"Andrew Hackman" <ahackman@cspa.org> 

02/15/2008 04:59 PM	To

	Margaret Sheppard/DC/USEPA/US@EPA

	cc

	"'Doug Fratz'" <dfratz@cspa.org>

	bcc

	

	Subject

	RE: Supplemental CSPA Comments on Docket ID No. EPA-HQ-OAR-2002-0064

	

						

	History:	

		This message has been replied to.			

Margaret,

Sorry for the delayed response I have been traveling this week and
soliciting clarification from our members.

As you have seen from the data in our comments, end-users typically
apply n-PB aerosols in short bursts lasting a second or less (dispensing
only a few grams) onto various electronic and electrical parts
throughout a manufacturing plant on an as-needed basis. Most of the time
a cleaning application is made directly to components of the
manufacturing equipment itself to eliminate electrical shorts or the
physical jamming of mechanical equipment. 

Therefore, "generally well ventilated" implies general plant
ventilation.  In these situations, fans and standard HVAC ventilation
systems provide building-wide ventilation.  

In the limited case where use of an entire aerosol product or more (such
as Facility D) was witnessed, well ventilated referenced specific
exhaust ventilation and fume hoods.

I hope this is helpful.

Thank you,

Andy Hackman

Director of State Affairs

The Consumer Specialty Products Association

Phone: (202) 833-7328

Fax: (202) 872-8114

Cell: (703) 608-2326

 

Confidentiality Notice: This e-mail message (including any attachments)
contains information from the Consumer Specialty Products Association
(CSPA)

and is covered by the Electronic Communications Privacy Act, 18 U.S.C.

2510-21, and is intended only for the named recipient (or recipients)
and

CSPA member companies. This e-mail, including any attachments or
hyperlinks

within it, may contain information that is confidential or otherwise

protected from disclosure. If you are not the intended recipient of this

email, you are not entitled to use, disclose, distribute, copy, print,

disseminate or rely on this email in any way. Even if you are the
intended

recipient or a CSPA member company, you may not distribute, disclose or

otherwise disseminate this email or its attachments outside the
membership

of CSPA, without CSPA's prior written consent.

-----Original Message-----

From: Sheppard.Margaret@epamail.epa.gov

[mailto:Sheppard.Margaret@epamail.epa.gov] 

Sent: Monday, February 04, 2008 5:01 PM

To: Andrew Hackman

Subject: RE: Supplemental CSPA Comments on Docket ID No.

EPA-HQ-OAR-2002-0064

Andrew,

Thanks for your follow-up.

I have another question after looking at the surveys, particularly
appendix B.  For question 5, I would like clarification what the
customers are likely to mean when they respond that the area is
"generally well ventilated."  For example, is this likely to mean that
there are fans and regional ventilation systems but not specific exhaust
ventilation and not fume hoods?  Is there agreement among users about
what "generally well ventilated" means, either quantitatively or in
terms of equipment used?

I expect to have a better idea of the status after talking with my new
boss, who starts later this month.

Margaret Sheppard

USEPA/Stratospheric Protection Division

SNAP Program

Tel. 202-343-9163

Fax 202-343-2362

email: sheppard.margaret@epa.gov

                                                                        

             "Andrew Hackman"                                           

             <ahackman@cspa.o                                           

             rg>                                                     To 

                                      Margaret Sheppard/DC/USEPA/US@EPA 

             02/04/2008 09:37                                        cc 

             AM                                                         

                                                                Subject 

                                      RE: Supplemental CSPA Comments on 

                                      Docket ID No.                     

                                      EPA-HQ-OAR-2002-0064              

                                                                        

                                                                        

                                                                        

                                                                        

                                                                        

                                                                        

Margaret,

Now that we are into 2008, I wanted to touch base and see what the
status is of the proposed rule on nPB in aerosol products.

Please let me know if there is anything else that we can do or provide.

If

it is of interest we could also try and pull together a meeting of our
members to discuss any concerns that the Agency still has.

Thanks again,

Andy Hackman

Director of State Affairs

The Consumer Specialty Products Association

Phone: (202) 833-7328

Fax: (202) 872-8114

Cell: (703) 608-2326

Confidentiality Notice: This e-mail message (including any attachments)
contains information from the Consumer Specialty Products Association
(CSPA) and is covered by the Electronic Communications Privacy Act, 18
U.S.C. 2510-21, and is intended only for the named recipient (or
recipients) and CSPA member companies. This e-mail, including any
attachments or hyperlinks within it, may contain information that is
confidential or otherwise protected from disclosure. If you are not the
intended recipient of this email, you are not entitled to use, disclose,
distribute, copy, print, disseminate or rely on this email in any way.
Even if you are the intended

recipient or a CSPA member company, you may not distribute, disclose or
otherwise disseminate this email or its attachments outside the
membership of CSPA, without CSPA's prior written consent.

-----Original Message-----

From: Sheppard.Margaret@epamail.epa.gov

[mailto:Sheppard.Margaret@epamail.epa.gov]

Sent: Friday, December 07, 2007 2:02 PM

To: Andrew Hackman

Cc: 'Doug Fratz'

Subject: RE: Supplemental CSPA Comments on Docket ID No.

EPA-HQ-OAR-2002-0064

Andy,

Thanks again for checking to see if we have any further questions.  So
far, I have just one question:  were any of the four facilities for
which you provided exposure data also included among the 29 customers in
the profiles?

I am aiming to complete a draft document for internal EPA review before
the end of the year.    Our current schedule is for a final rule in
summer of 2008.

Margaret Sheppard

USEPA/Stratospheric Protection Division

SNAP Program

Tel. 202-343-9163

Fax 202-343-2362

email: sheppard.margaret@epa.gov

             "Andrew Hackman"

             <ahackman@cspa.o

             rg>                                                     To

                                      Margaret Sheppard/DC/USEPA/US@EPA

             11/29/2007 02:40                                        cc

             PM                       "'Doug Fratz'" <dfratz@CSPA.ORG>

                                                                Subject

                                      RE: Supplemental CSPA Comments on

                                      Docket ID No.

                                      EPA-HQ-OAR-2002-0064

Margaret,

Thank you again for the opportunity to submit our supplemental comments
earlier this month.  I wanted to touch base with you again and see if
you or anyone else from your office has had any questions about the
additional data and comments that we submitted.

I also wanted to see if there is a timeline for future action on this
issue.

Thanks again for including us in this process.

Andy Hackman

Manager of State Affairs Programs

The Consumer Specialty Products Association

Phone: (202) 833-7328

Fax: (202) 872-8114

Cell: (703) 608-2326

Confidentiality Notice: This e-mail message (including any attachments)
contains information from the Consumer Specialty Products Association
(CSPA) and is covered by the Electronic Communications Privacy Act, 18
U.S.C. 2510-21, and is intended only for the named recipient (or
recipients) and CSPA member companies. This e-mail, including any
attachments or hyperlinks within it, may contain information that is
confidential or otherwise protected from disclosure. If you are not the
intended recipient of this email, you are not entitled to use, disclose,
distribute, copy, print, disseminate or rely on this email in any way.
Even if you are the intended

recipient or a CSPA member company, you may not distribute, disclose or
otherwise disseminate this email or its attachments outside the
membership of CSPA, without CSPA's prior written consent.

-----Original Message-----

From: Sheppard.Margaret@epamail.epa.gov

[mailto:Sheppard.Margaret@epamail.epa.gov]

Sent: Monday, November 19, 2007 10:41 AM

To: Andrew Hackman

Cc: 'Doug Fratz'

Subject: Re: Supplemental CSPA Comments on Docket ID No.

EPA-HQ-OAR-2002-0064

Mr. Hackman and Mr. Fratz,

I received your supplemental comments.  Thank you for working together

with your members to provide us this information.  I am looking forward
to reading through it.

Sincerely,

Margaret Sheppard

USEPA/Stratospheric Protection Division

SNAP Program

Tel. 202-343-9163

Fax 202-343-2362

email: sheppard.margaret@epa.gov

