On May 10, 2018, the Environmental Protection Agency (EPA) announced it would soon finalize a proposed ban on the use of methylene chloride and N-methylpyrrolidone (NMP) in paint stripping products. This action comes years after the EPA included both chemicals in its December 2016 list of the top 10 chemicals to be evaluated under the ongoing Toxic Substances Control Act (TSCA) reform.
A Little Background
Methylene chloride, also known as Dichloromethane (DCM), is a widely-used solvent (estimated use at over 260 million pounds per year) in a variety of industries and applications, including adhesives, pharmaceuticals, chemical processing, aerosols, and paint and coating products. The volatile chemical has recently been in the news due to its associations with potential health risks in humans, including possible harm to the central nervous system after short-term exposure, and potential for liver toxicity, liver cancer, and lung cancer after long-term exposure to the chemical.
On January 19, 2017, the EPA issued a proposed rule under Section 6(a) of the TSCA, as amended by the Frank R. Lautenberg Chemical Safety for the 21st Century Act, to prohibit the manufacture, processing, and distribution of methylene and NMP for most type of commercial paint and removal products. Now, the EPA has signaled it will continue to advance a rule to regulate consumer and worker use of the chemicals.
Does This Action Affect Me?
The proposed ban on methylene chloride may apply to you if you manufacture, process, distribute, or use methylene chloride or NMP for paint stripping. Chemical and allied products manufacturers, aircraft manufacturers, flooring contractors, and painting and wall covering contractors are among the potentially affected entities for the proposed rule. The ban will also affect facilities with in-house paint booths, which will now require to identify and source alternate paint stripper chemicals.
What It Means
The new rule will require manufacturers (including importers), processors, and most distributors of methylene chloride and NMP to provide extensive notification for downstream uses, and will require recordkeeping. Although banned for paint stripping, methylene chloride will still be allowed to be used for certain furniture stripping applications, refinishing by professionals and commercial workers, and for uses related to national security. Many retail stores are voluntarily pulling products containing the chemicals from their shelves.
Facilities that currently use methylene chloride for paint stripping should remove the chemical from their shelves and explore alternative non-chlorinated chemicals appropriate for their applications. For example, paint-stripping compounds with a benzyl alcohol base are also effective at removing paint, even though they may take longer to complete the stripping.
Contact our professionals with questions about the EPA’s methylene chloride directive and which steps you should be considering now.
Rajib Sinha, P.E.
Regional Initiatives Manager