all total flooding systems the employer
³shall provide a pre-discharge employee alarm * * *
which
³will give employees time to safely exit from the
discharge
³area prior to system discharge.''
While section 1910.162 can apply generally to gaseous agents,
it includes cardiotoxic levels specific to Halon 1301. Section
1910.162 paragraphs (b)(5) and (b)(6) provide alternative workplace
requirements based on specific design concentrations of Halon
1301. That is, if the design concentration is 7 percent, employees
must be able to egress in one minute, but if the design
concentration
is 10 percent, employees must be able to egress in 30 seconds.
These design concentrations are not identified as the cardiotoxic
NOAEL or LOAEL, so one cannot generalize a rule for use with
alternative agents which have different LOAEL and NOAEL values.
For this reason, EPA is concerned that halon substitute agents
could be used in the absence of enforceable compound-specific
cardiotoxic exposure levels. On the other hand, requiring other
gaseous agents to meet the 7 percent or 10 percent requirements
specified in 1910.162 will preclude their use because the design
concentrations of the alternative agents vary greatly, as does
their cardiotoxic values. Should OSHA create compound-specific
cardiotoxicity values to be applied to the use of halon substitutes
as gaseous total flooding agents in occupied spaces, these
conditions
would no longer be necessary and EPA would rescind them.
However, EPA is also aware that existing OSHA regulations
may provide adequate coverage against exposure to toxic levels
of gaseous agents and their decomposition products. Section
1910.162 (b)(3) states, "(t)he employer shall assure that employees
are not exposed to toxic levels of gaseous agent or its
decomposition
products," and paragraph (b)(4) states, "(t)he employer shall
provide a distinctive pre-discharge employee alarm * * * when
agent design concentrations exceed the maximum safe level for
employee exposure." EPA invites comment on the adequacy of 1910.162
(b)(3) to provide workplace protection for agents that differ
from Halon 1301.
In those relatively rare instances where explosion suppression
or fireball suppression of Class B fires is immediately necessary
to protect life, discharge of any suitable agent without an
alarm may be necessary. The Agency solicits descriptive comments
on such situations and on appropriate use restrictions of agents.
In many occupied areas, total flooding halons can be replaced
by improved detection equipment and manually operated extinguishing
systems. Improved detection systems, if they detect fires in
their early stages, can alert occupants to the existence of
a fire so they may extinguish it with hand-held extinguishers.
In those cases in which a total flooding system is deemed
necessary,
improved detection systems and the use of cross-zoning can also
reduce false alarms that result in the unnecessary discharge
of total flooding systems.
The following substitutes are approved by the Agency for
use as total flooding agents in occupied areas:
(a) HBFC-22B1
HBFC-22B1 is acceptable as a 1301 substitute only in occupied
areas from which personnel can be safely evacuated and egress
can occur before concentration of HBFC-22B1 exceeds its cardiotoxic
LOAEL. The required extinguishing concentration for HBFC-22B1
is estimated at 44,000 ppm (or 4.4 percent) and its design
concentration
is 5.4%. The LOAEL for cardiotoxicity is 1 percent while its
NOAEL is 0.3%. EPA proposes that, for occupied areas from which
personnel cannot be evacuated in one minute, use is permitted
only up to concentrations not exceeding the NOAEL for
cardiotoxicity.
For occupied areas from which personnel can be evacuated or
egress can occur in 30 to 60 seconds, use is permitted up to
a concentration not exceeding the LOAEL. All personnel must
be evacuated before concentration of HBFC-22B1 exceeds 1 percent.
This compound is unlikely to be feasible as a total flooding
agent because its design concentration exceeds its cardiotoxic
level.
While HBFC-22B1 has an ODP of 0.74 and will be phased out
on January 1, 1996, the Agency believes that the substance can
serve a useful role in helping users transition away from Halon
1301, which has an ODP estimated at 16. HBFC-22B1 is available
immediately and can replace 1301 at a ratio of 1.1 by weight
and a ratio of 1.3 by storage volume. Thus, current 1301 total
flooding systems can be converted to HBFC-22B1 with only minor
increases in storage volume (or losses in efficacy). Other total
flooding agents, though having a lower ODP, would require much
larger additions of agent weight and storage volume.
This agent was submitted to the Agency as a Premanufacture
Notice (PMN) and is presently subject to requirements contained
in a Toxic Substance Control Act (TSCA) section 5(e) Consent
Order and associated Significant New Use Rule (40 CFR 721.1296).
(b) HCFC-22
HCFC-22 is acceptable as a total flooding agent in occupied
areas from which personnel can be safely evacuated and egress
can occur before concentration of HCFC-22 exceeds its cardiotoxic
LOAEL.
HCFC-22 has an acute cardiotoxicity with a LOAEL of 5 percent;
however its extinguishment concentration of 11.6% and its design
concentration of 13.9 percent makes this compound unlikely to
be used as a single agent because it exceeds its cardiotoxic
level. EPA proposes that, for occupied areas from which personnel
cannot be evacuated in one minute, use is permitted only up
to concentrations not exceeding the NOAEL for cardiotoxicity.
For occupied areas from which personnel can be evacuated or
egress can occur in 30 to 60 seconds, use is permitted up to
a concentration not exceeding the LOAEL. All personnel must
be evacuated before the concentration of HCFC-22 exceeds 5 percent.
This compound is unlikely to be feasible as a total flooding
agent because its design concentration exceeds its cardiotoxic
effect level.
The ODP for HCFC-22 is 0.055 and the 100 year GWP is 1500,
both of which are higher than other candidate HCFCs. It also
requires the highest extinguishing concentration of the candidate
HCFCs and is somewhat inferior in terms of weight and storage
volume equivalents.
(c) HCFC-124
HCFC-124 is acceptable as a total flooding agent in occupied
areas from which personnel can be safely evacuated and egress
can occur before concentration of HCFC-124 exceeds its cardiotoxic
LOAEL. HCFC-124 demonstrates average performance as a fire
extinguishant,
has relatively low ODP of .022, and, compared to other candidate
1301 substitutes for which GWP has been estimated, has a relatively
low 100 year GWP value of 430. Testing indicates that the substance
has a cardiotoxicity LOAEL of 2.5 percent with no effect NOAEL
apparent at 1.0 percent. The extinguishing concentration of
HCFC-124 is 8.2 percent and its design concentration is 9.8%.
EPA proposes that, for occupied areas from which personnel
cannot be evacuated in one minute, use is permitted only up
to concentrations not exceeding the NOAEL for cardiotoxicity.
For occupied areas from which personnel can be evacuated or
egress can occur in 30 to 60 seconds, use is permitted up to
a concentration not exceeding the LOAEL. All personnel must
be evacuated before concentration of HCFC-124 exceeds 2.5 percent.
This compound is unlikely to be feasible as a total flooding
agent because its design concentration exceeds its cardiotoxic
level.
(d) [HCFC BLEND] A
[HCFC BLEND] A is acceptable alternative to Halon 1301 only
in occupied areas from which personnel can be safely evacuated
and egress can occur before concentration of [HCFC Blend] A
exceeds its cardiotoxic LOAEL. Based on full-scale testing,
the extinguishing concentration of this blend has been determined
to be approximately 8.6 percent and therefore the design
concentration
is approximately 10.3 percent. Preliminary reports of test data
indicate that the cardiotoxicity NOAEL of the blend is at least
10.0 percent, and therefore the LOAEL is likely to be greater
than 10.0 percent. The Agency is awaiting the final report
validating
this data, but believes the preliminary report represents a
conservative assessment of the cardiotoxicity of the blend.
The blend has an ODP higher than other proposed HCFC substitutes,
but appears somewhat more effective from a weight and storage
volume equivalency basis.
EPA proposes that, for occupied areas from which personnel
cannot be evacuated in one minute, use is permitted only up
to concentrations not exceeding the NOAEL for cardiotoxicity.
For occupied areas from which personnel can be evacuated or
egress can occur between 30 and 60 seconds, use is permitted
up to a concentration not exceeding the LOAEL. All personnel
must be evacuated before concentration of [HCFC Blend] A exceeds
10.3 percent. This compound is a feasible candidate for use
in a normally occupied area.
(e) HFC-23
HFC-23 is an acceptable alternative to Halon 1301 in occupied
areas only for high value applications such as those involving
the protection of public safety or national security;
telecommunication
or computer equipment related to public safety or national
security;
or life support functions; and from which personnel can be safely
evacuated and egress can occur before concentration of HFC-23
exceeds its cardiotoxic LOAEL.
HFC-23 is attractive for use as a total flooding agent in
occupied areas because the draft report on cardiotoxicity indicates
that its cardiotoxic NOAEL is over 30% without added oxygen
and over 50% with added oxygen, compared to a design concentration
of 14.9%. The Agency is awaiting the final report to validate
these values, but believes that the draft report adequately
represents the likely cardiotoxicity of the agent. Still, in
order to ensure safe evacuation, EPA proposes that, for occupied
areas from which personnel cannot be evacuated in one minute,
use is permitted only up to concentrations not exceeding the
NOAEL for cardiotoxicity. For occupied areas from which personnel
can be evacuated or egress can occur between 30 and 60 seconds,
use is permitted up to a concentration not exceeding the LOAEL.
All personnel must be evacuated before concentration of HFC-
23 exceeds 30 percent.
While this agent has an ODP of zero, it has a relatively
high GWP and an atmospheric lifetime of some 300 to 400 years.
Until the Agency completes its analysis of its likely effects
on global warming, it is listed as acceptable for particular
critical uses only.
The weight equivalent of HFC-23 is 2.0 while its storage
volume is 4.6.
(f) HFC-134a
The Agency has determined that HFC-134a is an acceptable
alternative to Halon 1301 only in occupied areas from which
occupants can be safely evacuated and egress can occur before
concentration of HFC-134a exceeds its cardiotoxic LOAEL. HFC-
134a has a cardiotoxic NOAEL of 4 percent, a LOAEL of 8 percent,
and an extinguishing concentration of 10.5 percent. EPA proposes
that, for occupied areas from which personnel cannot be evacuated
in one minute, use is permitted only up to concentrations not
exceeding the NOAEL for cardiotoxicity. For occupied areas from
which personnel can be evacuated or egress can occur between
30 and 60 seconds, use is permitted up to a concentration not
exceeding the LOAEL. All personnel must be evacuated before
concentration of HFC-134a exceeds 8 percent. This compound is
unlikely to be feasible as a total flooding agent in occupied
areas because its design concentration exceeds its cardiotoxic
level.
Like the other HFCs, HFC-134a has an ODP of zero. It also
has among the lowest GWP of the candidate 1301 replacements
for which GWP has been estimated.
Extinguishment tests conducted with HFC-134a indicate that
the substance is considerably less effective than 1301. Systems
that use HFC-134a will therefore require approximately 2.5 times
more extinguishant by weight and 3.1 times more storage volume
than 1301 systems. Such considerations preclude HFC-134a from
being used in most existing equipment.
(g) HFC-227ea
HFC-227ea is acceptable for use as a total flooding agent
in occupied areas from which occupants can be safely evacuated
and egress can occur before concentration of HFC-227ea exceeds
its cardiotoxic LOAEL. The preliminary report on the cardiotoxicity
of HFC-227ea indicates a cardiotoxic NOAEL of 8.1% and a LOAEL
of at least 10.5%. The Agency is awaiting the final report to
validate the data, but believes that the draft report represents
a conservative estimate of its likely cardiotoxic value. The
design concentration for this agent is 7.1%, which provides
a sufficient margin of safety for use in an occupied area. EPA
proposes that, for occupied areas from which personnel cannot
be evacuated in one minute, use is permitted only up to
concentrations
not exceeding the NOAEL for cardiotoxicity. For occupied areas
from which personnel can be evacuated or egress can occur between
30 and 60 seconds, use is permitted up to a concentration not
exceeding the LOAEL. All personnel must be evacuated before
concentration of HFC-227ea exceeds 10.5 percent.
HFC-227ea does not deplete stratospheric ozone. In addition,
HFC-227ea is the most effective of the proposed HFC substitutes
for Halon 1301. Testing indicates an extinguishing concentration
of 5.9 percent. HFC-227ea can replace Halon 1301 at a ratio
of 2.4 by weight and 2.55 by volume which may limit its
applicability
in existing total flood systems.
(h) FC 3-1-10
FC 3-1-10 is acceptable as a total flooding agent in occupied
areas only for those limited applications involving the protection
of public safety or national security; telecommunication or
computer equipment related to public safety or national security;
or life support functions. Experimental results indicate that
FC 3-1-10 can extinguish fires in a total flood application
at concentrations of 5.5 percent. The cardiotoxicity NOAEL of
40% for this agent is well above its extinguishment concentration
and therefore is safe for use in occupied areas. In order to
ensure safe evacuation, EPA proposes that, for occupied areas
from which personnel cannot be evacuated in one minute, use
is permitted only up to concentrations not exceeding the NOAEL
for cardiotoxicity. For occupied areas from which personnel
can be evacuated or egress can occur between 30 and 60 seconds,
use is permitted up to a concentration not exceeding the LOAEL.
All personnel must be evacuated before concentration of FC 3-
1-10 exceeds 40 percent.
Due to the long atmospheric lifetime of FC 3-1-10, the Agency
urges that the chemical be used only in those limited instances
described above in which a viable alternative is not available.
In order to reduce emissions of FC 3-1-10 into the atmosphere,
the Agency is also proposing to require that FC 3-1-10 not be
used in system discharge tests. In addition, the Agency is
proposing
to require FC 3-1-10 to be recovered from total flooding systems
before servicing and recycled for later use. Fire detection
should also be cross-zoned to avoid unnecessary discharge and
maintained to high reliability. In most total flooding
applications,
the Agency believes that alternatives to FC 3-1-10 exist. These
include the halocarbon replacements identified above. As a result,
EPA is proposing to restrict its use only to those applications
described above.
(i) [Inert Gas Blend]
[Inert Gas Blend] is approved as a total flooding agent in
occupied areas. This agent is a non-reactive, non-halocarbon
substance, and thus not carcinogenic, mutagenic, or teratogenic;
the toxicity and cardiotoxicity tests normally applied to halon
substitutes do not apply here. Rather, this agent is a potential
asphyxiant as it is designed to decrease the oxygen to a level
at which combustion cannot be supported. This blend is designed
to increase breathing rates, thus making the oxygen deficient
atmosphere breathable for short periods of time. Data submitted
by the manufacturer was peer-reviewed by pulmonary, cardiac,
and stroke specialists. All have agreed that the blend does
not pose significant risk to the working population and may
even pose less risk than does exposure to halocarbon agents.
However, to ensure safety, the Agency proposes to approve this
blend under the conditions that the design concentration results
in at least 14% oxygen and 4% carbon dioxide. In addition, if
the oxygen concentration of the atmosphere falls below 12%,
personnel must be evacuated and egress must occur within 30
seconds. Since a fire can be expected to consume oxygen and
form decomposition products, personnel should treat any fire
situation as an emergency and promptly exit the space.
Concerns have been raised about the decibel level of this
system upon discharge. The manufacturer has submitted a report
indicating the decibel level to be 117 decibels for 3 seconds
followed by a decay in noise level over 5 minutes, compared
to 130 decibels for a typical halon system. The Time Weighted
Average (TWA) of this system is 57 decibels. These levels are
in compliance with the OSHA workplace maximum allowed peak of
140 decibels and a maximum Time Weighted Average (TWA) of 90
decibels.
(j) Carbon Dioxide
Carbon Dioxide is approved as a total flooding agent in occupied
areas.
The Agency is not proposing to regulate alternative fire
protection agents that are currently in widespread use. However,
questions have been raised about the Agency's position on the
use of carbon dioxide as a total flooding agent in occupied
areas.
Exposure to carbon dioxide poses an imminent threat to life.
However, because it displaces oxygen, it is an effective fire
protection agent. As a result, both OSHA and the National Fire
Protection Association (NFPA) address CO2 systems for occupied
areas. OSHA 1910.162(b)5 requires a pre-discharge alarm for
systems with a design concentration of 4 percent or greater.
NFPA has written a standard (NFPA 12) that explicitly controls
how such CO2 systems may be safely used in occupied areas. To
protect life, it requires a system design such that no personnel
may be present upon system discharge. The EPA recognizes both
the OSHA regulation and the NFPA standard as industry practice
and therefore references them in this rule.
In the review of proposed substitutes, the Agency looks at
a variety of health and environmental factors, including whether
the agent contributes to global warming. While carbon dioxide
is a greenhouse gas, it is a byproduct of many industrial
processes.
We realize that carbon dioxide is recaptured and reformulated
as a fire fighting agent and thus does not require new production.
Therefore, the Agency has determined that its status as a
greenhouse
gas is irrelevant to our review.
(k) Water
Water sprinkler systems are also approved for use as a 1301
substitute in occupied areas. Such systems should not be used
on Class C electrical fires or in instances in which secondary
damage is considered unacceptable.
(5) Total Flooding: Unoccupied Areas.
In unoccupied areas, human exposure to potentially toxic
substitutes or decomposition products are of less concern than
in occupied areas. Key criteria in the decision process therefore
become agent efficacy and environmental considerations. At the
same time, the Agency must ensure that personnel are not exposed
to toxic concentrations of fire protection agents or their
decomposition
products when the substances are vented or leak out from the
extinguishment area. Precautions must also be taken to prevent
exposures to personnel entering a normally unoccupied area after
a discharge. In addition, if there is a possibility that someone
must enter a room while an agent is likely to exceed the NOAEL
level, Self Contained Breathing Apparatuses (SCBA) must be worn.
Based on these considerations, the Agency has determined
that the following agents are acceptable substitutes to Halon
1301 in unoccupied areas:
(a) HBFC-22B1
In unoccupied areas, toxicity concerns are minimal. Thus,
for the reasons outlined in the section on occupied areas, HBFC-
22B1 is acceptable for use in unoccupied areas. Because of its
low storage volume equivalency ratio, HBFC-22B1 can be used
in existing total flooding systems to help speed the transition
away from Halon 1301.
This agent was submitted to the Agency as a Premanufacture
Notice (PMN) and is presently subject to requirements contained
in a Toxic Substance Control Act (TSCA) section 5(e) Consent
Order and associated Significant New Use Rule (40 CFR 721.1296).
(b) HCFC-22
HCFC-22 is acceptable as a total flooding agent in unoccupied
areas. However, due to the low efficacy of the agent and its
high ODP and GWP relative to other proposed substitutes, the
Agency believes this is a less attractive replacement than other
potential candidates.
(c) HCFC-124
HCFC-124 is acceptable as a total flooding agent in unoccupied
areas. This agent is relatively effective for a physical action
agent and has lower ODP and GWP values than other substitutes.
(d) [HCFC BLEND] A
[HCFC BLEND] A is acceptable as a substitute for Halon 1301
in unoccupied total flooding applications. [HCFC BLEND] A is
not anticipated to result in toxic exposures when used in
unoccupied
areas. The blend has an ODP higher than other HCFC substitutes,
but appears more effective on a weight and storage volume
equivalency
basis.
(e) HFC-23
HFC-23 is an acceptable alternative to Halon 1301 in unoccupied
areas only for high value applications such as those involving
the protection of public safety or national security;
telecommunication
or computer equipment related to public safety or national
security;
or life support functions.
HFC-23 has a design concentration of 14.9%. While this agent
has an ODP of 0, it has a relatively high GWP and an atmospheric
lifetime of some 300 to 400 years. Until the Agency completes
its analysis of its likely effects on global warming, it is
listed as acceptable for particular critical uses only.
The weight equivalent of HFC-23 is 2.0 while its storage
volume is 4.6.
(f) HFC-125
HFC-125 is acceptable for use as a Halon 1301 substitute
in unoccupied areas.
Specific cardiotoxicity information has not been received
by the Agency regarding HFC-125. However, in unoccupied areas,
it is not expected that human health would be threatened by
use of HFC-125. In addition, HFC-125 does not deplete stratospheric
ozone.
Despite its zero ODP, HFC-125 has one of the highest calculated
GWP (100 year GWP of 2500) of any HFC or HCFC currently planned
for production as a halon or CFC substitute.
(g) HFC-134a
In unoccupied areas, toxicity concerns are minimal. Thus,
for the reasons outlined in the section on occupied areas, HFC-
134a is acceptable for use in unoccupied areas.
(h) HFC-227ea
In unoccupied areas, it is not expected that human health
would be threatened by use of HFC-227ea. In addition, HFC-227ea
does not deplete stratospheric ozone. HFC-227ea is therefore
acceptable for use in unoccupied areas.
HFC-227ea is the most effective of the proposed HFC substitutes
for Halon 1301. Testing indicates an extinguishing concentration
of 5.9 percent. HFC-227ea can replace Halon 1301 at a ratio
of 2.4 by weight and 2.55 by volume which may limit its
applicability
in existing total flood systems.
(i) FC 3-1-10
FC 3-1-10 is acceptable as a total flood agent in unoccupied
areas only for those limited applications involving the protection
of public safety or national security; telecommunication or
computer equipment related to public safety or national security;
Armored Personnel Vehicles and related vehicles; and for explosion
inertion/suppression with flammable liquids and gases. Due to
the long atmospheric lifetime of FC 3-1-10 and its global warming
potential, the Agency urges fire protection specialists to consider
alternatives to FC 3-1-10 in unoccupied areas. Such alternatives
would include other halocarbon systems, water sprinkler systems,
or manually operated extinguishers in conjunction with improved
and well-maintained fire detection and warning devices and the
use of cross-zoning to avoid unnecessary discharge.
In those limited cases described above in which FC 3-1-10
is the optimal fire protection choice, care must be taken to
limit releases of FC 3-1-10. To this end, the Agency is also
proposing to require (1) that systems not be tested using FC
3-1-10, and (2) that during servicing and maintenance all FC
3-1-10 be recovered from the total flood system and recycled
for later use.
(j) [Inert Gas Blend]
[Inert Gas Blend] is approved for use as a 1301 substitute
in unoccupied areas. This agent would not be considered a "drop
in" replacement in a total flooding system due to its high
extinguishing
concentration.
(k) Carbon Dioxide
Carbon Dioxide is approved for use as a Halon 1301 substitute
in unoccupied areas. CO2 is currently widely used as a total
flooding agent. In the past, CO2 systems were used in many of
the applications now served by halons. As a total flooding agent,
CO2 has an extinguishing concentration ten times that of Halon
1301 and requires 1.4 times the storage volume required by 1301
systems; it is also an asphyxiant in the concentrations required
for total flooding. Thus, it is most suited for use in unoccupied
areas.
In the review of proposed substitutes, the Agency looks at
a variety of health and environmental factors, including whether
the agent could potentially contribute to global warming. While
carbon dioxide is a greenhouse gas, it is a byproduct of many
industrial processes. We realize that carbon dioxide is recaptured
and reformulated as a fire fighting agent and thus does not
require new production. Therefore, the Agency has determined
that its status as a potential global warmer is irrelevant to
our review.
(l) Water
Water sprinkler systems are also approved for use as a 1301
substitute in unoccupied areas. EPA proposes that such systems
should not be used on Class C electrical fires or in instances
in which secondary damage is considered unacceptable.
(6) Explosion Inertion
Explosion inertion agents are not currently regulated by
OSHA or any other regulatory body. However, design concentrations
for systems protecting from explosion of various gases or flammable
liquids may expose personnel to cardiotoxic levels of inertion
agents. While the Agency is not currently proposing to place
conditions for the use of alternatives in occupied areas, it
may do so in the final rule subject to public comment as well
as further analysis with agencies such as OSHA and OMB. EPA
could place a condition for use of alternative agents in occupied
areas which would identify the cardiotoxic LOAEL and would prohibit
design concentrations that exceed that level.
EPA requests comment on the use of conditions where no
regulatory
gap, per se, exists, but where the use of an alternative poses
risk to the public. By imposing such conditions, EPA would be
establishing a new regulatory framework where one did not
previously
exist.
(a) HBFC-22B1
HBFC-22B1 is acceptable for use as a Halon 1301 replacement
in explosion inertion applications in unoccupied areas. HBFC-
22B1 is an effective halon substitute for explosion inertion,
requiring an inertion concentration of 8 percent. Because this
value exceeds the recommended exposure concentrations for short-
term exposures to HBFC-22B1, and because it cannot be assumed
that occupants would have an opportunity to safely evacuate
in the event of an explosion, the Agency considers this substitute
safe only for use in unoccupied areas.
HBFC-22B1 appears to be a suitable candidate for replacing
Halon 1301 in existing explosion inertion applications. The
storage volume equivalent for HBFC-22B1 is 1.6, lower than any
other halon substitute. Thus, despite the relatively high ODP
of HBFC-22B1 compared to other substitute agents, HBFC-22B1
can accelerate the transition away from Halon 1301.
This agent was submitted to the Agency as a Premanufacture
Notice (PMN) and is presently subject to requirements contained
in a Toxic Substance Control Act (TSCA) section 5(e) Consent
Order and associated Significant New Use Rule (40 CFR 721.1296).
(b) HFC-23
HFC-23 is acceptable as an explosion inertion agent only
for high value applications such as those involving the protection
of public safety or national security; telecommunication or
computer equipment related to public safety or national security;
or life support functions. While this agent has an ODP of 0,
it has a relatively high Global Warming Potential and an
atmospheric
lifetime of some 300 to 400 years. The Agency is currently
restricting
its use until further analysis on this issue is complete. Until
then, the Agency urges explosion protection specialists to consider
alternatives to HFC-23 in unoccupied areas.
HFC-23 is attractive for use as an explosion inertion agent
in occupied areas because the draft report on cardiotoxicity
indicates that its cardiotoxic NOAEL is over 30% without added
oxygen and over 50% with added oxygen. The Agency is awaiting
the final report to validate these values, but believes that
the draft report adequately represents the likely cardiotoxicity
of the agent.
Explosion inertion requires the rapid discharge of agent,
often without providing time for evacuation of personnel. Possible
exposure of occupants to toxic level of the compound must be
carefully controlled and balanced against the risk of explosion.
While the Agency is not currently imposing conditions on the
use of this agent in occupied areas, employers are advised to
evaluate this agent in light of the fact that the required design
concentrations vary for different atmospheres. The design
concentration
should not exceed the cardiotoxic LOAEL for HFC-23 of 50% in
an occupied area. The Agency also recommends that employers
provide an alarm to alert personnel of system discharge, and
to evacuate all personnel as soon as possible after system
discharge.
(c) HFC-125
HFC-125 is acceptable for use as an explosion inertion agent
only in unoccupied areas. At this time sufficient information
has not been received by the Agency to allow use of HFC-125
as an explosion protection agent in occupied areas. In applications
in which exposures to personnel can be avoided, however, HFC-
125 is acceptable.
(d) HFC-227ea
HFC-227ea is acceptable for use as an explosion inertion
agent in occupied and unoccupied areas. The preliminary report
on the cardiotoxicity of HFC-227ea indicates a cardiotoxic LOAEL
of at least 10.5%. The Agency is awaiting the final report to
validate the data, but believes that the draft report represents
a conservative estimate of its likely cardiotoxic value. Because
required design concentrations vary for different atmospheres,
explosion protection engineers must ensure that this agent is
not used in an occupied area when a concentration greater than
the estimated cardiotoxic LOAEL of 10.5% is required.
Explosion inertion requires the rapid discharge of agent,
often without providing time for evacuation of personnel. Possible
exposure of occupants to toxic level of the compound must be
carefully controlled and balanced against the risk of explosion.
While the Agency is not currently imposing conditions on the
use of this agent in occupied areas, employers are advised to
evaluate this agent in light of the fact that the required design
concentrations vary for different atmospheres. The design
concentration
should not exceed the cardiotoxic LOAEL for HFC-227ea of 10.5%
in an occupied area. The Agency also recommends use of an alarm
to alert personnel of system discharge, and to evacuate all
personnel as soon as possible after system discharge.
This agent is also acceptable for unoccupied areas.
(e) FC 3-1-10
FC 3-1-10 is acceptable as an explosion inertion agent only
for those limited applications involving the protection of public
safety or national security; telecommunication or computer
equipment
related to public safety or national security; or life support
functions. Due to the long atmospheric lifetime of FC 3-1-10
and its potentially large global warming potential, the Agency
urges explosion protection specialists to consider alternatives
to FC 3-1-10 in unoccupied areas. Explosion inertion studies
conducted with methane and propane indicate an inerting
concentration
of 7.8 percent and 9.5 percent respectively. Additional performance
data is being collected for use with other flammable gases.
No data has been received by the Agency for explosion suppression
applications.
The cardiotoxicity NOAEL of this agent is 40 percent and
its LOAEL is greater than 40%, and thus is well suited for use
in occupied areas. Explosion inertion requires the rapid discharge
of agent, often without providing time for evacuation of personnel.
Possible exposure of occupants to toxic level of the compound
must be carefully controlled and balanced against the risk of
explosion. While the Agency is not currently imposing conditions
on the use of this agent in occupied areas, employers are advised
to evaluate this agent in light of the fact that the required
design concentrations vary for different atmospheres. The design
concentration should probably not exceed the cardiotoxic NOAEL
for FC 3-1-10 of 40% in an occupied area. The Agency also
recommends
use of an alarm to alert personnel of system discharge, and
to evacuate all personnel as soon as possible after system
discharge.
In those limited cases described above in which FC 3-1-10
is determined to be the optimal explosion inertion choice, care
must be taken to limit releases of FC 3-1-10. To this end, the
Agency is also proposing to require (1) that systems not be
tested using FC 3-1-10, and (2) that during servicing and
maintenance
all FC 3-1-10 be recovered from the inertion system and recycled
for later use.
(f) [Inert Gas Blend]
[Inert Gas Blend] is approved for use as a 1301 substitute
for explosion inertion in occupied and unoccupied areas. This
agent is a non-reactive, non-halocarbon substance, and thus
not carcinogenic, mutagenic, or teratogenic; the toxicity and
cardiotoxicity tests normally applied to halon substitutes do
not apply here. Rather, this agent is a potential asphyxiant
as it is designed to decrease the oxygen to a level at which
combustion cannot be supported. This blend is designed to increase
breathing rates, thus making the oxygen deficient atmosphere
breathable for short periods of time. Data submitted by the
manufacturer was peer-reviewed by pulmonary, cardiac, and stroke
specialists. All have agreed that the blend does not pose
significant
risk to the working population and may even pose less risk than
does exposure to halocarbon agents.
The inerting concentration for this blend is 44 percent for
methane/air mixtures and 50 percent for propane/air mixtures.
A 50 percent concentration would result in an atmosphere of
only 10.5 percent oxygen content, which is the lower limit at
which studies show this agent safe for use with healthy, young
people. Explosion inertion requires the rapid discharge of agent,
often without providing time for evacuation of personnel. Possible
exposure of occupants to a hypoxic, or oxygen reduced, atmosphere
must be carefully controlled and balanced against the risk of
explosion. The Agency thereby requires an alarm to alert personnel
of system discharge, and all personnel must evacuate as soon
as possible after system discharge.
Concerns have been raised about the decibel level of this
system upon discharge. The manufacturer has submitted a report
indicating the decibel level to be 117 decibels for 3 seconds
followed by a decay in noise level over 5 minutes, compared
to 130 decibels for a typical halon system. The Time Weighted
Average (TWA) of this system is 57 decibels. These levels are
in compliance with the OSHA workplace maximum allowed peak of
140 decibels and a maximum Time Weighted Average (TWA) of 90
decibels.
b. Proposed Unacceptable Substitutes. (1) Streaming Agents:
Commercial/Industrial Use. (a) CFC-11. CFC-11 is proposed
unacceptable
in its proposed application as a Halon 2402 substitute or for
large outdoor uses. This agent has been proposed as a substitute
for Halon 2402, as well as for use in a new niche for large
outdoor fires, such as for dropping from helicopters. Halon
2402 is not used in the U.S. and thus does not require a substitute
agent. As a new use in the large outdoor sector, such as dropping
from helicopters, other non-ozone depleting methods are already
in use and thus do not warrant introduction of this substitute.
H. Sterilants
1. Overview
CFC-12 is widely used in combination with ethylene oxide
(EtO) to sterilize medical equipment and devices. The most
prevalent
combination consists of 12 percent EtO mixed with 88 percent
CFC-12; the mixture is therefore referred to as "12/88". EtO
serves as the actual sterilant in this mixture and can be used
alone as a sterilant, but by itself, EtO is highly flammable.
CFC-12 acts as a stabilizing agent to reduce the overall
flammability
of the blend.
Sterilants, including 12/88, are used in a variety of
applications.
These include hospital sterilization, medical equipment
sterilization,
pharmaceutical production, spice fumigation, commercial research
and development, and contract sterilization. Hospitals are by
far the most numerous users of sterilants. Within hospitals,
12/88 is the most popular sterilant. Estimates indicate that
in 1989, EtO/CFC-12 was used for over 95 percent of all
sterilization
in hospitals. Pure EtO systems are also used in hospitals, but
typically as small, tabletop models. Few hospitals have large
pure EtO systems in-house. Other individual users of sterilant
such as contract sterilizers and pharmaceutical producers, while
less numerous than hospitals, typically consume more sterilant
than the average hospital. They are also more likely to use
pure EtO sterilization systems to handle large capacity loads.
Despite the varied end uses of sterilants, the Agency did
not divide its analysis and regulation of the sterilants sector
into distinct end uses. This is because alternatives to 12/88
are consistent across end uses, and the sterilant sector as
a whole represents one of the smallest use sectors for Class
I substances which is being considered in the SNAP program.
On an ODP-weighted basis, US consumption of CFC-12 for
sterilization
represented less than 4 per cent of the total US consumption
of ozone depleting substances in 1990.
Several alternatives to 12/88 are currently in widespread
use, but each is limited in applicability by material properties
of the devices to be sterilized. These currently available
alternatives
are unlikely to serve as widespread substitutes for 12/88. Steam
sterilizers, for example, are used in many applications and
are less expensive to purchase and to operate than 12/88 systems.
However, steam can only be used to sterilize equipment that
can resist high temperatures. Pharmaceutical manufacturers already
use steam to the maximum extent possible, but hospitals may
be able to shift some of their current 12/88 use to steam by
separating heat-resistant devices from heat-sensitive ones.
Other alternatives such as radiation, peracetic acid, and
glutaraldehyde
are also in use, but, like steam, are incompatible with many
of the materials now sterilized with 12/88. In fact 30 to 50
per cent of new products are initially sterilized with gamma
radiation, but it is not possible to re-sterilize hospital surgical
equipment with gamma radiation. Instead, 12/88 must be used.
Other alternatives are currently under development. These
include chlorine dioxide, gaseous ozone, vapor phase hydrogen
peroxide, and ionized gas plasma. Many of these alternatives
are also incompatible with materials currently sterilized with
12/88. Those that may be applicable as partial substitutes for
12/88, such as hydrogen peroxide, are not expected to be
commercially
available in the near term.
For these reasons, alternatives such as steam and other
currently
available technologies should be used wherever applicable, but
are not specifically addressed in this proposal. Additional
information on such alternatives and on specific uses of 12/88
can be found in the supporting documentation retained in the
public docket. The proposed determinations in this section are
based on the risk screen described in the background document
titled "Characterization of Risk from the Use of Substitutes
for Class I Ozone-Depleting Substances: Sterilization."
2. Substitutes for Sterilization. a. Halocarbons
A number of halocarbon substitutes have been suggested as
viable alternatives to CFC-12 in EtO blends for sterilization.
These include HCFC-123, HCFC-124, HFC-125, HCFC-141b, and HFC-
134a and HFC-227ea. At present, however, only HCFC-124 and HFC-
227ea have been proposed as near-term candidates. While HCFC-
124 has been fully evaluated by the Agency in this rule, a final
determination on HFC-227ea will be completed as soon as exposure
data are received. Additional research will be required to
determine
the suitability of the other agents in EtO blends.
Many of the proposed halocarbons offer good potential as
EtO diluents. They demonstrate good flame retardation, low ODPs,
low GWPs, low toxicity, materials compatibility, acceptable
vapor pressures, and good blending properties. Mixtures of
halocarbons
with EtO would most likely be at ratios similar to 12/88, or
with a slightly lower EtO content. HCFC-124 has been tested
with 8.6 percent EtO, for example. Such properties would make
halocarbon blends virtual drop-in replacements for 12/88 in
existing systems. The blends would also be far less damaging
to stratospheric ozone than is 12/88.
b. Carbon Dioxide
Carbon dioxide is already in widespread use as a sterilant
in blends with EtO. The most common blend contains 10 percent
EtO and 90 percent CO2 and is referred to as "10/90". While
10/90 is compatible with most of the materials now sterilized
with 12/88, it must be used at higher operating pressures than
12/88 systems and hence is not a direct drop-in replacement
for 12/88. Use of CO2 blends requires that the sterilizing unit
itself be upgraded to handle higher operating pressures in order
to prevent excessive leakages of EtO from the system. However,
operating costs for CO2 systems are typically lower than those
for 12/88 systems.
CO2 and EtO tend to separate while stored in pressurized
containers. Thus, initial discharges from the canisters during
use may contain excessively high amounts of flammable EtO; final
discharges from nearly empty canisters may contain pure CO2
and may not effectively sterilize equipment. To overcome this
problem, "unit dose" canisters have been developed for use in
conjunction with CO2 sterilizers. For safe operation, these
canisters must be connected and disconnected from the sterilizing
unit before and after every use, thereby increasing the risk
of accidental exposure. Improved training procedures will be
required with such systems.
c. Pure EtO
Pure EtO systems can also be used in place of current 12/88
sterilizers. By itself, EtO is toxic, carcinogenic, and flammable.
Thus, additional precautions must be taken to limit occupational
exposures and conflagration. Present OSHA standards and proper
engineering controls have demonstrated their ability to provide
for safe operation of such systems. Pure EtO systems are currently
used by many contract sterilizers, large hospitals, and other
large users.
Pure EtO cannot be used in existing 12/88 sterilizing equipment
without significant technical changes. Large sterilizers may
have to be relocated or rooms modified in order to reduce damage
from possible explosions. Both large and small systems require
retrofits to provide the capability to properly vent EtO and
to prevent explosions. Such conversions are costly, but may
produce long-term cost savings. Operating costs for pure EtO
systems are lower than those for 12/88 systems.
3. Preliminary Listing Decisions
a. Acceptable. (1) HCFC-124
HCFC-124 is acceptable as a substitute for CFC-12 in EtO
blends.- Initial testing in hospital, industrial, and laboratory
settings indicates that an EtO/HCFC-124 blend can serve as a
virtual drop-in replacement for 12/88, enabling users to transition
away from CFC-12 while still using their existing equipment.
Use of HCFC-124 in sterilizers will allow significant reductions
in skin cancer cases and deaths resulting from ozone depletion.
HCFC-124 has an ODP of only 0.02. Modeling results indicate
that even if HCFC-124 replaces all current use of CFC-12 in
sterilization, resulting skin cancer deaths in the total US
population born before 2030 will total only 600 more than if
a zero ODP substitute were available. In addition, the low GWP
of HCFC-124 ensures that use of the chemical in sterilizers
will have a negligible effect on global warming.
Under Title III of the Clean Air Act Amendments of 1990,
the Agency is required to regulate any of the 189 hazardous
air pollutants (HAPs). Ethylene oxide is a HAP, and the user
is alerted to follow all upcoming regulations concerning the
use of ethylene oxide, whether used alone or in a blend. For
example, it is likely in the future that Title III will require
a system that prevents venting of EtO into the atmosphere,
therefore
users installing new HCFC-124/EtO systems may choose to take
this into consideration.
(2) Carbon Dioxide
Carbon dioxide is acceptable as a substitute for CFC-12 in
EtO blends used for sterilization. Carbon dioxide can effectively
reduce the flammability of EtO and does not deplete stratospheric
ozone. While CO2 is considered a greenhouse gas, atmospheric
modeling indicates that its use in the sterilants sector will
have no measurable impact on global warming. Furthermore, most
CO2 currently used in sterilant mixtures is the recaptured by-
product of other chemical processes, so its manufacture for
use in sterilizers should not increase emissions to the atmosphere.
Carbon dioxide is an asphyxiant in high concentrations, but
engineering controls designed to limit occupational exposures
from the more toxic EtO will also serve to prevent potentially
lethal exposures to CO2.
Blends of CO2 and EtO are commercially available at present,
and proven process cycles already exist. Blends of CO2 and EtO
have been in widespread use for years and dominated the market
before the development of 12/88. Recent flammability tests indicate
that the maximum concentration of EtO in CO2 blends may have
to be lowered from its traditional level of 10 per cent to perhaps
8 or 9 per cent to achieve adequate levels of safety. As mentioned
above, ethylene oxide is a HAP, and the user is alerted to follow
all upcoming regulations concerning the use of ethylene oxide,
whether used alone or in a blend.
Carbon dioxide blends will not serve as direct drop-in
replacements
for 12/88. The higher operating pressures of CO2/EtO blends
will require modifications to existing equipment. The Montreal
Protocol's technology assessment report on sterilants estimated
that less than one-half of the 12/88 sterilizers currently used
in hospitals are certified to operate at the higher pressures
necessary for CO2/EtO blends.
(3) Pure EtO
Pure EtO is acceptable as a substitute for 12/88 in
sterilization.
By itself, EtO is neither an ozone depleting substance nor a
contributor to global warming. However, EtO is toxic, carcinogenic,
and flammable. While these factors must be considered in the
decision to approve EtO as a substitute for 12/88 and must be
considered by users selecting appropriate substitutes for their
current use of 12/88, the Agency considers current applicable
standards and operating procedures (such as OSHA standards for
occupational exposure) sufficient to protect human health and
the environment. Thus, pure EtO systems are acceptable substitutes
for 12/88. Users are advised to adhere to all existing workplace
standards and to train workers in the proper operation of EtO
equipment. Historical experience with pure EtO systems indicates
that they can be used safely when operated in accordance with
such guidelines. Because of the threat posed by vented EtO to
the general population, the Agency also recommends that pure
EtO systems be used in conjunction with emission control
technologies
such as catalytic converters or acid water scrubbers to prevent
exposures of the general population to dangerous levels of EtO.
As mentioned above, ethylene oxide is a HAP, and the user
is alerted to the probability of future regulations concerning
the use of ethylene oxide, whether used alone or in a blend.
Pure EtO should not be considered a drop-in replacement for
12/88. EtO systems operate at atmospheric pressure or below,
allowing some current 12/88 equipment to be retrofit for pure
EtO through the addition of proper ventilation and control
technologies.
However, the costs associated with such changes, especially
with larger equipment, can be prohibitive. Nevertheless, use
of pure EtO can reduce operating costs substantially compared
to those achieved with equivalent 12/88 systems.
b. Unacceptable Substitutes [None]
I. Aerosols
1. Overview
To provide perspective on EPA's decisions in the aerosols
sector, this section presents first an overview of important
related regulations. Subsequent parts of the section describe
the substitutes in the aerosols sector and present EPA's decisions
on the substitutes. The decisions are summarized in Appendix
B at the end of this notice. The proposed decisions presented
in this section are based on the risk screen contained in the
draft background document entitled "Risk Screen on Use of
Substitutes
for Class I Ozone-Depleting Substances: Aerosols."
Following scientific concerns raised in 1974 regarding possible
ozone depletion from CFCs, EPA and the Food and Drug Administration
(FDA) acted on March 17, 1978 (43 FR 11301; 43 FR 11318) to
ban the use of CFCs as aerosol propellants in all but "essential
applications." During the mid-1970s, use as aerosol propellants
constituted over 50 percent of total CFC consumption in the
United States. The 1978 ban reduced aerosol use of CFCs in this
country by approximately 95 percent, eliminating nearly half
of the total U.S. consumption of these chemicals.
Some CFC aerosol products were specifically exempted from
the ban based on a determination of "essentiality". (See reference
Essential Use Determinations-Revised, 1978.) The other uses
of CFCs in aerosol and pressurized dispenser products (e.g.,
as an active ingredient, a solvent, or as the sole ingredient)
were excluded from the ban because they did not fit the narrow
definition of "aerosol propellant". Therefore, prior to the
1990 Clean Air Act Amendments, the only aerosol products that
still contained CFCs were products exempted from the 1978 ban
on CFC propellants or products excluded from the 1978 ban.
The amended Clean Air Act of 1990 includes statutory authorities
relevant to use of HCFCs in several sections of Title VI. Title
VI divides controlled ozone-depleting substances into two distinct
classes. Class I is comprised of CFCs, halons, carbon tetrachloride
and MCF. Class II is comprised solely of HCFCs. In addition
to mandating the phase out of Class I and Class II substances,
section 610 of Title VI also provides for the prohibition of
certain products made with Class I and Class II substances.
The product bans for Class I substances and Class II substances
are distinct from one another and are addressed in subsections
610(b) and 610(d), respectively. In section 610(b), Congress
directed EPA to promulgate regulations that prohibit the sale
or distribution of certain "nonessential" products that release
Class I substances as of November 15, 1992. Under this subsection,
Congress specifies particular products as nonessential and directs
EPA to identify other nonessential products. In the Notification
of Proposed Rulemaking (57 FR 1992, January 16, 1992), EPA proposed
regulations that implement the requirements of section 610(b)
and ban certain nonessential products that release Class I
substances.
Under this rule, EPA proposed to ban, among other products,
flexible and packaging foam, and aerosols and other pressurized
dispensers using CFCs. The use of methyl chloroform, while a
Class I substance, is not restricted under this proposed rule.
As directed by Congress, EPA conducted research into the
purpose or intended use of products containing Class I substances,
the technological availability of substitutes, safety and health
considerations, and other relevant factors including the economic
impact of banning selected products. EPA then proposed to ban
the use of CFCs as propellants and solvents in all aerosol products
with the following specific exemptions (57 FR 1992, January
16, 1992):
-Contraceptive vaginal foams;
-lubricants for pharmaceutical and tablet manufacture;
-metered dose inhalation devices;
-gauze bandage adhesives and adhesive removers;
-commercial products using CFC-11 or CFC-113 as lubricants,
coatings, or cleaning fluids for electrical and electronic
equipment;
-commercial products using CFC-11 or CFC-113 as lubricants,
coatings, or cleaning fluids for aircraft maintenance; and
-release agents for molds using CFC-11 or CFC-113 in the production
of plastic or elastomeric materials.
In addition to the first four products listed above, EPA
is likely to exempt additional medical products as directed
by the CAA. Medical devices, as defined in section 601, include
devices, diagnostic products, drugs, and drug delivery systems
that (a) utilize a Class I or Class II substance for which no
safe and effective alternative has been developed and (b) have
been approved and determined to be essential by the FDA
Commissioner
in consultation with the EPA Administrator. It is important
to note that a product being exempted from the Class I ban does
not imply exemption from the phase-out requirements under the
CAA, which the Agency is examining separately.
Section 610(d) of the CAA prohibits the sale or distribution
of certain products that contain or are manufactured with Class
II substances. This ban, which is effective January 1, 1994,
extends to certain aerosols and pressurized dispensers which
contain Class II substances and plastic foam products which
contain or are manufactured with a Class II substance. EPA believes
that the ban on certain products containing Class II substances
is self-executing. Section 610(d)(1) bans the sale of the specified
Class II products on its own terms, without any reference to
required regulations. Thus, EPA is not required to determine
which products will be banned.
However, section 610(d)(2) allows EPA to grant exceptions
and exclusions from the ban on aerosol and pressurized dispenser
products containing class II substances. Specifically, EPA is
authorized to grant exceptions from the prohibition where the
use of the aerosol product or pressurized dispenser is determined
by the Administrator to be essential as a result of flammability
or worker safety, and where the only available alternative to
use of a Class II substance is use of a Class I substance which
legally could be substituted for such Class II substance (i.e.,
use of a Class I substance that is still allowed). In addition
to these two criteria for exceptions, aerosol products may be
excluded from the ban as a result of a third consideration in
section 610 (d)(2); namely, that the ban on products containing
Class II substances shall not apply to any medical device.
Reflecting
the self-executing nature of the CAA ban, any aerosol product
or pressurized dispenser containing a Class II substance is
banned as of January 1, 1994, unless EPA grants an exception.
HCFCs have current and potential applications as propellants
and as solvents in aerosol products. However, until recently,
their use has been limited by the aerosol industry because of
their high cost relative to traditional options such as CFCs
and hydrocarbons. Increased regulation of CFCs, including taxation
of these substances and an eventual phase-out, has meant that
HCFCs are, for an interim period, economically viable in some
applications, particularly where concern about flammability
limits the use of cheaper alternatives, such as hydrocarbons.
2. Substitutes for Aerosols
The Class I substances that are currently being used in aerosol
applications include CFC-11, CFC-12, CFC-113, CFC-114, and methyl
chloroform (MCF). Similarly, the Class II substances that are
currently being used are HCFC-22, HCFC-142b, and HCFC-141b.
The Agency has elected only to discuss alternatives for the
CFC-11, CFC-113, MCF, HCFC-22, HCFC-142b, and HCFC-141b.
The uses for CFC-12 and CFC-114 are as propellants in medical
applications and will not be discussed here because the substitutes
for these applications are currently being developed and will
have to undergo FDA approval. Possible substitutes in this
application
include HFC-134a and HFC-227ea, which both have low toxicity
and zero ozone depletion potential. Regulatory approval for
these compounds, however, is contingent on FDA approval, which
will likely occur over the next several years.
A variety of chemicals are currently being used or are being
considered as substitutes for Class I and II controlled substances
used in non-inhalation aerosols and pressurized containers.
The suitability of alternatives depends upon the product in
which they are used. Each of these alternatives has its own
physical and chemical characteristics which make it optimal
choice for the product in question, in terms of such factors
as solvency properties, propellant characteristics, performance,
cost, and environmental considerations. However, the Agency
believes that a majority of the substitutes considered to replace
the Class I and II controlled substances used as propellants
or solvents in aerosols and pressurized containers as propellants
and solvents are currently available and easily integrated into
existing aerosol production facilities.
The primary substitutes for the propellant uses of HCFC-22
and HCFC-142b are as follows:
Hydrocarbons
Dimethyl ether
HFCs
Compressed Gases
Alternative Processes
The primary substitutes for the solvent/diluent uses of CFC-
11, CFC-113, MCF, and HCFC-141b are as follows:
Petroleum Distillates
Ketones, esters, ethers, and alcohols
HCFC-141b
Terpenes
Chlorinated Solvents
Water-Based Systems
This list of substitutes was compiled with the help of companies
that submitted information on substitutes to the Agency in response
to the January 16, 1992, Advance Notice of Proposed Rule-Making.
Today's decisions on these substitutes are listed in Appendix
B. The remainder of the section discusses these substitutes,
the decision on each substitute, and the Agency's reasoning
behind each determination. Vendors or users of other substitutes
not included on the table for the SNAP determinations on aerosols
should provide information on the substitutes so that the Agency
can complete the determinations.
a. Substitutes for Propellants.-(1) Hydrocarbons. Hydrocarbons
are promising replacements for nonessential uses of HCFC-22
as a propellant in aerosols and pressurized containers. These
small chain compounds, such as butane, isobutane, and propane,
have low boiling points, making them excellent propellants.
They are used separately or in mixtures, are inexpensive compared
to HCFC-22 (HCFC-22 is four times more expensive than
hydrocarbons),
and are readily available from most chemical distributors.
The Agency believes that the major area of concern with the
replacement of hydrocarbons for HCFC-22 is the high flammability
of hydrocarbons. In applications where a nonflammable propellant
is needed, a hydrocarbon could not be used. For example, the
use of hydrocarbons around electrical equipment could prove
hazardous if sparks from the equipment were to ignite the
hydrocarbon
propellant.
Hydrocarbons are adequate substitute propellants where
flammability
is not a concern. To reduce product flammability, hydrocarbons
can be used with water-based formulations in products such as
insecticides where product quality would not be adversely impacted.
Manufacturers are also hindered from selling hydrocarbon propelled
aerosols in certain jurisdictions. In California, for example,
the use of hydrocarbons is restricted because of their
classification
as volatile organic compounds which contribute to low level
ozone or smog.
(2) Dimethyl Ether. Dimethyl ether (DME) is a medium pressure,
flammable, liquified propellant. Because of its chemical
properties,
it can be used as a combination propellant/solvent, although
it is typically classified together with other propellants and
is used in combination with other propellants. Practices for
manufacture and use of aerosol products formulated with DME
parallel practices employed with hydrocarbons.
(3) Hydrofluorocarbons. Hydrofluorocarbons (HFCs) such as
HFC-134a and HFC-152a are partially fluorinated hydrocarbons,
which have recently been developed. These compounds are less
dense than HCFC-22, but with minor reformulation adjustments
could function equally well as propellants except in products
such as noise horns, which require a more dense gas. Because
HFCs have only recently been developed, they are only now becoming
readily available and are expected to be priced significantly
higher than HCFC-22.
Preliminary studies show that HFCs are nonflammable and have
low toxicity, which would make them good replacements for HCFC-
22 as a propellant. They also may be used in conjunction with
flammable chemicals to reduce the flammability of such mixtures.
For example, HFCs are being tested for use with dimethyl ether
(DME) in safety sprays and animal repellents. Although DME is
flammable, the overall product formulation is not. HFCs are
also being tested as replacements for CFCs still used in medical
applications because of their nonflammable, nontoxic properties.
(4) Compressed Gases. Compressed Gases such as carbon dioxide,
nitrogen, air, and nitrous oxide are common, low molecular weight
gases used as propellants in aerosol products but not as drop-
in replacements. First, alternative dispensing mechanisms and
stronger containers are needed because these gases are under
significantly greater pressure. Containers holding compressed
gases are, therefore, larger and bulkier. Second, because these
chemicals have low molecular weights, they are inadequate as
replacements for HCFC-22 in products requiring a dense gas
propellant,
such as noise horns, or in products requiring fine dispersion
of the product, such as surface lubricants and weld inspection
developers. Third, compressed gases dispel material faster because
they are under higher pressure, which contributes to wasted
product.
Compressed gases are readily available from most chemical
distributors and are inexpensive. Compressed gases cool upon
expansion. This property could be beneficial when they are used
as freezing agents and gum removers and could substitute for
some nonessential uses of HCFC-22. Compressed gases are also
nonflammable and can serve as propellants in applications where
a nonflammable propellant is necessary, but not in applications
where a fine even dispersion is required.
(5) Alternative Processes. Alternative processes, such as
manually operated pumps and sprays, provide an alternative delivery
mechanism in place of the aerosol dispenser. Development of
alternative process replacements depends on technological
feasibility,
but successful implementation of these processes depends on
consumer or worker preferences. Some products, such as aerosol
foams, cannot now be easily formed with alternative processes,
making the replacement of the propellant difficult. In other
products, the alternative process may not provide proper dispersion
or accurate application of the product, limiting its use. Persons
using manual pumps or sprays (in applications where alternative
processes function adequately as replacements) on a continuous
basis may become fatigued with the constant pumping motion,
thus reducing consumer satisfaction. Therefore, alternative
processes could not easily replace the use of aerosols in
applications
where it is not technologically feasible or where the product
is used repeatedly. Nonetheless, these substitutes can serve
as viable alternatives in certain applications.
b. Substitutes for Solvent/Diluents. (1) Petroleum Distillates.
Petroleum distillates are hydrocarbons fractionated from the
distillation of petroleum. These compounds are loosely grouped
into paraffins (six carbon chains to ten carbon chains-n-hexane,
n-heptane, etc.) and light aromatics (toluene and xylene) and
come in various grades of purity. These compounds have good
solvent properties, are inexpensive (about half the price of
MCF), and are readily available from chemical distributors.
When a controlled substance is used only as a diluent, such
as in automotive undercoatings, substitution using petroleum
distillates is relatively easy with minor reformulation changes.
Many of these products containing petroleum distillates even
outperform their chlorinated counterpart.
Petroleum distillates are, however, flammable, and thus cannot
be used as replacement solvents in applications where the solvent
must be nonflammable such as electronic cleaning applications.
In addition, pesticide aerosols formulated with certain petroleum
distillates must adhere to requirements imposed under the Federal
Insecticide, Fungicide, and Rodenticide Act (FIFRA).
(2) Oxygen-Containing Hydrocarbons. Oxygen-containing
hydrocarbons
are compounds are based on hydrocarbons containing appendant
oxygen (alcohols and ketones), integral oxygens (ethers), or
both (esters). These compounds are relatively inexpensive compared
to MCF-about half the cost-and are readily available from chemical
distributors. These compounds are also flammable and cannot
be used as substitute solvents in applications where the solvent
must be nonflammable.
These compounds are currently being blended with Class I
substances to reduce the amount of Class I substances used in
a product formulation. Since the quantity of these compounds
is small, the product still remains nonflammable. Some
manufacturers,
however, are completely reformulating products such as spot
removers with ketones, esters, ethers, or alcohols. To continue
the use of these convenient products, consumers may have to
be educated about the product's increased flammability.
(3) Hydrofluorocarbons (HCFCs). HCFC-141b is a potential
substitute to replace CFC-11 and CFC-113 used in solvent/diluent
applications in aerosols and pressurized dispensers. HCFC-141b's
ODP is similar to MCF, making it unlikely that aerosol
manufacturers
would reformulate their products away from MCF towards HCFC-
141b.
HCFC-141b has a number of characteristics which make it a
suitable alternative solvent, namely: it is nonconductive,
nonflammable,
and evaporates quickly. HCFC-141b is expensive compared to the
pretax price of CFC-113 (almost three times the cost). However,
HCFC-141b is slightly corrosive to plastic parts, and could
not serve as a drop-in replacement for all the uses of CFC-11
and CFC-113 as a solvent.
(4) Terpenes. Terpenes are unsaturated hydrocarbons based
on isoprene subunits. They have good solvent properties and
could replace ozone-depleting compounds in some solvent cleaning
applications. They are flammable, which limits their use in
applications that require nonflammable solvents. Some terpenes
have a slight citrus scent while others have a more stronger
unpleasant odor, thereby making them unpleasing to use over
a constant period of time.
(5) Chlorinated Solvents. Chlorinated solvents such as
perchloroethylene,
trichloroethylene, and methylene chloride can be used to replace
CFC-11, CFC-113, and MCF in solvent applications in aerosol
and pressurized containers. These chlorinated solvents are
extremely
effective and can dissolve compounds which are difficult to
dissolve in other solvents, such as fluorinated polymers used
in water and oil repellents. However, due to toxicity concerns
associated with these substances, their application is likely
to be limited, especially in products sold to the general public
or in products that are used frequently by workers. In addition,
pesticide aerosols formulated with these chlorinated solvents
must adhere to requirements under FIFRA.
Chlorinated solvents, because they are strong solvents and
nonflammable, are promising substitutes in cleaning applications
for electronic equipment or electric motors where safeguards
could be used to protect workers from the potentially toxic
fumes. These compounds are readily available from chemical
distributors
at prices comparable to MCF.
(6) Water-Based Formulations. Water-based formulations provide
a replacement for the use of CFC-11, CFC-113, and MCF as solvents
in aerosols and pressurized dispensers. These reformulated products
usually contain new components/active-ingredients that are water
soluble. The overall function of the reformulated product remains
the same, but the product's substituents are changed.
Most formulations are nonflammable, yet may be difficult
to use around sources of electricity because they may short
out electrical equipment. Such products may also have short
shelf-lives because the active ingredient may decompose in an
aqueous environment. Also, these products when sprayed do not
evaporate quickly, resulting in product accumulation. This may
be problematic in certain applications such as where the
accumulation
of a water-based product contributes to rust or corrosion. The
possibility of reformulating products is product-specific,
depending
on the feasibility of finding active ingredients that are water
soluble.
(7) Monochlorotoluene/ chlorobenzotrifluorides.
Monochlorotoluene
and chlorobenzotrifluorides are of commercial interest as solvent
substitutes for aerosols. These compounds can be used either
in isolation or in various mixtures, depending on desired chemical
properties. The Agency recently received information on these
formulations, and it will issue a SNAP determination for these
substitutes in the next set of listing decisions.
3. Preliminary Listing Decisions
a. Acceptable Substitutes. (1) Propellants (a) Hydrocarbons.
Hydrocarbons are acceptable substitutes as propellants in the
aerosols sector. Hydrocarbons have several environmental advantages
over other substitutes. For example, they have zero ozone-depletion
potential, and because of their extremely short atmospheric
residence times they are estimated to have insignificant impact
on global warming. Yet their reactivity contributes to formation
of tropospheric ozone. The Agency has assessed this effect,
however, and found that the increase in volatile organic compound
emissions (VOCs) from these substitutes will have no significant
effect on tropospheric ozone formation.
Hydrocarbons have a long history of use, and the increase
due to replacement of CFCs as aerosol propellants represents
a fraction of current consumption. Hydrocarbon propellants acquired
industrial importance in the U.S in the early 1950s. By 1978,
when the ban on CFC propellants in the U.S. was promulgated,
nearly half of all aerosol units being produced in the U.S were
already using hydrocarbon propellants. This percentage grew
to nearly 90 percent in 1979.
Most of the hydrocarbon propellants are essentially non-toxic.
Very high concentration of hydrocarbons are necessary to alter
normal body functions. No temporary or permanent physiological
malfunctions are produced by these chemicals. Very high
concentrations
of hydrocarbons may result in asphyxiation because of lack of
oxygen.
Hydrocarbon propellants are flammable. Thus, precautions
will need to be taken in receiving, unloading, transferring,
storing, and filling hydrocarbons aerosol products. The listing
of these compounds as acceptable substitutes does not exempt
producers or users from other regulatory or industrial standards
such as those promulgated by OSHA. However, because of the
widespread
use of these materials, industry is already familiar with the
safety precautions necessary in switching from a CFC filling
operation to one using hydrocarbons.
(b) HCFC-22
HCFC-22 is an acceptable substitute as a propellant in the
aerosols sector. The principal characteristic of HCFC-22 that
has resulted in its increased use is non-flammability. However,
the use of HCFC-22, either by itself or blended with other
compounds,
will be prohibited after January 1, 1994 due to the high ozone-
depletion potential of this compound. As noted earlier, section
610(d) of the CAA Amendments of 1990 prohibits the sale or
distribution
of aerosol products or other pressurized dispensers that contain
Class II substances (i.e., HCFCs) by January 1, 1994. Section
610(d)(2) allows EPA to grant exceptions where the use of the
aerosol product or pressurized dispenser is determined by the
Administrator to be essential as a result of flammability or
worker safety, and where the only available alternative to the
use of a Class II substance is the legally permitted use of
a Class I substance.
The Agency is not restricting substitution of HCFC-22 for
Class I propellants at this time. However, the Agency advises
companies that, under the SNAP program, the Agency will only
allow uses of HCFC-22 consistent with the exemptions provided
under section 610(d)(2), once these regulations are promulgated
in 1994.
(c) HCFC-142b
HCFC-142b is an acceptable substitute as a propellant in
the aerosols sector. Although this compound has a comparatively
high ODP, it is one of the few non-toxic, non-flammable
substitutes.
However, as described in the section on HCFC-22, use of HCFC-
142b, either by itself or blended with other compounds, will
be prohibited after January 1, 1994 under section 610(d)(2).
After that date, the SNAP program will only grant exemptions
for use of HCFC-142b for essential applications based on worker
safety and flammability as classified under section 610.
(d) HFC-152a and HFC-134a
HFC-152a and HFC-134a are acceptable substitutes as propellants
in the aerosols sector. HFC-152a has both zero ozone-depletion
potential and a low global warming potential. However, HFC-152a
by itself is flammable, and necessary precautions should be
taken when using this chemical. HFC-134a also has zero ozone-
depletion potential, yet this compound does have a relatively
long atmospheric lifetime and could therefore contribute to
global warming. Despite these concerns, the Agency has approved
these substitutes due to their ability to fill certain niche
applications where other substitutes do not exist.
The use of these HFCs by themselves or blended with HCFC-
22 or HCFC-142b will be allowed. However, as noted above, the
use of HCFC-22 and HCFC-142b, either by itself or blended with
other compounds, will be prohibited after January 1, 1994 under
section 610(d)(2). Limited exemptions will apply, as discussed
above.
(e) Dimethyl Ether
Dimethyl ether is an acceptable substitute propellant in
the aerosols sector. The principal environmental concern for
use of DME is its ability to contribute to ground-level ozone
formation. However, the Agency's screen of effects from increased
use of VOCs in aerosol products suggests that increases in ground-
level ozone formation from use of DME would be minor.
(f) Compressed Gases
Compressed gases are acceptable substitutes as propellants
in the aerosols sector. The Agency believes that although
compressed
gases such as air, carbon dioxide, nitrogen are presently only
used in about 7-9 per cent of the aerosol products, their use
will grow in the future. These gases have low toxicity and
industrial
practices for using these substitutes are well established.
Since these gases are under significantly greater pressure,
containers holding these gases will have to be larger and bulkier,
and safety precautions will have to be undertaken during filling
operations. Carbon dioxide and nitrogen are non-flammable and
do not require the use of explosion proof gassing equipment.
Nitrous oxide, while non-flammable, can create a moderate explosion
risk under certain temperature and pressure conditions.
(g) Alternative Processes
Alternative Processes are acceptable as propellants in the
aerosols sector. Alternative processes such as finger and trigger
pumps, two-compartment aerosol products, mechanical pressure
dispenser systems, and non-spray dispensers (e.g., solid stick
dispensers) have found increasing use as replacement for
conventional
aerosol products. The Agency believes that these products do
not pose any significant risks, since they rely on mechanical
force to replace the propellant.
(2) Solvents
(a) Petroleum Distillates.-Petroleum distillates are acceptable
substitutes as solvents in the aerosol sector. Petroleum
distillates
have had a long history of use, and increases due to replacements
for aerosol applications represent a fraction of the current
consumption across industries. Concerns for risks from these
compounds in possible uses as pesticide aerosol solvents have
already been addressed under FIFRA authorities.
(b) HCFC-141b
HCFC-141b, either by itself or blended with other compounds,
is an acceptable substitute for aerosol solvent applications.
Like HCFC-22, the principal problem with HCFC-141b is that it
has a comparatively high ODP-0.11. This is the highest ODP of
all HCFCs; in fact, the ODP of HCFC-141b is about twice as high
as HCFC-22. Yet in certain cases, such as where flammability
is a technical impediment to use of other alternatives, HCFC-
141b may be the only alternative to replace other ozone-depleting
solvents. Several companies have already contacted the Agency
indicating that they have tested alternatives, and that in some
cases only HCFC-141b meets performance or safety criteria.
Under the SNAP program, the Agency will allow the use of
HCFC-141b as a substitute for CFC-11 or CFC-113 use until January
1994, when regulations under section 610(d)(2) will be promulgated.
Key features of section 610 are described under the listing
decision for HCFC-22.
(c) Other Chlorinated Solvents
Trichloroethylene (TCE), perchloroethylene (PERC) and methylene
chloride (MeCl), are acceptable substitutes as solvents in the
aerosols sector. These substitutes have the technical capability
to meet a large portion of the needs of the aerosols industry.
However, the Agency anticipates that, due to toxicity concerns
associated with the past use of these alternatives, the market
share for these other chlorinated solvents will not increase
substantially.
The toxicity of these three solvents has been subject of
extensive analysis. Their use has the potential to pose high
risks to workers as well as to residents in nearby communities
or consumers using products containing such chemicals.
Although risks to workers can be reduced by adhering to OSHA
standards, residual risks to residents in nearby communities
may remain. The Agency is aware of potential for these risks
to occur, and it has the authority necessary to address them
under Title III of the CAA. This section of the CAA lists three
of these solvents as Hazardous Air Pollutants, and authorizes
the Agency to establish controls for their use. In addition,
any risks through use of these compounds as pesticide aerosols
have already been addressed using FIFRA authorities.
The Agency did not explicitly evaluate risks to consumers,
since it received no indication that these chlorinated solvents
were of commercial interest for use in consumer aerosols. The
Agency strongly encourages manufacturers to formulate consumer
products based on other compounds with fewer known adverse effects
on human health.
(d) Oxygen-Containing Hydrocarbons
Oxygen-containing hydrocarbons (ketones, esters, ethers,
and alcohols) are acceptable substitutes as solvents in the
aerosols sector. Most of these compounds have a long history
of use, and the increase due to replacement as aerosol substitutes
represents a fraction of the current consumption across all
industries.
(e) Terpenes
Terpene-based products are acceptable substitutes as solvents
in the aerosols sector. Terpene-based chemicals have a long
history of use as industrial solvents, and the increase due
to replacement of ozone-depleting compounds in aerosol applications
represents a fraction of current consumption across all industries.
Additionally, many of these chemicals are naturally occurring
organic hydrocarbons and exhibit significant biodegradability.
The use history of these chemicals does not negate the inherent
toxicity of these compounds to aquatic life. However, the Agency
does not believe that in this case significant adverse effects
are to be expected, since in aerosol applications the terpenes
volatilize during use and would consequently not be discharged
to surface or ground water where aquatic species are to be found.
(f) Water-Based Formulations
Water-based formulations are acceptable substitutes for
propellants
in the aerosols sector. The Agency did not identify any significant
environmental concerns associated with use of these products.
They can contain small amounts of VOCs, but these amounts are
minor in comparison to products formulated solely with organic
solvents.
b. Proposed Unacceptable Substitutes.
(1) Propellants.
None
(2) Solvents.
None
J. Tobacco Expansion. 1. Overview
Tobacco expansion is the process of puffing leaves of tobacco
to increase the volume of tobacco used in cigarette production.
Currently, one of the primary technologies used to expand tobacco
in the U.S. uses CFC-11. One and one half million pounds annually
are used in the U.S. in this application.
In the CFC-11 process, tobacco is saturated with CFC-11 in
a stainless steel vessel maintained at 120 degrees Fahrenheit
and pressurized to 20 psi. The tobacco is then permeated with
hot air (330 °F) which expands the tobacco. The CFC-11 is
vaporized
and recovered by cooling and compressing. The CFC-11 is continually
recovered and recycled.
The Agency received information about three potential
substitutes:
(1) Carbon dioxide technology, an alternative process substitute,
(2) HCFC-123, a drop-in replacement, and (3) HFC-227ea. In this
action, the Agency is listing carbon dioxide as an acceptable
substitute for CFC-11 in tobacco expansion. The decision on
HCFC-123 as a substitute for CFC-11 for tobacco expansion is
pending completion of the Agency's review of the data. Similarly,
HFC-227ea is pending completion of review of the data.
2. Proposed Acceptable Substitutes. a. Carbon Dioxide
The Agency has determined the use of carbon dioxide as a
substitute for CFC-11 in tobacco expansion to be acceptable.
Carbon dioxide has been successfully used in the tobacco industry
for approximately twenty years. It is non-toxic, non-flammable,
and it has zero ODP. A permissible exposure level (PEL) has
been set at 5,000 ppm, a level that can easily be met during
the well contained tobacco expansion process. The carbon dioxide
process is similar to the process using CFC-11, though pressure
and temperature parameters are different. For this reason carbon
dioxide cannot be used as a retrofit for CFC-11 equipment; new
equipment must be purchased in order to use carbon dioxide for
tobacco expansion.
Although carbon dioxide is a greenhouse gas, increased use
of carbon dioxide for tobacco expansion will not increase global
warming because the carbon dioxide used in tobacco expansion
is a by-product of the production of other gases. The carbon
dioxide is captured from a stream of gas that otherwise would
be emitted to the ambient air. Additionally, carbon dioxide
recycling equipment is available, which will also help limit
emissions of carbon dioxide to the atmosphere.
K. Adhesives, Coatings, and Inks. 1. Overview
Methyl chloroform (MCF) is used as a solvent in adhesives,
coatings, and inks because of its favorable properties: high
solvency, low flammability, low toxicity, relative high stability,
and low boiling point. Unlike a number of other solvents classified
as volatile organic compounds (VOCs), MCF does not photochemically
degrade in the lower atmosphere to lead to ground-level ozone
formation. This key property caused many manufacturers to switch
from formulations containing VOC solvents to MCF in the mid
1980s as regulatory pressure increased to reduce VOC emissions
in nonattainment areas. Companies achieved compliance by altering
their solvent-borne formulations, thereby avoiding costly capital
investment in new equipment, changes in operating procedures,
and employee retraining. This trend has been reversed as companies
have begun to respond to the phase-out of MCF under the
stratospheric
ozone protection provisions of the Clean Air Act.
This section examines substitutes that can be used in place
of MCF in this sector, and presents the Agency's proposed decisions
and supporting analysis on acceptability of these substitutes.
These determinations are summarized in Appendix B at the end
of the sector discussions.
Of the three uses for MCF in this sector, use of MCF is largest
in the adhesives subsector. In 1989, manufacturers of adhesives
consumed about 28,000 metric tons (MT) of MCF in their
formulations,
roughly nine per cent of the total MCF produced in the U.S.
(HSIA, 1991). Solvent-based adhesive formulations constitute
15 per cent of all adhesive types. MCF is desirable as a solvent
for adhesives because it evaporates rapidly, is nonflammable,
performs comparably to or better than VOC-formulated products,
and does not photochemically degrade in the lower atmosphere.
Current consumption of methyl chloroform as a solvent in the
adhesives sector is estimated to be 32,000 MT.
MCF is used in five adhesive types:
laminate adhesives;
flexible foam adhesives;
hardwood floor adhesives;
metal to rubber adhesives; and
tire patch adhesives.
MCF is no longer commonly used in the following adhesive
applications where its use was once widespread:
pressure sensitive adhesives (tapes, labels, etc.);
flexible packaging adhesives;
aerosol-propelled adhesives; and
shoe repair glues and other consumer adhesives. In manufacture
of coatings and inks, MCF usage rose steadily throughout the
1980s and began declining in the early 1990s. In 1989, the
consumption
of MCF used in coatings and inks was 18,480 MT, six percent
of the total 310,000 MT of MCF consumed in the U.S. Current
consumption in the coatings and inks sector is estimated to
be 23,000 MT. MCF is the only ozone-depleting substance currently
used in coatings and inks formulations. As with uses in adhesives,
MCF has replaced some of the applications in coatings and inks
which previously used VOC solvents.
The current use of MCF in coatings and inks applications
occurs four use areas:
flexographic and rotogravure printing inks;
wood stains;
metal coatings; and
aerospace coatings.
2. Substitutes in the Adhesives, Coatings, and Inks Sector
Methyl chloroform-based adhesives, coatings, and inks can
be replaced by either substitute solvents or alternative
application
technologies. In most instances, the alternatives are expected
to perform as well as products containing MCF. Factors that
determine which particular alternative is best in a given situation
include physical and chemical properties, replacement chemical
costs, capital investment costs, and product performance.
The primary substitutes to replace methyl chloroform in
adhesives,
coatings, and inks include:
petroleum distillates;
organic solvents (ketones, esters, ethers, alcohols);
chlorinated solvents;
terpenes;
water-based formulations;
high-solids formulation; and
alternative process alternatives;
-powder formulations
-hot melts
-thermoplastic plasma spray coatings
-radiation cured
-moisture cured
-chemical cured
-reactive liquids.
These substitutes can be grouped into four basic categories:
solvent substitutes, water-based formulations, high-solids
formulations,
and alternative processes.
a. Solvent Substitutes. Petroleum distillates are hydrocarbons
fractionated from the distillation of petroleum. These compounds
are loosely grouped into paraffins (six carbon chains to ten
carbon chains-hexane, heptane, etc.) and light aromatics (toluene
and xylene), and come in various levels of purity. These compounds
have good solvent properties, cost about half as much as MCF,
and are readily available from chemical distributors.
Organic solvents such as alcohols, ketones, ethers, and esters
dissolve a wide range of polar and semi-polar substances. These
compounds are relatively inexpensive compared to MCF (about
half the cost) and are readily available. They function well
as solvents and dissolve most resins and binders used in adhesives,
coatings, and inks.
Chlorinated solvents such as perchloroethylene and methylene
chloride are chlorinated hydrocarbons. These chemicals can be
used to replace MCF used in adhesives, coatings and inks. These
solvents are commercially available from chemical distributors
at prices comparable to those for methyl chloroform.
Chlorinated solvent compounds are chemically similar to MCF
and thus are able to substitute directly for MCF with minor
changes in the formulation of the product; product quality is
expected to remain unchanged. Manufacturers can use chlorinated
solvents in existing equipment with minor changes, resulting
in low capital costs.
Terpenes are unsaturated hydrocarbons based on isoprene
subunits.
They have good solvent properties and could replace MCF in some
coating and ink products. Terpenes, such as d-limonene, cost
about seven times more than MCF, and are commercially available
from chemical distributors. Manufacturers can use terpenes in
existing equipment with minor changes.
Monochlorotoluene and chlorobenzotrifluorides are also of
commercial interest as solvent substitutes for adhesives, coatings,
and inks. These compounds can be used either in isolation or
in various mixtures, depending on desired chemical properties.
The Agency recently received information on these formulations,
and it will issue a SNAP determination for these substitutes
in the next set of listing decisions.
b. Water-Based Formulations. Water-based coatings contain
water rather than conventional solvents. Primary uses of these
coatings include furniture, aluminum siding, hardboard, metal
containers, appliances, structural steel, and heavy equipment.
Water-based coatings are priced roughly 20 to 30 per cent more
than methyl chloroform-based coatings.
Water-based inks use water and other co-solvents such as
alcohols and alkyl acetates to dissolve resins, binders, and
pigments instead of conventional solvents. Water-based inks
accounted for 55 per cent of the flexographic inks and 15 per
cent of the gravure inks used in the U.S. in 1987. Water-based
inks are priced roughly 10 per cent less than methyl
chloroformbased
inks.
Water-based adhesives currently account for about 45 per
cent of world adhesive market. Water-based adhesives will likely
dominate the market to replace MCF in general consumer uses
and in areas where a rigid bond is not needed. Water-based
adhesives-
especially water-based latexes, which are stable dispersions
of solid polymeric material in an essentially aqueous medium-
can effectively replace MCF use in the flexible foams sector
because of the flexibility of the bond they provide. Water-based
latex adhesives have the potential to penetrate 85-90 per cent
of the MCF-based adhesive market in flexible foams applications.
They still pose a number of problems, however, including:
long set and dry times;
deterioration during storage; and
the production of bacteria-contaminated waste water.
Water-based replacements have not proven effective in binding
high density laminates or hardwood flooring. Slow tack, set,
and dry times continue to be a problem and trapped moisture
enhances the chances of warping. In cases where MCF is used
for door assemblies or sealants, water-based urethane adhesives
containing polyisocyanates can be used instead.
c. High-Solid Formulations. High-solids coatings resemble
conventional coatings in appearance and use, except high-solids
coatings contain less solvent and a greater percentage of resin.
High-solids coatings are currently used on appliances, metal
furniture, and farm and road construction equipment. High-solids
coatings are priced 20 to 30 percent higher than methyl chloroform-
based coatings, yet the buyer receives more usable paint because
the coatings contain less solvent reducing their volume.
High-solids adhesives can reduce the amount of solvent used
in adhesives by increasing the percentage of solids in the
formulation.
Adhesives formerly containing 30-50 percent solids contain
about 80 percent solids after reformulation. High-solids adhesives
have good performance characteristics, including initial bond
strength, and can be applied using existing equipment at normal
line speeds with minimal modification. For bonding rubber
assemblies,
high solid adhesive films are often too thick, resulting in
limited versatility and generally poor performance. High-solids
formulations, however, are already used widely in the flexible
foams, hardwood flooring, and high-pressure laminates industries.
The solvent of choice in these industries remains MCF, but with
a decreased portion of solvent in the formulations, less solvent
is consumed overall. High solids formulations are only a
transitional
replacement until adequate substitutes are found that do not
contain MCF.
d. Alternative Process Substitutes. Powder adhesives, the
first category of alternative process substitutes, are composed
of one-part epoxies, urethanes, and natural resins. These adhesives
are often supplied as powders that require heat to cure. They
are generally applied in one of three ways: by sifting the powder
onto preheated substrates, by dipping a preheated substrate
into the powder, and by melting the powder into a paste or liquid
and applying it by conventional means. Since high temperatures
are required to activate and thermoset powder adhesives, their
ability to replace MCF-based formulations will depend on the
characteristics substrates being bonded: if the materials being
bonded are heat sensitive, heat-activated powder adhesives can
not be used.
Powder coatings have no solvent, containing only resins and
pigments in powder form. Typically, the coated object is heated
above the powder's melting point, so that the resin fuses into
a continuous film. Powder coatings have been used on various
types of metal products such as appliances, concrete reinforced
bars, automobiles, steel shelving, lawn and farm equipment,
and some furniture. The elevated temperatures necessary to melt
the coatings, however, restrict the use of powder coatings on
plastic and wood products. Powder coatings are priced comparably
to methyl chloroform-based coatings.
Hot melt adhesives are 100 percent solid thermoplastic binders
that can be used to replace MCF formulations in applications
that require a rigid bond. Hot melts currently account for about
20 percent of the adhesives market, and they, along with water-
based adhesives, will likely benefit most from the move away
from MCF-based adhesive formulations. Hot melts are now used
instead of MCF formulations in laminating applications, especially
those involving the lamination of flexible foam products. They
can also replace MCF-based adhesive formulations in OEM production
of high-pressure laminates and possibly in the installation
of hardwood flooring. The potential ability of hot melt adhesives
to replace MCF-based formulations in the flexible foams sector
is limited to 10-15 percent penetration because of the need
for flexible bonds in most furniture and bedding applications.
Thermoplastic plasma spray coatings are powder coatings that
melt in transit towards the object to be coated propelled by
a pressurized inert gas, such as Argon. An electric arc strips
electrons from the plastic particles fusing them together as
they move through the applicator gun. Thermoplastic plasma spray
coatings can be used to coat large and small objects of metal,
wood, plastic, or fiberglass.
Radiation curing is a production technique for drying and
curing adhesives with radiant energy in the form of ultraviolet
(UV) or infrared (IR) light, electron beams (EB), and gamma
or x-rays. The binding agents that can be cured with radiant
energy are acrylics, epoxies, urethanes, anaerobic adhesives,
and polyester resins. In many cases, if the materials are either
heat sensitive or opaque, radiation curing cannot be employed.
Radiation-dried coatings are applied as either a powder or
as a high-solids form and dried using the same radiant energy
forms as used in radiation-cured adhesives. The binder systems
that can be dried with radiant energy are also similar. In cases
where the radiant energy is harmful to a component, such as
sensitive electronic equipment, radiant-dried coating cannot
be employed.
Moisture-cured, chemical-cured, and reactive liquid adhesives
are still not widely used because they are still being developed
or because performance or application problems still have to
be addressed. They will not be widely commercially available
for several years.
3. Preliminary Listing Decisions. a. Acceptable Substitutes
(1) Solvent Substitutes. (a) Petroleum Distillates
Petroleum distillates are acceptable substitutes for adhesives,
coatings, and inks. The principal concern with these substitutes
is over risk to workers during manufacture and use of the
alternative
solvent. However, the Agency's analysis of these alternatives
indicated that risks from use of petroleum distillates are well
understood and, as a consequence, already subject to necessary
controls. For instance, although these solvents are flammable,
industry has a good record of safe use of these substitutes.
Additionally, certain of the petroleum distillates have low
Permissible Exposure Limits (PELs), for example n-hexane, but
the Agency's survey of exposures in the workplace found that
these levels can successfully be attained if adequate ventilation
and appropriate work practices are implemented.
The Agency's analysis of the potential for risks to residents
in nearby communities did indicate the potential for adverse
effects near a site with industrial use of petroleum distillates
if a relatively toxic petroleum distillate is used. However,
the Agency does not believe that the risk screen describes the
true risk presented by these chemicals. First, it is unlikely
that solvents as toxic as the chemical chosen for the purpose
of the risk screen-n-hexane-are in wide-spread use. Second,
the screen used as past MCF emissions as a proxy for emissions
of n-hexane. This approach does not account for other regulatory
controls, such as VOC controls, that limit emissions of petroleum
distillates from industrial sites, and would consequently also
serve to lower any other health risks to the general population
from these chemicals.
For this reason, the Agency believes that petroleum distillates
merit use as substitutes, although it encourages manufacturers
to formulate products where possible with compounds with lowest
inherent toxicity.
(b) Alcohols, Ketones, Ethers and Esters
Alcohols, Ketones, Ethers and Esters are acceptable substitutes
for adhesives, coatings, and inks. The concerns for use of these
solvents parallel the concerns associated with petroleum
distillates.
In this case, two of the typical hydrocarbons examined in the
Agency's risk screen, methyl ethyl ketone and methyl isobutyl
ketone, also have comparatively low toxicity. For the same reasons
described in the section on petroleum distillates, the Agency
is approving these compounds as substitutes for MCF. This approval
also includes the same guidance to manufacturers-to select
chemicals
for product formulations with lowest inherent toxicity.
(c) Chlorinated Solvents
Perchloroethylene, methylene chloride and trichloroethylene
are acceptable substitutes for adhesives, coatings, and inks.
Uses of these solvents merit special caution, since they are
suspected human carcinogens. However, as with other solvents,
the Agency's risk screen indicates that proper workplace practices
significantly reduce risks in occupational settings. The Agency's
examination of risks to the general population determined the
highest potential for adverse effects to be associated with
use of trichloroethylene, since it has the greatest cancer potency.
The screen pointed to the need for further assessment of the
hazards from use of this chemical, and the Agency notes that
authorities exist to address any risks determined from such
analyses under Title III of the Clean Air Act. Title III lists
all three of the chlorinated solvents as Hazardous Air Pollutants,
and mandates development of Maximum Achievable Control Technology
to control emissions of these chemicals in various industrial
settings.
(d) Terpenes
Terpenes are acceptable substitutes for adhesives, coatings,
and inks. The principal environmental concern with terpenes
is their toxicity to aquatic life. In applications for terpenes
in adhesives, coatings, and inks, however, the terpenes are
both used and bound in the product formulation, meaning that
there are no discharges of wastewater effluent that could present
a risk. Other potential environmental hazards associated with
these compounds arise from their flammability and unpleasant
odors, but these can be controlled by good workplace practices.
(2) Water-Based Formulations/High-Solid Formulations
Water-based formulations and high-solid formulations are
acceptable substitutes for adhesives, coatings, and inks. The
Agency did not identify any environmental or health concerns
associated with use of these products. These formulations do
contain small amounts of VOCs, but the increase in VOC loadings
from these products is expected to be extremely small in comparison
to VOC contributions from other sources.
(3) Alternative Processes
Alternative processes, including powder formulations, hot
melt, thermoplastic plasma spray, radiation-based formulations,
and moisture-cured, chemical-cured, and reactive liquid
alternatives,
are all acceptable substitutes for adhesives, coatings, and
inks. The Agency did not identify any health or environmental
concerns associated with use of these substitutes. Since this
grouping includes such a wide variety of products for which
it is difficult to complete an in-depth risk screen, the Agency
solicits additional detail on any potential environmental or
health effects that merit further investigation.
X. Additional Information
A. Executive Order 12291
Executive Order (EO) 12291 requires the preparation of a
regulatory impact analysis for major rules, defined by the order
as those likely to result in: (1) An annual effect on the economy
of $100 million or more; (2) a major increase in costs or prices
for consumers, individual industries, Federal, state or local
government agencies; (3) significant adverse effects on
competition,
employment, investment, productivity, innovation, or on the
ability of United States-based enterprises to compete with foreign-
based enterprises in domestic or export markets.
EPA has determined that this proposed regulation does not
meet the definition of a major rule under EO12291 and therefore
has not prepared a formal regulatory impact analysis. EPA has
instead prepared an economic analysis which estimated potential
costs of the proposed regulation, using the reductions of
production
and consumption under the CFC phase-out as a baseline. This
analysis showed that the SNAP program was not likely to impose
costs of greater than $100 million on industry, and in fact,
to the extent the program established by this rule helps spread
the word about available, economically viable substitutes for
Class I and II ozone-depleting compounds, this rule provides
solid benefits to industry in their effort to move away from
prohibited compounds. The economic analysis summarized in the
foregoing discussion has been placed in the record for this
rulemaking.
B. Regulatory Flexibility Act
The Regulatory Flexibility Act, 5 U.S.C. 601-602, requires
that Federal agencies examine the effects of their regulations
on small entities. Under 5 U.S.C. 604(a), whenever an agency
is required to publish a general notice of proposed rule-making,
it must prepare and make available for public comment an initial
regulatory flexibility analysis (RFA). Such an analysis is not
required if the head of the Agency certifies that a rule will
not have a significant economic effect on a substantial number
of small entities, pursuant to 5 U.S.C. 605(b).
The Agency believes that today's proposed regulation, if
promulgated, will not have a significant effect on a substantial
number of small entities and has therefore concluded that a
formal RFA is unnecessary. Because costs of the requirements
as a whole are expected to be minor, the rule is unlikely to
adversely affect small businesses, particularly as the rule
exempts small sectors and end-uses from reporting requirements
and formal Agency review. In fact, to the extent that information
gathering is more expensive and time-consuming for small companies,
this rule may well provide benefits for small businesses anxious
to examine potential substitutes to any ozone-depleting Class
I and II substances they may be using, by requiring manufacturers
to make information on such substitutes available.
C. Paperwork Reduction Act
The information collection requirements in this proposed
rule have been submitted for approval to the Office of Management
and Budget (OMB) under the Paperwork Reduction Act, 44 U.S.C.
3501 et seq. An Information Collection Request document has
been prepared by EPA (ICR No. 1596.02) and a copy may be obtained
from Sandy Farmer, Information Policy Branch, EPA, 401 M St.,
SW. (PM-223Y), Washington, DC 20460 or by calling (202) 260-
2740.
Public reporting burden for this collection of information
is estimated to vary from 4 to 166 hours per response with total
estimated reporting burden on the industry of 8,772 hours. This
estimate includes time for initial contact with the Agency,
reviewing instructions, searching existing data sources, gathering
and maintaining the data needed, completing the collection and
presentation of information, and responding to any additional
requests for missing data.
Send comments regarding the burden estimate or any other
aspect of this collection of information, including suggestions
for reducing this burden to Chief, Information Policy Branch,
EPA, 401 M St., S.W. (PM-223Y), Washington, DC 20460, and to
the Office of Information and Regulatory Affairs, Office of
Management and Budget, Washington, DC 20503, marked "Attention:
Desk Officer for EPA." The final rule will respond to any public
comments on the information collection requirements contained
in this proposal.
XI. References
1. United Nations Environment Programme, World Meteorological
Organization, et al. Scientific Assessment of Stratospheric
Ozone: 1991 (17 December 1991).
2. Intergovernmental Panel on Climate Change, World
Meteorological
Organization, United Nations Environment Programme. Climate
Change: The IPCC Scientific Assessment (1990).
3. Halogenated Solvents Industry Alliance (HSIA),
1,1,1-Trichloroethane
(Methyl Chloroform) White Paper (May 1991).
List of Subjects in 40 CFR Part 82
Administrative practice and procedure, Air pollution control,
Reporting and recordkeeping requirements.
Dated: April 23, 1993.
Carol M. Browner,
Administrator.
Appendix A to the Preamble-Class I and Class II Ozone Depleting
Substances
Class I and Class II Ozone-Depleting Substances
CLASS I
Group I:
Chlorofluorocarbon-11
CFC-11 (CFCl3)
Trichlorofluoromethane
Chlorofluorocarbon-12
CFC-12 (CF2Cl2)
Dichlorodifluoromethane
Chlorofluorocarbon-113
CFC-113 (C2F3Cl3)
Trichlorotrifluoroethane
Chlorofluorocarbon-114
CFC-114 (C2F4Cl2)
Dichlorotetrafluoroethane
Chlorofluorocarbon-115
CFC-115 (C2F5Cl)
Monochloropentafluoroethane
Group II:
Halon-1211
(CF2ClBr)
Bromochlorodifluoromethane
Halon-1301
(CF3Br)
Bromotrifluoromethane
Halon-2402
(C2F4Br2)
Dibromotetrafluoroethane
Group III:
Chlorofluorocarbon-13
CFC-13 (CF3Cl)
Chlorotrifluoromethane
Chlorofluorocarbon-111
CFC-111 (C2FCl5)
Pentachlorofluoroethane
Chlorofluorocarbon-112
CFC-112 (C2F2Cl4)
Tetrachlorodifluoroethane
Chlorofluorocarbon-211
CFC-211 (C3FCl7)
Heptachlorofluoropropane
Chlorofluorocarbon-212
CFC-212 (C3F2Cl6)
Hexachlorodifluoropropane
Chlorofluorocarbon-213
CFC-213 (C3F3Cl5)
Pentachlorotrifluoropropane
Chlorofluorocarbon-214
CFC-214 (C3F4Cl4)
Tetrachlorotetrafluoropropane
Chlorofluorocarbon-215
CFC-215 (C3F5Cl3)
Trichloropentafluoropropane
Chlorofluorocarbon-216
CFC-216 (C3F6Cl2)
Dichlorohexafluoropropane
Chlorofluorocarbon-217
CFC-217 (C3F7Cl)
Monochloroheptafluoropropane
Group IV:
Carbon Tetrachloride
(CCl4)
Group V:
Methyl Chloroform
(C2H3Cl3)
1,1,1 Trichloroethane
CLASS II
Hydrochlorofluorocarbon-21
HCFC-21 (CHFCl2)
Dichlorofluoromethane
Hydrochlorofluorocarbon-22
HCFC-22 (CHF2Cl)
Monochlorodifluoromethane
Hydrochlorofluorocarbon-31
HCFC-31 (CH2FCl)
Monochlorofluoromethane
Hydrochlorofluorocarbon-121 HCFC-121 (C2HFCl4)
Tetrachlorofluoroethane
Hydrochlorofluorocarbon-122 HCFC-122 (C2HF2Cl3)
Trichlorodifluoroethane
Hydrochlorofluorocarbon-123 HCFC-123 (C2HF3Cl2)
Dichlorotrifluoroethane
Hydrochlorofluorocarbon-124 HCFC-124 (C2HF4Cl)
Monochlorotetrafluoroethane
Hydrochlorofluorocarbon-131 HCFC-131 (C2H2FCl3)
Trichlorofluoroethane
Hydrochlorofluorocarbon-132B HCFC-132B (C2H2F2Cl2)
Dichlorodifluoroethane
Hydrochlorofluorocarbon-133A HCFC-133A (C2H2F3Cl)
Monochlorotrifluoroethane
Hydrochlorofluorocarbon-141B HCFC-141B (C2H3FCl2)
Dichlorofluoroethane
Hydrochlorofluorocarbon-142B HCFC-142B (C2H3F2Cl)
Monochlorodifluoroethane
Hydrochlorofluorocarbon-221 HCFC-221 (C3HFCl6)
Hexachlorofluoropropane
Hydrochlorofluorocarbon-222 HCFC-222 (C3HF2Cl5)
Pentachlorodifluoropropane
Hydrochlorofluorocarbon-223 HCFC-223 (C3HF3Cl4)
Tetrachlorotrifluoropropane
Hydrochlorofluorocarbon-224 HCFC-224 (C3HF4Cl3)
Trichlorotetrafluoropropane
Hydrochlorofluorocarbon-225CA HCFC-225CA (C3HF5Cl2)
Dichloropentafluoropropane
Hydrochlorofluorocarbon-225CB HCFC-225CB (C3HF5Cl2)
Dichloropentafluoropropane
Hydrochlorofluorocarbon-226 HCFC-226 (C3HF6Cl)
Monochlorohexafluoropropane
Hydrochlorofluorocarbon-231 HCFC-231 (C3H2FCl5)
Pentachlorofluoropropane
Hydrochlorofluorocarbon-232 HCFC-232 (C3H2F2Cl4
Tetrachlorodifluoropropane
Hydrochlorofluorocarbon-233 HCFC-233 (C3H2F3Cl3)
Trichlorotrifluoropropane
Hydrochlorofluorocarbon-234 HCFC-234 (C3H2F4Cl2)
Dichlorotetrafluoropropane
Hydrochlorofluorocarbon-235 HCFC-235 (C3H2F5Cl)
Monochloropentafluoropropane
Hydrochlorofluorocarbon-241 HCFC-241 (C3H3FCl4)
Tetrachlorofluoropropane
Hydrochlorofluorocarbon-242 HCFC-242 (C3H3F2Cl3)
Trichlorodifluoropropane
Hydrochlorofluorocarbon-243 HCFC-243 (C3H3F3Cl2)
Dichlorotrifluoropropane
Hydrochlorofluorocarbon-244 HCFC-244 (C3H3F4Cl)
Monochlorotetrafluoropropane
Hydrochlorofluorocarbon-251 HCFC-251 (C3H4FCl3)
Trichlorofluoropropane
Hydrochlorofluorocarbon-252 HCFC-252 (C3H4F2Cl2)
Dichlorodifluoropropane
Hydrochlorofluorocarbon-253 HCFC-253 (C3H4F3Cl)
Monochlorotrifluoropentane
Hydrochlorofluorocarbon-261 HCFC-261 (C3H5FCl2)
Dichlorofluoropropane
Hydrochlorofluorocarbon-262 HCFC-262 (C3H5F2Cl)
Monochlorodifluoropropane
Hydrochlorofluorocarbon-271 HCFC-271 (C3H6FCl)
Monochlorofluoropropane
Appendix B to the Preamble-Preliminary Listing Decisions
Refrigerants-Acceptable Substitutes
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Application ³ Substitute ³
Initial decision ³ Proposed conditions ³
Comments
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
³ ³
³ ³
CFC-11 Centrifugal ³ 1 HCFC-123 ........ ³
Acceptable ........ ³ ³ EPA
worker-monitoring studies of
Chillers (Retrofits). ³ ³
³ ³ 123 show that
8-hour TWA can be
³ ³
³ ³ kept within 1 ppm
(less than the
³ ³
³ ³ OEL of 10 ppm) when
recycling and
³ ³
³ ³ ASHRAE standards
are followed.
³ ³
³ ³ 123 is the only
available
³ ³
³ ³ retrofit for
low-pressure systems;
³ ³
³ ³ it also has (1) the
lowest ODP of
³ ³
³ ³ all available HCFCs
and (2)
³ ³
³ ³ lowest GWP of all
available HCFCs
³ ³
³ ³ and HFCs.
CFC-11 Centrifugal ³ 1 HCFC-123......... ³
Acceptable ........ ³ ³ EPA
worker-monitoring studies of
Chillers (New Equipment/ ³ ³
³ ³ 123 show that
8-hour TWA can be
Alternative Substances). ³ ³
³ ³ kept within 1ppm
(less than the
³ ³
³ ³ OEL of 10ppm) when
recycling and
³ ³
³ ³ ASHRAE standards
are followed.
³ ³
³ ³ 123 is the only
replacement for
³ ³
³ ³ low-pressure
systems; it also has
³ ³
³ ³ (1) the lowest ODP
of all
³ ³
³ ³ available HCFCs,
and (2) lowest
³ ³
³ ³ GWP of all
available HCFCs and
³ ³
³ ³ HFCs.
³ 1 HCFC-22.......... ³
Acceptable ........ ³ ³ Alternative
Substance replacement
³ ³
³ ³ that will allow
early transition
³ ³
³ ³ out of CFCs in some
uses.
³ 2 HFC-134a......... ³
Acceptable......... ³ ³ Alternative
Substance replacement
³ ³
³ ³ that may be
appropriate in some
³ ³
³ ³ applications.
³ Ammonia Vapor ³
Acceptable ........ ³ ³
..................................
³ Compression ³
³ ³
³ Lithium/bromide/ ³
Acceptable......... ³ ³ Alternative
Substance equipment
³ water absorption ³
³ ³ commercially
available; can be
³ ³
³ ³ operated using
waste heat (e.g.
³ ³
³ ³ steam); can be
source of heated
³ ³
³ ³ water supply; (heat
recovery).
³ Ammonia-water ³
Acceptable......... ³ ³ Alternative
Substance equipment
³ absorption ³
³ ³ commercially
available for many
³ ³
³ ³ years.
CFC-12 Centrifugal ³ 2 HFC-134a......... ³
Acceptable ........ ³ ³
..................................
Chillers (Retrofits). ³ ³
³ ³
CFC-12 Centrifugal ³ 2 HFC-134a......... ³
Acceptable......... ³ ³
..................................
Chillers (New Equipment/ ³ ³
³ ³
Alternative Substances). ³ ³
³ ³
³ 1 HCFC-123......... ³
Acceptable ........ ³ ³ EPA
worker-monitoring studies of
³ ³
³ ³ 123 show that
8-hour TWA can be
³ ³
³ ³ kept within 1ppm
(less than the
³ ³
³ ³ OEL of 10ppm) when
recycling and
³ ³
³ ³ ASHRAE standards
are followed.
³ ³
³ ³ 123 is the only
replacement for
³ ³
³ ³ low-pressure
systems; it also has
³ ³
³ ³ (1) the lowest ODP
of all
³ ³
³ ³ available HCFCs,
and (2) lowest
³ ³
³ ³ GWP of all
available HCFCs and
³ ³
³ ³ HFCs.
³ 1 HCFC-22.......... ³
Acceptable ........ ³ ³ Alternative
Substance replacement
³ ³
³ ³ that will allow
early transition
³ ³
³ ³ out of CFCs in some
uses.
³ Ammonia Vapor ³
Acceptable......... ³ ³
..................................
³ Compression ³
³ ³
³ Ammonia/water ³
Acceptable......... ³ ³ Alternative
Substance equipment
³ absorption ³
³ ³ commercially
available.
³ Lithium/bromide/ ³
Acceptable......... ³ ³ Alternative
Substance equipment
³ water absorption ³
³ ³ commercially
available; can be
³ ³
³ ³ operated using
waste heat (e.g.
³ ³
³ ³ steam); can be
source of heated
³ ³
³ ³ water supply, (heat
recovery).
CFC-12 Reciprocating ³ 2 HFC-134a......... ³
Acceptable ........ ³ ³ Can be
retrofitted if system is
Chillers (Retrofits). ³ ³
³ ³ flushed.
CFC-12 Reciprocating ³ 1 HCFC-22.......... ³
Acceptable......... ³ ³ HCFC-22
systems account for
Chillers (New Equipment/ ³ ³
³ ³ majority (98%) of
reciprocating
Alternative Substances). ³ ³
³ ³ chiller market.
Readily available,
³ ³
³ ³ proven reliability.
Extensive
³ ³
³ ³ research underway
to identify
³ ³
³ ³ zero-ODP,
energy-efficient
³ ³
³ ³ substitutes for
HCFC-22-as
³ ³
³ ³ retrofits and in
new systems.
³ 2 HFC-134a......... ³
Acceptable......... ³ ³
..................................
CFC-12 Household ³ 1 HCFC-22/HFC-152a/ ³
Acceptable ........ ³ ³ To be used as
a service
Refrigerators, Single. ³ HCFC-124 ³
³ ³ refrigerant.
Precautions must be
Evaporator (Retrofits). ³ ³
³ ³ taken during
recycling of blends
³ ³
³ ³ to avoid mixing
with other
³ ³
³ ³ refrigerants.
CFC-12 Household ³ 2 HFC-134a......... ³
Acceptable ........ ³ ³ Leading
candidate as replacement
Refrigerators, Single ³ ³
³ ³ of CFC-12, but
testing still
Evaporator (New Equipment ³ ³
³ ³ underway.
/Alternative Substances). ³ ³
³ ³
³ 2 HFC-152a......... ³
Acceptable ........ ³ ³ Flammability
concerns believed to
³ ³
³ ³ be minor [see
ADL/UL reference
³ ³
³ ³ [#64123]; potential
for significant
³ ³
³ ³ energy efficiency.
CFC-12 Cold Storage ³ 1 HCFC-22.......... ³
Acceptable ........ ³ ³ Currently
more widely available
Warehouses (Retrofits). ³ ³
³ ³ than 134a, which
will allow early
³ ³
³ ³ transition from
CFC-12.
³ 1 HCFC-22/HFC-152a/ ³
Acceptable ........ ³ ³ Users may
experience flammability
³ HCFC-124 ³
³ ³ and/or energy
efficiency problems
³ ³
³ ³ due to potential
differential
³ ³
³ ³ fractionation of
this blend in
³ ³
³ ³ shellside
applications.
³ ³
³ ³ Precautions must be
taken during
³ ³
³ ³ recycling of blends
to avoid
³ ³
³ ³ mixing with other
refrigerants.
³ 2 HFC-134a......... ³
Acceptable ........ ³ ³
..................................
CFC-12 Cold Storage ³ Ammonia............ ³
Acceptable......... ³ ³ Widely
available and practical for
Warehouses (New Equipment ³ ³
³ ³ some (i.e. very
large)
/Alternative Substances). ³ ³
³ ³ applications.
³ 2 HFC-134a......... ³
Acceptable ........ ³ ³ Expected to
be available for
³ ³
³ ³ higher temperatures
near the
³ ³
³ ³ middle of the
decade.
³ 1 HCFC-22.......... ³
Acceptable......... ³ ³ Currently,
more widely available
³ ³
³ ³ than HFC-134a,
which will allow
³ ³
³ ³ early transition
from CFC-12.
³ High to Low ³
Acceptable......... ³ ³
..................................
³ Pressure Stepdown ³
³ ³
³ Process ³
³ ³
CFC-12 Residential ³ 1 HCFC-22/HFC-152a/ ³
Acceptable......... ³ ³ Precautions
must be taken during
Residential Dehumidifiers ³ HCFC-124 ³
³ ³ recycling of blends
to avoid
(Retrofits). ³ ³
³ ³ mixing with other
refrigerants.
³ 2 HFC-134a......... ³
Acceptable......... ³ ³
..................................
CFC-12 Residential ³ 1 HCFC-22.......... ³
Acceptable......... ³ ³
..................................
Residential Dehumidifiers ³ ³
³ ³
(New Equipment/ ³ ³
³ ³
Alternative Substances). ³ ³
³ ³
³ 2 HFC-134a......... ³
Acceptable......... ³ ³
..................................
CFC-12 Residential ³ 1 HCFC-22/HFC-152a/ ³
Acceptable......... ³ ³ Precautions
must be taken during
Freezers (Retrofits). ³ HCFC-124 ³
³ ³ recycling of blends
to avoid
³ ³
³ ³ mixing with other
refrigerants.
CFC-12 Residential ³ 1 HCFC-22.......... ³
Acceptable......... ³ ³ Currently
more widely available
Freezers (New Equipment/ ³ ³
³ ³ than HFC-134a,
which will allow
Alternative Substances). ³ ³
³ ³ early transition
from CFC-12.
³ 2 HFC-152a......... ³
Acceptable......... ³ ³
..................................
³ 2 HFC-134a......... ³
Acceptable......... ³ ³
..................................
CFC-12 Commercial Ice ³ 1 HCFC-22/HFC-152a/ ³
Acceptable......... ³ ³ Precautions
must be taken during
Machines (Retrofits). ³ HCFC-124 ³
³ ³ recycling of blends
to avoid
³ ³
³ ³ mixing with other
refrigerants.
CFC-12 Commercial Ice ³ 1 HCFC-22.......... ³
Acceptable......... ³ ³ Currently
more widely available
Machines (New Equipment/ ³ ³
³ ³ than HFC-134a,
which will allow
Alternative Substances). ³ ³
³ ³ early transition
from CFC-12.
³ 2 HFC-134a......... ³
Acceptable......... ³ ³
..................................
³ Ammonia Vapor ³
Acceptable......... ³ ³
..................................
³ Compression ³
³ ³
CFC-12 Industrial Process ³ 1 HCFC-22.......... ³
Acceptable......... ³ ³ Currently
more widely available
Refrigeration (Retrofits) ³ ³
³ ³ than HFC-134a,
which will allow
³ ³
³ ³ early transition
from CFC-12.
³ 2 HFC-134a......... ³
Acceptable......... ³ ³
..................................
³ 1 HCFC-22/HFC-152a/ ³
Acceptable......... ³ ³ User may
experience flammability
³ HCFC-124 ³
³ ³ and/or energy
efficiency problems
³ ³
³ ³ due to potential
differential
³ ³
³ ³ fractionation of
this blend in
³ ³
³ ³ shellside
applications.
³ ³
³ ³ Precautions must be
taken during
³ ³
³ ³ recycling of blends
to avoid
³ ³
³ ³ mixing with other
refrigerants.
CFC-12 Industrial Process ³ 1 HCFC-22.......... ³
Acceptable......... ³ ³ Currently
more energy efficient
(New Equipment/ ³ ³
³ ³ and more widely
available than
Alternative Substances). ³ ³
³ ³ HFC-134a, which
will allow early
³ ³
³ ³ transition from
CFC-12.
³ ³
³ ³ Technology is
available.
³ 2 HFC-134a......... ³
Acceptable......... ³ ³
..................................
³ Ammonia Vapor ³
Acceptable......... ³ ³
..................................
³ Compression ³
³ ³
³ Chlorine........... ³
Acceptable......... ³ ³ EPA suggests,
but does not require,
³ ³
³ ³ that this
substitute only be used
³ ³
³ ³ at industrial
facilities which
³ ³
³ ³ manufacture or use
chlorine in
³ ³
³ ³ the process stream.
³ Propane............ ³
Acceptable......... ³ ³ EPA suggests,
but does not require,
³ ³
³ ³ that this
substitute only be used
³ ³
³ ³ at industrial
facilities which
³ ³
³ ³ manufacture or use
hydrocarbons
³ ³
³ ³ in the process
stream.
³ Butane............. ³
Acceptable......... ³ ³ EPA suggests,
but does not require,
³ ³
³ ³ that this
substitute only be used
³ ³
³ ³ at industrial
facilities which
³ ³
³ ³ manufacture or use
hydrocarbons
³ ³
³ ³ in the process
stream.
CFC-12 Refrigerated ³ 1 HCFC-22/HFC-152a/ ³
Acceptable......... ³ ³ Precautions
must be taken during
Transport (Retrofits). ³ HCFC-124 ³
³ ³ recycling of blends
to avoid
³ ³
³ ³ mixing with other
refrigerants.
³ 2 HFC-134a......... ³
Acceptable......... ³ ³ Not yet
commercially available.
CFC-12 Refrigerated ³ 1 HCFC-22.......... ³
Acceptable......... ³ ³
..................................
Transport (New Equipment/ ³ ³
³ ³
Alternative Substances). ³ ³
³ ³
³ 2 HFC-134a......... ³
Acceptable......... ³ ³
..................................
CFC-12 Retail Food ³ 1 HCFC-22.......... ³
Acceptable......... ³ ³ Currently
more widely available
(Retrofits). ³ ³
³ ³ than HFC-134a,
which will allow
³ ³
³ ³ early transition
from CFC-12.
³ 2 HFC-134a......... ³
Acceptable......... ³ ³
..................................
³ 1 HCFC-22/HFC-152a/ ³
Acceptable......... ³ ³ Users may
experience flammability
³ HCFC-124 ³
³ ³ and/or energy
efficiency problems
³ ³
³ ³ due to potential
differential
³ ³
³ ³ fractionation of
this blend in
³ ³
³ ³ shellside
applications.
³ ³
³ ³ Precautions must be
taken during
³ ³
³ ³ recycling of blends
to avoid
³ ³
³ ³ mixing with other
refrigerants.
CFC-12 Retail Food (New ³ 1 HCFC-22.......... ³
Acceptable......... ³ ³ Currently
more widely available
Equipment/Alternative ³ ³
³ ³ than HFC-134a,
which will allow
Substances). ³ ³
³ ³ early transition
from CFC-12.
³ 2 HFC-134a......... ³
Acceptable......... ³ ³
..................................
³ Ammonia Vapor ³
Acceptable......... ³ ³
..................................
³ Compression ³
³ ³
CFC-12 Vending Machines ³ 1 HCFC-22.......... ³
Acceptable......... ³ ³ Currently
more widely available
(Retrofits). ³ ³
³ ³ than HFC-134a,
which will allow
³ ³
³ ³ early transition
from CFC-12.
³ 2 HFC-134a......... ³
Acceptable......... ³ ³
..................................
³ 1 HCFC-22/HFC-152a/ ³
Acceptable......... ³ ³ Users may
experience flammability
³ HCFC-124 ³
³ ³ and/or energy
efficiency problems
³ ³
³ ³ due to potential
differential
³ ³
³ ³ fractionation of
this blend in
³ ³
³ ³ shellside
applications.
³ ³
³ ³ Precautions must be
taken during
³ ³
³ ³ recycling of blends
to avoid
³ ³
³ ³ mixing with other
refrigerants.
CFC-12 Vending Machines ³ 1 HCFC-22.......... ³
Acceptable......... ³ ³ Currently
more widely available
(New Equipment/ ³ ³
³ ³ than HFC-134a,
which will allow
Alternative Substances). ³ ³
³ ³ early transition
from CFC-12.
³ 2 HFC-134a......... ³
Acceptable......... ³ ³
..................................
CFC-12 Water Coolers ³ 1 HCFC-22/HFC-152a/ ³
Acceptable......... ³ ³ Precautions
must be taken during
(Retrofits). ³ HCFC-124 ³
³ ³ recycling of blends
to avoid
³ ³
³ ³ mixing with other
refrigerants.
CFC-12 Water Coolers (New ³ 1 HCFC-22.......... ³
Acceptable......... ³ ³ Currently
more widely available
Equipment/Alternative ³ ³
³ ³ than HFC-134a,
which will allow
Substances). ³ ³
³ ³ early transition
from CFC-12.
³ 2 HFC-134a......... ³
Acceptable......... ³ ³
..................................
CFC-12 Mobile Air ³ 2 HFC-134a......... ³
Acceptable......... ³ ³
..................................
Conditioners (Retrofits). ³ ³
³ ³
³ 1 HCFC-22/HFC-152a/ ³
Acceptable......... ³ ³ To be used as
a service
³ HCFC-124 ³
³ ³ refrigerant.
Precautions must be
³ ³
³ ³ taken during
recycling of blends
³ ³
³ ³ to avoid mixing
with other
³ ³
³ ³ refrigerants.
CFC-12 Mobile Air ³ 2 HFC-134a......... ³
Acceptable......... ³ ³
..................................
Conditioners (New ³ ³
³ ³
Equipment/Alternative ³ ³
³ ³
Substances). ³ ³
³ ³
CFC-114 Centrifugal ³ 1 HCFC-124......... ³
Acceptable ........ ³ ³
..................................
Chillers (Retrofits). ³ ³
³ ³
CFC-114 Centrifugal ³ 1 HCFC-124 ........ ³
Acceptable......... ³ ³
..................................
Chillers (New Equipment/ ³ ³
³ ³
Alternative Substances). ³ ³
³ ³
³ 1 HCFC-142b........ ³
Acceptable......... ³ ³
..................................
CFC-500 Centrifugal ³ 2 HFC-134a......... ³
Acceptable......... ³ ³
..................................
Chillers (Retrofits). ³ ³
³ ³
³ 1 HCFC-22/HFC-152a/ ³
Acceptable......... ³ ³ Users may
experience flammability
³ HCFC-124 ³
³ ³ and/or energy
efficiency problems
³ ³
³ ³ due to potential
differential
³ ³
³ ³ fractionation of
this blend in
³ ³
³ ³ shellside
applications.
³ ³
³ ³ Precautions must be
taken during
³ ³
³ ³ recycling of blends
to avoid
³ ³
³ ³ mixing with other
refrigerants.
CFC-500 Centrifugal ³ 2 HFC-134.......... ³
Acceptable ........ ³ ³
..................................
Chillers (New Equipment/ ³ ³
³ ³
Alternative Substances). ³ ³
³ ³
³ 1 HCFC-22 ......... ³
Acceptable......... ³ ³
..................................
³ 1 HCFC-123......... ³
Acceptable......... ³ ³ EPA
worker-monitoring studies of
³ ³
³ ³ 123 show that
8-hour TWA can be
³ ³
³ ³ kept within 1ppm
(less than the
³ ³
³ ³ OEL of 10ppm) when
recycling and
³ ³
³ ³ ASHRAE standards
are followed.
³ ³
³ ³ 123 is the only
replacement for
³ ³
³ ³ low-pressure
systems; it also has
³ ³
³ ³ (1) the lowest ODP
of all
³ ³
³ ³ available HCFCs,
and (2) lowest
³ ³
³ ³ GWP of all
available HCFCs and
³ ³
³ ³ HFCs.
³ Ammonia Vapor ³
Acceptable......... ³ ³
..................................
³ Compression ³
³ ³
³ Lithium/bromide/ ³
Acceptable......... ³ ³ Alternative
Substance equipment
³ water absorption ³
³ ³ commercially
available; can be
³ ³
³ ³ operated using
waste heat (e.g.
³ ³
³ ³ steam); can be
source of heated
³ ³
³ ³ water supply, (heat
recovery).
CFC-500 Residential ³ 1 HCFC-22/HFC-152a/ ³
Acceptable......... ³ ³ Precautions
must be taken during
Dehumidifiers (Retrofits) ³ HCFC-124 ³
³ ³ recycling of blends
to avoid
³ ³
³ ³ mixing with other
refrigerants.
CFC-500 Residential ³ 1 HCFC-22.......... ³
Acceptable......... ³ ³ Currently
more widely available
Dehumidifiers (New ³ ³
³ ³ than HFC-134a,
which will allow
Equipment/Alternative. ³ ³
³ ³ early transition
from CFC-12.
Substances). ³ ³
³ ³
³ 2 HFC-134a......... ³
Acceptable......... ³ ³
..................................
CFC-500 Refrigerated ³ 1 HCFC-22/HFC-152a/ ³
Acceptable......... ³ ³ Precautions
must be taken during
Transport (Retrofits). ³ HCFC-124 ³
³ ³ recycling of blends
to avoid
³ ³
³ ³ mixing with other
refrigerants.
³ 2 HFC-134a......... ³
Acceptable......... ³ ³
..................................
³ 1 HCFC-22/Propane/ ³
Acceptable......... ³ ³ Precautions
must be taken during
³ HFC-125 ³
³ ³ recycling of blends
to avoid
³ ³
³ ³ mixing with other
refrigerants.
CFC-500 Refrigerated ³ 1 HCFC-22.......... ³
Acceptable......... ³ ³ Currently
more widely available
Transport (New Equipment/ ³ ³
³ ³ than HFC-134a,
which will allow
Alternative Substances). ³ ³
³ ³ early transition
from CFC-12.
³ 2 HFC-134a......... ³
Acceptable......... ³ ³
..................................
³ 1 HCFC-22/Propane/ ³
Acceptable......... ³ ³ Flammability
is a concern.
³ HFC-125 ³
³ ³ Precautions must be
taken during
³ ³
³ ³ recycling of blends
to avoid
³ ³
³ ³ mixing with other
refrigerants.
CFC-502 Cold Storage ³ 1 HCFC-22.......... ³
Acceptable......... ³ ³
..................................
Warehouses (Retrofits). ³ ³
³ ³
³ 1 HCFC-22/Propane/ ³
Acceptable......... ³ ³ Flammability
is a concern.
³ HFC-125 ³
³ ³ Precautions must be
taken during
³ ³
³ ³ recycling of blends
to avoid
³ ³
³ ³ mixing with other
refrigerants.
CFC-502 Cold Storage ³ 1 HCFC-22 ......... ³
Acceptable......... ³ ³ Currently
more widely available
Warehouses (New Equipment ³ ³
³ ³ than 125, which
will allow early
/Alternative Substances). ³ ³
³ ³ transition from
CFC-12.
³ 1 HCFC-22/Propane/ ³
Acceptable......... ³ ³ Flammability
is a concern.
³ HFC-125 ³
³ ³ Precautions must be
taken during
³ ³
³ ³ recycling of blends
to avoid
³ ³
³ ³ mixing with other
refrigerants.
³ Ammonia Vapor ³
Acceptable ........ ³ ³
..................................
³ Compression ³
³ ³
CFC-502 Residential ³ 1 HCFC-22.......... ³
Acceptable......... ³ ³
..................................
Freezers (New Equipment/ ³ ³
³ ³
Alternative Substances). ³ ³
³ ³
CFC-502 Commercial Ice ³ 1 HCFC-22.......... ³
Acceptable......... ³ ³
..................................
Machines (New Equipment/ ³ ³
³ ³
Alternative Substances). ³ ³
³ ³
³ Ammonia Vapor ³
Acceptable......... ³ ³
..................................
³ Compression ³
³ ³
CFC-502 Industrial Process ³ 1 HCFC-22.......... ³
Acceptable......... ³ ³ Currently
more widely available
Refrigeration (Retrofits) ³ ³
³ ³ than HFC-134a,
which will allow
³ ³
³ ³ early transition
from CFC-12.
³ 2 HFC-134a......... ³
Acceptable......... ³ ³
..................................
³ 1 HCFC-22/Propane/ ³
Acceptable......... ³ ³ Flammability
is a concern.
³ HFC-125 ³
³ ³ Precautions must be
taken during
³ ³
³ ³ recycling of blends
to avoid
³ ³
³ ³ mixing with other
refrigerants.
CFC-502 Industrial Process ³ 1 HCFC-22.......... ³
Acceptable......... ³ ³ Currently
more efficient and more
Refrigeration (New ³ ³
³ ³ widely available
than HFC-134a,
Equipment/Alternative ³ ³
³ ³ which will allow
early transition
Substances). ³ ³
³ ³ from CFC-12.
³ 2 HFC-134a......... ³
Acceptable......... ³ ³
..................................
³ Ammonia Vapor ³
Acceptable......... ³ ³
..................................
³ Compression ³
³ ³
³ Chlorine........... ³
Acceptable......... ³ ³ EPA suggests,
but does not require,
³ ³
³ ³ that this
substitute only be used
³ ³
³ ³ at industrial
facilities which
³ ³
³ ³ manufacture or use
chlorine in
³ ³
³ ³ the process stream.
³ 1 HCFC-22/Propane/ ³
Acceptable......... ³ ³ Flammability
is a concern.
³ HFC-125 ³
³ ³ Precautions must be
taken during
³ ³
³ ³ recycling of blends
to avoid
³ ³
³ ³ mixing with other
refrigerants.
CFC-502 Refrigerated ³ 1 HCFC-22.......... ³
Acceptable......... ³ ³
..................................
Transport (Retrofits). ³ ³
³ ³
³ 2 HFC-134a......... ³
Acceptable ........ ³ ³
..................................
³ 1 HCFC-22/Propane/ ³
Acceptable......... ³ ³ Flammability
is a concern.
³ HFC-125 ³
³ ³ Precautions must be
taken during
³ ³
³ ³ recycling of blends
to avoid
³ ³
³ ³ mixing with other
refrigerants.
CFC-502 Refrigerated ³ 1 HCFC-22.......... ³
Acceptable......... ³ ³
..................................
Transport (New Equipment/ ³ ³
³ ³
Alternative Substances). ³ ³
³ ³
³ 2 HFC-134a......... ³
Acceptable......... ³ ³
..................................
³ 1 HCFC-22/Propane/ ³
Acceptable......... ³ ³ Flammability
is a concern.
³ HFC-125 ³
³ ³ Precautions must be
taken during
³ ³
³ ³ recycling of blends
to avoid
³ ³
³ ³ mixing with other
refrigerants.
CFC-502 Retail Food ³ 1 HCFC-22.......... ³
Acceptable......... ³ ³
..................................
(Retrofit). ³ ³
³ ³
³ 1 HCFC-22/Propane/ ³
Acceptable......... ³ ³ Flammability
is a concern.
³ HFC-125 ³
³ ³ Precautions must be
taken during
³ ³
³ ³ recycling of blends
to avoid
³ ³
³ ³ mixing with other
refrigerants.
CFC-502 Retail Food (New ³ 1 HCFC-22.......... ³
Acceptable......... ³ ³ Currently
more widely available
Equipment/Alternative ³ ³
³ ³ than 125, which
will allow early
Substances). ³ ³
³ ³ transition from
CFC-12.
³ 1 HCFC-22/Propane/ ³
Acceptable......... ³ ³ Flammability
is a concern.
³ HFC-125 ³
³ ³ Precautions must be
taken during
³ ³
³ ³ recycling of blends
to avoid
³ ³
³ ³ mixing with other
refrigerants.
³ Ammonia............ ³
Acceptable ........ ³ ³
..................................
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Additional Requirements:
1 Use of HCFCs is subject to (1) no venting during servicing
prohibition under section 608, which was effective July 1, 1992,
(2)
recycling requirements under section 608 once they are
promulgated, (3) section 609 motor vehicle air conditioning
regulations,
(4) the phaseout schedule for all Class II chemicals under
section 605, which is currently being revised under EPA's efforts
to
accelerate the phaseout of all ozone-depleting chemicals, and
(5) mandatory recycling.
2 Use of HFCs is subject to the no venting prohibition under
section 608(c)(2), which takes effect November 15, 1995, at the
latest.
Refrigerants Unacceptable Substitutes
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Application ³
Substitute ³ Initial decision ³
Comments
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
³
³ ³
CFC-11 Centrifugal Chillers (New Equipment ³
HCFC-141b........................... ³ Proposed
Unacceptable........ ³ Flammability may be an issue. Has
/Alternative Substances). ³
³ ³ a
high ODP and is not generally
³
³ ³
available in new equipment.
CFC-12 Centrifugal Chillers (Retrofit).... ³
HCFC-22/HCFC-142b/CFC-12............ ³ Proposed
Unacceptable........ ³ As a blend of both Class I and
³
³ ³
Class II chemicals, it poses a
³
³ ³
higher risk of ozone depletion
³
³ ³
than use of Class II alone.
CFC-12 Centrifugal Chillers (New Equipment ³
HCFC-22/HCFC-142b/CFC-12............ ³ Proposed
Unacceptable........ ³ As a blend of both Class I and
/Alternative Substances). ³
³ ³
Class II chemicals, it poses a
³
³ ³
higher risk of ozone depletion
³
³ ³
than use of Class II alone.
CFC-12 Reciprocating Chillers (Retrofit).. ³
HCFC-22/HCFC-142b/CFC-12............ ³ Proposed
Unacceptable........ ³ As a blend of both Class I and
³
³ ³
Class II chemicals, it poses a
³
³ ³
higher risk of ozone depletion
³
³ ³
than use of Class II alone.
CFC-12 Reciprocating Chillers (New ³
HCFC-22/HCFC-142b/CFC-12............ ³ Proposed
Unacceptable........ ³ As a blend of both Class I and
Equipment/Alternative Substances). ³
³ ³
Class II chemicals, it poses a
³
³ ³
higher risk of ozone depletion
³
³ ³
than use of Class II alone.
CFC-12 Household Refrigerators, Single ³
HCFC-22/HCFC-142b/CFC-12............ ³ Proposed
Unacceptable........ ³ As a blend of both Class I and
Evaporator (Retrofit). ³
³ ³
Class II chemicals, it poses a
³
³ ³
higher risk of ozone depletion
³
³ ³
than use of Class II alone.
CFC-12 Cold Storage Warehouses (Retrofit). ³
HCFC-22/HCFC-142b/CFC-12............ ³ Proposed
Unacceptable........ ³ As a blend of both Class I and
³
³ ³
Class II chemicals, it poses a
³
³ ³
higher risk of ozone depletion
³
³ ³
than use of Class II alone.
CFC-12 Cold Storage Warehouses (New ³
HCFC-22/HCFC-142b/CFC-12............ ³ Proposed
Unacceptable........ ³ As a blend of both Class I and
Equipment/Alternative Substances). ³
³ ³
Class II chemicals, it poses a
³
³ ³
higher risk of ozone depletion
³
³ ³
than use of Class II alone.
CFC-12 Residential Freezers (Retrofits)... ³
HCFC-22/HCFC-142b/CFC-12 ........... ³ Proposed
Unacceptable........ ³ As a blend of both Class I and
³
³ ³
Class II chemicals, it poses
³
³ ³
higher risk to ozone depletion
³
³ ³
than use of Class II chemicals
³
³ ³
alone.
CFC-12 Residential Freezers (New Equipment ³
HCFC-22/HCFC-142b/CFC-12............ ³ Proposed
Unacceptable........ ³ As a blend of both Class I and
/Alternative Substances). ³
³ ³
Class II chemicals, it poses a
³
³ ³
higher risk of ozone depletion
³
³ ³
than use of Class II chemicals
³
³ ³
alone.
CFC-12 Industrial Process (Retrofit)...... ³
HCFC-22/HCFC-142b/CFC-12............ ³ Proposed
Unacceptable........ ³ As a blend of both Class I and
³
³ ³
Class II chemicals, it poses a
³
³ ³
higher risk of ozone depletion
³
³ ³
than use of Class II chemicals
³
³ ³
alone.
CFC-12 Retail Food (Retrofit)............. ³
HCFC-22/HCFC-142b/CFC-12............ ³ Proposed
Unacceptable........ ³ As a blend of both Class I and
³
³ ³
Class II chemicals, it poses a
³
³ ³
higher risk of ozone depletion
³
³ ³
than use of Class II chemicals
³
³ ³
alone.
CFC-12 Mobile Air Conditioners (Retrofits) ³
HCFC-22/HCFC-142b/Isobutane ........ ³ Proposed Unacceptable
....... ³ Flammability may be a serious
³
³ ³
issue. Data on flammability,
³
³ ³
fractionation and hose
³
³ ³
permeability is required for full
³
³ ³
evaluation.
³
HCFC-22/HCFC-142b/CFC-12............ ³ Proposed
Unacceptable........ ³ As a blend of both Class I and
³
³ ³
Class II chemicals, it poses a
³
³ ³
higher risk of ozone depletion
³
³ ³
than use of Class II chemicals
³
³ ³
alone.
CFC-12 Mobile Air Conditioners (New ³
HCFC-22/HCFC-142b/CFC-12............ ³ Proposed
Unacceptable........ ³ As a blend of both Class I and
Equipment/Alternative Substances). ³
³ ³
Class II chemicals, it poses a
³
³ ³
higher risk of ozone depletion
³
³ ³
than use of Class II chemicals
³
³ ³
alone.
All CFC-12 Refrigeration Uses............. ³ Hydrocarbon Blend
A................. ³ Proposed Unacceptable........ ³
Flammability may be a serious
³
³ ³
issue. Data on flammability,
³
³ ³
materials compatibility and hose
³
³ ³
permeability is required for full
³
³ ³
evaluation.
CFC-500 Centrifugal Chillers (Retrofit)... ³
HCFC-22/HCFC-142b/CFC-12............ ³ Proposed
Unacceptable........ ³ As a blend of both Class I and
³
³ ³
Class II chemicals, it poses a
³
³ ³
higher risk of ozone depletion
³
³ ³
than use of Class II chemicals
³
³ ³
alone.
All HCFC-22 Refrigeration Uses............ ³
HCFC-22/HCFC-142b/CFC-12 ........... ³ Proposed
Unacceptable........ ³ As a blend of both Class I and
³
³ ³
Class II chemicals, it poses
³
³ ³
higher risk to ozone depletion
³
³ ³
than use of Class II chemicals
³
³ ³
alone.
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Refrigerants-Pending
Decisions
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Application ³ Substitute ³
Comments
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
³ ³
CFC-12 Household Refrigerators, ³ HCFC/HFC/ ³
As discussed earlier, EPA is concerned about the potential
Single Evaporator (Retrofit). ³ fluoroalkane ³
wide use of perfluorinated compounds, particularly in
³ Blend A ³
situations where containment may be difficult to assure. As
³ ³
a result, EPA will be reviewing perfluorinated compound
³ ³
uses to assess the aggregate quantity likely to be used and
³ ³
to determine any necessary emission control.
³ HCFC-22/HCFC-142b. ³
EPA has not yet concluded review of the data.
CFC-12 Household Refrigerators, ³ HCFC/HFC/ ³
As discussed earlier, EPA is concerned about the potential
Single Evaporator (New Equipment/ ³ fluoroalkane ³
wide use of perfluorinated compounds, particularly in
Alternative Substances). ³ Blend A ³
situations where containment may be difficult to assure. As
³ ³
a result, EPA will be reviewing perfluorinated compound
³ ³
uses to assess the aggregate quantity likely to be used and
³ ³
to determine any necessary emission control.
³ HCFC-22/HCFC-142b. ³
EPA has not yet concluded review of the data.
³ R200b............. ³
EPA has not yet concluded review of the data.
CFC-12 Residential Freezers ³ HCFC/HFC/ ³
As discussed earlier, EPA is concerned about the potential
(Retrofits). ³ fluoroalkane ³
wide use of perfluorinated compounds, particularly in
³ Blend A ³
situations where containment may be difficult to assure. As
³ ³
a result, EPA will be reviewing perfluorinated compound
³ ³
uses to assess the aggregate quantity likely to be used and
³ ³
to determine any necessary emission control.
CFC-12 Residential Freezers (New ³ HCFC/HFC/ ³
As discussed earlier, EPA is concerned about the potential
Equipment/Alternative Substances) ³ fluoroalkane ³
wide use of perfluorinated compounds, particularly in
³ Blend A ³
situations where containment may be difficult to assure. As
³ ³
a result, EPA will be reviewing perfluorinated compound
³ ³
uses to assess the aggregate quantity likely to be used and
³ ³
to determine any necessary emission control.
CFC-12 Commercial Ice Machines ³ HFC-125/HFC-143a/ ³
Final decision pending receipt of data on flammability
(New Equipment/Alternative. ³ HFC-134a ³
controls and constituent toxicity of HFC-143a. Precautions
Substances). ³ ³
must be taken during recycling of blends to avoid mixing
³ ³
with other refrigerants.
CFC-12 Refrigerated Transport (New ³ HFC-125/HFC-143a/ ³
Final decision pending receipt of data on flammability
Equipment/Alternative Substances) ³ HFC-134a ³
controls and constituent toxicity of HFC-143a. Precautions
³ ³
must be taken during recycling of blends to avoid mixing
³ ³
with other refrigerants.
CFC-12 Cold Storage............... ³ R200a............. ³
EPA has not yet concluded review of the data.
CFC-12 Mobile Air Conditioners ³ HCFC/HFC/ ³
As discussed earlier, EPA is concerned about the potential
(Retrofits). ³ fluoroalkane ³
wide use of perfluorinated compounds, particularly in
³ Blend A ³
situations where containment may be difficult to assure. As
³ ³
a result, EPA will be reviewing perfluorinated compound
³ ³
uses to assess the aggregate quantity likely to be used and
³ ³
to determine any necessary emission control.
CFC-12 Mobile Air Conditioners ³ HCFC/HFC/ ³
As discussed earlier, EPA is concerned about the potential
(New Equipment/Alternative ³ fluoroalkane ³
wide use of perfluorinated compounds, particularly in
Substances). ³ Blend A ³
situations where containment may be difficult to assure. As
³ ³
a result, EPA will be reviewing perfluorinated compound
³ ³
uses to assess the aggregate quantity likely to be used and
³ ³
to determine any necessary emission control.
CFC-12 Chillers, Heat Pumps and ³ HFC-227ea ........ ³
EPA has not yet concluded review of the data.
Commercial Refrigeration Systems. ³ ³
CFC-12 Refrigerant ............... ³ HCFC-142b......... ³
EPA has not yet concluded review of the data.
CFC-13 Refrigerant................ ³ HFC-23............ ³
EPA requests additional data on the use of this substitute.
CFC-114 Centrifugal Chillers (New ³ R200b............. ³
EPA has not yet concluded review of the data.
Equipment/Alternative Substances) ³ ³
³ R200c............. ³
EPA has not yet concluded review of the data.
³ R200d ............ ³
EPA has not yet concluded review of the data.
³ R200e............. ³
EPA has not yet concluded review of the data.
³ R200f............. ³
EPA has not yet concluded review of the data.
³ R200g............. ³
EPA has not yet concluded review of the data.
³ R200j............. ³
EPA has not yet concluded review of the data.
³ R200i............. ³
EPA has not yet concluded review of the data.
CFC-114 Chillers, Heat Pumps and ³ HFC-227ea ........ ³
EPA has not yet concluded review of the data.
Commercial Refrigeration Systems. ³ ³
CFC-502 Air Conditioning, Heat ³ HFC-143a.......... ³
EPA has not yet concluded review of the data.
Pumps, and Chillers. ³ ³
CFC-502 Cold Storage Warehouses ³ HFC-125........... ³
Final decision pending data addressing efficiency concerns.
(New Equipment/Alternative ³ ³
Can be used as a component in mixtures. Not yet widely
Substances). ³ ³
available.
³ HFC-125/HFC-143a/ ³
Final decision pending receipt of data on flammability
³ HFC-134a ³
controls and constituent toxicity of HFC-143a. Precautions
³ ³
must be taken during recycling of blends to avoid mixing
³ ³
with other refrigerants.
CFC-502 Cold Storage.............. ³ R200a............. ³
EPA has not yet concluded review of the data.
CFC-502 Commercial Ice Machines ³ HFC-125/HFC-143a/ ³
Final decision pending receipt of data on flammability
(New Equipment/Alternative. ³ HFC-134a ³
controls and constituent toxicity of HFC-143a. Precautions
Substances). ³ ³
must be taken during recycling of blends to avoid mixing
³ ³
with other refrigerants.
CFC-502 Industrial Process ³ HFC-143a.......... ³
Pending receipt of data on flammability. Material has high
Refrigeration (New Equipment/. ³ ³
potential GWP.
Alternative Substances). ³ ³
³ HFC-125/HFC-143a/ ³
Final decision pending receipt of data on flammability
³ HFC-134a ³
controls and constituent toxicity of HFC-143a. Precautions
³ ³
must be taken during recycling of blends to avoid mixing
³ ³
with other refrigerants.
CFC-502 Refrigerated Transport ³ HFC-125/HFC-143a/ ³
Final decision pending receipt of data on flammability
(New Equipment/Alternative. ³ HFC-134a ³
controls and constituent toxicity of HFC-143a. Precautions
Substances). ³ ³
must be taken during recycling of blends to avoid mixing
³ ³
with other refrigerants.
CFC-502 Retail Food (New Equipment ³ HFC-125 .......... ³
HFC-125 can be used as a component in mixtures. Data on
/Alternative Substances). ³ ³
efficiency is needed to fully evaluate.
³ HFC-125/HFC-143a/ ³
Final decision pending receipt of data on flammability
³ HFC-134a ³
controls and constituent toxicity of HFC-143a. Precautions
³ ³
must be taken during recycling of blends to avoid mixing
³ ³
with other refrigerants.
³ HFC-143a.......... ³
Pending receipt of data on flammability. Material has high
³ ³
potential GWP.
Heat Pumps ....................... ³ HFC-134a.......... ³
EPA has not yet concluded review of the data.
³ HFC-152a.......... ³
EPA has not yet concluded review of the data.
³ HFC-32............ ³
EPA has not yet concluded review of the data.
³ HFC-125/HFC-134a/ ³
EPA has not yet concluded review of the data.
³ HFC-32 ³
³ R200a............. ³
EPA has not yet concluded review of the data.
Mobile Air Conditioning........... ³ CO2............... ³
EPA has not yet concluded review of the data.
Commercial and Residential Air ³ Evaporative ³
EPA has not yet concluded review of the data.
Conditioners, Cold Storage. ³ Cooling ³
Warehouses, Industrial Cooling, ³ ³
Mobile Air Conditioning. ³ ³
Conventional Air Conditioning..... ³ Dessicant- based ³
EPA has not yet concluded review of the data.
³ Dehumidi- ³
³ fication ³
³ Dessicant-based ³
EPA has not yet concluded review of the data.
³ Natural Gas ³
³ HFC-125/HFC-134a/ ³
EPA has not yet concluded review of the data.
³ HFC-32 ³
³ R200a............. ³
EPA has not yet concluded review of the data.
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Foams-Acceptable Substitutes
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Application ³ Substitute ³
Initial decision ³ Proposed ³
Comments
³ ³
³ conditions ³
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
³ ³
³ ³
CFC-11 Polyurethane, ³ HCFC-123............. ³
Acceptable............................... ³ ..............
³ Recent worker monitoring studies indicate
Rigid Laminated ³ ³
³ ³ OEL
for 123 (10 ppm) can be achieved
Boardstock. ³ ³
³ ³ with
increased ventilation, where needed.
³ ³
³ ³ Very
easy to use as a retrofit; energy
³ ³
³ ³
efficiency close to CFC-11. Current
³ ³
³ ³
availability is limited.
³ HCFC-141b............ ³
Acceptable............................... ³ ..............
³ Only chemical alternative that is or soon
³ ³
³ ³ will
be available in sufficient
³ ³
³ ³
quantities to meet demand of industry.
³ ³
³ ³ Has
highest ODP of HCFCs. Will allow
³ ³
³ ³
virtually immediate transition out of
³ ³
³ ³
CFC-11. Fairly good energy efficiency
³ ³
³ ³
properties.
³ HCFC-142b............ ³
Acceptable............................... ³ ..............
³ Technology not yet available in most
³ ³
³ ³
applications to allow near-term use.
³ ³
³ ³
Increases in thermal conductivity may
³ ³
³ ³
reduce energy efficiency.
³ HCFC-22 ³
Acceptable............................... ³ ..............
³ Technology under development.
³ HCFC-22/HCFC-141b.... ³
Acceptable............................... ³ ..............
³ Technology under development. HCFC-141b
³ ³
³ ³ is
only chemical alternative that is
³ ³
³ ³
currently available in sufficient
³ ³
³ ³
quantities to meet demand of industry
³ ³
³ ³ and
has fairly good energy efficiency
³ ³
³ ³
properties.
³ HCFC-141b/ HCFC-123.. ³
Acceptable............................... ³ ..............
³ Recent worker monitoring studies indicate
³ ³
³ ³ OEL
for 123 (10 ppm) can be achieved
³ ³
³ ³ with
increased ventilation, where needed.
³ ³
³ ³
Fairly good energy efficiency properties.
³ HCFC-22/ HCFC-142b... ³
Acceptable............................... ³ ..............
³ Technology not yet available in most
³ ³
³ ³
applications to allow near-term use.
³ ³
³ ³
Increases in thermal conductivity may
³ ³
³ ³
reduce energy efficiency.
³ HFC-134a............. ³
Acceptable............................... ³ ..............
³ Technology not yet available in most
³ ³
³ ³
applications to allow near-term use.
³ ³
³ ³
Potentially large increases in thermal
³ ³
³ ³
conductivity which will reduce energy
³ ³
³ ³
efficiency.
³ HFC-152a............. ³
Acceptable............................... ³ ..............
³ Technology not yet available in most
³ ³
³ ³
applications to allow near-term use.
³ ³
³ ³
Potentially large increases in thermal
³ ³
³ ³
conductivity which will reduce energy
³ ³
³ ³
efficiency. Flammability may be an issue
³ ³
³ ³ for
workers and consumers.
³ Hydrocarbons (Pentane ³
Acceptable............................... ³ ..............
³ Technology not yet available in most
³ etc.) ³
³ ³
applications to allow near-term use.
³ ³
³ ³
Potentially large increases in thermal
³ ³
³ ³
conductivity which will reduce energy
³ ³
³ ³
efficiency. Flammability may be an issue
³ ³
³ ³ for
workers and consumers. Major sources
³ ³
³ ³ of
VOC emissions are subject to the New
³ ³
³ ³
Source Review (NSR) program.
³ 2-Chloro-propane..... ³
Acceptable............................... ³ ..............
³ Technology under development.
³ ³
³ ³
Flammability may be an issue for workers
³ ³
³ ³ and
consumers.
³ Carbon Dioxide....... ³
Acceptable ³
³
CFC-11 Polyurethane, ³ HCFC-22 ³
Acceptable............................... ³ ..............
³ Technology under development. Increases
Rigid Appliance. ³ ³
³ ³ in
thermal conductivity may reduce
³ ³
³ ³
energy efficiency.
³ HCFC-123............. ³
Acceptable............................... ³ ..............
³ Recent worker monitoring studies indicate
³ ³
³ ³ OEL
for 123 (10 ppm) can be achieved
³ ³
³ ³ with
increased ventilation, where needed.
³ ³
³ ³ Easy
to use as a retrofit; energy
³ ³
³ ³
efficiency close to CFC-11. Current
³ ³
³ ³
availability is limited.
³ HCFC-141b............ ³
Acceptable............................... ³ ..............
³ Only chemical alternative that is or will
³ ³
³ ³ soon
be available in sufficient
³ ³
³ ³
quantities to meet demand of industry.
³ ³
³ ³ Has
highest ODP of HCFCs. Will allow
³ ³
³ ³
virtually immediate transition out of
³ ³
³ ³
CFC-11. Fairly good energy efficiency
³ ³
³ ³
properties.
³ HCFC-142b ........... ³
Acceptable............................... ³ ..............
³ Technology under development. Increases
³ ³
³ ³ in
thermal conductivity may reduce
³ ³
³ ³
energy efficiency.
³ HCFC-22/HCFC-141b ... ³
Acceptable............................... ³ ..............
³ Technology under development. HCFC-141b
³ ³
³ ³ is
only chemical alternative that is
³ ³
³ ³
currently available in sufficient
³ ³
³ ³
quantities to meet demand of industry
³ ³
³ ³ and
has fairly good energy efficiency
³ ³
³ ³
properties.
³ HCFC-22/HCFC-142b.... ³
Acceptable............................... ³ ..............
³ Technology under development. Increases
³ ³
³ ³ in
thermal conductivity may reduce
³ ³
³ ³
energy efficiency.
³ HCFC-123/HCFC-141b .. ³
Acceptable............................... ³ ..............
³ Recent worker monitoring studies indicate
³ ³
³ ³ OEL
for 123 (10 ppm) can be achieved
³ ³
³ ³ with
increased ventilation, where needed.
³ ³
³ ³
Fairly good energy efficiency properties.
³ HFC-134a............. ³
Acceptable............................... ³ ..............
³ Technology not yet available in most
³ ³
³ ³
applications to allow near-term use.
³ ³
³ ³
Potential increases in thermal
³ ³
³ ³
conductivity which will reduce energy
³ ³
³ ³
efficiency.
³ HFC-152a............. ³
Acceptable............................... ³ ..............
³ Technology not yet available in most
³ ³
³ ³
applications to allow near-term use.
³ ³
³ ³
Potential increases in thermal
³ ³
³ ³
conductivity will reduce energy
³ ³
³ ³
efficiency. Flammability may be an issue
³ ³
³ ³ for
workers and consumers.
³ Hydrocarbons (Pentane,³
Acceptable............................... ³ ..............
³ Technology not yet available in most
³ Isopentane, Hexane ³
³ ³
applications to allow near-term use.
³ etc.) ³
³ ³
Potentially large increases in thermal
³ ³
³ ³
conductivity which will reduce energy
³ ³
³ ³
efficiency. Flammability may be an issue
³ ³
³ ³ for
workers and consumers. Major sources
³ ³
³ ³ of
VOC emissions are subject to the New
³ ³
³ ³
Source Review (NSR) program.
³ Carbon Dioxide....... ³
Acceptable............................... ³
³
CFC-11 Polyurethane, ³ HCFC-22.............. ³
Acceptable............................... ³ ..............
³ Technology under development. Increases
Rigid Commercial ³ ³
³ ³ in
thermal conductivity may reduce
Refrigeration Foams, ³ ³
³ ³
energy efficiency.
Spray Foams and ³ ³
³ ³
Sandwich Panel Foams ³ ³
³ ³
³ HCFC-123............. ³
Acceptable............................... ³ ..............
³ Recent worker monitoring studies indicate
³ ³
³ ³ OEL
for 123 (10 ppm) can be achieved
³ ³
³ ³ with
use of increased ventilation, where
³ ³
³ ³
needed. Easy to use as a retrofit;
³ ³
³ ³
energy efficiency close to CFC-11.
³ ³
³ ³
Current availability is limited.
³ HCFC-141b............ ³
Acceptable............................... ³ ..............
³ Only chemical alternative currently or
³ ³
³ ³ soon
to be available in sufficient
³ ³
³ ³
quantities to meet demand of industry.
³ ³
³ ³ Has
highest ODP of the HCFCs. Will allow
³ ³
³ ³
virtually immediate transition out of
³ ³
³ ³
CFC-11. Fairly good energy efficiency
³ ³
³ ³
properties.
CFC-11 Polyurethane, ³ HCFC-142b............ ³
Acceptable............................... ³ ..............
³ Technology under development. Potential
Rigid Commercial ³ ³
³ ³
increases in thermal conductivity which
Refrigeration Foams, ³ ³
³ ³ will
reduce energy efficiency.
etc. (continued). ³ ³
³ ³
³ HCFC-22/142b......... ³
Acceptable............................... ³ ..............
³ Technology under development. Potential
³ ³
³ ³
increases in thermal conductivity which
³ ³
³ ³ will
reduce energy efficiency.
³ HFC-134a............. ³
Acceptable............................... ³ ..............
³ Technology under development. Potential
³ ³
³ ³
increases in thermal conductivity which
³ ³
³ ³ will
reduce energy efficiency.
³ HFC-152a............. ³
Acceptable............................... ³ ..............
³ Technology under development. Potential
³ ³
³ ³
increases in thermal conductivity which
³ ³
³ ³ will
reduce energy efficiency.
³ ³
³ ³
Flammability may be an issue for workers
³ ³
³ ³ and
consumers.
³ Hydrocarbons (Pentane,³
Acceptable............................... ³ ..............
³ Technology under development. Potential
³ Isopentane, Hexane ³
³ ³
increases in thermal conductivity which
³ etc.) ³
³ ³ will
reduce energy efficiency.
³ ³
³ ³
Flammability may be an issue for workers
³ ³
³ ³ and
consumers. Major sources of VOC
³ ³
³ ³
emissions are subject to the New Source
³ ³
³ ³
Review (NSR) program.
³ Carbon Dioxide....... ³
Acceptable............................... ³
³
CFC-11 Polyurethane, ³ HCFC-22.............. ³
Acceptable............................... ³ ..............
³ Technology under development. Increases
Rigid Slabstock and ³ ³
³ ³ in
thermal conductivity may reduce
Other. ³ ³
³ ³
energy efficiency.
³ HCFC-141b............ ³
Acceptable for use in insulating and ³ ..............
³ Only chemical alternative that is or soon
³ ³
flotation foams only ³
³ will be available in sufficient
³ ³
³ ³
quantities to meet demand of industry.
³ ³
³ ³ Will
allow virtually immediate
³ ³
³ ³
transition out of CFC-11. Fairly good
³ ³
³ ³
energy efficiency properties. HCFC-141b
³ ³
³ ³ has
an ODP of 0.11, almost equivalent to
³ ³
³ ³ that
of methyl chloroform, a Class I
³ ³
³ ³
substance. The Agency believes that,
³ ³
³ ³ with
the exception of flotation
³ ³
³ ³
applications, there are other non-ODP
³ ³
³ ³
alternatives, or alternatives with lower
³ ³
³ ³ ODPs,
available for use in packaging,
³ ³
³ ³
decorative, and other noninsulating
³ ³
³ ³
applications. Use of HCFC-141b for
³ ³
³ ³
flotation foams may be restricted
³ ³
³ ³
further under section 610 Non-Essential
³ ³
³ ³ Use
Ban. See HCFC discussion in Preamble
³ ³
³ ³ for
detail.
³ HCFC-123............. ³
Acceptable............................... ³ ..............
³ Recent worker monitoring studies indicate
³ ³
³ ³ OEL
for 123 (10 ppm) can be achieved
³ ³
³ ³
increased ventilation, where needed.
³ ³
³ ³ Easy
to use as a retrofit; energy
³ ³
³ ³
efficiency close to CFC-11. Current
³ ³
³ ³
availability is limited.
³ Hydrocarbons (Pentane,³
Acceptable............................... ³ ..............
³ Technology under development. Potential
³ Isopentane, Butane, ³
³ ³
increases in thermal conductivity which
³ Isobutane etc.) ³
³ ³ will
reduce energy efficiency.
³ ³
³ ³
Flammability may be an issue for workers
³ ³
³ ³ and
consumers. Major sources of VOC
³ ³
³ ³
emissions are subject to the New Source
³ ³
³ ³
Review (NSR) program.
³ Carbon Dioxide....... ³
Acceptable............................... ³
³
CFC-12 Polystyrene, ³ HCFC-22.............. ³
Acceptable............................... ³ ..............
³ Technology under development. Increases
Extruded Boardstock. ³ ³
³ ³ in
thermal conductivity may reduce
³ ³
³ ³
energy efficiency.
³ HCFC-142b............ ³
Acceptable............................... ³ ..............
³ Technology under development. Increases
³ ³
³ ³ in
thermal conductivity may reduce
³ ³
³ ³
energy efficiency
³ HCFC-22/142b......... ³
Acceptable............................... ³ ..............
³ Technology under development. Increases
³ ³
³ ³ in
thermal conductivity may reduce
³ ³
³ ³
energy efficiency.
³ HFC-134a............. ³
Acceptable............................... ³ ..............
³ Technology under development. Potential
³ ³
³ ³
increases in thermal conductivity which
³ ³
³ ³ will
reduce energy efficiency
³ HFC-152a............. ³
Acceptable............................... ³ ..............
³ Technology under development. Potential
³ ³
³ ³
increases in thermal conductivity which
³ ³
³ ³ will
reduce energy efficiency.
³ ³
³ ³
Flammability may be an issue for workers
³ ³
³ ³ and
consumers.
³ Hydrocarbons (Pentane,³
Acceptable............................... ³ ..............
³ Technology under development. Potential
³ Isopentane, Butane, ³
³ ³
increases in thermal conductivity which
³ Isobutane etc.) ³
³ ³ will
reduce energy efficiency.
³ ³
³ ³
Flammability may be an issue for workers
³ ³
³ ³ and
consumers. Major sources of VOC
³ ³
³ ³
emissions are subject to the New Source
³ ³
³ ³
Review (NSR) program.
³ HCFC-22/Hydrocarbons ³
Acceptable............................... ³ ..............
³ Technology under development. Increases
³ (Isopentane etc.) ³
³ ³ in
thermal conductivity may reduce
³ ³
³ ³
energy efficiency. Flammability may be
³ ³
³ ³ an
issues for workers and consumers.
³ Carbon Dioxide....... ³
Acceptable .............................. ³
³
CFC-11, CFC-113 ³ HCFC-141b............ ³
Acceptable............................... ³ ..............
³ Only chemical alternative that is or soon
Phenolic, Insulation ³ ³
³ ³ will
be available in sufficient
Board. ³ ³
³ ³
quantities to meet demand of industry.
³ ³
³ ³ Has
highest OPD of HCFCs. Will allow
³ ³
³ ³
virtually immediate transition out of
³ ³
³ ³
CFC-11. Fairly good energy efficiency
³ ³
³ ³
properties.
³ HCFC-142b............ ³
Acceptable............................... ³ ..............
³ Technology under development. Increases
³ ³
³ ³ in
thermal conductivity may reduce
³ ³
³ ³
energy efficiency.
³ HCFC-22.............. ³
Acceptable............................... ³ ..............
³ Technology under development. Increases
³ ³
³ ³ in
thermal conductivity may reduce
³ ³
³ ³
energy efficiency.
³ HCFC-22/142b......... ³
Acceptable............................... ³ ..............
³ Technology under development. Increases
³ ³
³ ³ in
thermal conductivity may reduce
³ ³
³ ³
energy efficiency.
³ HCFC-22/Hydrocarbons ³
Acceptable............................... ³ ..............
³ Technology under development. Potential
³ (Isopentane etc.) ³
³ ³
increases in thermal conductivity which
³ ³
³ ³ will
reduce energy efficiency.
³ ³
³ ³
Flammability may be an issue for workers
³ ³
³ ³ and
consumers.
³ Hydrocarbons (Pentane,³
Acceptable............................... ³ ..............
³ Technology under development. Potential
³ Isopentane etc.) ³
³ ³
increases in thermal conductivity which
³ ³
³ ³ will
reduce energy efficiency. Major
³ ³
³ ³
sources of VOC emissions are subject to
³ ³
³ ³ the
New Source Review (NSR) program.
³ ³
³ ³
Flammability may be an issue for workers
³ ³
³ ³ and
consumers.
³ 2-Chloropropane...... ³
Acceptable............................... ³ ..............
³ Proprietary technology. Flammability may
³ ³
³ ³ be an
issue for workers and consumers.
³ Carbon Dioxide ³
Acceptable ³
³
CFC-11 Polyurethane, ³ HCFC-123............. ³
Acceptable............................... ³ ..............
³ Current availability is extremely limited.
Flexible. ³ ³
³ ³
Recent worker monitoring studies
³ ³
³ ³
indicate OEL for 123 (10 ppm) can be
³ ³
³ ³
achieved with increased ventilation,
³ ³
³ ³ where
needed. Subject to section 610 Non
³ ³
³ ³
-essential Use Ban.
³ HFC-134a............. ³
Acceptable............................... ³ ..............
³ Technology under development.
³ HFC-152a............. ³
Acceptable............................... ³ ..............
³ Technology under development.
³ ³
³ ³
Flammability may be an issue for workers
³ ³
³ ³ and
consumers.
³ Methylene Chloride... ³
Acceptable............................... ³ ..............
³ Revised OSHA PELs have been proposed at
³ ³
³ ³ 25
ppm (TWA) for methylene chloride (Nov.
³ ³
³ ³ 7,
1991). Subject to meeting all future
³ ³
³ ³
ambient air controls for hazardous air
³ ³
³ ³
pollutants under Title III of the 1990
³ ³
³ ³ CAAA.
³ Acetone.............. ³
Acceptable............................... ³ ..............
³ Regulated as a VOC under Title I of the
³ ³
³ ³ Clean
Air Act. Major sources of VOC
³ ³
³ ³
emissions are subject to the New Source
³ ³
³ ³
Review (NSR) program. Flammability may
³ ³
³ ³ be an
issue for workers and consumers.
³ AB Technology........ ³
Acceptable............................... ³ ..............
³ AB generates more carbon monoxide (CO)
³ ³
³ ³ than
other blowing agents. OSHA has set
³ ³
³ ³ a PEL
for CO at 35 ppm TWA with a
³ ³
³ ³
ceiling of 200 ppm.
³ Carbon Dioxide....... ³
Acceptable .............................. ³
³
CFC-11 Polyurethane, ³ HCFC-22.............. ³
Acceptable............................... ³ ..............
³ Technology not yet available in most
Integral Skin. ³ ³
³ ³
applications to allow near-team use.
³ ³
³ ³
Subject to section 610 Non-essential Use
³ ³
³ ³ Ban.
³ HCFC-123............. ³
Acceptable............................... ³ ..............
³ Recent worker monitoring studies
³ ³
³ ³
indicates OEL for HCFC-123 (10 ppm) can
³ ³
³ ³ be
achieved with increased ventilation,
³ ³
³ ³ where
needed. Very easy to use as a
³ ³
³ ³
retrofit; energy efficiency close to CFC
³ ³
³ ³ -11.
Current availability is extremely
³ ³
³ ³
limited. Subject to section 610 Non-
³ ³
³ ³
essential Use Ban.
³ HCFC-141b............ ³
Acceptable only for uses which provide ³ ..............
³ Only chemical alternative that is
³ ³ for
motor vehicle safety in accordance ³ ³
currently available in sufficient
³ ³ with
Federal Motor Vehicle Safety ³ ³
quantities to meet demand of industry.
³ ³
Standards ³
³ Will allow virtually immediate
³ ³
³ ³
transition out of CFC-11. HCFC-141b has
³ ³
³ ³ an
ODP of 0.11, almost equivalent to
³ ³
³ ³ that
of methyl chloroform, a Class I
³ ³
³ ³
substance. The Agency believes that,
³ ³
³ ³ with
the exception of motor vehicle
³ ³
³ ³
safety foams, there are other non-ODP
³ ³
³ ³
alternatives, or alternatives with lower
³ ³
³ ³ ODPs,
available for use in integral skin
³ ³
³ ³
foams. See HCFC discussion in Preamble
³ ³
³ ³ for
detail on section 610 Non-Essential
³ ³
³ ³ Use
Ban and motor vehicle safety foams
³ ³
³ ³
exemption.
CFC-11 Polyurethane, ³ HCFC-22/HCFC-141b.... ³
Acceptable only for uses which provide ³ ..............
³ HCFC-141b has an ODP of 0.11, almost
Integral Skin ³ ³ for
motor vehicle safety in accordance ³ ³
equivalent to that of methyl chloroform,
(continued). ³ ³ with
Federal Motor Vehicle Safety ³ ³ a
Class I substance. The Agency believes
³ ³
Standards ³
³ that, with the exception of motor
³ ³
³ ³
vehicle safety foams, there are other
³ ³
³ ³
non-ODP alternatives, or alternatives
³ ³
³ ³ with
lower ODPs, available for use in
³ ³
³ ³
integral skin foams. See HCFC discussion
³ ³
³ ³ in
Preamble for detail on section 610
³ ³
³ ³
Non-Essential Use Ban and motor vehicle
³ ³
³ ³
safety foams exemption.
³ HFC-134a............. ³
Acceptable............................... ³ ..............
³ Technology under development.
³ HFC-152a............. ³
Acceptable............................... ³ ..............
³ Technology under development.
³ ³
³ ³
Flammability may be an issue for workers
³ ³
³ ³ and
consumers.
³ Hydrocarbons (Pentane,³
Acceptable............................... ³ ..............
³ Technology under development. Major
³ Isopentane, Butane ³
³ ³
sources of VOC emissions are subject to
³ etc.) ³
³ ³ the
New Source Review (NSR) program.
³ ³
³ ³
Flammability may be an issue for workers
³ ³
³ ³ and
consumers.
³ Methylene Chloride... ³
Acceptable............................... ³ ..............
³ Revised OSHA PELs have been proposed at
³ ³
³ ³ 25
ppm (TWA) for methylene chloride (Nov.
³ ³
³ ³ 7,
1991). Subject to meeting all future
³ ³
³ ³
ambient air controls for hazardous air
³ ³
³ ³
pollutant under Title III of the 1990
³ ³
³ ³ CAAA.
³ Carbon Dioxide....... ³
Acceptable .............................. ³
³
CFC-12 Polystyrene, ³ HFC-134a............. ³
Acceptable............................... ³ ..............
³ Technology not yet available in most
Extruded Sheet. ³ ³
³ ³
applications to allow near-term use.
³ HFC-152a............. ³
Acceptable............................... ³ ..............
³ Technology not yet available in most
³ ³
³ ³
applications to allow near-term use.
³ ³
³ ³
Flammability may be an issue for workers
³ ³
³ ³ and
consumers.
³ Hydrocarbons (Pentane,³
Acceptable............................... ³ ..............
³ Major sources of VOC emissions are
³ Isopentane, Butane, ³
³ ³
subject to the New Source Review (NSR)
³ Isobutane etc.) ³
³ ³
program. Flammability may be an issue
³ ³
³ ³ for
workers and consumers.
³ Carbon Dioxide ...... ³
Acceptable .............................. ³
³
CFC-12, CFC-114, CFC- ³ HCFC-22.............. ³
Acceptable............................... ³ ..............
³ Technology not yet available in most
11 Polyolefin. ³ ³
³ ³
applications to allow near-term use.
³ HCFC-142b ........... ³
Acceptable............................... ³ ..............
³ Technology not yet available in most
³ ³
³ ³
applications to allow near-term use.
³ HCFC-22/HCFC-142b.... ³
Acceptable............................... ³ ..............
³ Technology not yet available in most
³ ³
³ ³
applications to allow near-term use.
³ HCFC-22/Hydrocarbons ³
Acceptable............................... ³ ..............
³ Technology under development. Major
³ (Isopentane etc.) ³
³ ³
sources of VOC emissions are subject to
³ ³
³ ³ the
New Source Review (NSR) program.
³ ³
³ ³
Flammability may be an issue for workers
³ ³
³ ³ and
consumers.
³ HFC-134a............. ³
Acceptable............................... ³ ..............
³ Technology not yet available in most
³ ³
³ ³
applications to allow near-term use.
³ HFC-152a............. ³
Acceptable............................... ³ ..............
³ Technology not yet available in most
³ ³
³ ³
applications to allow near-term use.
³ ³
³ ³
Flammability may be an issue for workers
³ ³
³ ³ and
consumers.
³ Hydrocarbons (Butane, ³
Acceptable............................... ³ ..............
³ Technology under development. Major
³ Isopentane etc.) ³
³ ³
sources of VOC emissions are subject to
³ ³
³ ³ the
New Source Review (NSR) program.
³ ³
³ ³
Flammability may be an issue for workers
³ ³
³ ³ and
consumers.
³ Carbon Dioxide....... ³
Acceptable............................... ³
³
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Foams.-Unacceptable
Substitutes
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Application ³ Substitute ³ Initial
decisions ³ Comments
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
³ ³
³
CFC-11 ³ HCFC-141b (or ³ Proposed
³ HCFC-141b has an ODP of 0.11, almost equivalent to that
of
polyurethane, ³ blends thereof) ³ unacceptable
³ methyl chloroform, a Class I substance. The Agency
believes
rigid slabstock ³ ³ except for
³ that, with the exception of flotation applications,
there
and other. ³ ³ insulation and
³ are other non-ODP alternatives, or alternatives with
lower
³ ³ flotation
foams ³ ODPs, available for use in packaging, decorative,
and other
³ ³
³ noninsulating applications. Use of HCFC-141b may be
³ ³
³ restricted further under section 610 Non-Essential Use
Ban.
³ ³
³ See HCFC discussion in Preamble for details.
CFC-11 ³ HCFC-141b (or ³ Proposed
³ HCFC-141b has an ODP of 0.11, almost equivalent to that
of
polyurethane, ³ blends thereof) ³ unacceptable
³ methyl chloroform, a Class I substance. The Agency
believes
flexible. ³ ³
³ that non-ODP alternatives are sufficiently available to
³ ³
³ render the use of HCFC-141b unnecessary in flexible
³ ³
³ polyurethane foams.
CFC-11 ³ HCFC-141b (or ³ Proposed
³ HCFC-141b has an ODP of 0.11, almost equivalent to that
of
polyurethane, ³ blends thereof) ³ unacceptable
³ methyl chloroform, a Class I substance. The Agency
believes
integral skin. ³ ³ except for use
in ³ that, with the exception of motor vehicle safety foams,
³ ³ motor vehicle
³ there are other non-ODP alternatives, or alternatives
with
³ ³ safety foams.
³ lower ODPs, available for use in integral skin foams.
See
³ ³
³ HCFC discussion in Preamble for details on section 610
Non-
³ ³
³ Essential Use Ban and motor vehicle safety foams
CFC-114, CFC-12, ³ HCFC-141b (or ³ Proposed
³ HCFC-141b has an ODP of 0.11, almost equivalent to that
of
CFC-11 polyolefin ³ blends thereof) ³ unacceptable
³ methyl chloroform, a Class I substance. The Agency
believes
³ ³
³ that non-ODP alternatives, or alternatives with lower
ODPs,
³ ³
³ are sufficiently available to render the use of
HCFC-141b
³ ³
³ unnecessary in polyolefin foams. See HCFC discussion in
³ ³
³ Preamble for details on section 610 Non-Essential Use
Ban
³ ³
³ and motor vehicle safety foams.
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Foams.-Pending Substitutes
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Application ³
Substitute ³
Comments
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
³
³
CFC-11, CFC-113 polyurethane, ³ Alternative products:
expanded polystyrene, ³ Agency has not completed
review of data.
rigid laminated boardstock. ³ fiberboard, fiberglass
³
CFC-11, CFC-113 rigid polyurethane,³ Alternative products:
fiberglass, vacuum panels ... ³ Agency has not completed
review of data.
appliance foams. ³
³
CFC-11 polyurethane, rigid ³ Alternative products:
fiberglass, expanded ³ Agency has not completed
review of data.
slabstock and other. ³ polystyrene
³
CFC-11 polyurethane, rigid spray ³ Alternative products:
fiberglass, expanded ³ Agency has not completed
review of data.
and commercial refrigeration. ³ polystyrene
³
foams, and sandwich panels. ³
³
CFC-11, CFC-113 phenolic ......... ³ HFC-143a
.......................................... ³ Pending receipt
of additional data.
³ Alternative products:
fiberglass, expanded ³ Agency has not completed
review of data.
³ polystyrene
³
CFC-11 polyurethane, flexible..... ³ Alternative technologies:
new polyol technologies.. ³ Agency has not completed review of
data.
³ Enviro-Cure
Process................................ ³ Agency has not
completed review of data.
³ Alternative products:
fiberfill, natural latex ³ Agency has not completed
review of data.
³ foams, polyester batting
³
Foams, alternative process ....... ³ Electroset process
................................ ³ Insufficient data. Also
need information on
³
³ proposed end-use.
CFC-12, CFC-114 polystyrene, ³ HCFC-22/isopentane
blend........................... ³ Agency has not completed
review of data. Also need
extruded. ³
³ more data on proposed end use:
sheet and/or
³
³ boardstock.
³ HFC-124
........................................... ³ Insufficient
data. Also need information of
³
³ proposed end-use: sheet and/or
boardstock.
³ HFC-125
........................................... ³ Insufficient
data. Also need information of
³
³ proposed end-use: sheet and/or
boardstock.
³ HFC-143a
.......................................... ³ Insufficient
data. Also need information of
³
³ proposed end-use: sheet and/or
boardstock.
CFC-12, CFC-114 polystyrene, ³ Alternative products:
expanded polystyrene, ³ Agency has not completed
review of data.
extruded boardstock. ³ fiberboard
³
CFC-12, CFC-114 polyolefin ....... ³
HFC-143a........................................... ³ Agency
has not completed review of data.
³ Alternative products:
paper, cardboard, expanded ³ Agency has not completed
review of data.
³ polystyrene
³
Polyurethane, rigid/frothing ³ HFC-143a
.......................................... ³ Insufficient
data.
process. ³
³
Polyurethane, rigid .............. ³ HFC-356
........................................... ³ Insufficient
data. Also need information on
³
³ proposed end-use.
Blowing Agent .................... ³
³
³ HFC-227ea/pentane
................................. ³ Insufficient data. Also
need information on
³
³ proposed end-uses.
³ HFC-227ea/2-methylpropane
......................... ³ Insufficient data. Also need
information on
³
³ proposed end-uses.
³ Nitrogen gas
...................................... ³ Insufficient data.
Also need information on
³
³ proposed end-uses.
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Solvent
Cleaning-Acceptable Substitutes
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Application ³ Substitute
³ Initial decision ³ Proposed ³
Comments
³
³ ³ condition ³
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
³
³ ³ ³
Metals cleaning w/ CFC- ³ Aqueous cleaners..................
³ Acceptable ......... ³ ............. ³ EPA expects
to issue effluent
113, MCF. ³
³ ³ ³ guidelines
for this industry
³
³ ³ ³ under the
Clean Water Act by 1994.
³
³ ³ ³
Constituents should be drawn from
³
³ ³ ³ the
Agency's list of cleaner
³
³ ³ ³
components, available from the
³
³ ³ ³ SNAP
Coordinator.
³ Semi-aqueous cleaners (terpenes/
³ Acceptable ......... ³ ............. ³ EPA expects
to issue effluent
³ surfactants)
³ ³ ³ guidelines
for this industry
³
³ ³ ³ under the
Clean Water Act by 1994.
³
³ ³ ³
Constituents should be drawn from
³
³ ³ ³ the
Agency's list of cleaner
³
³ ³ ³
components, available from the
³
³ ³ ³ SNAP
Coordinator.
³ Semi-aqueous cleaners (alcohols)..
³ Acceptable ......... ³ ............. ³ EPA expects
to issue effluent
³
³ ³ ³ guidelines
for this industry
³
³ ³ ³ under the
Clean Water Act by 1994.
³
³ ³ ³
Constituents should be drawn from
³
³ ³ ³ the
Agency's list of cleaner
³
³ ³ ³
components, available from the
³
³ ³ ³ SNAP
Coordinator.
³ Semi-aqueous cleaners (petroleum-
³ Acceptable ......... ³ ............. ³ EPA expects
to issue effluent
³ based)
³ ³ ³ guidelines
for this industry
³
³ ³ ³ under the
Clean Water Act by 1994.
³
³ ³ ³
Constituents should be drawn from
³
³ ³ ³ the
Agency's list of cleaner
³
³ ³ ³
components, available from the
³
³ ³ ³ SNAP
Coordinator.
³ Organic solvents (esters, ketones,
³ Acceptable.......... ³ ............. ³ OSHA
standards must be met, if
³ ethers, etc.)
³ ³ ³
applicable. EPA investigating
³
³ ³ ³ workplace
exposures where no OSHA
³
³ ³ ³ standards
exist.
³ Trichloro-ethylene, perchloro-
³ Acceptable ......... ³ ............. ³ OSHA
standards must be met. EPA
³ ethylene, methylene chloride
³ ³ ³ expects to
issue Maximum
³
³ ³ ³ Achievable
Control Technology
³
³ ³ ³
requirements under the Clean Air
³
³ ³ ³ Act for
this application by 1994.
³ Supercritical fluids, plasma
³ Acceptable ......... ³ ............. ³ OSHA
standards for ozone must be
³ cleaning, UV/Ozone cleaning
³ ³ ³ met.
Electronics cleaning w/ ³ Aqueous cleaners..................
³ Acceptable ......... ³ ............. ³ EPA expects
to issue effluent
CFC-113, MCF. ³
³ ³ ³ guidelines
for this industry
³
³ ³ ³ under the
Clean Water Act by 1994.
³
³ ³ ³
Constituents should be drawn from
³
³ ³ ³ the
Agency's list of cleaner
³
³ ³ ³
components, available from the
³
³ ³ ³ SNAP
Coordinator.
³ Semi-aqueous cleaners (terpenes/
³ Acceptable ......... ³ ............. ³ EPA expects
to issue effluent
³ surfactants)
³ ³ ³ guidelines
for this industry
³
³ ³ ³ under the
Clean Water Act by 1994.
³
³ ³ ³
Constituents should be drawn from
³
³ ³ ³ the
Agency's list of cleaner
³
³ ³ ³
components, available from the
³
³ ³ ³ SNAP
Coordinator.
³ Semi-aqueous cleaners (alcohols)..
³ Acceptable ......... ³ ............. ³ EPA expects
to issue effluent
³
³ ³ ³ guidelines
for this industry
³
³ ³ ³ under the
Clean Water Act by 1994.
³
³ ³ ³
Constituents should be drawn from
³
³ ³ ³ the
Agency's list of cleaner
³
³ ³ ³
components, available from the
³
³ ³ ³ SNAP
Coordinator.
³ Semi-aqueous cleaners (petroleum-
³ Acceptable ......... ³ ............. ³ EPA expects
to issue effluent
³ based)
³ ³ ³ guidelines
for this industry
³
³ ³ ³ under the
Clean Water Act by 1994.
³
³ ³ ³
Constituents should be drawn from
³
³ ³ ³ the
Agency's list of cleaner
³
³ ³ ³
components, available from the
³
³ ³ ³ SNAP
Coordinator.
³ Organic solvents (esters,
ketones,³ Acceptable.......... ³ ............. ³
OSHA standards must be met, if
³ ethers, etc.)
³ ³ ³
applicable.
³ Trichloro-ethylene, perchloro-
³ Acceptable ......... ³ ............. ³ OSHA
standards must be met. EPA
³ ethylene, methylene chloride
³ ³ ³ expects to
issue Maximum
³
³ ³ ³ Achievable
Control Technology
³
³ ³ ³
requirements under the Clean Air
³
³ ³ ³ Act for
this application by 1994.
³ No-clean alternatives.............
³ Acceptable.......... ³ ............. ³ Approval
covers low solids fluxes
³
³ ³ ³ and inert
gas soldering.
³ Supercritical fluids, plasma
³ Acceptable ......... ³ ............. ³ OSHA
standards for ozone must be
³ cleaning, UV/Ozone cleaning
³ ³ ³ met.
³ Perfluoro-carbons.................
³ Acceptable for spot- ³ ............. ³ Under SNAP,
EPA has reviewed and
³
³ free cleaning and ³ ³ found
acceptable only certain
³
³ drying of high- ³ ³ narrowly
defined uses of
³
³ performance ³ ³
perfluorinated compounds. Wider
³
³ computer components ³ ³ use of
perfluorinated compounds
³
³ where no other ³ ³ (e.g.,
basic metal cleaning or
³
³ alternative exists ³ ³ circuit
board defluxing) is of
³
³ ³ ³ concern
due to long atmospheric
³
³ ³ ³ lifetimes,
and potential to
³
³ ³ ³ contribute
to global warming.
Precision cleaning w/CFC ³ Aqueous cleaners..................
³ Acceptable ......... ³ ............. ³ EPA expects
to issue effluent
-113, MCF. ³
³ ³ ³ guidelines
for this industry
³
³ ³ ³ under the
Clean Water Act by 1994.
³
³ ³ ³
Constituents should be drawn from
³
³ ³ ³ the
Agency's list of cleaner
³
³ ³ ³
components, available from the
³
³ ³ ³ SNAP
Coordinator.
³ Semi-aqueous cleaners (terpenes/
³ Acceptable ......... ³ ............. ³ EPA expects
to issue effluent
³ surfactants)
³ ³ ³ guidelines
for this industry
³
³ ³ ³ under the
Clean Water Act by 1994.
³
³ ³ ³
Constituents should be drawn from
³
³ ³ ³ the
Agency's list of cleaner
³
³ ³ ³
components, available from the
³
³ ³ ³ SNAP
Coordinator.
³ Semi-aqueous cleaners (alcohols)..
³ Acceptable ......... ³ ............. ³ EPA expects
to issue effluent
³
³ ³ ³ guidelines
for this industry
³
³ ³ ³ under the
Clean Water Act by 1994.
³
³ ³ ³
Constituents should be drawn from
³
³ ³ ³ the
Agency's list of cleaner
³
³ ³ ³
components, available from the
³
³ ³ ³ SNAP
Coordinator.
³ Semi-aqueous cleaners (petroleum-
³ Acceptable.......... ³ ............. ³ EPA expects
to issue effluent
³ based)
³ ³ ³ guidelines
for this industry
³
³ ³ ³ under the
Clean Water Act by 1994.
³
³ ³ ³
Constituents should be drawn from
³
³ ³ ³ the
Agency's list of cleaner
³
³ ³ ³
components, available from the
³
³ ³ ³ SNAP
Coordinator.
³ Organic solvents (esters, ketones,
³ Acceptable.......... ³ ............. ³ OSHA
standards must be met, if
³ ethers, etc.)
³ ³ ³
applicable. EPA investigating
³
³ ³ ³ workplace
exposures where no OSHA
³
³ ³ ³ standards
exist.
³ Trichloro-ethylene, perchloro-
³ Acceptable ......... ³ ............. ³ OSHA
standards must be met. EPA
³ ethylene, methylene chloride
³ ³ ³ expects to
issue Maximum
³
³ ³ ³ Achievable
Control Technology
³
³ ³ ³
requirements for this application
³
³ ³ ³ by 1994.
³ Supercritical fluids, plasma
³ Acceptable ......... ³ ............. ³ OSHA
standards for ozone must be
³ cleaning, UV/Ozone cleaning
³ ³ ³ met.
³ Perfluoro-carbons.................
³ Acceptable for spot- ³ ............. ³ Under SNAP,
EPA has reviewed and
³
³ free cleaning and ³ ³ found
acceptable only certain
³
³ drying of high- ³ ³ narrowly
defined uses of
³
³ performance ³ ³
perfluorinated compounds. Wider
³
³ computer components ³ ³ use of
perfluorinated compounds
³
³ where no other ³ ³ (e.g.,
circuit board defluxing or
³
³ alternative exists ³ ³ basic
metal cleaning) is of
³
³ ³ ³ concern
due to long atmospheric
³
³ ³ ³ lifetimes,
and potential to
³
³ ³ ³ contribute
to global warming.
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Solvent
Cleaning-Unacceptable Substitutes
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Application ³ Substitute ³
Initial decision ³ Comments
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
³ ³
³
Metals cleaning w/ ³ HCFC 141b and ³ Proposed
unacceptable with limited ³ High ODP; other alternatives
exist. Effective date:
CFC-113. ³ blends with ³ critical use
exemptions ³ As of 30 days after final rule for new
equipment;
³ alcohols ³
³ as of January 1, 1996 for existing
equipment. EPA
³ ³
³ will grant limited critical use
exemptions where
³ ³
³ all other substitutes fail to meet
safety or
³ ³
³ performance standards.
Metals cleaning w/ ³ HCFC 141b blends ³ Proposed
unacceptable ............ ³ High ODP; other alternatives
exist. Effective date:
MCF. ³ with alcohols ³
³ As of 30 days after final rule for new
equipment;
³ ³
³ as of January 1, 1996 for existing
equipment.
Electronics ³ HCFC 141b and ³ Proposed
unacceptable with limited ³ High ODP; other alternatives
exist. Effective date:
cleaning w/CFC-. ³ blends with ³ critical use
exemptions ³ As of 30 days after final rule for new
equipment;
113. ³ alcohols ³
³ as of January 1, 1996 for existing
equipment. EPA
³ ³
³ will grant limited critical use
exemptions where
³ ³
³ all other substitutes fail to meet
safety or
³ ³
³ performance standards.
Electronics ³ HCFC 141b blends ³ Proposed
unacceptable ............ ³ High ODP; other alternatives
exist. Effective date:
cleaning w/MCF. ³ with alcohols ³
³ As of 30 days after final rule for new
equipment;
³ ³
³ as of January 1, 1996 for existing
equipment.
Precision cleaning ³ HCFC 141b and ³ Proposed
unacceptable with limited ³ High ODP; other alternatives
exist. Effective date:
w/CFC-113. ³ blends with ³ critical use
exemptions ³ As of 30 days after final rule for new
equipment;
³ alcohols ³
³ as of January 1, 1996 for existing
equipment. EPA
³ ³
³ will grant limited critical use
exemptions where
³ ³
³ all other substitutes fail to meet
safety or
³ ³
³ performance standards.
Precision cleaning ³ HCFC 141b blends ³ Proposed
unacceptable............. ³ High ODP; other alternatives
exist. Effective date:
w/MCF. ³ with alcohols ³
³ As of 30 days after final rule for new
equipment;
³ ³
³ as of January 1, 1996 for existing
equipment.
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Solvent Cleaning-Pending
Decisions
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Application ³ Substitute ³
Comments
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
³ ³
Metals cleaning w/ ³ Monochloro-toluene/benzo- ³
Agency has not completed review of data.
CFC-113, MCF. ³ trifluorides ³
³ Brominated hydrocarbons........... ³
Agency has not completed review of data.
³ Volatile methyl siloxanes......... ³
Agency has not completed review of data.
³ ³
Preliminary indications are that this substitute
³ ³
merits approval.
Electronics ³ Brominated hydrocarbons........... ³
Agency has not completed review of data.
Cleaning w/CFC- ³ ³
113, MCF. ³ ³
Precision cleaning ³ Brominated hydrocarbons .......... ³
Agency has not completed review of data.
w/CFC-113, MCF. ³ ³
³ HCFC-123 ......................... ³
More information needed on feasibility of achieving
³ ³
OEL. EPA investigating toxicity concerns.
³ HCFC-225.......................... ³
Toxicity data yet to be completed. HCFC-225cb
³ ³
isomer is of commercial interest, but toxicity
³ ³
concerns may limit interest in the ca-isomer.
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Halons-Acceptable
Substitutes
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Application ³ Substitute ³ Initial
decision ³ Proposed ³ Comments
³ ³
³ conditions ³
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
³ ³
³ ³
Halon 1211 ³ HBFC-22B1......... ³ Acceptable in
non- ³ .................. ³ ODP of compound (.74)
precludes
Streaming Agents- ³ ³ residential
uses ³ ³ acceptability of widespread
use
Consumer. ³ ³ only
³ ³ in consumer applications. Will
be
Applications. ³ ³
³ ³ phased out (except for
essential
³ ³
³ ³ uses) January 1, 1996.
³ ³
³ ³ Anticipated exposure levels in
³ ³
³ ³ consumer applications exceed
³ ³
³ ³ toxic levels.
³ ³
³ ³ This agent was submitted to the
³ ³
³ ³ Agency as a Premanufacture
Notice
³ ³
³ ³ (PMN) and is presently subject
to
³ ³
³ ³ requirements contained in a
Toxic
³ ³
³ ³ Substance Control Act (TSCA)
³ ³
³ ³ Consent Order.
³ HCFC-123 ......... ³
Acceptable........ ³ ³
³ [HCFC Blend] B ... ³
Acceptable........ ³ .................. ³ Contains small
percentage of PFC
³ ³
³ ³ which has an unusually long
³ ³
³ ³ atmospheric lifetime, and
could
³ ³
³ ³ potentially contribute to
global
³ ³
³ ³ climate change. EPA suggests
but
³ ³
³ ³ does not require that users
³ ³
³ ³ minimize emissions by
minimizing
³ ³
³ ³ use during training, and by
³ ³
³ ³ recovery and recycling during
³ ³
³ ³ maintenance and servicing.
³ [CFC Blend]....... ³ Acceptable in
non- ³ .................. ³ Not commercialized for
residential
³ ³ residential
uses ³ ³ use.
³ ³ only
³ ³
³ ³
³ ³ [CFC Blend] can help transition
³ ³
³ ³ away from halon 1211 in
³ ³
³ ³ applications requiring a
highly
³ ³
³ ³ effective fire extinguishant
with
³ ³
³ ³ low toxicity.
³ ³
³ ³ Because CFCs are a Class I
³ ³
³ ³ substance, production will be
³ ³
³ ³ phased out by January 1, 1996.
³ ³
³ ³ The manufacturer notes that
this
³ ³
³ ³ agent is not suitable for
Class B
³ ³
³ ³ fires involving escaping
gases.
³ Carbon Dioxide.... ³
Acceptable........ ³ .................. ³ Not rated for
use against Class A
³ ³
³ ³ fires.
³ Dry Chemical...... ³
Acceptable........ ³ .................. ³ Can result in
temporary loss of
³ ³
³ ³ visibility if discharged in
³ ³
³ ³ confined areas.
³ Water............. ³
Acceptable........ ³ .................. ³ Not suitable
for use against
³ ³
³ ³ electrical fires (Class C).
³ Foam.............. ³
Acceptable........ ³ .................. ³ Effective
against flammable
³ ³
³ ³ liquids. Can also be used
against
³ ³
³ ³ Class A fires.
³ ³
³ ³ Not suitable for discharge onto
³ ³
³ ³ live electrical equipment.
Halon 1211 ³ HBFC-22B1 ........ ³
Acceptable........ ³ .................. ³ Proper
procedures regarding the
Streaming Agents- ³ ³
³ ³ operation of the extinguisher
and
Commercial/ ³ ³
³ ³ ventilation following
dispensing
Industrial ³ ³
³ ³ the extinguishant is
recommended.
Applications. ³ ³
³ ³ Worker exposure may be a
concern
³ ³
³ ³ in small office areas.
³ ³
³ ³ Acceptability in commercial
³ ³
³ ³ applications will accelerate
the
³ ³
³ ³ transition away from Halon
1211
³ ³
³ ³ which has a significantly
higher
³ ³
³ ³ ODP.
³ ³
³ ³ HBFC-22B1 is considered an
interim
³ ³
³ ³ substitute for Halon 1211.
³ ³
³ ³ Because the HBFC-22B1 has an
ODP
³ ³
³ ³ of .74, production will be
phased
³ ³
³ ³ out (except for essential
uses)
³ ³
³ ³ on January 1, 1996.
³ ³
³ ³ This agent was submitted to the
³ ³
³ ³ Agency as a Premanufacture
Notice
³ ³
³ ³ (PMN) and is presently subject
to
³ ³
³ ³ requirements contained in a
Toxic
³ ³
³ ³ Substance Control Act (TSCA)
³ ³
³ ³ Consent Order.
³ HCFC-123 ......... ³ Acceptable
....... ³ .................. ³
..................................
³ [HCFC Blend] B ... ³ Acceptable
....... ³ .................. ³ Contains small percentage
of PFC
³ ³
³ ³ which has an unusually long
³ ³
³ ³ atmospheric lifetime, and
could
³ ³
³ ³ potentially contribute to
global
³ ³
³ ³ climate change. EPA suggests
but
³ ³
³ ³ does not require that users
³ ³
³ ³ minimize emissions by
minimizing
³ ³
³ ³ use during training, and by
³ ³
³ ³ recovery and recycling during
³ ³
³ ³ maintenance and servicing.
³ [CFC Blend] ...... ³
Acceptable........ ³ .................. ³ [CFC Blend] can
help transition
³ ³
³ ³ away from halon 1211 in
³ ³
³ ³ applications requiring a
highly
³ ³
³ ³ effective fire extinguishant
with
³ ³
³ ³ low toxicity.
³ ³
³ ³ Because CFCs are a Class I
³ ³
³ ³ substance, production will be
³ ³
³ ³ phased out by January 1, 1996.
³ ³
³ ³ The manufacturer notes that
this
³ ³
³ ³ agent is not suitable for
Class B
³ ³
³ ³ fires involving escaping
gases.
³ Dry Chemical...... ³
Acceptable........ ³ .................. ³ Can result in
temporary loss of
³ ³
³ ³ visibility if discharged in
³ ³
³ ³ confined areas.
³ Carbon Dioxide.... ³
Acceptable........ ³ .................. ³ Not rated for
use against Class A
³ ³
³ ³ fires.
³ Water............. ³
Acceptable........ ³ .................. ³ Not suitable
for use against
³ ³
³ ³ electrical fires (Class C).
³ Foam ............. ³ Acceptable
....... ³ .................. ³ Effective against
flammable
³ ³
³ ³ liquids. Can also be used
against
³ ³
³ ³ Class A fires.
³ ³
³ ³ Not suitable for discharge onto
³ ³
³ ³ live electrical equipment.
Halon 1211 ³ HBFC-22B1 ........ ³ Acceptable
....... ³ .................. ³ Acceptability in
commercial
Streaming Agents- ³ ³
³ ³ applications will accelerate
the
Military ³ ³
³ ³ transition away from Halon
1211
Applications. ³ ³
³ ³ which has a significantly
higher
³ ³
³ ³ ODP.
³ ³
³ ³ HBFC-22B1 is considered an
interim
³ ³
³ ³ substitute for Halon 1211.
³ ³
³ ³ Because the HBFC-22B1 has an
ODP
³ ³
³ ³ of .74, production will be
phased
³ ³
³ ³ out on January 1, 1996.
³ ³
³ ³ This agent was submitted to the
³ ³
³ ³ Agency as a Premanufacture
Notice
³ ³
³ ³ (PMN) and is presently subject
to
³ ³
³ ³ requirements contained in a
Toxic
³ ³
³ ³ Substance Control Act (TSCA)
³ ³
³ ³ Consent Order.
³ HCFC-123.......... ³
Acceptable........ ³ .................. ³
..................................
³ [HCFC Blend] B.... ³
Acceptable........ ³ .................. ³ Contains small
percentage of PFC
³ ³
³ ³ which has an unusually long
³ ³
³ ³ atmospheric lifetime, and
could
³ ³
³ ³ potentially contribute to
global
³ ³
³ ³ climate change. EPA suggests
but
³ ³
³ ³ does not require that users
³ ³
³ ³ minimize emissions by
minimizing
³ ³
³ ³ use during training, and by
³ ³
³ ³ recovery and recycling during
³ ³
³ ³ maintenance and servicing.
³ FC 5-1-14......... ³ Acceptable for
use ³ FC 5-1-14 shall ³ Under SNAP, EPA has reviewed
and
³ ³ in military
³ not be used ³ found acceptable only certain
³ ³ flightlines,
³ during training ³ narrowly defined uses of
³ ³ inside
military ³ exercises. ³ perfluorinated
compounds. Wider
³ ³ aircraft; and
in ³ FC 5-1-14 must be ³ use of perfluorinated
compounds
³ ³ military
computer ³ recovered from ³ is of concern due to
long
³ ³ and telecom-
³ the fire ³ atmospheric lifetimes and
³ ³ munication
³ protection system ³ potential to contribute to
global
³ ³ facilities
³ prior to ³ warming.
³ ³
³ servicing and ³
³ ³
³ recycled for ³
³ ³
³ later use. ³
³ [CFC Blend]....... ³
Acceptable........ ³ .................. ³ [CFC Blend] can
help transition
³ ³
³ ³ away from halon 1211 in
³ ³
³ ³ applications requiring a
highly
³ ³
³ ³ effective fire extinguisher
with
³ ³
³ ³ low toxicity.
³ ³
³ ³ Because CFCs are a Class I
³ ³
³ ³ substance, production will be
³ ³
³ ³ phased out by January 1, 1996.
³ ³
³ ³ The manufacturer notes that
this
³ ³
³ ³ agent is not suitable for
Class B
³ ³
³ ³ fires involving escaping
gases.
³ Dry Chemical ..... ³ Acceptable
....... ³ .................. ³ Does not penetrate well
behind
³ ³
³ ³ obstacles.
³ Carbon Dioxide ... ³
Acceptable........ ³ .................. ³ Not rated for
use against Class A
³ ³
³ ³ fires.
³ Water ............ ³ Acceptable
....... ³ .................. ³ Not suitable for use
against
³ ³
³ ³ electrical fires (Class C).
³ Foam ............. ³ Acceptable
....... ³ .................. ³ Effective against
flammable
³ ³
³ ³ liquids. Can also be used
against
³ ³
³ ³ Class A fires.
³ ³
³ ³ Not suitable for discharge onto
³ ³
³ ³ live electrical equipment.
Halon 1301 Total ³ HBFC-22B1......... ³
Acceptable........ ³ For occupied areas ³ HBFC-22B1 can
be utilized in
Flooding-Occupied ³ ³
³ from which ³ existing equipment with only
Areas. ³ ³
³ personnel cannot ³ minor modifications and can
thus
³ ³
³ be evacuated in ³ facilitate a more rapid
³ ³
³ one minute, use ³ transition away from Halon
1301.
³ ³
³ is permitted only ³ The design concentration is
³ ³
³ up to ³ approximately 5.3% while its
³ ³
³ concentrations ³ cardiotoxic LOAEL is 1%.
³ ³
³ not exceeding the ³ Evacuation must be complete
³ ³
³ cardiotoxic NOAEL.³ before 1% concentration is
³ ³
³ For occupied areas ³ reached.
³ ³
³ from which ³ Must conform with OSHA 29 CFR
1910
³ ³
³ personnel can be ³ Subpart L Section 1910.160 of
the
³ ³
³ evacuated or ³ U.S. Code. This section
requires
³ ³
³ egress can occur ³ that employees be alerted to
³ ³
³ between 30 and 60 ³ impending system discharge by
³ ³
³ seconds, use is ³ suitable alarms and provided
with
³ ³
³ permitted up to a ³ sufficient time to safely exit
³ ³
³ concentration not ³ the area prior to system
³ ³
³ exceeding the ³ discharge.
³ ³
³ LOAEL. ³ Per OSHA requirements,
protective
³ ³
³ All personnel must ³ gear (SCBA) must be available
in
³ ³
³ be evacuated ³ the event personnel must
reenter
³ ³
³ before ³ the area.
³ ³
³ concentration of ³ HBFC-22B1 can be considered
only
³ ³
³ HBFC-22B1 exceeds ³ an interim substitute for
Halon
³ ³
³ 1%. ³ 1301. HBFC-22B1 has an ODP of
.74;
³ ³
³ ³ thus, production will be
phased
³ ³
³ ³ out on January 1, 1996.
³ ³
³ ³ This agent was submitted to the
³ ³
³ ³ Agency as a Premanufacture
Notice
³ ³
³ ³ (PMN) and is presently subject
to
³ ³
³ ³ requirements contained in a
Toxic
³ ³
³ ³ Substances Control Act (TSCA)
³ ³
³ ³ Consent Order.
³ HCFC-22........... ³
Acceptable........ ³ For occupied areas ³ The design
concentration is
³ ³
³ from which ³ approximately 13.9% while its
³ ³
³ personnel cannot ³ cardiotoxic NOAEL is 2.5% and
the
³ ³
³ be evacuated in ³ LOAEL is 5%.
³ ³
³ one minute, use ³ Must conform with OSHA 29 CFR
1910
³ ³
³ is permitted only ³ Subpart L Section 1910.160 of
the
³ ³
³ up to ³ U.S. Code. This section
requires
³ ³
³ concentrations ³ that employees be alerted to
³ ³
³ not exceeding the ³ impending system discharge by
³ ³
³ cardiotoxic NOAEL ³ suitable alarms and provided
with
³ ³
³ ³ sufficient time to safely exit
³ ³
³ For occupied areas ³ the area prior to system
³ ³
³ from which ³ discharge.
³ ³
³ personnel can be ³ Per OSHA requirements,
protective
³ ³
³ evacuated or ³ gear (SCBA) must be available
in
³ ³
³ egress can occur ³ the event personnel must
reenter
³ ³
³ between 30 and 60 ³ the area.
³ ³
³ seconds, use is ³
³ ³
³ permitted up to a ³
³ ³
³ concentration not ³
³ ³
³ exceeding the ³
³ ³
³ LOAEL ³
³ ³
³ All personnel must ³
³ ³
³ be evacuated ³
³ ³
³ before ³
³ ³
³ concentration of ³
³ ³
³ HCFC-22 exceeds 5 ³
³ ³
³ % ³
³ HCFC-124.......... ³
Acceptable........ ³ For occupied areas ³ The design
concentration is
³ ³
³ from which ³ approximately 9.8% while its
³ ³
³ personnel cannot ³ cardiotoxic NOAEL is 1.0% and
its
³ ³
³ be evacuated in ³ LOAEL is 2.5%.
³ ³
³ one minute, use ³ Must conform with OSHA 29 CFR
1910
³ ³
³ is permitted only ³ Subpart L Section 1910.160 of
the
³ ³
³ up to ³ U.S. Code. This section
requires
³ ³
³ concentrations ³ that employees be alerted to
³ ³
³ not exceeding the ³ impending system discharge by
³ ³
³ cardiotoxic NOAEL ³ suitable alarms and provided
with
³ ³
³ ³ sufficient time to safely exit
³ ³
³ For occupied areas ³ the area prior to system
³ ³
³ from which ³ discharge.
³ ³
³ personnel can be ³ Per OSHA requirements,
protective
³ ³
³ evaluated or ³ gear (SCBA) must be available
in
³ ³
³ egress can occur ³ the event personnel must
reenter
³ ³
³ between 30 and 60 ³ the area.
³ ³
³ seconds, use is ³
³ ³
³ permitted up to a ³
³ ³
³ concentration not ³
³ ³
³ exceeding the ³
³ ³
³ LOAEL ³
³ ³
³ All personnel must ³
³ ³
³ be evacuated ³
³ ³
³ before ³
³ ³
³ concentration of ³
³ ³
³ HCFC-124 exceeds ³
³ ³
³ 2.5% ³
³ [HCFC BLEND] A.... ³
Acceptable........ ³ For occupied areas ³ The design
concentration is
³ ³
³ from which ³ approximately 10.3%.
Preliminary
³ ³
³ personnel cannot ³ data indicates that the NOAEL
is
³ ³
³ be evacuated in ³ at least 10.0%, and therefore
the
³ ³
³ one minute, use ³ LOAEL is likely to be higher.
³ ³
³ is permitted only ³ Until the Agency receives the
³ ³
³ up to ³ LOAEL data, this agent is
³ ³
³ concentrations ³ approved to the design
³ ³
³ not exceeding the ³ concentration of 10.3%.
³ ³
³ cardiotoxic NOAEL ³ Evacuation must be complete
³ ³
³ ³ before 10.3% concentration is
³ ³
³ For occupied areas ³ exceeded. EPA awaits the final
³ ³
³ from which ³ report on cardiotoxicity test
³ ³
³ personnel can be ³ data.
³ ³
³ evacuated or ³ Must conform with OSHA 29 CFR
1910
³ ³
³ egress can occur ³ Subpart L Section 1910.160 of
the
³ ³
³ between 30 and 60 ³ U.S. Code. This section
requires
³ ³
³ seconds, use is ³ that employees be alerted to
³ ³
³ permitted up to a ³ impending system discharge by
³ ³
³ concentration not ³ suitable alarms and provided
with
³ ³
³ exceeding the ³ sufficient time to safely exit
³ ³
³ LOAEL ³ the area prior to system
³ ³
³ All personnel must ³ discharge.
³ ³
³ be evacuated ³ Per OSHA requirements,
protective
³ ³
³ before ³ gear (SCBA) must be available
in
³ ³
³ concentration of ³ the event personnel must
reenter
³ ³
³ [HCFC BLEND] A ³ the area.
³ ³
³ exceeds the ³
³ ³
³ design ³
³ ³
³ concentration of ³
³ ³
³ 10.3% ³
³ HFC-23............ ³ Acceptable for
³ For occupied areas ³ The design concentration is
³ ³ high value
³ from which ³ approximately 14.9% while
³ ³ applications
such ³ personnel cannot ³ preliminary data indicates
that
³ ³ as those
³ be evacuated in ³ its cardiotoxic NOAEL is 30%
³ ³ involving the
³ one minute, use ³ without added oxygen and 50%
with
³ ³ protection of
³ is permitted only ³ added oxygen. Its LOAEL is
likely
³ ³ public safety
or ³ up to ³ to exceed 50%. Evacuation
must be
³ ³ national
security;³ concentrations ³ complete before 30%
concentration
³ ³
telecommunication ³ not exceeding the ³ is reached. EPA
awaits the final
³ ³ or computer
³ cardiotoxic NOAEL ³ report on cardiotoxicity test
³ ³ equipment
related ³ ³ data.
³ ³ to public
safety ³ For occupied areas ³ Must conform with OSHA 29
CFR 1910
³ ³ or national
³ from which ³ Subpart L Section 1910.160 of
the
³ ³ security; or
life ³ personnel can be ³ U.S. Code. This section
requires
³ ³ support
functions ³ evacuated or ³ that employees be
alerted to
³ ³
³ egress can occur ³ impending system discharge by
³ ³
³ between 30 and 60 ³ suitable alarms and provided
with
³ ³
³ seconds, use is ³ sufficient time to safely exit
³ ³
³ permitted up to a ³ the area prior to system
³ ³
³ concentration not ³ discharge.
³ ³
³ exceeding the ³
³ ³
³ LOAEL ³
³ ³
³ All personnel must ³
³ ³
³ be evacuated ³
³ ³
³ before ³
³ ³
³ concentration of ³
³ ³
³ HFC-23 exceeds 30 ³
³ ³
³ % ³
³ ³
³ ³ Per OSHA requirements,
protective
³ ³
³ ³ gear (SCBA) must be available
in
³ ³
³ ³ the event personnel must
reenter
³ ³
³ ³ the area.
³ ³
³ ³ Due to concerns about this
agent's
³ ³
³ ³ Global Warming Potential, the
³ ³
³ ³ agency is currently
restricting
³ ³
³ ³ its use until further analysis
is
³ ³
³ ³ complete.
³ ³
³ ³ Required extinguishing
³ ³
³ ³ concentration and storage
volume
³ ³
³ ³ ratio are the highest of all
³ ³
³ ³ potential candidates, but
weight
³ ³
³ ³ ratio is only 2.0.
³ HFC-134a.......... ³
Acceptable........ ³ For occupied areas ³ The design
concentration is
³ ³
³ from which ³ approximately 12.6% while its
³ ³
³ personnel cannot ³ cardiotoxic LOAEL is
³ ³
³ be evacuated in ³ approximately 8.0% Evacuation
³ ³
³ one minute, use ³ must be complete before 8.0%
³ ³
³ is permitted only ³ concentration is reached.
³ ³
³ up to ³
³ ³
³ concentrations ³
³ ³
³ not exceeding the ³
³ ³
³ cardiotoxic NOAEL ³
³ ³
³ For occupied areas ³ Must conform with OSHA 29 CFR
1910
³ ³
³ from which ³ Subpart L Section 1910.160 of
the
³ ³
³ personnel can be ³ U.S. Code. This section
requires
³ ³
³ evacuated or ³ that employees be alerted to
³ ³
³ egress can occur ³ impending system discharge by
³ ³
³ between 30 and 60 ³ suitable alarms and provided
with
³ ³
³ seconds, use is ³ sufficient time to safely exit
³ ³
³ permitted up to a ³ the area prior to system
³ ³
³ concentration not ³ discharge.
³ ³
³ exceeding the ³
³ ³
³ LOAEL ³
³ ³
³ All personnel must ³ Per OSHA requirements,
protective
³ ³
³ be evacuated ³ gear (SCBA) must be available
in
³ ³
³ before ³ the event personnel must
reenter
³ ³
³ concentration of ³ the area.
³ ³
³ HFC-134a exceeds ³
³ ³
³ 8.0% ³
³ HFC-227ea......... ³
Acceptable........ ³ For occupied areas ³ The design
concentration is
³ ³
³ from which ³ approximately 7.1% while
³ ³
³ personnel cannot ³ preliminary data indicates
that
³ ³
³ be evacuated in ³ its cardiotoxic NOAEL is 8.1%
and
³ ³
³ one minute, use ³ its LOAEL is greater than
10.5%.
³ ³
³ is permitted only ³ Evacuation must be complete
³ ³
³ up to ³ before a concentration of
10.5%
³ ³
³ concentrations ³ is exceeded. EPA awaits the
final
³ ³
³ not exceeding the ³ report on cardiotoxicity test
³ ³
³ cardiotoxic NOAEL ³ data.
³ ³
³ For occupied areas ³ Must conform with OSHA 29 CFR
1910
³ ³
³ from which ³ Subpart L Section 1910.160 of
the
³ ³
³ personnel can be ³ U.S. Code. This section
requires
³ ³
³ evacuated or ³ that employees be alerted to
³ ³
³ egress can occur ³ impending system discharge by
³ ³
³ between 30 and 60 ³ suitable alarms and provided
with
³ ³
³ seconds, use is ³ sufficient time to safely exit
³ ³
³ permitted up to a ³ the area prior to system
³ ³
³ concentration not ³ discharge.
³ ³
³ exceeding the ³
³ ³
³ LOAEL ³
³ ³
³ All personnel must ³ Per OSHA requirements,
protective
³ ³
³ be evacuated ³ gear (SCBA) must be available
in
³ ³
³ before ³ the event personnel must
reenter
³ ³
³ concentration of ³ the area.
³ ³
³ HFC-227ea exceeds ³
³ ³
³ 10.5% ³
³ ³
³ ³ This agent was submitted to the
³ ³
³ ³ Agency as a Premanufacture
Notice
³ ³
³ ³ (PMN) agent and is presently
³ ³
³ ³ subject to requirements
contained
³ ³
³ ³ in a Toxic Substances Control
Act
³ ³
³ ³ (TSCA) Significant New Use
Rule
³ ³
³ ³ (SNUR).
³ FC 3-1-10......... ³ Acceptable for
³ For occupied areas ³ The design concentration is
³ ³ applications
³ from which ³ approximately 6.6% while its
³ ³ involving the
³ personnel cannot ³ cardiotoxic NOAEL is 40% and
its
³ ³ protection of
³ be evacuated in ³ LOAEL is over 40%.
³ ³ public safety
or ³ one minute, use ³ Must conform with OSHA 29 CFR
1910
³ ³ national
security;³ is permitted only ³ Subpart L Section
1910.160 of the
³ ³ tele- communi-
³ up to ³ U.S. Code. This section
requires
³ ³ cation or
³ concentrations ³ that employees be alerted to
³ ³ computer
³ not exceeding the ³ impending system discharge by
³ ³ equipment
related ³ cardiotoxic NOAEl ³ suitable alarms and
provided with
³ ³ to public
safety ³ For occupied areas ³ sufficient time to safely
exit
³ ³ or national
³ from which ³ the area prior to system
³ ³ security; or
life ³ personnel can be ³ discharge.
³ ³ support
functions ³ evacuated or ³ Per OSHA requirements,
protective
³ ³
³ egress can occur ³ gear (SCBA) must be available
in
³ ³
³ between 30 and 60 ³ the event personnel must
reenter
³ ³
³ seconds, use is ³ the area.
³ ³
³ permitted up to a ³
³ ³
³ concentration not ³
³ ³
³ exceeding the ³
³ ³
³ LOAEL ³
³ ³
³ All personnel must ³
³ ³
³ be evacuated ³
³ ³
³ before ³
³ ³
³ concentration of ³
³ ³
³ FC 3-1-10 exceeds ³
³ ³
³ 40% ³
³ ³
³ FC 3-1-10 shall ³ Under SNAP, EPA has reviewed
and
³ ³
³ not be used to ³ found acceptable only certain
³ ³
³ test total ³ narrowly defined uses of
³ ³
³ flooding systems ³ perfluorinated compounds.
Wider
³ ³
³ unless captured ³ use of perfluorinated
compounds
³ ³
³ and recycled or ³ is of concern due to long
³ ³
³ destroyed ³ atmospheric lifetimes, and
³ ³
³ ³ potential to contribute to
global
³ ³
³ ³ warming.
³ ³
³ Fire detection ³
..................................
³ ³
³ should be cross- ³
³ ³
³ zoned to avoid ³
³ ³
³ unnecessary ³
³ ³
³ discharge and ³
³ ³
³ maintained to ³
³ ³
³ high reliability ³
³ ³
³ FC 3-1-10 must be ³
..................................
³ ³
³ recovered from ³
³ ³
³ the fire ³
³ ³
³ protection system ³
³ ³
³ prior to ³
³ ³
³ servicing and ³
³ ³
³ must be recycled ³
³ ³
³ for later use ³
³ [Inert Gas Blend]. ³
Acceptable........ ³ The design ³ Studies have
shown that healthy,
³ ³
³ concentration ³ young individuals can remain
in a
³ ³
³ must result in at ³ 12% to 14% oxygen atmosphere
for
³ ³
³ least 14% oxygen ³ 30 to 40 minutes without
³ ³
³ and 4% CO2 ³ impairment. However, in a fire
³ ³
³ If the oxygen ³ emergency, the oxygen level
may
³ ³
³ concentration of ³ be reduced below safe levels,
and
³ ³
³ the atmosphere ³ the decomposition products
formed
³ ³
³ falls below 12%, ³ by the fire are likely to
cause
³ ³
³ personnel must be ³ harm. Thus, the Agency does
not
³ ³
³ evacuated and ³ contemplate personnel
remaining
³ ³
³ egress must occur ³ in the space after system
³ ³
³ within 30 seconds ³ discharge during a fire
without
³ ³
³ ³ Self Contained Breathing
³ ³
³ ³ Apparatus (SCBA) as required
by
³ ³
³ ³ OSHA.
³ CO2............... ³
Acceptable........ ³ .................. ³ System design
must adhere to OSHA
³ ³
³ ³ 1910.162(b)5 and NFPA Standard
12.
³ Water............. ³
Acceptable........ ³ ³
Halon 1301 Total ³ HBFC-22B1 ........ ³
Acceptable........ ³ .................. ³ HBFC-22B1 can
be considered only
Flooding- ³ ³
³ ³ an interim substitute for
Halon
Unoccupied Areas. ³ ³
³ ³ 1301. HBFC-22B1 has an ODP of
.74;
³ ³
³ ³ thus, production will be
phased
³ ³
³ ³ out January 1, 1996.
³ ³
³ ³ This agent was submitted to the
³ ³
³ ³ Agency as a Premanufacture
Notice
³ ³
³ ³ (PMN) and is presently subject
to
³ ³
³ ³ requirements contained in a
Toxic
³ ³
³ ³ Substance Control Act (TSCA)
³ ³
³ ³ Consent Order.
³ ³
³ ³ OSHA requires that protective
gear
³ ³
³ ³ (SCBA) be worn by personnel
³ ³
³ ³ entering the space until
oxygen
³ ³
³ ³ levels return to 19.5% and
³ ³
³ ³ relevant decomposition
products
³ ³
³ ³ decrease to OSHA limits.
³ HCFC-22........... ³
Acceptable........ ³ .................. ³ OSHA requires
that protective gear
³ ³
³ ³ (SCBA) be worn by personnel
³ ³
³ ³ entering the space until
oxygen
³ ³
³ ³ levels return to 19.5% and
³ ³
³ ³ relevant decomposition
products
³ ³
³ ³ decrease to OSHA limits.
³ HCFC-124.......... ³
Acceptable........ ³ .................. ³ OSHA requires
that protective gear
³ ³
³ ³ (SCBA) be worn by personnel
³ ³
³ ³ entering the space until
oxygen
³ ³
³ ³ levels return to 19.5% and
³ ³
³ ³ relevant decomposition
products
³ ³
³ ³ decrease to OSHA limits.
³ [HCFC BLEND] A ... ³
Acceptable........ ³ .................. ³ OSHA requires
that protective gear
³ ³
³ ³ (SCBA) be worn by personnel
³ ³
³ ³ entering the space until
oxygen
³ ³
³ ³ levels return to 19.5% and
³ ³
³ ³ relevant decomposition
products
³ ³
³ ³ decrease to OSHA limits.
³ HFC-23............ ³ Acceptable for
³ ³ Due to concerns about this
agent's
³ ³ high value
³ ³ Global Warming Potential, its
use
³ ³ applications
such ³ ³ is restricted pending
further
³ ³ as those
³ ³ review by the Agency.
³ ³ involving the
³ ³ Required extinguishing
³ ³ protection of
³ ³ concentration and storage
volume
³ ³ public safety
or ³ ³ ratio are the highest of all
³ ³ national
security;³ ³ potential candidates,
but weight
³ ³
telecommunication ³ ³ ratio is only
2.0.
³ ³ or computer
³ ³
³ ³ equipment
related ³ ³
³ ³ to public
safety ³ ³
³ ³ or national
³ ³
³ ³ security; Life
³ ³
³ ³ support
functions ³ ³
³ ³ such as
Armored ³ ³
³ ³ Personnel
³ ³
³ ³ Vehicles and
³ ³
³ ³ related
vehicles; ³ ³
³ ³ and for
explosion ³ ³
³ ³
inertion/suppres- ³ ³
³ ³ sion with
³ ³
³ ³ flammable
liquids ³ ³
³ ³ and gases
³ ³
³ HFC-125 .......... ³
Acceptable........ ³ .................. ³ OSHA requires
that protective gear
³ ³
³ ³ (SCBA) be worn by personnel
³ ³
³ ³ entering the space until
oxygen
³ ³
³ ³ levels return to 19.5% and
³ ³
³ ³ relevant decomposition
products
³ ³
³ ³ decrease to OSHA limits.
³ HFC-134a ......... ³
Acceptable........ ³ .................. ³ OSHA requires
that protective gear
³ ³
³ ³ (SCBA) be worn by personnel
³ ³
³ ³ entering the space until
oxygen
³ ³
³ ³ levels return to 19.5% and
³ ³
³ ³ relevant decomposition
products
³ ³
³ ³ decrease to OSHA limits.
³ HFC-227ea ........ ³
Acceptable........ ³ .................. ³ OSHA requires
that protective gear
³ ³
³ ³ (SCBA) be worn by personnel
³ ³
³ ³ entering the space until
oxygen
³ ³
³ ³ levels return to 19.5% and
³ ³
³ ³ relevant decomposition
products
³ ³
³ ³ decrease to OSHA limits.
³ ³
³ ³ This agent was submitted to the
³ ³
³ ³ Agency as a Premanufacture
Notice
³ ³
³ ³ (PMN) and is presently subject
to
³ ³
³ ³ requirements contained in a
Toxic
³ ³
³ ³ Substance Control Act (TSCA)
³ ³
³ ³ Significant New Use Rule
(SNUR).
³ FC 3-1-10......... ³ Acceptable for
³ FC 3-1-10 may not ³ Under SNAP, EPA has reviewed
and
³ ³ applications
³ be used for ³ found acceptable only certain
³ ³ involving the
³ training ³ narrowly defined uses of
³ ³ protection of
³ exercises ³ perfluorinated compounds.
Wider
³ ³ public safety
or ³ Detection should ³ use of perfluorinated
compounds
³ ³ national
security;³ be cross-zoned to ³ is of concern due to
long
³ ³
telecommunication ³ avoid unnecessary ³ atmospheric
lifetimes, and
³ ³ or computer
³ discharge and ³ potential to contribute to
global
³ ³ equipment
related ³ maintained to ³ warming.
³ ³ to public
safety ³ high reliability ³ OSHA requires that
protective gear
³ ³ or national
³ Recycling/recovery ³ (SCBA) be worn by personnel
³ ³ security; Life
³ equipment must be ³ entering the space until
oxygen
³ ³ support
functions ³ used during ³ levels return to 19.5%
and
³ ³ such as
Armored ³ servicing of fire ³ relevant decomposition
products
³ ³ Personnel
³ protection system ³ decrease to OSHA limits.
³ ³ Vehicles and
³ ³
³ ³ related
vehicles; ³ ³
³ ³ and for
explosion ³ ³
³ ³ inertion/
³ ³
³ ³ suppression
with ³ ³
³ ³ flammable
liquids ³ ³
³ ³ and gases
³ ³
³ [Inert Gas Blend]. ³
Acceptable........ ³ .................. ³ OSHA requires
that protective gear
³ ³
³ ³ (SCBA) be worn by personnel
³ ³
³ ³ entering the space until
oxygen
³ ³
³ ³ levels return to 19.5% and
³ ³
³ ³ relevant decomposition
products
³ ³
³ ³ decrease to OSHA limits.
³ Carbon Dioxide.... ³
Acceptable........ ³ .................. ³ OSHA requires
that protective gear
³ ³
³ ³ (SCBA) be worn by personnel
³ ³
³ ³ entering the space until
oxygen
³ ³
³ ³ levels return to 19.5% and
³ ³
³ ³ relevant decomposition
products
³ ³
³ ³ decrease to OSHA limits.
³ Water............. ³ Acceptable
³ .................. ³
Halon 1301 ³ HBFC-22B1......... ³ Acceptable only
in ³ .................. ³ HBFC-22B1 can be considered
only
Explosion ³ ³ normally
³ ³ an interim substitute for
Halon
Inertion. ³ ³ unoccupied
areas ³ ³ 1301. HBFC-22B1 has an ODP
of .74;
³ ³
³ ³ thus, production will be
phased
³ ³
³ ³ out on January 1, 1996.
³ ³
³ ³ This agent was submitted to the
³ ³
³ ³ Agency as a Premanufacture
Notice
³ ³
³ ³ (PMN) and is presently subject
to
³ ³
³ ³ requirements contained in a
Toxic
³ ³
³ ³ Substance Control Act (TSCA)
³ ³
³ ³ Consent Order.
³ ³
³ ³ OSHA requires that protective
gear
³ ³
³ ³ (SCBA) be worn by personnel
³ ³
³ ³ entering the space until
oxygen
³ ³
³ ³ levels return to 19.5% and
³ ³
³ ³ relevant decomposition
products
³ ³
³ ³ decrease to OSHA limits.
³ HFC-23............ ³ Acceptable for
³ .................. ³ Preliminary analysis of
³ ³ high value
³ ³ cardiotoxicity tests indicates
³ ³ applications
such ³ ³ that the no effect level for
³ ³ as those
³ ³ cardiac sensitization exceeds
50%
³ ³ involving the
³ ³ .
³ ³ protection of
³ ³ Design concentrations vary for
³ ³ public safety
or ³ ³ different atmospheres. The
design
³ ³ national
security;³ ³ concentration should not
exceed
³ ³
telecommunication ³ ³ the cardiotoxic
LOAEL of 50% in
³ ³ or computer
³ ³ an occupied area.
³ ³ equipment
related ³ ³ Due to concerns about this
agent's
³ ³ to public
safety ³ ³ Global Warming Potential,
its use
³ ³ or national
³ ³ is restricted pending further
³ ³ security; life
³ ³ Agency review.
³ ³ support
functions;³ ³ Required extinguishing
³ ³ and for
explosion ³ ³ concentration and
storage volume
³ ³ inertion/
³ ³ ratio are the highest of all
³ ³ suppression
with ³ ³ potential candidates, but
weight
³ ³ flammable
liquids ³ ³ ratio is only 2.0.
³ ³ and gases
³ ³
³ HFC-125 .......... ³ Acceptable only
in ³ .................. ³ OSHA requires that protective
gear
³ ³ normally
³ ³ (SCBA) be worn by personnel
³ ³ unoccupied
areas ³ ³ entering the space until
oxygen
³ ³
³ ³ levels return to 19.5% and
³ ³
³ ³ relevant decomposition
products
³ ³
³ ³ decrease to OSHA limits.
³ HFC-227ea......... ³ Acceptable
....... ³ .................. ³ Design concentrations vary
for
³ ³
³ ³ different atmospheres. The
design
³ ³
³ ³ concentration must not exceed
the
³ ³
³ ³ cardiotoxic LOAEL of 10.5% in
an
³ ³
³ ³ occupied area.
³ ³
³ ³ OSHA requires that protective
gear
³ ³
³ ³ (SCBA) be worn by personnel
³ ³
³ ³ entering the space until
oxygen
³ ³
³ ³ levels return to 19.5% and
³ ³
³ ³ relevant decomposition
products
³ ³
³ ³ decrease to OSHA limits.
³ ³
³ ³ This agent was submitted to the
³ ³
³ ³ Agency as a Premanufacture
Notice
³ ³
³ ³ (PMN) and is subject to
³ ³
³ ³ requirements contained in a
Toxic
³ ³
³ ³ Substance Control Act (TSCA)
³ ³
³ ³ Significant New Use Rule
(SNUR).
³ FC 3-1-10......... ³ Acceptable for
³ FC 3-1-10 shall ³ Design concentrations vary for
³ ³ applications
³ not be used to ³ different atmospheres. The
design
³ ³ involving the
³ test explosion ³ concentration must not exceed
the
³ ³ protection of
³ inertion systems ³ cardiotoxic LOAEL of 40% in an
³ ³ public safety
or ³ unless captured ³ occupied area.
³ ³ national
security;³ and recycled or ³
³ ³
telecommunication ³ destroyed ³
³ ³ or computer
³ ³
³ ³ equipment
related ³ ³
³ ³ to public
safety ³ ³
³ ³ or national
³ ³
³ ³ security; life
³ ³
³ ³ support
functions;³ ³
³ ³ and for
explosion ³ ³
³ ³ inertion/
³ ³
³ ³ suppression
with ³ ³
³ ³ flammable
liquids ³ ³
³ ³ and gases
³ ³
³ ³
³ FC 3-1-10 must be ³ Under SNAP, EPA has reviewed
and
³ ³
³ recovered from ³ found acceptable only certain
³ ³
³ the explosion ³ narrowly defined uses of
³ ³
³ inertion system ³ perfluorinated compounds.
Wider
³ ³
³ prior to ³ use of perfluorinated
compounds
³ ³
³ servicing and ³ is of concern due to long
³ ³
³ must be recycled ³ atmospheric lifetimes, and
³ ³
³ for later use ³ potential to contribute to
global
³ ³
³ ³ warming.
³ ³
³ ³ OSHA requires that protective
gear
³ ³
³ ³ (SCBA) be worn by personnel
³ ³
³ ³ entering the space until
oxygen
³ ³
³ ³ levels return to 19.5% and
³ ³
³ ³ relevant decomposition
products
³ ³
³ ³ decrease to OSHA limits.
³ [Inert Gas Blend]. ³
Acceptable........ ³ .................. ³ Efficacy data
required for
³ ³
³ ³ acceptance in normally
occupied
³ ³
³ ³ areas.
³ ³
³ ³ OSHA requires that protective
gear
³ ³
³ ³ (SCBA) be worn by personnel
³ ³
³ ³ entering the space until
oxygen
³ ³
³ ³ levels return to 19.5% and
³ ³
³ ³ relevant decomposition
products
³ ³
³ ³ decrease to OSHA limits.
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Halons-Unacceptable Substitutes
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Application ³ Substitute ³
Initial decision ³ Comments
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
³ ³
³
Halon 1211 ....................... ³ [CFC-11] ³
Proposed ³ This agent has been proposed for large
outdoor fires for
³ ³
Unacceptable ³ which non-ozone depleting alternatives
are currently used.
Streaming Agents-Commercial/ ³ ³
³
Industrial Applications. ³ ³
³
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Halons-Pending
Decisions
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Application ³ Substitute ³
Comments
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
³ ³
Halon 1211 ....................... ³ HFC-227ea......... ³
Cardiotoxicity and personnel monitoring data required.
Streaming Agents-Consumer ³ ³
Applications ³ ³
Halon 1211 ....................... ³ HFC-227ea......... ³
Cardiotoxicity and personnel monitoring data required.
Streaming Agents-Commercial/ ³ HBFC-22B1/HFC- ³
Cardiotoxicity, decomposition product, and personnel
Industrial Applications. ³ 227ea Blend ³
monitoring data required.
³ ³
HBFC-22B1 is considered an interim substitute for Halon 1211.
³ ³
Because the HBFC-22B1 has an ODP of .74, production will be
³ ³
phased out (except for essential uses) on January 1, 1996.
Halon 1211 ....................... ³ HFC-227ea......... ³
Cardiotoxicity and personnel monitoring data required.
Streaming Agents-Military ³ HBFC-22B1/HFC- ³
Cardiotoxicity, decomposition product, and personnel
Applications. ³ 227ea Blend ³
monitoring data required.
³ ³
HBFC-22B1 is considered an interim substitute for Halon 1211.
³ ³
Because the HBFC-22B1 has an ODP of .74, production will be
³ ³
phased out (except for essential uses) on January 1, 1996.
Halon 1301 ....................... ³ HBFC-22B1/HFC- ³
Cardiotoxicity and decomposition product data required.
³ 227ea Blend ³
Total Flooding-Occupied Areas .... ³ .................. ³
HBFC-22B1 is considered an interim substitute for halon.
³ ³
Because the HBFC-22B1 has an ODP of .74, production will be
³ ³
phased out (except for essential uses) on January 1, 1996.
³ HFC-32 ........... ³
Need additional information on potential flammability.
³ ³
Cardiotoxicity data is required.
³ ³
No company has proposed commercialization of this agent as a
³ ³
halon substitute.
³ ³
Due to its potential flammability, this agent may require
³ ³
blending with another agent.
³ Water Mist/Fog.... ³
This newly developing technology for use on Class A, B and C
³ ³
fires is of high interest. The Agency has not yet received
³ ³
a formal submission in order to complete its evaluation.
³ HFC-125........... ³
Need additional information on cardiotoxicity.
³ SF6............... ³
This agent has been proposed as an alternative for discharge
³ ³
testing of halon systems.
Halon 1301 ....................... ³ Water Mist/Fog.... ³
This newly developing technology for use on Class A, B, and
³ ³
C fires is of high interest. The Agency has not yet
³ ³
received a formal submission in order to complete its
³ ³
evaluation.
Total Flooding-Unoccupied Areas ³ ³
Halon 1301........................ ³ [HCFC BLEND] A.... ³
Explosion inertion test data on blend required.
Explosion Inertion ............... ³ SF6............... ³
This agent has been proposed as an alternative for discharge
³ ³
testing of halon systems.
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Sterilants-Acceptable Substitutes
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Application ³ Substitute ³
Initial ³ Proposed ³
Comments
³ ³
decision ³ conditions ³
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
³ ³
³ ³
12/88 Blend of EtO ³ CO2/EtO ³
Acceptable.... ³ ³ CO2/ETO blends can serve
as drop-in replacements to 12/88 in
/CFC-12. ³ ³
³ ³ some but not in all existing
equipment because they require
³ ³
³ ³ a higher operating pressure.
Sterilant ³ ³
³ ³ Maximum EtO concentration in a
CO2/EtO blend may have to be
³ ³
³ ³ reduced to 8-9 percent to reduce
flammability.
³ HCFC-124/ETO ³
Acceptable.... ³ ³ In a blend with EtO,
HCFC-124 is the only available drop-in
³ ³
³ ³ replacement for about half of
the equipment now using 12/88.
³ ³
³ ³ However, HCFC-124 is an ozone
depleting substance; it
³ ³
³ ³ should be use to sterilize only
that equipment that cannot
³ ³
³ ³ be sterilized using other
alternatives such as steam or CO2
³ ³
³ ³ /EtO blends.
³ ³
³ ³ Because HCFC-124 is a Class II
substance, its use may be
³ ³
³ ³ subject to future regulation
promulgated under Section 608
³ ³
³ ³ of the Clean Air Act Amendments
of 1990.
³ ³
³ ³ As a HAP, use of EtO must comply
with Title III of the CAA.
12/88 Blend of EtO ³ Pure ETO ³
Acceptable.... ³ ³ EtO is a toxic,
carcinogenic substance and is considered a
/CFC-12. ³ ³
³ ³ hazardous air pollutant.
Potential exposures of the general
³ ³
³ ³ population to EtO releases can
be limited either through
³ ³
³ ³ the use of catalytic converters
which convert waste EtO
³ ³
³ ³ into CO2 and water, or through
the use of acid water
³ ³
³ ³ scrubbers which convert waste
EtO into ethylene glycol.
Sterilant ³ ³
³ ³
³ ³
³ ³ Must be used in accordance with
manufacturer recommendations
³ ³
³ ³ to address flammability
concerns.
³ ³
³ ³ Must be used in accordance with
OSHA standards to limit
³ ³
³ ³ occupational exposures.
³ Steam ³
Acceptable.... ³ ³ Applicable only to
devices resistant to heat and moisture.
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Sterilants-Pending Decisions
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Application ³ Substitute ³
Comments
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
³ ³
12/88 blend of EtO/CFC-12 ³ [HCFC Blend] A.... ³
Agency has not completed review of data.
sterilant. ³ ³
³ HFC-125/EtO....... ³
Agency has not completed review of data.
³ HFC-227ea/EtO .... ³
Need exposure data.
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Aerosols-Acceptable
Substitutes
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Application ³ Substitute ³ Initial
Decision ³ Proposed ³ Comments
³ ³
³ Conditions ³
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
³ ³
³ ³
CFC-11, HCFC-22, ³ Hydrocarbons ³
Acceptable........ ³ .................. ³ Hydrocarbons
are flammable
HCFC-142b as ³ (Propane, ³
³ ³ materials and must be used
with
aerosol. ³ Isobutane, n- ³
³ ³ the necessary precautions.
propellants. ³ butane) ³
³ ³
³ Dimethyl ether.... ³
Acceptable........ ³ .................. ³ DME is
flammable and must be used
³ ³
³ ³ with the necessary
precautions.
³ ³
³ ³ Blends of DME with HCFCs would
be
³ ³
³ ³ subject to section 610
³ ³
³ ³ restrictions.
³ HFC-152a, HFC-134a ³
Acceptable........ ³ .................. ³ Expense of
these compounds is
³ ³
³ ³ likely to limit widespread
use.
³ Alternative ³
Acceptable........ ³ ³
³ processes (pumps, ³
³ ³
³ mechanical ³
³ ³
³ pressure ³
³ ³
³ dispensers, non- ³
³ ³
³ spray dispensers) ³
³ ³
³ Compressed Gases ³
Acceptable........ ³ ³
³ (Carbon dioxide, ³
³ ³
³ air, nitrogen, ³
³ ³
³ nitrous oxide) ³
³ ³
CFC-11 as aerosol ³ HCFC-142b......... ³ Acceptable
....... ³ .................. ³ Use of HCFC-142b, either
by itself
propellant. ³ ³
³ ³ or blended with other
compounds
³ ³
³ ³ will be prohibited January 1,
³ ³
³ ³ 1994 under section 610 (d).
³ HCFC-22 .......... ³ Acceptable
....... ³ .................. ³ Use of HCFC-22, either by
itself
³ ³
³ ³ or blended with other
compounds
³ ³
³ ³ will be prohibited January 1,
³ ³
³ ³ 1994 under section 610 (d).
CFC-11, CFC-113, ³ Petroleum ³
Acceptable........ ³ .................. ³ Petroleum
distillates are
MCF, HCFC-141b as ³ Distillates (C-6 ³
³ ³ flammable materials and must
be
aerosol solvents. ³ to C-10 paraffins ³
³ ³ used with the necessary
³ and light ³
³ ³ precautions. Pesticide
aerosols
³ aromatics) ³
³ ³ must adhere to FIFRA
standards.
³ Chlorinated ³
Acceptable........ ³ .................. ³ EPA expects to
issue control
³ solvents ³
³ ³ technology requirements under
³ ( ³
³ ³ Title III of the Clean Air
Act.
³ trichloroethylene ³
³ ³ Pesticide aerosols must adhere
to
³ , ³
³ ³ FIFRA standards. Not suitable
for
³ perchloroethylene ³
³ ³ use in consumer products.
³ , methylene ³
³ ³
³ chloride) ³
³ ³
³ Organic solvents ³
Acceptable........ ³ .................. ³ These
substitutes are flammable
³ (e.g., methanol, ³
³ ³ materials and must be used
with
³ ethanol, ³
³ ³ the necessary precautions.
³ isopropanol, ³
³ ³
³ acetone) ³
³ ³
³ Terpenes ......... ³
Acceptable........ ³ .................. ³ These
substitutes are flammable
³ ³
³ ³ materials and must be used
with
³ ³
³ ³ the necessary precautions.
³ Water-Based ³
Acceptable........ ³ ³
³ Formulations ³
³ ³
CFC-11, CFC-113, ³ HCFC-141b......... ³ Acceptable
....... ³ .................. ³ Use of HCFC-141b, either
by itself
MCF as aerosol ³ ³
³ ³ or blended with other
compounds
solvents. ³ ³
³ ³ will be prohibited January 1,
³ ³
³ ³ 1994 under Section 610 (d).
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Aerosols-Pending Decisions
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Application ³ Substitute
³ Comments
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
³
³
CFC-12 as aerosol propellant...... ³
HFC-227........................... ³ FDA approval still
required in metered dose inhalers. Likely
³
³ to have low environmental impacts.
CFC-11, CFC-113, MCF, HCFC-141b as ³ Monochloro/toluene/benzo-
³
aerosol solvents. ³ trifluorides
³
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Tobacco Expansion-Acceptable
Substitutes
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Application ³ Substitute ³ Initial
decision ³ Proposed ³ Comments
³ ³
³ conditions ³
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
³ ³
³ ³
CFC-11 Tobacco ³ Carbon dioxide.... ³
Acceptable........ ³ ³ Carbon dioxide
cannot be used as a
expansion. ³ ³
³ ³ drop-in or a retrofit, but
³ ³
³ ³ requires new equipment.
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Tobacco Expansion-Pending
Substitutes
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Application ³ Substitute ³
Comments
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
³ ³
CFC-11 Tobacco expansion.......... ³ HCFC-123.......... ³
Agency has not completed review of data. Potential
³ ³
drop-in replacement.
³ HFC-227ea......... ³
Agency has not completed review of data.
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Adhesives,
Coatings, and Inks-Acceptable Substitutes
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Application ³ Substitute
³ Initial decision ³ Proposed ³
Comments
³
³ ³ conditions ³
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
³
³ ³ ³
Methyl Chloroform, Adhesives, ³ Petroleum distillates
............ ³ Acceptable........ ³ ³
OSHA standards exist for many of
Coatings, and Inks. ³
³ ³ ³
these chemicals. Formulators
³
³ ³ ³
should use chemicals with lowest
³
³ ³ ³
toxicity, where possible.
³ Organic solvents
(Alcohols, ³ Acceptable........ ³
³ OSHA standards exist for many of
³ Ketones, Ethers, and
Esters) ³ ³ ³
these chemicals. Formulators
³
³ ³ ³
should use chemicals with lowest
³
³ ³ ³
toxicity, where possible.
³ Chlorinated solvents
(methylene ³ Acceptable........ ³ ³
High inherent toxicity. Use only
³ chloride,
trichloro-ethylene, ³ ³
³ when necessary.
³ perchloro-ethylene)
³ ³ ³
³
Terpenes.......................... ³ Acceptable........ ³
³
³ Water-based formulations
......... ³ Acceptable ....... ³ ³
³ High-solid formulations
.......... ³ Acceptable ....... ³ ³
³ Alternative technologies
(e.g., ³ Acceptable........ ³ ³
³ powder, hot melt,
thermoplastic ³ ³
³
³ plasma spray,
radiation-cured, ³ ³
³
³ moisture-cured,
chemical-cured, ³ ³
³
³ and reactive liquid)
³ ³ ³
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Adhesives, Coating, and
Inks-Pending Decisions
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÂÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Application ³ Substitute
³ Comments
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÅÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
³
³
Methyl Chloroform Adhesives, ³ Monochloro-toluene/benzo-
³ Agency has not completed review of
Coatings and Inks. ³ trifluorides
³ data.
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÁÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
Appendix C to the Preamble-Data Confidentiality Claims
Data Confidentiality Claims
1. Special Requirements for Submitting Data to the Docket
Data submissions must be provided in three copies. If
information
is claimed as confidential, all CBI must be deleted from the
third copy which will become part of the public docket. If no
claims of confidentiality are made for the submission, the third
copy should be identical to the other two. When portions of
the submission are claimed as CBI, the first two copies will
include the CBI material as provided in section V of this notice.
The following special preparation is required for the third
copy:
-Remove the "Supplemental Statement of Data Confidentiality
Claims." (see Appendix C, 2)
-Excise from the body of the study any information you claim
as confidential. Replace with generic information if it is
available.
-Mark the third copy plainly on both its cover and its title
page with the phrase "Public Docket Material-contains no
information claimed as confidential."
2. Supplemental Statement of Data Confidentiality Claims
For any portion of a submission that is claimed as confidential,
the following information must be included within a Supplementary
Statement of Data Confidentiality Claims:
-Identify specifically by page and line number(s) each portion
of the study for which you claim confidentiality.
-Give the reasons why the cited passage qualifies for confidential
treatment.
-Indicate the length of time-until a specific date or event,
or permanently-for which the information should be treated
as confidential.
-Identify the measures taken to guard against undesired disclosure
of this information.
-Describe the extent to which the information has been disclosed,
and what precautions have been taken in connection with these
disclosures.
-Enclose copies of any determinations of confidentiality made
by EPA, other Federal agencies, or courts concerning this
information.
-If you assert that disclosure of this information would be
likely to result in substantial harmful effects to you, describe
those harmful effects and explain why they should be viewed
as substantial.
-If you assert that the information is voluntarily submitted,
indicate whether you believe disclosure of this information
might tend to lessen the availability to EPA of similar
information
in the future, and if so, how.
If required substantiation is not provided along with the
submission of information claimed as confidential, EPA may make
the complete submitted information available to the public without
further notice to the submitter.
For the reasons set out in the preamble, EPA is hereby proposing
to amend 40 CFR Part 82 as follows:
PART 82-PROTECTION OF STRATOSPHERIC OZONE
1. Authority: The authority citation for part 82 continues
to read as follows: 42 U.S.C. 7414, 7601, 7671-7671q.
2. Part 82 is proposed to be amended by adding Subpart G
to read as follows:
Subpart G-Significant New Alternatives Policy Program
Sec.
82.170 Purpose and scope.
82.172 Definitions.
82.174 Prohibitions.
82.176 Applicability.
82.178 Information required to be submitted.
82.180 Agency review of SNAP submissions.
82.182 Confidentiality of data.
82.184 Petitions.
82.170 Purpose and scope.
(a) The purpose of the regulations in this subpart is to
implement section 612 of the Clean Air Act, as amended, regarding
the safe alternatives policy on acceptability of substitutes
for ozone-depleting compounds. This program will henceforth
be referred to as the "Significant New Alternatives Policy"
(SNAP) program. The objective of this program is to identify
substitutes for ozone-depleting compounds, to evaluate the
acceptability
of those substitutes, and to promote the use of those substitutes
believed to present lower overall risks to human health and
the environment.
(b) The regulations in this subpart describe persons and
substitutes subject to reporting requirements under the SNAP
program and explain preparation and submission of notices and
petitions on substitutes. The regulations also establish Agency
procedures for reviewing, processing, and for making public
EPA's notices and petitions on substitutes. Finally, the
regulations
prohibit the use of alternatives which EPA has determined may
have adverse effects on human health or the environment where
EPA has identified alternatives that on an overall basis, reduce
risk to human health and the environment and are currently or
potentially available.
82.172 Definitions.
(a) Act means the Clean Air Act, as amended, 42 U.S.C. 7401
et seq.
Agency means the U.S. Environmental Protection Agency.
Class I or II means the specific ozone-depleting compounds
described in section 602 of the Act.
Commerce means trade, traffic, transportation, or other commerce
that could potentially occur between a place in a state of the
United States and any place outside of such state.
Critical use means uses of a substitute where no other
substitute
exists that meets existing performance or technical standards.
Decision means any final determination made by the Agency
under section 612 of the Act on the acceptability or
unacceptability
of a substitute for a Class I or II compound.
EPA means the U.S. Environmental Protection Agency.
Formulator means any person engaged in the preparation or
formulation of a substitute, after chemical manufacture of the
substitute or its components, for distribution or use in commerce.
Health and safety study or study means any study of any effect
of a substitute or its components on health or the environment
or on both, including underlying data and epidemiological studies,
studies of occupational, ambient, and consumer exposure to a
substitute, toxicological, clinical, and ecological, or other
studies of a substitute and its components, and any other pertinent
test. Chemical identity is always part of a health and safety
study.
(1) Information which arises as a result of a formal,
disciplined
study is included in the definition. Also included is information
relating to the effects of a substitute or its components on
health or the environment. Any available data that bear on the
effects of a substitute or its components on health or the
environment
would be included.
(2) Examples include:
(i) Long- and short-term tests of mutagenicity, carcinogenicity,
or teratogenicity; data on behavioral disorders; dermatoxicity;
pharmacological effects; mammalian absorption, distribution,
metabolism, and excretion; cumulative, additive, and synergistic
effects; acute, subchronic, and chronic effects; and
structure/activity
analyses;
(ii) Tests for ecological or other environmental effects
on invertebrates, fish, or other animals, and plants, including:
acute toxicity tests, chronic toxicity tests, critical life
stage tests, behavioral tests, algal growth tests, seed germination
tests, microbial function tests, bioconcentration or
bioaccumulation
tests, and model ecosystem (microcosm) studies;
(iii) Assessments of human and environmental exposure, including
workplace exposure, and effects of a particular substitute on
the environment, including surveys, tests, and studies of:
biological,
photochemical, and chemical degradation; air, water and soil
transport; biomagnification and bioconcentration; and chemical
and physical properties, e.g., boiling point, vapor pressure,
evaporation rates from soil and water, octanol/water partition
coefficient, and water solubility;
(iv) Monitoring data, when they have been aggregated and
analyzed to measure the exposure of humans or the environment
to a substitute;
(v) Any assessments of risk to health or the environment
resulting from the manufacture, processing, distribution in
commerce, use, or disposal of the substitute or its components.
Importer means any person who imports a chemical substitute
into the United States. "Importer" includes the person primarily
liable for the payment of any duties on the merchandise or an
authorized agent acting on his or her behalf. The term also
includes, as appropriate:
(1) The consignee;
(2) The importer of record;
(3) The actual owner if an actual owner's declaration and
superseding bond has been filed; or
(4) The transferee, if the right to draw merchandise in a
bonded warehouse has been transferred.
Major industrial use sector means a sector which EPA has
reviewed under the SNAP program with consumption patterns of
ozone-depleting substances comparable to those for refrigeration,
foam-blowing, fire extinguishing, solvent cleaning, aerosols,
sterilants, tobacco puffing, pesticides, or adhesives, coatings
and inks.
Manufacturer means any person engaged in the direct chemical
manufacture of a substitute.
Mixture means any mixture or blend of two or more individual
chemical compounds.
Person means any natural person, firm, company, corporation,
joint-venture, partnership, sole proprietorship, association,
or any other business entity, any state or political subdivision
thereof, any municipality, any interstate body, and any department,
agency or instrumentality of the Federal government.
Pesticide has the meaning contained in the Federal Insecticide,
Fungicide, and Rodenticide Act, 7 U.S.C. Section 136 et seq.
and the regulations issued under it.
Premanufacture Notice Program has the meaning described in
40 CFR part 720 subpart A under the Toxic Substances Control
Act, 15 U.S.C. Section 2601 et seq.
Producer means any person who manufactures or formulates
a substitute for distribution or use in commerce.
Research and development means quantities of a substitute
manufactured, imported, or processed or proposed to be
manufactured,
imported, or processed solely for research and development.
Significant new use means use of a substitute in a major
industrial use sector as a result of the phase-out of ozone-
depleting compounds.
Small uses means uses of a substitute outside of a major
industrial use sector (see definition of major industrial use
sector in this section) or uses of a substitute of less than
10,000 lbs per year within a major industrial use sector or
any other sector.
Substitute means any chemical, product substitute, or
alternative
manufacturing process, whether existing or new, that could replace
a Class I or II compound.
Test marketing means the distribution in commerce of a
substitute
to no more than a defined number of potential customers to explore
market capability in a competitive situation during a limited
testing period prior to the broader distribution of that substitute
in commerce.
Use means any application of a substitute, whether for use
in a manufacturing process or product, consumption by the end-
user, or in intermediate uses such as formulation or packaging
for other subsequent uses.
82.174 Prohibitions.
(a) No person may use a substitute before the expiration
of 90 days after a notice is submitted to EPA under 82.176(a).
(b) No person may use a substitute which a person knew or
has reason to know was manufactured, processed, or imported
in violation of the regulations in this subpart or in violation
of any condition in the acceptability determination.
(c) No person may use a substitute without adhering to the
conditions set by the acceptability decision.
(d) No person may use a substitute after the effective date
of any rulemaking adding such substitute to the list of
unacceptable
substitutes.
82.176 Applicability.
(a) Any producer of a substitute must submit a notice of
intent to introduce a substitute into commerce 90 days prior
to such introduction. Any producer or formulator of a substitute
already in commerce must submit a notice as of 90 days after
[THE EFFECTIVE DATE OF THE FINAL RULE], if such substitute has
not already been reviewed and approved by the Agency.
(b) Substitutes exempt from reporting requirements under
the SNAP program are listed in paragraph (c) of this section.
(c) The following substitutes are exempt from notification
requirements:
(1) Substitutes already listed as acceptable. Producers of
substitutes need not resubmit notices of a substitute if the
substitute has already been listed under existing Agency decisions
as acceptable.
(2) Small use. Substitutes covered by the Agency's definition
of small uses in 82.172 are exempt from notification requirements.
However, the Agency may evaluate a substitute classified as
a small use if it has reason to believe the substitute could
present a risk of significant adverse effects on human health
and the environment, and require submissions to support such
evaluations. EPA will announce the obligation to make such
submissions
through the quarterly Federal Register notifications or to
individual
affected parties.
(3) Test marketing. Production of substitutes for the sole
purpose of test marketing is exempt from reporting requirements.
Persons taking advantage of this exemption are, however, required
to notify the Agency in writing.
(4) Research and development. Production of substitutes for
the sole purpose of research and development is exempt from
reporting requirements. Persons taking advantage of this exemption
are, however, required to notify the Agency in writing.
(5) Second-generation substitutes. Substitutes that replace
first-generation substitutes that are not ozone-depleting chemicals
are exempt from reporting. However, if the second generation
substitute is replacing a compound that contributes to
stratospheric
ozone depletion, information must be submitted to EPA for review
under SNAP.
(6) Formulation changes. In cases where substitution of Class
I or II compounds causes formulators to change other components
in a product, these auxiliary formulation changes are exempt
from reporting.
(7) Substitutes for export only. Substitutes entirely produced
for export only are not subject to reporting.
(8) Substitutes used as feedstocks. Substitutes used as
feedstocks
which are largely or entirely consumed, transformed or destroyed
in the manufacturing or use process are exempt from reporting.
82.178 Information required to be submitted.
(a) Persons whose substitutes are subject to reporting
requirements
pursuant to 82.176 must provide the following information:
(1) Name and description of the substitute. The substitute
should be identified by its (i) Commercial name; (ii) Chemical
name; (iii) Trade name(s); (iv) identification numbers (e.g.,
Chemical Abstract Service (CAS) registry, National Institutes
of Occupational Safety and Health Registry of Toxic Effects
of Chemical Substances (NIOSH RTECS), EPA hazardous waste
identification
number, OHM-TADS, DOT/UN/NA/IMCO shipping, HSDB, NCI); (v) Chemical
formula; and (vi) Chemical structure.
(2) Physical and chemical information. Key properties to
EPA will use to characterize the substitute include: molecular
weight; physical state; melting point; boiling point; density;
taste and/or odor threshold; solubility; partition coefficients
(Log Kow, Log Koc); vapor pressure; and Henry's Law Constant.
(3) Substitute applications. Identification of the applications
in which the substitutes are likely to be used.
(4) Process description. For each application identified,
descriptive data on processing, including in-place pollution
controls.
(5) Ozone depletion potential. The predicted ozone depletion
potential (ODP) of substitute chemicals. The submitter must
also provide supporting documentation.
(6) Global warming potential. Submitters must provide data
on the total global warming potential of the substitute, including
information on direct and indirect contributions to global warming
caused by the production or use of the substitute (e.g., energy
changes).
(7) Toxicity data. Health and safety studies on the effects
of a substitute, its components, its impurities, and its
degradation
products on any organism (e.g., humans, mammals, fish, wildlife,
and plants). For tests on mammals, the Agency requires a minimum
submission of the following tests to characterize substitute
risks: A range-finding study that considers the appropriate
exposure pathway for the specific use (e.g., oral ingestion,
inhalation, etc), and a 90-day subchronic repeated dose study
in an appropriate rodent species. For substitutes being evaluated
as fire suppressants, a cardiotoxicity study is also required.
Additional mammalian toxicity tests may be identified based
on the substitute and application in question. To sufficiently
characterize aquatic toxicity concerns, both acute and chronic
toxicity data for a variety of species are required. For this
purpose, the Agency requires a minimum data set as described
in "Guidelines for Deriving Numerical National Water Quality
Criteria for the Protection of Aquatic Organisms and their Uses,"
which is available through the National Technical Information
Service (#PB-85-227049).
Other relevant information and data summaries, such as the
Material Safety Data Sheets, should also be submitted. To assist
in locating any studies referred to but not included in a
submission,
the submitter must provide citations for the date and type of
submission to ensure that these studies can be located quickly.
(8) Environmental fate and transport. Where available, EPA
requests information on the environmental fate and transport
of substitutes. Such data shall include information on
bioaccumulation,
biodegradation, adsorption, volatility, transformation, and
other data necessary to characterize movement and reaction of
substitutes in the environment.
(9) Flammability. Data on the flammability of a substitute
chemical or mixture. Specifically, data on flash point and
flammability
limits must be submitted, as well as information on the procedures
used for determining the flammability limits. For substitutes
that will be used in consumer applications, documentation of
testing results conducted by independent laboratories should
be submitted where appropriate. Detail on any suggested abatement
techniques to minimize the risks associated with the use of
flammable substances or blends should also be provided.
(10) Exposure data. Modeling or monitoring data on exposures
associated with the manufacture, formulation, transport, and
use of a substitute. Descriptive process information for each
substitute application, as described in this section, will be
used to develop exposure estimates where exposure data are not
readily available. Depending on the application, exposure profiles
will be needed for workers, consumers, and the general population.
(11) Environmental release data. Data on emissions from the
substitute application and equipment, as well as pollutant releases
or discharge to all environmental media (ambient air, surface
and groundwater, hazardous/solid waste). Submitters should provide
information on release locations. Any information on any pollution
controls used or that could be used in association with the
substitute (e.g., emissions reduction technologies, wastewater
treatment, treatment of hazardous waste) and the costs of such
technology is also requested.
(12) Replacement ratio for a chemical substitute. The Agency
must receive information on the replacement ratio for a chemical
substitute versus the Class I or II substances being replaced.
The term "replacement ratio" means how much of a substitute
must be used to replace a given quantity of Class I or II substance
being replaced.
(13) Required changes in use technology. Detail on the changes
in technology needed to use the alternative is required. Such
information should include a description of whether the substitute
can be used in existing equipment-with or without some retrofit-
or only in new equipment. Data on the cost (capital and operating
expenditures) and estimated life of the technology modifications
should also be submitted.
(14) Cost of substitute. Data on the expected average cost
of the alternative. In addition, information is needed on the
expected equipment lifetime for an alternative technology. Other
critical cost considerations should be identified, as appropriate.
(15) Availability of substitute. If the substitute is not
currently available, the timing of availability of a substitute.
(16) Anticipated market share. Data on the anticipated near-
term and long-term nationwide substitute sales.
(17) Applicable regulations under other environmental statutes.
Information on whether the substitute(s) is (are) regulated
under other statutory authorities, in particular the Clean Water
Act, Safe Drinking Water Act, the Resource Conservation and
Recovery Act, the Federal Insecticide, Fungicide, and Rodenticide
Act, the Toxic Substances Control Act, the Comprehensive
Environmental
Response, Compensation and Liability Act, the Emergency Planning
and Community Right-to-Know Act, or other titles under the Clean
Air Act (CAA).
(18) Information already submitted to the Agency. Information
requested in the SNAP program notice that has been previously
submitted to the Agency as part of past regulatory and information-
gathering activities may be referenced. Submitters that cannot
provide references to data sent previously to the Agency should
include all requested information in the SNAP notice.
(19) Information already available in the literature. If
any of the data needed to complete the SNAP program notice are
available in the literature, complete references for such
information
should be provided.
(b) The Significant New Alternatives Policy (SNAP) form is
designed to provide the Agency with the information necessary
to reach a decision on the acceptability of a substitute.
(1) Submitters requesting review under the SNAP program only
should send the SNAP form to the address for the SNAP coordinator
provided on the form.
(2) Submitters filing jointly under SNAP and PMN should send
the SNAP addendum along with the PMN form to the PMN coordinator
identified on the SNAP form. Submitters must also send both
documents to the SNAP coordinator, with a reference to indicate
the notice has been furnished to the Agency under the PMN program.
Submitters providing information on new chemicals for joint
review under the Premanufacture Notice program and SNAP must
adhere to the TSCA minimum testing requirements described in
TSCA section 4.
(3) Submitters filing jointly under SNAP and under the Federal
Insecticide, Fungicide, and Rodenticide Act should send the
SNAP form to the Office of Pesticide Programs, Registration
Division, as well as to the SNAP coordinator.
82.180 Agency review of SNAP submissions.
(a) Processing of SNAP Notices.
(1) 90-day review process. The 90-day review process will
begin once EPA receives a submission and determines that such
submission includes data on the substitute that are complete
and adequate, as described in 82.178. The Agency may suspend
or extend the review period to allow for submission of additional
data needed to complete the review of the notice.
(2) Letter of receipt. The SNAP coordinator will send a letter
of receipt to the submitter once the Agency receives the SNAP
notice. The SNAP coordinator will also assign the SNAP notice
a tracking number, which will be identified in the letter of
receipt.
(3) Initial review of notice. The SNAP coordinator will review
the notice to ensure that basic information necessary to process
the submission is present (i.e., name of company, identification
of substitute, etc.). The SNAP coordinator will also review
substantiation of any claim of confidentiality.
(4) Determination of data adequacy. Upon receipt of the SNAP
submission, the Agency will review the completeness of the
information
supporting the application. If additional data are needed, the
submitter will be contacted following completion of this review.
The 90-day review period will not commence until EPA has received
data it judges adequate to support analysis of the submission.
(5) Availability of new information during review period.
If critical new information becomes available during the review
period that may influence the Agency's evaluation of a substitute,
the submitter must notify the Agency about the existence of
such information within 10 days of learning of such data. The
submitter must also inform the Agency of new studies underway,
even if the results will not be available within the 90-day
review period. The Agency may contact the submitter to explore
extending or suspending the review period depending on the type
of information received and the stage of review.
(6) Completion of detailed review. Once the preliminary data
review steps have been completed, the Agency will complete a
detailed evaluation of the notice. If during any time the Agency
perceives a lack of information necessary to reach a SNAP
determination,
it will contact the submitter and request the missing data.
(7) Criteria for review. To determine whether a substitute
is acceptable or unacceptable as a replacement for Class I or
II compounds, the Agency will evaluate:
(i) Atmospheric effects and related health impacts;
(ii) General population risks from ambient exposure to compounds
with direct toxicity and to increased ground-level ozone;
(iii) Ecosystem risks;
(iv) Occupational risks;
(v) Consumer risks; and
(vi) Cost and availability of the substitute.
(8) Communication of decision.
(i) Communication of decision to the submitter. Once the
SNAP program notice review has been completed, the Agency will
notify the submitter in writing of the decision. Sale or
manufacture
may continue if the Agency fails to reach a decision within
90 days or fails to communicate that decision or the need for
additional data to the submitter.
(ii) Communication of decision to the public. The Agency
will publish in the Federal Register every three months a complete
list of the acceptable and unacceptable alternatives that have
been reviewed to date. In the case of substitutes proposed for
placement on the unacceptable list or for removal from either
list, a formal rule-making process will ensue.
(b) Types of listing decisions. When reviewing and listing
substitutes, the Agency will place substitutes in one of 5
categories:
(1) General acceptance. Where the Agency has reviewed a
substitute
and found no reason to prohibit its use, it will list the
alternative
as acceptable for the applications listed in the notice.
(2) Approval subject to use limitations. After reviewing
a notice, the Agency may make a determination that a substitute
is acceptable if certain conditions are met to minimize risks
to human health and the environment.
(3) General prohibition. This designation will apply to
substitutes
where the Agency's review indicates that the substitute poses
risk of adverse effects to human health and the environment
and that alternatives exist that reduce overall risk.
(4) Prohibition with limited exemptions for critical use.
Even though the Agency can restrict the use of a substitute
based on the potential for adverse effects, it may be necessary
to grant a limited number of exemptions because of the lack
of alternatives for specialized uses within the application.
The Agency will refer to such exemptions as "critical use
exemptions."
Critical use exemptions will be granted only for the time period
necessary to develop and implement alternatives not yet available.
These exemptions are discussed further in 82.184.
(5) Substitutes pending completion of review. Submissions
for which the Agency has not reached a determination will be
described as pending. For all substitutes in this category,
the Agency will work with the submitter to obtain any missing
information and to determine a schedule for providing the missing
information if the Agency wishes to extend the 90-day review
period. EPA will use the authority under section 114 of the
Clean Air Act to gather this information, if necessary. In some
instances, the Agency may also explore using additional statutory
provisions (e.g., section 4 of TSCA) to collect the needed data.
(c) Outreach. The Agency will publish the SNAP determinations
and any revisions four times a year in the Federal Register.
In addition to the quarterly publications, the Agency will
communicate
decisions through a clearinghouse and its outreach program.
The outreach program includes a hotline and presentations at
conferences and in trade journals. The Agency will maintain
a list of vendors that sell substitutes that EPA has determined
present lower environmental risks than the Class I and II
compounds.
(d) Joint processing under SNAP and FIFRA. The Agency will
coordinate reviews of substitutes submitted for evaluation under
both FIFRA and the CAA.
(e) Joint processing under SNAP and TSCA. The Agency will
coordinate reviews of substitutes submitted for evaluation under
both the TSCA PMN program and the CAA.
82.182 Confidentiality of data.
(a) Clean Air Act provisions. Anyone submitting information
must assert a claim of confidentiality at the time of submission
for any data they wish to have treated as confidential business
information (CBI) under 40 CFR part 2, subpart B. Failure to
assert a claim of confidentiality at the time of submission
may result in disclosure of the information by the Agency without
further notice. The submitter should also be aware that under
section 114(c) of the Clean Air Act, emissions data may not
be claimed as confidential.
(b) Substantiation of confidentiality claims. At the time
of submission, EPA requires a substantiation of any confidentiality
claims made. Moreover, under 40 CFR part 2, subpart B,
confidentiality
assertions may later be reviewed even when confidentiality claims
are received. The submitter will also be contacted as part of
this evaluation process.
(c) Confidential provisions for toxicity data. In the event
that toxicity or health and safety studies are listed as
confidential,
this information cannot be maintained as confidential where
such data is also submitted under TSCA or FIFRA because of specific
disclosure provisions in those statutes. However, information
contained in the toxicity study that is not relevant to the
effects of a substance on human health and the environment (e.g.,
discussion of process information, proprietary blends) can be
maintained as confidential subject to 40 CFR part 2, subpart
B.
(d) Joint submissions under other statutes. Information
submitted
as part of a joint submission to either SNAP/TSCA or SNAP/FIFRA
must adhere to CBI practices under those statutes. For such
submissions, the SNAP handling of such notices will follow CBI
requirements under those statutes.
82.184 Petitions.
(a) Who may petition. Any person may petition the Agency
to amend existing listing decisions under the SNAP program,
or to add a new substance to the SNAP lists.
(b) Types of petitions. Four types of petitions exist:
(1) Petitions to add a substitute not previously reviewed
under the SNAP program to the approved list. This type of petition
is comparable to the 90-day notifications, except that it would
only be initiated by entities other than the companies that
manufacture, formulate, or use the substitute. Companies that
manufacture, formulate, or use substitutes that want to have
their substitutes added to the approved list must submit
information
on the substitute under the 90-day review program;
(2) Petitions to add a substitute not previously reviewed
under the SNAP program to the prohibited list;
(3) Petitions to delete a substitute from the approved list
and add it to the prohibited list;
(4) Petitions to delete a substitute from the prohibited
list and add it to the approved list.
(c) Content of the petition. A petition must contain the
information described in 82.178, which lists the items to
be submitted in a 90-day notification. The Agency also requires
that the petitioner submit information on the type of action
requested and the rationale for the petition. For petitions
that request approval for substitutes on "critical use" grounds,
the Agency requires the information described in paragraph (e)
in this section on critical uses. For petitions that request
a re-examination of a substitute previously reviewed under the
SNAP program, the submitter must reference the prior submittal.
(d) Petition process.
(1) Notification of affected companies. If the petition concerns
a substitute previously either approved or restricted under
the SNAP program, the Agency will contact the manufacturer(s)
of that substitute.
(2) Review for data adequacy. The Agency will review the
petition for adequacy of data. As with the 90-day notices, the
Agency may suspend review until the petitioner submits the
information
necessary to evaluate the petition. To reach a timely decision
on substitutes, EPA may use collection authorities such as those
contained in section 114 of the Clean Air Act as well as
information
collection provisions of other environmental statutes.
(3) Review procedures. To evaluate the petition, the Agency
may submit the petition for review to appropriate experts.
(4) Timing of determinations. If data are adequate, as described
in 82.180, the Agency will respond to the petition within
90 days of receiving a complete petition. If the petition is
inadequately supported, the Agency will query the petitioner
to fill any data gaps before the 90-day review period begins,
or may deny the petition because data are inadequate.
(5) Rulemaking procedures. EPA will initiate rulemaking whenever
EPA grants a petition to add a substance to the list of
unacceptable
substitutes, remove a substance from either list, approve an
alternative with conditions that are not otherwise required,
or grant a critical use exemption.
(6) Communication of decision. The Agency will inform
petitioners
within 90 days whether their request has been granted or denied.
If a petition is denied, the Agency will publish in the Federal
Register an explanation of the determination. If a petition
is granted, the Agency will publish the revised SNAP list
incorporating
the final petition decision within 6 months of reaching a
determination
or in the next scheduled update, if sooner.
(e) Critical use petitioners. Petitioners may request the
Agency, based on technology or safety concerns, to allow limited
exemptions for specialized uses of a substitute that has previously
been placed on the prohibited list. For such petitions, the
Agency requires that the petitioner provide documentation on
the critical use in question. This documentation shall include
descriptions of substitutes examined and rejected, process or
product in which the critical use substitute is needed, reason
for rejection of other alternatives, e.g., performance, technical
or safety standards, and anticipated date other substitutes
will be available and projected time for switching.
[FR Doc. 93-10422 Filed 5-11-93; 8:45 am]
BILLING CODE 6560-50-P