Comment submitted by ITW Chemtronics

ITW Chemtronics appreciates this opportunity to submit comment on the proposed rulemaking to list n-Propyl Bromide (nPB) as an unacceptable substitute for methyl chloroform, chlorofluorocarbon (CFC)?113, and hydrochlorofluorocarbon (HCFC)?141b under the Significant New Alternatives Policy (SNAP) program. Our company strongly opposes this proposed ban of nPB in aerosol cleaning operations as we believe it is unjustified and could create additional risks for the operation of our business. ITW Chemtronics is a manufacturer of specialty products used for cleaning in the service, repair and manufacturing of electronics and electrical equipment. Our product range includes innovative products specially designed and formulated for cleaning effectiveness, environmental safety, and convenience. It is our belief that the aerosol package is a safe and effective means of delivering cleaning solvent and that aerosol cleaning applications encourage the conservation of solvent through the use of a targeted cleaning approach in which a small amount of solvent delivered directly to the soiled part may eliminate the need to disassemble the equipment and completely submerse the parts in a cold cleaning operation or vapor degreaser. ITW Chemtronics? product line includes certain products that contain nPB. If nPB- based aerosol products were to be banned there would be adverse impacts on our company as well as on our customers. Our company?s field experience with nPB- based products indicates that these products have not caused any toxicity issues given current precautions and worker protection. Workers and maintenance personnel are already required by OSHA to wear appropriate personal protection in order to ensure a safe workplace; in our experience, these protections have been adequate to ensure that nPB-based products do not pose an ?unacceptable risk to human health.? As you proceed, we hope that you will consider the following: 1. nPB-based aerosol products serve vital functions in the industrial workplace and their elimination will significantly hinder effective cleaning operations. Other cleaning processes such as cold cleaning and vapor degreasing could pose significantly greater risks to workers and the environment as more solvent must be used in these cleaning applications. 2. nPB is non-flammable and is essential for use in certain applications that involve cleaning energized equipment or when cleaning is conducted in the vicinity of ignition sources such as sparks, arcs or flames. Elimination of this compound in these instances could pose very serious safety hazards for workers. Therefore, the ITW Chemtronics urges the EPA to refrain from banning the use of nPB in aerosol-based industrial cleaning and degreasing operations. Appropriate worker protections are already in place to address toxicity and exposure to this substance, and the risks of using other compounds that could potentially be flammable or pose other risks are too great. We appreciate your consideration of our views on this important issue and urge you once again to consider the negative impacts of this proposed action.