

Margaret Sheppard/DC/USEPA/US 

10/17/2007 04:07 PMTo 

"richardastrust.com" <richard@astrust.com>



cc

Karen Thundiyil/DC/USEPA/US@EPA, Dave Godwin/DC/USEPA/US@EPA, Julius
Banks/DC/USEPA/US@EPA



bcc











Subject

comments on draft safety guidelines for use of HCR-188C









 

For Follow Up:

  



Urgent Priority

 



 

Richard,

Thank you for providing us with draft safety guidelines for HCR-188C. 
EPA's comments are attached.  Comments are added in Word using the
review function. 



I will repeat my earlier general comments.  I have tried to incorporate
specific language in the Word document to address some of these issues.



In general, I sometimes found it hard to follow who is responsible for
taking certain steps.  For example, which apply to automotive
technicians?  to someone repairing a refrigerator?  to a person removing
refrigerant from an appliance at its end of life?  Often, I found it
hard to tell which procedures are relevant only to appliances, relevant
only to motor vehicles, or relevant to both.  



In the long run, the procedures will probably be easier to follow if
they are broken up by the intended audience.  For example, there might
be one section devoted to procedures for technicians evacuating
refrigerant from a refrigerator or freezer and a separate section for
automotive technicians.



Also, some statements are expressed as commands, while others are
informational phrases.  I think the procedures will be easier to follow
if the statements are all stated as commands.  Make clear what the
action is, who needs to do it, and when it needs to be done.



Please let me know if you have questions about specific comments.



Margaret Sheppard

USEPA/Stratospheric Protection Division

SNAP Program

Tel. 202-343-9163

Fax 202-343-2362

email: sheppard.margaret@epa.gov

