ktwerner@mmm.com 

05/10/2007 04:56 PM	To

	Margaret Sheppard/DC/USEPA/US@EPA, Jeff Cohen/DC/USEPA/US@EPA

	cc

	

	bcc

	

	Subject

	Fw: SNAP Acceptability Determination for NPB

	

	

FYI

----- Forwarded by Kurt Werner/US-Corporate/3M/US on 05/10/2007 03:55 PM

-----

                                                                        
  

             Kurt                                                       
  

             Werner/US-Corpora                                          
  

             te/3M/US                                                  
To 

                                       mcalamas@omb.eop.gov             
  

             05/09/2007 09:27                                          
cc 

             AM                        CNorman@pattonboggs.com          
  

                                                                  
Subject 

                                       SNAP Acceptability Determination 
  

                                       for NPB                          
  

                                                                        
  

                                                                        
  

                                                                        
  

                                                                        
  

                                                                        
  

                                                                        
  

Dear Mary Ann,

I am sorry I was not able to attend the recent meeting organized by
Caffey

Norman regarding nPB.

I would like to emphasize the need to complete the rule making on nPB. 
The

uncertainty associated with the regulatory acceptability, risks to
worker

health, and environmental impact of nPB have existed for many years. 
The

markets need clarity on these issues so as provide a common
understanding

associated with the risks of nPB and the management practices necessary
to

adequately protect workers.  Clear guidance on the acceptability in
various

end-use sectors will also foster sound decision making in costly solvent

specification processes.

I encourage OMB to advance the rule making process in a manner that

utilizes a bench-marked methodology for establishing industrial exposure

guidelines and removes the current ambiguity associated with the

recommended exposure guideline on nPB.  Consistency in the methodology
used

to establish exposure guidelines enables those making choices between

available solvents to better understand the relative margin of safety

associated with those solvent options.

Thank you for your consideration of these issues.

Sincerely,

Kurt T. Werner, DABT

EHS Manager

3M Specialty Materials

651-733-8494

