Anonymous public comment

I would like to express my reservations regarding the proposed rule [EPA–HQ–OAR–2012–0393; FRL–9779–4], which states that the definition of volatile organic compounds will be revised to add trans 1-chloro-3,3,3-trifluoroprop-1-ene (also known as SolsticeTM 1233zd(E)) (hereafter referred to as S12) to the list of compounds excluded from the definition of VOCs. I do not believe that the given justification, that S12 has little impact on ozone formation, is sufficient to add S12 to the list. In my opinion, too much attention is being paid to S12’s contribution to ozone formation and too little is being paid to its toxicity. S12 is a known toxin, with an OEL of 300 ppm, and a halogen with a GWP <5. In spite of its friendliness towards the ozone layer, the fact remains that this material is hazardous to both humans and to the environment. By removing its VOC classification, the EPA would be making it easier to trivialize the safety hazards posed by its use. There is more to this issue than simple ozone layer impact. When a chemical is a known VOC, everyone who works near and on it is immediately inclined to treat it with caution. Because of the already mentioned safety hazards, keeping S12 on the list of VOCs would be the safest course of action for everyone concerned with its use. Source: 1. " Honeywell Solstice Liquid Blowing Agent” Honeywell International Inc. http://honeywell.com/sites/JP/Products-Services/Consumer-Home/Documents/Acrobat%20Document.pdf (accessed February 15, 2013).