United States
                  Environmental Protection
                  Agency
Air and Energy Engineering
Research Laboratory
Research Triangle Park, NC 27711
                   Research and Development
EPA/600/S2-89/061  Feb. 1990
4*EPA         Project Summary
                   Alternative  Formulations to
                   Reduce  CFC  Use  in  U.S.
                   Exempted  and  Excluded  Aerosol
                   Products
                   Thomas P. Nelson and Sharon L. Wevill
                  Chlorofluorocarbons (CFCs) were
                  banned  from  use as aerosol
                  propellants In the U.S. in 1978.
                  However, the ban allowed for certain
                  exemptions   if  it   could  be
                  demonstrated that no acceptable
                  alternative propellants were available
                  and that the products were essential.
                  Essentiality was  based on  three
                  criteria: 1) the  economic significance
                  of the product; 2) the environmental
                  and health impacts of the product and
                  its substitutes; and 3) the effects on
                  the quality of  life resulting from no
                  longer having the product or  a
                  reasonable substitute available.  If  a
                  CFC served some purpose other than
                  as the propellant, that product  was
                  excluded from the  regulation. This
                  report  examines  the products
                  exempted and excluded from the 1978
                  ban,the present consumption of CFCs
                  still utilized for these products in the
                  U.S., and alternative  formulations
                  which may  be used to reduce or
                  eliminate the  CFC  content of these
                  products. The study shows that about
                  40% of the CFC  usage in  these
                  products can be immediately replaced
                  by  available  substitutes.  Seven
                  categories of products were identified
                  for which immediate replacement of
                  all of the CFC  content  is  not
                  technically feasible. Complete  CFC
                  replacement in these products must
                  await the commercialization of newer
                  substitutes currently being developed
                  by industry.  However, some  reform-
                  ulation is possible  in the interim for
some of these  seven categories,
allowing for reduction of CFC usage.
The product category requiring the
longest time to reformulate appears to
be  metered-dose inhalant  drug
products which will require the newer
chemicals and which must also be
subjected to regulatory approval by
the   U.S.  Food   and   Drug
Administration.
  This  Project Summary  was
developed by EPA's Air and Energy
Engineering  Research Laboratory,
Research  Triangle  Park,  NC,,  to
announce key findings of the research
project that is fully documented in  a
separate report of the same title (see
Project Report ordering information at
back).

Introduction
  The use of Chlorofluorocarbons (CFCs)
in categories of aerosol propellant use
considered "nonessential" was banned in
the  U.S. by regulations promulgated in
1978.   An  aerosol was defined  as  a
package consisting of a self-pressurized,
non-returnable  container constructed of
metal, glass, or plastic that  contains  a
fluid product and that is fitted with a valve
for expelling the product as a spray,
liquid, gas, foam, powder, or paste. The
banned CFC propellants were the fully
halogenated types: CFC-11, CFC-12,
CFC-113, CFC-114, and CFC-115.
  New  EPA regulations  were pro-
mulgated in 1988 to  implement the
Montreal Protocol  of 1987.  Under the
1988 regulations, the  entire supply of

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fully halogenated chlorofluorocarbons will
be reduced.
  tn view of the recent renewed interest
in reducing worldwide production and
consumption  of  CFCs  and  other
chemicals implicated in the depletion of
the Earth's  stratospheric ozone layer, the
U.S. Environmental Protection  Agency
(EPA)  undertook  a study  of currently
exempted  and  excluded  CFG  aerosol
applications and  their alternatives.  The
report of that study is summarized in this
document.
  The  EPA report lists  CFG aerosol
applications exempted and  excluded by
the 1978 regulations and  provides the
rationale for those cases. Technically
feasible methods  for reducing CFCs in
these aerosol products are suggested.
  Formulation options for  a number  of
products that  currently use regulated
CFCs are presented, as are the factors
considered  in developing  the alternative
formulations.  Formulation  options are
presented in the context of flammability
(on©   of   the   most   important
considerations), manufacturing difficulty,
cost, and end-use acceptability.
  Conclusions are  presented  for seven
categories of aerosol uses in which  CFCs
are most difficult to eliminate, and partial
or  interim  reformulations  of  some
categories  to  decrease CFG use are
noted.   Possible  CFC reductions, based
on several scenarios, are shown.
  Elements of  the  proposed   CFC
reduction plan are compared with the
scheduled  reductions  called for by the
1987 Montreal Protocol, and  additional
studies on aerosol  formulation are
recommended.

Exempted/Excluded CFC  Aerosol
Applications

  Table 1 lists CFC aerosol applications
exempted from  EPA's  1978 regulation.
Tho 14 applications  shown in Table 1
were exempted because they required a
CFC propellant  for reasons of safety,
health,  or national security.Some  CFC
aerosol applications were excluded  from
the 1978 regulation because they contain
propellant only; that is, the  propellant is
the  sole  ingredient and  may be
considered  the product itself. If the  CFC
serves  any  purpose  other than  as the
propelling agent, the CFC is deemed an
active ingredient and  the product is also
excluded from  regulation.  Table 2 lists
such excluded CFC aerosol applications.
Rationale for Exempting,
Excluding, or Not Regulating
  The rationale applied in 1978 and 1979
by  EPA  and  the  Food and  Drug
Administration (FDA) when considering
proposed exemptions included:
•   The need  for  a  nonflammable
    product;
•   The 5 years often taken by the Drug
    Division  of  the  FDA to approve an
    Amended  New  Drug Application
    (applies to bronchodilators and other
    inhalants);
•   Required  solvency and  purity
    profiles;
•   Doctrine  of equivalency-that  highly
    similar products  cannot  reasonably
    be treated differently
•   Limited   availability of  substitute
    propellents or products;
•   Stratospheric ozone  impact  (e.g.,
    production tonnage per year) and
•   Life-saving potential  of the proposed
    exempted  product  (e.g.,  medical,
    military, flammable gas  alarm
    systems).
  The  rationale for  exempting  specific
essential  uses of  CFC aerosols  is
examined.  The 14 specific applications
listed  in Table  1 are discussed, as  are
specific excluded applications  (such as
skin chillers  used for medical purposes)
and nonregulated applications.
  Approximately 28  product  types and
groups have been or are being produced
in  aerosol formulas  that  contain CFCs.
Background  data on  each product or
product group are provided, including
how  the  CFC  component  functions.
Industry's interest in preserving the CFC
ingredient(s) is  explained.  The primary
reasons for requesting exempted  status
were the unavailability of substitutes, the
long delays while obtaining approval from
the  FDA,  solvency and purity  profiles
(especially for CFC-113 uses), life-saving
potential of the  product,  and  regulations
in  hospitals,  aircraft organizations, etc.
against the use  of flammable propellents
in aerosols.
  During the 1977  to  1978 transition
period, no  nonflammable liquid propellant
alternatives to CFCs were lexicologically
approved and commercially available for
use.   Today  the situation  has changed,
with  the clearance  of  HCFC-22 and
certain blends of HCFC-22/142b, and the
forthcoming   availability of HFC-134a,
HCFC-123, HCFC-141b, and HCFC-124.
  As  may   be anticipated,  some
exempted, or excluded, products are no
longer in use or have been replaced with
ones  that contain alternative  propellants.
However, inhalant and solvent type
products are steadily  growing in  sales
volume.

Factors Considered When
Developing Alternative
Formulations
  Two or more  formulation options  are
presented for a number  of products that
currently use  regulated CFCs.   Some
have  a relatively greater potential than
others for stratospheric ozone depletion.
  The following factors were  considered
when developing  the  alternative
formulations:
• Production of  sprays with desired
  particle size distribution;
• Control of flammability;
• Precautionary  use  of questionable
  solvents, such as methylene chloride;
• Miinimum  changes in  anticipated use
  patterns;
• Maintenance  of  dispenser and
  organoleptic stabilities;
• Cost of alternative formulations;
• Availability of the alternative, including
  Toxic Substance Control Act  (TSCA)
  considerations;
• Pressure limitations;
• Product utility  or efficacy for intended
  uses;
• Toxicological factors; and
• Spray rate  and   use-up  rate
  optimization.

Aerosol Reformulation Options
(1989-1993)
  When  substituting alternative  aerosol
formulas for  CFC-based aerosol
products, one  of the  most  important
considerations is flammability.   De-
pending on circumstances, one or more
of three main formulation routes (shown
in Figure 1 will be taken.
  For companies  producing  CFC
aerosols, the  transition  to non-CFC
formulations will increase in difficulty and
cost (and often decrease in acceptability)
as the replacement formulas go from
Type  1A to 3B (shown in  Figure 1).

Costs of Converting Filling
Lines
  Many  of  the current fillers and
marketers of  non-pharmaceutical  CFC-
type aerosol products  are not equipped
to handle flammable  propellants.   To
handle Type 3  products, most would
either have to 1) commit  capital, time,
and training  resources to convert, while

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       Table 1.  Exempted Aerosol Propellent Applications-1978
        1.   Release agents for molds used to produce plastic and elastomeric materials.
        2.   Lubricants for rotary-type press-punches for the production of pharmaceutical tablets.
        3.  Lubricants, cleaner-solvents,  de-dusters  or coatings for industrial/institutional applications to electronic  or
           electrical equipment.
        4.  Mercaptan stench warning devices for mines.
        5.  Other warning devices, such as intruder alarms; boat horns, bicycle horns.
        6  Flying insect pesticides for use in commercial food handling areas, except when applied by total release or
           metered valve aerosol devices.
        7.  Propellants for flying insect pesticides for the fumigation of aircraft.
        8.  Flying insect spray for tobacco barns.
        9.  Metered dose inhalant drugs, as follows:
               steroid drugs for humans, (oral and nasal),
               Ergotamine tartrate drugs, and
               Adrenergic bronchodilator drugs (oral).
        10. Contraceptive vaginal foams for human use.
        11. Aerosols for the maintenance and operation of aircraft.
        12. Aerosols necessary for the military preparedness of the U.S.
        13. Diamond grit sprays.
        14. CFC-II5 (CCIF2-CF3 for the aeration of puffed food product.
               Table 2. Nonregulated CFC Aerosol Applications (Propellant as Active Ingredient)


                1.   CFC-12 used as a polyurethane blowing agent (insulation foams).
                2.   CFC-12 and CFC-114 mixtures used in tire inflators.
                3.   Certain specialty foams, whips, and puffs.
                4.   Medical solvents such as silicone-based bandage adhesive (CFC-113) and bandage adhesive
                    remover (CFC-113, with 5% CO2.
                5.   CFC-12 and CFC-114 refrigeration and air-conditioning system refill units.
                6.   Drain openers.
                7.   Microscope slide cleaners.
                8.   Computer cleaners and dusters (equivalent to No. 3 in Table 1).
                9.   Boat horns.
                10.  Halon  fire extinguishers (4 and 15 oz. containers)
                11.  Intruder alarm sonic devices for homes and cars.
                12.  Skin chillers (medical).
still accepting a statistical risk of fire or 2)
use a contract  filler equipped  to  handle
flammable propellents.
  The  conversion  cost for  a  medium-
speed Type 3 aerosol line would average
$900,000.   Smaller  operators  would
probably use contract  fillers rather  than
convert.  Some  of the larger  operators
would be expected to convert only one
line, while the remaining  larger operators
would probably convert only to Type  1
and Type 2 products or use a contract
filler.
  Table  3  shows estimates of the  total
industry  costs  of  in-house  filler
conversions from  CFCs to the Type 1, 2,
and 3 products defined in Figure 1.
Conclusions
  Seven categories  of aerosol  uses
involving CFCs have been  judged most
difficult to eliminate:
1. Certain mold releases.
2. Lubricants for electrical and electronic
  applications;
3. Lubricants for  pharmaceutical  pill and
  tablet presses;
4. Solvent  cleaners  and  dusters  for
  electronic and electrical equipment;
5. Metered-dose inhalant drugs;
6. Contraceptives for human use;and
7. Solvents for medical use.
Partial or interim reformulations for some
of  the products in these categories are
noted, as are possible reductions, based
on  several  scenarios,  for  CFC
consumption in the U. S.
  The perceived need for CFCs in  these
seven product categories is based on the
lack  of  available alternatives that can
completely  replace  the  CFCs  at  the
present  time; however, approximately 40
percent of the  CFCs  now used  in
exempted, or excluded  U.S. aerosol
products can be replaced  immediately.
Further, alternative non-CFC formulations
for some  of the seven remaining  CFC-
dependent  categories   are judged,
technically  feasible,  pending the
commercial  availability of  four "future1"
HCFCs  and HFCs.  Longer-range  CFG

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   7". Nelson and S. Wevilf are with Radian Corp., Austin, TX 78720
   N. Dean Smith is the EPA Project Officer (see below).
   The complete report, entitled "Alternative Formulations to Reduce CFG Use in
        U.S. Exempted and  Excluded Aerosol Products," (Order No. PB90
        149972IAS;Cost: $23.00, subject to change) will be available only from:
            National Technical Information Service
            5285 Port Royal Road
            Springfield, VA 22161
            Telephone: 703-487-4650
   The EPA Project Officer can be contacted at:
            Air and Energy Engineering Research Laboratory
            U.S. Environmental Protection Agency
            Research Triangle Park, NC 27711
United States
Environmental Protection
Agency
Center for Environmental Research
Information
Cincinnati OH 45268
Official Business
Penalty for Private Use $300
EPA/600/S2-89/061

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