From:	Doug Raymond [raymonds4@me.com]
Sent:	Wednesday, September 21, 2011 5:31 PM
To:	Pettingill Gene
Cc:	'djraymond@reg-resources.com'; Dnrecawm Aqmfoia1 (MailBox 
Resources); Alex Ryan-Bond
Subject:	Re: OTC Solvent Degreaser Model Rule - Small Quantity Usage 
Exemption Request

Gene,

Sorry for the delay.  Here are answers to your questions.  I will be on the call tomorrow.  If you 
need anything earlier call at 440-474-4999.
(1)    It is a 5-gallon bucket but what is the volume of solvent held in the bucket? 
 The 5 gallon sizes are in a bucket physically larger than 5-gallons in size. 
 The quantity of liquid inside the bucket is 5 gallons.
(2)    Is the solvent in the bucket when sold?  Yes, the solvent system is in the 
bucket when sold to the consumer.
(3)    What solvent is included in the bucket or sold with the bucket, so we can 
judge emissions impact.  The most volatile solvent can be mineral spirits, 
although other formulae have less volatile solvents.
(4)    Presume there are accompanying instructions and heating is not 
recommended. Yes, there are instructions included on each label with 
statements about flammability, etc that caution against heating and state 
that the products should be used in a closed container.
(5)    Do the directions give adequate instructions as to venting vapors?  The 
instructions caution about inhaling vapors and state that the product 
should be used in a closed container.
(6)    Do the directions give adequate instructions as to disposal of spent 
solvent?  The container specifically states that the consumer should 
dispose of material in accordance with local regulations.
(7)    Where can I go in Delaware (what store) to see one?  Products are sold in 
major automotive chains such as Advance Auto, Autozone, O'Reilly's, 
NAPA etc.  A local dealer would be Fisher Auto Parts in Milford Delaware.
(8)    Is your client the only seller in the business? Is the volume sold likely to be 
greater than 6000 units per year. Yes there are more than one 
manufacturer of parts cleaning solvents for small containers, in addition 
some containers are smaller, about a gallon in size.  I cannot speak to the 
total nationwide volume of all manufacturers.
(9)    Assume your client is a re-seller, who is the manufacturer? Does he have a 
Website address?  Two manufacturers websites are 
www.crcindustries.com and www.rscbrands.com.

Thanks for the review of this issue.

Doug Raymond
Raymond Regulatory Resources (3R), LLC
440-474-4999


On Sep 14, 2011, at 11:57 AM, Pettingill Gene (DNREC) wrote:
 

Doug,
 
                We plan to discuss your small quantity exemption request in a work group conference call later 
in the month. In the meantime the team is considering your request based upon a discussion the team 
had today.
 
       We know you are talking about say 6000 5-gal units sold per year.  We would like to know;
        
(1)    It is a 5-gallon bucket but what is the volume of solvent held in the bucket?
(2)    Is the solvent in the bucket when sold?
(3)    What solvent is included in the bucket or sold with the bucket, so we can judge emissions 
impact.
(4)    Presume there are accompanying instructions and heating is not recommended.
(5)    Do the directions give adequate instructions as to venting vapors?
(6)    Do the directions give adequate instructions as to disposal of spent solvent?
(7)    Where can I go in Delaware (what store) to see one?
(8)    Is your client the only seller in the business? Is the volume sold likely to be greater than 
6000 units per year.
(9)    Assume your client is a re-seller, who is the manufacturer? Does he have a Website 
address?
 
Know this is a lot of detail and I can’t promise getting it will guarantee the exemption, but we 
kinda would like to have a good feel for what we would recommend.
 
If it doesn’t make it into the model rule, you would always have the option to request the 
exemption from each state in the OTC when they do their individual rules.
 
                                                                                                                                gene