  SEQ CHAPTER \h \r 1 Executive Summary

EPA’s Office of Air and Radiation analyzed the potential economic
impacts of the final regulation for n-propyl bromide (nPB) under the
Significant New Alternatives Policy (SNAP) program.  The objective of
the analysis was to determine the societal costs of the final
regulation.  The majority of nPB is used in solvent cleaning, aerosol
solvents and as a carrier solvent in adhesives.  The final rule only
addresses the use of nPB in solvent cleaning.  Aerosol solvents and
adhesive uses of nPB are addressed in a separate proposed rule.

The overall societal cost of the final rule will range between $0 and a
net savings of $2.0 million annually.    Of this amount, there is a cost
of $ 0.3 to $ 0.8 million and savings of $ 2.3  to $ 2.4 million per
year due to solvent reductions.  Health benefits could not be
quantified.  Up to 4% of small businesses using nPB may experience
financial impacts as great as 1% of annual sales, and up to 3% may
experience impacts as great as 3% of annual sales if all expenses of
attempting to reduce emissions were incurred in a single year.  The
final rule is not expected to create a significant impact on a
significant number of small entities.  Costs and small business impacts
analyzed attribute costs of voluntary reductions in exposure to the
rule; however, the regulation itself does not impose any requirements or
costs upon users. 

1.    SEQ CHAPTER \h \r 1 Introduction

This report presents the results of EPA’s economic analysis of the
final regulation for use of propyl bromide (nPB) in solvent cleaning
under the Significant New Alternatives Policy (SNAP) program.  The first
objective of this analysis was to determine if the regulatory options
would result in a “significant impact on a substantial number of small
entities” (SISNOSE).    The analysis of small business impacts was
conducted in conformance with the Regulatory Flexibility Act (RFA) and
the Small Business Regulatory Enforcement Fairness Act (SBREFA).   The
second objective of this analysis was to estimate the costs to industry
of the final rule and to consider the rule’s benefits.  

This analysis defines a significant impact on small businesses by the
total number of companies impacted and the percent by which they are
affected by the proposed regulation.  For example, if no more than 20%
of businesses using nPB have sales impacted by greater than 1% or no
more than 100 businesses have sales impacted by greater than 3%, the
proposed regulatory option is not considered to impose a significant
impact on small businesses.  In addition, a small entity or business is
defined as one employing fewer than 500 people.  This is consistent with
the Small Business Administration’s (SBA) definitions of “small”
in most cases.  For those few cases where SBA has a different definition
for a specific code in the North American Industrial Classification
System (NAICS), EPA’s definition results in the same number of small
businesses with significant impacts and a larger percentage of small
businesses with significant impacts. 

The assumptions in this analysis are based on input provided from
experts in the field of chemical manufacturing, ventilation systems, and
medicine, as well as expert opinion from chemical associations and other
government agencies.  In addition, information was gathered from
articles and websites.  

There are three industrial sectors under the SNAP program that currently
use nPB: non-aerosol solvents, aerosols, and adhesives, coatings, and
inks.  This analysis only examined the non-aerosol solvent applications.
 EPA has separately analyzed the costs and small business impacts of a
proposal for aerosol and adhesive uses of nPB.  

The final rule finds nPB acceptable without restriction in solvent
cleaning.  Thus, it imposes no requirements and no costs.  EPA assumes
that most or all users will maintain or reduce workplace exposure levels
to the acceptable levels that EPA discusses in the preamble to the rule
(see section IV.E of the preamble to the final rule).  

The cost of compliance with each option is a comparison of the cost in
the absence of regulation to the costs of meeting the regulation’s
requirements and recommendations.  The analysis assumes that the great
majority of users in the end use are already meeting the acceptable
exposure levels discussed in the preamble and that the remaining
minority of users use a combination of equipment modifications and work
practices to reduce exposure to that level.  In all cases, the analysis
assumes the base case in the absence of regulation is that users use
equipment and practices that are common in their industry and that users
are exposed at levels shown historically for their industry (EPA,
2003a).  Assumptions are described in greater detail in sections 3 and 4
below.

The vast majority of nPB users in the industrial uses covered by the
rule are small businesses.  In general, small businesses will experience
a greater impact from costs of the proposed regulatory options, compared
to their income, than large businesses.  

The rest of this report is organized in five sections.   Section 2
describes the industrial uses for nPB and its market.  Section 3
analyzes impacts of the regulation upon small businesses and determines
whether there is a significant impact upon a significant number of small
entities.  Section 4 analyses overall costs to the economy of the final
rule.  Section 5 qualitatively describes the health benefits of the
final rule.  Section 6 summarizes the analyses on small businesses and
total economic impacts of the final rule. 2.  Characterization of
Markets for n-Propyl Bromide

There are three industrial sectors under the SNAP program which
currently use n-propyl bromide: non-aerosol solvents, aerosols, and
adhesives, coatings, and inks.  Within these sectors, the following end
uses currently use nPB:  metals cleaning, precision cleaning,
electronics cleaning, aerosol solvents, and adhesives.  The final rule
only addresses metals, precision, and electronics cleaning, the solvent
cleaning end uses.

Manufacturers of nPB estimate 9 million pounds of nPB were sold
worldwide in both 2000 and 2001.  Estimates for 2002 increased to 12
million pounds (Biles, 2001).  A more recent estimate predicts the
worldwide market for nPB is 8 to 10 million pounds per year, with about
half being used in the U.S. (ICF, 2005).  

Manufacturers allege that the market for nPB has decreased in recent
years because of an existing shortage on bromine (Tattersall, 2005). 
Formulators may be avoiding the manufacturing of nPB because production
of nPB is not as lucrative as that for a number of other brominated
compounds (Tattersall, 2005).

Data from 2001 indicates that nPB adhesive end-uses account for about
half of the solvent sold (Kenyon, 2001).  More recent data from Poly
Systems indicate that the U.S. market for nPB-based adhesives may be
less than 1.5 million pounds per year.  U.S. market estimates for nPB
aerosol solvents range from 0.5 million pounds per year (Tattersall,
2005) to approximately 1 to 2 million pounds (Kenyon, 2001).  

There are manufacturers of nPB in the U.S., Israel, China, India, the
U.K., France, Japan, and the Netherlands (TEAP, 2001).  There are
currently two U.S. companies that manufacture nPB for solvent use,
Albemarle Corporation and Chemtura.  At least 17 multinational companies
blend or package nPB, and roughly 70 vendors world-wide advertise sale
of nPB or equipment in which nPB is used (TEAP, 2001).  There are seven
major nPB solvent manufacturers (Albemarle, Chemtura, Poly Systems,
Enviro Tech International, Petroferm, AmeriBrom, Tulstar) and three
major nPB-based adhesive manufacturers in the U.S.  (TACC Adhesives,
Sovereign Specialty Chemical, and Mid-South Adhesives).  There are
another 60 or so small providers in the U.S. of specialty products,
including nPB, and 80 or so distributors and marketing representatives
selling products using nPB (IBSA, 2002).  Approximately 20 to 25
companies prepare aerosol formulations with nPB (Kenyon, 2001). 
Estimates for sales of nPB in the SNAP sectors vary.  As discovered
through product searches, very few companies manufacture only products
with nPB; most produce a number of product lines with different
solvents.  

Table 2-1 on the following page summarizes nPB market estimates per
industrial sector characterized by the sources of available data to the
EPA.  Figure 1 illustrates the data from Table 2-1.  

Table 2-1: Industry Expert’s Market Estimates of nPB Use in Cleaning
Solvent, Aerosol, and Adhesive Industrial Sectors

Source of Estimate	Amount of nPB Used Annually (millions of pounds)

	Cleaning Solvents 	Aerosols 	Adhesives	Global Market 

Email to W. Kenyon (Kenyon, 2001)	6 to 8	1 to 2	5 to 7	12 to 15

Brominated Solvents Consortium (Biles, 2001)



9.2 to 12

A. McCulloch (2001)



less than 15.4

ICF Consulting (2001)	5

3.5 (U.S. only)

	M. Ruckriegel (2002)

	1.1 to 1.4

	U. N. Technical and Economic Assessment Panel (TEAP, 2006)



11 to 221

EnviroTech International (ICF, 2005)



8 to 102

T. Tattersall (2005)	

0.5



E. Williams (2005)

Less than 1



1 Estimated usage for US is 2.9 million pounds.

2 Half of this amount is estimated to be used in the U.S.

As stated above, this analysis does not include the economic impacts on
the one known firm using an nPB-based coating.  However, documents
submitted by the company show the estimated annual usage of nPB to be a
minimal 21,000 pounds per year (Lake City Army Ammunition Plant, 2003). 


Figure 1: Estimates of nPB Market Use

 

On the following page, Table 2-2 provides the estimates for the number
of small businesses along with the total number of businesses using nPB,
by industrial sector.  Also, the table providesthe estimated number of
workers exposed to nPB by industrial sector.  The number of businesses
using nPB is based upon estimates from the International Brominated
Solvents Association (IBSA, 2002) and MicroCare Corporation (Tattersall,
2005), and information provided to Dr. William Kenyon (Kenyon, 2001).
The estimated number of businesses using aerosols that are affected is
25% to 50% lower in the 2002 compared to the data gathered in 1997
because the number of electronics firms in the U.S. has decreased in
recent years (U.S. Census Bureau, 2005a).  Table 2-2 below contains the
smaller estimate of affected aerosol users obtained in 2001 and 2002.
The analysis uses the earlier 1997 values throughout the remainder of
this document in the discussion of aerosol users because they result in
higher costs overall to the economy and avoid underestimating impacts.

Table 2-2:  Estimated Number of nPB Businesses and Workers Affected 

Industrial Sector	Number ALL Businesses Affected	Number SMALL Businesses
Affected	Number of Workers Exposed

Solvent cleaning	1500 to 4000	500 to 2300	8300 to 40,300 (3 to 72a per
business )

Aerosols	1000 to 5000	900 to 4750	2000 to 25,000 (2 to 5 per business )

Adhesives, coatings and inks	100 to 280	100 to 280	400 to 9,800 (4 to
35b per business )

Total	2540 to 9280	1440 to7330	3320 to 69,100

a  Sources:  PEI, 1990a, b.

b Source:  Swanson et al., 2002

In addition to the industrial sectors covered by the SNAP program, other
industries use nPB.  For years chemical companies have used nPB as a
feedstock.  Some clothing manufacturers use n-propyl bromide for spot
cleaning on new clothes.  There is anecdotal evidence that in Mexico,
companies use nPB for chemically “welding” together plastic parts of
toys.  These applications are beyond the scope of the SNAP program.

Non-aerosol solvent cleaning is performed in a large variety of
manufacturing operations.  Metal cleaning is commonly done to remove
grease, oil, and metal filings from a number of applications where metal
parts are coated, cut, plated, or stamped.  Electronics cleaning removes
primarily excess solder flux from printed circuit boards and other
electronic equipment.  Precision cleaning is removal of dirt, grease,
oil, solder flux, and other impurities where the degree of cleanliness
is essential to the end value of the product.  Below, Table 2-3 lists
the primary industrial categories performing non-aerosol solvent
cleaning under the North American Industrial Classification System
(NAICS).

NAICS sector 31-33: Manufacturing contains businesses that produce
high-value products that cost considerably more than the cost of
cleaning.  By analyzing the total value of shipments compared to the
total number of firms, NAICS subsector 336, Transportation Equipment
Manufacturing, is the subsector with the highest-priced products.  The
subsector with the lowest priced products is subsector 337, Furniture
and Related Product Manufacturing.  The average annual value of
shipments per business in each of the subsectors, based on the number of
employees at the business, is tabulated below in Table 2-4.  We use the
value of shipments from the 2002 Economic Census (U.S. Census Bureau,
2005a) as a proxy for sales. 

Table 2-3:  NAICS Subsectors Performing Non-Aerosol Solvent Cleaning

(U.S Census Bureau)

NAICS Subsector Code	NAICS Subsector Description	Example Application of
Solvents

331	Primary Metal Manufacturing	Cleaning grease from extruded copper
wire

332	Fabricated Metal Product Manufacturing	Cleaning off electroplated
metals

333	Machinery Manufacturing	Cleaning filings and grease off ball
bearings

334	Computer and Electronic Product Manufacturing	Cleaning solder flux
from printed circuit boards

335	Electrical Equipment, Appliance and Component Manufacturing	Cleaning
excess solder flux from electrical wiring

336	Transportation Equipment Manufacturing	Cleaning grease from metal
parts in motor vehicles

337

	Furniture and Related Product Manufacturing	Cleaning grease from metal
furniture parts

339	Miscellaneous Manufacturing	Cleaning of metal parts not included in
previous categories



The data in Table 2-4 below details the 2002 shipment values for each
subsector of NAICS code 33: Manufacturing.  As the size of the business
increases, so does the annual value of shipments.  The annual value of
shipments increases from approximately $250,000 for businesses with 1 to
4 employees to approximately $1.5 billion for companies with 2500
employees and over.  Table 2-4, which includes data from the non-aerosol
solvent cleaning subsectors, provides a starting point for assessing
small business and total economic impacts of  the final rule.

Table 2-4 Average Value of Shipments in NAICS Subsectors Performing
Solvent Cleaning

(U.S. Census Bureau)

Employee Size Category	Average Value of Shipments per Business ($) by
NAICS Subsector Code in 2002



	331, Primary Metal Mfg	332, Fabricated Metal Products	333, Machinery
Mfg	334, Computer and Electronic Products	335, Electrical Equipment,
Appliance, and Component Mfg	336, Transportation Equipment	337,
Furniture and Related Products	339,

Misc. Mfg

1 to 4	368,580	222,973	301,232	345,007	315,772	412,460	180,805	181,876

5 to 9	1,369,866	835,793	1,049,335	1,317,238	1,243,065	1,414,384	712,557
773,320

10 to 19	2,828,531	1,654,147	1,988,048	2,566,913	2,483,327	2,573,352
1,704,272	1,543,581

20 to 49	7,258,463	4,119,582	4,768,137	5,672,245	5,389,945	5,738,739
3,297,360	3,910,203

50 to 99	17,350,990	10,300,841	11,882,524	12,951,836	12,650,236
12,735,583	8,460,846	9,836,121

100 to 249	38,539,490	27,472,772	29,166,421	31,258,875	31,290,638
34,256,544	20,153,844	24,981,108

250 to 499	95,889,945	61,152,558	81,774,945	84,270,454	77,279,974
86,911,454	48,821,903	68,880,502

500 to 999	246,819,435	110,095,760	187,607,015	234,086,153	171,658,310
200,293,662	82,559,259	160,383,352

1,000 to 2,499	551,782,154	282,860,188	643,794,125	588,973,000
339,584,606	686,626,932	225,115,333	418,460,000

2,500 and over	1,416,529,727	0	0	2,057,896,897	0	3,112,489,540	0
503,273,000

Avg Value Ship Small Businesses in Sub-sector	11,935,698	3,812,656
5,359,829	8,261,788	9,539,205	11,029,561	2,536,805	2,923,741

Avg Value Ship ALL Businesses in Sub sector	28,783,017	4,168,836
6,620,907	20,810,094	13,417,905	45,029,773	2,875,473	3,857,370

Estimated Avg Value Shipments Subset Small Businesses using nPB
22,311,696	      6,814,736 	9,337,066	11,246,045	12,066,562	13,422,547
5,178,300	5,461,637

	

  SEQ CHAPTER \h \r 1 3. Small Business Impacts of Regulatory Options

EPA analyzed the requirements and recommendations of the final rule in
order to determine if there would be significant adverse financial
impacts to a significant number of small firms.  The majority of nPB
users are small businesses, with 500 employees or fewer.

Economic impact was calculated by dividing the annual cost compliance of
the regulatory option by annual value of shipments for a respective firm
size.  The result is a percent economic impact to the bottom line. 
Firms incur an economic impact of greater than 3% of value of shipments
were considered to experience significant adverse impact.  The lower the
percentage impact, the less the regulatory option would impede the
viability of a firm.  This analysis then considered the total number and
percentage of small business experiencing a significant impact to
determine if a regulatory option creates a SISNOSE. 

3.1 	Small business economic impacts on the solvent cleaning sector

  TC \l2 "3.1 Regulatory impacts on the solvent cleaning sector 

Under the final regulation, the use of nPB is acceptable in non-aerosol
solvent cleaning.  There is a discussion in the preamble of acceptable
exposure levels, but no requirement or explicit recommendation.  The use
of a modified or retrofit vapor degreaser would reduce both emissions
and solvent use and consequently produce a savings in annual solvent
cost while achieving the exposure limit for the users that are not
already meeting the acceptable exposure levels.  By increasing the
efficiency of the solvent cleaning equipment, reductions will be seen in
solvent use, nPB emissions and worker exposure levels.  

Although emission controls are not explicitly required under the
regulation, any attempt to further reduce solvent emissions would result
in a savings to the user.  Firms could reduce their workplace exposure
levels and the amount of solvent lost to evaporation by incorporating
emission controls.  Initially, capital costs could be as high as $43,500
(ICF, 2004).  However, firms would save annually as much as $53,500 on
nPB solvent costs with the retrofit (ICF, 2004).  An upgrade to the
vapor degreaser results in an average 60% decrease in the usage of nPB
(Gormely, 2001, and Murphy, 2002).  At such a level of reduction, most
businesses would recover the capital cost of controls within the first
year.  Table 3-1 on the next page shows the percent savings in the
solvent cleaning by NAICS subsector.

Based on exposure data from solvent suppliers, approximately 90% of
solvent users are already meeting an exposure level of 25 ppm, 80% are
meeting an exposure level of 17 to 18 ppm and 70% are meeting an
exposure level of 10 ppm (EPA, 2003a).  The analysis assumes that users
would continue to achieve their historical exposure levels in the
absence of a regulation from EPA.  For the purposes of this  analysis,
we conservatively assume that 80 % of nPB users in the solvent cleaning
sector are already achieving the acceptable exposure levels discussed in
the preamble, require no changes to their equipment, and achieve no
further solvent reductions in response to the rule.  For the remaining
20% of nPB users not already meeting acceptable levels of exposure, EPA
assumed that they have not yet made capital investments to reduce
employee exposure and solvent cost, but make those reductions
voluntarily in response to EPA’s final rule.  This assumption may
overestimate costs for installing equipment and savings from reduced
emissions if some users are unaware of the exposure levels EPA finds
acceptable or choose not to implement those levels.  Some less
knowledgeable users are not aware that reducing emissions would result
in significant cost savings, or are not choosing to make the capital
investments to reduce ongoing solvent costs.  Users of nPB solvent
cleaners aim for the exposure level that is listed on the product’s
material safety data sheet (MSDS) (Tattersal, 2004).  By doing so, users
will miss the opportunity for additional solvent savings as well as
further protection of employee health.  By not researching the
possibility of nPB exposure level reduction to below what is recommended
on a MSDS, some nPB users would miss out on a potential cost savings.  

Table 3-1 Small Business Percentage Annualized Cost and Savings in
Subsectors Performing Solvent Cleaning

NAICS Subsector	 Total # Firms In Solvent Cleaning	Total # Small Firms
Using nPB in Solvent Cleaning	Cost to Small Firms to Reduce Exposure    
      (% of Average Value of Shipments)	Solvent Savings to Small Firms
from Emission Reductions (% of Average Value of Shipments)	Cost plus
Saving to Small Firms to Reduce Exposure (% of Average Value of
Shipments)

331, Primary Metal Mfg	4400	40	0.02%	-0.16%	-0.14%

332, Fabricated Metal Products	55900	570	1.66%	-12.92%	-11.26%

333, Machinery Mfg	27700	280	0.59%	-4.36%	-3.77%

334, Computer and Electronic Products	15300	170	0.50%	-3.93%	-3.44%

335, Electrical Equipment, Appliance, and Component Mfg	6200	60	0.09%
-0.66%	-0.57%

336, Transport Equipment	11300	100	0.23%	-1.82%	-1.59%

337, Furniture and Related Products	22000	100	0.22%	-1.46%	-1.24%

339, Misc. Mfg. 	29500	170	0.28%	-1.74%	-1.46%

Total	172,300	1,490

	

As demonstrated above in Table 3-1, when compared to their current state
of business, small businesses in solvent cleaning overall  would have an
annual percentage gain when they reduce exposure and emissions.  Over
50% of the total annual cost savings would be shared between subsectors
332, Fabricated Metal Products, and 334, Computer and Electronic
Products.  The solvent savings in these two subsectors is directly
related to the amount of nPB they use, which is approximately 55% of the
nPB used in solvent cleaning.   Thus, there will not be significant
adverse impacts on small businesses using nPB for solvent cleaning under
the final rule.  

Typical emission rates and usage rates for batch vapor cleaners of
different sizes estimated for the halogenated cleaning solvents National
Emission Standard for Hazardous Air Pollutants (NESHAP) are on the next
page in Table 3-2 (Radian, 1993).  The first four columns in the table
are from Table 2 in the Radian memo (p. 7) supporting the NESHAP; the
column for annual solvent usage is calculated from those values.  This
calculation assumes that small and medium cleaners operate for 2 hours
per day and idle for 6 hours per day and large and very large cleaners
operate for 6 hours per day and idle for 6 hours per day.  However, the
amount of solvent saved will depend on the emissions before introducing
controls.  This analysis assumes that the type of cleaning equipment
that prevails in industry is the open-top vapor degreaser, and that
users are using equipment built after the NESHAP became final in 1995.  

Table 3-2:  Estimates of Typical Solvent Usage

Four Vapor Degreaser Size Categories

Degreaser  Size	Degreaser top surface area (m2)	Fraction of solvent
emitted1	Annual controlled emissions2 (kg/m2*yr)	Annual solvent
consumption





 kg/yr	lb/yr

Small	0.4	0.89	1,885.1	847	1860

Medium	0.8	0.89	1,885.1	1690	3730

Large	1.5	0.89	2648.1	4460	9820

Very Large	3.5	0.89	2648.1	10,400	22,900

1 Fraction of solvent emitted with current controls (kg emitted/kg
consumed)

2 Annual emissions from a vapor degreaser of this size with current
controls

Several suppliers of nPB have said that it costs from $3 to $5 per pound
when used in the solvent cleaning market (Kenyon (2000), Singh (2001)
and Tattersall (2005)).  Based on these estimates, one can see that the
cost of using nPB would range from $5580 to $114,500 per year for each
vapor degreaser.  

For purposes of comparison, the low end of retrofit options for reducing
emissions include spending $700 to install a mechanical hoist, which
requires pressing a button, or spending $8000 to install additional
condensing coils to reduce evaporative losses (Murphy, 2002).  Purchase
of a used vapor degreaser with higher-grade equipment would be in the
range of $ 2000 to $13,000 (Degreasing Devices web page), while purchase
of a new vapor degreaser would cost from $7000 to more than $ 100,000,
depending on the size of the degreaser and the particular features
(MicroCare, 2004).  This analysis assumes the life-time of a vapor
degreaser to be 10 years (MicroCare, 2004) and assumes that businesses
would budget a certain amount for replacement of equipment.  In some
cases, companies may offer financing to assist users that do not have
enough saved to pay the entire expense at the time of purchase
(Degreasing Devices, 2006).  It is also possible to rent a vapor
degreaser at a cost ranging from $500 to $2000 per month (Degreasing
Devices, 2006).  

There are a number of options available that would reduce the cost of
reducing emissions, even for the smallest businesses.  However, if a
company did not contract out cleaning to another firm, did not take
advantage of financing or renting a vapor degreaser, and did not set
aside 10%-15% of the cost of a degreaser each year as part of capital
planning, the cost of improving equipment would have a significant
impact on the smallest businesses. The average percentage of annual
shipments required for a small business to upgrade or purchase new
equipment in a single year without annualization is shown below in
Tables 3-3, 3-4, and 3-5.  This would show the worst-case impact of
equipment improvements upon a small business.  Of the three approaches,
the most expensive is to purchase an entirely new vapor degreaser, the
least expensive is to purchase a user vapor degreaser, and in the middle
is the cost of upgrading an existing vapor degreaser.  The cost of
upgrading a degreaser displayed in Table 3-5 does not include the cost
of renting another vapor degreaser for a month at $500 to $2000. 
Including the cost of renting a spare degreaser while having an existing
degreaser upgraded would increase the cost of upgrading by approximately
10%.   The businesses most likely to be adversely affected would be
small businesses with 1 to 4 employees.   These smallest businesses
might experience costs of 1% or more of the annual value of shipments
when upgrading a degreaser or purchasing a new degreaser.  In NAICS
codes 332, 337, and 339, small business with 4 or fewer employees might
experience impacts close to 3% of sales.  The annual cost of purchasing
nPB for a company this size is likely to be close to or less than the
cost of purchasing a vapor degreaser (as little as $2400 per drum,
compared to $7000 for a new vapor degreaser or $3000 for a used vapor
degreaser).  Thus, it may take longer to achieve a payback from any
solvent savings for the smallest businesses. If these smallest
businesses have not anticipated the expense of replacing a vapor
degreaser on a regular basis, they might experience significant impacts
during the year they must replace their vapor degreaser.  These impacts
would be far greater than those of the total annualized costs described
above in Table 3-1. 

Table 3-3:  One-Year Small Business Impact as a Percentage of Annual
Shipments in the Solvent Cleaning Sector 

From Upgrading a Vapor Degreaser

Employee Size Category	# Small Firms Using nPB in Solvent Cleaning
Assumed Cost Per Business for Upgrading a Vapor Degreaser	331, Primary
Metal Mfg	332, Fabricated Metal Products	333, Machinery Mfg	334,
Computer and Electronic Products	335, Electrical Equipment, Appliance,
and Component Mfg	336, Transport Equipment	337, Furniture and Related
Products	339, Misc. Mfg. 

1 to 4	306	 $      5,000 	1.36%	2.24%	0.03%	0.06%	1.58%	1.21%	2.77%
2.75%

5 to 9	180	 $      5,000 	0.36%	0.60%	0.03%	0.02%	0.40%	0.35%	0.70%
0.65%

10 to 19	258	 $      5,000 	0.18%	0.30%	0.01%	0.01%	0.20%	0.19%	0.29%
0.32%

20 to 49	316	 $      5,000 	0.07%	0.12%	0.00%	0.00%	0.09%	0.09%	0.15%
0.13%

50 to 99	185	 $      5,000 	0.03%	0.05%	0.00%	0.00%	0.04%	0.04%	0.06%
0.05%

100 to 249	163	 $     10,000 	0.03%	0.04%	0.00%	0.00%	0.03%	0.03%	0.05%
0.04%

250 to 499	61	 $     18,600 	0.02%	0.03%	0.00%	0.00%	0.02%	0.02%	0.04%
0.03%



 

Table 3-4:  One-Year Small Business Impact as a Percentage of Annual
Shipments in the Solvent Cleaning Sector

From Buying a Used Vapor Degreaser

Employee Size Category	# Small Firms Using nPB in Solvent Cleaning
Assumed Cost Per Business for Buying a Used Vapor Degreaser	331, Primary
Metal Mfg	332, Fabricated Metal Products	333, Machinery Mfg	334,
Computer and Electronic Products	335, Electrical Equipment, Appliance,
and Component Mfg	336, Transport Equipment	337, Furniture and Related
Products	339, Misc. Mfg. 

1 to 4	306	$3,000	0.81%	1.35%	0.02%	0.03%	0.95%	0.73%	1.66%	1.65%

5 to 9	180	$3,000	0.22%	0.36%	0.02%	0.01%	0.24%	0.21%	0.42%	0.39%

10 to 19	258	$3,000	0.11%	0.18%	0.00%	0.01%	0.12%	0.12%	0.18%	0.19%

20 to 49	316	$3,000	0.04%	0.07%	0.00%	0.00%	0.06%	0.05%	0.09%	0.08%

50 to 99	185	$3,000	0.02%	0.03%	0.00%	0.00%	0.02%	0.02%	0.04%	0.03%

100 to 249	163	$5,000	0.01%	0.02%	0.00%	0.00%	0.02%	0.01%	0.02%	0.02%

250 to 499	61	$10,000	0.01%	0.02%	0.00%	0.00%	0.01%	0.01%	0.02%	0.01%



Table 3-5:  One-Year Small Business Impact as a Percentage of Annual
Shipments in the Solvent Cleaning Sector

From Buying a New Vapor Degreaser

Employee Size Category	# Small Firms Using nPB in Solvent Cleaning
Assumed Cost Per Business for Buying a New Vapor Degreaser	331, Primary
Metal Mfg	332, Fabricated Metal Products	333, Machinery Mfg	334,
Computer and Electronic Products	335, Electrical Equipment, Appliance,
and Component Mfg	336, Transport Equipment	337, Furniture and Related
Products	339, Misc. Mfg. 

1 to 4	306	 $     7,000 	1.90%	3.14%	0.05%	0.08%	2.22%	1.70%	3.87%	3.85%

5 to 9	180	 $     7,000 	0.51%	0.84%	0.05%	0.03%	0.56%	0.49%	0.98%	0.91%

10 to 19	258	 $     7,000 	0.25%	0.42%	0.01%	0.01%	0.28%	0.27%	0.41%
0.45%

20 to 49	316	 $     7,000 	0.10%	0.17%	0.00%	0.00%	0.13%	0.12%	0.21%
0.18%

50 to 99	185	 $     7,000 	0.04%	0.07%	0.00%	0.00%	0.06%	0.05%	0.08%
0.07%

100 to 249	163	 $   25,000 	0.06%	0.09%	0.00%	0.00%	0.08%	0.07%	0.12%
0.10%

250 to 499	61	 $   50,000 	0.05%	0.08%	0.01%	0.01%	0.06%	0.06%	0.10%
0.07%



Table 3-6 estimates the number of small businesses with impacts of
greater than 1% of annual shipments and 3% of annual shipments,
depending on whether they upgrade an existing vapor degreaser, purchase
a used vapor degreaser, or purchase a new vapor degreaser.

Table 3-6:  Summary of One-Year Small Business Impacts in the Solvent
Cleaning Sector:

Number and Percentage of Businesses Impacted

Compliance approach	# Firms With Economic Impact > 1%	% of Firms with
Economic Impact >1%	# Firms With Economic Impact > 3%	% of Firms with
Economic Impact >3%

Upgrade Vapor Degreaser	56	3.8%	10	0.7%

Purchase Used Vapor Degreaser	50	3.4%	0	0%

Purchase New Vapor Degreaser	58	4.0%	38	2.6%



Based on these estimates, at most 58 small businesses in solvent
cleaning, or 4% of all nPB solvent users, will experience an impact of
greater than 1% of the annual value of shipments.  At most 38 small
businesses in solvent cleaning, or roughly 3% of all nPB solvent users,
will experience an impact of greater than 3% of the annual value of
shipments.  

This analysis of the final rulemaking for nPB in solvent cleaning
incorporates the following assumptions:

Solvent Cleaning Market

The 2005 US Economic Census provided the total number of firms and total
annual value of shipments, per employee size category, in each NAICS
subsector code (U.S. Census Bureau, 2005a).

The number of users varies by employee size category and by NAICS
subsector.  There are approximately 1450 small firms  that perform nPB
solvent cleaning.  Approximately 98% of the total businesses that
perform nPB solvent cleaning are small businesses (Stratus, 2005a).

The number of firms using nPB in solvent cleaning is approximately 1% of
all firms performing solvent cleaning (Stratus, 2005a).

Associated Capital Costs of Vapor Degreaser Upgrades

By analyzing exposure data obtained from industry (n=505), we estimate
that 80% of all users of nPB have adequate vapor degreasing technologies
and only 20% would need to upgrade their vapor degreasers (U.S. EPA,
2003a).

The range of costs for a capital upgrade to a firm’s vapor
degreaser(s) is between $1.90/lb and $2.70/lb of nPB used, based on
upgrade costs of $5000 for a small degreaser to $ 43,000 for a very
large degreaser, as defined in Table 3-2 .  This range is dependent on
the size and number of vapor degreaser(s) required by a firm.

The capital costs for upgraded equipment are amortized over a ten-year
period at a 7% discount rate.

Annual Costs:

The average price of nPB is $4/lb when purchased in 600-lb drums.  The
solvent savings from a capital upgrade to a firm’s vapor degreaser(s)
is approximately $2.30/lb of nPB used.  This is approximately a 60%
savings in solvent cost.

Training required for the proper use of the alternative solvent is
$1000/firm/year.  These costs were taken from the OSHA Methylene
Chloride RIA in 1996 dollars ($1996) and adjusted to 2005 dollars
($2005) (OSHA, 1996a).

The cost of personal protective equipment (PPE) involves that of gloves,
aprons and eye protection for all employees using these chemicals.  The
estimated cost for PPE is $804 per worker per year ($2005), using
information from OSHA’s RIA for the methylene chloride standard
(1996). 

Cleaning Solvent Use:

The total usage of nPB solvent cleaning for small businesses is 5.0
million lbs/year (ICF, 2004).

Average usage per user of cleaning solvent is 2000 lb/year.  Usage at
each employee size category is a multiple or fraction of 600 lbs
(1drum).

nPB cleaning solvent usage varies by firm size as well as by industrial
subsector.

Cleaning Solvent Use Patterns

nPB cleaning solvents were assumed to have a consumption rate that
increases with firm size.   Because larger firms manufacture a higher
number of goods, these firms would employ the largest size of vapor
degreaser or multiple smaller vapor degreasers.

The final rule protects human health with a minimal economic burden to
small firms that use nPB cleaning solvents.  Overall, small firms using
nPB would save on annual solvent expenditures if they make any changes
in response to the final rule and in most cases, they would require no
changes to their operations or equipment.  

Limitations and Uncertainties in Analysis for All nPB End Uses  TC \l2 "



Regulatory impacts on the adhesives, coatings, and inks sector 

The analysis in this document is based on data and estimates provided by
industry representatives and experts.  However, there are limitations
that should be mentioned.  Points to consider are:

Characterization of the number of entities using nPB in the industrial
subsectors is based on expert opinion and industry trends in the NAICS
subsectors.

Consumption patterns and potential substitute market shares for users
that consume extremely small quantities of nPB per year have not been
incorporated into the analysis.

This analysis is based upon assumptions about the effectiveness of
equipment in reducing emissions and exposure levels.  Actual
effectiveness may vary, based upon both equipment and user practices.

The analysis only examines the direct impacts of the regulatory options
on end users.  The analysis does not examine impacts on manufacturers of
nPB, since EPA does not directly regulate them.  Doing such an analysis
would require knowing the relative profitability of nPB compared to
other types of chemicals used in the same applications.  This
information is not available to EPA.

This report does not consider the possibility that businesses may be
able to pass on additional costs to consumers or that they may choose to
switch to an alternative type of solvent instead of reducing exposure
levels in response to the rule.

This analysis does not evaluate the degree to which cash liquidity might
affect purchasing decisions, particularly for small businesses.

4.  Total Economic Impacts of Final Rulemaking

The following section covers the total economic costs to implement the
proposed regulatory options within all industrial sector applications of
nPB.  The purpose of this section is to collectively assess the total
economic impacts of  the different regulatory options for the rulemaking
on nPB in non-aerosol solvent cleaning, aerosol solvents and adhesives. 
The total economic impacts were calculated by summing cost impacts to
small firms from section three of this report in addition to impacts to
those firms with 500 or more employees.  As previously stated, in the
case of adhesives, all users are small businesses.  Assumptions in this
analysis were stated above in Section 3.  

The total percentage of firms using nPB in the solvent cleaning sector
is approximately 1% of all firms in the industrial subsectors 331, 332,
333, 334, 335, 336, 337 and 339.  Of the small percentage of nPB solvent
users, approximately eighty percent already meet the proposed workplace
exposure limit in the absence of regulation.  In addition, some solvent
producers have product stewardship programs that provide for monitoring
exposure levels in the workplace (U.S. EPA, 2003a).  All cost and use
assumptions for the use of nPB in solvent cleaning are stated in Section
3.1.

The total annualized cost to the solvent cleaning sector is a maximum
net savings (a negative cost) of between $1.6 and $2.0 million.  Of this
amount, there is a cost of equipment of $ 0.3 to $ 0.8 million and
savings of $ 2.3  to $ 2.4 million per year due to solvent reductions. 
As discussed above in section 3.1, because the workplace exposure limit
is voluntary rather than required under this option, it is possible that
not all 20% of users failing to meet acceptable levels of exposure prior
to regulation will change their equipment in response to a final rule. 
Installing engineering controls will provide a safer work place for
nPB-using employees.  In addition, the estimated 20% of firms that EPA
expects to install controls as a result of the final rule would save
approximately 60% of their annual solvent cost by reducing solvent
losses through evaporation.  

NAICS Subsector Code	NAICS Subsector Description	Total # of Firms in
NAICS Subsector	Estimated # of Firms Using nPB in Solvent Cleaning in
NAICS Subsector	% Firms Using nPB in Solvent Cleaning	Estimated Cost for
Entire Subsector of Option A 

331	Primary Metal Manufacturing	4,480	45	1.0%	(-)$50,000

332	Fabricated Metal Product Manufacturing	56,100	570	1.0%	(-)$483,000

333	Machinery Manufacturing	27,900	285	1.0%	(-)$303,000

334	Computer and Electronic Product Manufacturing	15,700	175	1.1%
(-)$626,000

335	Electrical Equipment, Appliance and Component Manufacturing	6,300	60
0.9%	(-)$94,000

336	Transportation Equipment Manufacturing	11,700	110	0.9%	(-)$326,000

337	Furniture and Related Product Manufacturing	22,100	100	0.5%
(-)$38,000

339	Miscellaneous Manufacturing	29,600	170	0.6%	(-)$62,000

TOTAL	173,880	1,515	0.9%	(-)$1,981,000



Table 4-1:  Total Economic Impact on the Subsectors Using nPB for
Solvent Cleaning  in $2005    (Parentheses indicate a savings)

Benefits 

The primary benefits of this rule are reductions in adverse health
effects that may occur in response to voluntary reductions of exposure
to nPB.  Various studies have documented that nPB has effects upon the
central and peripheral nervous system, the liver, the male and female
reproductive system, and development of the fetus (ACGIH, 2005; CERHR,
2004; ICF, 2006).

The health benefits of this rule are not quantifiable and cannot be
monetized for several reasons.  First, there is insufficient data
available on the human health effects of specific concentrations of nPB
to calculate the reduction in the number of cases of different health
effects.  Second, there is little or no data on the frequency with which
specific health effects of different severity occur among exposed
workers to calculate the number and cost of different cases.   Third,
there is only limited data on the cost of treating adverse health
effects and no other data on willingness to pay to avoid specific health
effects.   

In addition, there is uncertainty around a number of factors that
contribute to the total amount of benefits, such as:

The total number of workers potentially using nPB.  As described above
in Table 2-2 on p.7, the total number of workers using this chemical is
expected to be between 3320 and 69,100 in any given year. 

The degree to which sensitive subpopulations may be present among the
working population.

The distribution of concentrations to which users of nPB are currently
exposed.  EPA has exposure data from two companies supplying nPB-based
solvents (more than 500 samples).  

The distribution of concentrations that would occur in response to
regulation.  Because in the final rule, nPB is acceptable without a
required exposure limit or an explicit recommended limit, it is possible
that not all nPB users with exposure levels above acceptable exposure
levels would change their equipment and practices to reduce exposure to
acceptable levels.



Conclusions

Table 6-1 below lists the number of small businesses affected,
considering both annualized and one-year cost impacts.  The table
identifies both the number of small businesses experiencing different
levels of significant impacts and the percentage of all small businesses
experiencing the impact.  None of the regulatory options result in a
significant impact on a significant number of small entities.

Table 6-1 Small Business Impacts, by Number and Percentage of Businesses
Impacted

Total #nPB Using Firms in Solvent Cleaning (Small)	Small Business
Impacts Based on Annualized Costs

	Small Business Impacts Based on One-Year Costs



	# Firms Economic Impact Over 1%	% of Small nPB-Using Businesses	# Firms
Economic Impact Over 1%	% of Small nPB-Using Businesses	# Firms Economic
Impact Over 3%	% of Small nPB-Using Businesses

1470	0	0	58	4.0	38	2.6%



Overall, the total cost to society to protect human health from
overexposure to nPB in the solvent cleaning sector is $0 to a savings of
$2.0 million annually.   Under the final rule, at most 4% of all firms
will have an economic impact greater than 1% and at most 2.6% of small
businesses will have an economic impact greater than 3%.  

7.	References

ACGIH, 2005.  The American Conference of Governmental Industrial
Hygienists (ACGIH). Documentation for Threshold Limit Value for
1-Bromopropane.  2005.

Biles, 2001.  Email from Blake Biles to Jeff Cohen on behalf of the
Brominated Solvents Consortium (BSOC).  Contains the BSOC estimates of
world-wide nPB sales for the calendar years 2000, 2001, 2002. 
A-2001-07, II-A-79.  

CERHR, 2004. NTP-CERHR Expert Panel report on the reproductive and
developmental toxicity of 1-bromopropane.  Center for the Evaluation of
Risks to Human Reproduction. Repro Toxicol. Vol.18, pp.157-188.  2004. 
(EPA-HQ-OAR-2002-0064-0096) 

Degreasing Devices, 2006.  Website for Degreasing Devices.  URLs:  
HYPERLINK "http://www.degreasingdevices.com" 
http://www.degreasingdevices.com ,   HYPERLINK
"http://www.degreasingdevices.com/rentals.htm" 
http://www.degreasingdevices.com/rentals.htm ,   HYPERLINK
"http://www.degreasingdevices.com/degreasers.htm" 
http://www.degreasingdevices.com/degreasers.htm ,   HYPERLINK
"http://www.degreasingdevices.com/degreaserssmall.htm" 
http://www.degreasingdevices.com/degreaserssmall.htm ,   HYPERLINK
"http://www.degreasingdevices.com/finance.htm" 
http://www.degreasingdevices.com/finance.htm ,
http://www.degreasingdevices.com/retrofit.htm

Gormley, 2001.  Email from Pamela Gormely, Thermal Equipment Corp. to
Margaret Sheppard, EPA.  April 3, 2001.  A-2001-07, II-A-75.

IBSA, 2002.  The International Brominated Solvents Association. 
Presentation to EPA.  September 17, 2002.  A-2001-07, II-A-60.

ICF, 2001.  ICF Consulting Memo to Margaret Sheppard.  Initial Screening
of Impacts on Small Businesses Using nPB.  August 30, 2001.  A-2001-07,
II-A-54.

ICF, 2004.  “The U.S. Solvent Cleaning Industry and the Transition to
Non Ozone Depleting Substances.  Prepared from the U.S. EPA September,
2004.  Retrieved at   HYPERLINK
"http://www.epa.gov/ozone/snap/solvents/EPASolventMarketReport.pdf" 
http://www.epa.gov/ozone/snap/solvents/EPASolventMarketReport.pdf .

ICF, 2005.  ICF Summary of Cal/OSHA Airborne Contaminants Advisory
Committee Meeting.  May 18, 2005.  Available in docket
EPA-HQ-OAR-2002-0064 at www.regulations.gov.

ICF, 2006.  nPB Risk Screen for use in solvent cleaning, aerosol
solvents and adhesives.  Available in docket EPA-HQ-OAR-2002-0064 at
www.regulations.gov.

Kenyon, 2000.  Presentation to 16th OORG meeting–Solvents Sector, May
2, 2000  Alternative Chemicals/Technologies to Replace Ozone Depleting
Solvents, Presentation by William Kenyon, Global Center for Process
Change and Joe Felty, Raytheon Systems Company, for the 16th OORG
Meeting, Solvents Sector; Washington D.C., May 2, 2000.  A-2001-07,
II-A-44.

Kenyon, 2001. Email to W. Kenyon from RRage1 Re: Questions from B.
Kenyon about nPB market. August 28, 2001.  A-2001-07, II-A-72.  

Lake City Army Ammunition Plant, 2003.  Submission by Lake City Army
Ammunition Plant providing data to support approval for limited use of
nPB in coating applications.   Submitted June 3, 2003. 
(EPA-HQ-OAR-2002-0064-0029).

Magid, 2005.  Dr. Hillel Magid conversation with Margaret Sheppard. 
November 16, 2005.  .Available in docket EPA-HQ-OAR-2002-0064-0208 at
www.regulations.gov.

McCulloch, 2001.  April 16, 2001 revised draft, “Projecting Future
Solvent Demand” from A. McCulloch, University of Bristol and Marbury
Technical Consulting with cover letter to EPA from Enviro Tech
International.  A-2001-07, II-A-66.

romothane™?”

  HYPERLINK
"http://www.bromothane.com/FAQs/FAQ.Q52_DegreaserCostBuy.html" 
http://www.bromothane.com/FAQs/FAQ.Q52_DegreaserCostBuy.html 

Murphy, 2002.  Margaret Sheppard call with Rod Murphy, Degreasing
Devices Company.  July, 2002.  A-2001-07, II-A-77.  

OSHA, 1996.  The Occupational Safety and Health Administration (OSHA). 
Final Economic and Regulatory Flexibility Analysis for OSHA’s Standard
for Occupational Exposure to Methylene Chloride.  January 7, 1996. 
A-2001-07, II-A-44

PEI, 1990a.  Occupational Exposure and Environmental Release Data for
Chlorofluorocarbons (CFCs) and their Substitutes, Revised Draft.  PEI
Associates for US EPA/ OTS (Contract 68-D8-0112).  November 19, 1990. p.
7-7.

PEI, 1990b.  Occupational Exposure, Environmental Release, and Control
Analysis for Aqueous Cleaning Substitutes for 1,1,1-Trichloroethane and
CFC-113 for Cleaning of Electronic or Metal objects, Revised Draft.  PEI
Associates for US EPA/ OTS (Contract 68-D8-0112).  November 16, 1990. p.
3-8.

Radian, 1993.  Radian memorandum to Paul Almodovar, EPA, estimating the
number of halogenated solvent cleaners.  May 26, 1993.  A-2001-07,
II-A-42.

Raymond, 2005.  Email to Margaret Sheppard from Dr. Larry Raymond
regarding the health impacts and subsequent treatment costs of nPB
impairment.   November 2, 2005.  Available in docket
EPA-HQ-OAR-2002-0064-0178 at www.regulations.gov.

Ruckriegel, 2002.  “Information Supporting n-Propyl Bromide as a
Solvent for Use in Industrial Manufacturing Adhesives.” M. Ruckriegel
of Poly Systems.  November 11, 2002. (A-2001-07, II-D-63)

Singh, 2001.  Singh emails re: content of iPB impurities in nPB.  July
27, 2001; September 24, 2001.  A-2001-07, II-A-74 and A-2001-07,
II-A-84.

Stratus, 2004.  Screening Analysis to Assess Potential Impacts on Small
Businesses in Regulation of n-Propyl Bromide in Solvent Cleaning”
prepared for Margaret Sheppard.  November 2, 2004.  .  Available in
docket EPA-HQ-OAR-2002-0064 at www.regulations.gov.

Stratus, 2005a.  Spreadsheet Economic Analysis of nPB Solvent Markets.  

Tattersall, 2005.  Conversation between Margaret Sheppard, EPA, and Tom
Tattersal of MicroCare Corp.  June 29, 2005.  .Available in docket
EPA-HQ-OAR-2002-0064 at www.regulations.gov.

TEAP, 2001.  UNEP (United Nations Environmental Programme):  Geographic
Market Potential and Estimated Emissions of n-Propyl Bromide. Report by
the Technology and Economic Assessment Panel (TEAP) Task Force of the
Solvents, Coatings and Adhesives Technical Options Committee (STOC). 
April, 2001.  A-2001-07, II-A-21.

TEAP, 2006.  UNEP (United Nations Environmental Programme):  Report of
the Technology and Economic Assessment Panel.  Progress Report.  May
2006.  Available in docket EPA-HQ-OAR-2002-0064 at www.regulations.gov.

U.S. Census Bureau, 2005.  General Summary of 2002 Economic Census of
Manufacturing in the United States.  Retrieved June, 2005 from 
http://www.census.gov/econ/census02/data/us/US000_31.HTM.

U.S. EPA, 2003.  Summary of Data on Workplace Exposure to n-Propyl
Bromide, May 21, 2003.  EPA’s summary of exposure data from nPB
suppliers and NIOSH. (EPA-HQ-OAR-2002-0064-0015 and
EPA-HQ-OAR-2002-0064-0016).

Appendix I:  Abbreviation List 

American Conference of Governmental Industrial Hygienists (ACGIH) 

Environmental Protection Agency (EPA)

ICF Consulting (ICF)

International Brominated Solvents Association (IBSA)

National Emission Standard for Hazardous Air Pollutants (NESHAP)

North American Industrial Classification System (NAICS)

n-propyl bromide (nPB)

Material Safety Data Sheet
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 PAGE   25 

Analysis of Economic Impacts of Final nPB Rulemaking for Cleaning
Solvent Sector 2-7-07

 PAGE   

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