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Unreasonable Risk: What Does The EPA Say?

Originally Published: July 26, 2021 | Last Updated: December 19, 2023 | Contributor: Jeff Beard (Fmr. President of Manufacturing Cleaning Association)

Like many manufacturing sites today in the US, there is a good chance your company is using vapor degreasing as your parts cleaning method. For many, their facility does not have someone dedicated to watching for changes from the EPA. Ladies and gentlemen if your site is using 1-bromopropane (nPB), Trichloroethylene (TCE), or Perchloroethylene (Perc), I recommend that you or someone begin to watch. The EPA has a lot going on, and its only just begun.

Within the past year the United States Environmental Protection Agency (EPA) has ruled that the use of 1-bromopropane (nPB), Trichloroethylene (TCE), or Perchloroethylene (Perc), as a vapor degreasing solvent, is an unacceptable risk to humans. Under the Toxic Substances Control Act (TSCA), the EPA is required to evaluate the risks associated with exposure to existing chemicals in commerce using the best available science, and then take action to address any unreasonable risks identified.

In August 2020, the EPA released the final risk evaluation for 1-BP (nPB). The final risk evaluation identifies unreasonable risks to workers, occupational non-users, consumers, and bystanders from 1-BP exposure under 16 out of 25 conditions of use.

The EPA completed the final risk evaluation for TCE under amended TSCA in November 2020. The final risk evaluation for TCE determined that there are unreasonable risks to workers, occupational non-users, consumers, and bystanders for 52 out of 54 conditions of use.

The EPA completed the final risk evaluation for perchloroethylene and determined that there are unreasonable risks to workers, occupational non-users, consumers, and bystanders from 59 out of 61 conditions of uses.

If you choose to read the risk assessment for each product you will find hundreds of pages of documentation supporting the EPA’s finding. While there will be naysayers, I believe the EPA has taken a stance that requires all users of these solvents to begin the “what if scenarios”. To those that may say “this is where it ends with no further action”, sorry, the EPA conducts risk evaluations for chemicals under the Toxic Substances Control Act (TSCA), as amended by the Frank R. Lautenberg Chemical Safety for the 21st Century Act. In other words, there is law/statute in place requiring the EPA to follow specific guidelines to the end, whatever the end may be.

While the EPA has taken hard line stances in the past on chemicals used for various industrial applications, few were as widely utilized, across a broad range of end user products as these 3 solvents.

There was one solvent however, that was as widely used, at least back in the day. Many of you do not know of it or remember the EPA action because it happened many years ago. Leading up to the last memorable action like this the EPA also used TSCA. In 1976, under the Toxic Substances Control Act (TSCA), the EPA banned commercial manufacturing and use of CFCS and aerosol propellants. This was later superseded by broader regulation by the EPA under the Clean Air Act to address stratospheric ozone depletion. At that time, the most popular vapor degreasing solvent was CFC-113, banned from many of the same uses listed in the recent EPA risk assessments. How many of you remember that? Probably not many.

Yes banned! That is a very real conclusion that the precision cleaning industry needs to come to grips with. The very real possibility that the EPA can use the statute in place to ban the 3 most readily used vapor degreasing solvents.

My industry experience dates back to the time when I sold CFC-113 for vapor degreasing. If nothing else, I hope you at least ponder and consider, “what will we do if this is banned”.

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