Summary of OMB Meeting

Date:  November 17, 2006

Attendees:  

Steve Risotto, Halogenated Solvents Industry Alliance (HSIA)

Caffey Norman, Patton Boggs representing HSIA

Amy Flynn, Office of Management and Budget (OMB)

Nancy Beck, OMB

Amanda Lee, OMB

Art Fraas, OMB

Kevin Bromberg, Small Business Administration

Margaret Sheppard, Environmental Protection Agency (EPA)

Subject:  EPA’s Proposed Rulemaking on n-Propyl Bromide (nPB)

	Mr. Fraas began the meeting by explaining that it is a meeting under
Executive Order 12866.  The rule is now on OMB’s website.  The sign-in
sheet and any materials submitted during the meeting will go on OMB’s
website.

	Mr. Norman mentioned concerns about the exposure levels of solvents in
adhesives when used in foam fabrication.  He also discussed exposure
limits for nPB, including the 2005 threshold limit value of 10 ppm and
California’s proposed permissible exposure limit (PEL) of 1 ppm.  Mr.
Risotto provided copies of material safety data sheets for nPB from two
manufacturers.  Mr. Norman mentioned new studies and cases concerning
neurotoxic effects of nPB.  He also mentioned other parties that are in
some way regulating nPB (e.g., California’s Proposition 65, European
Union’s labeling requirements).

	Mr. Bromberg asked if the HSIA had performed a new derivation of the
exposure limit.  Mr. Norman and Mr. Risotto indicated that in their
public comments, HSIA had recommended an exposure limit between 1 and 7
ppm.  Mr. Bromberg suggested that HSIA consider providing a new
derivation in their future comments.

	Mr. Bromberg also asked about typical exposure levels in different end
uses.  HSIA representatives indicated that adhesives users in foam
fabrication couldn’t meet 25 ppm and that aerosol use is also a
problem.  They stated that during degreasing, if vapors are enclosed or
colleted, it is possible to achieve 5 to 10 ppm.  Mr. Norman suggested
that for uses where the exposure limit is achievable, there should be a
regulatory limit.

