ESSENTIAL USE DETERMINATIONS—REVISED
          SUPPORT DOCUMENT
   ENVIRONMENTAL PROTECTION AGENCY
FULLY HALOGENATED CHLOROFLUOROALKANES
           March 17, 1978

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                   TABLE OF CONTENTS
I.    ESSENTIAL USE DETERMINATION METHOD	1

II.   ESSENTIALITY DETERMINATIONS AS OF
      PROPOSAL  	 6

III.  MIDWEST RESEARCH INSTITUTE REPORT 	 A-l

IV.   ESSENTIALITY DETERMINATIONS AS OF
      PROMULGATION  	 B-l

V.    MIDWEST RESEARCH INSTITUTE REPORT 	 C-l

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                      ESSENTIAL USES







Introduction







     This document describes the decision process EPA used



in granting essential use exemptions for certain uses of



chlorofluorocarbon aerosol propellants, and explains the



determinations reached for each product or use for which there



was a request for a waiver.  The reports prepared by EPA's



contractor, the Midwest Research Institute, are included,



along with other pertinent material.  For a comprehensive



picture of EPA's approach to alternatives and essential uses,



please refer to pages 8-11 in the "Final Support Document."



     A draft of this document was made available at proposal.



It has been revised following further Agency review.







Essential Use Determination Method







     Prior to proposal of this regulation in May 1977, EPA



published two Federal Register notices and held two public



meetings soliciting information from the public on the



availability of alternatives to chlorofluorocarbon pro-



pellants.  41 FR 49514  (November 7, 1976); 42 FR 1066  (January 5,



1977).  The notice for the second meeting specifically sought



comments on EPA's proposed criteria for granting exemptions.

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Following the January meeting, further comments were sought

from about 30 individuals who had contacted EPA with questions

or comments on the essential use issue.  EPA strongly encouraged

industry to submit requests for exemptions prior to proposal

so that tentative decisions could be published at the time of

proposal, and many did so.  Other requests were submitted

during the comment period on the regulation.

     After considering the points raised in discussions with

industry and the other government agencies represented on the

chlorofluorocarbon work group, the following four criteria

for determining essentiality were adopted by EPA:

     1.  Nonavailability of alternative products.

     2.  Economic significance of the product, including
         the economic effects of removing the product from
         the market.

     3.  Environmental/health significance of the product.

     4.  Effects on the "Quality of Life" resulting from
         no longer having the product available or using
         an alternative product.

     In evaluating the first criterion,  (the nonavailability

of alternative products), EPA looked at the safety and per-

formance capabilities of alternative propellants and alter-

native nonaerosol products.  Three pertinent factors influencing

each decision were:

     1.  The present indication that F-22 may be mutagenic
         meant that F-22 could not presently, if ever, be
         considered a substitute propellant.

     2.  The possibility of ozone destruction by the bromochldro-
         alkanes and bromofluoroalkanes make these undesirable
         substitutes.

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     3.  Because of the flammability of hydrocarbons, their
         use is less desirable in products where the flammability
         hazards could be increased, such as in confined space
         or high temperature applications, and where there
         is no safe way to reduce the possible hazard.

     The second criterion concerned the possibility that a

ban of a particular product would creat  severe economic hard-

ship because of the prohibitive cost of the substitute or

doing without the product.  This consideration did not include

the impact of the regulation on the chlorofluorocarbon and

related industries as this was accounted for in the economic

analysis.

     The last two criteria referred to the public benefit

that would be derived by permitting continued use of the

chlorofluorocarbon product  (or the detriment that would result

if the product were no longer to be available).

     Decisions to grant exemptions were based on all of the

above criteria.  No single factor was sufficient to determine

that a product or particular use was essential.  The non-

availability of an alternative did not itself suffice.  The

product also had to provide an important societal benefit to

obtain an exemption.  If an alternative existed, however, it

was not necessary to make any judgments concerning the other

criteria.

     The flow chart on page 5 was designed to systematize

the work group's consideration of each request.  Each

decision diamond for each product was discussed using the

data for information.  Decisions were recorded on special forms

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which are found in the Official Record of Rulemaking.  Work



Group unanimity was reached in most cases.  Any minority



opinions were recorded on the special forms.



     The categories of products for which EPA has reached a



decision are:



     la)  Flying insect pesticides



     Ib)  Wasp and hornet sprays



     2)   Other pesticides



     3)   Spray paints



     4)   Mine warning devices



     5)   Mold release agents



     6}   Solid lubricants



     7)   Liquid lubricants



     8)   Battery terminal protection



     9)   Paper frictionizing indicator



    10)   Electronic cleaners



    11)   Aerosol Computer Tape developers



    12)   Diamond grit spray

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                                        Figure
                                                1:  Flow Diagram for
                                                   Essentialicy Determination
                                                                           Yes
       Is an
   Alternative
  Propellant or
 Product Utility
    Available?
                               Is  the Environ/
   Is the Economic \ Yes
Impact of Alternative
     Acceptable?
                             Health Impact of
                             the Alternativ
                              A ceptable?
   Is  the Environ/
  Health Impact  of
 Removal Acceptable2
   Is the Environ/
  Health Impact of
 Retaining Product
     Acceptable?
 Is the Economic
Impact of  Removal
   Acceptable?
  is rhe Environ/
 Health Icpact of
Retaining Product
    Acceptable?
Non-
essential
                                                                               Essential
                                                                            Non-
                                                                            essential
                                                                              Nonessential
                                                                             Nor.es s*n-is 1
                                                                             tssentiai

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II.   Essentiality Determinations  As  of Proposal
     la.   Flying Insect Pesticides
     Decision:  Exemption granted for flying insect  pesticide use in
                nonresidential  food  handling establishments  and poultry
                coops; and for space-spraying of aircraft.
     Reason:    For most uses environmentally acceptable methods of appli-
                cation, alternative  propellents exist such as compressed
                air quns, foggers,  carbon dioxide and nitrogen.  These
                alternative methods  will provide products of lower or equi-
                valent costs because the cost of additional  equipment (e.g.
                carbon dioxide tanks, liquid nitrogen storage) would be off-
                set by the lower ingredient cost.
                For the specific areas of nonresidental food handling
                and aircraft decontamination, the above alternatives
                were not considered adequate substitutes for the following
                reasons..
                Food Handling
                The alternative methods would produce a coarse spray,
                thus resulting in a decreased suspension time of the
                active insecticidal ingredient.  As a result, more of
                the active  insecticide would have to be released to
                produce  the same result as  CFC propelled sprays.
                 In general,  this would  increase  the potential  for food

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         contamination by insecticides, some of which, depending
         en dosage, are already suspect health hazards.  The
         potential for food contamination with its subsequent
         health  effects would outweigh the health effects resulting
         from decreases in ozone.
         Aircraft  Decontamination
         CFC -   propelled insecticides are currently  used
         to  prevent the spread of  insects and disease on aircraft.
          Insects could be dangerous  to crops, fibers,  and animals
         in  various parts of  the world.  At  present,  no equally
         effective method of  application exists.  The spread  of
         disease would have a more adverse health effect
         than  the  small amounts of chlorofluorocarbons required
         in  this application.  Substitutes also  may  not meet  safety
         requirements for aircraft transportation.
Ib.  Wasp and Hornet  Sprays
Decision: Nonessential
Reason:  Although  not extensively  tested,  substitute propellants
          (carbon dioxide  plus chlorinated  hydrocarbons or  nitrogen)
          are available to  provide  the jet  spray  required  to knock
          down wasp and hornet nests.  Release of the substitute
          propellants  would  not result in adverse health or environ-
          mental  effects.   The lower cost of  the  substitute pro-
          pellants  is  estimated  to  balance the additional  cost of
          carbon dioxide tanks and  nitrogen storage  facilities.

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2.   Other Pesticides
Result:   Nonessential
Reason:   The effectiveness of pesticides depends upon the pesticide
          remaining in contact with the area to be treated.  Alterna-
          tive methods of application such as mechanical pump sprayers
          and brushes can provide the same result as the use of
          chlorofliiorocarbon propelled aerosols.  The alterna-
          tive methods are environmentally and economically and accep-
          table.  Therefore, the chlorofluorocarbon pesticides were
          judged to be nonessential.
3.   Spray Paints
Result:   Nonessential
Reason:   Not only, is an alternative propel 1 ant (hydrocarbons)
          available, but it is also currently used in 97% of spray
          paints.
4.   Mine Warning Devices
Result:   Essential
Reason:   The alternatives possessing the necessary chemical and
          toxic properties (e.g. miscibility with ethyl mercaptan,
          vapor pressure,  low toxicity,  flame suppression, etc.),
          belong to  the class of bromochloroalkanes and bromobluoro-
          alkanes which are also suspected to be destroyers of ozone.
          The removal of the present product using about 2000 pounds
          world-wide per year of F-ll would not balance the possible

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     adverse effects cf removing the product from the market.
5.  Mold Release Agents
Result:  Nonessential except for use as a release agent In plastic
         molding.
Reason;  Alternative methods of application such as airless spray,
         air sprays, electrostatic sprays, carbon dioxide exist
         and are currently in use for large-scale applications in
         rubber molding and foundrys.  However, the above methods
         do not provide the requisite film thickness to be workable
         for plastic molding at the present time.  Because of the
         pervasiveness of plastic molded products in critical  use
         applications  (e.g. medical supplies), removal of chloro-
         fluorocarbon  release agents would have more adverse
         environmental/health effects than their retention for this
         application.
6.  Solid Lubricants
Result: - Nonessential
Reason:  Alternative methods of application such as brush, dip,
         carbon  dioxide, and nitrogen exist and do not have adverse
         environmental/health impacts.   Use of alternative pro-
         pellants  could require reformulation of the solvent
         system  and some additional  testing for use in specific
         applications, but  this is  not expected to require large
         investments.

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7.   Liquid Lubricants
Result:  Nonessential
Reason:   Many alternative methods of application exist such as
          oil cans, compressed air, carbon dioxide, trichloro-
          ethane, and hydorcarbons.  While the hydrocarbons are
          flammable, the concentration of oil in chlorofluoro-
          carbon propelled already makes them flammable.  The
          alternative methods of oil cans, compressed air and
          carbon dioxide are all environmentally acceptable and
          little economic impact is anticipated from the change-
          over.
8.   Battery Terminal Protection
Result:   Nonessential
Reason;   Adequate alternative propel!ants exist (carbon dioxide,
          mechanical devices-, and hydrocarbons) and are environ-
          mentally acceptable.  The impact on the economy removal
          is considered to be insignificant.
9.-  Paper  Fritionizing Indicator
Result:   Nonessential
Reason:   In'general, other methods of  application are  feasible.
          Nonchlorofluorocarbon aerosol and  nonaerosol  methods of
          application are considered  viable  alternatives.   Because
          the  paper  fritionizing. indicators  are a  closed  technology,
          the  availability of corroborating  evidence was  not  possible  to
          obtain.   However,  it  is  beleved  that alternative  systems
          could  be made availafae.
                                 10

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10.   Electronic Cleaners
     Result:   Nonessential
     Reason:   Alternative methods of application such as carbon dioxide
               and mechanical systems are possible for most uses.  Carbon
               dioxide is currently used in some retail trade products.
               Mechanical systems are currently in the developmental
               stage but are expected to be available on a commercial
               basis within a year or more.  Conversion to carbon dioxide
               systems would involve small capital investment which could
               be offset by slightly higher selling price.
    11.    Aerosol Computer Taoe Developers
     Results:  Nonessential
     Reason;   Nonaerosol methods of delivery such as eyedroppers and
               brush are currently available.   In'addition, a reuseable
               system is also available.   Since there are no adverse
       :        environmental effects from  the substitutes and the cost
               of the substitute  units are comparable to  the propelled
      -        system,  the use of fluorocarbons was considered  non-
               essential.
      12.  Diamond Grit  Spray
      Result:  Nonessential
                                     n

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Reason:  Other environmentally and economically acceptable methods
         of application exist and on this basis the product was
         considered nonessential.
                                   12

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                Essential Use Determinations
                         Appendix B
    The Environmental Protection Agency, subsequent to the
proposed regulation of chlorofluorocarbons as aerosol
propellants, has made additional essential use de-
terminations.  The following categories of products were
examined:

    1)   Agents for Latent Fingerprint Development
    2)   Anti-Spatter Compounds for Welding
    3)   Aerosol Spray to Produce Smoke for TV or
           Movie Productions
    4)   Spray Mold Release Agent for Medicine Tablets
    5)   Leather Spray Polish Preservative
    6)   High Voltage Spray Insulation
    7)   Clipper Coolants and Lubricants
    8)   Moisture Removal Spray
    9)   Engine Degreasers
   10)   Electric Shaver Cleaners and Lubricants
   11)   Electronics and Aviation
   12)   Diamond Grit Spray
   13)   Pesticides

    The method used in making essential use determinations
is* discussed on page 1.

Essentiality Determinations

    1.   Agents for Latent Fingerprint Development

         Result:  Nonessential

         Reason:  Nonaerosol and hydrocarbon propellant sys-
                  tems are adequate substitutes for CFC
                  aerosols.  Since work is normally done
                  under a ventilation hood, safety is not
                  adversely affected.  Economic impact is
                  slight, and may be favorable if bulk
                  chemicals are used.

    2.   Anti-spatter Compounds for Welding

         Result:  Nonessential

         Reason:  One type of anti-spatter compound appears
                  to require the use of F-12 as a
                  carrier/propellant, so that no known
                  alternative is acceptable for this
                  formulation.  However, other formulations
                  to accomplish the same task use aqueous
                  carriers and carbondioxide propellants, or
                  are brush-applied.


                           B-l

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              This product can apparently be
              brush-applied (nonaerosol use of F-12 as
              a carrier is not restricted).  The
              economic impact of brush application
              would be minimal,  since most welders
              brush surfaces to  be welded.

3.   Aerosol Spray Used to Produce Smoke for TV or
       Movie Productions

     Result:  Nonessential

     Reason:  Nonaerosol fog generators are commonly
              used.  Carbon dioxide should be an ac-
              ceptable alternative propellant.  There
              are no known adverse health, safety, or
              environmental effects of these
              alternatives, and  the economic impact of
              substitution is considered slight.

4.   Spray Mold Release Agent for Medicine Tablets

     Result:  Nonessential

     Reason:  This product is actually a lubricant of
              moving parts of tablet machines not of
              the mold.  Brush application of the
              lubricant is commonly used by many phar-
              maceutical manufacturers, and carbon
              dioxide should prove an acceptable
              alternative propellant.  The economic
              impact of switching to alternatives,
              which are cheaper, is minimal.

5.   Leather Spray Polish Preservative

     Result:  Nonessential

     Reason:  Mechanical pump sprayers and hydrocarbon
              propellant systems are generally
              acceptable alternatives, with little or
              no adverse health  and environmental
              effects.  These alternatives are econo-
              mically competitive with CFC propellants
              so that no appreciable increase in cost is
              expected.

6.   High Voltage Spray Insulations

     Result:  Nonessential

     Reason:  One of the two major manufacturers of this
              product is converting to a hydrocarbon
              propellant, which  is environmentally ac-

                       B-2

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               ceptable and will not result in
               significantly increased costs.

 7.    Clipper Coolants and Lubricants

      Result:  Nonessential

      Reason:  Hydrocarbons and carbon dioxide are ac-
               ceptable alternative propellants,  and ap-1
               plication by brush or manual  pump spray
               is possible.  No adverse environmental or
               health effects are expected, nor is there
               a cost penalty to the user for conversions
               to these systems.

 8.    Moisture Removal Spray

      Result:  Nonessential

      Reason:  Major manufacturers of this product are
               using carbon dioxide and hydrocarbon-
               methylene chloride propellants.  These
               alternatives are environmentally ac-
               ceptable and economically competitive.

 9.    Engine Degreasers

      Result:  Nonessential

      Reason:  The great majority of aerosol engine de-
               greasers currently use hydrocarbon propel-
               lants.  Liquid application is also avail-
               able, either by brush, manual pumps, or
               air compressor.  The health and
               environmental, impacts of these
               alternatives are acceptable.  Finally,
               liquid application costs no more than
               aerosol application, and may result in net
               cost savings.

10.    Electric Shaver Cleaners and Lubricants

      Result:  Nonessential

      Reason:  A hydrocarbon propellant system will soon
               be introduced by the only national
               distributor of this product.  The possible
               adverse effects due to the flammability of
               hydrocarbons have apparently been
               remedied.  Brush application of the
               product is effective and environmentally
               acceptable.  The economic impact of either
               alternative should be small, with a cost
               saving expected if brush application is
               desired.

                        3-3

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11.   Electronics and Aviation

      Result:  Essential

      Reason:  Essential use exemptions have been granted
               to the segments of the electronics and
               aviation industries which use
               chlorofluorocarbon aerosol sprays for
               non-military uses.  These exemptions are
               not permanent.

               Because of limited data base at this time/
               EPA is deferring decisions on the essenti^
               ality of such uses.  While there are some
               electronic and aviation products for which
               there are alternative propellants or
               application techniques, there appear to
               be some uses for which chlorofluorocarbons
               may be necessary (such as for the main-
               tenance of aircraft and computer systems.)
               By postponing a final decision on these
               uses, EPA intends that the industry will
               use the added time to make an inventory of
               all the products using chlorofluorocarbon
               propellants and to investigate the avail-
               ability of substitutes.  Because of the
               cooperation of the industry thus far, EPA
               does not believe it is necessary at this
               time to promulgate a TSCA section 8(a)
               rule to gather this information.  The
               Agency also anticipates that information
               obtained from the Department of Defense
               (DOD) concerning .the products it uses
               will be of substantial benefit in evalu-
               ating those products which are used for
               both military and non-military uses.

               A final decision on whether to continue,
               and or narrow this exemption is unlikely
               before the end of 1978.  EPA will con-
               tinue its evaluation as further data are
               developed and in conjunction with its re-
               view of essential DOD uses.  It should
               also be noted that the use of F-113 as
               an active ingredient in many of these
               products will be reviewed in Phase II.
               The impact on the environment of the
               added delay is tolerable.  While we are
               unable to obtain a precise estimate of the
               quantities of chlorofluorocarbons fal-
               ling within the electronics and aviation
               exemptions, we believe less than one
               percent of all chlorofluorocarbons pro-
               duced for propellant uses are involved.

                        B-4

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                Furthermore some  firms  are  already  using
                substitute propellants  since  they are
                usually less costly.

.12.   Diamond Grit Spray

      Result:   Essential

      Reason:   A one person business that  manufacturers
                diamond-grit spray for  high quality lapi-
                dary use has expressed  a  need for an ex-
                emption for the spray.  In  order to pro-
                duce approximately 3000 cans  of the spray
                per year, the business  uses approximately
                three hundred pounds of chlorofluoro-
                carbons.  The business  claims that  no
                technically and economically  reasonable
                alternatives to the present product are
                available.  In view of  the  miniscule
                amount of chlorofluorocarbons that  would
                be released into  the atmosphere if  the
                use were to continue, EPA has granted  an
                essential use exemption for diamond grit
                spray for lapidary use.   This determina-
                tion supersedes the earlier determination
                found on page 15.

 13.   Pesticides

      Result:   Exemption granted for flying  insect
                pesticide use in  nonresidential food
                handling areas except when  applied  by
                total release or  metered  valve aerosol
                devices, and for  space-spraying of  air-
                craft.

      Reason:   Numerous requests seeking essential use
                exemptions for various  pesticide products
                were received.  All requests  have been
                denied except for cerain  uses in
                nonresidential food handling  areas  and for
                the space-spraying of aircraft.  Each
                determination was based on  information
                submitted by the  requestors and the EPA
                contractor, on the informal rulemaking
                hearing record, and on  advice provided to
                the Office of Toxic Substances by the
                Office of Pesticide Programs.

                The Agency wishes to stress that the
                essential use exemptions  granted here  do
                not permit any use of a pesticide the  use
                of which is otherwise prohibited or
                limited by Federal law.  Registrants,

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distributors, purchasers, and users of
pesticides are expected to comply with
pertient restrictions under the Federal
Insecticide, Fungicide, and Rodenticide
Act, the Federal Food, Drug, and Cosmetic
Act, the Federal Meat .Inspection Act, the
Poultry Products Inspection Act, and any
other applicable law.

Description of Aerosol Dispensing Devices

There are several types of aerosol
products used to apply pesticides.  In
addition to the standard aerosol
product, there are total release sprays
which release the entire contents of the
container at one time.  There are also
metered valve devices which release set
quantities of the active ingredient at
periodic intervals.  Finally, there are
fogging valve devices.  The total release,
metered spray, and fogging-valve systems
are commonly used for volumetric treatment
of industrial/institutional sites.  The
main advantages of using chlorofluoro-
carbon propellants in such systems are the
small, uniform droplet size they produce,
their low flammability potential, and
their solvent characteristics.
Chlorofluorocarbon formulations produce
tinier particles which remain suspended in
the air for a longer time than those
produced by nonchlorofluoro-
carbon formulations.  This suspension time
is known as the "hang time."

Requests for Exemptions

Numerous requests were received seeking to
extend the proposed exemption for
nonresidential food handling areas to uses
in livestock areas, all nonresidential
establishments, and in all areas of the
home.  Other persons sought exemptions
for the use of chlorofluorocarbons in
metered valve and total release aerosol
products.  Persons seeking exemptions
contended that the superior hang time of
Chlorofluorocarbon propelled pesticides
makes their use essential.  They argued
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that the shorter hang time of pesticides
using hydrocarbon or carbon dioxide
propellants would make it necessary to
use more of the pesticide to achieve
equivalent results, at the risk of greater
human exposure to pesticide residues.
Some requesters asserted that there were
no cheap, efficient alternatives.

Basis for Denial

While it is true that it may be necessary
to use greater amounts of a pesticide if a
nonchlorofluorocarbon propellant is used,
hang time and exposure factors are of
particular concern only in those special
cases where human exposure (inhalation,-
dermal, oral) may present a problem.
Generally, humans, food, and food
utensils can be and are excluded from
treatment areas during application.
Consequently hang time is not a critical
consideration since there is less risk of
exposure to the pesticide.  In commercial
and institutional food handling areas,
however, it is not always possible to
avoid exposing people, food, and food
equipment during treatment or shortly
thereafter.  Further, sufficient
precautions are not always taken.  Under
such circumstances it is important not
only that the amount of filth (insect
parts) in food be reduced, but that
exposure to pesticide residues be
minimized.  Since use of
chlorofluorocarbons will enable the
applicator to use less of the pesticide
to achieve the desired result, EPA has
concluded that use of chlorofluorocarbon
propellants in pesticides is essential.
For the reasons described below, this
exemption does not permit such
applications by metered valve or total
release devices.

For use in locations other than
nonresidential food handling areas,
alternative propellants
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such as hydrocarbons, carbon dioxide,
nitrous oxide, propane, and isobutane may
be used.  Examples of nonaerosol
alternatives are fog generators,
compressed air sprayers, hydraulic
sprayers, and flit guns.

Permitted Uses

The exemption for nonresidential food
handling areas permits use only in
commercial and institutional food
handling areas such as the kitchens,
dining areas, and pantries of restaurants
and schools.  Use of chlorofluorocarbon
formulations in livestock areas such as
barns and poultry houses is not permitted
unless the food product is actually
handled in that area.

Metered Valve Devices

EPA has denied all requests for
exemptions for chlorofluorocarbon metered
valve devices.  In view of the continuing
controversy about their public health
benefit, it is impossible to conclude that
they provide an important benefit which
warrants- the release of additional
chlorofluorocarbons into the atmosphere.

As pesticide manufacturers themselves
have stressed, an importa it goal of toxic
chemicals regulation is to minimize human
exposure to toxic chemicals.  In the case
of metered spray devices, EPA, the Food
and Drug Administration, and various
advisory committees have been concerned
for some time that the automatic release
of pesticides by metered valve devices,
regardless of the need for them,
needlessly increases the exposure of
humans, food/ and food utensils to the
pesticide.  Consequently, the government
has consistently questioned the necessity
for and safety of such devices.  Indeed,
even the legal status of these products
is at issue since no food additive
tolerance under Section 409(c)(1) of the
Federal Food, Drug, and Cosmetic Act has
been granted for use in areas where food
or food utensils may be present.
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Because of these concerns and in light of
the availability of other techniques for
dispersing pesticides, EPA decided to
prohibit all use of chlorofluorocarbons
in metered valve devices.  This includes
a prohibition on use in nonresidential
food handling areas since the benefit
derived from using chlorofluorocarbon
propellants, i.e., minimizing the amount
of the pesticide that needs to be used,
is offset by the additional exposure
resulting from the continuous application
of the product.

Total Release Products

Specific requests for exemptions were
also received for the use of total release
sprays in homes and at commercial sites.
Several manufacturers have claimed that
the total release dispensing mechanism is
the only means by which a pesticide can
penetrate all the recesses of an area or
achieve an immediate kill of the pests.
No alternative for such products is said
to exist; hydrocarbons are believed to
present a flammabililty hazard because of
the resulting high concentration of g'as in
one area.  Carbon dioxide is not
considered to produce a small enough
particle to allow adequate dispersion.

EPA disagrees with this argument and has
denied a general exemption for total
release products.  The Agency recognizes
that hydrocarbon and carbon dioxide
propellants may be unsatisfactory or
hazardous substitutes for many total
release systems, but the total release
formulation itself is not essential.
While it may offer a convenience over
other application techniques for some
uses, there are adequate alternatives.
Compressed air sprayers and standard
aerosol sprays can be used, as well as
dust mixtures, baits, liquid
formulations, and other pressurized
sprays.  The main difference between the
various systems is that the total release
spray totally envelops the application
area with large quantities of the
pesticide (the intended result being
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that some of it will settle in the areas
where the insects are), whereas the other
formulations are applied to the specific
areas where infestation appears to be
occurring.  (Even with total release
products, it is frequently necessary to
use other pesticides in conjunction since
the total release products usually do not
have a residual long-lasting effect).

Use of total release sprays in food
handling areas is not permitted.  As in
the case of metered valve devices, the
benefit derived from the
chlorofluorocarbon propellant is offset by
the added exposure resulting from the
treatment of the entire room or premises
instead of treatment of the specific areas
where infestation is occurring.

Use in Aircraft

EPA has also granted an exemption
permitting the spraying of
chlorofluorocarbon propelled pesticides
in aircraft for public health and
quarantine purposes.  Since the pesticide
is typically applied while passengers and
crew are on board, it is important to
decrease the human exposure by using a
minimum dosage of the product with the
longer hang time, i.e., the
chlorofluorocarbon product.
        B-10

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                   MIDWEST RESEARCH INSTITUTE REPORT
AGENTS FOR LATENT FINGERPRINT DEVELOPMENT

Product Description and Utility

     Chemical reagents are applied primarily for latent fingerprint develop-
ment on porous and absorbent surfaces (e.g., paper, cardboard, unfinished
wood, etc.) or on slightly textured surfaces (e.g., book covers, some plas-
tics, etc.).  Special fingerprint powders are most effective when applied to
smooth, nonabsorbent surfaces (e.g., glass, metal, painted surfaces, etc.) and
are generally preferred to disclose fresh latent prints at the crime scene.i^-
The chlorofluorocarbon propelled products comprise two basically different
chemical agents., for print development and two agents for the removal of un-
wanted stains caused by the developing agents.  These products are ninhydrin,
silver nitrate, ammonia, and mercuric salts.

Ninhydrin--
     This reagent is typically used as a 0.6% solution in acetone—  or petro-
leum ether.—   When the reagent is packaged as an aerosol spray, F-12 is nor-
mally the propellant.  Mixtures of F-ll and F-12 have been employed if the
reagent is contained in a glass aerosol spray bottle.JLJL'  Ninhydrin solution
may be sprayed or brushed on, or the document may be dipped into the solution.—'
While the essential requirement is to obtain a uniform and complete coverage of
a surface, some experts state that best results are obtained if a surface is
lightly but visibly wet,§jJ^L' but others state that a fine spray should be used
with as little wetting as possible.ZjJLL'  At the present time, ninhydrin is the
agent of preference for developing latent prints on paper and other porous sur-
face s. L^JOJ^IA/
                           •
Silver Nitrate-/-
     The use of silver nitrate is declining2j_L2/ and currently is regarded as
an agent of last resort.—'  It is employed only when large amounts of evidence
are to be processed, t^'  Silver nitrate solutions are used in several dif-
ferent formulations including aqueous solutions of 3 to S7.3.6/ or 107.6>7/ con-
centration, ethanol solutions,£jjj>/ or acetone solution^/ with sufficient
water added initially to dissolve the silver nitrate crystals.  The silver
nitrate reacts with chloride deposits remaining in latent fingerprints, but
it also reacts with traces of chloride found naturally in papers and other
substances to produce a background that reduces print contrast and the clarity
of the evidence. »•**'  Silver nitrate also has the limitation that it is use-
ful only for developing prints no more than 6 months old.z/  Only one company
is believed to supply silver nitrate reagent packaged as a chloroflurocarbon
(F-12) propelled aerosol.7?16»I7/
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Stain Removers--
     Aerosol formulations of stain removers include ammonium hydroxide for
ninhydrin stains—' and mercuric nitrate—' or mercuric chloride^/ for silver
nitrate stains.  Only one supplier is known to offer aerosol dispensed stain
removal sprays using chlorofluorocarbons as the propellant.i^/

     The F-12 employed for both the print developers and stain removers serves
only as a propellant except when ninhydrin is used in conjunction with petro-
leum ether or acetone; in these instances, the F-12 also serves as a secondary
                        71                                  '
solvent for the reagent.—'  Stain removers, silver nitrate, and ninhydrin are
also available as a spray container fitted with an external propellant.!§/
              *
     Little or no use of chemical developers is made at the crime scene' by
officers conducting the search for physical ""•M?n'*g. ^' *0» 13.14.18/  jn con.
trast to the use of powders, chemical development of latent prints is best
performed in the laboratory and physical evidence is carefully removed to the
laboratory where it is processed.IP_o_L£/  Over 90% of all print spraying in
the laboratory is estimated to be done in ventilation hoods.U  Laboratories
processing fairly large amounts of evidence seldom use the aerosol products,
relying instead on sprayers using a source of compressed gas.i^jJAjJJL'  A
national laboratory stated chat they used aerosol containers of ninhydrin
only for touch-up, to enhance the contrast of a previously sprayed print.-i_L'

     The two largest distributors of F-12 propelled aerosol fingerprint sprays
have, a combined annual output of about 40,000 units.ZjJLz/  Unit sizes range
from 2 to 16 oz.  The total annual consumption of F-ll and F-12 is estimated
to be approximately 3,500 to 4,000 lb.7?19/

     There would be no known impact on environmental quality or human health
and safety resulting from the removal of this product from the market.  Public
safety, as influenced by  law enforcement and criminal prosecution, can be
adequately served through the use of alternative methods.

Alternative Products or Systems

     As indicated previously, all of the reagents currently supplied in aerosol
form are feasibly applied by other means.  Although the prepackaged sprays do
represent a convenient and quickly usable form of these products, the substan-
tial majority of latent fingerprint development does not rely upon aerosol
products.

     Silver nitrate solutions present problems for the selection of aerosol
propellants other than F-12.  Some current silver nitrate sprays utilize an
external F-12 container in conjunction with an atomizer bottle.
                                       C-2

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Hydrocarbon Propellant—
     The most logical choice for an alternative propellant for ninhydrin would
be a hydrocarbon mixture.  Because of the high degree of flammability of the
reagent carrier (e.g., acetone, petroleum ether, etc.), the flammability of a
hydrocarbon propellant may not create additional problems (although the chloro-
fluorocarbon has some flame retardant properties).  A major custom aerosol
packager advises that no technical problems should occur in substituting hydro-
carbon propellants for F-12 when either acetone or ether is used as the primary
solvent for ninhydrin.—'  Spraying is normally conducted by trained laboratory
personnel using properly ventilated laboratory hoods so that the flammability
aspect should be minimal.  Hydrocarbon propellants would have no known reaction
or adverse effect on ninhydrin.  Testing of this propellant system should be
conducted since the influence of spray droplet si-*e and spray characteristics
may have an effect on sensitivity.

Carbon Dioxide--
     The use of impact-filled carbon dioxide, in conjunction with either
methylene chloride or 1,1,1-trichloroethane, as a propellant for ninhydrin
may be acceptable.—'  However, ninhydrin is quite sensitive to pH and either
carbon dioxide or its acidic products might adversely affect the stability of
the reagent; also the coarser spray produced by carbon dioxide may affect the
sensitivity of the ninhydrin.

Nonaerosol Sprays--
     Both ninhydrin and silver nitrate can be effectively sprayed using widely
available equipment.  Because of the large volume of reagent consumed, the
Federal Bureau of Investigation (FBI) uses commercial paint spray guns for
ninhydrin.—'  For departments using small quantities of reagent, it wpuld be
necessary to insure that solutions were either freshly prepared or properly
protected.  The advantage cited for the use of freshly prepared solutions in-
clude better results, >  ' greater control over spray patterns,iOjJJL' greater
reliability,8,10,147 significantly lower cost.9i10i18/ and the ability to use
precision, all-glass sprayers.—'

     For portable spraying in the field, rubber squeeze bulb sprayers can be
used where a limited area is involved.  Atomizers sold for nasal and throat
sprays generally provide a very coarse spray that is difficult to control.

     Where freedom from contamination and absolutely no reaction with sprayer
parts is essential, precision, all-glass sprayers can be used for either
laboratory or field use.II.'  These glass sprayers are available from several
suppliers—' and are widely employed in dispersing developing reagents on
paper chroma tograms, etc.  They are available in several spray sizes, including
ultra fine sprays.  If a true aerosol of ultra fine droplet size is desired,
the all-glass nebulizer can be used.ll/
                                      C-3

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Economic Considerations

     The use of hydrocarbon propellants should have little or no economic im-
pact on the consumers of these products.  If aerosol packaging of fingerprint
sprays was completely discontinued, the impact would be felt primarily by
smaller law enforcement agencies having limited laboratory facilities.  Costs
would be associated with the training of technicians to prepare bulk solutions
and the purchase of spray equipment.  In addition, an air compressor and air
line filter/dehydrator would be required unless compressed gas cylinders can
be utilized.  If it is assumed that a ventilation hood is already available
(it should be in use even if aerosol sprays are employed), the total cost of
laboratory glassware,, chemicals, and spraying equipment could be from $250 to
$500/agency.  However, the use of bulk chemicals rather than aerosol sprays is
more cost effective so that an eventual cost savings should result.
                                      C-4

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ANTT-SPATTER COMPOUNDS FOR WELDING

Product Description and Utility

     Spatter is molten metal thrown out of the arc pool in the elctric arc
welding process.  When cool and on an untreated surface, spatter can usually
be removed only by hand grinding or mechanical means.

     Anti-spatter compounds are formulations which are designed to prevent
spatter from adhering to surfaces.  These surfaces include areas on a work-
piece adjacent to a weld, jigs, and fixtures of a welder, and nozzles and
tips of wire welders and MIG guns.23"2*"  After a weld is completed, the anti-
spatter product is removed by wiping, water rinsing, or air blasting from an
air hose.

     One special application of anti-spatter compounds essentially requires
spraying of the material.  This use involves treatment of the nozzles or tips
of MIG welding guns or wire welders to prevent spatter from adhering to the
tip (inside and outside) and thereby interfering with the flow of shielding
gas.

     Several suppliers offer an aerosol packaged spray for nozzles and
tips.23'27"30'  These sprays are particularly useful in directing the coating
up into the inside of the welding gun tip as well as coating the outside of
the nozzle.  Several of these aerosol products are conspicuously labeled:
"Contains no Fluorocarbons,"2*»3 ' or "Contains no Fluorocarbons or Hydrocar-
bons."—'  The industry is conscious of the desire to restrict fluorocarbon
usage, and it appears that alternative propellants have been found to be sat-
isfactory for certain types of anti-spatter products.

     Anti-spatter compositions are usually one of three types.  These are:
(a) inorganic or mineral solids; (b) resins and soaps; and (c) resins or gels
containing silicone fluids or greases.

     At the present time it appears that only one product that is sold directly
to users employs F-12 as the propellant.—'  In this product the primary func-
tion of the F-12 is as a suspension carrier.  Its propellant properties are a
secondary function.  In the formulation, methylene chloride is also added to
decrease the internal pressure.—   Since F-12 has a boiling point of about
-30°C, this particular formulation could not retain the use of F-12 as a carrier
and be applied by means other than an aerosol.  Reformulation of this product
with other solvent carriers (including other chlorofluorocarbons) for appli-
cation by other techniques  (e.g., brushing) have not been attempted.3-2-'  The
                                       C-5

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active ingredient of this proprietary anti-spatter product consists of a finely
dispersed mineral solid suspended in the F-12 carrier/propellant.  The product
is sprayed onto an area, and the weld made immediately through the film of anti-
spatter.—Drying time for the spray is typically 5 to 10 sec.

     This product is packaged in 16 oz aerosol cans, of which 33% is F-12.-3-!/
Approximately 12,000 cans are used annually.22J  MRI estimates that about
5,000 Ib of F-12 are used per year in this product type.

     There should be no impact on environmental quality or human health and
safety associated with the removal of this product without replacement by an
alternative.
              *
Alternative Products or Systems

     A suitable alternative for F-12 in this product line must have suitable
properties as a propellant and as a carrier.  An acceptable carrier should
fulfill the following technical requirements.11'

     *  The carrier must wet metal surfaces well, even when contaminated with
        oil, grease, rust preventives, etc.

     *  The fine dispersion of mineral must be maintained without agglomera-
        tion or serious caking.

     *  The carrier should dry quite readily when sprayed onto the metal
        surface (less than 30 sec).
                                                                           «
     *  The carrier should not corrode the metal or the can.

     *  The carrier must present a minimal hazard to the user.

     The producer states that numerous solvents and carriers have been con-
sidered as a replacement for F-12 because use of a replacement would consider-
                                    •*•) I
ably reduce the cost of the product.^'   None of the replacements have been
successful.

     Several anti-spatter compounds use water as the carrier.-=^j-!2/  DuBois
states that water is not suitable for its product because, even with wetting
agents, the aqueous mixture does not evenly wet grease or oil-contaminated
metallic surfaces.!!'  The use of water also increases the drying time to
between 5 and 10 min.29?32/
                                       C-6

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     Early in 1976, DuBois attempted to substitute a combination of methylene
chloride and carbon dioxide for the F-12 propellant/carrier.  This reformula-
tion proved unsatisfactory because of severe settling and agglomeration of the
mineral.  Severe plugging of the aerosol valve was experienced.  After several
months the product had become so caked that it could not be redispersed on a
paint shaker.H/

     Hydrocarbon propellants present a flammability and explosion hazard.  Use
o£ a flame retardant might be able to reduce a hydrocarbon-propelled spray
from a category of "Extremely Flammable," down to "Flammable," but it is doubt-
ful that the hazard could be totally eliminated.  The use of chlorinated or
brorainated minerals is considered undesirable because chlorinated hydrocarbons
may, under welding conditions, form harmful vapors and gases.

     Other possible alternatives include water-based concentrates (similar to
other anti-spatter products29,30/) which are diluted with tap-water before
being brushed or pressure sprayed onto the work, resinous materials in a sol-
vent base  (typically 1,1,1-trichloroethane or methylene chloride) designed to
be brushed or sprayed onto the metal and having the characteristic of fast
drying, and jellies or pastes which can be applied to the work but are so
widely used for nozzles and tips that they are generally called "tip dips."
These are stated not to be viable alternatives with the DuBois formulation.—'

     Aerosol packaged products using carbon dioxide as the propellent are
available^,27,28,307 for formulations such as the water-based concentrates
and the resinous materials in a solvent base (e.g., 1,1,1-trichloroethane or
methylene chloride).  These products offer the ability to direct the spray
into, the inside of the welding nozrle.  In rare cases they are sprayed on the
work that  is to be welded..

     Most welders and producers of most anti-spatter products consider aerosol
sprays to be prohibitively expensive to use for coating most work to be welded.
Welders continue to use aerosol sprays on gun tips, but they prefer to apply
anti-spatter to the base metal by brushing, wiping, or spraying from an air
line gun.  The DuBois anti-spatter is several times more expensive than other
anti-spatter compounds.  The maker believes that the reluctance of users to
switch to much cheaper products provides evidence that the product is viewed
favorably  on a cost/effectiveness basis.11'

     The options that appear at present for the specific formulation under
consideration are  limited to either complete reformulation of the anti-spatter
compound with sacrifices in drying time and performance or withdrawal of the
product  from the market.
                                      C-7

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Economic Considerations

     If the product is redeveloped either as an aerosol or a bulk compound
for conventional application to the work, the impact on users would be re-
flected in some increased costs due to slower welding and spatter removal
times.

     If the product is discontinued, the greatest impact would be on those
users involved in welding of products where surface appearance is important,
not on welders of plate or structural alloys.  Since users must believe that
each dollar spent for anti-spatter saves more than one dollar in total welding
costs, the impact can be estimated as some multiple of present expenditures on
this product. "For 12,000 units at $3.50 each, a cost multiplier of three sug-
gests impacts on the order of $125,000/year associated with nonavailability of
this product.  The increased costs of welded products would be passed on to
consumers.

     The direct consequences to DuBois if this product could not be produced
would reflect lost sales of less than $50,000/year.  Commissions earned by
500 to 600 sales representatives would be slightly reduced.
                                        0-8

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AEROSOL SPRAY TO PRODUCE  SMOKE  OR  FOG

Product Description  and Utility

      The  common  name used  in  industry  for  this  aerosol  product  is  "Fog  Juice."
The  composition  consists  of a mixture  of F-12 and  light mineral  oil  in  approxi-
mately  50/50  proportions. ll/  it is  packaged  in 16 oz containers commonly
called  "Pressure Packs."   Rather than  using  spray  nozzles,  the  containers are
equipped  with a  connector  similar  to that  on a  tire inflation hose.!£/   The
fog  effect  is produced when the fine spray of oil  and F-12  from  the  Pressure
Pack comes  into  contact with  an electrically heated hot plate.   The  oil is
vaporized and becomes smoke.  'Depending on the  type of  scene being created,
the  audience  sees either  smoke  or  fog.  The  "Fog Juice" is  used  in the  pro-
duction of  stage shows,  television shows,  motion pictures,
      The quantity of F-12 propelled  product  used  each  year is  approximately
 1,500 16-oz  containers.x-i/  Since  the  compound  is approximately 507, F-12,  the
 use  of the  compound  results  in the release of approximately 750 Ib/year of
 chlorof luorocarbon.   The total usage is  very small since  one can will  provide
 30 min of smoke,  and most smoke or fog scenes only require smoke generation
 for  10 to 15 sec.34"36'   The two major distributors of this F-12 propelled
 product are  Mutual Hardware  Corporation located in New York and the Aztec
 Company located in Florida.

     .The chlorofluorocarbon  propelled  spray  permits the use of a compact equip-
 ment package, not requiring  an air compressor.   Tne smoke generators equipped
 with "Pressure Packs" can be remotely  operated  thereby permitting easier stage
 settings and fewer people to operate the machine.

      The F-12 propellant is  soluble  in the hydrocarbon oil and therefore is
.capable of establishing a fairly constant vapor pressure  within the container.
 The  constant pressure is a benefit to  regulating the quantity  and quality  of
 spray desired.

      No information  was obtained indicating  that harmful  by-products are formed
 from the F-12 when it is in  contact  with the heated surface of the smoke gene-
 rator.  The distributors of  the smoke  generators  contend  that  the machine  should
 be used with adequate ventilation. —   The primary danger quoted from use  of
 the  machine is that  panic situations could arise  in crowded areas if some  mem-
 bers of the 'crowd thought that the generated smoke was the result of an actual
 fire.?-l/  This situation could exist whether or not the chlorofluorocarbon
 propellant was used  in the smoke generation.

      The removal of this product without replacement by an alternative would
 generally have no known impacts on environmental quality, human health, and
 safety.

                                        C-9

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Alternative Products or Systems

Nonaerosol Fog Generator--
     This type of machine has been in use for over 50 years and does not re-
quire the use of propellant gases.H'  The machine uses light weight mineral
.oil and produces smoke from the use of heat and the conversion of water into
steam.  The use of an air compressor or manual pump is required to spray the
heated oil into the smoke generating area.  Dry ice can be used with the
machine to create special density effects with the generated smoke.

Dry Ice—
     In -some instances dry ice has been used in theatrical, movie and tele-
vision productions to simulate the effect of smoke or fog.!£/  The vapor pro-
duced by the dry ice is difficult to disperse and may limit the degree to
which special effects are obtainable.

Carbon Dioxide—
     Impact—filled carbon dioxide should be an acceptable propellant system
provided that the coarser spray pattern does not substantially affect the de-
sired results.  Sprays of light lubricating oils, consisting of a mixture of
hydrocarbons, commonly use this propellant system.  It appears reasonable Co
assume that with some reformulation, this propellant should also be applicable
to the light weight mineral oil used in this type of product.

Other Compressed Gases—
     Industry sources indicated that compressed gases such as nitrogen, air,
nitrous oxide, etc., are not presently being used in the industry. =£*•=£'  The
solubility of the gases in the oil would probably be very small and therefore
cause the pressure of the can to decrease by a factor of 3 to 4 from the time
the can is put into service up to the point where insufficient pressure is
available for proper operation.

Hydrocarbon Propellants—
     This product is not commonly packaged with a hydrocarbon propellant.   The
primary reason for not using hydrocarbons is related to the safety factor in-
volved in filling cans with a flammable propellant.  The chlorofluorocarbon
propellant was selected by the supplier because of the positive safety factors
and the increased costs to the manufacturer associated with equipment changes,
insurance, etc., when using hydrocarbons.!!/  Since the fog machines using
pressurized containers were designed for the F-12 propellants, additional
testing would be necessary to establish any smoke machine equipment changes
required, the shelf life of the pressurized container, and the smoke character-
istics or effects possible when using hydrocarbon propellants.
                                       C-10

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F-22 Propellant--
     If available, this chlorofluorocarbon would be an acceptable alternative.
No problem would be anticipated in converting from F-12 to F-22 for this prod-
uct.

Economic Considerations
     At the present time a 16-oz container of this product sells for approxi-
mately $4.50.  Since the manufacturing costs are about 25% of the retail price,
the use of an alternative propellant system should generally have little
effect on the production cost or on the retail price.—'
              >
Carbon Dioxide--
     If this propellant would prove to be acceptable, the resultant product
should prove to be advantageous to the consumer.  The current product employs
50% F-12 whereas with impact-filled carbon dioxide products the propellant
normally represents only approximately 5 to 10% of the total contents.127
However, the cost of the packaged system should probably remain about the same
since the decrease in propellant content is balanced by an increase in light
mineral oil content.  Costs due to any change in filling equipment by the
manufacturer would likely be passed on to the consumer.

F-22 Propellant--
     If available, the use of F-22 in a propellant formulation should require
no changes for the manufacturers and consumer prices should remain essentially
the same as for the F-12 propelled product.  A low cost pressure depressant is
normally used with the higher cost F-22 so that the total cost of the propel-
lant system is about the same as that for F-12.
                                       C-ll

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SPRAY MOLD RELEASE AGENT FOR MEDICINE TABLETS

Product Description and Utility

     The product under consideration is actually not a mold release agent for
medicine tablets but rather a Teflon® solid lubricant sprayed onto selected
external moving parts of a tablet machine.1§/  Rotary type tablet machines
have multiple stations of punches and cams to compress the powder into tablet
form.  This particular product is used primarily to lubricate the upper punch
shafts or barrels and the socket or guide sleeves of the lower punch.  Other
products (e.g., high melting, extreme pressure greases) are used to lubricate
the rotary headvs and other parts.  Grease formulations are not acceptable for
the punches because, as the shaft moves up and down, the grease tends to'mi-
grate to the bottom of the punch and collect a dust of the powdery tablet
material.  This buildup will eventually flake and drop down into the material
being pressed into the tablet, resulting in a contaminated product.  The
Teflon® product resists this downward migration and eliminates the contamination
potential.

     •This aerosol product consists of an ultra-micron size Teflon® in methylene
chloride carrier and propelled by F-12.I/  Approximately 50% of the formulation
is F-12.  From information supplied by the manufacturer, it is estimated that
approximately 4,500 Ib of F-12 are consumed annually for this product.38/  xhe
F-12 is used solely as a propelIant in this product.  Numerous other Teflon®
solid lubricant products are available in aerosol containers; however most, if
not all of them, contain binders which are not suitable for this application.^/

     The removal of this F-12 propelled product from the market would have no
adverse impact on environmental quality or human health or safety.

Alternative Products or Systems

     Alternative methods for the application of solid lubricants have been
described in a previous report.xZ.'  A brief discussion is given below for some
of these methods as they apply to this particular situation.

Hydrocarbon PropeHants--
     This propellant system would be a suitable alternative except for the
flammability potential.  The manufacturer states that most pharmaceutical pro-
ducers do not like to employ flammable materials in their production facili-
ties. H/

Carbon Dioxide —
     Impact-filled carbon dioxide should be a suitable alternative propellant
svstem.  However, the manufacturer has not requested the contract filler to
                                       C-12

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attempt this method.  This system has been utilized for other similar products
so that no problems should be incurred in the formulation of this aerosol prod-
uct.

Brush Application--
     This method is commonly used by many pharmaceutical manufacturers for
lubricating tablet machines.38/  Powdered Teflon® is mixed with a suitable
carrier (e.g., methylene chloride) and applied by brush prior to machine
startup.  The method is somewhat messy and usually results in a coating
rather than the thin film obtainable from an aerosol product.  However, no
operating problems seem to be incurred by this method.

Economic Considerations

     The economic aspects of the alternative methods of application have been
treated in a previous report.1Z/
                                        C-13

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LEATHER SPRAY POLISH PRESERVATIVE

Production Description and Utility

     This product is a proprietary formulation of a viscous liquid which is
applied to raw leather goods for preservation.  It is manufactured by ACA Cor-
poration, Brooklyn, New York, Jim York Chemical Company, Houston, Texas, and
other small companies.  The product is supplied in both drums and aerosol cans
to manufacturers, wholesalers, and retailers of leather goods such as saddles,
boots, belts, and shoes.  The drummed product is offered to larger manufac-
turers using high- volumes of the preservative and is typically applied from a
paint spray type?-apparatus with a high pressure spray device.  Companies and
shops that use smaller volumes purchase the product is aerosol cans (16 oz)
and apply the preservative as an aerosol spray.

     The aerosol product uses F-12 as a propellant.  The preservative is a
viscous liquid, and the F-12 serves to propel the preservative onto the leather
in a finely divided aerosol spray.  Application in this manner provides a uni-
form wetting of the leather surface.

     This product is used by both industrial and commercial firms as well as
individual consumers.  About 757. of che market is in the industrial/commercial
sector and the remaining 25% is in the consumer sector.  Annual sales of the
aerosol cans by Jim York Chemical Company are 20,000 cases of 12 units each or
about 240,000 units/year.  This company produces an estimated 20% of the total
sales volume, so the total annual sales of the industry is about 1,200,000
units. —'  Each unit contains 7 fluid ounces of F-12, so that the total annual
consumption of F-12 is about 8.4 million fluid ounces (716,700 Ib).

     Removal of this product from the market without replacement by an alter-
native would have no adverse impacts on environmental quality, human health,
or human safety.

Alternative Products or Systems

Hydrocarbon Propellants--
     A spray leather preservative is commercially available as an aerosol prod-
uct with a hydrocarbon propellant.22'  The use of hydrocarbon propellents may
create some safety risks because of increased flammability.  The degree of
risk would depend upon the conditions under which the product is used.  The
use of a hydrocarbon propellant results in an otherwise acceptable product.

Carbon Dioxide--
     Impact—filled carbon dioxide is compatible with the other components of
this system and could be used as a propellant system.  Its usage would result
in a more coarse spray than that obtained with either hydrocarbons or F-12.

                                       C-14

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One manufacturer stated that the use of carbon dioxide would produce a suf-
ficiently coarse spray that the product may not be competitive with products
using hydrocarbon propellants due to decreased area coverage per unit weight
of product dispensed.—'

F-22 Propellant--
     If available, this chlorofluorocarbon should be an acceptable alternative.
No problems would be anticipated in the conversion from F-12 to F-22 for this
product.

Mechanical Pump Sprayer--
     A mechanical pump spray system equipped with a trigger spray device would
be an acceptable alternative.  Some leather preservatives are available 'in
less viscous liquid formulations which are applied manually with a cloth,
sponge, etc., or sprayed with a mechanical pump sprayer.—'  High volume con-
sumers use a pressurized spray system, such as a paint spray apparatus or a
compressed air hand sprayer similar to those used for pesticide application,
and do not employ individual aerosol cans except in specialized instances.

Economic Considerations

     The use of a hydrocarbon propellant should present no increase in cost
to the consumer since these products are commercially available at a competi-
tive cost.

     Mechanical pump sprayer should present little, if any, overall increase
in consumer costs.  If a trigger spray system is used, a slight initial cost
may result due to the pump sprayer, but subsequent product could be purchased
as a refill at a lower cost.  The net result should be little or no increase
in costs to the consumer.

     The use of carbon dioxide as a propellant system should not result in in-
creased consumer costs.  Costs of conversion of the F-12 filling systems to
carbon dioxide systems probably would not be passed on to the consumer since
this aerosol product would compete with the hydrocarbon propelled products
currently on the market.
                                       C-15

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HIGH VOLTAGE SPRAY INSULATION

Product Description and Utility

     This product consists primarily of a heavy acrylic used entirely by the
industrial sector (primarily electronics firms) as an insulation material to
prevent corona in high voltage circuits.227  One of the principal uses is in
television repair.i2.'   The acrylic is propelled from the container by F-12,
whose sole function is that of propellant.

     Chemcronics, Incorporated is the major producer of this relatively low
volume product.^/  The total annual sales volume for the entire market of
this product is estimated to be 20,000 to 30,000 units per year.^P-/  This
corresponds to a total F-12 annual consumption of approximately 6,200 Ib.

     The removal of this product from the market without replacement by an
alternative would have no adverse impacts on environmental quality, but re-
moval could place humans at risk from the corona developed in high voltage
circuits,

Alternative Products or Systems

     Alternative delivery systems must be capable of dispensing the acrylic
such that a thin, uniform layer is applied.  Upon drying, the resultant film
should provide an even, pinhole-free coating to the parts.

Hydrocarbon Propellents—'—
     The major producer of this product has successfully formulated and tested
an aerosol using a hydrocarbon propellant system.  Present acrylic formulations,
excluding propellants, are flammable.  Use of a hydrocarbon propellant will
increase the flammability of this product.  No significant additional problems
are anticipated in view of the current precautions stated for the use of this
product.  Chemtronics planned to convert its product to this propellant in
January 1978.

Carbon Dioxide£P_/~
     This propellant system has been tested and found to produce an uneven
dispensing pattern which resulted in the formation of an uneven film.'  Test
results showed this product to be unacceptable for its intended purpose.

F-22 Propellant--
     If available, this chlorofluorocarbon would likely be an acceptable al-
ternative.  No problems would be anticipated in the reformulation of the
acrvlic to accommodate the use of this propellant.
                                       C-16

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Economic Considerations

     The use of the hydrocarbon propellant system will not result in any appre-
ciable increased costs to the consumers.—'

     If available, the use of F-22 in a propellant formulation should require
no changes for the manufacturer and consumer prices should remain essentially
the same as for the F-12 propelled product.  A low cost pressure depressant
is normally used with F-22 so that the total cost of the propellant system
averages to approximately that for F-12.
                                       C-17

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CLIPPER COOLANTS AND LUBRICANTS

Product Description and Utility

     Aerosol clipper coolants and lubricants are utilized by veterinarians and
animal groomers to cool, lubricate, and, in one case, to sanitize the blades
of electric clippers before hair removal from a variety of animals.  Although
a number of different companies manufacture and market products that are de-
signed to fill this need, the formulations are similar.  A typical formulation
contains an oil base, a' solvent carried lubricant (a silicone or 1,1,1-tri-
chloroethane), isopropyl alcohol, and the propellant.  In the majority of prod-
ucts the propellant is approximately a 50:50 mixture of F-ll and F-12.—/  One
manufacturer adds a quaternary ammonium compound to improve the disinfectant
quality of the product.^/  Clipper coolants and lubricants are marketed in
6-, 14-, 15- and 16-oz spray cans.

     F-ll and F-12 function primarily as a propellant system.  A secondary
function of the F-ll is as a solvent.  A waxy, greasy material composed pri-
marily of body oil residues is deposited between the blades of the clipper
during the clipping process.i!'  Due to the close juncture of the cutting
blades, this deposit tends to increase friction (thus increasing the tempera-
ture of the blades) and decreases the cutting efficiency resulting in an in-
creased pulling of hair.  In addition to its use as a wetting agent and pres-
sure depressant, the F-ll serves to dissolve this waxy buildup.il/

     Until approximately August 1977, all manufacturers had been using the
F-ll and F-12 propellant system.  Currently two manufacturers are in the
process of altering their propellant system.^i^5/

     One industrial source estimates that the total market for this product
line is approximately 400,000 standard units (16-oz cans) per year.—'   De-
pending upon the manufacturer contacted, chlorofluorocarbons  comprise any-
where from 94 to 987. of the product.  Based on these data,  and assuming 95%
propellant content, approximately 6.5 x 10^ fluid ounces  of F-ll and  F-12 are
consumed yearly.  If the propellant is equally divided between F-ll and F-12,
then about 2.6 x 105 Ib of F-12 and 2.9 x 105 Ib of F-ll are used per year in
the manufacture of this product line.iSJ

     The removal of F-ll and F-12 as the propellant system without replacement
by an alternative should have no known detrimental impacts  on environmental
quality and/or human health and safety.

Alternative Products or Systems

     Alternative propellant systems which substitute other propellants directly
for chlorofluorocarbons exist, and several manufacturers  are in the process of

                                      G-18

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converting to other systems.  Properties that alternative propellents for this
product should provide, include:

     1.  Blade cooling properties;

     2.  Blade lubrication;

     3.  Grease solvent properties; and

     4.  Compatibility with the metal blades.

Hydrocarbon or ^Hydrocarbon Plus Flame Retardant—
     According to an industry source, at least one company is currently In the
process of converting its product to a hydrocarbon propellant system.f_l/  Spe-
cific information concerning the hydrocarbon propellant system was not avail-
able.  Therefore, it cannot be determined whether the system is pure hydrocar-
bon or hydrocarbon plus flame retardant.  If the proper ratio of hydrocarbon
to flame retardant was used, this propellant system could provide the properties
necessary for this product line.  A pure hydrocarbon propellant system could
present a flammability and explosion problem.  The use of water or certain
chlorinated hydrocarbons as ?:.re retardants would reduce this risk, but the
electric shock hazard of *ny water-containing products or inhalation hazards
of chlorinated hydrocarbons would have to be ascertained.
                                                              •
Carbon Dioxide--
     •According to another industry source, it is possible to use impact-filled
carbon dioxide as a propellant system.  The company spokesman indicated that
their product will be impact filled with carbon dioxide as the propellant within
60 days.—'  This alternative propellant will cool, lubricate and be compatible
with the blades.  It will not, however, provide grease solvent properties.

F-22 Propellant--
     This propellant is considered by industry as a feasible alternative for
F-12 if  it becomes available.

Brush Application--
     This product could be applied as a liquid directly to the blades by brush.
This would be more time consuming, and the product may not come into contact
with all surfaces of the blade.

Manual pump sprayer--
     According to an industry source, this system is currently being imple-
mented at one production site.^JL'  The manual pump could meet all parameters
deemed necessary except that it will not provide the rapid cooling effect
observed when F-ll and F-12 are used.
                                     019

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Economic Considerations

     Conversion to the alternative propellants or delivery systems (i.e.,
hydrocarbon or carbon dioxide propellants and the manual pump spray) will not
result in increased consumer costs for this product.
                                       C-20

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MOISTURE REMOVAL SPRAY

Product Description and Utility

     This aerosol product is utilized to remove moisture from electric motors,
electronic equipment, relays, transformers, and other electrical equipment.
These products are formulated with a variety of ingredients for moisture re-
moval and rust prevention.  Two common components are high flash point petro-
leum distillates and certain chlorinated hydrocarbons.  Proper selection of
the chlorinated hydrocarbons will result in a product that has no detrimental
effect on the plastic components of the equipment.£2/  One current formulation
contains approximately 25% F-12 and 75% of a proprietary water removal solvent
generally consisting of chlorinated hydrocarbon solvents plus additives. 12.'
The primary function of F-12 is that of a propellant, although it does lend a
degree of nonflammability to the aerosol spray.

     Principal users of these products are electrical repair personnel, elec-
trical contractors, and others concerned with the restoration of water-damaged
electrical equipment.—'   In general, the product is not used extensively by
large electrical equipment manufacturers^!/ or the general public.

     Attempts to ascertain the quantity of F-12 consumed annually for this
product were unsuccessful.  One contract filler, currently using F-12, could
not identify other manufacturers employing F-12.12.'   Manufacturers of competi-
tive aerosol products, using propellants other than the chlorofluorocarbons,
could not identify any producers using F-12 for this product, "t^"""' but
some small formula tors or packagers of this product may still use F-12.—'
It is estimated that the consumption of F-12 is rapidly declining because of
the conversion by many companies to alternative propellant systems.  In this
regard, the removal of the chlorofluorocarbon propelled product from the mar-
ket would have little, if any, adverse impacts on environmental quality and
human health or safety.

Alternative Products or Systems

Hydrocarbon Propellants —
     Many manufacturers are converting from F-12 to hydrocarbon mixtures as a
propellant for this product.!!/  This propellant does produce a flammable
spray.  However, one manufacturer has used this propellant without any added
flame retardant for a number of years with no known adverse effects.—'  While
it would not be advisable to use this product while the electrical component
is operating and producing an arc or electrical discharge, this restriction is
not a severe detriment to the utility of the product.12.'  For those products
chat utilize a chlorinated hydrocarbon as the principal ingredient, the re-
sultant spray should not have the flammability potential of a normal hydro-
carbon propellant.

                                       C-21

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Carbon Dioxide--
     Impact-filled carbon dioxide is currently used in at least one formulation
consisting of a high flash point (175°F) petroleum distillate and methyl chloro-
form with added penetrants and inhibitors.£§/  Under certain circumstances, the
coarse spray produced by this propellant may affect the surface coverage and
decrease the efficiency of the product.  In some instances, this propellant
may not dispense all of the active ingredient from the container before the
pressure drops to an insufficient level.

Thermal Drying—
     In this procedure, the water-damaged component is removed from the equip-
ment and placed in a drying oven for moisture removal.ULz^.'  Some companies
have walk-in ovens that can accommodate large electrical components.A!/- An
advantage to this method is that no chemicals are in contact with the compo-
nent, thus alleviating any potential detrimental effect of the chemicals.  The
method is much more time consuming since the damaged part is removed from the
system.  For those instances in which removal of the part would not be possible
or very time consuming, space heaters are often employed.is/

Manual Pump Sprayers —
     This type of sprayer is not in common usage and reportedly suffers from
the lack of sufficient pressure to permit satisfactory moisture removal.H/

Solvent Bath—
     For certain applications with small parts, this may be an acceptable
method.  However, for situations requiring disassembly of the machine or in-
strument, the labor required would not make the method cost effective.

Brush Applications--
     This method may be adequate for some applications.  However, in most in-
stances, there is insufficient access to the components to allow adequate
moisture removal by this technique.

Compressed Air Sprayers~
     A compressed air sprayer should be an adequate method for larger equip-
ment or components.  The quantity of product used by this method would likely
be greater.  However, since bulk quantities could be purchased, the overall
cost should not increase appreciably.  This would depend upon the care with
which the product is applied.

F-22 Propellant —
     F-22 could be used as an alternative propellant for most component systems
if it were available.  This propellant may have a detrimental effect on some
component parts, but in general, would be acceptable.
                                      C-22

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Economic Considerations

     There would be no economic impact associated with the use of hydrocarbon
mixtures or carbon dioxide as a propellant system on consumers or users of
these products.  On the current market, both products are priced competitively
with those products using F-12 as the propellant.  The use of the bake-out
ovens for thermal drying would likely be more costly due to the necessity for
removal of the components.
                                       C-23

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ENGINE DEGREASERS

Product Description and Utility

     This product is produced and marketed to industrial and commercial con-
cerns as well as being available to the general public.   Regardless of which
portion of the market utilises the product, its universal purpose is to pro-
vide a rapid and cost-effective method for the removal of grease from various
types of surfaces without damaging the surface.  Grease-free surfaces tend to
improve the cosmetic appearance of areas and can help promote safety.  In ad-
dition, grease-free surfaces improve the ease of accessibility for maintenance
and repairs.  For engines, specifically, use of a degreaser prevents grease
buildup, which could reduce convective heat losses from the engine.  A reduc-
tion in convective heat loss could, under certain circumstances, result in
higher-than-normal engine operating conditions and internal engine damage.

     Engine degreasers have various compositions, but three components are
generally common to this product line:  a solvent, a degreaser, and a pro-
pellant.  The solvent is ordinarily a saturated or an aliphatic hydrocarbon.H£/
The degreaser is a grease emulsification agent.!£/  The propellant is either
a nonflammable blend of isobutane and F-12ii' or a hydrocarbon mixture.—'
The primary function of the F-12/isobutane mixture and the liquifiable com-
pressed gas is to provide a propellant system for the product, although the
presence of the F-12 in the former may lend some degree of nonflammability to
the product.

     Approximately 12 to IS million units of aerosol engine degreaser are pro-
duced annually.—'  A standard unit is a 16-oz can.  According to an industrial
source, the percentage of these aerosol products containing F-12 as a propellant
is very small.  If one assumes that about 27, of the total amount of product
uses hydrocarbon/chlorofluorocarbon mixtures as propellants, then an estimated
40,000 to 50,000 Ib of chlorofluorocarbons (as F-12) may be consumed annually
in the manufacture of this product line.—'  These numbers are approximate
because the propellant in question is a blend of isobutane and F-12.  For the
calculations a 50:50 ratio of hydrocarbon and chlorofluorocarbon has been
assumed.

     Removal of this product without replacing it with an alternative could
affect safety.  An increase in the incidence of accidents which could be attri-
buted  (directly or indirectly) to increased exposure to unsafe working sur-
faces might be possible if the product is removed and not replaced with an
alternative.  No known or potential direct impacts on human health or the en-
vironment should result if this product line is removed and not replaced with
an alternative.
                                      C-24

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Alternative Products or Systems

Compressed Gas Aerosols —
     Pressure reduction as the volume of the contents decreases is the major
drawback for compressed gases other than carbon dioxide.  In addition, com-
pressed gas propellants would be inadequate to discharge the product in the
case of inadvertent misuse of the product (e.g., inverting the can).

Carbon Dioxide—
     Impact filling with carbon dioxide could be used to alleviate the pressure
loss problem associated with compressed gases.  Since this product line should
not be an aquequs system, impact filling with carbon dioxide is one potential
alternative propellant system.£§/

Hydrocarbon Aerosols--
     Pure hydrocarbon propellants can provide the characteristics required for
this product line.1ft'  According to an industrial source, the vast majority of
aerosol engine degreasers currently marketed utilize this propellant system.—'
Hydrocarbons could, under certain circumstances, present a flammability and/or
explosion problem.  However, in view of the current market, this does not appear
to present a serious problem.—'  Currently used fire retardant additives can-
not be used to reduce the flammability or explosion risk, since they could
quite possibly react with plastics and rubbers with which they might come into
contact. ll/

F-22 Propellant--                                        .
     If available this chlorofluorocarbon would be an acceptable alternative.
No problems would be anticipated in converting from F-12 to F-22 for this
product.

Brush Application—
     By bulk (as a liquid) degreasers may be applied by brush.  If the circum-
stances permit, the article in need of degreasing may be dipped in the de-
greaser.  At least two companies market engine degreasers in bulk quanti-
ties.54^577                                 .                                   /

Manual Pump Spray—
     In addition to brushing and dipping, these degreasers are applied by
manual pump sprayers.  This system allows the degreaser to be applied to hard
to reach areas and equipment with average surface area.

Compressed Air Hand Sprayer—
     This system is similar to  the back pack sprayer utilized by some pesti-
cide applicators.  The system consists of a galvanized or stainless steel
tank with a removable pump and a section of hose with a variety of nozzles.
The degreaser is mixed before being poured into the tank.  The pump is inserted

                                    C-25

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and locked into place, and the tank is manually pressurized.  For manual pump
sprayers and compressed air hand sprayers a wide range of nozzles, which allow
the applicator to select the desired spray characteristics, are available.

Economic Considerations

Carbon Dioxide--
     If impact-filled carbon dioxide would be an acceptable propellant, there
should be little or no increased costs to the consumer due to the propellant
system.  With this system, the decrease in propellant costs (F-12 versus CC^)
would likely be balanced by the increased quantity of product in the container.
Any cost incurred for conversion of the filling equipment may be passed on to
                .»
the customer.  However, the final product must be economically competitive with
the current hydrocarbon propelled products.

Brush Application--
     If applicable, this technique should provide a low cost means of appli-
cation since the degreaser can be purchased as a solution, eliminating the
cost of the aerosol container.

Manual Pump Spray—•
     Use of a manual pump spray should result in a cost either approximately
the same as, or slightly less than, the F-12 propelled product depending upon
the type of manual pump dispenser utilized.
              «
Compressed Air Hand Sprayer—
     For applications to large surface areas, these devices may be advantageous.
The tanks are available in a variety of sizes and costs.  A 2-gal. galvanized
steel tank costs $25.79, while a 4-gal. tank costs $29.79.^£/  por stainless
steel tanks, the 2-gal. capacity costs $44.79 and the 4-gal. $49.79.^i/  Since
bulk volumes of the degreaser can be used, cost savings should be incurred
with extended time usage on high volume consumption.
                                       C-26

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ELECTRIC SHAVER CLEANERS AND LUBRICANTS

Product Description and Utility

     This product type is manufactured and marketed by several organizations.
A typical formulation consists of the active ingredient which is an alcohol and
oil mixture, the propellant system which is chlorofluorocarbons-11 and -12, and
the solvent which is a refined petroleum distillate.  The product also contains
a small percentage of a lubricant, such as palmitate or a silicone.  »'

     The product is applied to the electric shaver after use to clean and lubri-
cate the shaving blades.—'  Use of the product purportedly assists in main-
taining the sharpness of the blades by keeping them lubricated and free of ex-
cess hair clippings.£2/  The market for this product includes the individual
consumer who uses electric shavers and low volume commercial electric shaver
repair shops.—'  The product is marketed as an aerosol in 6-oz cans and as a
liquid in 8-oz containers.—'

     F-ll and F-12 function as a propellant system and provide a convenient
method to remove hair from the shaver blades.^P-'   In a 6-oz aerosol can, the
propellant system accounts for approximately 907, of the total product.IP./
For calculation purposes 6 oz will be assumed to be the standard size can.
The annual production of this product type is estimated to be 1 x 10° units/
year.^1/  The ratio of F-ll to F-12 is 50:50.£2/  According to MRI estimates,
2.58 x 105 Ib of F-ll and 2.3 x 105 Ib of F-12 are used per year in this prod-
uct
     The removal of this product type from the marketplace should result in no
adverse effects on environmental quality or human health and safety.

Alternative Products or Systems

     Several propellant systems exist which could be feasible alternatives to
F-ll and F-12 for use in this product type.  The only national distributor for
this type of product is currently in the process of converting to one of the
alternatives.

Compressed Gas Aerosols —
     Pressure reduction as the volume of the contents decreases is the major
drawback for compressed gases.  This is not a practical alternative for this
product line.

Carbon Dioxide—
     Impact filling with carbon dioxide may alleviate the pressure loss problem
associated with other compressed gases.  The high pressure of the propellant


                                        C-27

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would provide enough force to blow away the hair in the shaver blades.   This
system could be applicable as an alternative propellant for this product type.

Hydrocarbon Propellants—'--
     This product has been reformulated to utilize a hydrocarbon propellant.
The new product has been tested by the national distributor on its electric
shavers and found to perform in a satisfactory manner.  A product containing
a hydrocarbon propellant will be marketed during February 1978.  Although
hydrocarbon propellants normally present a potential flammability hazard, the
prior testing has indicated that no problems of this nature should occur with
their current electric shavers.  No testing has been conducted on other makes
of electric shavers.

F-22 Propellant—
     F-22 should be a feasible alternative for this product type, if it becomes
available.

Nonaerosol Method —
     Excess hair can be removed from and a lubricant applied to the shaver
blades by nonaerosol methods.  .Excess hair can be removed by using a small
brush, followed by application of a lubricant and cleaner as a liquid.—'

Economic Considerations

     Substitution of a hydrocarbon propellant for F-ll and F-12 in this product
type should result in little, if any, increased cost to the consumer.—'

     A 6-oz aerosol can*of this product contains approximately 0.6 oz of active
ingredient. w The cost is $1.95.—'  This results in a cost of $3.25/oz of ac-
tive ingredient.  An 8-oz container of the product as a liquid costs $2.50 or
31.25c/oz.  If manual application is utilized the consumer can expect a cost
savings.
                                      C-28

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AIRCRAFT DEODORANT SPRAY

Product Description and Utility

     Aerosol deodorant sprays are used in aircraft cabins and holds to control
undesirable odors from cooking, food decay, airsickness, excessive usage of
aircraft toilet systems, and other sources.  Without rapid treatment of odor
problems, an increase in airsickness may occur on passenger aircraft.  This
product is also utilized on cargo aircraft for odor removal.

     These aerosol products generally use a 50:50 mixture of F-ll and F-12 as
a propellent system.£2/  The primary function of the chlorofluorocarbons is as
the propellant and the nonflammability properties lent to the spray are secon-
dary functions.  It is estimated that approximately 110,000 Ib of the two
chlorof luorocarbons are consumed annually-for this product.—'  If an equal
volume of mixture is used consistently throughout the industry, this would
correspond to approximately 58,000 Ib of F-ll and 52,000 Ib of F-12.  According
to one industry source, this product is normally sold in 6-oz containers.—'

     Aside from personal discomfort situations which may occur, the removal of
this product from the market would likely have no adverse impacts on environ-
mental quality and human health or safety.

Alternative Products or Systems

     The inability of current manufacturers to utilize F-ll/F-12 mixtures would
likely result in attempts to utilize hydrocarbon-water mixtures or carbon di-
oxide as propellents for aerosol spray products or to utilize mechanical pump
spray dispensing systems.S2f  According to the Materials Transportation Bureau
of the Department of Transportation (DOT) rules and regulations, aerosol dis-
pensers are not classified as hazardous materials and can be carried by an air-
craft operator if authorized or required aboard his aircraft for its operation
(Section 175.10).—'  For any alternative propellant, prior testing would be
required to assure that the material would not undergo reaction or affect any
of the cabin components, such as the Lexan (polycarbonate plastic) windows.

Hydrocarbon Propellants--
     Hydrocarbon-water-glycoi mixtures of the type currently used for household
room deodorizers may be acceptable alternatives.  A spokesman concerned with
rules and regulations for a U.S. airline stated that, as far as he could deter-
mine, the use of a product with this propellant system would be within the cur-
rent rules and regulations.—'  According to the Federal Aviation Administra-
tion,—'' materials used on board commercial aircraft are governed by Department
                                        >29

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 of Transportation regulations.   This propellant system could be utilized  provided
'it is  formulated and packaged in accordance with the regulations pertaining to
 products of this type (see for example Section 172.101,  173.115, and 173.300).— /

 Carbon Dioxide--
      Impact filling with carbon dioxide could be used as an alternative pro-
                f •) /
 pellant system.2i'   However,  this system produces a relatively coarse spray so
 that the effectiveness of the deodorizer may be impaired due to a decrease in
 the time the particles will remain in the air.  It is unknown at this time
 whether this propellant will  effectively dispense all of the active ingredient
 from the container  before the propellant pressure decreases to an ineffective
 level.  In addition, the internal pressure within the aerosol container may be
 above  the level  stated in the DOT regulation.  Testing of this type of formu-
 lation would be  necessary before a judgment could be made of its overall  ef-
 fectiveness.

 Manual Pump Spray--
      A product using this type of dispensing system could be employed for air
 deodorizers.  The finger-type pumps would be applicable for relatively small
 areas.  For large areas this  method may prove to be physically taxing.  A
 trigger-type pump can be adjusted to a fine spray, but generally the particle
 size would likely be too large to result in an efficient product.

 Economic Considerations

 The technology for  hydrocarbon-water-glycol propelled products is well de-
 veloped because  of  their extensive usage in household deodorizers;  minimal
 problems should  be  incurred with this formulation.  Since the current house-
 hold products are priced competitively with the chlorofluorocarbon propelled
 products, no increase in prices should be passed on to the airlines utilizing
 this product.

      If carbon dioxide should prove to be an effective alternative  propellant,
 no increases in  price should  occur since this product will likely be in compe-
 tition with the  hydrocarbon-water-glycol propelled products.  If the manufac-
 turer has the product contract filled, no price increases should arise since
 filling costs are generally the same for F-12, hydrocarbon, or carbon dioxide
 propellants.
                                       C-30

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PRODUCTS FOR THE AIRLINE  INDUSTRY

     This area encompasses several products, specifically  lubricants, corrosion
preventives, solvent cleaners, dye penetrants, and  touch up paints, which
have specific usages in the airline industry.  Airline spokesmen or anonymous
sources in  the airline industry state that most of  the industry has reviewed
their uses  and employed alternative products wherever possible.67-70/  FOr ai\
of  these products,  the general attitude appears to  be that for products applied
in  the shop area under controlled conditions, alternative methods are available
and can be  used.  These alternatives include hydrocarbon propellants.  However,
for usage on the aircraft itself the airlines are extremely reluctant to utilize
any propellant which may  present a flammability problem.  This is due to the
cost of each aircraft, which may be of the order of $25,000,000.£2/  However,
some anonymous sources stated that alternatives could be used for most appli-
cations.

     Since  it is not possible to discuss all of these products together, each
will be discussed separately under the headings of  product description and
utility, alternative products or systems, and economic considerations.

Product Description and Utility

Lubricants —
     These  products are basically the same as those discussed under the head-
ing of "lubricants" in a  previous report.127  They  encompass both liquid (light
petroleum oils) and solid (Teflon , molybdenum sulfide, graphite, etc.) lubri-
cants.  Molybdenum  sulfide is used more extensively than the Teflon .—'
While none  of the airlines contacted could provide  figures regarding the actual
quantities  consumed by the industry because of the  wide number of lubricants
used, they  stated that significant quantities of each type are employed.  The
chlorofluorocarbons employed and their functions are the same as described in
                       •17 /
in  the previous report. —'

Solvent Cleaners —
     These  products are the same as those described in the earlier report
• under the topic of  electronic cleaners.—'

Touch Up Paints—
     This is the same product described in the previous report as spray
paints.227

Dye Penetrant —
     This product is employed to detect stress cracking in metal parts.  Two
different processes are employed for the use of dye penetrants;  (a) the visi-
ble process and  (b) the fluorescent process.


                                        C-31

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     In the visible process, the penetrant is applied to the metal part to be
inspected; this is followed by a cleaner to remove excess penetrant from the
metal surface.  A developer is then applied and any stress cracks appear as
red lines on the white background of the dried developer.—'

     For the fluorescent process, the metal part to be inspected is dipped into
a tank of water-soluble penetrant.  Excess penetrant is washed from the metal
surface with water and the metal part coated with dry developer powder in a
tank.  After exposure to air, the metal surface is viewed with a "black light"
to detect areas of stress cracking.£§/

     Aerosol forms of both of these products are available.  Bulk solutions
are more commonly used with the fluorescent process for economic reasons.—'
Although, the F-12 is used primarily as a propellant, one source indicated
that the F-12 also provides good wetting properties for the penetrant.—'
Contact with two manufacturers of this product revealed little information
concerning the quantity of F-12 consumed.71,727  ^& aerosol product contains
approximately 65% propellant.—'  Typically the remainder consists of a mix-
ture of petroleum solvent and a phthalate with small quantities of the fluo-
rescent dyes.  Both manufacturers declined to discuss any information concern-
ing the total annual industry-wide sales.  Therefore, the total quantity of
F-12 used in this produce is unknown.

Corrosion Preventives—
     This type of product is applied to form two different types of coatings.
One type forms a dry, thin, hard coating whereas the other results in a soft,
nondrying type of coating.SLiM/  Both types are used as sealants against
moisture, hydraulic fluids, brake fluids, or other liquids which could result
in corrosion of metal surfaces.  The aerosol products are used primarily for
small applications or special control conditions.—'   For larger application,
bulk solutions are employed. 7'
     The aerosol products utilize a mixture of F-ll and F-12 as the propellant
system.—'  The actual quantities employed for this specific application are
unknown because of the wide industrial utilization of this product.
     For all of these products, their removal from the market without replace-
ment would have no effect on environmental quality.   However, due to the rather,
unique nature of this industry, an assessment of the impact of their removal
on human health or safety is beyond the scope of the present study.

Alternative Products or Systems

     As stated previously, the applicability of alternative products or systems
to deliver the same goods differs from one industry source to another.  Some
sources state that for certain applications, no alternatives exist at the present

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time, while others, who wish to remain anonymous, state that alternatives can
be used for most, if not all," of the present uses of the chlorofluorocarbon
propelled products.  The principal factor involved with most of the applica-
tions appears to center around the problem of flammability.

Touch Up Paints —
     More progress has been made in the use of alternative systems with this
product than with the others.—'  Hydrocarbon propelled aerosols can be and are
being used in many applications, depending upon the specific conditions.  For
other applications, airless sprayers are being used with satisfactory results.
Another source stated that nonflammability of this product is not really a
strict criteria since the paint formulations are flammable and the use of a
hydrocarbon propellant would result in little increased flammability.—'
Other sources stated that very few situations would occur where, with proper
precautions, a hydrocarbon propelled product and/or an airless sprayer could
not be ..COH 69.70/

Solvent Cleaners—
     Alternative propeHants or delivery systems for this product have been
discussed in an earlier report.—'

Lubricants--
     Alternative propellants or delivery systems for this product have been
discussed in an earlier report. =2J
                                                                           •
Corrosion Preventives--
     Alternative propellants or mechanical methods of application would be
very similar to those described in a previous report for liquid lubricants.—'
Some variation in the efficiency of application of certain aerosol propellants
may be anticipated because of the viscosity of the product.  Although some cur-
rent corrosion preventives are flammable, hydrocarbon propellants would
probably be generally unacceptable because of the flammability potential.
Testing would be required for any new propellant system to evaluate total
product dispersal, spray patterns and characteristics, and the overall prod-
uct acceptability.
                                    p
     Bulk solutions are currently used in conjunction with pressurized con-
tainers (e.g., garden sprayers, backpack sprayers, etc.) for large area appli-
cations.  With the proper selection of nozzles, this system may be applicable
for some current applications of aerosol products.  Airless sprayers may be
applicable for selected applications in which a thin film would be required.
Some testing may be required to attain the proper viscosity for the operation
of the sprayer.
                                       C-33

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Dye Penetrants—

     Aerosols--Since the product consists primarily of a petroleum solvent
plus a phthalate with small quantities of dyes, other aerosol propellant sys-
tems may be applicable.  Impact-filled carbon dioxide may be an acceptable
alternative if no formulation or shelf life problems are encountered with the
potential formation of acidic by-products.  Small amounts of moisture in the
aerosol container will result in the formation of carbonic acid which may. have
a detrimental effect on the phthalate or the fluorescent dyes.  The use of a
wetting agent may also be required to provide good surface coverage.  Recently,
question has been raised concerning the efficiency of carbon dioxide propellant
to dispense all of the product from an aerosol container.  This potential method
would require further testing before product acceptability could be established.

     Hydrocarbon propellants would not.be an acceptable alternative if the
product is to be utilized in a situation where flammability would pose a sig-
nificant problem.

     Nonaerosol methods--Manual application of dye penetrants by brushing the
solution onto a metal surface and removing the excess with a cloth is currently
practiced, in certain applications, by at least one airline.—'  it would ap-
pear that other mechanical methods of application may also be acceptable.

     One possibility may be the use of trigger-type pump sprays.  If surface
wetting would be a problem, then it may be necessary to incorporate a suitable
wetting agent, into the formulation.  This potential change in formulation
would require further testing to determine if compatibility problems may arise.

     According to one industry source, airless sprays apparently will not work
with the current bulk solutions.^!.'  However, this may be a problem of surface
wetting.  If this problem can be overcome, the method should be an acceptable
alternative.

Economic Considerations

     The economic aspects of solid lubricants, corrosion preventives (liquid
lubricants), solvent cleaners, and spray paints have been discussed in a pre-
vious report, —'

     For dye penetrants, the use of impact-filled carbon dioxide as a propel-
lant should not lead to any increased cost to the consumer.  As with many,
other products, the decrease in cost due to the propellant is balanced by the
use of more product in the formulation of the total aerosol system.  The use
of bulk solutions and a mechanical application method should, ultimately, lead
to a reduction in costs.  Initially, increased costs will occur because of the
                                       C-34

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purchase o£ portable sprayers.  The rate at which the lower  cost  of  the  bulk
solutions will overcome the initial sprayer costs will be  dependent  upon the
volume of dye penetrant consumed.
                                       C-35

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CONTACT CLEANER/LUBRICANT

Product Description and Utility

     This product is similar to the electronic cleaners employing'F-113 and F-12
described in an earlier report!!' except that an additional component is added'
as a lubricant, preservative, and anti-corrosion agent.  The primary purpose of
the lubricant is the prevention of the formation of metallic oxides by simple
oxidation or by oxidation due to atmospheric contaminants such as sulfur diox-
ide.Zl'  The product is typically used by repairmen for cleaning and maintenance
of electrical and electronic components such as switches, relays, radio and tele-
vision tuners, transmitters, timers, and many others.2£/  in addition to civil-
ian repairmen, it is also used in certain military applications.—/

     The cleaner/lubricant is produced by a sole manufacturer in two forms:
(a) an aerosol formulation using F-12 as the propellant; and (b) as a bulk
liquid containing either the pure lubricant or as a dilute solution in
l,l,2-trichloro-l,2,2-trifluoroethane (F-113).  In the aerosol form, the com-
ponents are approximately 8% lubricant package, 157. perchloroethylene,  42%
F-113, and 357. F-12.  The sole function of the F-12 in this product is  that
of a propellant.  The manufacturer claims that a very fine spray pattern is
required for the effective use of this product.  The perchloroethylene  is
added as a solvent for the lubricant package to obtain good miscibility with
the F-11.3 and is present in both the aerosol and bulk products.Z5/  This re-
port will be concerned only with the use of F-12 as the aerosol propellant,
and no consideration will be given to the subject of the applicability  of
F-113 as the cleaning solvent.

     Based on information provided by the manufacturer, it is estimated that
approximately 4,000 Ib of F-12 are consumed annually in this product.—'

     For the product employed for use by civilian repairmen, the removal of
the F-12 propelled product from the market would have no known adverse  impacts
on environmental quality or human health and safety.

Alternative Products or Systems

Hydrocarbon Propellant—
     Considering the quantity of chlorinated hydrocarbon employed in the aero-
sol formulation of this product, a hydrocarbon propellant would appear  to be an
adequate alternative because the chlorinated compounds should lend a degree of
nonflammability to the spray.  In addition, this propellant would also  satisfy
the manufacturers requirement for a fine spray to preserve the effectiveness
of the product.  However, tests by the contract aerosol filler for this prod-
uct show that the current formulation with a hydrocarbon propellant is  flammable
when sprayed across an open flame.—   When the bulk liquid is placed in an

                                       C-36

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open cup and igniced, the liquid will flame momentarily.Z5/  Because of the
flammability characteristics, this propellant system would not likely be an
acceptable alternative.

Carbon Dioxide--
     The manufacturer has requested the contract filler to prepare test samples
using carbon dioxide as the propellant.  This propellant is used with the elec-
tronic cleaners containing only F-113, and if the containers are impact filled, ,
no formulation problems should arise.  However, the spray resulting from the use
of carbon dioxide is more coarse than that obtained using F-12 and this may re-
sult in a reduction of the effectiveness of this particular product.
               >
F-22 Propellant—
     F-22 could likely be used as an alternative propellant system for most
components if it were available.  This compound may have a detrimental effect
on some component parts, but it could prove to be acceptable.

Manual Pump Sprays—
     In view of the manufacturers comment that the product works better when
used in small amounts, manual pump sprays would probably not be a feasible
alternative due to the rather coarse spray pattern produced and the large
quantity of material dispensed.

Bulk Liquid Methods—                      '  ;
     This product is sold in bulk quantities 'for application by cloth, brush,
or cotton-tipped applicators.  For many applications, these are a suitable
method of application.  However, in many electronic components, it is very
difficult to manually apply a liquid because of the difficulty in gaining
access to the component.  If partial dismantlement of the equipment would be
necessary, there would be increased labor cosis.

Economic Considerations

     As stated previously, this cleaner/lubricant is produced by only one manu-
facturer.  The sales attributable to the aerosol product constitute approxi-
mately 50 to 60% of the total annual sales for this company.

     If carbon dioxide should prove to be an acceptable alternative, no in-
crease in consumer costs would be anticipated since the aerosol product is
filled by a contract filler who normally charges the same price for filling
with carbon dioxide as for F-12.
                                       C-37

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References

 1.  Harrison, W. R.  Suspect Documents - Their Scientific Examination.
     Praeger, New York, 1958.  pp. 126-129.

 2.  Federal Bureau of Investigation.  FBI Handbook of Forensic Science.
     Revised Edition.  Washington, D.C., August 1975.

 3.  Moenssens, A. A.  Fingerprint Techniques.  Chilton Book Company,
     Philadelphia, Pennsylvania, 1.971.  pp. 120-126.
                                                             •
 4.  Svensson, A., and 0. Wendell.  Techniques of Crime Scene Investigation.
     American Elsevier Publishing Company, New York, 1965.

 5.  Safersten, R.  Criminalistics, An Introduction to Forensic Science.
     Prentise Hall, Englewood Cliffs, New Jersey, 1965.

 6.  Federal Bureau of Investigation.  Instructions for the Preparation of
     Chemicals Utilized to Develop Latent Fingerprints on Porous Surfaces.
     Washington, D.C., 1977.

 7.  Worsham, R.  Personal Communication.  Criminalistics, Inc., Miami, Florida.

 8.  Bigler, E.  Personal Communication.  Director, Florida State Criminalistics
     Laboratory, Tallahassee, Florida.
                                                 i
 9.  Locke, D.  Personal Communication.  Head, Identification Section, Missouri
     State Highway Patrol Laboratory,.Jefferson City, Missouri.

10.  Sergeant Rice.  Personal Communication.  Laboratory Supervisor, Regional
     Criminalistics Laboratory, Independence, Missouri.

11.  Officer Foster.  Personal Communication.  Identification Department,
     Houston Police Department, Houston, Texas.

12.  Jones, R.  Personal Communication.  Director, Kansas Bureau of Investi-
     gation, Topeka, Kansas.
                                                 >
13.  Malaer, 0.  Personal Communication.  Latent Print Examiner, Houston
     Police Department, Houston, Texas.

14.  Bonebrake, G.  Personal Communication.  Supervisor, Latent Fingerprint
     Section, Federal Bureau of Investigation, Washington, D.C.

15.  Hoffniaister, H.  Personal Communication.  Fingerprint Laboratory,
     Texas Department of Public Safety, Austin, Texas.

                                       038

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16.  Sirchie Fingerprint Laboratories.  Catalog, Raleigh, North Carolina.

17.  Edwards, W.  Personal Communication.  Chief Chemist, Sirchie Fingerprint
     Laboratories, Raleigh, North Carolina.

18.  Hasty, D.  Personal Communication.  Supervisor, Identification Division,
     Florida State Criminalistics Laboratory, Tallahassee, Florida.

19.  Edwards, W.  Letter to L. Longanecker, EPA, dated November 1, 1977.
     Chief Chemist, Sirchie Fingerprint Laboratories, Raleigh, North Carolina.
                                      •
                                                                              •
20.  Shah, S.  .Personal Communication.  Acra-Pak Inc., Elkhart, Indiana.

21.  Murrill, E., and P. Siewald.  Personal Communication.  Midwest Research
     Institute, Kansas City, Missouri.

22.  Federal Bureau of Investigation.  Crime in the United States--1975.
     Uniform Crime Reports.  Washington, D.C.  /

23.  Lewis, L.  Personal Communication.  Lincoln Electric Company.  Kansas
     City, Missouri.

24.  Marriott, L., .and P. Saunders.  Personal Communication.  PureweId, Inc.
     Kansas City, Missouri.

25.  Britell, S.  Personal Communication.  Welding Equipment Supply Company.
     Kansas Ci,ty, Missouri.

26'.  Bailey, L.  Personal Communication.  Kirk Welding Supply.  Kansas City,
     Missouri.

27.  Carr, R. J.  Personal Communication.  Welders Products and Service
     Company.  Kansas City, Missouri.

28.  Johnson, P.  Personal Communication.  Hohenschield Welders Supply
     Company.  Kansas City, Missouri.

29.  Arcair Protex, Original.  Arcair, Lancaster, Ohio.  Wayne House.  Personal
     Communication and Product Data Sheet, 1975.              1

30.  Protect-0-Metal No. 2.  G. W. Smith and Sons.  Dayton, Ohio, Product
     Brochure  (undated).

31.  Silver, D.  Personal Communication; also Spat-R-Proof 106 product data
     bulletin.  York Engineering Company, Chicago, Illinois.
                                       C-39

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32.  Letter to P. W. Brunner.  July 13, 1977, from William N. Grave.  DuBois
     Chemicals, Sharronville, Ohio.  Also personal communication.

33.  Kirschenbaum, S.  Personal Communication.  Eska Chemicals, Lakewood,
     New Jersey.

34.  Mutual Hardware Corporation.  Personal Communication.  Long Island,
     New York.

35.  Mole-Richardson Company.  Personal Communication.  Hollywood, California.

36.  Calvin Communications, Inc.  Personal Communication.  Kansas City,
     Missouri.

37.  Midwest Research Institute.  Investigation of Alternatives for Selected
     Aerosol Propellant and Related Applications of Fluorocarbons.  EPA Con-
     tract No. 68-01-3201, Task VI, Publication No. EPA 560/1-77-004, October
     1977.

38.  Mohn, W.  Personal Communication.  Key Industries, Englishtown, New Jersey.

39.  York, J.  Personal Communication.  Jim York Chemical Company, Houston,
     Texas.

40.  Friedman, A. .Personal Communication.  Chemtronics, Inc., Hauppauge,
     New York.

41.  Young, J.  Personal Communication.  Sunbeam Appliance and Service
     Company, Chicago, Illinois.

42.  Burns, D.  Personal Communication.  Carson Chemical Company, New Castle,
     Indiana.

43.  Smith, R.  Personal Communication.  Metz Engineering Company, Kansas
     City, Missouri.

44.  Dr. Christopherson.  Personal Communication.  EVSCO Pharmaceutical
     Corporation, a division of Damon Company, Buena, New Jersey.

45.  Pet Chemical Company.  Personal Communication.  Miami Springs, Florida.

46.  Midwest Research Institute estimate based on information from reference 41.

47.  Century Electric Division, Gould, Inc.  Personal Communication.
     St. Louis, Missouri.
                                       C-40

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^8.  Reed, A.  Personal Communication.  CRC Chemicals, Inc., Warminster,
     Pennsylvania.

49.  Agnew, G.  Personal Communication.  WD-40 Company, San Diego, California.

50.  Leinen, R.  Personal Communication.  3-M Company, St. Paul, Minnesota.

51.  Industrial Transformer, Motor, and Generator Repair, General Electric
     Company.  Personal Communication.  Kansas City, Missouri.

52.  Kornfeld-Thorp Electric Company.  Personal Communication.  Kansas City,
     Missouri.  *

53.  Industrial Apparatus Repair, Westinghouse Electric Corporation.  Personal
     Communication.  Kansas City, Missouri.

54.  Mr. Piszynski.  Personal Communication.  Gunk Laboratories, Inc.,
     Chicago, Illinois.

55.  Szumlas, J.  Personal Communication.  Crown Industrial Products,
     Hebron, Illinois.

56.  Midwest Research Institute estimate based on information from reference 54.

57.  Stone R.  Personal Communication.  Midwestern Sales Representative,
     Masury-Columbia Company, Elmhurst, Illinois.

58.  Prices  from Sears, Roebuck and Company, Kansas City, Missouri.

59.  Kouts, N.  Personal Communication.  Kansas City Appliance and Shaver
     Center, Kansas City, Missouri.

60.  Frangos, J.  Personal Communication.  Connecticut Aerosols, Inc.,
     Milford, Connecticut.

61.  Tierney, B.  Personal Communication.  Remington Electric Shaver,
     Bridgeport, Connecticut.

62.  Midwest Research Institute estimates are based on data supplied by
     references 59 and 60.

63.  Granville, R.  Personal Communication.  Celeste Industries Corporation,
     Easton, Maryland.  See also letter to J. T. Repasch, Environmental
     Protection Agency, Washington, D.C. from Mr. Granville dated July 27,
     1977.
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64.  Hazardous Materials Regulations, 49 CFR Parts 171-177, Materials Trans-
     portation Bureau, Department of Transportation, in Federal Register,
     September 27, 1976.

65.  Williamson, B.  Personal Communication.  Trans World Airlines, New York,
     New York.

66.  Francis, W.  Personal Communication.  Air Carrier District, Federal
     Aviation Administration, Kansas City, Missouri.

67.  Jones, A.  Personal Communication.  Eastern Airlines, Miami, Florida.

68.  Anonymous Source.  Personal Communication.  A major U.S. airline.

69.  Anonymous source.  Personal Communication.  A major U.S. airline.

70.  Anonymous source.  Personal Communication.  A major U.S. airline.

71.  Santos, R.  Personal Communication.  Turco Products Division, Purex
     Corporation, Carson, California.

72.  Magnaflux Corporation.  Personal Communication.  Chicago, Illinois.

73.  Lohkemper, 0. A.  Letter to J. T. Repasch, Environmental Protection
     Agency, Washington, D.C., dated October 20, 1977.  Caig Laboratories,
     Inc., Escondido, California.

74.  Caig Laboratories, Inc.  Bulletin C-400.  Escondido, California.  1976.

75.  Lohkemper, 0. A.  Personal Communication.  Caig Laboratories, Inc.,
     Escondido, California.
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