NCHR Comments to EPA on Methylene Choloride and N-Methylpyrrolidone Use in Paint Remover

Comments of the National Center for Health Research on
Proposed Restrictions on Methylene Chloride and N-Methylpyrrolidone Use in Paint Removal under Section 6 of the Amended Toxic Substances Control Act
Submitted via (May 19, 2017) Docket ID EPA‐HQ-OPPT‐2016‐0231

The National Center for Health Research is pleased to submit these comments on the Environmental Protection Agency’s (EPA’s) proposed rule to restrict the use of methylene chloride (MC) and n‐Methylpyrrolidone (NMP) in paint and coating removal under section 6 of the Frank H. Lautenberg Chemical Safety For the 21st Century Act (LCSA).

The requirements of the law were designed by Congress to protect the health and safety of the American people and must be followed. It is essential that the EPA implement the new law to benefit all Americans as intended.

This proposed rule, along with two companion EPA proposals on trichloroethylene (TCE), represent the first use of LCSA’s authority for regulating unsafe chemicals.

The only effective remedy for the health risks posed by MC and NMP is to ban their use for paint and coating removal. EPA’s analysis demonstrates that a ban is needed to provide meaningful protections against the potentially deadly risks of these chemicals, and that labeling changes and other measures are insufficient.  We strongly agree.

However, EPA is proposing to defer action on furniture refinishing, despite the EPA’s findings that many worker and consumer exposures to MC are from furniture refinishing.  We urge the EPA to also ban MC use in furniture refinishing products.

TSCA section 6(c)(1) requires EPA to publish a final rule on chemicals presenting unreasonable risks within one year of proposal. This deadline applies to the MC and NMP rulemaking under the terms Of TSCA section 26(l)(4).  We urge the EPA to comply with the law and publish the final rule on MC and NMP as required.

NCHR can be reached through Stephanie Fox-Rawlings at