EPA to make a ruling on Methylene Chloride
Just like any industry, issues come and go. Paint companies that were allergic to low VOC regulations found in many instances that following those regs resulted in a superior product. Other issues, like developing paint that works in colder temperatures, took off and now they’re largely taken for granted. The use of strippers with methylene chloride has dogged the industry for quite some time— both “back then” and “still now,” with experts and woodworkers taking strong positions for or against it. An alternative stripping chemical, n-methyl-pyrrolidone (NMP), isn’t faring much better.
Paint stripper has long been a contentious issue in this industry, if the decibel level of many conversations we’ve had is any indication. The people we consulted, all well-respected experts in the field, have very different opinions on the topic and we’re happy to present them all.
Because the U.S. Environmental Protection Agency (EPA) announced that it is about to issue a rule on methylene chloride, and no one’s sure what it’s going to say. The Lautenberg Chemical Safety for the 21st Century Act, which amended the Toxic Substances Control Act (TSCA), requires EPA to perform risk evaluations on the uses of ten specific chemicals including methylene chloride. EPA is nearing the completion of Problem Formulations for the first ten chemicals.
Here is a timeline of EPA’s recent work on methylene chloride:
• In 2014, EPA addressed the paint stripping uses in its risk assessment.
• In January 2017, EPA proposed prohibiting the consumer and commercial paint stripping uses for methylene chloride.
• In June 2017, EPA announced that it will not re-evaluate the paint stripping uses of methylene chloride.
Based on this work, EPA is announcing three updates:
• EPA intends to finalize the methylene chloride rulemaking.
• EPA is not re-evaluating the paint stripping uses of methylene chloride and is relying on its previous risk assessments.
• EPA is working to send the finalized rulemaking to Office of Management and Budget shortly.
The EPA states it is working diligently to implement the new law get the most modern and safe chemicals to market, and to ensure the safety of existing chemicals.
Our panel of experts includes Bob Flexner, a writer on woodworking and wood finishing; Ed Drazga, president of Chemique; and Mark Monique, president of Savogran.
Bob Flexner Says Keep It
Long-time readers may remember Bob Flexner (photo below) as a writer of a wood refinishing column in our pages years ago, for which we thank him profusely, and he’s still very active in the woodworking industry. Back in the day Bob could rattle some folks with his opinions about products and procedures, and he’s showing no sign of slowing down. Flexner gave us a bit of history on the chemical, noting that it was developed by a chap with the perhaps-you’ve-heard-of-him name of W.M. Barr in 1946. “It quickly took off in the marketplace because it was a huge advance over the existing paint strippers, which were highly flammable,” he said. “This advance was probably the single biggest ever made.” With that development, Barr started the Memphis, Tennessee company that still bears his name and now provides us brands such as Klean-Strip and Armorall.
“Methylene chloride is also an exempt VOC, so it is more environmentally friendly than the flammable solvents,” Flexner continued, “but this was not an issue in 1946.”
First Off, Fast and Furious
The product works quickly, but when used without sufficient ventilation, it can be quite the health hazard. Hence, the EPA has spent the last three or so decades trying to decide if and when the substance needs to be banned. In the meantime, of course, many manufactures have made safer and friendlier—but slower acting—strippers to use in its stead.
Flexner has written and blogged extensively on this topic and allowed us to share some of his thoughts in this article. “Until recently,” he said, “the main argument has been that it causes cancer. The problem with this argument is that all the evidence indicates otherwise. So it appears that now the argument has been expanded to include how many deaths the solvent has caused due to acute exposure.”
This can be a problem: acute exposure happens with this chemical because methylene chloride metabolizes to carbon monoxide in the blood stream, replacing oxygen, which can lead to a heart attack, especially in people with a pre-existing heart condition.
“The number of deaths reported is between 40 and 50 since 1975 or 1980 depending on the source,” said Flexner. “That’s less than 2 a year. Say that again, less than two a year!” Not to make light of anyone’s tragedy, but most of the time he noted, it’s due to people using the product in a closed environment, where concentrates of the chemical build up to toxic levels.
While many folks have taken a position against continued use and sale of the product, Flexner is opposed to phasing it out. As a long time woodworker, he wants products that work, and he wants products that work safely, and he feels methylene chloride can be used safely when people follow the directions. “I don’t want to be accused of minimizing anyone’s death, but are two a year enough to justify removing this extremely effective solvent from the marketplace?” he asks. “Strippers based on methylene chloride are by far the fastest acting and strongest we have available, and their substitutes all have problems. The question about banning any product always comes down to weighing the benefits against the harmful effects. I don’t think these harmful effects justify the ban in this case.”
Three To Get Ready
In the meantime, three large retail chain stores— Lowes, Home Depot, and Sherwin-Williams—have announced their intention to remove strippers containing both methylene chloride and n-methyl pyrrolidone (NMP) from their stores. “Apparently, the lobbying groups that have been most up front in pressuring these companies to this action have been effective,” Flexner surmises. “They are Safer Chemicals Healthy Families, which claims to be a coalition of 450 organizations comprising 11 million members; the Resources Defense Council, and Mind the Store.”
But Bob, tell us how you really feel. “I want to point out how absurd I think this announcement is of Lowes, Home Depot and Sherwin-Williams.” That’s how he really feels. “All three sell ladders. Three hundred people are killed each year from ladder falls. 164,000 go to emergency rooms. One-and-half people die each year from acute exposure to methylene chloride, most while stripping a bathtub with poor ventilation and their heads stuck down inside the tub. Methylene chloride is heavier than air, so the solvent collects in these tubs.
“Eliminating methylene chloride and NMP strippers will leave the flammable strippers as the only effective alternative,” he continued. “There are a few others, which contain a lot of water, are very slow, and won’t work on high-performance coatings.” For now, he is urging independent paint stores to continue to carry the products. It’s very possible the EPA will ban them, but until then, it’s up to you. “Independent stores are not likely to bow to pressure from the lobbying groups,” he said.
The Perspective from Chemique
Ed Drazga is the president of Chemique, which has been in the chemical products manufacturing business for over 45 years. It produces products for other trades along with paint, for example plumbing, and makes several lines of stone and wood care products.
Drazga is happy to hear that some larger retailers are taking it off their shelves, and he’s ready to turn dealers, woodworkers, and consumers onto safer alternatives such as those available from Chemique. “It’s a good move for consumers, retailers, and manufacturers like us that have already moved away from MC,” he said. “Eliminating access to consumers—at this level of distribution—will greatly reduce consumer exposure. At the end of the year, when Home Depot, Lowe’s and Sherwin-Williams are no longer carrying MC containing removers, there will still be many retail locations that carry it, but eliminating it from the three biggest chains is a great start.”
Drazga adds that if people don’t have the option to buy it readily available, they might just open their minds more towards safer strippers. “Eliminating MC containing removers will open the door further for safer removers and show consumers that safer products work well too—and they don’t come with the skull and crossbones. Not only are these retailers looking out for their customers,” he said, “but they are also eliminating potential lawsuits that could be brought against them.”
He adds the chemical is still prevalent in other industries. “According to EPA statistics,” he reported, “only 25% of yearly methylene chloride usage goes toward paint and coating removal products.
Even with the elimination of removers that contain MC, there’s still a huge requirement for industrial applications.”
Mark Monique says Learn Your Chemistry
Mark Monique, president of Savogran, has been involved in this issue for quite some time, and his company is trying to work with the EPA to find ways to keep the chemical available while warning people of its dangers and educating them on how to use it properly.
For now, he’s waiting to see what the EPA decides to do. “The EPA proposed the ban in the final days of the Obama administration, but by December 2017, the agency had relegated the rule to its list of ‘long-term actions,’ giving no indication about when the rule would be finalized,” he said, noting that now the EPA has changed its mind and is ready to issue a final rule. Until it’s finalized and published in the Federal Register, however, no one will know exactly what’s in it or when it will go into force.
“We have requested a reasonable implementation timeline,” said Monique. “As an industry group, we asked EPA to consider the enhanced labeling that was recently approved by the Consumer Product Safety Commission (CPSC) in the new rule as a mitigation against improper use. In May we received the first load of cans from our supplier with the enhanced labeling, which includes a pictogram stating the product is not to be used for stripping bath tubs and including strong language not to use the product in enclosed spaces.”
There are times, he notes, where methylene chloride is clearly the best choice, and that there is nothing comparable to replace it at this time. “There will be many instances were professionals will not be able to use the flammable alternatives or the green products because of efficiency,” he said. “In that regard, we asked the EPA to consider an on-line training course be developed in the short term which would train users of MC-based paint strippers in their safe and effective use. After completing the on-line training course, and successfully passing an examination to prove competence, a certificate would be issued and the person buying the product would present it at the point of sale to authorize its purchase.” A similar plan was adopted in United Kingdom, which had banned the substance, but then recanted to allow professionals access to the products.
All that said, however, Savogran will have alternatives at the ready in just a few weeks. “We will be rolling out our methylene chloride (DCM) free line of paint removal products no later than September 1st,” said Mark.
It’s no surprise that customers who depend on this product aren’t excited about this potential proclamation. “Our end users, particularly the professionals, are very troubled that the traditional methylene chloride formulated products might go away,” said Monique. It’s not an environmental issue, for example like VOCs, as Monique related that the EPA proposed regulation states potential environmental impacts are judged to be low.
Still, he’s got to develop products that will work in the face of a possible ban. The challenge is speed—alternative strippers have never worked as fast as MC. “We can successfully reformulate the products with lower weight percentages of methylene chloride,” he said. “The challenge is reformulating the higher weight percentage products, as methylene chloride is so effective, nonflammable and VOC exempt.”
He advises independent dealers to wait until a final ruling is published, but on the other hand, be ready to react. “Although no action is required at this time as we will not know the full impact of the regulation until it is published in the Federal Register, dealers should begin looking at the alternatives. We have products available with similar characteristics and functionality to the methylene chloride formulated products.”