Natural Resources Defense Council (NRDC)
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
Natural Resources Defense Council (NRDC) filings
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Activity

Natural Resources Defense Council (NRDC) filed 1 comment on this docket between Jul 10, 2017 and Jul 10, 2017. 24 other organizations filed here. The comment window closed 3357d ago.

What Natural Resources Defense Council (NRDC) filed (1)

Jul 10, 2017· Comment submitted by Elizabeth Hitchcock, Government Affairs Director, Safer Chemicals Healthy Families (SCHF) and Jennifer Sass, PhD, Senior Scientist, Natural Resources Defense Council (NRDC)· EPA-HQ-OPPT-2016-0231-0907

Safer Chemicals Healthy Families (SCHF) and Natural Resources Defense Council (NRDC) submit these comments on the Environmental Protection Agency's (EPA's) proposed rule to restrict use of methylene chloride (MC) and n-methylpyrrolidone (NMP) in paint and coating removal under section 6 of the newly enacted Frank H. Lautenberg Chemical Safety for the 21st Century Act (LCSA). SCHF is a coalition of national, state and local organizations committed to assuring the safety of chemicals used in our homes, workplaces and in the many products to which our families and children are exposed each day. SCHF and its partners took a leadership role during the LCSA legislative process, advocating the most protective legislation possible to reduce the risks of toxic chemicals in use today. The Natural Resources Defense Council (NRDC) is a SCHF coalition partner. NRDC is a national, non-profit environmental organization of lawyers, scientists, and other professionals. NRDC submits these comments on behalf of our over two million members and online activists. SCHF and NRDC do not have any financial interest in the topic of these comments. The following organizations have endorsed and are supporting the SCHF and NRDC comments: Alaska Community Action on Toxics Alliance for a Healthy Tomorrow Asbestos Disease Awareness Organization Breast Cancer Prevention Partners Clean and Healthy New York Clean Water Action- Connecticut Earthjustice Ecology Center Environmental Health Strategy Center Healthy Legacy League of Conservation Voters Learning Disabilities Association Maryland PIRG Oregon Environmental Council Science and Environmental Health Network U.S. Public Interest Research Group (PIRG) VPIRG WE ACT for Environmental Justice

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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