Discussion and Conclusions from 

Sessions 2 and 3

U.S. Environmental Protection Agency

Maria J. Doa 

Washington DC 

U.S. Environmental Protection Agency
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

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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?

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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 

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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

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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

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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 

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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 

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• 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

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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 

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Thank You 

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