"Bromberg, Kevin L." <kevin.bromberg@sba.gov> 

02/09/2007 11:41 AM	

To

"'Flynn, Amy E.'" <Amy_E._Flynn@omb.eop.gov>, Jeff Cohen/DC/USEPA/US@EPA

cc

Subject

FW: 134A transition Issues

 



 

From: SLewit@aol.com [mailto:SLewit@aol.com] 

Sent: Friday, February 09, 2007 11:40 AM

To: kevin.bromberg@sba.gov; jmcknight@NMMA.ORG

Subject: 134A transiton Issues

Mr. Bromberg;

 

Per our conversation today,  I want to state for the record that the
change from R22 to 134A requires much more then than the “hand
holding” that some foam producers have indicated.  I am having first
hand and experience with this today.

 

Our company licensed our patented PRISMA technology to two divisions of
a major boat builder.  The first division (BB-134) was licensed in early
2005 and was already using 134A.  The second division (BB-R22) was
licensed in the summer of 2005 and was using R22 foam.

 

Our supplier, BASF produces the foam for all three companies (Compsys,
BB-134, and BB-R22).   We ran parts for BB-134 and BB-R22 at our plant
using our R22 system.  We were able to successfully produce parts using
our R22 system.

 

BB-R22 had the tools transferred from our plant to their plant.  Within
24 hours BB-R22 was successfully producing parts with R22 foam.

 

BB-134 could not use R22 foam so our supplier produced what we were told
was the 134A version of our foam.  They sent this foam to BB-134. 
BB-134 had no success with that 134A formulation or with numerous other
134A formulations sent in by the suppler.   To prove that it was a foam
issue we sent the tool back to us at Compsys.  We performed trials with
our R22 systems and once again we were able to produce good parts.   The
suppler has spent over 14 months working with BB-134 and Compsys to
develop a 134A foam system that will work.  

 

The issue is so severe that we have had to ship tools from our plant to
our foam suppler so that they could work in their laboratories to
develop a workable 134A formulation.  The effort continues without
success to this date. 

 

This single experience caused great expense and hardship on both our
company and BB-134.  Keep in mind we are working with BB-134 on only 4
different tool configurations.  COMPSYS has over 2000 different parts
that we produce and the holding company of BB-134 and BB-R22 produces
tens of thousands of boats.

 

Also keep in mind when the foam suppliers say they have qualified a 134A
system, they have done so in their laboratories.  Here conditions are
ideal.  In the boat factories we do not have nearly the ideal conditions
of the labs.  The process sensitivity of 134A vs R22 is not known,
however based on our experience to date and the experience of other boat
builders we very concerned.   

 

It is completely un-realistic to expect successful industry transition
in only 10 short months.   Our industry needs to have until 2010 as
agreed or the change will cause undo hardship on our company and on the
entire boating industry.

 

Thank you for your further consideration on this issue

 

Scott Lewit

---------------------------------------------

Scott M. Lewit

Compsys, Inc.

Structural Composites, Inc

7705 Technology Drive

W. Melbourne, FL 32904

321-951-9464

321-728-9071 (f)

slewit@aol.com

  HYPERLINK "http://www.structuralcomposites.com/_" 
www.structuralcomposites.com  

www.preforms.com

