A Summary of Proposed Regulation on N-Methylpyrrolidone under TSCA
A popularly used cleaning solvent has landed on the Environmental Protection Agency’s naughty list, which means new restrictions are likely on the horizon.
If you are using n-Methyl-2-pyrrolidone (NMP) in chemical processes or products, now is the time to begin considering alternatives or preparing for new regulations, rules, and limitations. New proposed regulatory actions by the EPA aim to address the unreasonable health risks revealed in a 2020 EPA Risk Evaluation. The EPA determined that NMP poses an unreasonable health risk due to significant adverse effects, including fetal loss from short-term exposure and reduced fertility from long-term exposure. Other effects include liver, kidney, and neurotoxicity, immunotoxicity, skin irritation, and sensitization. To mitigate the health risks, EPA is proposing product reformulation and the use of personal protective equipment (PPE) to adequately reduce exposures. That means restrictions on use, reductions in formulation, and new OSHA standards.
What is NMP and Where is it Used?
NMP is a solvent used in a variety of industries and applications, such as paint and coating removal, petrochemical processing, engineering plastics coatings, agricultural chemicals, electronic cleaning and industrial/domestic cleaning. NMP is produced and imported into the United States, with use estimated at over 184 million pounds per year. EPA estimates that approximately 9 percent of total NMP usage is for paint and coating removal products (EPA NMP Factsheet).
- Electronics – NMP can be used to remove wax, flux, and burrs, clean electronic parts, and thin semiconductor and color filter photo-resists. It’s also a solvent used in the manufacturing of lithium-ion batteries, which are essential for powering modern electronics and electric vehicles.
- Automotive – NMP can be used to clean molds and metal parts.
- Industrial and household cleaning – NMP can be used in paint strippers, graffiti removers, oven cleaners, and automotive and industrial cleaner formulations.
- Pharmaceuticals – NMP can be used as a solvent and extraction medium for purifying and crystallizing drug ingredients.
- Petrochemical processing – NMP can be used as an extraction medium in industrial processes to recover hydrocarbons like 1,3-butadiene and acetylene, and to absorb hydrogen sulfide from sour gas.
- NMP can also be used in agricultural chemicals, engineering plastics coatings, leather treatments, makeup and cosmetic products, clothing and shoes, bedding and linens, and adhesives for craft projects.
Proposed Regulatory Actions:
- Proposed Rule Changes:
- The EPA is proposing to ban several occupational uses of NMP, including its incorporation into lubricants and machinery manufacturing, as well as in anti-freeze, de-icing products, automotive care products, lubricants, and greases. Consumer uses of NMP are generally not included in the ban due to their lower concentration and infrequent use.
- The EPA proposes specific prescriptive controls for workers exposed to NMP such as: respiratory protection (respirators, hoods, ventilation), dermal protection (gloves, coveralls, chemical suits), and restrictions on NMP concentrations for specific uses. These all require planning, training, implementation, and monitoring which will increase costs and administrative burden on industry.
- Set a concentration limit, container size, and add label requirements on NMP for 7 allowed consumer uses and establish recordkeeping and downstream notification requirements.
- These changes will impact import/export of NMP under TSCA as well.
- Compliance Timeframes:
- Compliance dates for the prohibitions are staggered: 12 months for manufacturers, 15 months for processors, 18 months for distributing to retailers, 21 months for all other distributors, and 24 months for industrial and commercial users.
The EPA is seeking public comments on the proposed actions, compliance timeframes, and additional measures needed to mitigate risks associated with NMP until July 29. You can comment of the proposed rule here.
AlterEcho is advising producers and consumers to start preparing for the changes and consider alternatives in order to stay in regulatory compliance.
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