Originally Published: April 15, 2021 | Last Updated: December 19, 2023 | Contributor: Jeff Beard (Fmr. President of Manufacturing Cleaning Association)
As you have heard the EPA risk assessment studies have determined the use of 1-bromopropane (nPB) Trichloroethylene (TCE), Dichloromethane (Methylene Chloride) and Perchloroethylene (Perc) as “unreasonable risk to human health” when used as a vapor degreasing solvent, as well as a majority of the other industrial uses for these solvents were used for. In December 2020, the State of New York banned the used of TCE for vapor degreasing effective December 1, 2021.
When you consider the New York action along with previous rulemaking in California and Minnesota against the use of TCE, the long-term viability of TCE nationally seems dire. Now is the time to consider alternative degreasing methods. The outcome of your decision on what is best for your site will take time to implement.
What are the solvent replacement options to be considered? Here are a few options as I see them, along with some considerations.
Option One: Hope For An EPA Waiver For Your Industry, Allowing Continued Use
Recommended Considerations
Based upon the data presented by EPA, this seems highly unlikely altogether.
Option Two: Forgo Vapor Degreasing Altogether
Recommended Considerations
First, evaluate the following:
- “Why do we degrease our parts?”
- “Is vapor degreasing of parts a ‘must,’ ‘like to,’ or ‘wish to?'”
- “Is it in-process clean or final clean?”
If you are vapor degreasing prior to aqueous cleaning, conduct a study on how the removal of this pre-clean step will affect your alkaline cleaner. My experience says absolutely review this thoroughly, there will be cause/effect.
Consider how the removal of vapor degreasing affects the next step of the process. How does it affect the process before vapor degreasing? Ask yourself, will changing the oil used for machining or stamping give you more flexibility? The answer to this question determines the next steps you should take.
Option Three: Send Parts & Hardware To Someone Else For Vapor Degreasing
Recommended Considerations
- Consider logistics, such as time and distance, as well as the timing and cost of work in progress.
- Consider the implications of relying on someone else to meet your cleaning spec, assuming you have one in place that is documented.
Option Four: Purchase Carbon Absorption Equipment & Continue Using Current Chemicals
Recommended Considerations
- Engineering controls are in place currently under NESHAP. Enhancement of these options is unlikely, and not possible with nPB due to thermal breakdown and acidity issues.
Option Five: Convert To A Fluorinated Vapor Degreasing Solvent Using Existing Equipment
Recommended Considerations
- Consider that lower boil points may not remove some soils, such as waxes which are temperature-sensitive in their removal.
- Additionally, higher vapor pressure of the solvent may increase solvent loss during operation and idling. This will exacerbate the use of the phrase “we know we have some leaks” in your operation.
- You’ll also have similar results for standard manufacturing oils.
Option Six: Purchase A New Vapor Degreaser Made For Fluorinated Solvents
Recommended Considerations
- First, consider the total cost of new equipment.
- As mentioned in Option Five, consider that lower boil points may now remove some soils.
- New machines are very efficient in solvent recovery vs. existing or old vapor degreasers.
Option Seven: Decide To Convert To Aqueous Parts Cleaning
Recommended Considerations
- As mentioned previously, first consider the cost of new equipment.
- Think about the handling of water from incoming to waste; wash and rinse. Also, consider your process for drying the parts.
- Converting means you will need to learn the intricacies of a vastly different process.
- Aqueous parts cleaning can provide equal or better cleaning results.
Option Eight: Decide To Convert To Vacuum Vapor Degreasing
Recommended Considerations
- Consider the cost of new equipment.
- Learn about waterless degreasing with hydrocarbon, modified alcohol, or fluorinated solvents.
- Expect similar degreasing results.
Final Thoughts
I do not see a clear winner from these options that manufacturers will settle on. This was the same type of disruption that occurred when the EPA banned CFCs in the 90’s.
We are fortunate that technology in the cleaning business has made great strides in the past 30 years. The fluids and equipment technology shift has 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 manufacturer’s requirements.
