From: Dan Nowlan <dnowlan**At_Symbol_Here**BERRYMANPRODUCTS.COM>
Subject: Re: [DCHAS-L] EPA Proposes to Limit the Use of Two Toxic Chemicals in Paint Removers.
Date: Fri, 13 Jan 2017 15:24:01 +0000
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: 96B01B2E9C84674ABE1BA48CDA33910303192B66F2**At_Symbol_Here**BPMAIL.bpi.local
In-Reply-To <2F5FC80A-542D-49C6-9DE8-C88B85DD077B**At_Symbol_Here**>

Long-time listener, first-time caller here.

I've been watching these EPA proposals closely for a while because they directly affect one of our products, an aerosol paint stripper based on DCM. However, we also have two nonflammable aerosol degreasers based on trichloroethylene, which is also under TSCA scrutiny. I understand the health concerns of the chemicals in question here and don't feel the need to dwell on them. What I don't understand is what EPA expects us formulators to replace these components with, especially in the cast of TCE. I don't see how you can remove tools from the toolbox when there are in some cases really are not suitable replacements.

DCM and NMP are used in paint strippers because they work. There may be some alternatives to these two chemicals that exhibit modest efficacy'things like high-MW esters (high because they'll need to have low vapor pressures to qualify for the LVP VOC exemption that consumer products enjoy)'but that doesn't mean that end users will be happy with them. Moreover, in the case of TCE, there is IMO just one relatively suitable replacement, perchloroethylene, which is almost certainly going to encounter the same host of actions...and sooner rather than later.

The whole reason that aerosol degreasers, especially energized electrical cleaners, make use of TCE in the first place is because it's truly just about the only nonflammable chemical with a high enough KB that evaporates quickly. Sure, there are a couple other chlorinated solvents that meet those criteria, including DCM and perc. However, DCM is often a bit too aggressive for older/sensitive wire insulation, and perc just doesn't dry fast enough for some applications. TCE has the benefit of higher electrical resistance than perc, too, a property that is critical in energized applications. So yes, we can use perc in place of TCE...but only until EPA bans that, too. Then we'll either start seeing exotic (and pricey to ridiculously price) HFC blends that don't work very well or we'll hear about people using flammable cleaners in energized applications. I'll let you do the math on the latter scenario.

Honestly, I'm not really sure why I've written all this. I don't see that I've posed any questions for the group. Perhaps I'm just frustrated and venting a little. That said, congratulations for making it down this far! I probably would have stopped reading already. Happy Friday!

Best regards,

Dan Nowlan
Chemist, R&D
Berryman Products, Inc.
(817) 640-2376, ext. 147

-----Original Message-----
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Stuart, Ralph
Sent: Friday, January 13, 2017 6:49 AM
Subject: [DCHAS-L] EPA Proposes to Limit the Use of Two Toxic Chemicals in Paint Removers.

The U.S. Environmental Protection Agency (EPA) is proposing to place limits on the use of two common chemicals in paint removers in order to protect consumers and workers from serious health risks associated with this use. The chemicals are methylene chloride and N-methylpyrrolidone (NMP).

Under the new toxic chemicals law passed in June, EPA now has a legal mandate to restrict chemicals already in commerce that pose unreasonable risks to public health and the environment. There are many cases of people who have become ill or even died as a result of exposure to methylene chloride-containing paint removers. Today's action, when finalized, will save lives and protect people from other serious health risks, including cancer and developmental effects.

EPA, in a 2014 assessment, concluded that methylene chloride can cause a range of adverse health effects, including harm to the central nervous system, liver toxicity, and cancer. EPA is now proposing to prohibit manufacture (including import), processing, and distribution in commerce of methylene chloride when used as a paint remover, except for commercial furniture refinishing which the Agency will address in a separate proposal. EPA is also proposing to require manufacturers, processors, and distributors to notify retailers and others in their supply chains of the prohibitions.

EPA assessed NMP in 2015 and identified risks to people, particularly pregnant women and women of childbearing age, who have high exposure to NMP through paint or coating removal. EPA is inviting comments on two approaches to address the risks from NMP. One approach would prohibit manufacture (including import), processing, and distribution in commerce of NMP when used as a paint remover, as well as require various notification measures on the restrictions to downstream processors and users. The other approach would put in place a combination of requirements to address unreasonable risks, including limiting the amount of NMP in paint remover products, providing warning labels for consumers, and requiring workers to wear specialized gloves and other equipment. EPA is seeking comment on both approaches. In addition, EPA is proposing to exempt certain national security uses of methylene chloride and NMP from the requirements of this rule.

Comments on the proposed rule must be received 90 days after date of publication in the Federal Register. Once published, the proposed rule and supporting documents will be available in the Federal Register docket at: by searching for HQ-OPPT-2016-0231.

This e-mail is from DCHAS-L, the e-mail list of the ACS Division of Chemical Health and Safety.
For more information about the list, contact the Divisional secretary at secretary**At_Symbol_Here**

This e-mail is from DCHAS-L, the e-mail list of the ACS Division of Chemical Health and Safety.
For more information about the list, contact the Divisional secretary at secretary**At_Symbol_Here**

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