Julie,

Here are some suggestions we made in the proposed rule about ways to
reduce risk to workers (68 FR 33308):

(	All users of nPB should wear appropriate personal protective
equipment, including chemical goggles, flexible laminate protective
gloves and chemical-resistant clothing.  Special care should be taken to
avoid contact with the skin since nPB, like many halogenated solvents,
can be absorbed through the skin. 

(	Follow guidelines in the National Emission Standard for Hazardous Air
Pollutants (NESHAP) for halogenated solvents cleaning if you are using
nPB for non-aerosol solvent cleaning.  The equipment and procedural
changes described in the halogenated solvents NESHAP can reduce
emissions, reduce solvent losses and lower the cost of cleaning with
organic solvents.  For more information on the halogenated solvents
NESHAP, visit http://www.epa.gov/ttn/atw/eparules.html and
http://www.epa.gov/ttn/atw/degrea/halopg.html.

(	Use the employee exposure monitoring programs and product stewardship
programs where offered by manufacturers and formulators of nPB-based
solvents and adhesives. 

(	Follow all recommended safety precautions specified in the
manufacturer’s Material Safety Data Sheets (MSDSs).

(	Use sufficient ventilation and emissions controls to meet the 25 ppm
AEL in adhesives or aerosol applications (or, once developed, the
applicable OSHA PEL).  Examples of ventilation equipment for aerosol
uses include ventilation hoods and fans.  Adhesive appliers can use
spray booths, ventilation hoods or ducts, and fans to reduce exposure.

(	Request a confidential consultation from your State government.  You
can contact the appropriate state agency that participates in OSHA’s
consultation program.  These contacts are on OSHA’s web site at 
http://www.osha.gov/oshdir/consult.html . For further information on
OSHA’s confidential consultancy program, visit OSHA’s web page at
http://www.osha.gov/html/consultation.html.

(	If the manufacturer or formulator of your nPB-based product does not
have an exposure monitoring program, we recommend that you start your
own exposure monitoring program, and/or request a confidential
consultation from your State government.

(	A medical monitoring program should be established for the early
detection and prevention of acute and chronic effects of exposure to
nPB.  The workers' physician(s) should be given information about the
adverse health effects of exposure to nPB and the workers' potential for
exposure. 

(	Workers should receive safety training and education that includes
potential health effects of exposure to nPB, covering information
included on the appropriate material data safety sheets, as required by
OSHA's Hazard Communication Standard (29 CFR 1910.1200).

We note that these steps are useful for reducing exposure to any
industrial solvent, and not just nPB.

If you are using nPB for cleaning, you are most likely to control
emissions using a vapor degreaser designed to meet the halogenated
solvents cleaning NESHAP.  The kind of equipment that keeps down
emissions will typically have at least two sets of cooling coils, a
roll-top cover, and a relatively long freeboard, all of which keep
vapors inside the machine.  In addition, it helps to take pieces out of
the vapor degreaser slowly.  Attached are some useful tips that one
cleaning company provides to its customers.

I would not recommend hand wiping using nPB because of the likely high
exposures.  

I hope this is helpful.  If you have further questions or you would like
to talk about this, please call me at 202-343-9163.

Margaret Sheppard

USEPA/Global Programs Division

SNAP Program

Tel. 202-343-9163

Fax 202-343-2338

email: sheppard.margaret@epa.gov

	

"Kaiser, Julie A. (JCH)" <KaiserJA@PWCJAX.NAVY.MIL>

11/04/03 08:09 AM

	

To:	Margaret Sheppard/DC/USEPA/US@EPA

cc:	

Subject:	SNAP Proposed Rulemaking



Margaret, 

The EPA webpage lists you as the contact for questions regarding the

proposed rule.  Other than the MSDS, is there guidance on what
constitutes

"controlled workplace exposure to nPB" to lower health risks to workers?
  

Please advise.  

Thanks,

 

Julie Kaiser

Sr. Environmental Coordinator

Johnson Controls-HILL

 		 

SUMMARY: The Environmental Protection Agency (EPA) published in the
Federal

Register of June 3, 2003, a Notice of Proposed Rulemaking related to the

Significant New Alternatives Policy (SNAP) program's review of n-propyl

bromide. During the public comment period, members of the public
requested

clarification or correction of a number of statements in the preamble to
the

proposed rule. This document identifies, corrects, and clarifies these

portions of the preamble. 

SUPPLEMENTARY INFORMATION: The Environmental Protection Agency published
in

the Federal Register of June 3, 2003 (68 FR 33284

<http://www.epa.gov/fedrgstr/EPA-AIR/2003/June/Day-03/a13254.htm>), a
Notice

of Proposed Rulemaking related to the Significant New Alternatives
Policy

(SNAP) program's review of n-propyl bromide. During the public comment

period, members of the public requested clarification or correction of

certain 

