DCHAS-L Archives, Jan 13 2017 - Re: [DCHAS-L] EPA Proposes to Limit the Use of Two Toxic Chemicals in Paint Removers.

Ah my beloved and worthy adversary is at it again. Have to weigh in.

Prop 65 doesn't ban anything. What could be better than that for you guys? All it does is require manufacturers to tell people when some chemical in the product can cause reproductive damage, developmental effects or cancer in people or animals. No warnings needed if it causes kidney damage or your arms to fall off. It just warns about repro, developmental and cancer. Then it's up to customers to read the warning and make up their own minds.

And the only fines for failing to put the proper warning on the label are paid by the manufacturers, No one else get's hurt. I've even defended a manufacturer who was a good guy but just put his trust in a phony supplier. The run-in with this law made that manufacturer be much more careful about getting written documentation from his suppliers and inspired him to ask more questions. Good on the law. In fact, that manufacturer just hung up the phone from talking to me on another subject. He lived through his Prop 65 encounter without any scar tissue forming.

And wonder of wonders, Prop 65 has a Citizen's Enforcement Clause in it! Power to the People! So it doesn't cost California tax payers a dime. California doesn't need inspectors to run around looking for violations or labs to test the products. All that is usually done by activists groups or law firms. Want a law that works? Sic roving bands of lawyers on it.

So here is a law that really is enforced well and it costs taxpayers NOTHING. Here's your template for efficient, cost-free regulations. It seems to me one of the political parties SAYS it is looking for just such a thing. Here it is guys.

Imagine if all of the OSHA regulations had citizen's enforcement clauses----sigh----but I dream.

Monona Rossol, M.S., M.F.A., Industrial Hygienist

President: Arts, Crafts & Theater Safety, Inc.

Safety Officer: Local USA829, IATSE

181 Thompson St., #23

New York, NY 10012 212-777-0062

actsnyc**At_Symbol_Here**cs.com www.artscraftstheatersafety.org

-----Original Message-----
From: Alan Hall <oldeddoc**At_Symbol_Here**GMAIL.COM>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Fri, Jan 13, 2017 2:23 pm
Subject: Re: [DCHAS-L] EPA Proposes to Limit the Use of Two Toxic Chemicals in Paint Removers.

Neal et al,

Typical politically-orieneed s BD (Bull Droppings).

While product process substitution is a generally good idea, what to do when nothing else works as well or even works at all? TCE has its problems, but I reviewed "perc" (tetrachloroethylene) some years ago and it is much worse than TCE in terms of both acute and chronic toxicity. Same with MeCl. The devil we do know for the devil we also know all too well? Not a good idea scientifically.

I attended a really excellent talk of Prop 65 while at the ISEA Fall Meeting in Late Nov-early Dec. Whaddabuncha.

If there was ever mass insanity/hysteria, Prop 65 embodies all of it. Chemophobia in the extreme on anabolic steroids. As if everything in the known universe isn't composed of chemicals?

Sometimes, I'm glad I live in Texas.and not elsewhere. I sometimes wonder about a remote island in Micronesia?

Alan

On Fri, Jan 13, 2017 at 12:17 PM, Debbie M. Decker <dmdecker**At_Symbol_Here**ucdavis.edu> wrote:

These were my thoughts, as well. I have some family furniture that needs refinishing and DCM/NMP paint stripper is the ONLY material that will take off the old finish.

And I have the same question about replacements in the skilled trades - and there just isn't any.

I guess we can commiserate together, stock up on the soon-to-be-banned products, and work to encourage EPA use a systems approach, as Ralph suggested.

Add it to the list of windmills to tilt at.

Debbie M. Decker, CCHO, ACS Fellow
Past Chair, Division of Chemical Health and Safety
University of California, Davis
(530)754-7964
(530)304-6728
dmdecker**At_Symbol_Here**ucdavis.edu

Birkett's hypothesis: "Any chemical reaction
that proceeds smoothly under normal conditions,
can proceed violently in the presence of an idiot."

-----Original Message-----
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Dan Nowlan
Sent: Friday, January 13, 2017 7:24 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] EPA Proposes to Limit the Use of Two Toxic Chemicals in Paint Removers.

Long-time listener, first-time caller here.

I've been watching these EPA proposals closely for a while because they directly affect one of our products, an aerosol paint stripper based on DCM. However, we also have two nonflammable aerosol degreasers based on trichloroethylene, which is also under TSCA scrutiny. I understand the health concerns of the chemicals in question here and don't feel the need to dwell on them. What I don't understand is what EPA expects us formulators to replace these components with, especially in the cast of TCE. I don't see how you can remove tools from the toolbox when there are in some cases really are not suitable replacements.

DCM and NMP are used in paint strippers because they work. There may be some alternatives to these two chemicals that exhibit modest efficacy=E2=80"things like high-MW esters (high because they'll need to have low vapor pressures to qualify for the LVP VOC exemption that consumer products enjoy)=E2=80"but that doesn't mean that end users will be happy with them. Moreover, in the case of TCE, there is IMO just one relatively suitable replacement, perchloroethylene, which is almost certainly going to encounter the same host of actions...and sooner rather than later.

The whole reason that aerosol degreasers, especially energized electrical cleaners, make use of TCE in the first place is because it's truly just about the only nonflammable chemical with a high enough KB that evaporates quickly. Sure, there are a couple other chlorinated solvents that meet those criteria, including DCM and perc. However, DCM is often a bit too aggressive for older/sensitive wire insulation, and perc just doesn't dry fast enough for some applications. TCE has the benefit of higher electrical resistance than perc, too, a property that is critical in energized applications. So yes, we can use perc in place of TCE...but only until EPA bans that, too. Then we'll either start seeing exotic (and pricey to ridiculously price) HFC blends that don't work very well or we'll hear about people using flammable cleaners in energized applications. I'll let you do the math on the latter scenario.

Honestly, I'm not really sure why I've written all this. I don't see that I've posed any questions for the group. Perhaps I'm just frustrated and venting a little. That said, congratulations for making it down this far! I probably would have stopped reading already. Happy Friday!

Best regards,

Dan Nowlan
Chemist, R&D
Berryman Products, Inc.
(817) 640-2376, ext. 147

-----Original Message-----
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Stuart, Ralph
Sent: Friday, January 13, 2017 6:49 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: [DCHAS-L] EPA Proposes to Limit the Use of Two Toxic Chemicals in Paint Removers.

https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/federal-register-notice-methylene-chloride-and-n

The U.S. Environmental Protection Agency (EPA) is proposing to place limits on the use of two common chemicals in paint removers in order to protect consumers and workers from serious health risks associated with this use. The chemicals are methylene chloride and N-methylpyrrolidone (NMP).

Under the new toxic chemicals law passed in June, EPA now has a legal mandate to restrict chemicals already in commerce that pose unreasonable risks to public health and the environment. There are many cases of people who have become ill or even died as a result of exposure to methylene chloride-containing paint removers. Today's action, when finalized, will save lives and protect people from other serious health risks, including cancer and developmental effects.

EPA, in a 2014 assessment, concluded that methylene chloride can cause a range of adverse health effects, including harm to the central nervous system, liver toxicity, and cancer. EPA is now proposing to prohibit manufacture (including import), processing, and distribution in commerce of methylene chloride when used as a paint remover, except for commercial furniture refinishing which the Agency will address in a separate proposal. EPA is also proposing to require manufacturers, processors, and distributors to notify retailers and others in their supply chains of the prohibitions.

EPA assessed NMP in 2015 and identified risks to people, particularly pregnant women and women of childbearing age, who have high exposure to NMP through paint or coating removal. EPA is inviting comments on two approaches to address the risks from NMP. One approach would prohibit manufacture (including import), processing, and distribution in commerce of NMP when used as a paint remover, as well as require various notification measures on the restrictions to downstream processors and users. The other approach would put in place a combination of requirements to address unreasonable risks, including limiting the amount of NMP in paint remover products, providing warning labels for consumers, and requiring workers to wear specialized gloves and other equipment. EPA is seeking comment on both approaches. In addition, EPA is proposing to exempt certain national security uses of methylene chloride and NMP from the requirements of this rule.

Comments on the proposed rule must be received 90 days after date of publication in the Federal Register. Once published, the proposed rule and supporting documents will be available in the Federal Register docket at: https://www.regulations.gov/ by searching for HQ-OPPT-2016-0231.

---
This e-mail is from DCHAS-L, the e-mail list of the ACS Division of Chemical Health and Safety.
For more information about the list, contact the Divisional secretary at secretary**At_Symbol_Here**dchas.org

---
This e-mail is from DCHAS-L, the e-mail list of the ACS Division of Chemical Health and Safety.
For more information about the list, contact the Divisional secretary at secretary**At_Symbol_Here**dchas.org

---
This e-mail is from DCHAS-L, the e-mail list of the ACS Division of Chemical Health and Safety.
For more information about the list, contact the Divisional secretary at secretary**At_Symbol_Here**dchas.org

--- This e-mail is from DCHAS-L, the e-mail list of the ACS Division of Chemical Health and Safety. For more information about the list, contact the Divisional secretary at secretary**At_Symbol_Here**dchas.org

About This Archive \|	DCHAS-L 2017 Index \|	DCHAS-L Yearly Index
Search All Posts: Advanced Search Disclaimer