Telephone log:  return call from Ed Williams, LPS Laboratories  Tel.
770-243-8914

6/1/2007

Ed Williams called concerning nPB and the proposed rule that would
prohibit the use of nPB in aerosols.

LPS’s customers use nPB in spot applications, rather than production. 
He spoke to an industrial hygienist, who thought it would be a challenge
to get up to 10 ppm (TLV).

LPS is looking for end users to do a study.  Mr. Williams asked, how
many users would be necessary for EPA to consider the test valid?  I
responded, the more users, the better—at least 10.

They are looking at a plant that extrudes vinyl and cuts it—they use
aerosols solvent for cleaning/maintenance as they go, as needed.

LPS believes that brake shops applications would be of concern—they
are operating all day, all the time.

In their future comments, LPS might give description of different
applications, describing exposure patterns (e.g., brake cleaners,
electrical contact cleaning).

Mr. Williams commented that nPB is one of the more expensive
alternatives—people tend use only if they are not comfortable with
flammable cleaners

If nPB is not available, more users will switch to flammables and more
expensive options (e.g., HFEs, HFCs)—If plastic compatibility is not
an issue, people would like to use nPB if not comfortable with flammable
options.

