Volume XIV, Issue 2 - February 2017

In this issue:

Regulatory Alert--EPA Ban on Industrial Solvents?

Upcoming Course: Quality Critical Cleaning and Cleaning Validation

Feature -- Too Much of a Good Thing

I have read your book “Handbook of Critical Cleaning” and it has helped me a lot designing a solvent cleaning system for us. Surface cleanliness is the number #1 challenge for us. The book helped me tremendously to design and develop an efficient cleaning process. 
Santosh Kumar Tiwari, PhD
Sr. Materials Engineer, Advanced Technology Development
Varex Imaging

Regulatory Alert

EPA Ban on Industrial Solvents?

Barbara Kanegsberg, BFK Solutions LLC

Backed by recently enacted Federal legislation with strong bi-partisan support, the U.S.  EPA is proposing to ban the use of trichloroethylene in vapor degreasers; and the EPA may propose bans on other solvents used in critical cleaning including N-methyl pyrrolidone (NMP), 1-bromopropane (n-propyl bromide), and perchloroethylene (PCE).

The EPA will hold a public meeting on risks associated with use of the chemicals on Tuesday February 14th.You can arrange to attend remotely on-line.

For more information:

February 14th public meeting: (Register by February 10) https://www.federalregister.gov/documents/2017/01/19/2017-01236/risk-evaluation-scoping-efforts-under-tsca-for-ten-chemical-substances-notice-of-public-meeting

Proposed TCE ban: https://www.federalregister.gov/documents/2017/01/19/2017-01229/trichloroethylene-tce-regulation-of-use-in-vapor-degreasing-under-tsca-section-6a

Relatively Painless Cleaning Validation March 6 – 8, Burlingame, CA

Cleaning validation is a source of discomfort, particularly for those in medical device manufacture, pharma, and food. It’s not surprising. With all the attention focused on design, formulation, and product development, cleaning and scaling up the cleaning process to production level may be treated as an afterthought. Before diving into a cleaning validation, you need to achieve cleaning validation readiness -  combine your thoughtfully-designed product with reliable, defendable critical cleaning processes.

If you missed our course last autumn, Ed and Barbara Kanegsberg will present “Quality Critical Cleaning and Cleaning Validation Processes,” a 3 day certified CfPA course that helps lower your stress level by getting you up to speed on critical cleaning, surface analysis, standards, and regulatory issues. To register http://www.cfpa.com/CourseDescription/CourseDescription?Offering=170306CA1867&CourseID=1867

Feature Article

This month we are reprising a feature that appeared in Clean Source in  August 2013.

Too Much of a Good Thing

“All things are poison, and nothing is without poison; only the dose permits something not to be poisonous.”

This 16th Century statement by Paracelsus states that at some level there can be too much, even of a good thing. Here are 8 examples where “more” is not better for critical cleaning; where “more” can waste money and compromise product quality.

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About BFK Solutions

We’re independent. We don’t sell chemicals or cleaning equipment; and we don’t take commissions. Instead, we work for you. This saves you cold hard cash. We use our 30 years of experience to help you make good decisions about your cleaning processes, your manufacturing processes, your business. Check our website; send us an email; give us a call. We always like to hear from you.