EPA Proposes Protection From NMPs for Workers

WASHINGTON -- The EPA has proposed a new rule under the Toxic Substances Control Act (TSCA) that would protect workers and consumers from exposure to the solvent n-methylpyrrolidone, or NMP.

EPA is proposing establishment of an NMP Workplace Chemical Protection Program (WCPP) to protect workers from exposure in nearly all industrial and commercial uses. This would include requirements to prevent direct skin contact with NMP that would go into effect a year after the rule is finalized.

NMP can be found in adhesives and sealants, paints and coatings, paint removers, lubricants, automotive care products, degreasers, cleaners and furniture care products.

An EPA 2020 risk evaluation found that the “developmental toxicant” causes serious health effects, including miscarriages, fetal death and reduced fertility, as well as damage to the liver, kidneys, immune system and nervous system.

If finalized, the rule would limit the concentration of NMP in some consumer and commercial products, establish strict workplace health controls for many use of it, and ban some uses that cannot safely continue and for which alternatives already exist.

“We’re making great strides in our efforts to protect people’s health from exposure to chemicals like NMP,” said Assistant Administrator for the Office of Chemical Safety and Pollution Prevention Michal Freedhoff. “Our proposed common-sense worker protections would keep people safe while also ensuring that NMP could continue to be used, as needed.”

A number of different options exist for mitigating risks from NMP, including transition to safer chemicals and greener processes/technologies, promotion of best practices, and phase out of uses. Implementing these approaches could involve regulatory action, voluntary approaches, or a mixture of both.

NMP is used to manufacture and produce many electronics, polymers, agricultural chemicals and petrochemical products. It is used in the production of specialized electronics, such as semi-conductors and magnet wire, as well as lithium-ion batteries used in a wide variety of applications, including aerospace vehicles and electronic devices.

It also has numerous other industrial, commercial and consumer applications, including adhesives and sealants, paints and coatings, paint removers, lubricants, automotive care products, degreasers, cleaning and furniture care products.

To protect consumers from exposure to NMP in glues and adhesives, EPA is proposing a NMP concentration limit of no greater than 45 percent, as well as container size limits and labeling requirements for other types of consumer products so that they are not used in commercial settings where their more frequent use could pose risks.

EPA expects that many sectors, including the semiconductor and lithium-ion battery manufacturing sectors, have already implemented the types of exposure controls in their facilities that EPA would require. For example, semiconductor manufacturing fabrication machines, enclosed and automated tools, and clean rooms are some of the exposure controls already in place that EPA expects would meet the requirements of the rule.

For several other uses (such as in paints, adhesives, inks, coatings and soldering materials), EPA proposes prescriptive workplace controls, including concentration limits and use of personal protective equipment.

EPA is proposing to ban the commercial use of NMP in automotive care products, cleaning and degreasing products, metal products and cleaning and furniture care products because EPA believes these uses cannot safely continue. EPA is also proposing to ban the use of NMP in antifreeze, de-icing products and lubricants because it believes these uses have already ceased.

The proposed rule would also ban the commercial use of NMP in fertilizers and other agricultural chemical manufacturing processes because EPA does not currently have information demonstrating that they could be safely continued. For these uses, EPA believes that such information may exist, and EPA expects to conduct proactive outreach during the comment period to better understand industrial practices associated with these uses.

The EPA will accept public comments on the proposed rule for NMP for 45 days following publication in the Federal Register via docket EPA-HQ-OPPT-2020-0744.