Comment submitted by L.E.

Document ID: EPA-HQ-OAR-2008-0503-0035
Document Type: Public Submission
Agency: Environmental Protection Agency
Received Date: January 30 2009, at 02:24 AM Eastern Standard Time
Date Posted: January 30 2009, at 12:00 AM Eastern Standard Time
Comment Start Date: January 16 2009, at 12:00 AM Eastern Standard Time
Comment Due Date: February 17 2009, at 11:59 PM Eastern Standard Time
Tracking Number: 8083d81d
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Docket ID No.: EPA-HQ-OAR-2008-0503 Overall I am in support of the proposed rule to allocate 63.0 metric tons (MT) of Chlorofluorocarbons (CFCs) for the use in Metered Dose Inhalers (MDIs) for the 2009 calendar year. It is my understanding that on September 2007, the Parties agreed to extend the global laboratory and analytical exemption through December 31, 2011, as part of Decision XIX/18 of the Montreal Protocol. However, my comments and concerns are the following: 1). Has the government provided any incentives or additional guidelines for manufacture’s to provide alternative methodology or new technology for the use of MDI’s that do not require the use of CFCs? 2). What are the steps that the EPA, FDA and MDI’s manufactures have proactively taken in order to avoid requesting future exemptions for allocation of essential use allowances for CFCs in MDIs? 3) Does the EPA foresee extending the global laboratory and analytical exemption for the future use of MDIs in the situation that there has been limited or no advancement in new technology for limiting the use CFCs in MDIs? The goal of The Montreal Protocol agreement is by year 2050 to restore the stratospheric ozone layer and avoid potential negative impacts on global warming. As a result I strongly encourage that government should motivate and provide guidelines/regulations for manufactures to limit or phase out the use of CFCs in MDIs. The allowance for any type of ozone depletion substances will result negative environmental and human effects; therefore, they should be limited and restricted to the greatest possible. L.E.

Related Comments

   
Total: 2
Comment submitted by P. Brammer
Public Submission    Posted: 01/22/2009     ID: EPA-HQ-OAR-2008-0503-0034

Feb 17,2009 11:59 PM ET
Comment submitted by L.E.
Public Submission    Posted: 01/30/2009     ID: EPA-HQ-OAR-2008-0503-0035

Feb 17,2009 11:59 PM ET