‘Tis the season to be brave – to get educated, to speak up, to consider your critical cleaning options, to strategize.
The U.S. EPA, under what is sometimes referred to as TSCA reform, is looking not only at the environmental impact of certain chemicals but also at worker exposure. As a consequence, the EPA may heavily regulate and even ban many uses for a number of halogenated solvents (chlorinated and brominated). Actions are likely to impact critical and precision cleaning – and therefore production – for manufacturers throughout the U.S.
The first group of chemicals being evaluated includes methylene chloride, n-propyl bromide (1-bromopropane), and the two featured in this article: trichloroethylene (TCE), and perchloroethylene (PCE). The next group of chemicals will include trans-1,2-dichloroethylene (trans-DCE).
If you think the EPA always moves very slowly – think again.
Immediate: TCE
The EPA published the risk evaluation for TCE in November 2020. They found unreasonable risk to “workers and occupational non-users” for many manufacturing activities – including cleaning/vapor degreasing.
The EPA is accepting nominations (including self-nominations) for the trichloroethylene (TCE) Small Business Advocacy Review (SBAR) panel. The deadline for self-nomination is December 14, 2020. For general background, consider joining the webinar on December 15. Both the SBAR and webinar can be accessed via this link
https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/risk-management-trichloroethylene-tce
Get involved! Benefits of being on this panel include the opportunities provide input to the EPA and to gain valuable insight into what may happen next. The SBAR Panel is for small businesses. If you are a small business, if your supply chain involves small manufacturers, we suggest you become involved. Working through your professional organization may allow one individual to be the focal point for many small businesses.
Next: PCE
The risk evaluation for perchloroethylene (PCE, tetrachloroethylene) is expected to go public before the end of the year 2020. That’s only a few weeks away! Once it is released, there will probably be an SBAR panel and public webinar announcement for PCE within the following few weeks as well.
Ideas and Translations
The more you understand about new and impending regulations, the more you understand the thought process and rationale, the better you will be at making sure you have effective critical cleaning options.
It seems to me that governmental regulatory agencies and manufacturers speak different languages. While I have not found an online dictionary, I am becoming increasingly fluent in both languages and in moving between the two. If you have questions, please give me a call. I know we have some great ideas for critical cleaning!
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