New Restrictions on N-Methylpyrrolidone to Safeguard Health

The Environmental Protection Agency (EPA) published a new rule targeting the unreasonable risk N-Methylpyrrolidone (NMP) poses to human health. This rule introduces significant restrictions on using NMP across various industrial, commercial, and consumer applications.

Uses of NMP

NMP is widely used as a solvent in the production of electronics such as semiconductors, polymers, petrochemical products, paints and coatings, and paint and coating removers.

Health Impact

The EPA has determined that NMP can cause severe health effects, including:

- Miscarriages and reduced fertility
- Liver and kidney damage
- Immune system impairment
- Nervous system damage

Proposed Restrictions under TSCA Section 6(a) To mitigate the identified risks, the EPA proposes the following measures:

1. Occupational Use Restrictions: Prohibit the manufacture (including import), processing, distribution, and use of NMP for five occupational conditions of use (COUs).
2. Consumer Use Regulations : Impose container size limits and labeling requirements for the manufacture (including import), processing, and distribution of NMP for seven consumer uses.
3. Prescriptive Controls : Implement concentration limits and require personal protective equipment (PPE) for seven occupational COUs.
4. Workplace Controls : Enforce strict workplace controls, including an NMP Workplace Chemical Protection Plan (WCPP), to prevent direct skin contact with NMP. This applies to all other occupational COUs, including commercial use of paints, coatings, and adhesive removers containing high NMP concentrations, especially for the Department of Defense (DOD) and NASA.
5. Consumer Use Limits : Establish a concentration limit on NMP for the import, processing, and distribution in commerce of one consumer use.
6. Recordkeeping and Notification : Set recordkeeping and downstream notification requirements.

Applicability

Entities involved in the manufacture, import, processing, distribution, use, or disposal of NMP or products containing NMP may be affected by this proposed rule.

Public Participation

The EPA encourages public and stakeholder review and feedback on the proposed rule. Comments will be accepted for 45 days following the publication of the rule.