REPORT TO CONGRESS
ON
THE PROGRESS OF REGULATION
TO PROTECT STRATOSPHERIC OZONE
April 1983
O.S.. ENVIRONMENTAL PROTECTION AGENCY
401 M Street, S.W.
Washington/ D.C. 20460
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The Environmental Protection Agency transmits this report
on regulatory activities to protect stratospheric ozone in
accordance with Section 155 of the Clean Air Act Amendments of
1977 (Public Law 95-95).
Admi nistrator
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TABLE OF CONTENTS
SUMMARY 1
I. THE OZONE DEPLETION ISSUE 5
II. THE AEROSOL PROPELLANT RULE .12
III. CHLOROFLUOROCARBON PRODUCTION AND USE 15
IV. INTERNATIONAL COOPERATION 18
V. FURTHER REGULATION 21
REFERENCES »...» 23
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LIST OF FIGURES
Figure 1: Combined Annual Production of
CFC-11 and CFC-12 (1960-1981) Iff
Figure 2: Combined Annual U.S. Production of
CFC-11 and CFC-12 Expressed as
Percent of World Production
(1960-1981) .....16
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SUMMARY
As mandated by Section 155 of the Clean Air Act Amendments
of 1977/ PL 95-95 (CAA)/ the Environmental Protection Agency
(EPA) submits to Congress this report on the progress of
regulation to protect stratospheric ozone. It covers the period
from February 1982 to the present. Section 155 requires the
Administrator to report annually to Congress on actions taken by
the Environmental Protection Agency and other Federal agencies to
regulate sources of halocarbon emissions, the results of such
regulations in protecting the ozone layer, the need for
additional regulatory action, if any, and recommendations for
control of substances, practices, processes, or activities other
than those involving halocarbons which affect stratospheric ozone
and cause or contribute to harmful effects on public health or
welfare.
This report reviews activities related to the protection of
stratospheric ozone from potential depletion due to emissions of
a number of substances including chlorofluorocarbons (CFCs).
Although it is now believed that the level of carbon dioxide and
other substances in the atmosphere can to a degree moderate total
column ozone depletion, if total column ozone concentrations were
reduced, increased amounts of solar ultraviolet radiation irr the
wavelength region of 290-320 nanometers (UV-B) would penetrate
the atmosphere to reach the earth's surface. An overall increase
in UV-B radiation, it is believed, would lead to a higher
incidence of nonmelanoma skin cancer among humans, and may lead
to decreased plant productivity, and disruptive effects on the
aquatic food chain.
In 1982, two major reports were issued addressing the
scientific aspects of the ozone depletion issue. The first,
prepared by Federal agencies primarily involved in upper
atmosphere research and the United Nation's World Meteorological
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Organization, provided a comprehensive discussion of the current
state-of-knowledge of the stratosphere and man's impact on it.
The second, prepared by the National Academy of Sciences,
constituted its third assessment of the ozone depletion issue.
In addition to reviewing the current state of relevant knowledge
in both atmospheric and UV-radiation/biological effects research
and noting changes in the scientific understanding that had taken
place since their 1979 assessment, the Academy report noted that
important scientific uncertainties bearing on the issue remain,
and made numerous recommendations for additional investigation to
reduce uncertainties.
In addition to CFCs, other potential ozone affecting
substances, including other halocarbons, carbon dioxide, and
nitrogen oxides, are being investigated by EPA and other
agencies. Research programs at EPA, the National Aeronautics and
Space Administration, the National Oceanic and Atmospheric
Administration, the Federal Aviation Administration, and the
Department of Energy seek to determine the potential strato-
spheric effects of these compounds. One program, initiated by
EPA and the National Oceanic and Atmospheric Administration in
1982, is designed to upgrade the ozone measuring capabilities at
several monitoring stations around the world and to provide
important data for the early detection of changes in the ozone
layer.
In 1978, the Food and Drug Administration (FDA) and EPA
promulgated rules prohibiting the manufacture and processing of
certain CFCs for nonessential aerosol propellant uses. SPA
continues to receive and process exemption requests pursuant to
that rulemaJcing. In 1982, one exemption request was granted, two
were denied, and several others were voluntarily withdrawn.
Annual U.S. and world production of commercially-important
chlorofluorocarbons CFC-11 and CFC-12 peaked in 1974 at 831
million pounds and 1,871 million pounds, respectively. In
subsequent years, U.S. production declined steadily—more sharply
than world levels—and in 1980 reached a level 45 percent below
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its peak production figure. Between 1980 and 1981, however,
domestic production increased by 7.5 percent. The contribution
of U.S. production of CPC-11 and CFC-12 to the world total has
dropped from 72 percent in 1960 to only 29 percent in 1981.
Since domestic restrictions were placed on non-essential aerosol
propellant uses of CFCs, the amount used for that purpose has
decreased abruptly from about 420 million pounds in 1976 to under
25 million pounds in 1982. However/ CFC demand for some non-
aerosol uses/ such as for solvents and blowing agents for rigid
foams has grown steadily and may be expected to continue to grow.
Because CFC emissions in any country are dispersed
throughout the earth's atmosphere, the protection of
stratospheric ozone is an international issue. A few countries
have prohibited most aerosol propellant uses of CFCs. Other
developed nations have achieved reductions in such uses by
regulatory or voluntary actions. Several nations are assessing
the feasibility of reducing emissions from other uses. Japan and
the European Economic Community have limited CFC-11 and CFC-12
production capacity to present levels. With other U.S. agencies,
EPA is participating in the activities of a number of
international organizations which promote, coordinate, and assess
research and study of the scientific, public health, and economic
aspects of the CFC/ozone depletion issue. During 1982, the U.S.
participated in United Nations Environment Program activities
related to the development of a global framework convention to
address the issue of stratospheric ozone depletion/protection.
In 1980, EPA issued an Advance Notice of Proposed Rulemaking
(ANPR) requesting public comment about possible effects on human
health and the environment from the continuing use of CFCs, on
the appropriateness of restricting non-aerosol uses, and on the
merits of several mandatory-control and economic-incentive
approaches to achieving that end. The ANPR also solicited
comments on the validity of the ozone depletion theory, and on
the effectiveness of restricting the production or use of CFCs as
a means of dealing with any significant problem. Also in 198(1,
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JPA issued a proposed rule to regulate emissions of certain
halocarbon solvents—some of which could promote eventual ozone
depletion—from new, modified, or reconstructed organic solvent
degreasing/cleaning operations. This proposed rule was issued
under the authority of Part A of the CAA Amendments of 1977. The
health effects data on these solvents are currently being
reviewed by EPA's Science Advisory Board; upon completion of that
review, a decision will be made regarding the need for future
control of these solvents.
To fulfill the requirements of the CAA Amendments of 1977
and to improve and expand the scientific basis for evaluating the
necessity of further reductions in CFG emissions, EPA and other
Federal agencies are continuing to monitor and support research
related to improving our understanding of atmospheric science,
the adverse health and environmental consequences of ozone
depletion, the technological capabilities for limiting CFC
emissions from major sources, and the costs of achieving such
controls. Any further Agency action will be based on credible
scientific evidence and sound economic analyses subject to
rigorous peer review. However, significant gaps remain in our
understanding of these and other aspects of the ozone
depletion/protection issue. Moreover, statistical analyses of
ozone measurements taken around the world indicate that total
column ozone has probably increased slightly over the last
several years, although this change is not considered
statistically significant. A sound basis exists, therefore, for
a policy that recognizes (1) the importance of continuing
research and atmospheric monitoring activities to decrease
scientific uncertainties and increase knowledge bearing on all
aspects of the issue, and (2) that, for the near future, such
efforts can continue without incurring significant impacts on
stratospheric ozone, public health, or the environment.
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I. THE OZONE DEPLETION ISSUE
Ozone is found throughout the stratosphere—a region of the
atmosphere extending from approximately 10 to 50 kilometers above
the earth's surface—and also at lower altitudes. Total column
ozone, that; is, the total amount of ozone through which sunlight
passes before reaching the surface of the earth, is important to
the earth's ecology, in part because it limits the amount of
solar ultraviolet radiation that reaches the earth, specifically,
radiation in the wavelength region of 290-320 nanometers
(UV-B). Exposure to increased levels of OV-B radiation is known
to cause acute effects (e.g., sunburn) and has been strongly
correlated to subchronic and chronic effects (e.g., nonmelanoma
skin cancer) among certain human populations.
The concentration of ozone present in the stratosphere is
determined by a dynamic balance between natural processes that
produce and destroy it. Scientists have developed atmospheric
models (computer simulations) to represent the complex chemical,
transport, and radiative processes in the atmosphere to test
their current understanding of the atmosphere and to estimate
possible future stratospheric changes. Based on these
theoretical representations, the ozone depletion theory
postulates that the natural rate of ozone destruction and
creation in the stratosphere can be altered by the chemical
action of several chemical species, including those containing
chlorine (e.g., Cl, CIO), hydrogen (e.g., HO, H02)r and nitrogen
(e.g., NO, NO2).
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Chlorine and nitrogen species are natural constituents of
the stratosphere. Both also have man-made origins such as from
chlorofluorocarbons (CFCs)*~a source of chlorine species—that
are released to the atmosphere in conjunction with their use or
disposal, or from aircraft engine exhausts that directly inject
nitrogen species into the stratosphere. A significant increase
in the concentration of these chemical species in the
stratosphere is of concern because some act as catalysts in
chemical reactions that destroy ozone.
CFCs are very stable in the lower atmosphere, or
troposphere. After their release, they migrate very slowly from
the troposphere into the stratosphere where they are decomposed
by solar ultraviolet radiation and release chemically active
chlorine species. Consequently, the continued worldwide release
of CFCs has the potential to increase the concentration of
chlorine-containing species in the stratosphere that may
eventually result in decreased stratospheric ozone on a global
scale. Increases in the concentrations of some chlorine species
in the stratosphere have been measured; to date, however, no
change in the earth's total ozone layer--beyond natural
variations—has been detected by the analysis of historical ozone
records.
In 1982, the National Aeronautics and Space Administration
(NASA), the Federal Aviation Administration (FAA), the National
Oceanic and Atmospheric Administration (NOAA) and the World
Meteorological Organization (WMO) issued a report, The
Stratosphere 1981; Theory and Measurements/ which discussed the
current state-of-knowledge of the stratosphere and man's impact
* Chlorofluorocarbons are a family of halocarbon
chemicals. Historically, CFC-11 and CFC-12 have accounted
for most of worldwide CFC production. However, other CFCs
are achieving increasing commercial importance, including
CFC-113, CFC-114, CFC-115, and a related compound, CFC-22,
which, unlike the other commercially-important CFCs, also
contains hydrogen.
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on it.1 This report was based on a joint USA/WMO Meeting of
Experts Workshop held in May 1981 that was attended by over 100
scientists representing most of the institutions in the world
engaged in upper atmosphere research.
The report compared the results of recent atmospheric model
calculations performed by researchers from around the world.
Their models included the most up-to-date chemistry/ used a CFC
emission scenario that assumed world CFC production would remain
constant—at 1976 levels—into the future, and excluded the
effects of other potential ozone perturbants. The model
calculations gave "steady-state" ozone depletion values ranging
from 5-9 percent* In other words, assuming world CFC emissions
continued at 1976 levels into the future and ignoring the
possible effects of other stratospheric pollutants, current model
calculations show that the existing balance between ozone-
creating and ozone-destroying processes in the stratosphere could
be changed in such a way that a new equilibrium, or "steady-
state," would be achieved near the end of the 21st century and
that the total amount of stratospheric ozone would be 91-95
percent of what it is today. If other commercially-important
halocarbons are included in the models at their current emission
rates, the individual depletion estimates (5-9 percent) generally
increase by about a third (to approximately 7-12 percent). Other
stratospheric pollutants that are omitted from these calculations
could markedly alter this result. Assumptions of growth in tFC
emissions generally result in higher calculated ozone depletion
estimates.
The calculated values of future ozone depletion are highly
uncertain and may be expected to change as our understanding of
stratospheric chemical and physical processes improve. The
depletion range cited above is based on identical input data and
reflects only differences in the models themselves. The actual
uncertainty in depletion estimates may be considerably larger.
The 5-9 percent "steady state" depletion range estimate,
however, represents a significant reduction from the 16.5 percent
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depletion estimate reported by the national Academy of Sciences
(HAS) in its 1979 assessment of the CFC/ozone depletion issue2.
The differences between current results and those reported in
1979 are attributed to refinements in the values of important
chemical reaction, rates used in the model calculations.
Statistical trend analysis of.historical ozone data has been
used to look for trends in global ozone. The analysis of ozone
records collected over the last two decades by ground-based
stations around the world fa-ils to reveal any significant change
in total ozone that can be ascribed to human activities. This
result is not inconsistent with atmospheric model calculations,
since no detectable trend would be expected on the basis of
current theory. A recent assessment indicates that statistical
analyses of data obtained from the current network of ground-
based monitoring stations may be sensitive enough to detect as
little as a. 2-4 percent change in the total amount of
stratospheric ozone.
In addition to CFCs, scientists are investigating other
chemical substances, including methyl chloroform, nitrogen
oxides, and carbon dioxide for their suspected effects on ozone.
o Analysis of the relative ozone depletion potential of
various substances by the Lawrence Livermore National
Laboratory (LLNL) modeling studies indicates that methyl
chloroform—an industrial solvent currently finding
widespread commercial use—has, on a pound-per-pound basis,
about one-seventh (0.14) the potential of CFC-11 for
depleting stratospheric ozone.3
o Nitrogen oxide emissions from aircraft flying at high
altitudes (either upper troposphere or lower stratosphere)
also may affect stratospheric ozone, particularly in the
northern hemisphere where most air travel occurs.
Atmospheric model calculations indicate that nitrogen oxides
released in subsonic aircraft exhausts in the region of the
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tropopause may already have increased ozone concentrations by
between 0*5 and 1 percent. However, as aircraft operate at
higher altitudes, injecting nitrogen oxides directly into the
lower stratosphere, the effect may be to decrease ozone in
that region. Scientists explain that the effect of exhaust
emissions on ozone differs as a function of altitude because
of differences in the atmospheric chemistry that dominates at
various altitudes. Significant increases in the number of
flights or flight altitudes may-be necessary, however, before
significant ozone changes would occur.
Aircraft emissions do not. constitute the only source of
nitrogen oxides in the stratosphere. Other sources include
nitrous oxide (^O) emissions from combustion and from soils
and waters as a result of agricultural and waste management
practices.
o Increases in carbon dioxide in the atmosphere, due
primarily to increased burning of fossil fuels, are expected
to lead to decreases in stratospheric temperatures with the
consequent slowing of chemical reactions taking place in the
stratosphere. This could make the impact of CFCs on
stratospheric ozone less than would otherwise be the case
without a change in stratospheric temperature. .A carbon
dioxide buildup may also result in global surface temperature
increases. Both temperature changes may result in climatic
changes of unknown variations.4
Although scientists have made great progress in
understanding complex stratospheric processes through modeling,
laboratory experiments, and atmospheric monitoring, substantial
work remains in order tp decrease scientific uncertainties. In
this context, recent model calculations reported by LLNL suggest
that over the next century the combined effect of CFCs~assuming
world emissions remained constant at 1980 levels—and the other
stratospheric pollutants discussed above would result in no net
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change in the total amount of ozone that shields the earth from
solar UV-B radiation. However, there could be future changes in
the altitudinal distribution of stratospheric ozone.5 Although
this forecast/ like all model results, is strongly dependent on
the projected emission scenarios for all pollutants used in the
calculations and the correctness of our current understanding of
the stratosphere as represented in the model, the LLNL
calculation estimates a future ozone depletion in the middle
stratosphere (with maximum change at an altitude of 40 km) that
is counterbalanced by a buildup of ozone below 25 km. While the
environmental consequences of changes in the vertical
distribution of stratospheric ozone remain uncertain, it is the
total column ozone, of course, that is relevant to the amount of
UV-B radiation that reaches the earth's surface.
In 1982, the National Academy of Sciences released its third
assessment of the scientific aspects of the ozone depletion issue
in a report entitled Causes and Effects of Stratospheric Ozone
Reduction; An Update.6 Part I of the two-part report reviews
the status of knowledge about the stratosphere, the potential for
man-made causes to change stratospheric ozone levels and the
effects of those changes. The report notes that discrepancies
between theory and observations have driven research over the
last several years, and that such research had reduced
discrepancies. It also observes, however, that important
discrepancies remain, meaning that there are still uncertainties
inherent in the results of modeling exercises.
While stating that ongoing, planned, and proposed research
in the field, in the laboratory, and in theory can be expected to
further reduce the apparent discrepancies, the MAS report also
makes specific recommendations for future atmospheric research.
These recommendations urge (1) that atmospheric research maintain
a broad perspective but. emphasize resolving discrepancies between
theory and observation, (2) that global monitoring include both
sound ground-based and satellite observations (particularly of
ozone above 35 km, where theory indicates the largest ozone
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reductions might occur), and (3) that, in addition to CFCs, other
potential stratospheric pollutants be assessed and their
consequences for stratospheric ozone evaluated.
Consistent with these recommendations, EPA, NOAA, WMO, the
Chemical Manufacturers Association Fluorocarbon Program Panel
(FPP), and the Interagency Committee for Stratospheric Ozone
Protection (ICSOP)—the Federal o*zone research coordinating
committee established by CAA~began a joint two-year project in
1982 to upgrade ground-based monitoring of the vertical
distribution of ozone at selected observing stations around the
world. These automated stations will collect important data on
the status of ozone, including data on ozone above the 35-kn
altitude. The ground-based measurements will also provide
valuable information with which to compare satellite
observations.
Part II of the MAS report reviews the current state of
knowledge concerning the effects on biological systems of an
increase in UV concomitant with an ozone reduction, and provides
numerous research recommendations.6 A decrease in ozone,
independent of other factors, increases the intensity of UV-B
radiation reaching the earth's surface. Scientists agree that
increased UV-B levels at the earth's surface would increase the
incidence of human nonmelanoma skin cancer, especially among
light-skinned people. The WAS report estimates that more than 90
percent of skin cancer other than melanoma in the U.S. is
associated with sun-light exposure and that the damaging
wavelengths are in the UV-B spectral region. The report goes on
to estimate that there would be a 2-5 percent increase in basal
cell skin cancer incidence and a 4-10 percent increase in
squamous cell skin cancer incidence in the U.S. for each 1
percent decrease overall in stratospheric ozone. Nonmelanoma
skin cancer is a problem primarily because it causes
disfigurement and imposes economic burdens associated with its
treatment.^ if detected early, it is usually treated
successfully.
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Although the postulated relationship between malignant
melanoma, a dangerous form of skin cancer, and UV-B radiation
exposure has been studied for over two decades, a dose-response
relationship has not been identified. For melanoma/ total
accumulated UV-B dose does not appear to be a significant causal
factor, although acute or repeated exposures to sunlight may be
important. Melanomas are increasing at a faster rate than most
other cancersf especially among younger, more affluent, and
better educated persons ; however, the relationship between OV-B
exposure and melanoma is not known.
Information on nonhuman effects of increased UV-B is
difficult to quantify at present. EPA is funding a multi-year
field research study to determine the effects of increased UV-B
on selected economically important crops grown under otherwise
normal conditions- Nonagricultural terrestrial organisms have
been shown to be susceptible to increases in UV-B radiation
exposure. Laboratory studies show that a number of aquatic
species (algae, plankton, fish larvae) which exist close to the
surface may be living close to their UV tolerance levels. EPA
has funded research over the last three years which has provided
excellent data on UV-B radiation penetration in a variety of
water conditions.
II. THE AEROSOL PROPELLANT RULE
In 1978, EPA and FDA simultaneously published rules
prohibiting the use of fully-halogenated CFCs—including CFC-11
and CFC-12—as aerosol propellants in nonessential appli-
cations.8 The final EPA rule prohibited the manufacture of these
CFCs for nonessential aerosol propellant uses after October 15,
1978. In addition, the rule also prohibited, after December 15,
1978, other activities related to the exploitation of CFCs for
nonessential aerosol propellant uses, including their processing
and distribution in bulk, their processing for export, and their
importation in bulk or in nonessential aerosol articles.
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Under the Federal Food, Drug, and Cosmetic Act, FDA
prohibited the manufacture or packaging of food/ drugs, medical
devices, and cosmetic products containing fully-halogenated
chlorofluoroalJcanes as an aerosol propellant after December 15,
1978, and the initial introduction into interstate commerce of
finished food, drugs, medical devices, and cosmetic products
containing these substances after April 15, 1979. The FDA rule
exempted certain drugs and food products.
In its rule, EPA exempted certain propellant uses determined
to be essential on the basis of criteria contained in a support
q
document for the rule. These criteria included the availability
of substitutes, the economic significance of the product, the
environmental and health impacts of the aerosol product and its
substitutes, and the effect on the quality of life if the product
or a reasonable substitute were unavailable. Current exemptions
to the-EPA rule include CFC aerosoL propellant applications in
conjunction with mining, aircraft operation, national defense,
pesticide use, manufacture and servicing of electrical and
electronic equipment, and mold release agents.
In 1982, EPA granted a temporary- exemption for the use of
CFCs in automatic pesticide dispensing units for the 1982 tobacco
insect infestation season. A request for a permanent exemption
for this use was denied on the basis of the availability of
suitable non-CFC substitutes. EPA also denied a request to allow
the manufacture and export of personal protection (tear gas)
devices that would use CFCs as an aerosol propellant, again based
on the availability of substitutes. Several other exemption
requests were withdrawn by petitioners, including one for limited
research and development purposes and another for use in a crowd
dispersal device. EPA is currently reviewing a petition
concerning the use of CFCs as an aerosol propellant to deliver
insecticides in aircraft applications.
Until the reporting requirements expired in March 1982,
manufacturers and processors were required to submit annual
reports to EPA if they manufactured or processed CFC propellants
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cor exempted aerosol products. In 1981 reports were received
from 5 manufacturers and 76 processors. Data from the reports
indicate that aerosol props11ant use accounted for about 23
million pounds of CFCs in 1981. In comparison, aerosol use
accounted for an estimated 448 million pounds of CFCs in 1973.10
A study has been conducted for EPA to evaluate the economic
impact of the ban on nonessential CFC aerosol propellants.
Preliminary results indicate that in general the impact on
consumers was small since good substitutes were readily
available/ often at lower cost to the consumer. There appeared
to be a negative impact on profits, especially on CFC
manufacturers and on aerosol fillers. There was also a one-time
cost for aerosol product manufacturers and fillers to reformulate
and convert to hydrocarbon- or carbon dioxide-propelled
products.^
On December 15, 1980, EPA published an interpretive rule,
under authority of Section 12(b) of TSCA, requiring individuals
to notify EPA of exports or expected exports of substances
regulated under Section 6 of TSCA. The rule requires
individuals to notify EPA of the first shipment of each year to a
given country. EPA in turn will notify the importing countries
of the export of CFCs to that country and the nature of the EPA
regulations. Since January 1982, EPA has received approximately
133 reports from 19 companies giving notice of export to
approximately 73 countries. These exports include bulk shipments
of CFCs and CFCs in mixtures such as in exempted aerosol
products.
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III. CHLOROFLUOROCARBON PRODUCTION AND USE
EPA continues to monitor the production and use of
chlorofluorocarbons implicated in the ozone depletion issue. The
U.S. International Trade Commission (ITC) publishes annual
domestic production data for some halogenated (chlorinated and
fluorinated) hydrocarbons, including CFC-11 and CFC-12 13. World
production data for CFC-11 and CFC-12 are published annually by
the Chemical Manufacturers Association (CMA). These data are
based on reports submitted by 19 CFC-producing companies located
around the world and on estimates of remaining world production
of these chemicals14. Since 1976, CMA has also published
aggregated annual estimates of CFC-11 and CFC-12 sales, as
reported by the 19 CFC-producing companies, for specific CFC use
categories including refrigeration, foam blowing, and aerosol
propellant uses. Detailed production and use data on most other
commercially-important CFCs, however» are not readily available
on a world or domestic basis.
The production of CFC-11 and CFC-12 in the U.S. have
followed similar trends over the last two decades1^. Their
combined production volume increased at an average annual rate of
9.2 percent through the 1960s and early 1970s, reaching a peak of
about 831 million pounds in 1974. (See Figure 1.) Following a
steep (20 percent) drop in 1975 from the 1974 level, U.S.
production of these two chemicals continued to decline through
1980 when production stabilized at about 454 million pounds. ITC
data for 1981 indicates that the combined production of CFC-11
and CFC-12 increased 7.5 percent over the 1980 level to a total
of 488 million pounds, corresponding to 59 percent of the peak
production level achieved in 1974.
World production of CFC-11 and CFC-12 also peaked in 1974 at
an estimated 1,871 million pounds before declining slightly at an
average annual rate of 2.7 percent through 1979.14 (See
Figure 1.) Since 1979, the combined world production of these
chemicals is estimated to have increased at a 1.6 percent annual
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4.0
"
iiii
i r
I i i i I I i i > I I
i r
Figure 1: Combined Annual Production of
CFC-U and CFC-12 (1960-1981)
M
O
2.0
1.0
0.8
0.6
u
•^
O
0.2
Data Source: ITC and Chemical
Manufacturers Association
- 1 I i i i i
!_i_ I i » i i I t
i i
i i «
1960
1970
1980
I
30
60
L
I
i i i
I
i r
T
Figure 2; Combined Annual U.S. Production
~ of CFC-11 and CFC-12 Expressed
as Percent of World Production
(1960-1981)
40
Data Source: ITC and Chemical
20 Manufacturers Association
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rate. In 1981, world production reached 1,674 million pounds/ or
89 percent of the peak production level achieved in 19.74.
Throughout the last two decades, the contribution of U.S.
production of CPC-11 and CPC-12 to the world total has declined
on an average of 3 percent per year. (See Figure 2.) In I960,
the U.S. accounted for 72 percent of world production; in 1981,
the U.S. accounted for only 29 percent of v/orld production.
Historic data on sales of CFC-11, CFC-12 and the other
commercial CFCs for the major use categories is not complete for
the domestic and world markets* However, reliable estimates of
CFC sales for aerosol propellant uses in the U.S. indicate that
sales declined from 420 million pounds in 1976 to about 21
million pounds in 1980.^ Because CFC-11 and CFC-12 dominate the
CFC propellant market, these data reveal that the approximate
proportion of annual domestic production for this use has
declined from 64 percent in 1976 to 4.6 percent in 1980. On a
worldwide scale, sales estimates for CFC-11 and CFC-12 also show
a decline in aerosol propellant use: 953 million pounds in 1976
(58 percent of annual production) to 536 million pounds in 1980
(38 percent of annual production.)14 The decrease in CFC
production for aerosol propellant uses has been accompanied by
increases in nonaerosol uses—as solvents, blowing and insulating
agents in foam manufacturing, heat exchange media in
refrigeration and air conditioning, and in other specialized
processes. Anticipated recovery of the economy combined with
expected market growth in the use of CFCs for solvents and
blowing agents for rigid foams leads SRI International to predict
an average 4 percent annual increase from 1981 to 1986 in
domestic consumption of CFCs for non-aerosol uses. *
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IV. INTERNATIONAL COOPERATION
Most major CFG'producing and using nations have taken steps
to reduce CFC emissions, although few nations have reduced their
CFC emissions as much as the U.S. The ten members of the
European Economic Community (EEC) are required by an EEC Council
decision to cap production capacity for CFC-11 and CFC-12 and
they agreed to a voluntary reduction in aerosol propellant uses
of these CFCs by at least 30 percent of 1976 levels by the end of
1981. Several member countries report that they have achieved
significantly greater reductions in aerosol uses than the agreed
30 percent. In 1982, Denmark became the first EEC nation to
adopt formal restrictions on aerosol propellant use of CFCs.
Japan has decided to cap production capacity informally with end
results equivalent to those of the EEC. Canada, Sweden, and
Torway have banned most aerosol propellant uses of CFC-11 and
CFC-12, and other countries have achieved reductions without
regulation. In a recent action, Norway refused to permit the
construction of a CFC foam blowing plant on the grounds the plant
lacked adequate means for recovery of CFC emissions.
A number of international organizations are active in the
CFC issue. The Organization for Economic Cooperation and
Development (OECD), through its Environment Committee, reviewed
the CFC issue and prepared a report on the current status of the
atmospheric science, potential UV effects, industry facts and
figures, and actions by members and international
organizations. In a related exercise, scientists in several
countries used agreed-upon CFC emission scenarios in atmospheric
modeling studies. Work continues at OECD, in part funded under a
cooperative agreement with EPA, to evaluate the economic
consequences of some of the scenarios, both in terms of future
CFC use patterns and ozone depletion consequences. The results of
this scenario work will be particularly useful for evaluating the
effects on eventual ozone depletion of alternative emission
control strategies. In the U.S., modelers at du Pont and the
LLNL participated in this effort, which has been coordinated by
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EPA. The results are intended for use by OECD and national
policy makers.
The United Nations Environment Program (UNEP) serves as the
coordinator and evaluator of international research on
environmental issues. UNEP, through its Coordinating Committee
on the Ozone Layer (CCOL), conducts an annual scientific
assessment of the ozone depletion issue. At its last meeting in
November*1981, CCOL reiterated the WMO suggestion that satellite
measurements be integrated with ground-based observations to
improve ozone monitoring. The group also noted increases in
nonaerosol uses of CFCs and the production of other potential
ozone depleters.
In May 1981, the UNEP Governing Council agreed to a Swedish
*
initiative to begin work on a global framework convention to
protect stratospheric ozone. The first meeting of the
legal/technical working group was held in Stockholm, Sweden, in
January 1982, a/id was attended by representatives from the U.S.
and 26 other countries and 5 international organizations. The
report of this meeting contains a general discussion of points to
be covered in a convention. A second meeting was held in Geneva,
Switzerland, in December 1982, at which draft texts for the
convention, prepared by the UNEP Secretariat, were discussed. At
the meeting, the U.S. position urged greater international
cooperation in areas of research, monitoring, and information
exchange. This position was developed in consultation with
industry and other non-governmental organizations representing a
spectrum of viewpoints. Furthermore, it was the U.S. position
that additional control measures to protect stratospheric ozone
should be coordinated internationally at such time that such
measures are deemed necessary.
Other groups active internationally include the World Health
Organization, which is participating in an epidemiological study
of skin cancer and other potential UV-related health effects; the
International Committee of Scientific Unions, which is concerned
wi h.h h-inincHffsl effects of UV radiation and the scientific issues
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overall; and the WHO, which is involved in the atmospheric
science. The Chemical Manufacturers Association, through its
Fluorocarbon Program Panel (an international group), continues to
sponsor experimental research related to improving the
understanding of atmospheric processes/ and annually publishes
world production and emissions information for CFC-11 and CFC-12.
Domes-tic control issues potentially involve cooperative
action with other nations. It is anticipated that continuing
cooperation to examine various scientific and policy issues in
international forums will lead to better understanding and
development of international responses to the issue.
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V. FURTHER REGULATION
Scientific concern that the growth in the commercial use and
unregulated emission to the atmosphere of certain halocarbon
substances could be endangering the ozone layer has been an
underlying factor in pre-regulatory action taken by EPA in the
recent past.
In 1980f EPA published a proposed rule under Part A of the
CAA that would limit emissions of volatile organic compounds,
including the halogenated solvents CFC-113 and nethyl chloroform/.
from new, modified/ or reconstructed organic solvent
cleaners..16 EPA continues to evaluate the inclusion of these
compounds in a final rule.
Also in 1980, EPA published an Advance notice of Proposed
Rulemaking concerning possible future regulation of CFCs.1 This
action was prompted, in large part, by the conclusions of the
1979 HAS assessment of the CFC/ozone depletion issue—prepared
when atmospheric model estimates of future ozone depletion were
significantly higher than they are today—and by concern over
expected growth in nonaerosol uses of CFCs. EPA issued the ANPR
to solicit public comment and additional information on numerous
aspects of the issue. In response, EPA. received more than 2,000
comments addressing issues that ranged from the validity of the
ozone depletion theory and other scientific questions, to tire
effectiveness of restricting production or use of CFCs as a means
of dealing with any significant problem and the need for
concerted, international action if CFC controls were deemed to be
necessary. EPA is now conducting a thorough review of all
available information and scientific evidence having relevance to
the issue.
Since 1980, significant reductions in the scientific
estimates of future stratospheric ozone depletion have occurred
using increasingly more advanced and sophisticated atmospheric
models. Global ozone data collected for more than 20 years has
been analyzed and has revealed no statistically-significant
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change in the earth's ozone layer over the last decade.
Furthermore, there has been moderation in the growth of
halocarbon uses in the U.S. and the world. International
cooperation and coordination in research, monitoring/ and
information exchange is expected to continue to grow, building a
foundation for future action should controls be deemed
necessary. These factors combine to provide a sound basis for a
policy that recognizes (1) the importance of continuing research
and atmospheric monitoring activities to decrease scientific
uncertainties and increase knowledge bearing on all aspects of
the issuef and (2) that, for the near future, such efforts can
continue without incurring potentially large impacts on
stratospheric ozone/ public health, or the environment. Any
further Agency action will be based on credible scientific
evidence and sound economic analyses subject to rigorous peer
review.
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REFERENCES
World Meteorological Organization, National Aeronautics and
Space Administration, Federal Aviation Administration, and.
National Oceanic and Atmospheric Administration, The
Stratosphere 1981; Theory and Measurements, Geneva,
rland & Greenbelt, Me
Switzerland & Greenbelt, Maryland, January 1982.
2» National Academy of Sciences, Protection Against Depletion of
Stratosph*
NAS, 1979,
Stratospheric Ozone by Chlorofluorocarbons, Washington, D.C.:
rT\
3. 0. J. Wuebbles, "The Relative Efficiency of a Number of
Halocartaons for Destroying Stratospheric Ozone," Livermore,
CA: Lawrence Livermore National Laboratorv (DOE Contract No.
W-7405-Eng-48), January 1981.
4. National Aeronautics and Space Administration, "Present State
of Knowledge of the Upper Atmosphere: An Assessment Report,"
January 1980.
5. D. J. Wuebbles, F. M. Luther and J. E. Penner, "Effect of
Coupled Anthropogenic Perturbations on Stratospheric Ozone,"
J. Geophysical Research (in press), 1982.
6. National Research Council, Causes and Effects of
Stratospheric Ozone Reduction: An Update, Washington, D.C:
National Academy Press, 1982.
7. W. Riggan, J. Van Bruggen, J. Acquavella, and J. Beaubier,
U.S. Cancer Mortality Rates and Trends, 1950-1978, Vol II.,
EPA publication in preparation.
8. Environmental Protection Agency, "Fully Halogenated Chloro-
fluoroalkanes," 43 FR 11318, March 17, 1978 and Food aad Drug
Administration, "Certain Fluorocarbons (Chlorofluorocarbons)
in Food, Food Additive,•Drug, Animal Food, Animal Drug,
Cosmetic, and Medical Device Products as PropelIants in Self-
Pressurized Containers," 43 FR 11301, March 17, 1978.
9. Environmental Protection Agency, "Essential Use
Determinations—Revised Support Document to Final Regulation
on Fully Halogenated Chlorofluoroalkanes," March 17, 1978.
10. Kathleen A. Wolf, Regulating Chlorofluorocarbon Emissions:
Effects on Chemical Production, Santa Monica, CA;Rand
Corp., (N-1483-EPA), August, 1980.
11. F.H. Ando and C.R. Marshall, The Economic Impact of
Regulating Chlorofluorocarbon""Emissions from Aerosols; A
Retrospective Study, Fort Washington, PA;JACA Corp.,Tu.S.
EPA contract No. 68-01-6043), in preparation.
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12. Environmental Protection Agency, "Chemical Imports and
Exports: Notification of Export," 45 FR 32344,
December 16, 1980.
13. U.S. International Trade Commission, "Synthetic Organic
Chemicals, U.S. Production and Sales," 1960-1981.
14. 1981 World Production and Sales of Fluorocarbons FC-11 and
FC-12, Chemical Manufacturers Association, August 25, 1982.
15.. SRI International, "Fluorocarbons. Product Review," Chemical
Economic Handbook, August, 1982.
16. Environmental Protection Agency, "Standards of Performance
for New Stationary Sources; Organic Solvent Cleaners,"
45 FR 39766, June 11, 1980.
17. Environmental Protection Agency, "Ozone-Depleting Chloro-
fluorocarbons: Proposed Production Restriction,"
45 FR 66726, October 7, 1980.
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