  SEQ CHAPTER \h \r 1 Executive Summary

EPA’s Office of Air and Radiation analyzed the potential economic
impacts of three options for regulation of n-propyl bromide (nPB) under
the Significant New Alternatives Policy (SNAP) program.  The objective
of the analysis was to determine the societal costs of the regulatory
options.  This analysis focuses in particular on small businesses,
although EPA has analyzed impacts on large businesses, as well.  The
majority of nPB is used in solvent cleaning, aerosol solvents and as a
carrier solvent in adhesives.  Solvent cleaning is addressed in a
separate document supporting a final rule.

The following three regulatory options were considered:

Option A:  nPB is unacceptable in aerosol solvents and as a carrier
solvent in adhesives

Option B:  nPB is acceptable subject to use conditions in aerosol
solvents and as a carrier solvent in adhesives

Option C:  nPB is acceptable subject to use conditions in aerosol
solvents but unacceptable for use as a carrier solvent in adhesives

Option A is the chosen option in the proposed regulation.  In this
option, the use of nPB is unacceptable in both aerosol solvents and as a
carrier solvent in adhesives.  The largest portion of the cost will be
in the aerosol solvents end use because of the larger number of
companies using nPB.  Option B is the alternate proposal that EPA offers
for comment in the preamble.  The table below shows the total annual
societal impact of each regulatory option.  The overall societal cost of
Option A will range between $37.0 and $44.0 million annually.  Health
benefits could not be quantified.  None of the three options that EPA
analyzed created a significant impact on a significant number of small
entities.

Estimated Impacts of Regulatory Options

Impact	Option A	Option  B	Option C

Number (Percentage) of Affected Small Businesses with Impact of 1% of
Annual Sales or Greater	258 (8%)	92 to 441

(3 to 13%)	76 to 396

(2 to 12%)

Number (Percentage) of Affected Small Businesses with Impact of 3% of
Annual Sales or Greater	0 (0%)	4 to 9 (0.2 to 0.3%)	0 (0%)

Societal Cost

($ Millions, $2005)	$38.6 to $46.4	$42.3 - $ 67.5	$26.6  - $ 50.2

1.    SEQ CHAPTER \h \r 1 Introduction

This report presents the results of EPA’s economic analysis of three
regulatory options for use of propyl bromide (nPB) under the Significant
New Alternatives Policy (SNAP) program.  The first objective of this
analysis was to determine if the regulatory options would result in a
“significant impact on a substantial number of small entities”
(SISNOSE).    The analysis of small business impacts was conducted in
conformance with the Regulatory Flexibility Act (RFA) and the Small
Business Regulatory Enforcement Fairness Act (SBREFA).   The second
objective of this analysis was to estimate the costs to industry of the
proposed rule and to consider the rule’s benefits.

This analysis defines a significant impact on small businesses by the
total number of companies impacted and the percent by which they are
affected by the proposed regulation.  For example, if no more than 20%
of businesses using nPB have sales impacted by greater than 1% or no
more than 100 businesses have sales impacted by greater than 3%, the
proposed regulatory option is not considered to impose a significant
impact on small businesses.  In addition, a small entity or business is
defined as one employing fewer than 500 people.  This is consistent with
the Small Business Administration’s (SBA) definitions of “small”
in most cases.  For those few cases where SBA has a different definition
for a specific code in the North American Industrial Classification
System (NAICS), EPA’s definition results in the same number of small
businesses with significant impacts and a larger percentage of small
businesses with significant impacts.

The assumptions in this analysis are based on input provided from
experts in the field of chemical manufacturing, ventilation systems, and
medicine, as well as expert opinion from chemical associations and other
government agencies.  In addition, information was gathered from
articles and websites.

There are three industrial sectors under the SNAP program that currently
use nPB: non-aerosol solvents, aerosols, and adhesives, coatings, and
inks.  Non-aerosol solvent are discusses in a separate document that
supports a final rule.  In the analysis of the industrial sector that
includes adhesives, coatings, and inks, the three end uses will be
treated independently.  This analysis only examined the adhesive
applications within that sector.  To EPA’s knowledge, nPB formulations
are not yet commercially available in coating or ink formulations.  At
this time, nPB-based coatings are being made only as a special
formulation for one firm.  This firm already meets the regulatory
restrictions that this analysis evaluates for other end uses and thus,
would experience no additional costs.

Three regulatory options (A, B, and C), propose the use of nPB in each
industrial sector application as acceptable, acceptable with a use
condition or unacceptable.  If nPB is found acceptable with a use
condition, its use will be permissible when the users meet an exposure
limit through control equipment or work practices, perform worker
exposure monitoring, and keep exposure data records.  If nPB is found
unacceptable, its use is prohibited and firms must switch to a different
solvent or formulation.

Table 1-1 on the next page lists the three regulatory options analyzed
in this report for the proposed rulemaking of nPB.  For each of the
regulatory options, EPA made an end use determination that is specific
to the respective industrial end use:

Option A:  nPB is unacceptable in aerosol solvents and as a carrier
solvent in adhesives.

Option B:  nPB is acceptable subject to use conditions in aerosol
solvents and as a carrier solvent in adhesives

Option C:  nPB is acceptable subject to use conditions in aerosol
solvents but unacceptable for use as a carrier solvent in adhesives

Table 1-1: nPB Rulemaking Regulatory Options

Industrial End Use	Option A	Option B	Option C

Aerosols	Unacceptable	Acceptable with use condition	Acceptable with use
condition

Adhesives	Unacceptable	Acceptable with use condition	Unacceptable

The cost of compliance with each option is a comparison of the cost in
the absence of regulation to the costs of meeting the regulation’s
requirements and recommendations.  Where nPB is found unacceptable,
users would need to switch to an alternative formulation with a
different cost, and in some cases, also would need to make process or
equipment changes appropriate to the new formulation.  The analysis also
assumes compliance with other environmental, health and safety
regulation for the alternative formulations.  Where nPB is found
acceptable with a use condition, users would need to meet a workplace
exposure limit by an appropriate combination of equipment and work
practices, would need to monitor workers’ exposure to nPB, and would
need to keep records of workers’ exposure levels for at least 3 years.
  In all cases, the analysis assumes the base case in the absence of
regulation is that users use equipment and practices that are common in
their industry and that users are exposed at levels shown historically
for their industry (EPA, 2003).  Assumptions specific to each sector are
described in greater detail in sections 3 and 4 below.

The vast majority of nPB users in the industrial uses covered in Table
1-1are small businesses.  In general, small businesses will experience a
greater impact from costs of the proposed regulatory options, compared
to their income, than large businesses.

The rest of this report is organized in five sections.   Section 2
describes the industrial uses for nPB and its market.  Section 3
analyzes impacts of the regulatory options upon small businesses and
determines whether there is a significant impact upon a significant
number of small entities for each option.  Section 4 analyses overall
costs to the economy of the different regulatory options.  Section 5
qualitatively describes the health benefits of the proposed rule and
other regulatory options.  Section 6 summarizes the analyses on small
businesses and total economic impacts and compares the small business
impacts and costs to all businesses of the different regulatory options.
2.  Characterization of Markets for n-Propyl Bromide

There are three industrial sectors under the SNAP program which
currently use n-propyl bromide: non-aerosol solvents, aerosols, and
adhesives, coatings, and inks.  Within these sectors, the following end
uses currently use nPB:  metals cleaning, precision cleaning,
electronics cleaning, aerosol solvents, and adhesives.  Metals,
precision, and electronics cleaning are addressed in a separate analysis
for a final rule.

Coatings and inks are not included in this analysis.  The SNAP program
has received a complete submission for use of nPB in a specific coating
application, as an ammunition sealant and coating (Lake City Army
Ammunition Plant, 2003).  The proposed rule specifically applies only to
this application and imposes no additional costs because the user
already achieves the exposure limit and performs exposure monitoring.
EPA has also received two incomplete submissions for use of nPB as a
foam blowing agent and as part of a fire suppressant blend.  The latter
two submissions are outside the scope of the proposal on nPB.

Manufacturers of nPB estimate 9 million pounds of nPB were sold
worldwide in both 2000 and 2001.  Estimates for 2002 increased to 12
million pounds (Biles, 2001).  A more recent estimate predicts the
worldwide market for nPB is 8 to 10 million pounds per year, with about
half being used in the U.S. (ICF, 2005).

Manufacturers allege that the market for nPB has decreased in recent
years because of an existing shortage on bromine (Tattersall, 2005).
Formulators may be avoiding the manufacturing of nPB because production
of nPB is not as lucrative as that for a number of other brominated
compounds (Tattersall, 2005).

Data from 2001 indicates that nPB adhesive end-uses account for about
half of the solvent sold (Kenyon, 2001).  More recent data from Poly
Systems indicate that the U.S. market for nPB-based adhesives may be
less than 1.5 million pounds per year.  U.S. market estimates for nPB
aerosol solvents range from 0.5 million pounds per year (Tattersall,
2005) to approximately 1 to 2 million pounds (Kenyon, 2001).

There are manufacturers of nPB in the U.S., Israel, China, India, the
U.K., France, Japan, and the Netherlands (TEAP, 2001).  There are
currently two U.S. companies that manufacture nPB for solvent use,
Albemarle Corporation and Chemtura.  At least 17 multinational companies
blend or package nPB, and roughly 70 vendors world-wide advertise sale
of nPB or equipment in which nPB is used (TEAP, 2001).  There are seven
major nPB solvent manufacturers (Albemarle, Chemtura, Poly Systems,
Enviro Tech International, Petroferm, AmeriBrom, Tulstar) and three
major nPB-based adhesive manufacturers in the U.S.  (TACC Adhesives,
Sovereign Specialty Chemical, and Mid-South Adhesives).  There are
another 60 or so small providers in the U.S. of specialty products,
including nPB, and 80 or so distributors and marketing representatives
selling products using nPB (IBSA, 2002).  Approximately 20 to 25
companies prepare aerosol formulations with nPB (Kenyon, 2001).
Estimates for sales of nPB in the SNAP sectors vary.  As discovered
through product searches, very few companies manufacture only products
with nPB; most produce a number of product lines with different
solvents.

Table 2-1 on the following page summarizes nPB market estimates per
industrial sector characterized by the sources of available data to the
EPA.  Figure 1 illustrates the data from Table 2-1.

Table 2-1: Industry Expert’s Market Estimates of nPB Use in Cleaning
Solvent, Aerosol, and Adhesive Industrial Sectors

Source of Estimate	Amount of nPB Used Annually (millions of pounds)

	Cleaning Solvents 	Aerosols 	Adhesives	Global Market

Email to W. Kenyon (Kenyon, 2001)	6 to 8	1 to 2	5 to 7	12 to 15

Brominated Solvents Consortium (Biles, 2001)

9.2 to 12

A. McCulloch (2001)

less than 15.4

ICF Consulting (2001)	5

3.5 (U.S. only)

	M. Ruckriegel (2002)

	1.1 to 1.4

	U. N. Technical and Economic Assessment Panel (TEAP, 2006)

11 to 221

EnviroTech International (ICF, 2005)

8 to 102

T. Tattersall (2005)

0.5

E. Williams (2005)

Less than 1

1 Estimated usage for US is 2.9 million pounds.

2 Half of this amount is estimated to be used in the U.S.

As stated above, this analysis does not include the economic impacts on
the one known firm using an nPB-based coating.  However, documents
submitted by the company show the estimated annual usage of nPB to be a
minimal 21,000 pounds per year (Lake City Army Ammunition Plant, 2003).

Figure 1: Estimates of nPB Market Use

On the following page, Table 2-2 provides the estimates for the number
of small businesses along with the total number of businesses using nPB,
by industrial sector.  Also, the table providesthe estimated number of
workers exposed to nPB by industrial sector.  The number of businesses
using nPB is based upon estimates from the International Brominated
Solvents Association (IBSA, 2002) and MicroCare Corporation (Tattersall,
2005), and information provided to Dr. William Kenyon (Kenyon, 2001).
The estimated number of businesses using aerosols that are affected is
25% to 50% lower in the 2002 compared to the data gathered in 1997
because the number of electronics firms in the U.S. has decreased in
recent years (U.S. Census Bureau, 2005).  Table 2-2 below contains the
smaller estimate of affected aerosol users obtained in 2001 and 2002.
The analysis uses the earlier 1997 values throughout the remainder of
this document in the discussion of aerosol users because they result in
higher costs overall to the economy and avoid underestimating impacts.

Table 2-2:  Estimated Number of nPB Businesses and Workers Affected

Industrial Sector	Number ALL Businesses Affected	Number SMALL Businesses
Affected	Number of Workers Exposed

Solvent cleaning	1500 to 4000	500 to 2300	8300 to 40,300 (3 to 72a per
business)

Aerosols	1000 to 5000	900 to 4750	2000 to 25,000 (2 to 5 per business)

Adhesives, coatings and inks	100 to 280	100 to 280	400 to 9,800 (4 to
35b per business)

Total	2540 to 9280	1440 to7330	3320 to 69,100

a  Sources:  PEI, 1990a, b.

b Source:  Swanson et al., 2002

In addition to the industrial sectors covered by the SNAP program, other
industries use nPB.  For years chemical companies have used nPB as a
feedstock.  Some clothing manufacturers use n-propyl bromide for spot
cleaning on new clothes.  There is anecdotal evidence that in Mexico,
companies use nPB for chemically “welding” together plastic parts of
toys.  These applications are beyond the scope of the SNAP program.

Non-aerosol solvent cleaning is performed in a large variety of
manufacturing operations.  Metal cleaning is commonly done to remove
grease, oil, and metal filings from a number of applications where metal
parts are coated, cut, plated, or stamped.  Electronics cleaning removes
primarily excess solder flux from printed circuit boards and other
electronic equipment.  Precision cleaning is removal of dirt, grease,
oil, solder flux, and other impurities where the degree of cleanliness
is essential to the end value of the product.   These uses are discussed
in greater detail in a separate analysis of the final rule addressing
solvent cleaning.

Aerosol solvents are used in many of the same manufacturing applications
as solvents and are applied to the same industrial soils; however, the
location of utilization is different.  Most nPB used as an aerosol
solvent is for in-place cleaning of electrical or electronic equipment
and aerospace maintenance cleaning.  nPB aerosol use applies to the
following NAICS designations listed in Table 2-3:

Table 2-3:  NAICS Subsectors Using nPB as an Aerosol Solvent

(U.S. Census Bureau)

NAICS Code	NAICS Category Description	Example Application of Solvents

334	Computer and Electronic Product Manufacturing	In-place cleaning of
adhesives or solder flux in installed electronic equipment

335	Electrical Equipment, Appliance and Component Manufacturing	Cleaning
excess solder flux from electrical wiring

336	Transportation Equipment Manufacturing	In-place cleaning of coatings
or grease from metal parts in airplanes

Other minor uses of nPB as an aerosol solvent include lubricants and
cleaning sprays for spinnerrettes used in the production of synthetic
fibers.  EPA’s estimate of the number of nPB aerosol users is between
1000 to 5000 firms, as stated previously in Table 2-2.

Primary use of nPB-based adhesives is in laminate countertops and
flexible foams manufacturing.  Adhesives user estimates range from 40
(Ruckriegel, 2002) to 280 firms (ICF, 2001).  To date, EPA has found the
following applications of nPB as a carrier solvent for adhesives:

Table 2-4:  NAICS Subsectors Using nPB as a Carrier Solvent in Adhesives

(U.S. Census Bureau)

 NAICS Code	NAICS Category Description	Example Application of Adhesives

326150	Urethane and other foam product (except polystyrene)
manufacturing	Sticking pieces of foam together during foam fabrication
to make cushions

336360	Motor vehicle seating and interior trim manufacturing	Assembling
foam-containing aircraft seating

337110	Wood kitchen cabinet and counter top manufacturing	Gluing
high-pressure laminate counter-tops in kitchens

337121	Upholstered household furniture manufacturing	Gluing foam
cushions

337124	Metal household furniture manufacturing	Gluing foam cushions

In addition, nPB-based adhesives are also used for prefabricated homes
(trailers) and for cushions in pet beds (HSIA, 2001).   More recently,
one adhesive manufacturer has been marketing nPB-based adhesives for use
in laying down carpeting in boats (Walnut, 2004).  These uses are
relatively small compared to the NAICS codes listed above.  In the past,
some floor-laying contractors in the southeastern U.S. used nPB-based
adhesives to glue wood or tile on concrete floors.  However, Franklin
International withdrew its nPB-based adhesive from this market due to
regulatory uncertainty (Thomas, 2001).

Users of nPB-based adhesives tend to be small businesses.  Larger
companies may choose to use the least expensive adhesives, which are
flammable; the large foam fabricators can afford to make major capital
expenditures for fire-proofing and explosion-proofing needed with
flammable adhesives.  The smaller foam fabricators are more likely to
use nPB as an adhesive because they have fewer resources available to
put into capital expenditures for fire-proofing or to put into a search
for water-based adhesives that require an engineering process change
(Seilheimer, 2001).

Below, Table 2-5 provides the NAICS subsectors utilizing nPB-based
adhesives along with each subsector’s average value of shipments
listed by firm size.

Table 2-5:  Average Value of Shipments in NAICS Subsectors

Employing nPB as a Carrier Solvent in Adhesives

(U.S. Census Bureau)

	Average Value of Shipments per Small Business ($)

by NAICS Subsector

	337121, Upholstered household furniture	337110,

Wood kitchen cabinet and counter tops	326150,

Urethane and other foam products (except polystyrene)	336360, Motor
vehicle seating and interior trim	337124,

Metal household furniture

Employee Size Category

	1 to 4	234,345	156,833	496,318	425,863	187,950

5 to 9	963,021	622,744	1,305,183	1,728,132	903,393

10 to 19	1,771,416	1,141,119	3,152,283	3,082,486	1,431,480

20 to 49	3,653,623	2,619,197	6,615,331	5,508,370	3,538,684

50 to 99	8,089,968	7,386,365	13,281,000	14,088,500	7,547,536

100 to 249	17,502,175	17,151,091	31,524,872	44,310,286	19,821,719

250 to 499	40,250,813	55,982,674	64,119,800	123,803,610	D(1)

Avg Small Businesses  in Sub sector	3,588,297	1,150,768	10,472,992
12,542,725	3,141,720

Avg ALL Businesses in Sub sector	5,490,101	1,475,602	11,110,822
44,808,573	5,239,747

Avg Subset Small Businesses using nPB	11,519,540	5,999,622

18,950,068	12,019,847	20,401,301

(1) “D” designates “Data withheld to avoid disclosing data of
individual companies; data are included in higher level totals.”  The
average value of shipments for businesses estimates those values marked
with “D” and thus may be overestimated or underestimated. (U.S.
Census Bureau, 2005)

The value of shipments increases from approximately $200,000 for
businesses with 1 to 4 employees to approximately $50 million and above
for companies with 250-499 employees.  Therefore, any regulatory option
that requires a large capital investment or increased solvent costs is
most likely to have a significant impact on the smallest firms using
nPB-based adhesives.

  SEQ CHAPTER \h \r 1 3. Small Business Impacts of Regulatory Options

EPA analyzed three regulatory options in order to determine if there
would be significant adverse financial impacts to a significant number
of small firms.  The economic impact to these firms is addressed by the
end use: aerosol solvents and adhesives.  The majority of nPB users are
small businesses, with 500 employees or fewer.  In the case of
adhesives, all known users are small businesses.

Economic impact was calculated by dividing the annual cost compliance of
the regulatory option by annual value of shipments for a respective firm
size.  The result is a percent economic impact to the bottom line.
Firms incur an economic impact of greater than 3% of value of shipments
were considered to experience significant adverse impact.  The lower the
percentage impact, the less the regulatory option would impede the
viability of a firm.  This analysis then considered the total number and
percentage of small business experiencing a significant impact to
determine if a regulatory option creates a SISNOSE.

3.2 	Small business economic impacts on the aerosol sector  TC \l2 "
Option A is the regulatory option in the proposed rule.  Option A
declares the use of nPB acceptable in solvent cleaning.  This option has
no regulatory impacts on the solvent cleaning sector.  Options A, B, C
and D find the use of nPB acceptable in solvent cleaning. Thus, there
would not be any economic impacts on the solvent cleaning sector from
the regulatory options.  Options A, B, C and D will not have a cost
impact on businesses in the non-aerosol solvent sector, and therefore,
will not impose a significant impact on small businesses in the related
industrial sectors.

3.2 Regulatory impacts on the aerosol sector

In the industrial sectors using nPB-based aerosols, approximately 99% of
all firms are small businesses with 500 employees or less.  Since small
businesses account for the majority of the firms employing nPB aerosols,
EPA analyzed the economic impacts to small businesses that may occur
because of the proposed regulatory options.

Table 3-1 identifies, by industrial subsector, the number of nPB aerosol
solvent using firms, the nPB usage per firm per year, and the total nPB
usage for a particular firm size per year.  The three industrial
subsectors using nPB-based aerosols are 334, 335 and 336.  The greatest
number of users and consequently the greatest usage occurs in subsector
334, Computer and Electronic Product Manufacturing (Stratus, 2004a).

Under regulatory Option A, the use of nPB in aerosol solvents is
unacceptable, i.e., prohibited.  Therefore, users must switch to an
alternative aerosol solvent.

Stratus Consulting analyzed three alternatives to nPB-based aerosol
solvents if nPB were found unacceptable (Stratus, 2004a).  The three
classes of likely alternatives are:  flammable solvents (ex., hexane),
blends of trans-dichloroethylene with hydrofluoroethers or
hydrofluorocarbons (trans-DCE blends), and HCFC-225.

The analysis of regulatory Option A, pertaining to aerosol solvent
applications, incorporated the following assumptions:

Aerosol solvent cost assumptions:

nPB $14.00/lb

flammables $10.79/lb

trans-DCE blends $24.71/lb

HCFC-225 $26.06/lb

Table 3-1: Small Business nPB Aerosol Solvent Usage by Subsector

 Business Size Category	NAICS Code 334

Computer and Electronic Products 	NAICS Code 335

Electrical Equipment, Appliance, and Component Mfg

	NAICS Code 336

Transport Equipment

	Total Usage by Business Size Category (lb/yr)

(%) Total Usage by Business Size Category

	Total # of Firms Using nPB	nPB Usage per Firm (lb/yr)	Total nPB Usage
(lbs/year) for 334	Total # of Firms Using nPB	nPB Usage per Firm (lb/yr)
Total nPB Usage (lbs/year) for 335	Total # of Firms Using nPB	nPB Usage
per Firm (lb/yr)	Total nPB Usage (lbs/year) for 336

1 to 4	260	25	6,500	96	25	2,400	197	25	4,925	13,825	1.6%

5 to 9	185	50	9,250	75	50	3,750	97	50	4,850	17,850	2.0%

10 to 19	271	100	27,100	92	100	9,200	123	100	12,330	48,630	5.6%

20 to 49	410	200	82,000	134	200	26,800	184	200	36,400	145,200	16.6%

50 to 99	325	400	130,000	73	400	28,800	126	400	50,400	209,200	23.9%

100 to 249	207	800	165,600	47	800	37,600	86	800	68,800	272,000	31.1%

250 to 499	62	1600	99,200	13	1600	20,800	30	1600	48,000	168,000	19.2%

Total	1721	 	520,000	529	 	129,000	843	 	226,000	875,000

Aerosol solvent alternative use patterns:

The analysis assumed the largest percent of companies would switch away
from nPB to flammables, a smaller fraction would switch to trans-DCE
blends, and the smallest number would switch to HCFC-225.  The estimated
percentages were 45%, 30%, and 25%, respectively.  Although most users
will want to use the less expensive, flammable aerosols, this analysis
assumes that most of the users that could use flammable solvents safely
have already switched.  In addition, most users of nPB chose to do so
because of its lack of flammability and cleaning capabilities (Stratus,
2004b).

The switch to flammables considers forecasts made by industry leaders
that predict the electrical contact cleaning market will shift to
flammable aerosols in the next decade (Williams, 2005).

 Percentages for the nonflammable aerosol solvent blends (trans-DCE
blends and HCFC-225) are based on smaller proportions of users choosing
this aerosol solvent.  HCFC-225 is scheduled to be phased out of
production in the next decade as an ozone-depleting substance (2015)
(Stratus, 2004b).

Associated costs for nPB-based aerosols:

$96 per worker, two times per year, for exposure monitoring, based on
costs in OSHA RIA for methylene chloride (OSHA, 1996a).

10 minutes for a manager or technical worker to review exposure data,
two times per year, at a cost of $60/hr.

Associated costs for trans-DCE blends:

No ventilation upgrade is required with the use of trans-DCE blends.
The acceptable exposure limit is obtainable without additional
ventilation.

The costs incurred result from the difference in solvent costs.  This
cost is approximately $10.71/lb, which is the cost of trans-DCE blends
minus the cost of nPB.

Users switching away from nPB-based aerosol solvents will not switch to
chlorinated solvents.  This assumption is parallel with Status’s
analysis (Stratus, 2004b).  The use of chlorinated solvents, such as
perchloroethylene, in aerosol applications involves the consideration of
health and environmental impacts and regulations.  As a result, few
users have been using chlorinated solvents as substitutes for
ozone-depleting substances such as HCFC-141b as an aerosol solvent (3M,
2003).

Associated costs for HCFC-225:

No ventilation upgrade is required with the use of HCFC-225 blends.  The
acceptable exposure limit is obtainable without additional ventilation.

The costs incurred result from the difference in solvent costs.  This
cost is approximately $11.75/lb, which is the cost of HCFC-225 minus the
cost of nPB.

Associated costs for flammable aerosol solvents:

If the user’s decision were based on solvent cost alone, it is
apparent that users would switch to flammables if nPB were found
unacceptable.  However, if users choose to switch to flammables, they
will need to meet OSHA regulations and any requirements from their
insurers.  The analysis assumes that all nPB users switching to
flammable aerosol solvents will purchase and install fire extinguishers
and explosion proofing

The installation of fume hoods is required to switch to flammables.
OSHA requires ventilation systems for flammable sprays that reduce
concentrations to 25% of the lower flammability limit of a compound
(OSHA, 1996b).

The cost of fire suppression increases as the size of the firm
increases, as more fire extinguishers and spark arrestors would be
required for a larger firm.  The approximate cost is $800/spray booth
(IRTA, 2000).

The cost of fire proofing to meet fire code, such as using explosion
proof light fixtures or changing electrical wiring, increases as the
size of the firm increases.  The cost ranges between approximately
$50,000 for smaller firms up to $250,000 for large firms (IRTA, 2000).

The unit cost for installation of fume hoods is applied to 70% of small
firms switching from nPB to flammables that employ fewer that 20
employees and 30% that have 20 or more employees (Stratus, 2004b).

The fume hood costs for flammable aerosols are the same as those for nPB
(Stratus, 2004b).

Costs per worker

The cost of PPE involves that of gloves, aprons and eye protection for
all employees using these chemicals.  The estimated cost for PPE is $804
per worker per year ($2005), using information from OSHA’s Regulatory
Impact Analysis (RIA) for the methylene chloride standard (1996).

Workers undergo training at a cost of $1000 for a specialist to make a
presentation.   These costs were taken from the OSHA Methylene Chloride
RIA in 1996 dollars ($1996) and adjusted to 2005 dollars ($2005) (OSHA,
1996a).  More extensive training is required where new ventilation
equipment is installed, also requiring up to one week of staff time at a
mean labor rate of $21/hr (BLS, 2005).

Under regulatory Option A, the unacceptability of nPB aerosol solvents
will require a shift away from nPB to alternative aerosol solvents.
Table 3-2 illustrates the economic impact of shifting to alternatives in
subsector 334, Table 3-3 shows impacts to subsector 335 and Table 3-4
shows impacts to subsector 336.  Each table shows the economic impact to
an average firm in the respective size category.

Table 3-2: Annualized Small Business Impacts to Firms in Subsector 334
When Using Aerosol Solvents (Option A—Unacceptable)

 	 	Flammables	Trans-DCE Blends	HCFC-225

Employee Size Category	# of Small Businesses Using nPB	% Economic Impact
To Employee Size Category	# Firms With Economic Impact > 1%	% Economic
Impact To Employee Size Category	# Firms With Economic Impact > 1%	%
Economic Impact To Employee Size Category	# Firms With Economic Impact >
1%

1 to 4	260	1.66-2.33%	117	0.31%	0	0.32%	0

5 to 9	185	0.43-0.61%	0	0.10%	0	0.10%	0

10 to 19	271	0.22-0.31%	0	0.07%	0	0.07%	0

20 to 49	410	0.19-0.31%	0	0.04%	0	0.05%	0

50 to 99	325	0.12-0.21%	0	0.03%	0	0.03%	0

100 to 249	207	0.08-0.17%	0	0.02%	0	0.03%	0

250 to 499	62	0.04-0.11%	0	0.02%	0	0.02%	0

TOTAL	1,721	 	117 (7%)	 	0	 	0

Subsector 334 is the largest subsector using nPB aerosol solvents.
Table 3-2 details the small business impacts to subsector 334 when firms
switch from nPB to each of the alternatives.  As stated in the
assumptions earlier in this section, firms will likely split on which
one of the three alternatives they will choose.  The assumed percentage
of users choosing to use each alternative is provided in the assumptions
stated earlier in this section, on p. 17.

This analysis assumes that 45% of nPB aerosol solvent users would shift
to flammables.  In 334, when firms switch from nPB to the flammable
aerosols, the smallest firm size will experience an economic impact of
greater than 1%, but less than 3%.  The 117 small firms affected account
for 7% of all nPB users in subsector 334.  The impact to the smallest
firm size to employ flammables results from the large capital cost of
explosion proofing as a percentage of their annual value of shipments.

Table 3-3: Annualized Small Business Impacts to Firms in Subsector 335
When Using Aerosol Solvents (Option A—Unacceptable)

 	 	Flammables	Trans-DCE Blends	HCFC-225

Employee Size Category	Number Of Small Businesses Using nPB	% Economic
Impact To Employee Size Category	# Firms With Economic Impact > 1%	%
Economic Impact To Employee Size Category	# Firms With Economic Impact >
1%	% Economic Impact To Employee Size Category	# Firms With Economic
Impact > 1%

1 to 4	96	1.83-2.21%	43	0.33-0.35%	0	0.33-0.35%	0

5 to 9	75	0.46-0.56%	0	0.10%	0	0.11%	0

10 to 19	92	0.22-0.27%	0	0.07%	0	0.07%	0

20 to 49	134	0.20-0.27%	0	0.05%	0	0.05%	0

50 to 99	73	0.13-0.18%	0	0.03%	0	0.03%	0

100 to 249	47	0.08-0.13%	0	0.02%	0	0.03%	0

250 to 499	13	0.05-0.09%	0	0.02%	0	0.02%	0

TOTAL	529	 	43 (8%)	 	0	 	0

Subsector 335 is the smallest of the three sectors using nPB-based
aerosols.  Table 3-3 gives the economic impact in subsector 335.  There
are approximately 529 small businesses estimated to need to switch away
from nPB to an alternative aerosol solvent.  As in subsector 334, the
smallest firm size will experience an economic impact of greater than 1%
but less than 3% of the value of shipments when switching to flammables.
 The 43 firms account for 8% of all small nPB users in subsector 335.

Table 3-4: Small Business Impacts to Firms in Subsector 336 When Using
Aerosol Solvents (Option A—Unacceptable)

 	 	Flammables	Trans-DCE Blends	HCFC-225

Employee Size Category	Number of Small Businesses Using nPB	% Economic
Impact to Employee Size Category	# Firms with Economic Impact > 1%	%
Economic Impact to Employee Size Category	# Firms with Economic Impact >
1%	% Economic Impact to Employee Size Category	# Firms with Economic
Impact > 1%

1 to 4	197	1.44-2.03%	89	0.27%	0	0.28%	0

5 to 9	97	0.42-0.59%	0	0.09%	0	0.10%	0

10 to 19	123	0.22-0.32%	0	0.07%	0	0.07%	0

20 to 49	184	0.20-0.32%	0	0.04%	0	0.05%	0

50 to 99	126	0.13-0.23%	0	0.03%	0	0.04%	0

100 to 249	86	0.07-0.16%	0	0.02%	0	0.02%	0

250 to 499	30	0.04-0.11%	0	0.02%	0	0.02%	0

TOTAL	843

89 (11%)

0

0

Table 3-4 gives the economic impact data for all 843 small businesses
using nPB in subsector 336.  As seen in subsectors 334 and 335,
subsector 336 has economic impact in the smallest firm size, 1 to 4
employees, over 1% but not greater than 3% of sales.  The economic
impact occurs in 89 businesses in the smallest firm size category when
switching to flammables.

Under Option A, approximately 8% of small businesses in total would
experience an economic impact greater than 1% of annual sales but less
than 3% within NAICS subsector codes 334, 335, and 336.  Thus, under
Option A, there would not be a significan impact on a significant number
of small entities.  As shown in Table 3-5 below, the most significant
economic impact of Option A occurs when the smallest firms, 1 to 4
employees, switch away from nPB to flammable aerosol solvents.  However,
the choice to switch from nPB to flammables is assumed to occur in only
45%of businesses, not all businesses.  Table 3-5 provides the weighted
nPB alternative economic impact to all subsectors using nPB-based
aerosols.

Table 3-5:  Total Impacts for Small Business Users of Aerosol Solvents
in Subsectors 334, 335, 336 (Option A—Unacceptable)

Employee Size Category	Number of Small Firms Using nPB	Number of Firms
with Impact > 1%	% of Row	Number of Firms with Impact > 3%	% of Row

1 to 4	552	249	45%	0	0%

5 to 9	356	0	0%	0	0%

10 to 19	486	0	0%	0	0%

20 to 49	728	0	0%	0	0%

50 to 99	524	0	0%	0	0%

100 to 249	340	0	0%	0	0%

250 to 499	105	0	0%	0	0%

TOTAL	3092	249	8%	0	0%

Under regulatory Options B and C, the use of nPB-based aerosol solvents
is acceptable with a requirement to meet an exposure limit of 20 ppm and
to monitor worker exposure in order to demonstrate workers using nPB are
being protected from chemical overexposure.  The operator of the
facility must also keep records of the monitored exposure data at the
facility for at least three years.

Table 3-6 below indicates the economic impacts of Options B or C on all
small firms using nPB in subsectors 334, 335 and 336.  Under these
options, there will not be a significant impact on a significant number
of small firms using nPB aerosol solvents.  The smallest firms, 1 to 4
employees, will have an economic impact of greater than 1% but less than
3% if the higher, more conservative cost estimate more accurately
describes the ventilation equipment companies will use.  The smallest
employee size category is approximately 8% of all small businesses
employing nPB in aerosol solvents, and they use approximately 1.5% of
the total nPB used in aerosol solvents.  In this case, 13% of all
businesses have economic impacts of greater than 1%.  In the smallest
firm size, 1-4 employees, 70% of the firms are estimated to have an
impact of greater than 1% of sales.   This reflects the additional cost
of installing ventilation equipment.  The lower end estimate of
ventilation equipment costs predicts a smaller number of small
businesses having an impact of 1% or greater.

Table 3-6:   Annualized Impacts for Small Business Users of Aerosol
Solvents in Subsectors 334, 335, 336 as a Percentage of Annual Shipments
(Options B or C—Acceptable with Use Condition)

Employee Size Category	Number of Small Businesses Using nPB in Subsector
	334, Computer and Electronic Products	Number of Small Businesses Using
nPB in Subsector	335, Electrical Equipment, Appliance, and Component Mfg
Number of Small Businesses Using nPB in Subsector	336, Transport
Equipment

1 to 4	260	0.91-1.83%	96	1.00-2.01%	197	0.79-1.59%

5 to 9	185	0.24-0.50%	75	0.25-0.53%	97	0.23-0.48%

10 to 19	271	0.12-0.28%	92	0.11-0.29%	123	0.13-0.29%

20 to 49	410	0.13-0.33%	134	0.14-0.35%	184	0.14-0.34%

50 to 99	325	0.09-0.24%	73	0.10-0.25%	126	0.10-0.25%

100 to 249	207	0.09-0.24%	47	0.12-0.24%	86	0.09-0.22%

250 to 499	62	0.07-0.17%	13	0.07-0.19%	30	0.07-0.18%

TOTAL	1721

529

843

Table 3-7:  Annualized Small Business Impacts in Subsectors Using
Aerosol Solvents

(Options B or C—Acceptable with Use Condition)

Small Business Aerosol Solvent Usage -- NAICS 334, 335 & 336

Employee Size Category	# Firms Using nPB	# Firms with Economic Impact >
1%	% of Row	# Firms with Economic Impact > 3%	% of Row

1 to 4	553	67-387	13-70%	0	0%

5 to 9	357	0	0%	0	0%

10 to 19	486	0	0%	0	0%

20 to 49	728	0	0%	0	0%

50 to 99	524	0	0%	0	0%

100 to 249	340	0	0%	0	0%

250 to 499	105	0	0%	0	0%

TOTAL	3093	67-387	2-13%	0	0%

The analysis of regulatory Options B and C, which are the same for
aerosols, incorporated the following assumptions:

Aerosol Solvents Market

The total number of firms and total annual value of shipments by
employee size category in each NAICS subsector code was taken from the
2002 Economic Census.  (U.S. Census Bureau, 2005)

The number of users varies by employee size category and by NAICS
subsector.  There are 3092 small firms using nPB aerosol solvents.
Their distribution is shown in Table 3-1, where they are separated by
subsector code (Stratus, 2004b).

The distribution of nPB solvent use was estimated to be 60% consumed in
subsector 334, 15% consumed in subsector 335 and 25% consumed in
subsector 336 (Stratus, 2004b).  This is based upon historical use of
ozone depleting solvents in those subsectors (ICF, 2004).

Aerosol Solvents Use

All users of nPB will continue to use nPB, rather than switching to
other alternatives.

As shown in Table 3-7, the greatest number of firms using nPB aerosols
is those with 20 to 49 employees.  As firm size increases above this
employee size range, the number of users decreases. (Stratus, 2004b)

In this analysis, the total nPB use by small businesses is approximately
900,000 lbs/yr with additional use by large businesses. (Stratus, 2004b)

Recent information on aerosol users indicates that the amount and number
of aerosol users may be only half the previous estimate.  This would
lead to approximations of the usage at 500,000 pounds per year and 1600
total users (Tattersall, 2005).  Thus, the estimates of costs in this
document are likely to be high and overpredict total cost of the
regulatory options.

Users of aerosol solvents generally use smaller amounts than users of
non-aerosol cleaning solvents due to the method of application.  For
aerospace applications, we would expect large amounts of usage on the
order of 6000 to 20,000 lb/yr.  For electronics cleaning applications,
we would expect a smaller amount of 200 lb/yr or less (Tattersal, 2005).
 The amount of aerosol cleaner used is one to two orders of magnitude
lower than the amount use in vapor degreasers, as described in the
previous section.  All employee size category usage is a multiple or
fraction of 200 lbs/year.

Associated Costs of Ventilation

To meet the requirement of Options B or C, users will likely need to
install engineering controls, or ventilation equipment, to reduce the
amount of nPB to which a worker is exposed.

The capital costs of new fume hoods apply to 70% of businesses with 1 to
19 employees and 30% already have adequate ventilation installed.  For
business with 20 employees and over, the capital costs for new fume
hoods apply to 30% and 70% already have existing adequate ventilation
(Stratus, 2004b).

Fume hoods costs were provided by Stratus Consulting and are based on a
study of laboratory fume hood installations conducted for the University
of Wisconsin in 2000 (Wisconsin, 2000).   The Wisconsin study values are
stated below in 2000 dollars ($2000) but were adjusted to 2005 dollars
($2005) in the analysis.

The costs derived from the Wisconsin study are conservatively high as
compared to a previous study conducted by ICF Consulting.  ICF estimated
costs to be between $500 and $1000 for a new fume hood or spray booth
(ICF, 2001).  The fume hoods involved in the University of Wisconsin
study are those operated in a laboratory setting.

The capital costs attributed to the fume hoods are amortized over a
15-year period at a 7% discount rate.

The number of fume hoods required is assumed to be at least 1 fume hood
for every 20 employees.

Capital Costs:

Fume hood cost is $9500 per new fume hood (Wisconsin, 2000).

Fume hood installation cost is $9500 per fume hood (Wisconsin, 2000).

Fume hood testing to verify performance is $650 per fume hood
(Wisconsin, 2000).

Annual Costs:

Workers undergo training at a cost of $1000 for a specialist to make a
presentation.   These costs were taken from the OSHA Methylene Chloride
RIA in 1996 dollars ($1996) and adjusted to 2005 dollars ($2005) (OSHA,
1996a).

More extensive training is required where new ventilation equipment is
installed, also requiring up to one week of staff time at a mean labor
rate of $21/hr (BLS, 2005).

Energy costs, taken from the Wisconsin study $2000, included the cost of
water, steam production, and electricity, and were estimated to be
$424/fume hood/year.  These costs were then inflated to $2005
(Wisconsin, 2000).

HVAC maintenance costs, taken from the Wisconsin study $2000, were
estimated to be $54/ heating, ventilation and air conditioning (HVAC)
system/year.  These costs were then inflated to $2005 (Wisconsin, 2000).

Fume hood maintenance costs, taken from Wisconsin study $2000, were
estimated to be $50/fume hood/year.  These costs were then inflated to
$2005 (Wisconsin, 2000).

Exposure monitoring costs, taken from the OSHA Methylene Chloride RIA in
$1996, were calculated as a function of the number of employees exposed
at the respective firm size.  These costs were estimated to be $40
($1996)/employee/monitoring event (OSHA, 1996a), or approximately $170
per employee per year ($2005).

The cost for recordkeeping is approximately $184 per business.  This
calculation was based on the requirement of approximately 3.2 hours per
year to collect and review the exposure data and then file the records.
The cost was calculated using 10 minutes per employee per monitoring
event, 1.8 monitoring events per year on average, 10 exposed employees
per company, resulting in an average of 3 hours per year per business to
collect and review the exposure data at $60/hr.  In addition, the
analysis assumes 0.2 hours per business at $20/hr to file the exposure
records.

Aerosol Use Patterns

Aerosol solvents were assumed to have the highest consumption among
firms employing 20 to 250 employees.

Firms with less than 20 employees were assumed to consume lower levels
of nPB.

Larger firms, 250 employees and over, were assumed to be less likely to
use nPB because of product and process improvements which have led to
reduced rework and need for transportable cleaning solvents.  In
addition, large firms are more visible to scrutiny and view worker use
of nPB aerosol solvents as a liability (Magid, 2005).

As indicated in Table 3-7, with Options B or C there is not an
annualized economic impact over 3% to any small businesses in any of the
three NAICS subsectors (334, 335 and 336) when using nPB-based aerosol
solvents.  Options B and C require the facility operator to employ
monitoring and recordkeeping.  These two options require an element of
enforcement for EPA regional offices.  With both sets of options, all
significant economic impact is to the smallest firm size.  However, 2 to
13% of firms are impacted in Options B and C, and 8% of the smallest
firms are impacted in Options A and D when firms must switch to an
alternative aerosol solvent.

Small business economic impacts on the adhesives sector

  TC \l2 "

3.3	Regulatory impacts on the adhesives, coatings, and inks sector

In the analysis of regulatory options, EPA determined the use of nPB in
the adhesives sector to be unacceptable in regulatory Options A and C.
Stratus consulting analyzed three likely alternatives adhesives to nPB.
The alternatives analyzed were adhesives based with water, acetone, or
methylene chloride.  The economic impact on small businesses stems from
the cost to switch to an alternative adhesive.  These costs are the
price differential between the substitute solvent and nPB, capital costs
if engineering controls are required, and operation and maintenance
costs.

Stratus Consulting’s analysis estimated the percentage of small
businesses to be affected by the proposed regulatory options.  Table 3-8
identifies the number of small business using nPB-based adhesives and
the total number of businesses in each of the NAICS codes.  Taking a
closer look, 172 of the 280 small businesses or 61.4% are in one
subsector, 326150, the urethane and other foam products code.

Table 3-8:  Number of Small Business Using nPB-Based Adhesives by NAICS
Code

NAICS Code

	Business Category

	Total Number of Businesses in Each NAICS Code	Number of Businesses
Using nPB-Based Adhesives	Percent of Businesses Using nPB-Based
Adhesives

326150

	Urethane and other foam products (except polystyrene)	623	172	27.6%

336360

	 Motor vehicle seating and interior trim	384	21	5.5%

337110

	 Wood kitchen cabinet and counter tops	9,557	27	0.3%

337121

	Upholstered household furniture	1,946	49	2.5%

337124	Metal household furniture	384	11	2.9%

TOTAL all NAICS codes	12,894	280	2.2%

TOTAL without 326150	12,271	108	0.9%

The analysis of the regulatory Options A and C incorporates the
following assumptions in order to estimate the percent impact upon small
businesses:

Adhesive solvent cost:

The cost of nPB is approximately $3.59 per pound in the adhesives
sector.

Adhesive cost assumptions–cost/gallon adhesives (Stratus, 2004):

nPB–$18.30/gallon

water-based–$7.55/gallon

methylene-chloride based–$7.90/gallon

acetone–$6.83/gallon

Adhesives Usage and Users:

All users of nPB-based adhesives are small businesses.

Amount of use varies by the type of adhesive and the type and size of
the respective business

The use of nPB in the adhesives sector is in firms with 10 to 250
employees.  The smallest firm size does not employ nPB because it is
more expensive to use than other available alternatives.

Users would need to use 20% more gallons of acetone-based and methylene
chloride based adhesive for the same operation compared to nPB-based or
water-based adhesives because of higher volatility of those compounds.

Most users of nPB-based adhesives forced to switch would be in the foam
fabrication industry (NAICS code 326150) and in aircraft seating (NAICS
code 336360) because of their high nPB usage.  Refer to Table 3-8.

Adhesives manufacturers used about 3.5 million pounds of nPB to produce
adhesives in 2000 in the U.S.  This is likely to overestimate the usage
of nPB based on more recent information indicating usage of closer to
1.1-1.3 million lb/yr (Ruckriegel, 2002).

There are as many as 280 users of nPB-based adhesives if the total
amount of nPB used is 3.5 million lb/yr.

Data from industrial subsectors that consume nPB-based adhesives was
extracted for this analysis from the 2002 U.S. Economic Census (U.S.
Census Bureau, 2005).

Equipment Required for Adhesive Alternatives:

The small firms currently using nPB in the adhesive sector do not have
spray booths or proper ventilation in place and would assume all costs
in order to use an alternative.  This is a conservative assumption since
there are several documented cases of nPB users with spray booths
already installed (IRTA (2000), NIOSH (2000a), NIOSH (2000b) and NIOSH
(2002)).

Depending on the size of the facility, the numbers of spray booths vary.
 Table 3-9 lists the assumed number of spray booths and workers per
spray booth.  Low range estimates assume one worker per booth and high
range estimates assume two workers per booth.

Table 3-9:   Worker and Ventilation Equipment Assumptions in Adhesive
Subsectors

Number of Employees

at Facility

	Number of Spray Booths

	Number of Workers Spraying Adhesive

1 to 4	1	1-2

5 to 9	3	3-6

10 to 19	6	6-12

20 to 49	8	8-16

50 to 99	10	10-20

100 to 249	14	14-28

250 to 499	24	24-48

Costs associated with spray booths:

$1000 to $1500 per spray booth (ICF, 2001).

44% added on to capital costs to cover installation costs (ICF, 2001;
Stratus, 2004).

$200 per spray booth for maintenance (ICF, 2001; Stratus, 2004).

$400/person/week of training to use alternative adhesive (40 hours at
$10/hr) (IRTA, 2000); one to two people per spray booth.

In addition, workers undergo training at a cost of $1000 for the entire
firm for a specialist to make a presentation.  These costs were taken
from the OSHA Methylene Chloride RIA in 1996 dollars ($1996) and
adjusted to 2005 dollars ($2005) (OSHA, 1996a).

Other costs specific to nPB-based adhesives:

$96 per worker, two times per year, for exposure monitoring, based on
costs in OSHA RIA for methylene chloride (OSHA, 1996a).

10 minutes for a manager or technical worker to review exposure data,
two times per year, at a cost of $60/hr.

Other costs specific to methylene chloride-based adhesives:

$12,000 for each upgraded ventilation system accompanying a spray booth,
in order to meet OSHA rules for methylene chloride (OSHA, 1996a).

$100 extra in electric utilities per year per spray booth/ventilation
unit (OSHA, 1996a).

$970 for a facility health monitoring program, plus $212 per worker for
personal health monitoring–costs which are likely under OSHA rules for
methylene chloride (OSHA, 1996a).

$116 per facility plus $ 946 per worker for personal protective
equipment–costs that are likely under OSHA rules for methylene
chloride (OSHA, 1996a).

Other costs specific to water-based adhesives:

$6000 for facilities with fewer than 100 employees, $12,000 for
facilities with 100 to 249 employees, or $18,000 for facilities with 250
to 500 employees to pay either for driers or for extra factory space
where foam can dry out

$700 per new spray gun (one per spray booth)

$2800 for a new adhesive pump (one for each 15 booths)

$120 in additional electric utilities for each spray booth/ventilation
installed

Other costs specific to acetone-based adhesives:

$750 per new spray gun (one per spray booth)

$3000 for a new adhesive pump (one for each 15 booths)

$800-1000 for fire prevention equipment, such as spark arrestors

$53,000 to 323,000 per spark arrestor (roughly, one per booth) for
changes to meet fire code, such as explosion proofing and electrical
rewiring–costs of $53,000 to $1.3 million per facility

$500 per year in additional insurance premiums

nPB adhesives market

The model uses information from the 2002 Economic Census to list the
number of companies in each relevant NAICS subsector (U.S. Census
Bureau, 2005).

Estimates indicate that less than 2.2% of all businesses in the relevant
NAICS codes use nPB-based adhesives.

In a separate analysis, EPA considered the quantity of small businesses
that would experience an adverse economic impact as a result of the
regulatory use condition which would require adhesive users to switch
away from nPB.  Table 3-10 shows the average annualized cost compliance
per firm, which is based on the subsectors respective chosen
alternative.  On average, the cost of switching to acetone-based
adhesive is the most expensive with methylene chloride-based adhesive
following second because of higher capital costs.

Table 3-10:  Average Annualized Cost of Compliance for Small Businesses
Using nPB-Based Adhesive when Switching to an Alternative in Option A
and C:

Methylene Chloride, Water or Acetone

(Parentheses indicate a savings)

NAICS Code

	Business Category	Average Annualized Cost of Compliance Per Small
Business Using nPB in Option A and C

(Thousands of $2005)	Average Annual Value Shipments per Small Businesses
in NAICS Code (Thousands of $2005)

Methylene Chloride	Water Based	Acetone

	326150	Urethane and other foam products (except polystyrene)	$38-59
(-)$1-3	$83-165	$10,473

336360	 Motor vehicle seating and interior trim	(-)$68-85	(-)$143-145
(-)$50 to +1	$30,930

337110	 Wood kitchen cabinet and counter tops	$40-57	$10-11	$95-142
$1,151

337121	Upholstered household furniture	$50-71	$11-14	$96-181	$3,588

337124	Metal household furniture	$61-87	$16-19	$100-221	$3,142

SECTOR AVG	 	$30	(-)$22	$134	$9,856

In Table 3-10, NAICS subsector code 336360, motor vehicle seating and
interior trim users reap solvent savings when employing any of the three
alternative adhesives.  The calculation includes 1.5 million pounds of
nPB per year consumed by the rather small subsector of only 21 firms
using nPB.  With a difference of more than ten dollars between nPB and
water-based adhesive, it is evident why there is such a large solvent
savings when switching to this alternative.  This calculation can also
explain the large savings in this subsector for firms switching to
methylene chloride and acetone based adhesives.

The Halogenated Solvents Industry Alliance has suggested that adhesive
users have sometimes chosen to use n-propyl bromide instead of methylene
chloride to avoid potential liability associated with medical monitoring
required by OSHA for use of methylene chloride (HSIA, 2001).  In
addition, companies may wish to avoid using methylene chloride, a
solvent that is heavily regulated and that may be carcinogenic.
Water-based adhesives tend to cause messy “webbing”, unlike
solvent-based adhesives, making them less appealing to adhesive users.
In addition, water-based adhesives take longer to dry than solvent-based
adhesives and require either heaters to speed drying time, more labor
hours to achieve the same product output, or a process change and
additional space (IRTA, 2001; Walnut, 2001).  Flammable adhesives are
already favored by larger companies because of their lower cost:  only
$6.83/gallon, compared to $18.30/gallon for nPB-based adhesives,
$7.55/gallon for water-based adhesives, or $7.90/gallon for methylene
chloride (Stratus, 2004).  Using flammable adhesives safely,
particularly in foam fabrication, requires installation and use of spark
arrestors and may require purchase of explosion proof electrical and
lighting equipment and other steps required to meet local fire safety
codes (Seilheimer, 2001).  Some smaller companies may prefer to pay a
higher price for non-flammable nPB-based adhesives, rather than paying
the high capital cost of equipment to use flammable adhesives
(Seilheimer, 2001).  These reasons may explain why end users apparently
are not already implementing the less expensive alternatives.  However,
other types of adhesives are already in the industry, since nPB-based
adhesives are used by less than 28% of businesses in the foam
fabrication industry and by a far smaller fraction of the other
industries using nPB-based adhesives (see Table 3-8 above).

Table 3-11:  Small Business Impacts to Firms Switching Away from nPB in
Adhesives

(Options A and C)

NAICS Code	Business Category	Total # of Small Businesses using nPB
Number of Small Businesses with Economic Impact > 1%	Number of Small
Businesses with   Economic Impact > 3%

326150	Urethane and other foam products (except polystyrene)	172	0	0

336360	 Motor vehicle seating and interior trim	21	0	0

337110	 Wood kitchen cabinet and counter tops	27	5	0

337121	Upholstered household furniture	49	4	0

337124	Metal household furniture	11	0	0

TOTAL	 	280	9 (3%)	0

The analysis in Table 3-11 implies there will not be a significant
impact on a substantial number of small adhesive users if the proposed
rule becomes final.  Upholstered Household Furniture Manufacturers,
NAICS code 337121, would experience the highest average cost of
conversion.  Wood Kitchen Cabinet and Counter Top Manufacturing, NAICS
code 337110, would experience the highest cost of conversion as a
percentage of annual shipments and would have the largest number of
small businesses experiencing impacts (i.e., greater than 1% of annual
sales).

Manufactures of aircraft seating, captured under NAICS Code 336360,
Motor Vehicle Seating and Interior Trim Manufacturing, would experience
cost savings if users are able to choose freely between water-based,
flammable and methylene chloride-based adhesives.  However, the Federal
Aviation Administration (FAA) sets tight specifications on aircraft
seating that might preclude use of flammable adhesives (e.g.,
acetone-based).  In addition, aircraft seating manufacturers may need to
receive special permission from FAA to use water-based adhesives,
depending on the flammability test results.  Given these hurdles, the
actual cost of switching away from nPB may be higher.

Under regulatory Option B, the use of nPB is acceptable with a use
restriction.  The restriction would require employers to meet an
exposure limit of 20 ppm and to monitor worker exposure.  According to
worker exposure data submitted to the Agency, firms may have difficulty
meeting the exposure limit (U.S. EPA, 2003a; ICF, 2006).  Under Option
B, EPA expects most or all users would install engineering controls to
reduce worker exposure.  In addition to engineering controls, EPA
requires firms to monitor worker exposure, as well as to keep records of
the exposure data for at least three years.

Table 3-12:  Small Business Impacts in NAICS Subsectors Using nPB-Based
Adhesives

(Option B—Acceptable With Use Condition)

Employee Size Category	Number of Firms 	NAICS Subsector Code

326150	336360	337110	337121	337124

	Using nPB-Based Adhesive 	In Size Category, All 5 Sub-sectors 	With
Impact > 1%	With Impact > 3%	Urethane And Other Foam Products (Except
Polystyrene)	Motor Vehicle Seating And Interior Trim	Wood Kitchen
Cabinet And Counter Tops	Uphol-stered Household Furniture	Metal
Household Furniture

1 to 4 employees	0	5,421	0	0	0.00%	0.00%	0.00%	0.00%	0.00%

5 to 9 employees	0	2,370	0	0	0.00%	0.00%	0.00%	0.00%	0.00%

10 to 19 employees	9	1,637	9	4-9	0.00%	0.00%	2.91-3.90%	3.24-4.34%	0.00%

20 to 49 employees	54	1,168	16-22	0	0.66-0.89%	1.00-1.35%	1.68-2.26%
1.51-2.03%	0.00%

50 to 99 employees	107	525	0-23	0	0.42-0.56%	0.54-0.73%	0.86-1.16%
0.86-1.15%	0.00%

100 to 249 employees	108	438	0	0	0.26-0.34%	0.00%	0.42-0.56%	0.44-0.61%
0.40-0.54%

250 to 499 employees	2	155	0	0	0.19-0.26%	0.00%	0.00%	0.00%	0.00%

TOTAL	280	11,714	25-54	4-9

	A maximum of 280 firms employ adhesives that are nPB-based.  nPB has
at most 2.5% of the market share of all adhesive use, which is minimal.
Those firms that continue to use nPB with the use requirement will, in
some instances, have economic impacts of greater than 3% of sales.  The
impacts greater than 1% are in boldface in Table 3-12.  Table 3-12
depicts the economic impacts to a firm using nPB-based adhesives firm
under Option B.  The largest number of small firms adversely impacted
will be those firms with 10 to 100 employees.

Below in Table 3-13 are the total estimated impacts on the NAICS
subsectors using nPB-based adhesive under Option B.  Approximately 54
firms or 19% of all firms using nPB-based adhesive experience economic
impacts over 1%.  All firms using nPB-based adhesives in the 10 to 19
employee size categories have economic impacts over 3%.  Cumulatively,
19% of all nPB-based adhesive using firms will have a significant impact
under Option B.  This is not a significant impact on a significant
number of small businesses, although the highest estimate is a
relatively high percentage of firms using nPB-based adhesives.

Table 3-13:  Small Business Impacts in NAICS Subsectors Using nPB-Based
Adhesives

(Option B—Acceptable With Use Condition)

NAICS 337121, 337110, 326150, 336360 & 337124

Employee Size Category	Number of Firms Using nPB-Based Adhesives	Number
of Firms with Impact > 1%	% of Row	Number of Firms with Impact > 3%	% of
Row

1 to 4 employees	0	0	0%	0	0%

5 to 9 employees	0	0	0%	0	0%

10 to 19 employees	9	9	100%	4-9	100%

20 to 49 employees	54	15-22	28-41%	0	0%

50 to 99 employees	107	0-23	0-21%	0	0%

100 to 249 employees	108	0	0%	0	0%

250 to 499 employees	2	0	0%	0	0%

TOTAL	280	24-54	9-19%	4-9	1-3%

The following assumptions were used in the economic cost impacts of
Option B on the adhesive subsectors:

Associated Costs of Ventilation

 To meet the requirement of Options B, most users will likely need to
install engineering controls, or ventilation, to reduce the amount of
nPB to which a worker is exposed.

The analysis applied the capital cost of ventilation to all firms using
nPB.

The cost of the spray booth was taken from Institute for Research and
Technical Assistance’s (IRTA) 2000 Cleaner Technologies Analysis of
Foam Fabrication (IRTA, 2000) and inflated to $2005.

The cost of the spray booth ventilation system and installation were
taken from OSHA’s 1996 RIA on Methylene Chloride and confirmed on
websites for spray booths (OSHA, 1996a) and inflated to $2005.

Capital Costs:

Spray booth:  $1000-$1400 in $2000 (IRTA, 2000).

Ventilation system: $11,000 in $1996 (OSHA, 1996a).

Ventilation system installation: cost of the spray booth and ventilation
system combined in $1996 (OSHA, 1996a).

Annual Costs:

Training for the proper work practice use of personal protective
equipment (PPE) and ventilation system is $1000/firm/year.   Workers
undergo training at a cost of $1000 for the entire firm for a specialist
to make a presentation.  These costs were taken from the OSHA Methylene
Chloride RIA in 1996 dollars ($1996) and adjusted to 2005 dollars
($2005) (OSHA, 1996a).

Energy costs, taken from the Wisconsin study in $2000 and the IRTA study
in $2000, included the cost of water, steam production, and electricity,
and were estimated to be $100-$400/spray booth/year (Wisconsin, 2000,
IRTA, 2000).

Spray booth maintenance costs, taken from the IRTA study in $2000, were
estimated to be $200/spray booth/year (IRTA, 2000).

 The cost of PPE involves that of gloves, aprons and eye protection for
all employees using these chemicals.  The estimated cost for PPE is $804
per worker per year ($2005), using information from OSHA’s RIA for the
methylene chloride standard (1996).

Exposure monitoring costs, taken from the OSHA Methylene Chloride RIA in
$1996, were calculated as a function of the number of employees exposed
at the respective firm size.  These costs were estimated to be $40
($1996)/employee/monitoring event (OSHA, 1996a), or approximately $170
per employee per year ($2005).

The cost for recordkeeping was approximately $184 per business.  This
calculation was based on the requirement of approximately 3.2 hours per
year to collect and review the exposure data and then file the records.
The cost was calculated using 10 minutes per employee per monitoring
event, 1.8 monitoring events per year on average, 10 exposed employees
per company, resulting in an average of 3 hours year per business to
collect and review the exposure data at $60/hr.  In addition, the
analysis assumes 0.2 hours per business at $20/hr to file the exposure
records.

As indicated in Tables 3-12 and 3-13, with Option B there is a
significant economic impact to a number of small businesses with 10 to
100 employees in the NAICS subsectors 337110 (Wood kitchen cabinets and
countertops) and 337121 (Household upholstered furniture) when using
nPB-based adhesives.

The proposed regulatory Option A, which has the same requirements for
adhesives users as Option C , finds the use of nPB unacceptable as a
carrier solvent in adhesives.  All three alternatives proposed as a
substitute for nPB (methyl chloride, water, and acetone) do not have a
substantial impact on the small businesses within the industrial sectors
using nPB based adhesives.  Therefore, Options A and C will not pose a
significant adverse economic impact on a significant number of small
firms employing nPB adhesives when they switch to an alternative.  The
cost to the regulated community will vary depending on the choice of
alternative solvent.

Limitations and Uncertainties in Analysis for All nPB End Uses  TC \l2 "

Regulatory impacts on the adhesives, coatings, and inks sector

The analysis in this document is based on data and estimates provided by
industry representatives and experts.  However, there are limitations
that should be mentioned.  Points to consider are:

Characterization of the number of entities using nPB in the industrial
subsectors is based on expert opinion and industry trends in the NAICS
subsectors.

Consumption patterns and potential substitute market shares for users
that consume extremely small quantities of nPB per year have not been
incorporated into the analysis.

The estimated price for the adhesives industry used in this analysis is
near the high end of the range of prices seen in the past two years.
This will exaggerate the cost of the regulatory options.

The estimated price of a fume hood and installation costs are variable.
High-end estimates are highly conservative and therefore will likely
exaggerate the initial capital costs and the number of small businesses
experiencing a significant impact.

Users of flammable aerosol solvents may not require as extensive
fire-proofing as this analysis suggests.  The analysis implies that it
is more expensive to install fire-proofing for use of flammable aerosol
solvents than it is to switch to non-flammable aerosol solvents, such as
trans-DCE blends with HFCs or HFEs, or HCFC-225.  If this is the case,
then presumably more users would use non-flammable alternatives than
this analysis assumes.  Since industry opinion is that most users of
HCFC-141b would choose to switch to flammable aerosols because of their
lower price (3M, 2003), this may indicate that the analysis
overestimates either the amount and cost of equipment for fire-proofing
or overestimates the number of users switching to flammable aerosol
solvents.  In either case, the calculated costs for Option A, the
proposed regulatory option, would be conservatively high.

The analysis only examines the direct impacts of the regulatory options
on end users.  The analysis does not examine impacts on manufacturers of
nPB, since EPA does not directly regulate them.  Doing such an analysis
would require knowing the relative profitability of nPB compared to
other types of chemicals used in the same applications.  This
information is not available to EPA.

This report does not consider the possibility that businesses may be
able to pass on additional costs to consumers or that they may choose to
switch to an alternative type of solvent, aerosol solvent or adhesive
instead of complying with the regulatory use conditions.

This analysis does not consider the performance or aesthetic
characteristics of different types of chemicals (e.g., cleaning
performance, odor, or relative cleanliness of applying certain
adhesives).  Thus, if users avoid certain alternatives because of actual
or perceived differences in performance or aesthetic characteristics,
this preference is not captured in the analysis.

This analysis does not evaluate the degree to which cash liquidity might
affect purchasing decisions, particularly for small businesses.

4.  Total Economic Impacts of Proposed Rulemaking

The following section covers the total economic costs to implement the
proposed regulatory options within all industrial sector applications of
nPB.  The purpose of this section is to collectively assess the total
economic impacts of the different regulatory options for the rulemaking
on nPB in non-aerosol solvent cleaning, aerosol solvents and adhesives.
The total economic impacts were calculated by summing cost impacts to
small firms from section three of this report in addition to impacts to
those firms with 500 or more employees.  As previously stated, in the
case of adhesives, all users are small businesses.  Assumptions in this
analysis were stated above in Section 3.

Total economic impacts on the aerosol sector

The majority of nPB aerosol use is with small firms, those with 500
employees or less.  Of the 3130 firms using nPB in aerosol solvents,
only 1.2% of them are firms with 500+ employees.  Larger firms, with
larger profits, were assumed not to consume nPB at the levels of smaller
firms.  Product or process improvements in the more sophisticated firms
have lead to reduced rework and decreased need for transportable
cleaning solvents.  Also, these larger firms that have a higher number
of employees may view worker use of nPB as a liability (Magid, 2005).
All cost and use assumptions for nPB use in aerosol solvents are stated
in Section 3.1.

Option A finds the use of nPB unacceptable in aerosol solvent
applications.  Because the majority of firms have large annual shipment
values and most users will use only one or two hundred pounds of nPB per
year, there is a minimal impact (less than 1%) to upgrade or install new
equipment or switch to an alternative aerosol solvent.  Overall, the
range of annualized compliance costs for firms to switch to alternative
solvents and upgrade equipment, when necessary, is $1500 for the
smallest firms (1 to 4 employees) to $1.2 million per firm for those
with 2500+ employees.  The range of total annual cost for all three
industrial subsectors to employ an alternative solvent along with any
equipment upgrades is between $44.8 and $50.5 million.

Overall, with Options B or C, the range of annualized compliance cost to
a firm to monitor worker exposure and improve ventilation would be
approximately $7,000 to $2.0 million (Stratus, 2004).   Total annual
cost for all three industrial subsectors (334, 335 and 336) to employ
nPB with a use requirement ranges from $26.9 to $37.5 million.  The
range of costs depends on the cost of ventilation, ventilation
installation, personal protection equipment, exposure monitoring and
recordkeeping of exposure data.

Options B and C prohibit the use of nPB in aerosol solvents but are
similar in total societal costs to Options A and D, which allow the use
of nPB in aerosol solvents with a use restriction.   The option of
unacceptability is more certain to be protective of human health and
ensures that other, less risky options are used as required by Section
612 of the Clean Air Act.  Costs of the different regulatory options are
summarized below in Table 4-1.

The wider range of costs for Options B and C reflect the wide range of
assumptions for the cost of ventilation equipment.  Depending on whether
most users install laboratory-grade hoods at over $10,000 each, or more
basic ventilation booths at closer to $1000 each, the cost of Options B
and C may be more expensive or less expensive than Option A.  In
addition, the analysis of Options B and C does not take into account
that some users may choose to switch to alternatives.  If ventilation
costs are toward the higher end, one would expect more voluntary
switching from nPB to alternative aerosol solvents.

Table 4-1:  Total Economic Impact on the NAICS Subsectors

Using nPB-Based Aerosols by Option (in $2005)

NAICS Subsector Code	NAICS Subsector Description	Total # of Firms in
NAICS Subsector	Estimated # of Firms Using nPB in Aerosols in NAICS
Subsector	% Firms Using nPB in Aerosols	Estimated Cost for Entire
Subsector of Option A (nPB Unacceptable) 	Estimated Cost for Entire
Subsector of Options B and C (nPB Acceptable w/Use Condition)

334	Computer and Electronic Product Manufacturing	15,672	1747	11.1%	$
21.5 to 23.5 million	$ 14.6 to 25.6 million

335	Electrical Equipment, Appliance and Component Manufacturing	6,319
532	8.4%	$ 5.4 to 5.9 million	$ 3.5 to 6.2 million

336	Transportation Equipment Manufacturing	11,708	851	7.3%	$ 9.4 to 10.2
million	$ 6.2 to 11.6 million

TOTAL	33,699	3130	9.3%	$ 36.3 to 39.7 million	$ 24.3 to 43.5 million

Total economic impacts on the adhesives end use

All users of nPB adhesives are small users.  Information gathered from
industry leaders suggests that large firms, those with 500 or more
employees, had already switched away from nPB or never adopted its use
due to higher implementation costs and regulatory uncertainty.  These
assumptions are listed in Section 3.2 of this document.

EPA is proposing to find nPB unacceptable for use as a carrier solvent
in adhesives.  If this proposal were to become final, it would be
illegal to use nPB in adhesives as a substitute for ozone-depleting
substances in adhesives.  Under the proposal, users of nPB-based
adhesives must implement an alternative (methylene chloride, water, or
acetone).  All cost and use assumptions for the nPB-based adhesives
alternatives in Options A and C are stated in Section 3.2.  The annual
cost per firm to institute an alternative ranges between $9,000 and
$22,000.  An annualized total cost of alternative implementation for all
of the sectors using nPB adhesives is between $3.0 million and $6.7
million.  The high- and low-end costs differ in estimates for the
installation of required equipment.  The varying costs that led to the
low and high estimations were the varying costs of the spray booths,
spray guns, water pumps, electricity, fire equipment and explosion
proofing.

This analysis is conservative.  It assumes that no firm currently using
nPB-based adhesives have spray booths installed and all will install
spray booths to meet the recommended exposure limit, if any, for the
chosen alternative.  At least 8 users of nPB-based adhesives already
have spray booths installed, based upon information from the National
Institute for Occupational Safety and Health and the Institute for
Research and Technical Assistance (IRTA, 2000).  This is between 4% and
20% of all users of nPB-based adhesives, depending on whether one uses
ICF Consulting’s (ICF, 2001) or Poly System’s (Ruckriegal, 2002)
estimate of the use of nPB-based adhesives.

Table 4-2 on the following page shows per NAICS code the economic impact
based on the subsector’s use of alternative(s) to nPB.  It is assumed
that users in each code will use a combination of the three
alternatives.  For all the codes in the table below, 80% of the use will
transfer to water-based adhesives, 12% to methylene chloride adhesives,
and the remaining 8% to acetone adhesives.  These proportions of the
alternatives that would be adopted assume that most businesses willing
to put in the capital upgrades in flammable adhesives and methylene
chloride have already done so; additionally, the analysis assumes that
businesses avoid using methylene chloride because of requirements of the
OSHA standard.

In a few cases, users would reduce their costs by switching to a less
expensive adhesive than nPB; most notably, users in NAICS code 336360,
Motor vehicle seating and interior trim, all would reduce their costs by
switching away from nPB.  This NAICS code encompasses manufacture of
aircraft, including aircraft foam seating cushions made with spray
adhesive.  Most likely, in this application, users choose nPB-based
adhesives because they meet performance requirements for non-flammable
furnishings in aircraft while having less stringent workplace and
environmental regulatory requirements than methylene chloride.  See also
the discussion on pp.27-28 for further reasons why users are not already
using less expensive alternatives.

Table 4-2:  Estimated Impacts on Small Businesses in Adhesives
Applications by Options A and C

(Parentheses indicate a savings)

NAICS Code	Business Category	Annualized Cost of Compliance Per Small
Business Using nPB

in Options A and C

($2005)	Average Annual Value Shipments per Small Businesses in NAICS
Code

($2005)	Typical Cost Per Small nPB User in NAICS Category As a % of
Annual Sales

 	 	Methylene Chloride	Water Based	Acetone

Methylene Chloride	Water Based	Acetone

326150	Urethane and other foam products (except polystyrene)	48,000
(-)1,000	158,000	10,473,000	0.46%	(-)0.01%	1.51%

336360	 Motor vehicle seating and interior trim	(-)82,000	(-)151,000
(-)10,000	30,930,000	(-)0.26%	(-)0.49%	(+)0.03%

337110	 Wood kitchen cabinet and counter tops	49,000	11,000	139,000
1,151,000	4.26%	0.96%	12.08%

337121	Upholstered household furniture	60,000	13,000	171,000	3,588,000
1.67%	0.36%	4.77%

337124	Metal household furniture	75,000	18,000	214,000	3,142,000	2.39%
0.57%	6.81%

SECTOR AVG	30,000	(-)22,000	134,400	9,856,800	0.30%	(-)0.22%	1.36%

Although the EPA is proposing to find nPB unacceptable, the analysis
considered the costs of finding nPB-based adhesives acceptable with a
use condition.  As stated in Section 3.2, the requirement is to monitor
the exposure of users working with nPB, as well as keep records of the
exposure data for at least three years.

Table 4-3 below depicts the impact of different regulatory options:
Option B, where nPB is acceptable with a use condition, and Options A
and C, where nPB is unacceptable and has a lower cost compared to Option
B.  When compared with Options A and C, which list nPB as unacceptable,
Option B costs two or more times the other options.   This reflects both
the higher cost of nPB-based adhesives and the cost of installing and
operating ventilation systems when using nPB, compared to other
adhesives.

Table 4-3:  Total Economic Impact on the NAICS Subsectors using
nPB-Based Adhesives by Option

(Parentheses indicate a savings)

NAICS Subsector Code	NAICS Subsector Description	Total # of Firms in
NAICS Subsector	Estimated # of Firms Using nPB in Adhesives in NAICS
Subsector	% Firms Using nPB in Adhesives	Estimated Cost for Entire
Subsector of Option A or C (nPB Unacceptable)	Estimated Cost for Entire
Subsector of Option B (nPB Acceptable with Use Condition)	Difference
between Unacceptability (A or  C) and Acceptable with Use Condition (B)

326150	Urethane and other foam products (except polystyrene)	623	172
27.6%	$3.1 to $6.4 million	$11.3 to $ 15.0million	(-)$8.2 to 8.6 million

336360	 Motor vehicle seating and interior trim	384	21	5.5%	(-) $2.6 to
$2.7 million	$1.1 to $1.5 million	(-) $3.9 to 4.1 million

337110	 Wood kitchen cabinet and counter tops	9,557	27	0.3%	$540,000 to
$730,000	$1.4 to $1.9 million	(-) $0.9 to 1.2 million

337121	Upholstered household furniture	1,946	49	2.5%	$1.3 to $1.9
million	$3.2 to $4.4 million	(-) $2.0 to $2.4 million

337124	Metal household furniture	384	11	2.9%	$200,000 to $260,000	$0.9
to $1.2 million	(-) $0.7 to 0.9 million

TOTAL	12,894	280	2.2%	$2.3 to 6.7 million 	$18.0 to 24.0 million	(-)
15.7 to 17.2 million

Benefits

The primary benefits of this rule are reductions in adverse health
effects that may occur in response to reduced exposure to nPB.  Various
studies have documented that nPB has effects upon the central and
peripheral nervous system, the liver, the male and female reproductive
system, and development of the fetus (ACGIH, 2005; CERHR, 2004; ICF,
2006).

The health benefits of this rule are not quantifiable and cannot be
monetized for several reasons.  First, there is insufficient data
available on the human health effects of specific concentrations of nPB
to calculate the reduction in the number of cases of different health
effects.  Second, there is little or no data on the frequency with which
specific health effects of different severity occur among exposed
workers to calculate the number and cost of different cases.  Third,
there is only limited data on the cost of treating adverse health
effects and no other data on willingness to pay to avoid specific health
effects.

In addition, there is uncertainty around a number of factors that
contribute to the total amount of benefits, such as:

The total number of workers potentially using nPB.  As described above
in Table 2-2 on p.7, the total number of workers using this chemical is
expected to be between 3320 and 69,100 in any given year.

The number of workers using nPB in each of the major industrial sectors.
 Greater benefits would be expected when protecting workers in the
adhesives end use than in other end uses because of the higher exposure
levels observed during application of nPB-based adhesives.

 The degree to which sensitive subpopulations may be present among the
working population.

The distribution of concentrations to which users of nPB are currently
exposed.  EPA has exposure data from several health hazard evaluations
conducted on three firms using nPB-based adhesives (more than 100
samples), and from two studies for usage of nPB-based aerosols
(approximately 10 samples) (ICF, 2006; EPA, 2003).  The certainty of the
distribution for adhesives is greater than for aerosols because of the
larger number of samples.

The distribution of concentrations that would occur in response to
regulation.  In those regulatory options where nPB is unacceptable or
where a exposure limit is required, one would assume that all adverse
health of nPB would be avoided through compliance with the rule.

In the regulatory options where nPB would be unacceptable in one or more
industrial sectors, another factor to consider is potential health
effects of alternatives to nPB.  In general, the alternatives to nPB
that users would need to switch to do not cause more harm to human
health than nPB.  Other alternative solvents can be used in compliance
with their respective exposure limits (ICF, 2006).  Some chlorinated
solvents that might be used as alternatives to nPB also are suspect
carcinogens, and thus, the potential adverse health effects of these
compounds when used in accordance with existing regulations would also
need to be considered.

Conclusions

Table 6-1 below lists the number of small businesses affected by each
regulatory option for each sector or end use.  As stated previously in
the analysis, Option A, the regulatory option in the proposed rulemaking
of nPB, impacts the smallest number of small businesses by more than 1%
of a firm’s sales and impacts no small businesses by over 3% of annual
sales.

Table 6-1:  Number of Small Businesses with Impacts Greater than 1%

by Regulatory Option and nPB Use Application

Industrial Sector Application	Option A	Option B	Option C

  Aerosols	249	67-387	67-387

  Adhesives	9	25-54	9

Total	258	92-441	76-396

Table 6-2 identifies both the number of small businesses experiencing
different levels of significant impacts and the percentage of all small
businesses experiencing the impact.  None of the regulatory options
result in a significant impact on a significant number of small
entities.

Table 6-2 Small Business Impacts, by Number and Percentage of Businesses
Impacted

Regulatory Option	Total #nPB Using Firms (All)	Total #nPB Using Firms
(Small)	# Firms Economic Impact Over 1%	% of Small nPB-Using Businesses
# Firms Economic Impact Over 3%	% of Small nPB-Using Businesses

Option A	3410	3370	258	7.7%	0	0%

Option B	3410	3370	92-441	2.7-13.1%	4-9	0.2-0.3%

Option C	3410	3370	76-396	2.3-11.8%	0	0%

Table 6-3 below lists the range of total societal compliance costs for
the use of nPB in all the considered regulatory options.  Overall, in
the chosen option, Option A, the total cost to society to protect human
health from overexposure to nPB is $38.6 to $46.4 million annually.
Under the proposed Option A, approximately 8% of all firms will have an
economic impact greater than 1% and no firm will have an economic impact
greater than 3%.

Table 6-3: Total Annual Economic Cost of All Regulatory Options
($Million)

(Parentheses indicate a savings)

Industrial Sector Application	Option A	Option B	Option C

  Aerosols	$36.3 - $39.7 	$24.3 - $43.5	$24.3 - $43.5

  Adhesives	$2.3 - $6.7 	$18.0 - $24.0	$2.3 - $6.7

Total Costs	$ 38.6- $ 46.4	$42.3 - $ 67.5	$26.6  - $ 50.2

7.	References

3M, 2003.  Attachment II: HCFC Aerosol Coalition—Comments on the phase
out of HCFC’s containing aerosols.  July 31, 2003.
(EPA-HQ-OAR-2002-0064-58).

ACGIH, 2005.  The American Conference of Governmental Industrial
Hygienists (ACGIH). Documentation for Threshold Limit Value for
1-Bromopropane.  2005.

Biles, 2001.  Email from Blake Biles to Jeff Cohen on behalf of the
Brominated Solvents Consortium (BSOC).  Contains the BSOC estimates of
world-wide nPB sales for the calendar years 2000, 2001, 2002.
A-2001-07, II-A-79.

BLS, 2005.  Bureau of Labor Statistics:  Job openings and labor turnover
in 2005.  Retrieved on March 9, 2006 from
http://www.bls.gov/opub/ted/2006/feb/wk1/art03.htm.

CERHR, 2004. NTP-CERHR Expert Panel report on the reproductive and
developmental toxicity of 1-bromopropane.  Center for the Evaluation of
Risks to Human Reproduction. Repro Toxicol. Vol.18, pp.157-188.  2004.
(EPA-HQ-OAR-2002-0064-0096)

HSIA, 2001.  Margaret Sheppard notes from meeting with the Halogenated
Solvents Industry Association (HSIA).  October 17, 2001.  A-2001-07,
II-A-67.

IBSA, 2002.  The International Brominated Solvents Association.
Presentation to EPA.  September 17, 2002.  A-2001-07, II-A-60.

ICF, 2001.  ICF Consulting Memo to Margaret Sheppard.  Initial Screening
of Impacts on Small Businesses Using nPB.  August 30, 2001.  A-2001-07,
II-A-54.

ICF, 2004.  “The U.S. Solvent Cleaning Industry and the Transition to
Non Ozone Depleting Substances.  Prepared from the U.S. EPA September,
2004.  Retrieved at   HYPERLINK
"http://www.epa.gov/ozone/snap/solvents/EPASolventMarketReport.pdf"
http://www.epa.gov/ozone/snap/solvents/EPASolventMarketReport.pdf .

ICF, 2005.  ICF Summary of Cal/OSHA Airborne Contaminants Advisory
Committee Meeting.  May 18, 2005.  Available in docket
EPA-HQ-OAR-2002-0064 at   HYPERLINK "http://www.regulations.gov"
www.regulations.gov . (Attachment # 14 to 11-17-2006 email from M.
Sheppard, EPA to N. Beck, OMB with requested documents).

ICF, 2006.  nPB Risk Screen for use in solvent cleaning, aerosol
solvents and adhesives.  Available in docket EPA-HQ-OAR-2002-0064 at
www.regulations.gov.

IRTA, 2000.  Institute for Research and Technical Assistance (IRTA)
study on the

Cost and Feasibility of Alternative Adhesives.  June 2000.  A-2001-07,
II-D-70

IRTA, 2001.  Personal communication with K. Wolf, and M. Morris,
Institute for Research and Technical Assistance (IRTA).  November 16,
2001.

Kenyon, 2001. Email to W. Kenyon from RRage1 Re: Questions from B.
Kenyon about nPB market. August 28, 2001.  A-2001-07, II-A-72.

Lake City Army Ammunition Plant, 2003.  Submission by Lake City Army
Ammunition Plant providing data to support approval for limited use of
nPB in coating applications.   Submitted June 3, 2003.
(EPA-HQ-OAR-2002-0064-0029).

Magid, 2005.  Dr. Hillel Magid conversation with Margaret Sheppard.
November 16, 2005.  .Available in docket EPA-HQ-OAR-2002-0064-0208 at
www.regulations.gov.

McCulloch, 2001.  April 16, 2001 revised draft, “Projecting Future
Solvent Demand” from A. McCulloch, University of Bristol and Marbury
Technical Consulting with cover letter to EPA from Enviro Tech
International.  A-2001-07, II-A-66.

NIOSH, 2000a.  Letter from Dept. of Health and Human Services to Marx
Industries, Inc., February 1, 2000.  Re: results of nPB exposure
assessment survey conducted Nov. 16-17, 1999;   A-2001-07, II-D-7   Also
see  NIOSH Health Hazard Evaluation Report: HETA #99-0260-2906; Marx
Industries, Inc.; Sawmills, NC.  National Institute for Occupational
Safety and Health.  June 2003.  Available online at   HYPERLINK
"http://www.cdc.gov/niosh/hhe/reports/pdfs/1999-0260-2906.pdf"
http://www.cdc.gov/niosh/hhe/reports/pdfs/1999-0260-2906.pdf .

NIOSH, 2000b.  Letter from Dept. of Health and Human Services to Custom
Products, Inc., December 21, 2000.  Re: results of nPB exposure
assessment survey conducted Nov. 16, 2000.  A-2001-07, II-D-8.  Also see
NIOSH Health Hazard Evaluation Report: HETA # 98-0153-2883; Custom
Products, Inc.; Mooresville, NC.  National Institute for Occupational
Safety and Health.  November 2002.  Available online at   HYPERLINK
"http://www.cdc.gov/niosh/hhe/reports/pdfs/1998-0153-2883.pdf"
http://www.cdc.gov/niosh/hhe/reports/pdfs/1998-0153-2883.pdf

NIOSH, 2002.  NIOSH Health Hazard Evaluation Report:
HETA#2002-0410-2891, STN Cushion Company, Thomasville, NC, August 2002.
A-2001-07, II-A-31.  Also available online at   HYPERLINK
"http://www.cdc.gov/niosh/hhe/reports/pdfs/2000-0410-2891.pdf"
http://www.cdc.gov/niosh/hhe/reports/pdfs/2000-0410-2891.pdf .

OSHA, 1996a.  The Occupational Safety and Health Administration (OSHA).
Final Economic and Regulatory Flexibility Analysis for OSHA’s Standard
for Occupational Exposure to Methylene Chloride.  January 7, 1996.
A-2001-07, II-A-44

OSHA, 1996b.  The Occupational Safety and Health Administration (OSHA).
Spray finishing using flammables and combustible materials.  (29 CFR
1910.107).  March 7, 1996.  Retrieved from   HYPERLINK
"http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS
&p_id=9753"
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&
p_id=9753 .

PEI, 1990a.  Occupational Exposure and Environmental Release Data for
Chlorofluorocarbons (CFCs) and their Substitutes, Revised Draft.  PEI
Associates for US EPA/ OTS (Contract 68-D8-0112).  November 19, 1990. p.
7-7.

PEI, 1990b.  Occupational Exposure, Environmental Release, and Control
Analysis for Aqueous Cleaning Substitutes for 1,1,1-Trichloroethane and
CFC-113 for Cleaning of Electronic or Metal objects, Revised Draft.  PEI
Associates for US EPA/ OTS (Contract 68-D8-0112).  November 16, 1990. p.
3-8.

Raymond, 2005.  Email to Margaret Sheppard from Dr. Larry Raymond
regarding the health impacts and subsequent treatment costs of nPB
impairment.   November 2, 2005.  Available in docket
EPA-HQ-OAR-2002-0064-0178 at www.regulations.gov.

Ruckriegel, 2002.  “Information Supporting n-Propyl Bromide as a
Solvent for Use in Industrial Manufacturing Adhesives.” M. Ruckriegel
of Poly Systems.  November 11, 2002. (A-2001-07, II-D-63)

Seilheimer, 2001.   Telephone log of call between Margaret Sheppard,
EPA, and Bob Seilheimer, Imperial Adhesives. April 4, 2001.  A-2001-07,
II-A-66.

Stratus, 2004.  “Screening Analysis to Assess Potential Impacts on
Small Businesses in Regulation of n-Propyl Bromide in Adhesives and
Aerosol Solvent Cleaning” prepared for Margaret Sheppard, U.S. EPA.
August 4, 2004.  Available in docket EPA-HQ-OAR-2002-0064 at
www.regulations.gov.

Swanson, M.B., J.R. Geibig, and K.E. Kelly.  2002.  Alternative
Adhesives Technologies: Foam Furniture and Bedding Industries, Final
Draft.  Volume 2: Risk Screening and Comparison.  Chapter 4: Exposure
Assessment.  Produced by the University of Tennessee Center for Clean
Products and Clean Technologies under a grant from EPA’s Design for
the Environment Branch, Office of Pollution and Prevention and Toxics.
June 2002.  Available online at   HYPERLINK
"http://eerc.ra.utk.edu/ccpct/aap1.html"
http://eerc.ra.utk.edu/ccpct/aap1.html .

Tattersall, 2005.  Conversation between Margaret Sheppard, EPA, and Tom
Tattersal of MicroCare Corp.  June 29, 2005.  .Available in docket
EPA-HQ-OAR-2002-0064-0191 at   HYPERLINK "http://www.regulations.gov"
www.regulations.gov .

TEAP, 2001.  UNEP (United Nations Environmental Programme):  Geographic
Market Potential and Estimated Emissions of n-Propyl Bromide. Report by
the Technology and Economic Assessment Panel (TEAP) Task Force of the
Solvents, Coatings and Adhesives Technical Options Committee (STOC).
April, 2001.  A-2001-07, II-A-21.

TEAP, 2006.  UNEP (United Nations Environmental Programme):  Report of
the Technology and Economic Assessment Panel.  Progress Report.  May
2006.  Available in docket EPA-HQ-OAR-2002-0064 at www.regulations.gov.

Thomas, 2001.  Margaret Sheppard conversation with A. Thomas of Franklin
International.  A-2001-07, II-A-64.

U.S. Census Bureau, 2005.  General Summary of 2002 Economic Census of
Manufacturing in the United States.  Retrieved June, 2005 from
http://www.census.gov/econ/census02/data/us/US000_31.HTM.

U.S. EPA, 2003a.  Summary of Data on Workplace Exposure to n-Propyl
Bromide, May 21, 2003.  EPA’s summary of exposure data from nPB
suppliers and NIOSH. (EPA-HQ-OAR-2002-0064-0015 and
EPA-HQ-OAR-2002-0064-0016).

U.S. EPA, 2003b.  Spreadsheet Analysis of Regulatory Options in nPB
Proposed Rule for the Adhesives End Use.  A-2001-07, II-A-56.

Walnut, 2001.  Notes on October 1, 2001 conference call between Margaret
Sheppard, EPA/SNAP program, and Fred Walnut, John Poinecka, and Ron
Sendeling, TACC Adhesives.  A-2001-07, II-A-73.

Williams, 2005.  Margaret Sheppard conversation with Ed Williams,
Technical Manager, LPS Laboratories.  November 3, 2005.  Available in
docket EPA-HQ-OAR-2002-0064-0198 at www.regulations.gov.

Wisconsin, 2000.  “Fume hood Performance Test and Life Cycle Cost
Analysis.”  Prepared by the State of Wisconsin for the University of
Wisconsin Milwaukee.  February 21, 2000.  Available in docket
EPA-HQ-OAR-2002-0064 at   HYPERLINK "http://www.regulations.gov"
www.regulations.gov  or online at
http://www.lab-crafters.com/UWM-HBASC5-SUM.pdf.

Appendix I:  Abbreviation List

American Conference of Governmental Industrial Hygienists (ACGIH)

Bureau of Labor Statistics (BLS)

Environmental Protection Agency (EPA)

Federal Aviation Administration (FAA)

Halogenated Solvents Industry Association (HSIA)

Heating, ventilation and air conditioning (HVAC)

Hydrochlorofluorocarbon-225ca and cb (HCFC-225)

ICF Consulting (ICF)

Institute for Research and Technical Assistance (IRTA)

International Brominated Solvents Association (IBSA)

National Institute of Occupational Safety and Health (NIOSH)

North American Industrial Classification System (NAICS)

n-propyl bromide (nPB)

Personal protective equipment (PPE)

Regulatory Flexibility Act (RFA)

Regulatory Impact Analysis (RIA)

Significant Impact on a Substantial Number of Small Entities (SISNOSE)

Significant New Alternatives Policy (SNAP)

Small Business Regulatory Enforcement Fairness Act (SBREFA)

Occupational Safety and Health Administration (OSHA)

Trans-dichloroethylene (trans-DCE)

 Anecdotal evidence indicates that at some companies implementing
water-based adhesives, workers will stack new-sprayed foam pieces to dry
while working on other pieces, avoiding any waiting or process
down-time.  (IRTA, 2001)

 PAGE

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Analysis of Economic Impacts of Proposed nPB Rule for Aerosols and
Adhesives 2-7-2007

 PAGE

August 1, 2005 DRAFT	DO NOT QUOTE OR CITED

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