Minutes for December 5, 2006 Meeting Concerning EPA’s Rulemaking on
n-Propyl Bromide

Attendees:

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)

Rich Morford, Enviro Tech International

Bill Thomas, Enviro Tech International

Geraldine Edens, McKenna Long &Aldridge, representing Enviro Tech
International

Fred Anderson, McKenna Long &Aldridge, representing Enviro Tech
International

Marc Stelljes, SLR International

Will Pickrell, Albermarle Corporation

Nancy O’Malley, Albermarle Corporation

	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.

	Fred Anderson gave an overview of the issues to be discussed:  the
legality and scientific issues associated with EPA’s rule on n-propyl
bromide, and particularly the exposure limit.  He said that EPA’s
proposed value of 25 ppm from 2003 acts as a de facto regulatory
standard; industry has adjusted.

	The representatives from Enviro Tech and Albemarle brought a number of
issues concerning EPA’s review of n-propyl bromide:

The lengthy process and lack of certainty about a final decision

The lack of new scientific data that would result in a new decision
coming out of risk assessment

The length and detail of EPA’s review for nPB, compared to that for
other chemicals under the SNAP program

Reports of cases of overexposure from use of nPB-based adhesives should
not be considered representative of the current situation

	Dr. Stelljes discussed a draft document obtained under the Freedom of
Information Act from EPA, a derivation of an acceptable exposure limit .
 Drs. Stelljes and O’Malley disagreed with certain aspects of the
analysis, particularly how it dealt with different female reproductive
effects (length of estrous cycle and lack of estrous cycling).  Dr.
Stelljes compared the results to those in an analysis performed by
Toxicological Excellence in Risk Assessment (TERA).  Drs. Stelljes and
O’Malley thought that sperm and liver effects were stronger endpoints
than the female reproductive effects in the draft exposure limit
derivation.  Dr. Stelljes said there was no new science justifying an
AEL based on the female reproductive effects.

	Mr. Pickrell and Mr. Morford expressed concern that if EPA were to
repropose a rule with an exposure limit lower than 25 ppm, it would hurt
their industry.  Mr. Morford also expressed concern about equity in
EPA’s review of nPB compared to other solvents.

	Both Albemarle and Enviro Tech do not sell nPB in adhesives.  However,
although Enviro Tech does not sell nPB in adhesives, Mr. Morford said
that his company would not want to restrict the use of nPB in that end
use, because competitors might tell customers that nPB has been banned. 
He suggested that another option involving use conditions, such as
limits or ventilation requirements, might be appropriate.  Mr. Morford
believes that the case reports of workers being overexposed were due to
“bad actors.”  Finally, Mr. Morford emphasized the need to reach a
final decision.

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