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EPARulemakingEPA-HQ-OPPT-2016-0231

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

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Mar 25, 2022
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closed 3357d ago
American Coatings Association filings
2

Activity

American Coatings Association filed 2 comments on this docket between May 16, 2017 and May 25, 2017. 24 other organizations filed here. The comment window closed 3357d ago.

What American Coatings Association filed (2)

May 25, 2017· Comment submitted by David Darling, Vice President, Health, Safety, and Environmental Affairs, American Coatings Association (ACA)· EPA-HQ-OPPT-2016-0231-0337

Please find attached comments from the American Coatings Association (ACA) In summary, ACA suggests that the proposed rule is fundamentally flawed since EPA's proposal to ban MeCl2, and either ban or significantly restrict the use of NMP, will devastate industries and force consumers to choose between alternatives that are less effective; that can present health and environmental risks (that EPA has not assessed and underestimated); and that are more costly to use. It is very important to note that not only is EPA proposing to ban the most effective paint stripper available in the market - MeCl2, but also ban or significantly restrict the use of arguably the best replacement for MeCl2 - NMP. Further, this proposal would duplicate regulations that are already in place, and therefore is not needed. The proposal also relies on scientifically and procedurally flawed risk assessment that violates Office of Management and Budget ("OMB") guidelines for major scientific rulemakings. EPA should withdraw this flawed proposal, and consider instead a more effective regulatory approach based on improved labeling and consumer education. ACA appreciates that EPA has included a second option for NMP that would allow continued use with requirements for labeling and PPE: however while ACA supports this option, ACA does not support the 35% by weight standard for reformulations. Respectfully Submitted, /s/ David Darling, Vice President, Health, Safety, and Environmental Affairs

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May 16, 2017· Comment Submitted by David Darling, Vice President, Health, Safety, and Environmental Affairs, American Coatings Association (ACA)· EPA-HQ-OPPT-2016-0231-0327

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

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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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Co-filers (24)

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