Product manufacturing and product cleaning is like surfing on a Tsunami. It takes courage, intelligence, planning, and knowing the right time to act. How do you surf on a Tsunami? First, be aware that it exists. Next, figure out if it is heading toward your company, directly or indirectly. Many tsunamis and impending tsunamis threaten to engulf manufacturing.
Moderate or Ginormous?
In the United Stated, one looming issue, emanating from the U.S. EPA, is referred to as TSCA reform, amended TSCA, new TSCA, or Lautenberg. In a recent linkedIn post, I commented that while the EPA proposal to list n-propyl bromide as a Hazardous Air Pollutant is like a rip tide (thanks, Miles Free, for the heads-up about the impending HAP listing), the EPA TSCA determination of unreasonable risk to workers from nPB and other chlorinated solvents is like a Tsunami.
Unreasonable risk
Under amended TSCA, EPA conducted risk evaluations for cleaning solvents n-Propylbromide (1-bromopropane), carbon tetrachloride, methylene chloride, n-methylpyrrolidone (NMP), perchloroethylene, and trichloroethylene. EPA determined there to unreasonable risks to workers for many manufacturing applications. Notice that this list includes chlorinated and brominated solvents of interest to product manufacturers.
On the horizon, EPA is in the process of a risk evaluation for trans-DCE. Trans-DCE is the solvent that is the active ingredient in designer solvent blends. Will this turn into a tidal wave? We don’t know for sure. However, in our experience, if a chemical is active in removing soil, there is the potential for it to impact biological systems.
What me worry?
Yes, you!
There’s a stigma to using certain solvents, particularly ones that some regulators refer to as “Bad Actors.” I have never heard a molecule of perchloroethylene intone “Out! Out! Damn spot!”
Manufacturers may use halogenated solvents because their chemical and physical properties do an excellent job of removing soils. Because some solvents have been declared to be “evil,” manufacturers go into a sort of denial. They may claim they use a little water, a little alcohol, a little acetone.
Solvents? We hear assertions, sometimes from large trade associations, that none of their members use chlorinated or brominated solvents. This flies in the face of reality. The Rocket Scientist and I repeatedly observe chlorinated and/or brominated solvents used to augment a process, but not acknowledged.
Perhaps you have a successful cleaning process using what are currently referred to as “good” or “environmentally preferred” cleaning agents. You look around the facility and find no hidden degreasers, no drums of perchloroethylene or nPB, just low-VOC aqueous cleaners. Can you stop worrying? Maybe. Check the upstream supply chain. Do your suppliers depend on more aggressive cleaners? Find out now, not later.
Immediate activities
Do not wait until you can see the Tsunami. If you depend directly or indirectly on the cleaning efficacy of chlorinated or brominated solvents, there are actions to take now, before any use restrictions, phaseout or solvent ban.
Understand what clean looks like to you and your customers. Figure out what might damage the materials of construction and understand the steps to avoid this damage.
Investigate alternative options. This is particularly important if Corporate, or a customer, or the military hands you a long list of supposed substitute cleaning agents. Investigate what it will take to change the cleaning process. Changing a cleaning process is itself a complex process, one that involves far more than selecting chemicals and equipment.
If a sales rep says “don’t worry, just send me some parts, and we’ll take care of deciding on a new process,” it’s prudent to worry. By all means, listen to what people have to say about cleaning performance; but take it all under advisement. You and your cleaning team are in the best position to decide what’s right for your product and for your manufacturing environment.
We don’t know when the Tsunami will appear. We do know that taking a serious look at alternative processes will allow your manufacturing facility to achieve optimal cleaning and optimal productivity.
We’re in for stormy seas
BFK Solutions can help you navigate. In upcoming editions of “How to Surf on a Tsunami, we will update you on upcoming rules and regulations, as they take definitive form. We will provide a close, critical look at alternative technologies. Many of them are promising. All require investment in testing, evaluation, and (for most) new equipment.
