SFA

Topic: Halogenated Solvent Cleaning Rule - open comment period

(Submitted by Dr. John B. Durkee of Precision Cleaning)


Some are hard to kill. Apparently, the EPA's "Halogenated Solvent Cleaning" rule is one of those items. First written in 1994 to set limits, methods, and standards under which one could clean with six chlorinated solvents, this rule is still (and properly) under review. You might want to review it  too, and perhaps add your voice.

The 1994 rule was a success – validating the use (then) of trichloroethylene (TCE) and perchloroethylene (PERC) in open-top vapor degreasers. Today some are using, and purchasing, these machines. Incidently, n-propyl bromide is not covered by this rule.

The US Clean Air Act, which spawned the 1994 rule, requires EPA to review the impact of this rule and decide if further regulation is required to protect the public from risk. In this case, the risk is of cancer – from using TCE.


This review has been ongoing: EPA made a proposal in 2006, and most (including me) expected it to become a final rule when public comments were digested by them in 2007. But, the 2007 "almost regulation" turned out to be a unintentional draft.

Continued  public comment later spoke that additional human exposure data had become available, and that EPA should consider that data as well. Under court challenge, EPA so agreed.


In October, EPA collected the additional data and wrote a regulation with three possible cases. They also asked the public to again comment – hopefully for the last time. The comment period expires on December 4. This is so that the EPA can meet a court-ordered compliance date by users of May 3, 2010.

If you are interested in solvent cleaning with TCE, particularly of: narrow tubing or web structures, or are doing aerospace work, or are doing military maintenance, you should become familiar with what's being proposed, and perhaps comment.

You can download the current proposal, and its request for any additional exposure effect data, at http://edocket.access.gpo.gov/2008/E8-24013.htm.

It's fairly long, written in EPA-ese, but possibly important to you.

Submitted by:

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John B. Durkee, PhD, PE
Consultant in Industrial Cleaning
POB 847 Hunt, TX 78024

(830)-238-7610

jdurkee@precisioncleaning.com