The proposed ban on nPB that was added late into the Philadelphia "Proposed Air Regulation XIV, Control of Perchloroethylene from Dry Cleaning Facilities," dated June 24, 2010 was brought into question at the public hearing on August 12 in Philadelphia, PA.  Over 75 dry cleaners and interested persons were in attendance at the hearing and presented a wide array of concerns with the proposed regulations and made excellent points about its economic viability and enforceability.  Regarding the nPB issue, world renowned toxicologist, board member of Cal OEHA, and expert on the main chemical ingredient of DrySolv (n-propyl bromide), Dr. Mark Stelljes, was in attendance and discussed in detail the factual errors and omissions inherent in the claims made in the Adam Finkel report entitled "Increased Toxicity and Carcinogenicity of n-Propyl Bromide (1-Brompropane) Relative to Perchloroethylene."  Dr. Stelljes has authored a White Paper for Philadelphia on nPB in direct response to the claims made in the Finkel (2010) report, which contains egregious errors and inconsistencies, and displays a lack of understanding of the science and mathematics of toxicology.  

The factual errors and omissions in the Finkel report are discussed in detail in the White Paper, however here is a brief summary of the major points:

1. The inhalation LC50 values reported by Finkel are incorrect.  The true values stand in stark contrast to the claims made by Finkel (2010).
2. The summary of a particular report, Ichihara et al. (2004a) is incomplete and misleading.
3. The summary of Majersik et al. (2007) is inaccurate.
4. The summary of Raymond and Ford (2007) report is incomplete.
5. The summary of the CDC (2008) case study in NJ is incomplete and misleading.
6. The summary discussion "lacks basic understanding of dose-response relationships, which are the underpinning of the entire discipline of toxicology."
7. The summary of reproductive toxicity is outdated and inaccurate.
8. The summary of the carcinogenic potency of nPB is only speculative and not based on actual reviewed data.
9. One of the paragraphs in the conclusion is inaccurate in its claim about the safety of nPB
10. The conclusions made by Finkel (2010) are "unsupportable based on the weight of the scientific literature on nPB and PCE."

It is unclear at this time what position Philadelphia will take on the proposed ban on n-propyl bromide, however the comments and questions, including those from the Dr. Stelljes White Paper, will be published by the Philadelphia Air Management Board in response to the public hearing.  In addition to these, many other interesting points were raised by those in attendance. 

Several local drycleaners raised the issue concerning the cost of purchasing new machinery to run other chemistries in this economy.  Ray Roccon of Enviro Tech International pointed out that the cost of electricity in Philadelphia is due to increase once a moratorium on rate increases lapses in December of 2010.  The costs of electricity for drycleaners will then increase by roughly 20-30%.  Ray also said that by using DrySolv, dry cleaners can actually reduce their overall utility consumption by at least 30% or more due to its energy efficiency benefits and reduced steam pressures and cycle times.  Richard Morford, also of Enviro Tech International, presented a case to the board members pointing out that they have been reviewing available data on Perc since 2007 in order to develop this proposed rule, and yet they had only reviewed n-propyl bromide since February of 2010 and only reviewed the Finkel (2010) report in deciding to propose a complete ban on nPB.  Rich also pointed out that while Finkel had cited only 3 studies, that there are well over 150 peer reviewed, published studies available on nPB that were not cited or even reviewed.  The Dr. Stelljes White Paper addresses these omissions and errors in greater detail.

For more detail, please refer to the Dr. Stelljes White Paper.