The U.S. Environmental Protection Agency announced a proposed rule under the Toxic Substances Control Act (TSCA) that would protect workers and consumers from exposure to the solvent n-methylpyrrolidone (NMP). EPA’s 2020 risk evaluation found that this chemical causes serious health effects, including miscarriages 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 that would be allowed in some consumer and commercial products, establish strict workplace health controls for many uses of NMP, and ban some uses that cannot safely continue and for which alternatives already exist.

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. NMP also has numerous other industrial, commercial and consumer applications, including adhesives and sealants, paints and coatings, and paint removers, among others.

To protect consumers from exposure to NMP in glues and adhesives, EPA is proposing an NMP concentration limit of no greater than 45%, 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 is also proposing a NMP Workplace Chemical Protection Program (WCPP) to protect workers from exposure to NMP for nearly all industrial and commercial uses. The WCPP would include requirements to prevent direct skin contact with NMP that would go into effect a year after the rule is finalized. 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 which EPA expects would meet the requirements of the rule. For several other occupational conditions of use of NMP (such as its use in paints, adhesives, inks, coatings, and soldering materials), EPA proposes to require 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.

EPA encourages members of the public and stakeholders to read and comment on the proposed rule. EPA has and will continue to engage with industry stakeholders on the proposed rule. The agency is especially interested in hearing perspectives from the public on the feasibility and effectiveness of the proposed requirements for worker protections, including from workers and entities that would be required to implement the workplace protections or from entities that believe they can feasibly implement the workplace protections.

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.

EPA will host a public webinar to provide an overview of the proposal on Thursday, June 20, at 1:00 p.m. EDT. Registration is available here.