A
summary of the regulatory and health issues surrounding the use of n-propyl
bromide in foam-fabricating adhesives
Adhesive solvents solvate and act as a carrier for adhesive
resins (solids), carrying them to the materials to be bonded. Once the adhesive
is applied, the solvent evaporates, leaving only the solids behind to produce a
lasting bond. Solvents are also
instrumental in providing adhesion to materials. This is achieved by lowering
the adhesive’s surface tension or by solvating any contaminants that are on the
surface of the substrate, such as oils or mold-release compounds. This action
allows the adhesive to wet into the surface of the material to be bonded, an
action fundamental in creating the bond.
Solvents also influence adhesives’ wet tack and open time. It is important that
a solvent evaporate quickly, so as to provide the quick strength (wet tack)
that is needed for the fast handling of bonded-foam parts. However, if the
solvent evaporates too quickly, the adhesive will dry and be tack free before a
larger part can be assembled. It is critical that the adhesive have a long
working time in order for the spray operator to assemble a variety of parts. An
adhesive with the proper working window allows a sprayer to fabricate large and
small parts, as well as high-tension parts or simple parts that have little
“spring open” force.
Regulatory Status of NPB
The 1990 Montreal Protocol of Substances that Deplete the
Ozone Layer banned the production of methyl chloroform (also known as 1,1,1
trichloroethane) by January 1, 1996.1 Methyl chloroform
was a non-flammable and non-toxic solvent for use in foam-fabricating spray
adhesives. Eliminating methyl chloroform created an immediate need for
alternatives. One solution was methylene chloride, or dichloromethane. This
solvent was also non-flammable, but was considered to be a suspected
carcinogen. As such, the Occupational Safety and Health Administration (OSHA)
set a time-weighted average (TWA) exposure limit of 25 parts per million (ppm).
Installing air-handling equipment capable of maintaining an airborne TWA
concentration of 25 ppm or below was very difficult and became impractical.
Water-based and hot-melt adhesives were used in many spray applications, but
many foam fabricators were not satisfied with their performance. A
non-flammable, non-toxic, fast-drying and inexpensive solvent was needed, as
well as a good solvent for the adhesive resins used to formulate spray
adhesives.
In the late 1990s, n-propyl bromide was introduced in adhesive formulations as
such a material. N-propyl bromide (also known as normal propyl bromide, NPB,
1-bromopropane and 1-BP) was non-flammable and fast-drying, and worked well in
foam-fabricating formulations. These adhesives quickly gained popularity and
were successful in replacing methylene chloride, as well as water-based and
hot-melt formulations. NPB is not considered a hazardous air pollutant (HAP) by
the EPA, nor is it a hazardous waste under the Resource Conservation and
Recovery Act (RCRA).2 NPB is a volatile organic compound (VOC), therefore its
use is controlled under state and local regulations implementing federal clean-air
requirements at 40 CFR Part 51.2 NPB was submitted to
the EPA’s Significant New Alternatives Policy Program (SNAP) in hopes that it
would be approved for use as a replacement for ozone-depleting methyl
chloroform. (The SNAP program was developed by the EPA after it was given the
authority by the Clean Air Act in Section 612 to develop a program for
evaluating alternatives to ozone-depleting substances. Under this program, any
materials to be used as replacements for known ozone depletors are either
accepted or are deemed unacceptable. It is unlawful to use a material in place
of an ozone depletor if it is deemed unacceptable by the SNAP program.2)
Foam fabricators were allowed to use NPB-based adhesives while waiting for approval
under the SNAP program. As of the June 3, 2003, proposed rule, the only use
condition that the EPA proposed for use in adhesives was that the NPB does not
contain any more than 0.05% isopropyl bromide (2-bromopropane) by weight before
adding stabilizers or other chemicals.2 In addition, the
EPA proposed that the TWA exposure level be kept below 25 ppm; however, the EPA
expected users to defer to any permissible exposure limits ultimately
established by OSHA. OSHA is studying the issue and has yet to outline a TWA
exposure limit for NPB.
NPB Health Concerns
As foam fabricators began using NPB-based adhesives, health
issues began to arise, particularly in the area of neurotoxicity (causing
damage to nerves). A request was made on March 17, 1998, by the North Carolina
Department of Labor (NCDOL) for the National Institute for Occupational Safety
and Health (NIOSH) to perform a health-hazard evaluation (HHE) at a North Carolina foam seat
cushion company. Adhesive spray operators at this factory reported in medical
surveys that they had a headache at least once per week, painful tingling in
hands or feet, a tremor, and the sensation of being drunk when not drinking.3
The initial TWA exposures to NPB were measured to be 60.0-381.2 ppm.3
After installation of new spray booths, TWA exposures were 1.2-58.0 ppm.3
In April 1999, the NCDOL responded to reports that four employees of a North
Carolina foam-fabricating company had been treated at a local hospital for
neurological symptoms of an unclear cause.4 The four had
previously been hospitalized in March 1999 for complaints of lightheadedness
and/or dizziness, lower extremity weakness, varying degrees of difficulty
standing or walking, and varying degrees of bilateral lower extremity numbness,
as well as abnormal sensations such as burning, prickling, or tingling in the
lower extremities.4 NCDOL issued a request for a
health-hazard evaluation to NIOSH, which found the initial NPB TWA exposures of
18.1-253.9 ppm.4
On August 28, 2000, employees of another North Carolina foam-fabricating
company made a confidential request to NIOSH for an HHE.5
Two sprayers had been admitted to the emergency room of a local hospital in
June 2000. One of the sprayers had been using NPB adhesive for about one year;
the other had been using it for about six months.6 The
first sprayer developed a sore throat, difficulty swallowing, stumbling,
incontinence of urination, numbness in the perineum, and numbness with a
burning sensation in the legs, thighs, hips, and lower back, and ultimately
became unable to stand up by herself.6 The second
sprayer developed a staggering gait, urinary incontinence, slurred speech,
difficulty swallowing, and tingling, burning or numbness in the hands, legs,
lower back, hips, and perineum.6 Air sampling was
performed by an independent party before the initial NIOSH visit. At the end of
October 2000, this party determined the TWA exposure to NPB to be in the range
of 60-261 ppm, after the ventilation had already been improved.6
During the initial NIOSH visit in mid-November 2000, the TWA exposure to NPB
was found to be in the range of 41.3-143 ppm.5
In February 2003, The Occupational Safety and Health Division of The Utah Labor
Commission performed a site visit at a foam-cushion fabricator in Utah.7
Several sprayers had been admitted to the emergency room with many of the
symptoms listed in the above cases. This case, however, provided some
interesting follow-up information. Three of the most severely affected sprayers
were followed up as outpatients for two years. The most affected sprayer was a
29-year-old female whose ability to walk was so impaired that she needed a cane
even two years after her initial examination in the emergency room.8
This sprayer and another female, age 43, were still not able to work two years
after their initial visits to the ER.8 A male sprayer,
46, had originally visited the ER with mild-to-moderate lower extremity
weakness, difficulty walking and tingling, burning or numbness in the lower
extremities. At his two-year follow-up evaluation, he reported experiencing
headaches and mild weakness in his lower extremities with debilitating pain.8
The TWA exposure to NPB during the Utah OSHD inspection was found to be in the
range of 91.8-126.7 ppm.7
Neurotoxicity is not the only health concern regarding NPB. The Center for the Evaluation
of Risks to Human Reproduction (CERHR) issued a report in October 2003 that
stated, “There is sufficient evidence to conclude that inhaled 1-BP causes
reproductive toxicity in male and female rats...These results are assumed
relevant for human hazard assessment. The human data on potential effects of
1-BP are too limited in content to conclude that 1-BP is a human reproductive
or developmental toxicant.”9 Based on this conclusion,
the Office of Environmental Health Hazard Assessment (OEHHA) listed NPB on
Proposition 65 effective December 7, 2004.10 Therefore,
NPB is listed as a chemical known by the State of California to cause
reproductive toxicity.
Conclusion
The EPA has issued a new proposed rule under the SNAP
program. This notice, in the Federal Register, “proposes
to list NPB as an unacceptable substitute for methyl chloroform,
chlorofluorocarbon (CFC)-113, and hydrochlorofluorocarbon (HCFC)-141b when used
in adhesives or in aerosol solvents because NPB in these end uses poses
unacceptable risks to human health when compared with other substitutes that
are available.”11 As stated in the new proposed rule,
this action to eliminate NPB in adhesives has been taken because of the rising
health issues that occur with the elevated exposure levels that are typically
seen in adhesive spraying operations.
As previously mentioned, OSHA has yet to issue an exposure limit for NPB in the
workplace. The American Conference of Governmental Industrial Hygienists
(ACGIH) set a threshold limit value (TLV) of 10 ppm for NPB; the EPA had
proposed an exposure level of 25 ppm. Although the EPA and ACGIH exposure
values are highly respected values that employers can target for protecting
their employees’ health and safety, the ultimate authority of enforcement is
with OSHA.
So where does this leave suppliers and manufacturers in the foam-fabricating
industry who must answer to employees, the government, and the bottom line?
Consider this thought from the Occupational Safety and Health Act of 1970,
Public Law 91-596, sec. 5(a)(1): "OSHA requires an employer to furnish
employees a place of employment that is free from recognized hazards that are
causing or are likely to cause death or serious physical harm." Thus,
employers should understand that not all hazardous chemicals have specific OSHA
exposure limits. An employer is still required by OSHA to protect their
employees from hazards, even in the absence of an OSHA exposure limit.5
So, with the increasing threat of employee lawsuits and the pending rejection
by the EPA, it would behoove any user of NPB-based adhesive to switch to an
alternate as soon as possible.
For more information, contact Steven E. Adams, Worthen Industries,
Upaco Adhesives Division, 4105 Castlewood Road, Richmond, VA 23234; phone (804)
275-9231, ext 113; or e-mail sadams@upaco-richmond.com.
Stephen E.Adams Steven E. Adams is a representative of Worthen Industries, Upaco Adhesives Division, Richmond, VA.
References 1. ozone.unep.org/pdfs/Montreal-Protocol2000.pdf , p. 13. 2. U.S. EPA (2003) “Protection of
Stratospheric Ozone: Listing of Substitutes for Ozone-Depleting Substances-
n-Propyl Bromide; Proposed Rule.” Federal Register, Part
III, 40 CFR Part 82, Vol. 68, No. 106, June 3, 2003, pp. 33284-33316. 3. Reh,
C.; Mortimer, V.; Nemhauser, J.; Trout, D. (2002) NIOSH Health Hazard
Evaluation Report HETA #98-0153-2882. Custom Products Inc., Mooresville, NC. 4. Harney, J.; Nemhauser, J.; Reh, C.; Trout, D.; Schrader, S.;
(2003) NIOSH Health Hazard Evaluation Report HETA #99-0260-2906.
Marx Industries Inc., Sawmills, NC. 5. Harney,
J.; Hess, J.; Reh, C.; Trout, D. (2002) NIOSH Health Hazard
Evaluation Report HETA #2000-0410-2891. STN Cushion Co., Thomasville, NC. 6. Ichihara, G.; Miller, J.;
Ziolkokwska, A.; Itohara, S.; Takeuchi, Y. (2002) “Neurological Disorders in
Three Workers Exposed to 1-Bromopropane.” Journal of Occupational
Health. 44, 1-7.
7. Utah Labor Commission, Occupational Safety and Health
Division, (2003) Inspection #305400616. Marx Industries
Inc., Salt Lake City, UT. 8. Majersik, J.; Caravati, E.; Steffens, J. (2007) “Severe
Neurotoxicity Associated with Exposure to the Solvent 1-Bromopropane (N-Propyl
Bromide).” Clinical Toxicology. 45, 270-276. 9. National Toxicology Program,
U.S. Dept. of
Health and Human Services, Center for the Evaluation of Risks to Human
Reproduction. (2003) “NTP-CERHR Monograph on the Potential Human Reproductive
and Developmental Effects of 1-Bromopropane.” NIH Publication
No.04-4479, Appendix II, p. 47. 10. www.oehha.ca.gov/prop65/prop65_list/1bpnote.html 11. U.S. EPA (2007) “Protection of
Stratospheric Ozone: Listing of Substitutes for Ozone-Depleting Substances-
n-Propyl Bromide in Adhesives, Coatings, and Aerosols; Proposed Rule.” Federal
Register, 40 CFR Part 82, Vol. 72, No. 103, May 30, 2007, pp.
30168-30207.
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