Printech Archive
Re: Use of acetone in reformulated products

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Date: Mon May 24 1999 - 17:12:53 CDT

Do you believe EPA should assume the roles of OSHA, the Fire Marshal, and DOT to regulate chemicals based on flammability and combustibility?

If yes, what value would or could EPA add to help a company safely manage their flammable and combustible materials?

If no, EPA must review material usage based on waste generation [or its potential] and the impact of that waste generation on the environment.

We live in an imperfect world with imperfect standards. There are no chemicals [with the possible exception of water] that are absolutely benign under all circumstances. Rules and regulations allow for alternatives [chemicals, processes] to be discover
ed and used and for lawyers and consultants to profit.

So, why regulate a substance as a VOC when the impacts to ozone [smog] generation is considered negligible because the potential for a fire or explosion is high? It seems like it should be up to OSHA, the Fire Marshal or DOT to do so.

Mark C. Stoddard
Compliance & Technical Assistance Program

>>> <> 05/24/99 10:37AM >>>

You are absolutely correct in describing the EPA position on the delisting of acetone and other chemicals. However, the response completely misses the point that Marci raised. With its high vapor pressure and low ignition point the use of acetone in an i
ndustrial environment becomes quite hazardous.

Shouldn't the EPA be concerned about such hazards as they contemplate removing such materials from the basic control system provided by the VOC regulations? Apparently there is no one in the EPA who will admit to having such a responsibility. I've aske
d around with no success.

Alex Ross

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