EPA Lautenberg Update – A Window of Opportunity

The EPA is further scrutinizing cleaning solvents trichloroethylene (TCE), perchloroethylene (PCE, tetrachloroethylene), methylene chloride (MC), n-methyl-pyrrolidone (NMP), and n-propyl bromide (nPB, 1-bromopropane). We discussed EPA actions in the February issue of Clean Source.  Now, the EPA has published new documents relating to these solvents and five other chemicals and has opened a comment period that ends July 26th.

Take action! Let the EPA know if you have a responsible, non-emissive process, including cleaning. The five chemicals are aggressive (that’s partly why they are useful for cleaning). They must be used responsibly. It’s not just the chemical – it’s the process. There are many ways to use the five chemicals – some pose little or no risk to people or the environment. The EPA ought to hear about those excellent processes so they can concentrate on the “bad actors.”  We give you an example of a good process, where to find the new documents, and where to make comments.

A good process
Here’s a totally fictitious example of what the EPA ought to hear about.  A forward thinking company (Unkoated Inc.) uses methylene chloride, to remove the coating from purple widgets for aerospace applications; and they use methylene chloride in a very non-emissive process. They have in fact invested in what we’ll call a “Total Lockdown Decoating System.” Unkoated Inc. has written, documented records indicating safe usage – things like solvent emissions, worker monitoring, releases to other parts of the manufacturing area and to the surrounding area, and process equipment design and maintenance.  They’ve looked at other chemicals for decoating with an astonishing lack of success.  The other chemicals turned the widgets a suspicious, fluorescent green. Even more disturbing, during tests of the green widgets, the engine wouldn’t start – the fighter jet just sat their, silently. The last straw was that the communications system only played the greatest hits of Milli Vanilli.  Unkoated Inc. was back to using methylene chloride. However, they figured out how to use it in a very non-emissive process.

Right now, during the comment period, is the magical moment for Unkoated Inc. to let the EPA know IN WRITING about their excellent cleaning process and their excellent chemical stewardship. They should should do this even if they have  written to the EPA in the past or talked to the EPA at a conference or have been featured as “Best Widget Company of 2015” in “Military Matters Magazine,”  because the EPA folks have tons of information to sort through – and they may have missed the article. The benefits to Unkoated Inc.  is that the information they provide  could be instrumental in having the EPA decide they don’t have to further investigate methylene chloride for decoating purple aerospace widgets, because the process is performed in a “Total Lockdown Decoating System.” The EPA gets an indication of which processes they may need to worry less about; the EPA can make more effective use of their resources.

The mechanics
Each chemical has a separate place for comments (a separate docket). We have included a table with links to these dockets. To make your comments relevant to what the EPA needs, read over the Scope and Problem Formulation documents. A “Scope of the Risk Evaluation” document for each chemical was published in 2017.  The “Problem Formulation of the Risk Evaluation” documents (the ones that opened this 45 day comment period) provide a mechanism to expand and extend the Scope documents. This sounds like two steps where one might do; the reason is that legislation required the EPA to act rapidly ( there was a deadline on issuing the 2017 documents).  The current EPA action and your input will let the EPA come up with a realistic picture of the way the chemicals are actually used. The “Problem Formulation” documents effectively recognize that more complete documents are needed. The Scope and Problem Formulation documents will eventually be combined.

The EPA has limited resources and is looking for guidance to allocate them where needed most. That is why they should be informed of any low risk applications so that those applications do not wind up getting swept up into a broad restricting document. By the way, if you have a non-beautiful process, this would be an excellent opportunity to find a better substitute (No! not just any substitute!) or to make the current process fabulous (safer, less emissive).

Table of links for  cleaning chemicals affected by recent EPA actions

 

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