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.
Comment submitted by L.E.
This is comment on Proposed Rule
Protection of Stratospheric Ozone: Allocation of Essential Use Allowances for Calendar Year 2009
View Comment
Related Comments
Public Submission Posted: 01/22/2009 ID: EPA-HQ-OAR-2008-0503-0034
Feb 17,2009 11:59 PM ET
Public Submission Posted: 01/30/2009 ID: EPA-HQ-OAR-2008-0503-0035
Feb 17,2009 11:59 PM ET