In proposed rules published May 3, the EPA proposed banning most uses of dichloromethane, also known as dichloromethane, a common solvent and processing aid. It is used in a variety of consumer and commercial applications, including adhesives and sealants, automotive products, and paint and coating removers. The chemical is produced in large quantities – between 100 million and 500 million pounds between 2016 and 2019, according to the Chemical Data Report (CDR) – so a ban, if passed, would have major implications for many industries. A huge impact. department.
        The EPA proposal addresses “an unreasonable risk of harm to human health from dichloromethane under conditions of use, as documented in EPA risk definitions under the Toxic Substances Control Act (TSCA)”. or the environment identified in the TSCA risk assessment and apply the requirements to the extent necessary so that the chemicals no longer pose an unreasonable risk.
        In addition, the EPA’s proposed rule requires a Chemical Workplace Protection Plan (WCPP), which includes requirements for compliance with inhalation concentration limits and exposure monitoring for certain conditions of continuous use of dichloromethane. It will also impose record keeping and downstream notification requirements for several conditions of use and provide certain time-limited exceptions to use requirements that could cause serious harm to national security and critical infrastructure.
        Companies that manufacture, import, process, commercially distribute, use or dispose of methylene chloride or products containing methylene chloride could potentially be affected by the proposed rule. The proposed rule lists more than 40 different categories of industries that may be subject to the law, including: wholesale of chemicals; oil loading terminals and terminals; production of basic organic and inorganic chemicals; disposal of hazardous waste; enterprises for the processing of materials; paints and paints. manufacturers; plumbing and air conditioning contractors; painting and wall cladding contractors; auto parts and accessories stores; production of electrical equipment and parts; production of welding and soldering equipment; dealers of new and used cars; dry cleaning and laundry services; as well as dolls, toys and games. production.
        The proposed rule does state that “Approximately 35 percent of annual methylene chloride production is used for pharmaceutical purposes and is not subject to or regulated by the TSCA.” )( B) Any substance other than the definition of “chemical” in paragraphs (ii)-(vi). These exemptions “include … any food, dietary supplement, drug, cosmetic, or device, as defined in Section 201 of the Federal Food, Drug, and Cosmetic Act, that is manufactured, processed, or traded as food, food supplement, drug, cosmetic or device…”
        For those industries that may be affected by this ban, it is important to start thinking about alternatives. EPA’s evaluation of alternatives to the use of methylene chloride identified alternatives for a variety of applications such as adhesives, sealants, degreasers, paint and coating removers, sealants, and lubricants and greases. However, it should be noted that no alternatives to technological additives (including) were found. The evaluation of alternatives “does not recommend products that should be used in place of dichloromethane; rather, its purpose is to provide a representative list of alternative products and chemicals and their hazards compared to dichloromethane, in order to provide screening for potential alternatives. The results are considered part of the TSCA Section 6(a) dichloromethane rule.” Comments on the proposed rule must be received no later than July 3 and are available through the federal electronic rulemaking portal at https://www.regulation.gov.
       Disclaimer: Due to the general nature of this update, the information provided here may not apply in all situations, and should not be acted upon without specific legal advice based on your particular situation.
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