Posted on August 18, 2020 by
Anthony Cardno, CHMM
On August 11, 2020, the Environmental Protection Agency completed its risk evaluation for 1-bromopropane (1-BP) as required under the Frank R. Lautenberg Chemical Safety for the 21
st Century Act (LCSA), which amended the Toxic Substances Control Act (TSCA).
So what is 1-bromopropane, and what does this mean for industry and the general public?
What is 1-bromopropane?
1-BP is commonly used as a solvent in vapor degreasing, dry cleaning, spot cleaning, stain removers, sealants, adhesives and a variety of similar activities. 1-BP use in the United States increased starting in 2007, when the EPA approved 1-BP as a replacement for more harmful ozone-depleting substances such as tetrachloroethylene under the Clean Air Act’s Significant New Alternatives Policy (SNAP).
Why evaluate the risks now?
TSCA, enacted in 1976, required the EPA to evaluate new and existing chemicals to determine if they pose an “unreasonable risk” to human health or the environment.
Under LCSA, the EPA is required to evaluate chemicals already on the market (and thus already on the TSCA Inventory) under a more stringent definition of “unreasonable risk” than previously existed. 1-bromopropane was
one of ten chemicals for which the EPA began risk evaluations in December of 2016, and for which the statutory deadline for completing those evaluations is fast approaching.
What did the EPA decide?
The EPA found that 1-BP presents an unreasonable risk to workers, occupational non-users (that is, workers who are nearby but not directly coming in contact with the chemical), consumers, and bystanders under 16 of 25 evaluated conditions of use.
Not every condition of use affects all four of those categories. For consumers, the agency found that 1-BP poses an unreasonable risk through short-term inhalation and dermal exposure while for bystanders short-term inhalation is the only unreasonable risk. For workers and occupational non-users, the unreasonable risk is from both short- and long-term inhalation exposures.
EPA did not find unreasonable risk to the environment or the general population for any of the 25 conditions of use. The agency also did not evaluate dangers posed by releases of 1-BP to the air or as hazardous waste as those situations are evaluated and regulated under the Clean Air Act and the Resource Conservation and Recovery Act respectively.
1-BP was
added to the list of Hazardous Air Pollutants in June 2020.
What’s Next?
LCSA requires the EPA to establish regulations to mitigate or remove the unreasonable risk. The agency’s next step is to write those regulations, which could impose limits on manufacturing, processing, using, storing, or disposing of the chemical, or could outright prohibit 1-BP. As with most environmental regulations, the EPA will have to publish a proposed version of the rule first and open up public comment before revising and promulgating the final rule. LCSA allows the EPA two years from the publication of the final risk evaluation to complete the risk management portion of the process.
Since the final risk evaluation of 1-BP was published on August 11, 2020, the risk management regulations for 1-BP should be promulgated no later than August 11, 2022.