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Questions and Answers on Alternative Adhesives, Coatings and Inks

This fact sheet provides an overview of regulations governing production, use and replacement of three ozone-depleting solvents, CFC-113, methyl chloroform (1,1,1-trichloroethane, TCA or 1,1,1), and HCFC-141b (1,1-dichloro-1-fluoroethane), under Title VI of the Clean Air Act. This fact sheet also provides information on how to find substitutes. If you have questions beyond those in this fact sheet, or would like paper copies of the lists, please call the Stratospheric Ozone Protection Hotline toll-free at 1 (800) 296-1996.

Lists of Substitutes

Questions and Answers About EPA's SNAP Program and the USE of CFC-113, TCA, HCFC-141b and their Substitutes as Carrier Solvents in Adhesives, Coatings and Inks

A. SNAP review process

  1. What does "SNAP" stand for and what is involved in SNAP program reviews?
  2. Where can I find information on which substitutes have been listed as acceptable or unacceptable under SNAP?
  3. I want to get SNAP approval for a compound or a process used as a carrier solvent in an adhesive, a coating or an ink. What should I do?

B. Scope of SNAP

  1. Which solvent uses are subject to SNAP review and requirements?
  2. How does the SNAP program regulate carrier solvents used in adhesives, coatings and inks?

C. SNAP Status of Different Substitutes

  1. Which substitutes for CFC-113, TCA or HCFC-141b have already been listed as acceptable under the SNAP program?
  2. What’s going on with the SNAP review of nPB?

A. SNAP review process

  1. What does "SNAP" stand for and what is involved in SNAP program reviews?
    SNAP is EPA's Significant New Alternatives Policy program. The SNAP program implements Section 612 of the Clean Air Act. Under SNAP, EPA evaluates substitutes that companies propose to use as replacements for ozone-depleting substances like CFC-113, TCA, and HCFC-141b, in order to determine that the substitutes won't cause greater damage overall to human health or the environment than either the ozone depleters they are replacing or than other available substitutes. EPA generally reviews four key items when evaluating each proposed substitute:
    • ozone-depleting potential,
    • global-warming potential,
    • toxicity, and
    • flammability.

    Based on this evaluation, EPA then decides whether unrestricted use of a substitute should be allowed, certain limits need to be placed on use, or use should be prohibited altogether.

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  2. Where can I find information on which substitutes have been listed as acceptable or unacceptable under SNAP?
    EPA published its first set of SNAP decisions on March 18, 1994 in the Federal Register (59 FR 13044). Since then, EPA has issued numerous updates. You can view the lists at www.epa.gov/ozone/snap/lists/.

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  3. I want to get SNAP approval for a compound or a process used as a carrier solvent in an adhesive, a coating or an ink. What should I do?
    • You should first determine if the specific application you have in mind falls within the scope of the industrial sectors that are subject to SNAP. Your proposal may involve a compound that does not substitute for an ozone-depleter, or an application where ozone depleters have played only a minor role. In these cases, SNAP may not apply.
    • Next, if you think that SNAP applies, you should check the lists of substitutes under SNAP for the appropriate sector. If your substitute is already on an existing list as acceptable, acceptable-with-restrictions, or unacceptable substitute, EPA does not require further review. Please be aware that in the solvents sectors, EPA does not certify individual companies' products. Instead, the acceptability decisions are for specific compounds (e.g., trichloroethylene), for classes of substitute compounds (e.g., oxygenated organic solvents), or for alternative technologies (e.g., hot-melt adhesives).
    • If your substitute is not on a list or if you are not sure if SNAP applies, you should call the SNAP solvents sector analyst at 202-343-9210 to determine whether your product is covered by a broad category or has otherwise been addressed by the SNAP program.
    • If you and the analyst together decide that your product is new and has not been reviewed, you must submit it for EPA review using the SNAP submission form. You can get the form by calling the hotline or viewing www.epa.gov/ozone/snap/submit/index.html.

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B. Scope of SNAP

  1. Which solvent uses are subject to SNAP review and requirements?
    EPA currently only reviews substitutes for CFC-113, TCA and HCFC-141b in three industrial sectors:
    • non-aerosol solvent cleaning,
    • aerosols (aerosol solvents), and
    • carrier solvents used in adhesives, coatings and inks, because it was in these sectors that use of CFC-113 and TCA were most widespread. EPA chose not to subject to SNAP review industrial sectors that historically used CFC-113, TCA and HCFC-141b on a more limited basis, such as hydraulic system testing.

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  2. How does the SNAP program regulate carrier solvents used in adhesives, coatings and inks?
    CFC-113 has not been used on a widespread basis in the formulations of adhesives, coatings, or inks. EPA’s SNAP program in this sector is aimed at reviewing substitutes for TCA. In the adhesives sector, the SNAP program has historically focused on the following applications, which all formerly used TCA widely:
    • laminate adhesives,
    • flexible foam adhesives,
    • hardwood floor adhesives,
    • metal-to-rubber adhesives, and
    • tire patch adhesives.

    The preamble language to the original SNAP rule also explicitly lists several subsectors that once relied on TCA, but as of the date of that March, 1994 rule, had not used TCA for some time. EPA historically has not subjected these applications to SNAP review:
    • pressure-sensitive adhesives such as tapes and labels,
    • flexible packaging adhesives,
    • aerosol-propelled adhesives, and
    • shoe repair glues and other consumer adhesives.

    Under the SNAP program, coatings are “durable and decorative coatings” such as paints or wood stains. In the coatings and inks end uses, the SNAP program has historically focused on the following applications, which all formerly used TCA widely:
    • flexographic and rotogravure printing inks,
    • wood stains,
    • metal coatings, and
    • aerospace coatings.

    Lubricant and medical coatings, however, are not currently regulated under SNAP. As in adhesives, it is possible that the Agency may expand the scope of SNAP to cover an application that it has not historically regulated under SNAP, if EPA determines that the use of ozone depleters or their substitutes in that application poses a significant environmental or health risk.

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C. SNAP Status of Different Substitutes

  1. Which substitutes for CFC-113, TCA or HCFC-141b have already been listed as acceptable under the SNAP program?
    EPA has already listed as acceptable many carrier solvents in adhesives, coatings, and inks substitutes for CFC-113 and TCA, including:
    • Non-ozone-depleting chlorinated solvents (methylene chloride, trichloroethylene, perchloroethylene)
    • Organic solvents used without water (terpenes, petroleum hydrocarbons, and oxygenated organic solvents such as esters, ethers, alcohols, etc.)
    • Trans-1,2-dichloroethylene
    • Hydrofluoroether (HFE) 7100 and 7200
    • Monochlorotoluenes and benzotrifluorides, subject to a 50 ppm workplace standard for monochloro-toluenes and a 100 ppm standard for benzotrifluoride. This includes parachlorobenzotrifluoride (PCBTF).
    • Petroleum Hydrocarbons
    • Additional technologies that serve as alternatives such as hot melt adhesives and powder coatings

    Solvents that have been listed as unacceptable substitutes for CFC-113 and TCA are:
    • chlorobromomethane (CBM).

    To ensure that you receive the most recent and comprehensive information, you should always check www.epa.gov/ozone/snap/lists/index.html#adcoink. The web site is updated more frequently than this fact sheet is updated.

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    2. What’s going on with the SNAP review of nPB?
    EPA has received petitions to add n-propyl bromide (nPB) to the list of
    acceptable alternatives for the CFC-113, TCA and HCFC-141b in the
    solvent sector for metal, precision, and electronics cleaning, as well
    as in aerosol and adhesive applications.

    EPA issued a proposed rule on June 3, 2003 . EPA is proposing to list n-propyl bromide (nPB) as an acceptable substitute for ozone-depleting substances (ODSs), subject to use conditions, in the solvent cleaning sector and aerosol solvents and adhesive end uses. While we find that nPB has a short atmospheric lifetime and low ozone depletion potential when emitted from locations in the continental U.S., the Agency cautions that significant use of nPB closer to the equator poses significant risks to the stratospheric ozone layer. Further, if workplace exposure to nPB is poorly controlled, it may increase health risks to workers. In the interim, until the Occupational Safety and Health Administration (OSHA) develops a mandatory workplace exposure limit under the Occupational Safety and Health Act, the Agency recommends that users of nPB adhere to an acceptable exposure limit of 25 parts per million (ppm) over an eight-hour time-weighted average.

    EPA is proposing to list nPB as an acceptable substitute for chlorofluorocarbon (CFC)-113, hydrochlorofluorocarbon (HCFC)-141b, and methyl chloroform when used in aerosol solvent and adhesive end uses, subject to the condition that nPB used in these end uses not contain more than 0.05% isopropyl bromide by weight before adding stabilizers or other chemicals. We are also proposing to list nPB as an acceptable substitute for CFC-113 and methyl chloroform in general metals cleaning, electronics cleaning, and precision cleaning, subject to the condition that nPB used in these end uses not contain more than 0.05% isopropyl bromide by weight before adding stabilizers or other chemicals.

    The public comment period on this proposal is from June 3, 2003 through August 4, 2003. The proposed rule gives instructions on how to submit your comments.

    After considering the public comments, EPA will prepare a final rule in consultation with other parts of the government. The timing of the final rule will depend on the number and complexity of the issues raised in public comments. It usually takes EPA a year or more to finalize a rule after issuing a proposal.



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