American Chemistry Council
EPARulemakingEPA-HQ-OPPT-2016-0231

Methylene Chloride and N-Methylpyrrolidone (NMP); Rulemaking under TSCA Section 6(a)

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Last modified
Mar 25, 2022
Comment window
closed 3357d ago
American Chemistry Council filings
2

Activity

American Chemistry Council filed 2 comments on this docket between May 16, 2017 and Jul 6, 2017. 24 other organizations filed here. The comment window closed 3357d ago.

What American Chemistry Council filed (2)

Jul 6, 2017· Comment submitted by Richard A. Starr and Brendan N. Mascarenhas, American Chemistry Council (ACC)· EPA-HQ-OPPT-2016-0231-0905

Comments from the American Chemistry Council on EPA's proposed risk management measures under section 6 of the Toxic Substances Control Act (TSCA) as amended by the Frank R. Lautenberg Chemical Safety for the 21st Century Act (LCSA) for certain uses of methylene chloride, also called dichloromethane (DCM), and N-methylpyrrolidone (NMP). ACC submits these comments in response to EPA's January 19, 2017 proposal to prohibit the manufacture, processing, and distribution in commerce of DCM and NMP for consumer and commercial uses in paint and coating removal. While EPA has improved its consideration of a range of options for some proposed risk management measures in this proposal, ACC has significant concerns that the use of analyses and assumptions unsupported by the best available scientific and economic data has led to proposed restrictions that create unnecessary burdens on regulated entities while yielding no substantial risk reduction.

May 16, 2017· Comment submitted by Michael P. Walls, Vice President, Regulatory & Technical Affairs, American Chemistry Council (ACC)· EPA-HQ-OPPT-2016-0231-0328

Filed on regulations.gov — full text not in the inline record.

Abstract

Section 6(a) of the Toxic Substances Control Act (TSCA) provides authority for EPA to ban or restrict the manufacture (including import), processing, distribution in commerce, and use of chemicals, as well as any manner or method of disposal. EPA identified methylene chloride and N-methylpyrrolidone (NMP) for risk evaluation as part of its Work Plan for Chemical Assessments under TSCA. Methylene chloride and NMP are used in paint and coating removal. In the 2014 TSCA Work Plan Chemical Risk Assessment for methylene chloride and the 2015 TSCA Work Plan Chemical Risk Assessment for NMP, EPA identified risks associated with commercial and consumer paint and coating removal with methylene chloride or NMP. EPA is proposing under section 6 of TSCA to reduce the risks from methylene chloride and NMP in paint and coating removal.

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