Advocacy Comments on Methylene Chloride and N-Methylpyrrolidone; Regulation of Certain uses Under TSCA

April 17, 2017

The U.S. Small Business Administration’s (SBA) Office of Advocacy (Advocacy) submits the following comments in response to the Environmental Protection Agency’s (EPA) proposed rule, “Methylene Chloride and N-Methylpyrrolidone; Regulation of Certain uses Under TSCA Section 6(a).” Safe chemical use and prevention of hazardous exposure to chemicals are a priority for small businesses to be able to protect both the consumer and their employees. Small businesses, however, have raised concerns with EPA’s basis (i.e., risk assessment) for its regulatory proposal for the use of methylene chloride and n-methylpyrrolidone (NMP) in paint and coating removal. Small businesses are also concerned with the agency’s consideration of the viable and technically feasible alternatives for methylene chloride and NMP. In addition, small businesses formulators have also raised concerns that the agency did not evaluate the full cost of a potential ban on the use of these chemicals on their products. Finally, small businesses have expressed concerns with the agency’s size restriction on the distribution of products with these chemicals. Advocacy urges EPA to carefully address these small business concerns and consider providing regulatory flexibilities for small businesses that allow the agency to achieve its regulatory objective.

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