KNOWLEDGE IS POWER

Find and comment on the proposed 1BP rule; read what others are saying

The public has until September 23 to comment to the EPA. The proposed rule to manage n-Propyl Bromide (nPB) has been published in the Federal Register. Notice that EPA uses the term 1-BP rather than nPB. As part of the manufacturing community, meaning if you use nPB, or methylene chloride (MC), or trichloroethylene (TCE) or perchloroethylene (PCE) in degreasing, cleaning, or key process fluids or if you provide cleaning equipment, consider commenting on the nPB rule. As indicated in the feature article, nPB is treated very differently than the chlorinated solvents. 

We suggest that manufacturers first comment on nPB and then ALSO comment on other chlorinated solvents impacted by EPA, even if the comment period for those solvents is past, even if a final rule for that solvent has been issued. The rule may be cast in concrete, However, our interpretation of comments in the proposed nPB rule indicate that mushy concrete may be more the case. As of August 31, 2024, the only final rule is for MC. 

Here are “Winnie the Poo” instructions. Brilliant, computer-comfy people are confused by complex web pages. Many find terminology used by regulatory agencies to be daunting. 

To get to the rule, go to the docket.

https://www.regulations.gov/docket/EPA-HQ-OPPT-2020-0471/document 

Once you are on that page, find the “docket documents” tab. The first item is the Proposed Rule; click on it to open the rule in text format. To download a PDF version of the rule, go to the very bottom of the proposed rule and click the download button.

From the same page, you can also access support documents from the EPA and comments made by others. 

To submit comments
You can submit written comments to the EPA through Sept 23, 2024. Once accepted and posted, your comments are public.

At the top, just below the Title “1-Bromopropane (1–BP); Regulation Under the Toxic Substances Control Act (TSCA)”, is a button labeled “Comment.” Click on the button to open the Comment document. The comment window is best considered as a summary of your thoughts, because it has only a 5000-character limit. Make those thoughts clear, compelling, and incisive; think of it as like speed dating or an elevator speech. Your more complete comments can be added as attachments (each <10Mb). 

Effective comments
EPA is far more likely to read comments if they are written by you or by a representative of your organization. Way back in the day, we used to think that EPA weighed comments instead of reading them. Not true! It stands to reason that pro-forma, cloned, generic information supplied by a trade group or lobbyist are likely to be met with glazed eyeballs if not gentle snoring. We find data and clear evidence of success to be more compelling than assertions of product performance or disparaging comments. 

Comments have to come from you; we can’t submit them. Many of you have called to bounce ideas off us. Some have asked us to look over written comments. We expect this, because we write, teach, and edit. We co-edited two editions of the “Handbook for Critical Cleaning.” The Cleaning Lady minored in English literature and economics. Depending on our other time constraints, we are happy to help. Give us a call!

Hear BFK Solutions at Parts Cleaning Conference

BFK Solutions will present “Understand and Address the Regulatory Landscape” on September 10 at the Chicago Parts Cleaning Conference, held in conjunction with IMTS2024. Whether you are involved in metal finishing, electronics, optics, medical devices, or aerospace/aeronautics, impending EPA regulations could hamstring critical product cleaning.

Don’t let performance take a back seat. Using our experience working with the private, military and regulatory sectors and observations of current regulatory approaches, we will outline options for critical cleaning that let you stay in business and thrive. Come to our program; let’s catch up!

View Agenda

Aqueous Cleaning On-Demand Course – Make your team brilliant!

Critical cleaning isn’t taught in college or in most training programs. Not to worry! Sign up for our Product Quality Cleaning Workshop on-demand program. Lee Rensberger, Manufacturing Engineer of Industrial OEM Components, took the course. He also signed up his tech who was “blown away with the amount of information provided. He no longer thinks in terms of just proper chemical mixture, process time, and minimal required process temperatures, but what actually happens at the molecular level… most importantly - whether or not the process is performing to the level of cleanliness required by the customer. He wants to understand the science behind the cleaning!” Have your team take the course. Be brilliant!

For more information and to register