MEMORANDUM
FROM:
Hodayah
Finman
TO:
Docket
DATE:
July
27,
2006
RE:
Developing
country
requests
for
CFCs
for
use
in
MDIs
EPA
contacted
several
developing
countries
that
obtain
pharmaceutical
grade
CFCs
from
US
companies
to
determine
if
these
countries
would
still
require
some
amount
of
CFCs.
The
Agency
took
action
in
December
2005
to
virtually
eliminate
CFC
production
for
export
to
developing
countries
but
later
learned
that
some
countries
would
continue
to
require
small
volumes
of
CFCs
for
use
in
medical
devices.
Two
countries
indicated
to
EPA
that
they
still
require
CFCs
for
MDIs.
One
country
wrote
to
EPA
on
May
30,
2006
and
indicated
that
they
still
had
a
need
for
CFCs
in
2007
and
2008
and
requested
that
EPA
allow
for
the
continued
export
of
modest
amounts
of
material
to
satisfy
this
patient
need.
A
second
country
contacted
the
Agency
by
phone
in
June
2006
and
indicated
that
although
they
did
not
have
specific
data
they
could
easily
share
with
the
EPA,
that
they
did
have
a
continued
need
for
CFCs
for
MDIs
for
2007,
2008
and
possibly
beyond.
They
too
requested
that
EPA
consider
allowing
some
amount
of
production
for
export
to
their
country.
The
Agency
subsequently
learned
through
a
discussion
on
the
topic
of
developing
countries
and
CFCs
for
use
in
MDIs
at
the
49th
Meeting
of
the
Executive
Committee
that
oversees
developing
country
phaseout
projects
under
the
Montreal
Protocol,
that
indeed
this
party
was
experiencing
difficulties
in
their
transition
away
from
CFCs
in
the
MDI
sector.
