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

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The Fertilizer Institute filed 1 comment on this docket between Jun 9, 2017 and Jun 9, 2017. 24 other organizations filed here. The comment window closed 3357d ago.

What The Fertilizer Institute filed (1)

Jun 9, 2017· Comment submitted by Ed Thomas, Director, Regulatory Affairs, The Fertilizer Institute (TFI)· EPA-HQ-OPPT-2016-0231-0521

The Fertilizer Institute (TFI), on behalf of its member companies, submits these comments addressing the U.S. Environmental Protection Agency's (EPA or Agency) proposed rule entitled "Methylene Chloride and N-Methylpyrrolidone; Regulation of Certain Uses Under TSCA Section 6(a)" (hereinafter "NMP Uses Under TSCA"). The NMP Uses Under TSCA Proposed Rule, published in the Federal Register on January 19, 2017, appears at 82 Fed. Reg. 7,464. TFI represents the nation's fertilizer industry, including producers, importers, retailers, wholesalers and companies that are engaged in all aspects of the fertilizer supply chain. Fertilizer is a key ingredient in feeding a growing global population, which is expected to surpass 9.5 billion people by 2050. Half of all food grown around the world today is made possible through the use of fertilizer. Several TFI members utilize N-Methylpyrrolidone as a solvent while manufacturing urease inhibited fertilizers and as proposed would be subject to the requirements upon which EPA is seeking comment in the NMP Uses Under TSCA Rule. As such, TFI offers the attached comments in response to the NMP Uses Under TSCA Proposed Rule.

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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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Methylene Chloride and N-Methylpyrrolidone (NMP); Rulemaking under TSCA Section 6(a) (EPA) — The Fertilizer Institute | OpenPolis