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.
Methylene Chloride and N-Methylpyrrolidone (NMP); Rulemaking under TSCA Section 6(a)
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)
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.
View on regulations.gov →Co-filers (24)
See everyone who commented →- American Chemistry CouncilTHIS ORG2 filings · confidence 97%
- Environmental Defense Fundtrade assoc.6 filings · confidence 97%
- American Coatings Associationtrade assoc.2 filings · confidence 97%
- Aerospace Industries Associationtrade assoc.1 filing · confidence 97%
- Chemical Users Coalitiontrade assoc.1 filing · confidence 85%
- Information Technology Industry Counciltrade assoc.1 filing · confidence 97%
- IPC - Association Connecting Electronics Industriestrade assoc.1 filing · confidence 85%
- Keller and Heckman LLP on behalf of TSCA Reform Rules Coalitiontrade assoc.1 filing · confidence 85%
- Lockheed Martin Corporationunverified attribution1 filing · confidence 70%
- Mass Comment Campaign sponsored by League of Conservation Voters (LCV) (web)trade assoc.1 filing · confidence 85%
- Massachusetts Chemistry and Technology Alliancetrade assoc.1 filing · confidence 85%
- National Association of Home Builderstrade assoc.1 filing · confidence 97%
- National Automobile Dealers Associationtrade assoc.1 filing · confidence 97%
- National Electrical Manufacturers Associationtrade assoc.1 filing · confidence 85%
- Natural Resources Defense Council (NRDC)trade assoc.1 filing · confidence 97%
- Rapid Blanket Restorer Corporationunverified attribution1 filing · confidence 70%
- Rubber Manufacturers Associationtrade assoc.1 filing · confidence 97%
- S.D. Warren Company d/b/a Sappi North Americaunverified attribution1 filing · confidence 70%
- Savogran Companyunverified attribution1 filing · confidence 70%
- Semiconductor Industry Associationtrade assoc.1 filing · confidence 97%
- Silent Spring Institutetrade assoc.1 filing · confidence 85%
- The Fertilizer Institutetrade assoc.1 filing · confidence 97%
- Toxics Use Reduction Institutetrade assoc.1 filing · confidence 85%
- W. M. Bar & Companyunverified attribution1 filing · confidence 70%
- W. M. Barr & Companyunverified attribution1 filing · confidence 70%