Banned by the EPA - What are my options?
Banned! Yes banned! That is a very real conclusion that the precision cleaning industry needs to come to grips with. The very real possibility that the EPA can use the statute in place to ban the 3 (nPB, TCE, Perc) most readily used vapor degreasing solvents.
My intent here is not to be unnecessarily provocative. I want you to understand the very real possibility of what could occur based upon the recent EPA rulings. The EPA has seemingly boxed itself into a corner, almost requiring strict action by the words they use- “unreasonable risk to human health”. It’s hard to imagine splashing those words into the ether sphere and then say- “oh just kidding, keep operating as you have been, no worries.”
Regardless of the ultimate actions taken by the EPA, this legislation will change how industry views vapor degreasing, especially the companies still using these solvents. This ruling would likely cause manufacturers using these solvents to consider what options are available to them today, while also trying to read the tealeaves of the EPA. The hope would be that manufacturers can make an informed, long-term decision, that will not require re-visiting this subject again for many years.
So, what are the solvent replacement options to be considered? Here are a few options at least as I see them.
- Doing nothing, continue using the solvent of your choice
- Hope for some waiver for my specific industry allowing continued use
- Forgo parts degreasing all together
- Send parts to someone else for cleaning
- Purchase carbon absorption equipment and continue using
- Convert to a fluorinated vapor degreasing molecule using existing equipment
- Purchase a new vapor degreaser to better contain the solvent
- Convert to aqueous cleaning
- Convert to Airless vacuum vapor degreasing
I do not see a clear winner of these manufacturing options. This was the same type of disruption that occurred when the EPA banned CFC’s. As the situations are very similar, I think we can use the past to predict the future. At that time, the EPA created the Significant New Alternatives Program (SNAP).
What’s most interesting is that TCE and nPB are one of several options given to manufacturers, via the EPA Significant New Alternatives Program (SNAP)
Obviously, timing of this is statute is quite unfortunate. Statute does not stand still during a pandemic. Because we are talking about this now, the good news is you still have time. There is still time to consider your options, time to investigate more than one option.
I will address Option 1 as listed. I can’t imagine in 2021 this would reasonably be an option for any manufacturer. Again, let history guide us. There were people that evidently believed the rules did not apply to them when CFC’s were banned. As a result, there were significant fines and federal prison time. All of which are unpleasant. With today’s social media, can you imagine the public backlash a company would have inflicted upon them if they were found in violation. I would submit the damage would be significant, unyielding, and relentless. Unfortunately, the best a company could hope for would be to ride it out and somehow survive, as in literally still have some customers to keep the doors open.
We are fortunate that technology in the cleaning business has made great strides in the past 30 years. The fluids and equipment technology shift have been driven by nonstop advancements in manufacturing and end user requirements for better products. Suppliers of products in the cleaning industry have been forced, rightfully so, to make advancements and keep up with manufacturers requirements.