Environmental impact of the use of chemicals and materials is the concern of
John G. Henry
From: MARK STODDARD [mailto:MSTODDAR@dem.state.in.us]
Sent: Monday, May 24, 1999 5:13 PM
Subject: Re: Use of acetone in reformulated products
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 discovered 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
>>> <RossRadTec@aol.com> 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 industrial 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 asked around with no success.