All,

I just noticed this section of the EPA’s proposed rule for 1-bromopropane (https://www.govinfo.gov/content/pkg/FR-2024-08-08/pdf/2024-17204.pdf):

The Agency understands that certain engineering controls can reduce exposures to people inside the workplace but may lead to increased ventilation of 1–BP outside of the workplace, thereby increasing risks to people in fenceline communities of adverse health effects from exposures to 1–BP in ambient air. Therefore, EPA is proposing to prohibit increased releases of 1–BP to outdoor air associated with the implementation of the WCPP. This proposed requirement is intended to avoid unintended increases in exposures to people from 1–BP emissions to ambient air. The proposed rule would require owners and operators to attest in their WCPP exposure control plan that engineering controls selected do not increase emissions of 1–BP to ambient air outside of the workplace and document in their exposure control plan whether additional equipment was installed to capture emissions of 1–BP to ambient air. EPA requests comment on how this proposed requirement may impact the availability, feasibility, or cost of engineering controls as a means to reduce workplace exposures to or below the proposed ECEL.

This would be quite the precedent if it’s how EPA is approaching engineering controls when it proposes its formaldehyde rule. Are any of you planning to submit a comment that addresses this aspect of the rule?

Chris

________________________________

Christopher M. Kolodziej, Ph.D.
Chemical Hygiene Officer

UCLA Environment, Health & Safety | Chemical Safety

Phone: (310) 794-5013

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