Document bKQo8MxV5X2zNpzVmJwga7Y6

Identification and Comparison of Solvents and Paint Removers as Alternatives to Methylene Chloride in Paint Removal Applications R&D, W. M. Barr March 21, 2017 Sierra Club v. EPA 18cv3472 NDCA Attachments Prod 1 ED 002061 00042896-00001 ABSTRACT This study compares the paint removing performance of methylene chloride to 22 solvents currently used in non-methylene chloride paint removers or solvents proposed as an alternative to methylene chloride by chemical manufacturers. The paint stripping performance of three methylene chloride paint removers was then compared to 26 non-methylene chloride paint removers and five experimental formulas using alternative methylene chloride chemistry. The solvents and paint removers were tested on 1 month and 1 year aged wood panels treated with multiple layers of an oil-based alkyd paint, a solvent-borne epoxy paint and OEM automotive coating. For chemically resistant oil-based alkyd, solvent-born epoxy paints and OEM automotive coatings, only methylene chloride based paint removers were determined to be effective. BACKGROUND Methylene chloride has been the preferred solvent for use in paint removers for seventy years. Before methylene chloride was introduced, most paint removers consisted of a mixture of benzene and other volatile solvents such as methanol, acetone, and methyl ethyl ketone. Paint removers formulated with these volatile solvents are extremely flammable and the flammability of these paint removers resulted in fires causing injury and deaths. The benzene based removers were rapidly replaced with the methylene chloride paint removers because methylene chloride paint removers can be formulated to be non-flammable and are effective in removing multiple layers of paint. The physical characteristics give the methylene chloride molecule the ability to quickly penetrate multiple layers and to soften or dissolve chemically resistant coatings. Methylene chloride does not deplete the ozone layer and is considered to make negligible contributions to smog formation, the green-house effect and acid rain. Like other organic solvents, methylene chloride can be harmful to human health if used improperly. Consumer Use of Paint Removers Most consumers use paint removers for refinishing antique furniture, or woodworking's (doors, frames, moldings, etc.) in older houses. Many of these items have been painted, and repainted many times over the years. This results in items having multiple layers of paint containing different chemistry types and a different degree of difficulty from being removed. Paint removers are also used in the auto body repair industry to help with vehicle restoration. Effect of Paint Chemistry and Age of Paint There is a range of paint types that a consumer can encounter when paint stripping. The main paint chemistries that can be encountered include latex, urethane, 1-part epoxy, 2-part epoxy, enamel (alkyd type), lacquer, varnish, and shellac based paint. In recent times, latex paint has taken over the painting industry as the paint technology of choice. This paint is relatively easy to remove with paint strippers, but is also a paint technology that people will not frequently encounter as they are stripping older items. Historically, enamel alkyd based paint have been the most prevalently used paint technology. The resin used in alkyd paint dries by an oxidation reaction with oxygen from the air after the solvents has evaporated from the paint. The oxidation reaction irreversibly cross-links the polymers hardening the alkyd resin making it very difficult to remove. The alkyd paint continues to form cross-linking bonds as the paint ages making older painted items even harder to strip. 2-part epoxy paint is by far the most difficult paint technology to remove. It is frequently used in industrial settings. For this reason, the Sierra Club v. EPA 18cv3472 NDCA Attachments Prod 1 ED 002061 00042896-00002 experimental studies outlined in this report will focus on the removal of alkyd, 2-part epoxy paint, and OEM automotive coatings. Basics of Paint Remover Formulation A chemical paint remover is composed of a mixture of solvents, additives and sometimes an activator. To be an effective paint remover, the solvent must be able to penetrate multiple layers of paint and have solubility to cause the paint to swell which breaks the bond of the paint to the substrate. The movement of the solvent from the paint remover to the paint layer is call diffusion and is the result of the random kinetic movement of the solvent. The rate of diffusion of is affected by the size of the solvent molecule (molar volume) and the polarity of the molecule. Smaller, nonpolar molecules will have a higher diffusion rate into the coating than molecules that are larger or more polar. The more effective replacements for methylene chloride will be molecules with the following general characteristics, small polar or halogenated molecules, five-member cyclic rings or six-member aromatic rings. These types of molecules are generally flammable and will also have health and safety risks. Additives, such as surfactants, thickeners and paraffin wax are added to modify the physical properties of the paint remover. Surfactants improves the wetting of the surface by the paint remover and permits the use of water for clean-up after the paint has been stripped. Thickeners are added to allow the paint removers to cling to vertical surfaces. To reduce the evaporation of methylene chloride and other solvents in the paint remover, paraffin wax is added. Paraffin wax reduces the evaporation of the solvents by forming a physical barrier between the paint remover and air. The weight loss of methylene chloride over a period of five hours was compared to the weight loss of a paint remover containing more than 60% methylene chloride and an evaporation retarder with the results shown in Figure 1. Approximately 20 grams of methylene chloride and 20 grams of the paint remover were placed in separate containers and the weight of the sample remaining was determined at timed intervals. After 30 minutes, only 0.5% of the straight methylene chloride remained in the container. The result of the study showed that evaporation retarder is effective in reducing the evaporation rate of methylene chloride from the paint remover. As shown in Figure 1, 98.9% of the paint remover remained after 30 minutes and 93.5% remained after five hours. Since the methylene chloride based paint remover (containing evaporation retardant) is effective after 15 minutes from application, the amount of methylene chloride released into the atmosphere during this time is minimal, minimizing the inhalation risk to the product user. At 15 min, only 0.6% of the methylene chloride based paint stripper formula has evaporated. Sierra Club v. EPA 18cv3472 NDCA Attachments Prod 1 ED 002061 00042896-00003 Figure 1. Comparison of weight loss of methylene chloride to a methylene chloride paint remover formulated with an evaporation retarder at 70F. At 15 min, only 0.6% of the methylene chloride based paint stripper formula has evaporated. r i : J- .. ,, _,, ____________ ,, _ To increase the performance of the paint remover, an acid or a base is sometimes added as an activator. The activator is thought to disrupt the bond between the substrate and the paint and weaken or break the chemical or physical bonds in the polymer that is used in the paint. Formic acid, ammonium hydroxide and ethanolamine are common activators used in paint removers. To establish the performance criteria of methylene chloride based paint removers, the label copies from different manufactures were evaluated for consumer benefits. The three most important criteria include: A. Fast removal of the coating, starts working within 15 minutes. B. Removal of many types of coatings including oil-based and epoxy paints for architectural coatings and factory applied OEM automotive paints C. Removal of multiple layer of coatings Other criterial considered in the evaluation of the paint remover includes the cost of the paint remove and the VOC content of the paint remover. The VOC content of paint removers is limited to 50 % by weight. When considering viability of a paint remover it must be considered that the paints to be removed are generally older and more chemically resistant than many paints available today. While water-based latex paints are widely available and chemically easily removed, they were not nearly as common 30 or more years ago. Furthermore, there are coatings in common use today that are Sierra Club v. EPA 18cv3472 NDCA Attachments Prod 1 ED 002061 00042896-00004 considered more chemically resistant than water-based latex paints. Once again, this study focuses on the more difficult, chemically resistant oil-based alkyd and solvent-born two-part epoxy paints. MATERIALS AND METHODS The procedure used to test the performance of the solvents and paint removers is based on a modification of the ASTM D-6189 (2003) test method (Standard Practice for Evaluating the Efficiency of Chemical Removers for Organic Coatings). Modification of the procedure included using 12 x 8 inch panels instead of 12 x 12 inch panels and the panels were treated with five coats of the oil-based alkyd paint instead of three coats as described in the panel preparation procedure in the ASTM D-6189 test method. Painted panels aged 1 month were used for screening experiments and painted panels aged 1 year were used for final efficacy validation. The solvents and paint removers were applied to the panel using a pipette instead of following manufactures directions for application as called for in the ASTM test method. During the paint removal step, scrapping was performed using moderate force with a plastic paint scrapper. Solvent Selection - The solvents used in this study were selected from solvents currently used in non methylene chloride paint removers, solvents recommended as methylene chloride replacements by chemical manufacturers, and the EPA Exempt VOC Solvents list. Technical grade samples of the solvents were obtained and used in this study's experimental formulations without further purification. Paint Remover Selection - The paint removers used in this study were purchased from hardware stores or from suppliers on the internet. Composition and the flash point of the paint removers based on information found in the Material Safety Data Sheets (MSDS) are listed in Appendix A. All paint removers were used as is in the experiments. Experimental Paint Removers - Based on the results of the solvents screening testing, two alternative methylene chloride solvents were identified as having some paint remover potential. These solvents were formulated into paint removers that meet the 50 wt% VOC requirements. Three other experimental formulas based on solvent chemistry utilized by paint removers on the market today were also formulated into experimental paint removers with the VOC content less than 50 wt%. These experimental paint removers are listed below: A. a solvent based remover based on toluene, methanol, and acetone B. a solvent based remover based on 1,2 trans-dichloroethylene, methanol, and acetone C. a solvent based remover based on 1,3-dioxolane, methanol, and acetone D. an emulsion based on benzyl alcohol E. an emulsion based on dibasic esters (DBE) Paint Selection - Oil-based alkyd paint was selected to be used since it has historically been the most predominantly used paint technology and consumers are typically stripping older items which contains multiple layers of this type of paint. Two-part component epoxy paint was also selected because it is the most difficult paint technology to remove and is frequently used in industry applications. The paints used were purchased from a local hardware or paint stores. The paints purchased for this study are listed in Table 1 along with numbers of layers of paint used on the test panel. Only one type of paint was used for each test panel. Sierra Club v. EPA 18cv3472 NDCA Attachments Prod 1 ED 002061 00042896-00005 Table 1. List of paint, paint type and number of coatings used in study Paint Rust-Oleum Professional High Performance Protective Enamel Exterior Gloss Sherwin Williams Macropoxy 646 Paint Type Oil-based alkyd paint Two component oil-based epoxy paint Number of Coatings 5 3 1 Month Aged Panel Preparation Procedure - Sanded birch plywood (4 ft. x 4 ft. x 34 in.) was cut into approximately 12 x 8 inch panels. A four-inch multi-purpose paint roller was used to apply the coats of the designated paint to the birch panels as determined in Table 1. Each layer of paint was dried for four hours at ambient conditions and then was placed in a laboratory oven at 50C overnight. Each layer of paint was tinted to a different color to increase the visibility of the paint layers. The color schematic went as follows: Blue = color of 1st paint layer applied, White = color of 2nd paint layer applied, Green = color of 3rdpaint layer applied, Yellow = color of 4th paint layer applied, Red= last paint layer applied. After the red coat of paint was applied, the panels were then aged for 30 days at 50C in the laboratory. The test panels were then stored at ambient conditions until needed for the stripping test. 1 Year Aged Panels- Painted panels aged for 1 month/30 days are only good for giving directional data on the efficacy of a paint stripper. These 1 month aged panels are typically used by the formulation chemist to quickly screen new chemistries to see if they have the potential of becoming an efficacious paint remover. The reality is that consumers are trying to remove multiple layers of paint off items that are many years old. As mentioned in the introduction, alkyd paint types get harder to remove over time due to their chemistry. True efficacy validation of a paint remover requires it to be tested on Alkyd painted boards that have been allowed to age for at least 1 year. These boards were initially prepared in the same manner as the 1 month aged boards, but were allowed to sit at ambient conditions for up to a year prior to testing. Automotive Panel Preparation - The hood from a 2006 Chevrolet Impala SS was purchased in good condition with the factory paint intact. The hood was cleaned with a damp cloth and used in testing without further modifications. The original paint was used on the hood, so the paint job during removal testing was at least 9 years old. The age of this paint is not as of great importance due to the chemistry being stable over time in comparison to the Alkyd paint which continues to react and get stronger. Neat Solvent Screening - Neat solvent screening was done on 1 month aged boards to generate directional efficacy data on chemicals that might be promising to be incorporated in a paint remover formula. A grid is marked on the panel with masking tape creating test cells approximately 1 34 in. x 1 34 in. for the stripping trials. Each cell was labeled with the name of the solvent to be tested and the duration time of the test. A C31 Large Commercial Sponge from 3M was cut to approximately sized 134 in. x 1 34 in. x % in. pieces were placed on each test cell to control evaporation and retain the solvent to the test area. For each sample, 2 ml of solvent was applied to the sponge and a timer is started. Additional solvent was added to the sponges as needed to ensure that the solvent remained in contact with the surface of the test panel. At the timed intervals, the test area was scraped using a plastic scraper and evaluated for the effects on the coatings and the number of layers of paint removed. Sierra Club v. EPA 18cv3472 NDCA Attachments Prod 1 ED 002061 00042896-00006 Experimental Paint Remover Screening and Validation - Experimental paint remover formulas were tested on 1 month aged boards to get directional efficacy data in comparison to a commercialized paint remover competitive set. This process helps weed out underperforming formulas prior to testing on valuable 1 year aged boards. This same experiment was then repeated on 1 year aged alkyd painted boards to validate the true efficacy of the experimental and commercially available paint removers. A grid was marked on the panel with masking tape to create test cells of approximately 11'A in. x l / i in. dimensions. Each cell was labeled with the name of the solvent to be tested and the time duration of the test. Approximately 2 ml of the paint remover was applied to the cell and a timer is started. At timed intervals, the test area was scraped using a plastic scraper and judged for the effects on the coating and the numbers of layers of paint removed. Results Neat Solvent Screening - Neat solvent experiments were done on 1 month aged painted boards for the sole purpose of getting directional efficacy data to drive future non-methylene chloride formulation development. The results comparing the performance of methylene chloride to the 22-alternate solvents selected are listed in Table 2. The performance was evaluated after 15 minutes, 30 minutes and 1 hour with number of layers of paint removed and the effect of the solvent on the paint noted. Methylene chloride performed the best removing all five layers of oil-based alkyd paint and two layers of the two-component oil-based epoxy paint in 15 minutes. Trans-l,2-dichloroethylene and 1,3dioxolane were identified as the best performing alternate solvent removing all five layers of the oilbased alkyd paint in 30 minutes. After 1 hour, 1,3-dioxolane removed two layers of the two-component oil-base epoxy paint, however, trans-l,2-dichloroethylene failed to remove any layers of the epoxy paint after an hour. Results from this experiment helped drive decisions on which chemicals could be used in new experimental paint removal formulas that did not utilize methylene chloride. Table 2. Neat solvent experiments were done on 1 month aged painted boards for the sole purpose of Chemical (Neat) methylene chloride trans-1,2 dichloroethylene l,3dioxolane n-methyl-2-pyrrolidone acetone dimethoxymethane (methylal) n-butyl propionate dimethyl sulfoxide (DMSO) dimethyl carbonate benzyl methyl ether TOC (2,5,7,10 tetraoxaundecane) 3-methoxy-3-m ethyl-1-butyl acetate (MMB-AC) Steposol MET-10U PCBTF/Oxsol 100 3-m etho xy-3-m eth yl-l-b u tan ol (MMB) Eastman Omnia (butyl-3-hydroxybutyrate) benzyl alcohol dibasic esters (LVP) dibutoxymethane (butylal) propylene carbonate Elevance Clean 1200 soya methyl ester glyercol formal Alkyd (5 Layers) 15 min 30 min 1 hrs s s S 5 5 5 5 5 5 iiiiiil 5 5 5 5 5 5 5 5 4 Epoxy (3 Layers) 15 min 1 30 min 1 2 i2 2 Ah no effect on coati ng IIMIMIMmmmS slight softening of paint but no removal with plastic scraper paint has softened requiring effort to remove with plastic scraper paint has blistered with all layers paint removed with plastic scraper Sierra Club v. EPA 18cv3472 NDCA Attachments Prod 1 ED 002061 00042896-00007 getting directional efficacy data to drive future formulation development. Results of solvent testing showing the layers of oil-based alkyd and two component oil- based epoxy removed. The performance of trans-l,2-dichloroethylene and 1,3-dioxolane in removing OEM automotive paint was then compared to methylene chloride and three solvents n-methyl-2-pyrrolidone, benzyl alcohol and DBE currently used in commercially available non-methylene chloride paint removes with the results listed in Table 3. The performance of the solvents was evaluated after 15 minutes, 30 minutes, 1 hour and 4 hours with number of layers of paint removed and the effect of the solvent on the paint noted in Table 3. Once again methylene chloride performed the best by removed the clear and color coat in fifteen minutes. Trans-l,2-dichloroethylene and 1,3-dioxolane removed the clear and color coat after 30 minutes while NMP, benzyl alcohol and DBE had no effect on the paint after four hours. None the neat solvents, including methylene chloride, stripped all layers of the automotive coating including the primer. Only a formulated paint remover would remove all layers of an automotive coating. Table 3. Results of solvent testing showing the layers of OEM automotive paint removed. Chemical (Neal methylene chloride______ trans-l,2dichloroethylene l,3dioxolane___________ n-methyl-2-pyrrolidone benzyl alcohol__________ dibasic esters (LVP)______ No effect____________________ Stripped clear coat and top coat Stripped clear coat, top coat and base coat Experimental Formula Paint Remover Screening on 1 month Aged Boards Experimental paint remover formulas were tested on 1 month aged boards to get directional efficacy data in comparison to a commercialized paint remover competitive set. This process helps weed out underperforming formulas prior to testing on valuable 1 year aged boards. Test results comparing the performance of three methylene chloride paint removers to 5 experimental formulas and 26 commercial non-methylene chloride paint removers on one month aged boards are presented in Table 4. The panels used in this experiment were evaluated after 5 minutes, 15 minutes, 30 minutes, 1 hour and 4 hours with the numbers of layers of paint stripped by the paint remover recorded. For test panels Sierra Club v. EPA 18cv3472 NDCA Attachments Prod 1 ED 002061 00042896-00008 painted with oil-based alkyd paint, two of the three methylene chloride paint removers, Klean Strip Aircraft Remover and Klean Strip Premium Stripper, stripped all five layers of the alkyd paint after five minutes. The third paint remover, Klean Strip Strip-X, contains less methylene chloride and took 15 minutes to strip the five layers of the alkyd paint. Experimental Formulas A, B, and C were also able to strip all five layers of the oil-based alkyd paint in 15 minutes. Experimental Formula A was formulated with toluene, methanol and acetone. Experimental Formulas B and C contained the two alternate solvents identified in the alternated solvent study and were formulated with 1,2 trans-dichloroethylene, methanol, and acetone and 1,3-dioxolane, methanol, and acetone. Experimental Formula D based on a benzyl alcohol emulsion and Experimental Formula E based on a DBE emulsion failed to strip any layers of the alkyd paint after four hours. Fifteen of the twenty-six commercial non-methylene chloride paint removers tested stripped all layers of alkyd paint in four hours. Eight of sixteen paint removers that stripped the alkyd paint were formulated with NMP. Five of the sixteen paint removers were formulated for professionals to remove automotive or aircraft coatings were based a blend of solvents and high levels of an activator. The remaining two formulas were based on dimethyl sulfoxide (DMSO) or caustic. For the panels painted with the two-component oil-based epoxy paint, two of the three methylene chloride paint removers, Klean Strip Aircraft Remover and Klean Strip Premium Stripper, stripped two layers of the epoxy paint after 15 minutes. The third paint remover, Klean Strip Strip-X which contains less methylene chloride, took four hours to remove two layers of the epoxy paint. The experimental and Sierra Club v. EPA 18cv3472 NDCA Attachments Prod 1 ED 002061 00042896-00009 Table 4. Results of paint remover screening showing the layers of oil-based alkyd and two-component oil-based epoxy removed on 1 month aged panels. Promising experimental formulations from this test were later validated on 1 year aged panels with competition. Com pany W . M. Barr D um ond Ecoprocote EZ Strip Franm ar M otsenbocker Packaging Service Co. PPG So lven t K leen e S u n n y s id e T h is S tu ff W o rk s, Inc. Zin sser Paint R e m o ve r K le an -Strip A ircraft R e m o ver K le an -Strip P rem iu m Strip p e r K le an -Strip Strip -X Strip p e r C'rtristrip S a fe r Pain t & V a rn ish S trip p in g G el Experim ental Fo rm ula A Experim ental Fo rm ula B Experim ental Fo rm ula C Experim ental Fo rm ula D Experim ental Fo rm ula E Peel Aw ay 1 Peel A w ay 5 So y Based Peel Aw av 7 Sm art Strip Sm art Strip Pro EcoFast H D H ea vy D u ty Pain t S trip p e r EZ S trip Paint and V arn ish S trip p e r So v-G el Paint and U re th a n e R e m o ve r Lift O ff P ain t and V arn ish R e m o v e r C ro w n P ain t S trip N e xt D u ra P re p 2 0 0 C o atin g R e m o ver (G el) D u ra P re p 2 4 0 Ind u strial C o a tin g R e m o v e r (G el) DuraPrep Prep 400 O verspray Rem over D -Zolve 1 0 1 2 P o w d e r Co atin g R e m o ve r (im m e rsio n tank) D -Zo lve 1 5 -3 3 R (aircraft) M u lti-S trip P ro fe ssio n a l Pain t R e m o v e r Readv Strip Pro R e ad y Strip S a fe r Pain t & V arn ish R e m o ve r R eady-Strip Sp ray U ltri-Strip TSW 2 M ulti-M aster T SW 2 G M u lti-M aster (G el) TSW 3G (G EL) M ason-M aster TSW 9 Piasti-M aster M agic Strip C itrus-A ction Ingredien ts (M SD S) m e th y le n e ch lo rid e/m e th an o l/T all o il/am m o niu m h yd ro xid e /xy le n e m e th y le n e ch lo rid e /m e th a n o l/S to d d a rd solvent m e th ylen e ch io rid e/m e th an o l/to lu en e/a ce to n e/xvlen e NM P/DBE tolu e n e /ace to n e /m e th an o l 1,2 tra n s d ich lo ro e th y le n e /a ce to n e /m e th a n o l 1,3 d io xo la n e /a ce to n e /m e th a n o i benzyl alcohol em ulsion DBE em ulsion calcium h yd ro xid e /m a g n e siu m h yd ro xid e /so d iu m h y d ro x id e /w a te r benzyl alco ho l/N M P/so ya m eth yl este r/D B E /w ate r benzvl alcohol/N M P/D B E/w ater w ater/b en zyl ako h o l/w ate r w ater/b en zyl ako h o l/fo rm ic acid/w ater N M P/sov m ethvl ester/w a te r D B E/triethyl p ho sp hate/w ater NM P/D BE/sov ester/w ater a ce to n e/2 -b u to xye th an o l/D B E /w ater DBE/DM SO /w ater benzyl alcohol\solvent n ap hth a/2 -am ino eth an ol/n on ylp he no l, branched eth o xy la te d benzyl alco ho l/h ydrogen p ro xid e/so lven t nap hth a/glyco llic acid/m alic acid/b arium b is(d in o n yln a p h th a le n e su p h o n a te )/a m in e s, co co alkyl, eth o xy la te d benzyl alco ho l/p etroleu m d istilla te s/glyco lk acid/q u aternary am m onium co m p ou n ds/h yd ro gen p ro xid e/w ater alkyl m e th yl e ste r/p o ta ssiu m hyd ro xide /cyciic a m id e /w a te r alkyl m e th yl e ste r/p e tro le u m n ap h th a/b en zyl a k o h o l/m e th y l phenyl ether/w ater D B E /N M P /fo rm ic acid/w ater D B E /N M P /fo rm ic acid/w ater D B E /N M P /fo rm ic acid/w ater N M P /D B E/m o n o eth an o lam in e/w ater D B E /N M P /fo rm ic acid/w ater NM P/D BE/w ater NM P/D BE/w ater potassium h yd ro xid e /b u ty l ce llo so iv e/w a te r D B E/p ro prietary su rfactan t/w ater N M P /D B E/d -lim o n e n e /w a te r R etail C o st (gallo n) $ 2 7 .9 9 $ 2 2 .9 8 $ 1 8 .9 7 $ 3 9 .9 4 $ 2 3 .8 8 * $ 4 2 .9 7 * $ 3 1 .5 5 * $ 3 9 .9 6 * $ 3 4 .0 0 * $ 6 8 .3 0 $ 7 8 .1 2 $ 9 0 .1 5 $ 5 0 .5 9 $ 7 7 .7 4 $ 5 4 .9 9 $ 3 8 .9 8 $ 8 1 .2 0 $ 4 9 .9 4 $ 4 7 .9 2 $ 4 1 .3 4 $ 4 0 .7 5 $ 1 2 7 .6 0 Not A vailable Not A vailable $ 4 9 .9 7 $ 3 9 .9 7 $ 3 4 .7 1 $ 3 9 .9 2 $ 6 6 .8 5 $ 9 9 .9 5 $ 9 9 .9 5 $ 8 5 .0 0 $ 9 9 .9 5 $ 8 4 .3 2 no layers of paint w e re re m o v e d w ith p lastic paint scra p e r p aint has so fte n e d re q u irin g e ffo rt to re m o v e w ith p lastic scrape r p aint has b liste re d w ith all laye rs o f paint re m o ve d w ith p lastic scra p e r Esti m ated reta i I p ric e o f e xp eri m enta I f o r m u la s b ased on fo r m u la , p a c k a g i ng, a nd m anufacturing costs. um the commercial paint removers failed to strip any layers of the epoxy paint at 15 and 30 minutes, 1 hour and four hours. Since the experimental formulas A, B, and C showed comparable efficacy on the 1 month aged alkyd painted board in comparison to the methylene chloride containing formulas they were allowed to advance onto the validation test done on a 1 year aged alkyd painted board. Final Efficacy Validation of Experimental Formulations vs Competition on 1 Year Aged Boards As shown in the results in Table 5, Klean Strip Premium Stripper took 15 minutes to remove all layers of paint on a 1 year aged panel but only 5 minutes on the newer 1 month aged panel. The alternate paint removers also required more time to strip all layers of the alkyd paint on the aged panels. The time to strip all layers increased to an hour compared to 30 minutes for the Experimental Formulas A, B, and C. Crown Safer Paint Strip stripped all layers of paint after 24 hours on the new panels but failed to remove any layers of paint on the 1 year aged panels. See Appendix B for a visual of 1 month and 1 year aged panels used in this validation test. The difference in results between the 1 month aged panels in Table 4 and Table 5 is due to the inconsistencies of how Alkyd paint cures over a month time. Experiments done in Table 4 were done with one month boards created on different time periods than used in table 5. As the alkyd painted panels age, the alkyd resin continues to crosslink making the paint more difficult to strip. More consistent results are obtained using alkyd painted panels which are aged for at least one year. 1 month aged panels are used strictly for directional feedback and should not be used to validate the final efficacy of a paint remover. Table 5. Validation results of paint remover testing done on panels aged 1 month to 1 year. Since Alkyd paint continues to bond and get harder to remove over time, 1 year aged paint boards are more realistic on what the consumer will experience while paint stripping. Klean-strip Premium Stripper methylene chloride based stripper is far superior to the current competitive set on the market. New experimental formulas are extremely flammable and do not perform as fast as current methylene chloride formulations. The difference in results between the 1 month aged panels in Table 4 and Table 5 is due to the inconsistencies of how Alkyd paint cures over a month time. As the alkyd painted panels age, the alkyd resin continues to crosslink making the paint more difficult to strip. More consistent results are obtained alkyd painted panels which are aged for at least one year. 1 month aged panels are used strictly for directional feedback. Month Old Panel-Alkyd (5L; Klean-Strip Premium Stripper Klean-Strip Strip-X Stripper Experimental Formula A Experimental Formula B Experimental Formulae Citristrip Safer Paint & Varnish Stripping Gel PeeiAwayl Smart Strip Smart Strip Pro EZ Strip Paint and Varnish Stripper Lift Off Paint and Varnish Remover Crown Safer Paint Strip methylene chioride/methanoi/Stoddard solvent methylene chloride/methanol/toiuene/acetone/xviene toluene/acetone/methanol 1,2 trans dichloroethylene/acetone/methanol 1,3 dioxolane/acetone/methanoi NMP/DBE caidum hydroxide/magnesium hydroxide/sodium hydroxide water/benzy! alcohol water/benzyl aicohol/formic add DBE/triethyl phosphate acetone/2-butoxvethanol/D6E DBE/DMS0 1 M U t p r 1 ;;; : : : no layers of paint were removed with plastic paint scraper paint has softened requiring effort to remove with plastic scraper paint has blistered with all layers of paint removed with plastic scraper Sierra Club v. EPA 18cv3472 NDCA Attachments Prod 1 ED 002061 00042896-00011 Test results comparing the performance of three methylene chloride paint removers to five experimental formulas and five commercial non-methylene chloride paint removers on an OEM automotive coating are listed in Table 6. The five commercial non-methylene chloride paint removers were formulated to remove automotive or aircraft coatings containing a blend of solvents and an activator. The effects on automotive coating was evaluated after 15, and 30 minutes, 1 hour and 4 hours. Only one of the paint removers tested, Klean Strip Aircraft Remover, stripped all layers of the OEM automotive coating. Klean Strip Aircraft Remover stripped the clear, color and base coat in 15 minutes and continued to strip all layers at 4 hours without drying. Klean Strip Aircraft Remover is formulated to remove automotive coatings containing methylene chloride and the activator ammonium hydroxide. Klean Strip Premium Stripper and Klean Strip Strip-X, removed the clear and color coat after 15 minutes but did not strip the primer coat after four hours. Klean Strip Premium Stripper and Klean Strip-X are methylene chloride paint removers but do not contain an activator. Experimental Formulas A, B, and C were also able to strip the clear and color coat after 15 minutes but failed to strip the primer coat after 4 hours. Experimental Formulas D and E failed to strip the automotive coating after four hours. D-Zolve 15-33R rom Solvent Kleene was the only commercial non-methylene chloride paint remover tested that stripped the automotive coating. D-Zolve 15-33R is a paint remover designed to remove aircraft coatings and took four hours to remove the clear and color coats. Table 6. Results of paint remover testing on an OEM Automotive Coating. Company Paint Remover ingredients (MSDS) W.M. Barr PPG boivent ivieene Klean-Strip Aircraft Remover Klean-Strip Premium Stripper Klean-Strip Strip-X Stripper Citristrip Safer Paint & Varnish Stripping Gel Experimental FormulaA Experimental Formula B Experimental Formulae Experimental Formula D Experimental Formula E DuraPrep 200 Coating Remover (Gel) DuraPrep 240 Industrial Coating Remover (Gel) DuraPrep Prep 400Overspray Remover D-Zolve 1012 Powder Coating Remover(immersiontank) D-Zolue 15-33R (aircraft) methylene chioride/methanol/Tai! oil/ammonium hydroxide/xylene methylene chloride/methanol/Stoddard solvent methylene chioride/methanol/toluene/nony! phenol ethoxylate/acetone/xylene NMP/DBE toluene/acetone/methanol 1,2 trans dichloroethyiene/acetone/methano! 1,3 dioxolane/acetone/methanol benzyl alcohol emulsion DBE emulsion benzyl alcohol\solvent naphtha/2-aminoethanol/nonylphenol, branched ethoxy! ated benzyl alcohol/hydrogenproxide/solvent naphtha/giycollicadd/malicadd/barium bis(dinonylnaphthalenesuphonate)/amines, coco alkyl, ethoxy!ated benzyl afcohol/petroieum distillates/glycoiicacid/quatemary ammonium compounds/hydrogen proxide alkyl methyl ester/potassium hydroxide/cydic amide alkyl methyl ester/petroleum naphtha/benzyi alcohol/methyl phenyl ether No effect Stripped dear coat and top coat Stripped clear coat, top coat and base coat Conclusion The performance of methylene chloride was compared to 22 alternate solvents selected as possible replacements for methylene chloride in paint removers. Testing was conducted on three types of paints using wood panels painted with an oil-based alkyd paint, wood panels paint with a two-component oilbased epoxy paint and an OEM automotive coating. Trans-1,2-dichloroethylene and 1,3-dioxolane were Sierra Club v. EPA 18cv3472 NDCA Attachments Prod 1 ED 002061 00042896-00012 identified as the best performing alternate solvent tested. However, based on the results from this study, none of the alternative solvents tested were determined to be an adequate replacement for methylene chloride. Based on the results of the solvents screening testing, two solvents, trans-l,2-dichloroethylene and 1,3dioxolane were selected as having some paint remover potential and were formulated into paint removers that met the 50 wt% VOC limit for paint removers. Three other experimental formulas were also formulated based on a toluene, methanol and acetone formula, a benzyl alcohol emulsion formula and a DBE emulsion formula. Three methylene chloride paint removers were then compared to the fiveexperimental formula and 26 commercially available non-methylene chloride paint removers. Based on the results of the paint remover study, none of the experimental formulas or the 26 non-methylene chloride paint removers were determined to be an adequate replacement for methylene chloride paint removers. Performance of the experimental formulas based on trans-l,2-dichloroethylene and 1,3dioxolane was determined to be no better than the experimental formula based on toluene, methanol and acetone. Methylene chloride has been the preferred for use in paint removers for seventy. Consumers expect that paint removers to be able to remove many types of coatings, remove multiple layers of the coating and to start working within 15 minutes and quickly remove the coating. To be an effective paint remover, the solvent must be able to penetrate multiple layers of paint and have solubility to cause the paint to swell which breaks the bond of the paint to the substrate. The size of the solvent molecule and the polarity of the molecule affects rate the solvent penetrates the coating. The movement of the solvent from the paint remover to the paint layer is call diffusion and is the result of the random kinetic movement of the solvent molecules. Smaller, nonpolar molecules will have a higher diffusion rate into the coating than molecules that are larger or more polar. The more effective replacements for methylene chloride will be molecules with the following general characteristics, small polar or halogenated molecules, five-member cyclic rings or six-member aromatic rings. Unlike methylene chloride, these types of molecules are most likely flammable and possibly will have a significant threat to health and safety. Sierra Club v. EPA 18cv3472 NDCA Attachments Prod 1 ED 002061 00042896-00013 Appendix A. Composition of Paint Removers and Flash Point as Listed in Material Safety Data Sheets Com pany W . M. Barr Paint Rem over Klean Strip Aircraft Rem over Klean Strip Prem ium S trip p e r Klean Strip Strip-X S trip p e r Citristrip Stripping Gel Experim ental Form ula A Experim ental Form ula B Experim ental Form ula C Experim ental Form ula D Experim ental Form ula E Ingredients (M SDS) Chem ical Nam e CAS N um ber m ethylene chloride 75-09-2 m ethanol 67-56-1 am m onium hydroxide 1336-21-6 x y le n e 1330-20-7 hydrotreated light distillate (petroleum ) 64742-47-8 fatty acid soap 68132-50-3 e th y lb e n z e n e 100-41-4 m ethylene chloride 75-09-2 m ethanol 67-56-1 Stoddard Solvent 8052-41-2 m ethylene chloride 75-09-2 m ethanol 67-56-1 acetone 67-64-1 x y le n e 1330-20-7 to lu e n e 108-88-3 e th y lb e n z e n e 100-41-4 ethyl alcohol 64-17-5 isopropyl alcohol 67-63-0 n-m ethyl-2-pyrrolldone 872-50-4 dim ethyl adipate 627-93-0 dim ethyl glutarate 1119-40-0 acetone 67-64-1 to lu e n e 108-88-3 m ethanol 67-56-1 acetone 67-64-1 trans-l,2-dichlo roethylene 646-06-0 m ethanol 67-56-1 acetone 67-64-1 1 ,3 -d lo x o la n e 646-06-0 m ethanol 67-56-1 benzyl alcohol 100-51-6 alcohol ethoxylate (alcohols, c 9 - ll, 68439-46-3 e th o x y la te d ) w ater 7732-15-5 dim ethyl adipate 627-93-0 dim ethyl glutarate 1119-40-0 starch 9005-25-8 alcohol ethoxylate (alcohols, C9-11, 68439-46-3 e th o x y la te d ) W eight % 60 -1 0 0 5 -1 0 <5 <5 <5 <5 <3 60 -1 0 0 1 0 -2 0 <5 3 0 -4 0 1 5 -2 6 < 10 < 10 < 10 <5 <5 <5 3 0 -6 0 1 0 -3 0 1 0 -2 0 4 0 -5 0 4 0 -5 0 < 10 4 0 -5 0 4 0 -5 0 < 10 4 5 -5 5 4 0 -5 0 < 10 2 0 -40 <5 4 0 -6 0 1 0 -3 0 1 0 -2 0 5 -2 0 <5 Flash Point no flash to b o ilin g no flash to b o ilin g 30F >200F 0F 0F 0F no flash to b o ilin g no flash to b o ilin g Sierra Club v. EPA 18cv3472 NDCA Attachments Prod 1 ED 002061 00042896-00014 Com pany Dumond Ecoprocote EZ Strip Fram m ar M otsenbocker Paint Rem over Peel Aw ay 1 Peel Aw ay 5 Soy Based Peel Aw ay 7 Sm art Strip Sm art Strip Pro Ingredients (M SDS) Chem ical Nam e CAS N um ber calcium hydroxide 1305-62-0 m agnesium hydroxide 1309-42-8 sodium hydroxide 1310-73-2 benzyl alcohol 100-51-6 n-m ethyl-2-pyrrolidone 872-50-4 fatty acid m ethyl ester 67784-80-9 a lp h a -(4 -n o n y lp h e n y l)- om ega-hydroxy-polyfoxy- 127087-0 l,2,e th an ed iyl) branched dim ethyl glutarate 1119-40-0 dim ethyl adipate 627-93-0 benzyl alcohol 100-51-6 n-m ethyl-2-pyrrolidone 872-50-4 a lp h a -(4 -n o n y lp h e n y l)- om ega-hydroxy-polyfoxy- 127087-0 l,2,e th an ed iyl) branched dim ethyl glutarate 1119-40-0 dim ethyl adipate 627-93-0 w ater 7732-18-5 benzyl alcohol 100-51-6 titanium dioxide 13463-67-7 w ater 7732-18-5 benzyl alcohol 100-51-6 titanium dioxide 13463-67-7 fo rm ic acid 64-18-6 w ater 7732-18-5 EcoFast HD Heavy Duty Paint Stripper benzyl alcohol Bio-Based Em ulsion Solvent-Free Thickeners EZ Strip Paint and V arnish S trip p e r Soy-G el Paint and V arnish Stripper Lift O ff Paint and Varnish Rem over Solvent-Free Surfactants dim ethyl adipate dim ethyl succinate dim ethyl glutarate triethyl phosphate n-m ethyl-2-pyrrolidone dim ethyl adipate dim ethyl glutarate soy ester Proprietary Thickening and Su rfactan t Blend acetone 2-butoxy ethanol dim ethyl adipate dim ethyl succinate dim ethyl glutarate 100-51-6 NonHazardous NonHazardous NonHazardous 627-93-0 106-65-0 1119-40-0 78-40-0 872-50-4 627-93-0 1119-40-0 67781-80-9 P ro p rie ta ry 67-64-1 111-76-2 627-93-0 106-65-0 1119-40-0 W eight % 21 16 9 2 0 -5 0 2 5 -3 5 1 5 -2 0 <3 2 5 -3 5 2 0 -4 0 1 0 -2 0 <2 2 5 -3 5 4 0 -6 0 3 0 -5 0 1 -5 4 0 -6 0 3 0 -5 0 1 -5 1 -5 Trade Secret Trade Secret Trade Secret < 1 1 -5 3 -7 5 -1 0 1 0 -3 0 3 -7 41 4 0 -4 5 1 5 -2 0 1 -5 < 10 Not Listed Not Listed Not Listed Not Listed Flash Point none > 200F > 200"F none none non flam m able not listed > 200"F not listed Sierra Club v. EPA 18cv3472 NDCA Attachments Prod 1 ED 002061 00042896-00015 Com pany P a c k a g in g Services Co PPG Solvent Kleene S u n n y sid e Paint Rem over Crow n Paint Strip Next Dura Prep 200 Coating Rem over Dura Prep 240 Industrial Coating Rem over Dura Prep Prep 400 Overspray Rem over D-Zolve 1012 Pow er Coating Rem over M ulti-Strip Professional Paint Rem over Ready Strip Pro Ready Strip Safer Paint & V arnish Rem over Ready Strip Spray Ingredients (M SDS) Chem ical Nam e CAS N um ber dim ethyl sulfoxide 67-68-5 dim ethyl glutarate 1119-40-0 dim ethyl succinate 106-65-0 dim ethyl adipate 627-93-0 alcohol ethoxylate surfactant Not Listed benzyl alcohol 100-51-6 solvent naphtha (petro leum ), light arom atic 64742-95-6 2-am inoethanol 141-43-5 nonylphenol, branched, e th o x y la te d 68412-54-4 benzyl alcohol 100-51-6 hydrogen peroxide 7722-84-1 solvent naphtha (petroleum ), heavy 64742-94-5 arom atic barium bisfdinonyln a p h th a le n e su lp h o n a te ) 25619-56-1 am ines, co co alkyl, e th o x y la te d 61791-14-8 2-(m ethoxym ethylethoxy) propanol 34590-94-8 dim ethyl sulfoxide 67-68-5 dim ethyl glutarate 1119-40-0 benzyl alcohol 100-51-6 alkyl m ethyl ester P ro p rie ta ry potassium hydroxide cyclic am ide n-m ethyl-2-pyrrolidone dim ethyl glutarate dim ethyl adipate dim ethyl succinate fo rm ic acid non-hazardous com ponents benzyl alcohol n-m ethyl-2-pyrrolidone fo rm ic acid non-hazardous com ponents benzyl alcohol n-m ethyl-2-pyrrolidone fo rm ic acid non-hazardous com ponents n-m ethyl-2-pyrrolidone dim ethyl glutarate dim ethyl adipate dim ethyl succinate m onoethanolam m e isopropanolam ine m ixture non-hazardous com ponents 1310-58-3 72-50-4 872-50-4 1119-40-0 627-93-0 106-65-0 64-18-6 N/A 100-51-6 872-50-4 64-18-6 N/A 100-51-6 872-50-4 64-18-6 N/A 872-50-4 1119-40-0 627-93-0 106-65-0 141-43-5 78-96-6 110-97-4 122-20-3 N/A W eight % 2 0 -2 5 4 5 -4 5 1 0 -2 0 5 -1 5 0 -1 1 5 -4 0 1 -5 1 -5 0 .1 -1 1 5 -4 0 5 -1 0 3 -7 0 .1 -1 0 .1 -1 3 0 -6 0 7 -1 3 5 -1 0 5 -1 0 Trade Secret 2 -5 5 -3 0 1 5 -3 5 2 0 -3 5 5 -1 0 5 -1 5 1 -2 2 0 -4 0 2 0 -3 5 5 -1 5 2 -1 5 5 0 -6 5 2 0 -3 5 5 -1 5 2 -1 5 5 0 -6 5 3 5 -5 0 2 0 -3 5 5 -2 0 3 -5 1 -3 2 -5 4 5 -5 0 Flash Point 160F 221F 178F 203F 170F 203F 205F 205F 2 0 5 "F Sierra Club v. EPA 18cv3472 NDCA Attachments Prod 1 ED 002061 00042896-00016 Com pany Paint Rem over Ready Strip Spray S u n n y sid e U ltra-Strip Ingredients (M SDS) Chem ical Nam e CAS N um ber n-m ethyl-2-pyrrolidone 872-50-4 dim ethyl glutarate 1119-40-0 dim ethyl adipate 627-93-0 dim ethyl succinate 106-65-0 m onoethanolam ine 141-43-5 78-96-6 isopropanolam ine m ixture 110-97-4 122-20-3 non-hazardous com ponents N/A n-m ethyl-2-pyrrolidone 872-50-4 dim ethyl glutarate 119-40-0 dim ethyl adipate 627-93-0 dim ethyl succinate 106-65-0 fo rm ic acid 64-18-6 non-hazardous com ponents N/A n-m ethyl-2-pyrrolidone 872-50-4 TSW 2 M ulti-M aster dim ethyl glutarate 1119-40-0 dim ethyl adipate 627-93-0 This Stuff W orks, ine TSW 2G M ulti-M aster (G el) TSW 3G (Gel) M asonM aster n-m ethyl-2-pyrrolidone dim ethyl glutarate dim ethyl adipate potassium hydroxide butyl cellosolve 872-50-4 1119-40-0 627-93-0 1310-58-3 11-76-2 dim ethyl glutarate 1119-40-0 Z in s s e r TSW 9 Plasti-M aster dim ethyl adipate M agic Strip Citrus-A ction proprietary surfactant n-m ethyl-2-pyrrolidone dim ethyl glutarate dim ethyl adipate dim ethyl succinate m onoethanolam ine d-lim onene 627-93-0 Trade Secret 872-50-4 1119-40-0 627-93-0 106-65-0 141-43-5 5989-27-5 W eight % 3 5 -5 0 2 0 -3 5 5 -2 0 3 -5 1 -3 2 -5 4 5 -5 0 3 5 -5 0 2 0 -3 5 5 -2 0 3 -5 1 -2 5 -3 5 Trade Secret Trade Secret Trade Secret Trade Secret Trade Secret Trade Secret Trade Secret Trade Secret Trade Secret Trade Secret Trade Secret 2 5 -5 0 2 5 -5 0 2 .5 -1 0 2 .5 -1 0 2 .5 -1 0 1 .0 -2 .5 Flash Point 205F >200F > 2 1 2 "F >212F non flam m able >212F >199F Sierra Club v. EPA 18cv3472 NDCA Attachments Prod 1 ED 002061 00042896-00017 Appendix B: Photographs comparing test results on new and aged panels painted with an oil-based alkyd paint. Figure 1. Results of stripping screening test on a new panel (1-month-aged) painted with an oilbased alkyd paint. Column 1 is Klean Strip Premium (methylene chloride based), Column 2 is Strip-X methylene chloride based (lower level), Column 3 is an experimental formula containing toluene, Column 4 is an experimental formula containing trans-l,2-dichloroethylene, Column 5 is an experimental formula containing 1,3-dioxolane and Column 6 is Citrus strip (contains NMP and DBE). Blue = 1st paint layer applied, White = 2nd paint layer applied, Green = 3rd paint layer applied, Yellow = 4lh paint layer applied, Red= last paint layer applied. Seeing Red = no layers of paint were stripped. 5 min 15 min 30 min 1 hr Sierra Club v. EPA 18cv3472 NDCA Attachments Prod 1 ED 002061 00042896-00018 Figure 2. Results of stripping validation test on an aged panel (1-year-aged) painted with an oilbased alkyd paint. Column 1 is Klean Strip Premium (methylene chloride based), Column 2 is Strip-X methylene chloride based (lower level), Column 3 is an experimental formula containing toluene, Column 4 is an experimental formula containing trans-l,2-dichloroethylene, Column 5 is an experimental formula containing 1,3-dioxolane and Column 6 is Citrus strip (contains NMP and DBE). Blue = 1st paint layer applied, White = 2nd paint layer applied, Green = 3rd paint layer applied, Yellow = 4th paint layer applied, Red= last paint layer applied. Seeing Red = no layers of paint were stripped. 1 2 3 4 5 6 5 min 15 min 30 min 1 hr Sierra Club v. EPA 18cv3472 NDCA Attachments Prod 1 ED 002061 00042896-00019 Figure 3. Results of stripping screening test on a new panel (1-month-aged) painted with an oilbased alkyd paint. Column 1 is Peel Away 1 (caustic based), Column 2 is Smart Strip (benzyl alcohol based), Column 3 is Smart Strip Pro (benzyl alcohol based with formic acid), Column 4 is EZ strip (DBE and triethyl phosphate), Column 5 Lift Off (acetone and 2-butoxy ethanol and DBE based) and Column 6 is Safer Paint Strip (DMSO and DBE based). Blue = 1st paint layer applied, White = 2ndpaint layer applied, Green = 3rdpaint layer applied, Yellow = 4thpaint layer applied, Red= last paint layer applied. Seeing Red = no layers of paint were stripped. ** Ingredients of competitive products cited from MSDS and/or GC analysis. 1 2 S 4 Sierra Club v. EPA 18cv3472 NDCA Attachments Prod 1 ED 002061 00042896-00020 Figure 4. Results of stripping validation test on an aged panel (1-year-aged) painted with an oilbased alkyd paint. Column 1 is Peel Away 1 (caustic based), Column 2 is Smart Strip (benzyl alcohol based), Column 3 is Smart Strip Pro (benzyl alcohol based with formic acid), Column 4 is EZ strip (DBE and triethyl phosphate), Column 5 Lift Off (acetone and 2-butoxy ethanol and DBE based) and Column 6 is Safer Paint Strip (DMSO and DBE based). Blue = 1st paint layer applied, White = 2ndpaint layer applied, Green = 3rdpaint layer applied, Yellow = 4thpaint layer applied, Red= last paint layer applied. Seeing Red = no layers of paint were stripped. ** Ingredients of competitive products cited from MSDS and/or GC analysis. 30 min 1 hr 4 hrs 24 hrs Sierra Club v. EPA 18cv3472 NDCA Attachments Prod 1 ED 002061 00042896-00021 Authors Matthew M. Petkus is the Director of Research and Development at W.M. Barr and is an expert in studying the product usage habits of consumers. During his career of working in the CPG industry, Matt has traveled and studied the consumer product usage habits in Argentina, Italy, Japan, UK, China, Germany, and in the USA. Most recently at W.M. Barr, Matt has participated in an ethnography study in the USA focused on observing consumer use habits of paint stripper products. Matt holds his PhD and Master's Degree in Chemistry from Arizona State University. Matt received his Bachelor of Science in Chemistry from the University of Wisconsin-Whitewater. Most recently, Matt received his Master's degree in Product Development and Design Management from Northwestern University. Timothy G. Teague is a Senior Research & Development Chemist at W.M. Barr and is responsible for developing new products for the consumer market. During his thirty-year career, he has worked as a Research & Development Chemist formulating new consumer and industrial products and as a Quality Assurance Chemist supporting manufacturing activities. As a Research & Development Chemist, he has formulated a wide range of new consumer and industrial products including coatings for exterior wood, kitchen cabinet stains, paint removers, thinners for coatings, and cleaning and other products. Tim has a Bachelor of Science in Chemical Engineering from the University of Arkansas at Fayetteville. Sierra Club v. EPA 18cv3472 NDCA Attachments Prod 1 ED 002061 00042896-00022