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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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Last modified
Mar 25, 2022
Comment window
closed 3357d ago
Environmental Defense Fund filings
6

Activity

Environmental Defense Fund filed 6 comments on this docket between Apr 10, 2017 and May 21, 2018. 24 other organizations filed here. The comment window closed 3357d ago.

What Environmental Defense Fund filed (6)

May 21, 2018· Mass Comment Campaign sponsored by Environmental Defense Fund (EDF) (email). Sample attached· EPA-HQ-OPPT-2016-0231-0922

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

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May 21, 2018· Mass Comment Campaign sponsored by Environmental Defense Fund (EDF) (email). Sample attached· EPA-HQ-OPPT-2016-0231-0923

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

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Jul 10, 2017· Comment submitted by Lindsay McCormick, Chemicals and Health Project Manager on behalf of Environmental Defense Fund (EDF)· EPA-HQ-OPPT-2016-0231-0912

Comments submitted by Lindsay McCormick, Chemicals and Health Project Manager, on behalf of Environmental Defense Fund.

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Jul 10, 2017· Mass Comment Campaign sponsored by Environmental Defense Fund (EDF) (web)· EPA-HQ-OPPT-2016-0231-0917

To Whom It May Concern: Attached is a document containing the signatures of 33,363 Environmental Defense Fund supporters from across the country who have submitted electronic comments regarding EPA's Regulation of Certain Uses under Toxic Substances Control Act: Methylene Chloride and N-Methylpyrrolidone. The comment they each submitted reads: "I'm writing today to strongly urge EPA to finalize its rules to ban high-risk uses of trichloroethylene (TCE), methylene chloride (DCM), and N-methylpyrrolidone (NMP) under the new Toxic Substances Control Act (TSCA). These chemicals are extremely toxic. TCE is carcinogenic and can cause heart defects in the developing fetus. DCM is a very lethal chemical over the past few decades, dozens of workers have died from using DCM-based paint stripping products. NMP is often used as a substitute for DCM in paint stripping products, yet it also presents major health risks ranging from developmental and reproductive toxicity to neurotoxicity to liver and kidney damage. EPA had not successfully banned a chemical under the original TSCA in nearly three decades. Now, with its greater authority under the new TSCA as amended by the Lautenberg Act, EPA can score an early public health victory by banning these toxic chemicals for these high-risk uses. But the chemical industry is complaining and pressuring EPA to back off, delay, or weaken these much needed rules. Some in industry are suggesting that measures like putting a simple label on these deadly products or requiring workers to wear protective gear would suffice. But labels, personal protective equipment, and concentration limits are not enough to protect my family and community. I strongly urge the Agency to stay on track and promptly ban TCE used as a spot cleaning agent in dry cleaning, as an aerosol spray degreaser in commercial and consumer settings, and as a vapor degreaser in commercial settings, and both DCM and NMP used for commercial and consumer paint stripping. Safer alternatives are already widely available. There is simply no excuse to continue putting my family's and my community's health at risk by delaying or weakening these rules." Please let me know if you have any additional questions or concerns about this submission. Thank you for your consideration, Heather Shelby Manager, Grassroots Organizing & Activism Environmental Defense Fund hshelby@edf.org

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Jun 6, 2017· Mass Comment Campaign sponsored by Environmental Defense Fund (EDF) (email)· EPA-HQ-OPPT-2016-0231-0438

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

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Apr 10, 2017· Comment submitted by Jennifer McPartland, PhD, Senior Scientist and Richard Denison, PhD, Lead Senior Scientist, Environmental Defense Fund (EDF)· EPA-HQ-OPPT-2016-0231-0303

Letter from Environmental Defense Fund opposing comment period extension.

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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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