EPA Proposals under TSCA Section 6: NMP and Methylene Chloride
Using their authority under Section 6, the EPA recently published a proposed rule seeking to prohibit the use of NMP and methylene chloride for consumer and commercial paint and coating removal, in addition to other restrictions.
For NMP, as an alternate proposal, the EPA is proposing that (1) commercial users of NMP for paint and coating removal establish a worker protection program for dermal and respiratory protection and not use paint and coating removal products that contain greater than 35 percent NMP by weight (except for product formulations destined to be used by DoD or its contractors performing work only for DOD projects); and (2) processors of products containing NMP for paint and coating removal reformulate products such that these products do not exceed a maximum of 35 percent NMP by weight, identify gloves that provide effective protection for the formulation, and provide warning and instruction labels on the products.
As we’ve mentioned before, solvents such as NMP and methylene chloride have been on the radar of several regulatory agencies due to concerns about health and safety risks for a long time.
The EPA’s recent proposal is yet another reason companies are looking to replace NMP and methylene chloride as soon as possible.
Fortunately, there are plenty of viable options available on the market.
When seeking a long-term cleaning solvent replacement for NMP or methylene chloride for compliance reasons, the obvious starting point is to find something that will quickly reduce environmental, health and safety risks.
The next step is usually sampling possible alternatives and testing performance parameters in a given application.
As a basic first step, industrial solvent end-users or formulators may want to focus on the following safety and regulatory aspects:
- No use of hazardous air pollutants (HAPs)
- Maximum flammability rating of Combustible Class IIIA, or NOS (seek flash points > 140 F)
- High Boiling Point (i.e. for heated cold cleaning applications)
- Low Vapor Pressure (if there are emission concerns or VOC compliance issues)
- Are there concerns or studies indicating that the substance is a potential carcinogen or reproductive toxin? Other health/toxicity concerns leading to reporting requirements or liability exposure?
- Reasonable, if any, exposure limits
- Not a RCRA listed or subject to RCRA hazarous waste
Using solvents, or aqueous formulations that contain solvents and other ingredients, will almost always involve some safety concerns.
It’s a matter of reducing these risks, and weighing the importance of specific safety concerns based on the application at hand.
But, if you are looking to transition from solvents such as NMP or methylene chloride, starting with the above general EHS parameters may put you in a better position to manage future safety and compliance hurdles.
The bigger challenge is to meet safety goals without sacrificing performance.
If you are looking for a partner to help you find a solution to replace NMP, methylene chloride or another solvent, feel free to contact us.