## Discussion and Conclusions **from**

**Sessions 2 and 3 U.S. Environmental Protection**  **Agency**

Maria J. Doa Washington DC
U.S. Environmental ProtectionAgency

## Outline • Summary of discussion questions • Summary of case studies • Summary of key challenges • Summary of key successes • Summary of lessons learned • Summary of non-chemical exposure reduction options 2 U.S. Environmental ProtectionAgency

## Potential Outcomes of Sessions 2 and 3
• List of criteria that potential alternatives will need to satisfy if they are to be used as replacements for TCE. • What were the key lessons learned in transitioning from TCE to an alternative that could help inform future substitutions? • Are there generalizations that can be made so that future substitutions are easier to conduct? • Are there any characteristics or combinations of characteristics that resulted in no viable alternatives to TCE? • List of measures other than chemical substitution that can be used to reduce exposure to TCE? U.S. Environmental ProtectionAgency 34



## Case Studies • This session addressed issues related to the use of TCE in aerosol form and cold cleaning in both small commercial and consumer settings.

– Case studies on use of aqueous cleaners – Slide Products, Astro Pak, TURI, and IRTA

– Alternatives evaluations

– Transitioning TCE in vapor degreasing U.S. Environmental ProtectionAgency

## Factors to Consider • Need to consider the complete process not just the cleaning step

– Is cleaning needed?

– Is the current level of cleaning necessary?

– Does the process need to be modified?
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## Factors to Consider • Performance • Cost effectiveness • Environmental Health and Safety

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## Factors to Consider • Buy-in from management

– Is there money?

– Is there a commitment?

– Business case is important 

### • Input of hands-on user • Peer feed-back U.S. Environmental ProtectionAgency 7

## Factors to Consider • Costs

– Important to consider costs other than price of TCE and capital costs

– Need to consider other costs associated with the use of TCE

– To use the DoD construct: • Why TCE? • Why not TCE?

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## Why TCE? • Relatively low cost • Non-flammable • High density vapor • Relatively low boiling point • Chemical stability • Ability to dissolve all greases, fats, oils, waxes, resins, gums and rosin fluxes generally used in metalworking operations • Broad compatibility with metal substrates U.S. Environmental ProtectionAgency 9

## Why not TCE? • Cost of control technologies/engineering controls • Record keeping administrative costs • Personal protective equipment requirements • Waste disposal • Increase risk of inhalation exposure route • Potential acute and chronic exposure effects • Subject to multiple regulations U.S. Environmental ProtectionAgency 1011



## Key Challenges • Flammability when cleaning energized electrical equipment • Compatibility with a wide variety of substrates and materials • Functionality and effectiveness in market place/cost effectiveness • Worker training • Military Specifications • Corporate support and funding U.S. Environmental ProtectionAgency12 

### • Pilot the potential product with users • Educating customers • Multiple phase out and reformulations have been successful 

## Key Successes

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## Lessons Learned • Engage the user early • A key initial task is to characterize performance needs such as required level of cleanliness and throughput • On-site visits to facilities to aid in transition • Implementation plan U.S. Environmental ProtectionAgency 13

## Non-chemical exposure reduction

options • Reduce worker exposure by ensuring users have proper training for new processes and/or new equipment • Closed systems • Labeling for commercial purposes only • Proper PPE • Air monitoring U.S. Environmental ProtectionAgency 14

## Thank You

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