Design for the Environment
Cleaner Technology Substitutes Assessment
Outline with Examples
Created for a DfE Printing Project Meeting
March 10, 1993
-------
Table of Contents
I. Profile of Use Cluster
A. Definition of application
B. Market information
C. Identification of Substitutes
II. Functional Subgroups
A. Definition of function
B. Market information
C. Identification of Substitutes
IILSubstitutes Comparative Assessment, Function I
A. Substitute 1
1. Lifecycle Risk Analysis
2. Pollution Prevention Opportunities
3. Comparative Performance & Cost
B. Substitute 2
1. Lifecycle Risk Analysis
2. Pollution Prevention Opportunities
3. Comparative Performance & Cost
C. ETC.
IV. Substitutes Comparative Assessment, Function II
A. Substitute 1
1. Lifecycle Risk Analysis
2. Pollution Prevention Opportunities
3. Comparative Performance & Cost
B. Substitute 2
1. Lifecycle Risk Analysis
2. Pollution Prevention Opportunities
3. Comparative Performance & Cost
C. ETC.
-------
You will find the Profile of Use Cluster Application, Functional Subgroup Identification
and Definitions, and Substitute Identification pieces for Lithographic Blanket Washes and
Screen Reclamation/Stencil Removal in separate documents called Introductory Outline of
Cleaner Technology Substitutes Assessments (CTSAs). Below is an outline of the types of
information found in those sections of the CTSA documents.
PROFILE OF USE CLUSTER APPLICATION
A. Definition of application
• chemistry of use (e.g., inks used in lithography)
• desired performance characteristics
B. Market Information (profile of use, e.g. inks) [Baseline]
• volume, annual amount used
• manufacturers of chemical
• users of chemical
• # of companies producing chemical
• trends
C. Identification of Substitute Chemicals, Technologies, Processes
[products]
Description
• list of potential substitutes
for chemical products:
• chemistry of use
• performance characteristics
• percentage used in clustered products
for alternative technologies: (e.g. possibly heat sensitive paper which avoids ink)
• description of technology
• performance characteristics
• chemical use implications of alternative
The Use Cluster Analysis of the Printing Industry, a background document which includes
a market profile and defines the processes, chemicals and technologies used by the industry,
provides the information for this part of the CTSAs. An EPA economist researched the
draft document and industry representatives are working with the DfE Printing Project to
revise the analysis for publication.
-------
FUNCTIONAL SUBGROUP IDENTinCATION
[This may be omitted if it is not needed. Where substitutes consist of a product, this
section may be used to identify the function of the component chemicals in the mixture.]
List functions performed by chemicals within the products
e.g. for inks: solvents, dispersants, pigments, etc.
Industry workgroup members identified the functional subgroups for the selected use
clusters. This information will be reviewed for accuracy by an EPA chemist and/or chemists
from the industry.
FUNCTIONAL SUBGROUP 1 (e.g. solvents)
(Note: There may be several functional subgroups within a product.)
Definition of function
• chemistry of use (e.g., solvent used as ink pigment dispersant)
• desired performance characteristics
Market Information
• volume, annual amount used
• manufacturers of chemical
• users of chemical
• # of companies producing chemical
• trends
Definition of function is submitted by industry workgroup members and reviewed by an
EPA chemist
Market information is submitted by industry or researched by an EPA economist
-------
SUBSTITUTES IDENTIFICATION
Description
• list of potential substitutes
for chemical substitutes:
• chemistry of use
• performance characteristics
• percentage used in clustered products
for alternative technologies:
• description of technology
• performance characteristics
• chemical use implications of alternative
Substitutes are defined, for purposes of the analysis, in the broadest sense of the term,
including alternative chemicals, technologies and processes. In order to have complete
information on current trends in the industry, we need industry to identify alternatives and
submit information for to assist in the assessment of risk, performance and costs of
substitutes.
Please see the attached letter (Exhibit 1 a/b) sent out to suppliers describing the type of
information on alternatives we are seeking. To address company concerns about
confidentiallity, third parties are collecting the data for the project, thus maintaining
anonymity for those submitting information. Printers are asked to submit information on
alternative work practices as well.
EPA staff have formed a workgroup responsible for analyzing the alternatives.
-------
Environmental Conservation Board
of the Graphic Communications Industries
A Cooperative Voice for Environmental Action
1899 Preston White Drive
Reston, VA 22091-4367
703/648-3218 • FAX 703/648-3219
February 18, 1993
Dear Printing Industry Supplier
We are contacting you regarding a project known as the Design for the Environment
(DfE) Printing Project. Specifically, the DfE Printing Project, a cooperative initiative
between the graphic communications industry and the United States Environmental Protection
Agency (EPA), requests that you consider providing information on alternatives to currently
used chemicals or technologies in the area of blanket washes for offset lithography. The goal
of the DfE program is to assist the industry in making informed, environmentally responsible
design choices by providing standardized analytical tools for industry application and
providing information on the comparative characteristics of alternative chemicals and
technologies.
We have enclosed additional information on the DfE Printing Project in order to give
you further background on the project, and to bring you up to date on its current status. To
summarize the work to date, after several meetings in 1992, the group working on offset
lithography has focused its efforts on the issue of blanket washes. To date, the committees
working on those assessments have collected chemical and volume information for
"traditional" blanket washes.
The next step in the assessment process is collection of data on various alternatives.
Alternatives are those products or technologies which are defined by industry as alternatives
to traditional methods. For example, products that have lower VOCs, or eliminate regulated
chemicals such as CFCs. A technology that eliminated or required less of a chemical
product would also qualify as an alternative process or technology.
In the case of chemical product alternatives, we are looking for chemicals, and
volume in the alternatives. For technology alternatives, we would like a description of the
technology, and performance, cost and use information associated with the new technology.
After information on alternatives has been collected it is the project's goal to provide
accurate information to printers so that they are able to make informed judgements on the
products and technologies they choose to use in their facilities. The DfE project will work
with manufacturers and printers to develop case studies outlining the use of alternative
products and technologies. The case studies will be available to the offset lithographic
community.
EXHIBIT la
-------
Printing Industry Supplier
February 18,1993
Page 2
In order to alleviate concerns about proprietary information, we have been requested
to act as intermediaries in the submission of product and technology information to EPA.,
keeping the supplier's company confidential. We encourage you to use this mechanism for
supplying information to the project. Please send information to either:
Mark J. Nuzzaco Thomas Purcell
Executive Director Core Group Industry Co-Chair
ECB Printing Industries of America
1899 Preston White Drive 100 Daingerfield Road
Reston, VA 22091 Alexandria, VA 22314
Tel: 703/648-3218 Tel: 703/519-8114
Fax: 703/648-3219 Fax: 703/548-3227
We hope that you will agree that a proactive approach to this EPA initiative is in the
best interest of suppliers and their customers. We thank you in advance for you participation
in the project. Additionally, we hope to see you at the upcoming DfE Printing Project's
Industry Workgroup meeting on March 10-11 at the Washington D.C. Marriott. Please
contact us if you have any questions.
Sincerely,
Mark J. Nuzzaco
Executive Director
Enclosure
MJN/sm
cc: ECB Board of Directors
ECB Member CEOs
ECB Technical Committee
John M. Nannes
Kathy Ramus
Ken Schnettler
EXHIBIT Ib
-------
SUBSTITUTE 1
(Note: This analysis is completed for each substitute.)
BASIC CHEMICAL PROPERTIES
The physical and chemical characteristics of the chemical will be detailed. This includes
such information as chemical name and any synonyms; CAS number; structure; molecular
formula; molecular weight; physical state, melting point; boiling point; vapor pressure; water
solubility; other solubilities; density, flash point.
The following is an example (Exhibit 2) of the information the EPA chemist is providing
for the chemicals in the clusters. Industry is encouraged to provide this information on
alternative chemicals when they are submitted for the assessment.
-------
RM1 ICB FORM
(Readily Available Information)
Chemical Name: 2-Methoxyethanol acetate (ester) Molecular Formula: C5H1003
CAS Number: 110-49-6 Molecular Weight: 118
Chemist: Fred L Metz Physical State: Colorless, flammable
liquid with mild ethereal odor
Structure: CHgOCHjCHjOOCCHg Synonyms: 2-MEA; Ethylene glyco!
monomethyl ether acetate
Trade Name: Methyl Cellosolve acetate
Melting Point: -65°C (M) Water Solubility: Miscible (M)
Boiling Point: 145°C (M) Density: 1.005(M)
Vapor Pressure: 5.3 mm Hg (M) at 25°C Flash Point: 55.6°C (open cup)
55.6°C (closed cup)
Other Solubilities:
Above data is either measured (M) or estimated (E).
Additional Pertinent Chemical Information:
One major function of 2-methoxyethanol acetate is to dissolve various components of mixtures,
in both aqueous and nonaqueous systems, for the uses described below, and to keep them in
solution until the last stages of evaporation. It is these dispersive applications that cause the
greatest concern for widespread human and environmental exposure.
Common Industrial Synthesis:
2-Methoxyethanol acetate is produced by the reaction of ethylene oxide with methanol, followed
by esterification with acetic acid, acetic acid anhydride, or acetic acid chloride together with an
acid catalyst.
CHo
CH3OH
2) CHgOC^CHgOH + CHgCOOH - » CHgOC^CHjOOCCHg
acid
catalyst
Chemistry of Use:
2-Methoxyethanol acetate and the other ethylene glycol ethers have a wide range of uses as
solvents, with particular applications in paints, stains, inks, lacquers, and the production of food-
contact plastics. In addition, they are used as resin solvents in surface coatings and inks for
silkscreen printing and in photographic and photolithographic processes, as solvents for dyes
in textile and leather finishing, and as general solvents in a wide variety of home and industrial
cleaners.
EXHIBIT 2
-------
HAZARD SUMMARY
• Summary of Health Hazard Concern
• Quantitative Dose Response Assessment
• Summary of Safety Hazard Concerns
• Summary of Ecological Concern
• Quantitative Level of Concern
Health and ecological hazard information is an important component of the exposure
assessment from which risk of chemicals is derived. Hazard information is available in EPA
data bases and will be compiled from the DfE Scoring System and by Health and
Environmental Review Division (HERD) on the use cluster chemicals. See the attached
Exhibits 3 a/b/c for examples of text and tables provided in EPA documents evaluating
human and environmental health hazards of chemicals.
In some cases readily available information may not be sufficient to establish comparative
risks for chemicals in the cluster. In these cases HERD will look for structural analogs from
which they can derive the necessary information.
Industry associations with additional hazard information may submit relevent test results
to the HERD for inclusion in the hazard review.
-------
GENERAL INFORMATION
ACRYLONITRILE
NOVEMBER 20, 1*91
HEALTH AND ENVIRONMENTAL HAZARD
Summary of Health Hazard Concerns and Quantitative Do«e-Re*ponae Assessment
Although AN is a very acutely toxic chemical and there is also evidence for reproductive and
developmental toxicity concerns, the driving health hazard concern is for carcinogenicity. It has an
EPA carcinogen classification of B1, 'probable human carcinogen', based on the observations of (1) a
statistically significant increase in incidence of lung cancer in exposed workers and (2) tumors.
generally brain astrocytomas, in studies in two rat strains exposed by various routes (drinking water,
gavage, and inhalation).
O'Berg (1980) conducted an occupational epidemiology study on 1345 male workers exposed to AN
at a DuPont textile fiber plant in Camden, SC at some time between 1950 and 1966. A trend of
increased cancer incidence was seen with increased duration of exposure and increased length of
follow-up time..
Quast (1980) administered AN in drinking water to rats of both sexes for 2 years. Statistically
significant increases were observed in tumors of the CNS (astrocytomas), Zymbal gland, stomach,
tongue, small intestine, and mammary gland. In general, the increases were dose-related. Similar
results were seen in the Quast (1980) inhalation study. The IRIS oral slope factor is 5.4E-1 per mkd; it
should be used only for dietary intake. This value is a geometric mean derived from individual slope
factors calculated for three different rat drinking water bioassays. The overall risk of tumors was
determined from the number of animals having tumors that were statistically significant at any site.
The drinking water unit risk is 1.5E-5 per ^g/L, but should not be used if the water concentration
exceeds 600
The IRIS inhalation unit risk is 6.8E-5 per ^g/m1, but should not be used if the air concentration
exceeds 1E+2 ng/m3. The unit risk was derived from a relative risk using the epidemiological data of
O'Berg. The cohort was sufficiently large and followed for an adequate time period. An increased risk
of respiratory cancer remained after adjustment for smoking.
Summary of Environmental Hazard and Quantitative Level of Concern
Acute toxicity values for AN as listed in the Aquire data base range from < 1-1 00 mg/L for inverte-
brates and fish.. Crustaceans are especially sensitive to AN, with acute values from 1-1 1 mg/L The
value commonly cited as a chronic toxicity value (2.6 mg/L) is drawn from Henderson et al.. (1961);
however this is not correct because this value is not a true chronic test endpoint. The endpoints of
survival, growth, development, and reproduction that are commonly measured in current chronic tests
were not Determined by Henderson et al.
In 1980, Analytical Biochemistry Laboratories, Inc. conducted a chronic fish early life stage test.
Statistically significant decreases in growth were obtained at the lowest tested concentration, 0.34
mg/L The no-observed-effect concentration (NOEC) is probably near or lower than this concentration.
A level of concern was calculated using this lowest test value (0.34 mg/L). An uncertainty factor of 10
was then applied to this value to account for the variations and error due to the differing sensitivities of
the tested species, the type of organism tested, and extrapolations from the laboratory to the natural
environment.
For AN, this results in a concern level of 34 *ig/L (34 ppb). This value is considerably lower than
modeled stream concentrations during low (7Q10) flow conditions. (The modeled maximum low flow
concentration is 1493 pg/L or 1500 ppb.) Under these conditions toxicity to aquatic populations is a
substantial concern.
EXHIBIT 3a
-------
Health Hazard Table
Table 3. Summary of Toxicity Data on Aerosol Spray Paint Components Ranked from High to Moderate Concern by SAT
OkMftfed
Methyfene chloride
Cadmium annge/nd
lithopone
Lead molybdale
Lead »ulf«ie
Moh/Mate orange
Chromiun lead
molybdenum oxide
Toluol
DicthylCBC given) dimethyl
ether
Aluminum
U.l-Trichloroethane
Henne
1,1,2-Trichloroethane
Ti ichloroethylenc
Ammonia
CASH*.
1549-2
12656-57-4
10190-55-3
7446-14-2
7758-97-6
1265645-8
12709-98-7
10848-3
111-96-6
7429-90-5
71-55-6
110-54-3
127-18-4
79-00-5
79-01-6
7664-41-7
CampMienf
TyP«
Solvent
Pigment
Pigment
Pigment
Pigment
Pigment
Pigment
Solvent
Solvent
Pigment
Solvent
Solvent
dOvVCHt
Solvent
Solvent
pH stabilizer
•SAT
Hani*
Rank
H
H
H
H
H
H
H
MH
MH
MH
M
M
M
M
M
Ivr*
Welght-rf-Eridcnce
CUMlftcalloa'
B2
Bl2
None
None
None
Under review4
A*
D
None
None
Under review
Under review
C
Under review
OraJStap*
Factor
(ma/kgHtay)-1
7.5E-3
-
-
-
-
-
-
-
-
-
-
-
5.7E-2
-
Oral
RID
(mi/hftMlajr)
6E-2.
5E-42
-
-
-
Under
review
-
2E-1
-
-
Under
review
1E-2
4B-2
Under
review
Inhai
RIC
(as./!-3)
Under
review
Under
review2
.
.
.
-
-
4E-1
-
-
2E-1
-
Under
review
Under
.mjla-M
ICVICW
InhaL
UvJIRtok
tot*3)'1
4.7E-7
1AE-3?
•
.
-
•
\3R-23
-
-
-
-
-
1.6E-5
-
Drinking Water
UnltRfek
OND^)"'
Z1E-7
-
-
-
-
-
-
-
-
-
-
-
1.6E4
-
M
U)
or
-------
Ecological Hazard Table
W
M
H
RELATIONSHIP OF 1988 TRI RELEASES REPORTED BY SPECIFIC SEGMENTS OF THE AN INDUSTRY TO
ESTIMATES OF EXCESS LIFETIME CANCER CASES AND MAXIMUM AQUATIC CONCENTRATIONS
REPORTING TRI FACILITIES
AND PROCESSING ACTIVITIES
AN MANUFACTURE
Amarican Cyanamid
BP International
Starling Chamicala
DuPonl
Monaanto
ADIPONITRILE MANUFACTURE
Monaanto
ACRYLAMIDE MANUFACTURE
Amar ican Cyanamid
Dow Chamicala
Nalco
ACRYLIC FIBERS MANUFACTURE
Amarican Cyanamid
OuPont
Montanto
TMO Group
ABS/SANS RESINS MANUFACTURE
DowChamical
OEPIaatica
Monaanto
NITRILE ELASTOMER MANUFACTURE
BF Goodrich
Arrmak
Goodyaar
Unifoyal
RELEASES
(Ib)
STACK/FUGI-
TIVE AIR
637.000
90.000
24.000
802,000
2.235.000
149.000
SURFACE
WATER
5.380
1.800
2.882
7.348
108.000
430.000
EXCESS LIFETIME
CANCER CASES
FROM
AIR
6
13
40
6
FROM DRINKING
WATER
7
<1
<1
<1
MAXIMUM AQUATIC
CONCENTRATION (ppb)
(CMKONIC CONCERN UVtl
ISMPPBl
1493
<1
507
<1
SUMMARY A
DISPOSITION
N0 ACHYLONITRILI
(OPTIONS ^ NOVEMBER 20, 1«9
-------
VOLUME INFORMATION
Market Information
[general information regarding manufacture of the chemical and its use in
manufacturing the product in question]
• volume, annual amount used, % used in product
• manufacturers of substitute 1
• users of substitute 1
• trends
Volume and formulation information are also important components of the exposure
model which defines the comparative risk of selected chemicals. Industry workgroup
'members are the major source of this information. Necessary data includes: volume of
chemicals in products in the use cluster; percentage (ranges and averages) of chemicals in
products; and, total volume manufactured per year of chemicals in use cluster. The EPA
chemist and economist will oversee the collection of this information.
Attached is an example (Exhibit 4 a/b) of the type of formulation information needed for
the analysis and a form for submitting this information to the project.
-------
w
a
M
td
Design for the Environment Printing Project
FORMULATION DATA FOR BLANKET WASHES & STENCIL REMOVAL
Quantitative evaluation of the exposures and risks associated with a product requires data
on the product formulation. The most useful information is a complete list of all
chemicals in a product and the concentration (range and average) of each chemical in the
product. A brief description of each chemical's function, e.g. solvent/ surfactant/ can
also be useful for assessment and communication purposes. Specific product names are not
necessary. (see Example 1 below)
A less desirable but still useful alternative to reporting specific chemical
concentrations is to list the chemicals associated with each functional component and
provide the concentration of that entire component. For example/ someone might report
that ethyl acetate and isopropanol make up the solvent component of their product and that
the solvent component comprises 25% by weight of the product, (see Example 2 below)
Product
category
blanket
wash
stencil
removal
Chemical name
2-propanol
2-butanone
acetone
ethyl acetate
2-propanol
sodium
hypochlorite
CAS f
67-63-0
78-93-3
67-64-1
141-78-6
67-63-0
7681-52-9
Weight % of
chemical in
product as used
range avg
10-20%
9-25%
25-40%
15%
15%
30%
5%
Function
solvent
solvent
solvent
solvent
oxidizer
Weight % of
functional
component as used
range avg
20-35%
25%
Product
name
(optional)
Example 1
Example 2
-------
We appreciate your participation in this very important part of the data collection effort. Please
submit formulation data by April 12. Remember that you can keep your company name and product name
anonymous. Send data on lithographic blanket washes to:
Tom Purcell
Printing Industries of America, Inc.
100 Daingerfield Road
Alexandria, VA 22314
tel. 703-519-8114 fax 703-548-3227
OR
Send data on screen stencil removal products to:
Marcie Kinter
Screen Printing Association International
10015 Main St.
Fairfax, VA 22031-3489
tel. 703-385-1335 fax 703-273-0456
Mark Nuzzaco
Environmental Conservation Board of the
Graphic Communications Industry
1899 Preston White Dr.
Reston, VA 22091-4367
tel. 703-648-3218 fax 703-648-3219
4b
Product
category
Chemical name
CAS 1
Weight % of
chemical in
product as used
range avg
Function
Weight % of
functional
component as used
range avg
Product
name
(optional)
-------
REGULATORY STATUS
This section of the analysis contains a description of existing regulations, i.e., OSHA Pels,
and on going regulatory actions by government agencies for the chemicals in the cluster.
This information is collected from the scoring system data base by an EPA chemical
engineer. Two examples (Exhibits 5 a/b) of regulatory status information follow.
-------
DATE: 02/25/93 TIME: 11:51:37 PAGE!
Lists which contain the Chemica-1:
108-88-3 BENZENE, METHYL-
COUNT OF RECORDS = 14
Code List
> CAA 111 STANDARDS OF PERFORMANCE FOR NEW STATIONARY SOURCES OF
> CAA 112 NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS
> CERCLA COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION AND
> CWA 304 INFORMATION AND GUIDELINES
> CWA 307(A) TOXIC POLLUTANTS
> CWA 311 CLEAN WATER ACT SECTION 311 HAZARDOUS SUBSTANCES
> NPDWR . NATIONAL PRIMARY DRINKING WATER REGULATIONS
> PARA-4C PRE-TREATMENT POLLUTANTS
> PRIO POLL PRIORITY POLLUTANTS
> RCRA U LIST OTHER DISCARDED COMMERCIAL CHEMICAL PRODUCTS
> SARA 110 SUPERFUND SITE PRIORITY CONTAMINANT LIST
> SARA 313 EPCRA SECTION 313 LIST OF TOXIC SUBSTANCES
> TSCA 8A PAIR TOXIC SUBSTANCES CONTROL ACT (PRELIMINARY ASSESSMENT
> TSCA 8D HEALTH AND SAFETY DATA REPORTING RULES
END OF REPORT
EXHIBIT 5a
-------
Table A-2. Existing Aerosol Spray Paint Chemical Regulations
„ -w^_. .
~b —
^TT^* ^^
"tinr Miitii
OctaM
Alifirciif M iMtacMfeoM
CycMMMM
MMhykyclohMMM
•-Kyi***
•-Xylan
p-XybM
£»,»«»«
MMhybMcfcloiU*
IfctcUatoMkylMM (T«m-)
I.l.l-Tiitilnin 1*111 .
I.I .2- T nchlovoo*M*
1 . 1 ,2-Ttichl*(oiri*ws**M«
TlkhlMMkyfaM
rninn f rnni
AM«.
«^^u~
Akduli
bcrnrri^akoi
CASN*.
110-54-3
•030-3O4
•032-32-4
III45-9
IIO-B2-7
IOI-I7-2
101 til
I0t 11-3
95-47-4
106-42-1
100-41-2
75-09-2
127-11-4
71-55-4
79-00-5
74-13-1
79-01-4
47-44-1
IOt-IO-1
71-34-3
47-414)
V«Wfitv
Volttil*
VnUtiU
Voblil*
Vobtili
Voltfil*
VoUltl*
ValMik
VolMil*
VolMit*
Voblil*
VolMito
Voblil*
Voblib
Voblib
• »^.-.;»-
VOWIM*
Vobtib
Voblib
Voblib
Voblib
Voblib
Voblib
SAT
••TLa
M
LM
LM
LM
LM
MH
LM
LM
LM
H
M
M
LM
M
L
LM
LM
LM
SDWA MCL*
1.000
10.000
10.000
10.000
700
5.0
200
5.0
5.0
SDWA
«•* Y»rt
MCLG*
1.000
10.000
10.000
10.000
1.000
0
200
3.0
0
***
CEBCLAXf
1.000
1.000
1.000
1.000
100
1.000
100
100
5.000
Ct~I~lR
RCKATC
wu
0.7
0.5
4tfWh
•uu
•CKbltiMt
no/
501 —
fAltf
IINT
400<
500*
30V
409
200*
I00>
I00>
lOV
100-
100*
too*
3501
10*
1.00V
IW
750»
100*
too*
400>
ATTIH
TLV
1-tV-V
100
100
50
350
10
50
•VM
JXW
50
O**r
CtfT
CAA'
CAA1
CAA'
CAA'
Cd
M
H
-------
INDUSTRIAL CHEMISTRY AND PROCESSES DESCRIPTION
I. The chemistry and process of manufacturing the chemical will be discussed.
[Include process diagram]
II. The chemistry and process of manufacturing the products which are the subject
of this use cluster will be discussed.
[Include process diagram]
Chemistry and process flow diagrams provide the basis for determining possible sources
of releases within the manufacture of a chemical or production of a product in a use cluster.
In cases where the volume of a chemical used in the use cluster product is negligible when
compared to the total volume manufactured of that chemical, one can elect not to perform
analysis for I. above.
It may be sufficient to create one process flow diagram for the manufacture of the use
cluster product if there is one primary process used by the industry. Industry representatives
can work with EPA to develop the process flow diagram(s). See Exhibit 6 for an example
of a process flow diagram.
8
-------
W
a
M
W
l-l
H
Ox
Eihylunt
^~>
Sml
Aluminum
clilotidn
IwJ
B«u«n«
Sillier
Dry
ben/cn*
HacycU
compl*ii
CmU«
clhyltieniciw
BOIIIMM BKIUCIH; E IhyltMniciw PulyclliylLcMiciit
iLiumy (<.-»jinA'
Sd
Pulyclhyl
bcillcii*
t lliyllxulltlM
(IICHluCI
-------
SOURCE RELEASE ASSESSMENT
This assessment identifies potentially harmful releases and waste from chemicals in the
identified use cluster. This release information informs the exposure model which estimates
possible risks to humans or the environment. In addition, release reduction/mitigation
strategies will be identifed in the pollution prevention and control technology opportunity
assessment sections described below using this release information. Uncertainties will be
characterized.
Industry will work with EPA to identify releases/wastes of concern from chemicals in the
use cluster in each of these areas:
I. Manufacture of chemical/ Disposal
II. Manufacture of products/ Disposal
III. Use of products/ Disposal
In cases where the chemical volume used in the use cluster product is negb'gible compared
to the total volume manufactured, then I. can be skipped. See Exhibit 7 for an example of
information provided in the source assessment.
-------
SOURCE ASSESSMENT: IDENTIFICATION OF RELEASES/WASTES
OF CONCERN
• The largest waste stream in AN production consists of still bottoms from the wastewater
stripper, the final purification of AN, the distillation of acetonrtrile, and the purification of
acetonitrile. These four waste streams are RCRA listed hazardous wastes (K011, K013, and
K014) and are generally managed by storage in a deep well pond with subsequent deep well
injection. Air releases from the holding pond may be significant. Phone calls to the facilities
may be required to verify that holding ponds are stilt in use in light of the RCRA Land Disposal
Restrictions. TRI releases via deep well injection total 4.333,900 pounds for 1988.
• The second largest release source is stack emissions, with fugitive emissions also close to this
amount. Examples of major stack release sources are the absorber vent and distillation
column purge vents.
• . Examples of fugitive air emissions sources are vatve leaks, pump and compressor seals,
product storage tanks, transfer operations and emissions from the deep well ponds.
• HCN is a major by-product which may be either recycled or disposed of Efforts to increase
the reutilization of HCN should be encouraged.
EXHIBIT 7
-------
EXPOSURE ANALYSIS AND RISK CHARACTERIZATION
I. Manufacture of chemical
Occupational
Environment
Human Health Endpoint
Air
Water
Land
Non-human Endpoint
Air
Water
Land
Safety Concerns
Disposal
II. Manufacture of product/ Disposal
same as above
III. Use of products/ Disposal
same as above
EPA staff will estimate exposure in the above areas inorder to provide information for
the risk characterization of the selected cluster. Exposure scenarios will be developed for
each area above with the help of industry. EPA will create the risk characterization section
of the CTSA. See Exhibits 8 a/b/c/d/e/f for examples of an exposure assessment and risk
characterization write-up. (Note that the attached examples focus on product use, not
manufacture and do not include analyses on water or land releases.)
10
-------
Aerosol Spray Paints Cluster Analysis
4.0 EXPOSURE ASSESSMENT
Indoor Air exposure to aerosol paint can occur through the following routes:
• Inhalation of gas and vapor components (e.g., solvent or propellant) of spray paint;
• Inhalation of paint solids and resins (e.g., colorant and binders) from overspray; and
• Dermal exposure to paint solids and non-volatile components through incidental contact
of exposed skin with paint mist in air and incidental or accidental spraying of hands and
fingers.
4.1 Occupational Exposure Assessment
4.1.1 Worker Population
The total estimated worker population in the United States who use or are exposed to aerosol
spray paint in an indoor environment is approximately 970,000. Aerosol spray paints are
predominantly utilized in the following occupational settings:
Construction Industry - lay out of building grids;
Building Maintenance • heat resistant products on furnaces, boilers, grills, stoves, etc; paints
are also used for applying safety markings;
Vehicle Maintenance and Repair - touch-up/finish of auto bodies; painting of other vehicle
parts;
Floral Industry - preparation of floral arrangements;
Carpentry • finishing;
Household furniture - finishing;
Aircraft and Parts • touch-ups and repairs; and
Advertising • making signs, etc.
For the purposes of this assessment, the number of workers potentially exposed to aerosol
spray paints by spray usage and industry type was estimated (SAIC I992)using the assumption that
only 25% of the workforce in the selected industries actually use or are exposed to spray paint, and
of those, approximately 40% use or are exposed to spray paint indoors. Therefore, approximately
10% of the estimated worker population in each industry is assumed to be exposed to spray paint
indoors.
Estimates of the number of employees exposed to aerosol spray paint according to usage and
industry type are presented in Table A-l of Appendix A. The industry codes have been categorized
into Gve groups of estimateo usage (volume and frequency). The groups are categorized as follows:
Group 1: 2 cans per day (highest);
Group 2: 1 can per day,
Group 3: 1 can per week;
Group 4: 1 can per month; and
Group 5: 1 can per four months (lowest).
EXHIBIT 8a
-------
4.1.2 Worker Exposure Analysis
Appendix B presents the detailed exposure assessment methodology and major assumptions
used by SAIC (1992) to estimate worker exposures. Tables 5 and 6 present the results of the
occupational exposure assessment for volatile and non-volatile components, respectively. Estimated
daily doses based on one can of spray paint used per 8-hour workday are presented in column 5 of
Table 5 and 6. Potential dose rate estimates for dermal contact, based on use of one can of spray
paint per 8-hour workday, are presented in column 12 of Table 6. Lifetime Average Daily Dose
(LADD-o,) and Average Daily Dose (ADD) estimates for workers are presented in columns 8 and
11 of Table 5 and 6, respectively. The averaging time for the LADD^ was 70 years (i.e., a person's)
and for ADD was 40 yean (Le., a person's working life).
4.2 Consumer Exposure Assessment
4.2.1 Consumer Population
Based on information from a 1987 national usage survey of household solvent products
(Westat 1987) and 1988 U.S. Bureau of Census data, approximately 68.2 million people in the United
States are potentially exposed to components of aerosol spray paints. Of these, approximately 51%
(33.2 million) are male and 49% (35.0 million) are female. Typical consumer applications of aerosol
spray paints include painting or reGnishing furniture, trim and shutters, and appliances and other
household items; hobbies; and automobile touch-up and refinishing. Approximately 18 percent of
aerosol spray paint activities take place entirely indoors (excluding the garage), and another 16
percent take place in a garage. Consequently, it was assumed that indoor use of aerosol spray paints
by consumers ranges from approximately 18 to 34 percent Activities occurring in the garage were
assumed to occur while the door was closed thereby mimicking an indoor air exposure. Automotive
aerosol spray paint products are typically used outdoors.
4.2.2 Consumer Exposure Analysis
Appendix B presents the exposure assessment methodology and major assumptions used by
Versa: (1992a) to estimate consumer potential dose rates. Central tendency and high-end potential
dose rate estimates for short-term (24-hour) consumer exposure to volatile and non-volatile
components of aerosol spray paints are presented in column 6 and 7 of Tables 5 and 6, respectively.
Estimates of the central tendency and high-end potential Lifetime Average Daily Dose (LADD-)
for volatile and non-volatile components are presented in columns 9 and 10 of Tables 5 and 6,
respectively.
Exposure estimates were obtained using the Multi-Chamber Concentration and Exposure
Model (MCCEM), which offers both short-term and long-term exposure calculations (GEOMET
1991). A generic house was used which assumed that the aerosol spray paint was used in the kitchen.
The short-term exposures and LADD^s of the individual volatile and non-volatile components were
extrapolated, based on weight-%, from those calculated for total volatiles and total non-volatiles.
The consumer exposure assessment estimated individual exposures for twelve scenarios based
on the varying the following parameters: inhalation rate, exposure frequency, exposure, duration.
amount of product used per event, percent of time event takes place indoors, and time spent in room
after event. By selecting median and/or mean values for all parameters and choosing high values for
certain minor parameters, four scenarios were developed in an attempt to estimate the central
tendency value. The central tendency is either the mean or median exposure value. Eight scenarios
were developed to estimate high end exposures to result in values which are estimated to fall above
the 90th percentile of the potential dose rate distribution. Although 8 high end scenarios were
developed, 4 scenarios were not used due to concerns that the combination of high values for each
EXHIBIT 8b
-------
parameter may have pushed these scenarios off the curve to a bounding estimate. A bounding
estimate is an estimate to which no real person is exposed.
4J Major Data Gaps and Uncertainties
For any exposure scenario there are uncertainties inherent in the assumptions and methods
used to calculate the corresponding exposure levels. Additionally, the parameters that comprise the
exposure modek exhibit some degree of variability. Identification of uncertainties, therefore, are
required to provide decision-makers with the complete spectrum of information regarding the quality
of an assessment, including the major data gaps and the effect the data gaps have on the accuracy
or reasonableness of the exposure estimates developed. This section discusses the sources of error,
areas of uncertainty, and data gaps which, conceivably, may weaken any conclusions that may be
drawn from this assessment
43.1 Occupational Exposure Assessment
The scarcity of published aerosol spray paint studies and exposure models requires that
exposure estimates be made by adapting other modek. Quantification of exposure is best
accomplished with measurements made during spray paint can use, but little data was available for
this specific work task. The major areas of uncertainty in the exposure estimates presented in this
report include the following:
Exposed population - Information was not available regarding the specific occupations or
SIC codes that use aerosol spray paints. Professional judgment was used to select the SIC
codes of the exposed population and in the estimation of the number of workers exposed
within each code.
Occupational use estimate • While a significant amount of the spray paint used
occupationally is purchased in retail stores, no information was available regarding the
actual end use (i.e., household vs. workplace). The estimate that approximately 50% of
the units produced have an occupational end use is based on input from an industry
source and professional judgment
Use of the CEB Dermal Exposure Model - The CEB dermal exposure model requires an
estimate of the amount of material remaining on the skin (Q). The CEB assessment
manual provides a table of estimated Q" values, which are based on the immersion of
hands into liquids of varying viscosity. Aerosol spray paint use would likely result in far
less material on the skin than liquid immersion. Therefore, the dermal exposure estimates
from this model are likely to be conservatively high.
Constituents in the spray paint - The formulations of spray paint products are highly
variable. The estimates of constituent percentages presented in this report are derived
from actual product data and reference data bases. The variability between spray paint
products translates into uncertainty in the estimated exposures.
4.3.2 Consumer Exposure Assessment
Although there are indications that the majority of aerosol spray paint consumed in the
United States is used by consumers, the end-use markets are characterized poorly with no accurate
breakdown of consumption by user groups. Consequently, it is possible to enumerate the consumer
population expected to be exposed to components of aerosol spray paint only by comparison of
national population statistics with the results of the Westat survey. Attempts at enumerating the
population by questioning trade associations and other professional organizations were unsuccessful
EXHIBIT 8c
-------
The accuracy of the MRI database used to obtain information qn the concentration of volatile
components was low for some of the results. Specifically, the true values for the first study were
±30% of the reported concentrations with recoveries of 96-115%. For the second study, the true
values were ±0.2-5.0 times the reported concentrations with recoveries of 70-135%. Additionally,
concentration data for non-volatile components of aerosol paints were limited to dated information
from Clinical Toxicology of Commercial Products (Gosselin and Hodge, 1984). Use of these data add
a degree of uncertainty to the exposure assessment
MCCEM, the model used in this assessment to estimate the potential short-term and lifetime
exposures to total volatiles and total non-volatiles in aerosol spray paint used average assumptions
with regard to room volume, and infiltration and exfiltration rates. In addition, assumptions regarding
such input parameters such as the overspray fraction of the paint, aerosol settling velocity, the
fraction of overspray available for inhalation, and the activity pattern of the individual all add
uncertainty to the exposure estimates. Perhaps the most important contributor to uncertainty is the
assumption regarding the number of times paint is used per lifetime. The exposure frequency was
based on the Westat survey response regarding the time since last painting. This is not the same as
the time between painting events. This discrepancy tends to inflate the frequency of use. Therefore,
the time since last painting was divided by 2 in order to decrease the frequency of use. A factor of
2 was used based on the fact that, on average, the survey question would have been asked of people
half way between events. Since this was found to be the most sensitive parameter in the exposure
calculation, more data are needed in order to estimate a more reliable exposure frequency.
Tables 5 and 6 present a summary of the occupation and consumer exposure to volatile and
non-volatile chemicals, respectively, and are sorted by chemical and component class. It also provides
a summary of the SAT hazard ratings for specific chemical components not previously identified in
the moderate to high concern table (i.e., Table 3).
EXHIBIT 8d
-------
Aerosol Spray Paints
Table 5. Summary of Volatile Component Occupational and Consumer Inhalation Potential Dose Rate
Findings by Chemical and Component Type
CAS*
6744-1
110-82-7
100-41-4
110-54-3
108-87-2
56-37-7
75-09-2
78-93-3
108-10-1
111-65-9
80-564
; >''b'Z,
IteMl
Drily
Dw«
On***
«farr)
2J66
0.037
0.18
0.473
0.12
0.041
1.779
0.651
0.531
0.053
0.0186
C«MMMMr Dally DMM lUagt
(mtfl&tmj)
Central
Tendency
9.82E+00 -
l.ME+01
1.42E-01 - 2.37E-01
6.15B-01 -
1.03E+00
1.75E+00 -
2.92E-KW
3.55E-01 - 5.92B-01
1.66E-01 - Z76B-OI
&55E-f 00 -
1.09B+01
X35E+00 -
4.27E-KK)
1.96E+00 -
3.28E+00
2.13B-01 - 3.55E-01
4.73E-02 - 7.90E4H
tU&Eot
5.45E401 -
7.86E+01
7.88E-01 -
1.14B+00
3.41E+00 -
4.93E-KK)
9.72E+00 -
1.40E+01
1.97E+00 -
ZS4E-KX)
9.19B-01 -
133E+00
3.64B+01 -
5^5E+01
1.42E+01 -
Z05E+01
1.09B401 -
1.57E+01
1.18E+00 -
1.71E+00
2.63E-01 - 3.79E-01
LoAt-Tena
f
Oct«y*U«Ml ADD1
(•^kc-fn)
(nwt»)Z
0.0203-3^400
0.0003 - 0.0500
0.0015 - 0.2400
0.0040 - 0.6400
0.0010 - 0.1640
0.0004 - 0.0560
0.0150 - 2.4000
0.0056 - 0.9000
0.0045 - 0.7200
0.0005-0.0720
0.00010 - 0.0162
CMBMBCT LADDL^ RBBBC
(mtfvlSf)
CetHral
tutittuj
3J3E-03 - 1.05E-
02
431E-05 - 1 .52E-
04
2.08E-04 - &58B-
04
5.93E-04 - 1 J7B-
03
1 JOB-04 - 330E-
04
5.61B-05 - 1.77B-
04
Z22&O3 - 7.01 E-
03
8.65E-04 - 2.73E-
03
6.65E-04 - Z10E-
03
7.21E-05 - Z28E-
04
1.60E-05 - 5.06B-
05
Hlfl^arf
1 J4B-02 - 5.03E-02
Z67E-04 - 7.28E-04
1.16B-03 - 3.15E-03
3J9E4B - 8.97E-03
6.66E-04 - 1^2E-03
3.11E-04 - 8.49E-04
121E-02 - 3J6E-02
4JOE-03 - 131E-02
3.69E-03 -1.01E-02
4.00E-04 - 1.09E-03
8^9E-05 - X43E-04
M
S
M
to
M
H
ao
-------
RISK CHARACTERIZATION
Risks were estimated for both occupational and consumer settings. The
following exposure routes were evaluated: 1) inhalation of vapor components
such as solvents and propellants, 2) inhalation of aerosols of paint solids
and resins such as colorants and binders, 3) dermal exposure to paint
solids and other non-volatile components through incidental contact.
Both short-term and long-term exposures were estimated: 24-hour dose,
average daily dose (ADD) during a 40-yr working lifetime, and total
lifetime (70-yr) average daily dose (LADD). Central tendency (mean or
median) and high end (>90th percentile) estimates were developed by
constructing scenarios in which major input parameters vary. The variables
included: inhalation rate, exposure frequency, exposure duration, quantity
of product used per event, concentration of chemical in product, percent of
time event takes place indoors, and time spent in room after event.
Carcinogenic risks were evaluated by estimating upper-bound individual
lifetime risks. Carcinogenic risk for a chemical is calculated by
multiplying the estimated exposure level and the chemical's carcinogenic
potency estimate. For example a lifetime average exposure level of 3 \ig/m3
to a chemical with a carcinogenic potency (unit risk) of 5 x 10~7/lig/m3
•would result in a lifetime risk of 1.5 x 10"'. Other toxicologic endpoints
were evaluated by calculating a "hazard index," which is the ratio of the
exposure level to a Reference Dose (RfD) or Reference Concentration (RfC).
EPA defines a Reference Dose or Reference Concentration (for inhalation
exposures) as a daily lifetime exposure level that is unlikely to present
an appreciable risk of deleterious effects. A Reference Dose is expressed
as a mg/kg/day dose and a Reference Concentrations as a mg/m3 air
concentration. A hazard index value greater than one (i.e. the exposure
level is above the RfD or RfC level) is assumed to present a potential
concern. Hazard index values below one are assumed to represent minimal
concern. Sample risk estimates for some of the aerosol spray paint
chemicals are shown in the table below.
Preliminary Risk Estimates
Chemical
methylene
chloride
Cd orange/red
lithopone
CrPbMo oxide
Toluene
Hexane
Hazard quotient
Occ. range
0.25 - 40
0.28 - 44
84 - 13500
70 - 11000
Consumer high
end
0.21 - 0.56
0.46 - 1.3
70 - 191
58 - 160
Upper bound cancer risk
Occ . range
IE-OS -
2E-03
6E-04 -
8E-02
4E-03 -
5E-01
Consumer
high end
2E-05 -
6E-05
1E-03 -
4E-03
1E-02 -
3E-02
The risk estimates shown above should be regarded as only rough, screening
level estimates because of many uncertainties and limitations in both the
underlying data and the mathematical models employed. The exposure
modeling relied heavily on extrapolations from generic data and assumptions
based on professional judgment.
EXHIBIT 8f
-------
INTRODUCTION TO POLLUTION PREVENTION AND CONTROL TECHNOLOGY
OPPORTUNITY ASSESSMENT
This assessment will provide a summary of available information regarding pollution
prevention and control technology opportunities which may reduce/mitigate industrial
releases of a chemical or chemicals under review. Specific individual processes for chemical
manufacturing and use for which possible human and/or environmental risks will be
identified in each of the components of the risk reduction hierarchy. The hierarchy
essentially consists of:
1) source reduction (including technology changes and improved management practices)
2) responsible recycling/reuse
3) improved treatment technologies
4) improved disposal technologies
Information collected will address worker exposure issues, so as to identify all cost and
performance issues associated with the use of a particular chemical or technology.
If relevant information does not exist to compile portions of this assessment, then the
resulting information needs will be clearly identified as areas for potential future
investigation.
An EPA chemical engineer will work with industry to identify opportunities for pollution
prevention and will then assess these alternatives.
11
-------
Source reduction and pollution prevention opportunities will be identified by industry and
the EPA chemical engineer in the following areas:
An example of the information included in this analysis follows as Exhibit 9.
SOURCE REDUCTION OPPORTUNITIES
Process Change Assessment
Information gathering and engineering assessments will be performed on process changes
and conditions that reduce releases. Such information includes equipment modifications
and altered process conditions.
Management Practices Assessment
The impact of altered management practices to reduce releases will be examined.
Examples of such management practices include the incorporation of periodic monitoring
and maintenance of areas where fugitive air releases may occur.
RECYCLE OPPORTUNITIES
Areas where improved recycling would reduce releases will be examined. Examples
include the use of condensers in stacks to recover volatile organics followed by separation
and recycle.
CONTROL TECHNOLOGIES
Treatment technologies that result in mitigated releases will be examined. Examples
include the use of incinerators to burn organic waste for energy.
Disposal technologies that result in mitigated releases will be examined. Examples
include the use of vitrification for highly toxic metals.
12
-------
POLLUTION PREVENTION/CONTROL TECHNOLOGY OPPORTUNITY ASSESSMENT ACRYLONITRILE
MANUFACTURING ' NOVEMBER 20, 1991
SOURCE REDUCTION OPPORTUNITIES
Procea* Chang* A*a«aament
° PrOC6SS Chang6S that Wi" 6liminate the need to water
h COU'd * investi9ated in the separation of AN product and water generated
from the react,on such as improved distillation or extraction following distillation
Management Practice* A*«e**ment
- within the facility to limit
the efficiency of the incinerator/flare.
RECYCLE OPPORTUNITIES
Potential opportunities that could be investigated are:
• Use of nitrogen blanket or purge to address explosive potential by reducing oxygen content in
product stream and allow start-up emissions to be sent to absorber.
• Routing of startup emissions to a combined water scrubber/carbon adsorption or other
trchnology that may overcome explosive , -otential and allow for recycling of the AN.
CONTROL TECHNOLOGIES
Improved control technologies that have been employed or may be worthy of further investigation:
Thermal incineration of absorber off-gas.
Process flare to receive emissions from column vents.
Floating roof tanks in place of fixed roof tanks to reduce AN emissions from storage tanks.
Double mechanical seals.
Rubber seals on process sewers and sumps with drainage to central sump and dedicated
process sewer to eliminate emissions from open sewers.
Insulated storage tanks to reduce thermal breathing.
Enclosed sampling system for product/process sampling.
Conversion of holding pond to tanks or into covered units.
Improved treatment technologies that may be worthy of investigation include:
• Incinerate hazardous wastewaters and bottoms streams in a hazardous waste incinerator;
. eliminate holding ponds.
• Extraction of hydrocarbons from the wastewater prior to being sent to the holding pond or for
reuse (e.g., carbon adsorption, solvent extraction).
EXHIBIT 9
-------
PERFORMANCE
Information relating to the comparative performance of the substitute will be presented.
These issues will include the affect on performance of any necessary risk reduction
equipment or procedures.
Include information on multiple functions of specific chemicals, i.e. may act as pigment
and solvent. Also, certain chemicals may only work with specific other chemicals in other
functional subgroups, e.g. solvent x may only work with a specific rosin.
COST
Information relating to the comparative cost of the substitute will be presented. This will
include the cost of any necessary risk reduction equipment or procedures.
Include information on chemicals, processes or technologies that do not perform as well
therefore requiring greater quantities of materials and incurring a greater cost.
Information on performance and cost of alternatives will be collected through industry
performance testing of substitutes using industry approved parameters. EPA will assist in
developing parameters and testing methodologies. Testing will seek to document, in case
study form, quality trade offs, work practice changes and cost considerations involved in
using process, chemical and technology alternatives. See Exhibit 10 a for an outline of what
performance testing goals and schedule.
13
-------
PERFORMANCE TESTING
DESIGN FOR THE ENVIRONMENT PRINTING PROJECT
There are two purposes for performance testing in the DfE
Printing Project. First, printer performance testing will be used
to create a baseline for the performance and cost analyses in the
substitute assessments. This means that traditional as well as new
alternatives need to be identified and tested by printers to form
a basis for comparison between products.
Second, performance testing will document any quality trade
offs and work practice changes so printers will have the
information necessary to try alternative products in their plants.
Thus, information from the performance tests will be included in
the substitute assessment analysis and will be written as case
studies for printers. It is important that the performance
information be based on documented standardized tests, as much as
possible, so that quality trade offs and cost considerations can be
considered along with risk trade-offs.
Proposed Outline
I. Study Design and Printer Identification
GATF/SPTF with the help of the EPA's Office of Research and
Development/Office of Pollution Prevention and Toxics and industry
printers and suppliers (Performance Committee) will develop a study
design. The committee will identify parameters/variables as well
as agree upon an acceptable level of uncertainty for the test.
Baseline testing will be performed in controlled conditions at
selected test sites, like GATF and SPAI. In addition, printers
will be identified through the committee or technical assistance
organizations in the states and asked to provide case studies on
performance.
II. Product Identification
Products with representative formulas will be chosen using
Material Safety Data Sheets to provide a sampling of approximate
chemical data for traditional products and new alternatives.
Traditional products need to be tested simultaneously with new
alternatives in order to create baseline information (i.e.
comparing products on an equal basis). The committee will select
the representative products which will be masked for the test.
Masked MSDS forms will also be created to provide proper
documentation when the chemicals come into the print shops.
EXHIBIT lOa
-------
III. Product Testing
Two steps in performance testing have been identified. First,
a controlled test at one site will be performed for a number of
traditional and alternative products to test the study design.
While the parameters will all be tested for in a scientific manner,
documentation will be by case study method, explaining that
absolute certainty can not be attached to the results of the tests.
Second, identified, masked products will be tested by printer
who have volunteered the use of their shops. An organization, like
GATF or SPAI, or an other contractor, will provide technical
assistance to printers and will help the printers document the test
results using the Study Design. Again, the goal of the tests is
not to provide absolute certainty as to the substitutability of the
product. Rather the goal is to document, in a structured manner,
how the product worked, any work practice or other modifications it
required, any quality trade offs identified by the pressman, as
well as issues which may affect cost. This information will inform
the substitute assessment and printers who are interested in
knowing about alternative products.
IV. Documentation of Results
The contractor, with the assistance of EPA's Office of
Research and Development, will provide test results to the
substitute assessments and will write case studies for printers
which document the impressions and judgements of the pressmen as
well as providing factual information.
Proposed Timeline
I and II.
Study Design, Printer and Product Identification - 2 months
III.,
Initial Controlled Test and Printer Testing - 3 months
IV.
Documentation of Results - 2 months
EXHIBIT lOb
-------
ENERGY IMPACTS
Discuss the energy requirements for manufacture of the chemical and for manufacture
of the product, using this chemical. Discuss sources of energy.
Industry will provide information for this analysis from the performance testing results.
RESOURCE CONSERVATION
Discuss natural resource issues; what impacts on non renewable resources the
manufacture of this chemical or product have.
EPA staff and industry will work together to define the data needs for this piece.
INTERNATIONAL TRADE ISSUES
Discuss the international trade in this chemical and any issues surrounding this trade.
Also include discussion of any international agreements which may affect the use of this
chemical or product.
The above sections will be integrated into a social cost/benefits issues piece written by
the EPA economist on the project.
14
------- |