By Pat Rizzuto
July 31 — The Environmental Protection Agency will regulate uses of trichloroethylene that pose health risks to workers or consumers unless companies voluntarily stop using the solvent or find ways to reduce exposures, according to a senior agency official.
“Voluntary efforts are frequently quicker and more cost-effective than regulations,” Wendy Cleland-Hamnett, director of EPA's Office of Pollution Prevention and Toxics (OPPT), said July 29 during a workshop. “But where we can't do it through voluntary efforts, we will pursue regulations.”
In the U.S., most trichloroethylene is used in refrigerant manufacturing, which poses minimal exposure risks and isn't an application the EPA is focusing on. The EPA is concerned about worker exposure in commercial degreasing operations and dry cleaning, as well as consumer exposure through various products that contain TCE.
The EPA held a workshop July 29-30 to discuss alternatives to trichloroethylene use as a degreaser. Participants also discussed ways to reduce exposures if the solvent must be used. In future forums, the agency will address TCE alternatives for dry cleaners.
Most of the vast amount of TCE used in the U.S. wouldn't be affected by such regulations if the EPA pursued them.
Companies make about 250 million pounds of trichloroethylene in the U.S. or import it into this country annually, said Tala Henry, director of OPPT's Risk Assessment Division.
The vast majority of that total, 83.6 percent (209 million pounds), is used to make refrigerants in well-controlled and contained workplace environments, Henry said.
Some portion of the remaining applications of TCE may pose a concern.
The EPA estimates 14.7 percent (36.75 million pounds) of the remaining trichloroethylene is used as a commercial degreasing solvent, and 1.7 percent (4.25 million pounds) has consumer applications such as automotive degreasing products, home office toner aids, home mirror edge sealant and arts and crafts fixatives or cleaners, Henry said.
Few consumer uses of TCE remain, and uncontrolled commercial applications have significantly decreased in recent years, Steven Bennett, senior science affairs director at the Consumer Specialty Products Association, told Bloomberg BNA on the sidelines of the meeting. He pointed to a recent EPA analysis that found metal fabricators reduced the amount of trichloroethylene they use for degreasing by 79 percent from 2001 to 2012.
OPPT organized the workshop as its initial response to its analysis of risks TCE poses when used in degreasing, dry cleaning and some arts and crafts applications.
Thousands of workers in small commercial degreasing shops and dry cleaning facilities face an increased risk of contracting cancer and giving birth to children with cardiac or other health problems, OPPT concluded.
Employees who don't work with TCE directly, but work near where it is used, also faced increased health risks, the assessment said.
The offspring of pregnant consumers who inhale brief high concentrations of TCE-containing arts and crafts sprays or other materials may also face risks, the assessment found, although many companies have stopped using TCE in consumer goods, according to information presented at the workshop.
Trichloroethylene is found at more than half of the nation's superfund sites, according to the Agency for Toxic Substances and Disease Registry, which focuses on human health risks of hazardous waste sites.
TCE also is a volatile organic compound and hazardous air pollutant, said Margaret Sheppard, an environmental scientist with EPA's Office of Air and Radiation.
Trichloroethylene is relatively inexpensive; has no flash point, making it less of a fire risk than some alternatives; is versatile because it can remove many different contaminants from many different materials; and requires no rinsing or drying because it quickly evaporates, according to presentations made during the meeting.
Those attributes have made both workers and companies comfortable with the solvent and reluctant to change, speakers said.
During public comments at the workshop, Mike Partain quoted a physician who, decades ago, summarized the challenge posed by both TCE's useful properties and its health and environmental problems.
“Any manufacturer contemplating the use of trichloroethylene may find in it many desirable qualities. Too, in the absence of closed systems of operation, he may find in this solvent the source of disaster for exposed workmen,” Partain said, quoting Carey McCord, a physician, in the July 30, 1932, issue of the Journal of the American Medical Association, or JAMA.
Partain addressed workshop participants as a private citizen who said he and other men have contracted breast cancer as a result of drinking TCE-contaminated water while living in Camp Lejeune, a Marine Corps Base in North Carolina.
Workshop participant Julia Quint, a toxicologist who has retired from the California Department of Public Health, summarized another challenge she said the EPA will face in persuading companies to choose non-TCE-based cleaning methods.
The Occupational Safety and Health Administration's permissible exposure level for TCE is 100 parts per million, averaged over eight hours, Quint said.
The EPA's risk assessment doesn't directly compare concentrations of concern to OSHA's PEL.
The exposure levels that concern the EPA would, however, be lower than OSHA's PEL, Quint said.
That means a company could be complying with legal limits and therefore be disinclined to think its workers were exposed to unsafe levels of TCE, she said.
The California Division of Occupational Safety and Health (Cal/OSHA) has established an occupational limit of 25 ppm, while the American Conference of Governmental Industrial Hygienists (ACGIH) has set an occupational exposure limit of 10 ppm, Quint said.
Katy Wolf, executive director of the Institute for Research and Technical Assistance, a nonprofit organization that has helped companies identify non-TCE-based methods to degrease equipment, was among many speakers that discussed alternative ways of degreasing equipment.
These alternatives include water-based cleaners that may contain small amounts of surfactants, rust inhibitors and other compounds; acetone; a coating that could be peeled off to remove contaminants; and frozen crystals of carbon dioxide called “snow,” she said.
Major chemical manufacturers that have made alternatives include 3M, DuPont and Honeywell International Inc., according to a presentation by Ryan Hulse, a senior manager at Honeywell.
Many companies want to do the right thing and switch, but they are scared that the alternatives won't work and won't satisfy their customers, Heidi Wilcox, a field specialist at the Toxics Use Reduction Institute (TURI) at the University of Massachusetts at Lowell, said.
TCE users want another chemical that can provide the benefits of trichloroethylene, without its waste disposal costs or health and environmental risks, said Wayne Ziegler, a materials engineer with the Army Research Laboratory.
There is, however, no single chemical or non-chemical cleaning process that can substitute for all of TCE's applications that also have none of its problematic attributes, said Jason Marshall, director of services for the TURI's Cleaning Lab.
Marshall made similar points in a July 2 interview with Bloomberg BNA.
Nevertheless, some companies and government agencies already have found alternatives.
Workshop speakers included officials from the Defense Department, specialty chemical manufacturing companies, academia and private sector consultants who have helped companies identify TCE alternatives. They discussed strategies they used to make or help others make the transition to non-TCE-based cleaning methods.
There are many alternatives that clean well, are cost-effective and that protect workers' health, speakers said.
The challenge is to find the specific alternative or alternatives that can work for a specific company and its customers, Marshall and other speakers said.
In recent years, up to 80 percent of the companies TURI works with have fully adopted its recommendations concerning ways to eliminate hazardous solvents, cut their use or reduce workers' exposure, he said.
The companies are adopting TURI's recommendations because the institute spends a lot of time with each company to understand its basic issues, Marshall said. Those basic issues include:
Different companies have to clean different materials to different standards, Brent Ekstrand, a vice president at Astro Pak Corp., said. Its clients include NASA and pharmaceutical and semiconductor manufacturers.
NASA requires complete, precision cleaning, with no spots, Ekstrand said. Astro Pak had to work with NASA to find a TCE alternative that would meet its specifications, he said, adding the agency eventually chose aqueous-based cleaning technologies.
Some but not all of the equipment the Defense Department needs degreased requires that level of cleanliness, Ziegler of the Army Research Laboratory said. But military operations often require degreasing that works very quickly, he said.
As DOD sought alternatives, it needed to be sure the alternatives wouldn't slow down operations, Ziegler said. Some DOD facilities accomplished this by purchasing sufficient equipment to double their cleaning capacity, he said. One payoff was the savings in waste disposal and other costs because the DOD facilities were no longer working with TCE, Ziegler said.
Workshop participants gave the EPA a mix of advice as to how it should proceed.
Michael Muth, president of Slide Products Inc., a specialty chemical company that manufactures degreasers that don't contain chlorinated solvents, urged the EPA to publicize its concerns about TCE.
Customers are more easily persuaded to purchase alternatives when a government agency focuses on health risks of the products they currently use, he said.
Wolf, with the Institute for Research and Technical Assistance, urged the EPA to use its regulatory authority.
“If you pass a regulation, you get their attention,” Wolf said. A handful of companies may participate in a voluntary initiative; thousands would follow if TCE were banned, she said.
Jennifer Sass, a senior scientist with the Natural Resources Defense Council, commended the EPA on its assessment.
“Since in many cases there are safer alternative materials available, EPA should immediately establish more health-protective exposure limits for these unsafe uses and ban TCE use in small commercial degreasing facilities and in consumer aerosol degreasers and protective coating sprays,” Sass said.
Rick Reiss, a principal scientist with Exponent, a consulting firm hired by the Halogenated Solvents Industry Alliance, urged the agency to improve its exposure estimates before proceeding.
EPA's analysis contains so many inconsistencies and inaccuracies, especially in its exposure assessment, that its conclusions are meaningless, Reiss said.
The agency should gather more information about small facilities that use TCE for degreasing and determine the extent of worker exposure and what exposure control technologies are in use, he said.
Christina Franz, an attorney and senior director at the American Chemistry Council, urged the agency to reach out to the Small Business Administration to craft a strategy to work with the types of small companies the EPA is concerned about.
Maria Doa, director of the EPA's Chemical Control Division, described the workshop as the first of many steps the agency will take to begin managing health and environmental risks from TCE.
The agency will work to build on the expertise that TURI and other organizations have developed in helping facilities switch from TCE, she said.
The agency also will use the workshop information to help craft strategies to work with different industries, trade associations and other interested parties and develop materials that could help companies understand the business case for switching to alternatives, Doa said.
Finally, the agency recognizes that some companies are still using TCE and may need to continue to do so due to specifications of their customers or other constraints. The EPA will use ideas and recommendations from workshop participants to revise a document it's preparing to help commercial facilities decrease workers' exposure when using TCE, she said.
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Some of the presentations made at the workshop are available via http://www.regulations.gov by searching Docket No. EPA-HQ-OPPT-2014-0327. EPA said it will post additional materials in the docket
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