EPA’s Expert Public 

Workshop on Alternatives 

and Risk Reduction 

Approaches to 

Trichloroethylene (TCE) 

Use as a Degreaser 

 

Location: U.S. Environmental Protection Agency (EPA) 

Rachel Carson Green Room, William Jefferson Clinton South 

1201 Constitution Ave., NW, Washington, DC 20460 

 

Tuesday, July 29, 2014, 9:00 a.m. – 5:00 p.m.

Wednesday, July 30, 2014, 8:30 a.m. - Noon

 

August 26, 2014

Workshop Summary

Docket EPA-HQ-OPPT-2014-0327
EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as 

a Degreaser Workshop Summary 8/26/2014 ii

Contents

Executive Summary......................................................................................................................... iii

Background .....................................................................................................................................1

Findings from the TCE Risk Assessment...........................................................................................2

Overview and Purpose of the Workshop.........................................................................................4

Evaluating Worker Risks and Process for Informed Substitution and Solvent Selection ................4

Alternatives Process, Efficacy, and Health Considerations..............................................................5

Session 1: Keynote & Background Lectures: Use of TCE and Perspectives on Application.............8

Use of TCE as an Aerosol, Vapor & Cold Cleaner.............................................................................8

Use of TCE as a Vapor Degreaser...................................................................................................11

Regulatory Landscape for TCE in Federal and State Air Programs ................................................12

Overview of Regulations in California on Solvent Degreasers.......................................................14

Purpose and Goals of Afternoon Discussion Sessions...................................................................15

Session 2: Aerosols and Cold Cleaning...........................................................................................15

Session 3: Vapor Degreasing..........................................................................................................24

Public Comment.............................................................................................................................34

Strategies to Reduce Worker Exposure .........................................................................................36

Discussion and Conclusions from Sessions 2 and 3 .......................................................................40

Public Comment.............................................................................................................................42

Wrap Up and Next Steps................................................................................................................43

Appendix A: Workshop Agenda .....................................................................................................45

Appendix B: Speaker Biographies .................................................................................................53
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a Degreaser Workshop Summary 8/26/2014 iii

Executive Summary 

On July 29–30, 2014, EPA held a public workshop on the use of trichloroethylene (TCE) as a degreaser, 

availability and efficacy of safer alternatives, and possible risk reduction approaches. This workshop was 

held to support activities to reduce the health risks from TCE exposures to consumers using spray 

aerosol degreasers and the risks to workers using TCE as a degreaser in small commercial shops 

identified in the final TCE risk assessment, released on June 25, 2014.

One goal of the workshop was to develop criteria that potential alternatives to TCE will need to satisfy. 

Expert panelists examined key lessons learned in transitioning from TCE to various alternatives that 

could help inform future substitutions. The sessions looked at general principles and guidelines so that 

future substitutions are easier to conduct. Panelists also attempted to create a list of methods other 

than chemical substitution that can be used to reduce exposure to TCE. 

This Executive Summary and the brief Workshop Summary that follows are intended to capture the 

main ideas that were presented and discussed. This report is not a transcript, but it is based on the 

contemporaneous notes of a scientist who attended all sessions. No recording or transcript was made of 

the Workshop. Appendix A presents the Workshop Agenda, and Appendix B presents the available 

speaker biographies. Visuals (slides), other supporting materials used or referenced by the speakers, and 

public comments are available on the regulatory docket for the TCE Workshop.

Final TCE Risk Assessment 

In her welcome address, Wendy Cleland-Hamnett of EPA noted that the workshop fits into larger efforts 

of TCE risk reduction. This TCE risk assessment is the first of its kind developed by EPA under the Existing 

Chemicals Program list of TSCA Work Plan chemicals, developed in March 2012.

Tala Henry of EPA presented findings from the TCE Risk Assessment, which focused on TCE use in 

degreasing operations and the products used for degreasing. The TCE Risk Assessment covers 

commercial and consumer use of TCE. The assessment includes information about releases from 

facilities. The main risks identified from TCE for workers and occupational bystanders at small 

commercial degreasing facilities and dry cleaning facilities using TCE-based degreasers and spotting

agents are potential cancer risk concerns and short-term and long-term non-cancer risks. The main risk 

identified from TCE for consumers and residential bystanders using TCE-containing degreasers and 

spray-applied protective coatings are potential short-term non-cancer risks. Workers are mainly at risk 

from inhalation exposure but they are also at risk from dermal exposure. Environmental risks were not 

evaluated as part of the TCE risk assessment due to minimal concerns for ecological hazards. 

TCE Workshop Overview and Keynotes 

Jeff Morris of EPA indicated that the overarching purpose of this meeting is to move forward together to 

find practical solutions that address the risk concerns identified in the risk assessment and to respect the 

industrial process. 
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Solutions for TCE have not yet been identified. EPA needs fit-for-purpose approaches for reducing the 

risks identified in the TCE risk assessment. Degrees of freedom will narrow if we go from voluntary to 

regulatory TCE approaches. EPA would like to encourage voluntary use reduction. 

In the first of the keynote and background lectures, Julia Quint, retired from the California Department 

of Public Health, discussed reasons for using quantitative risk assessments. She outlined general 

guidelines for informed substitution of TCE and other toxic chemicals. The effective substitutes must 

address functional uses. If a substitute has no data, it should be avoided, and other known toxic 

substitutes that may be used as a substitute should be assessed and evaluated. Regrettable TCE 

substitutes have been used in the past, such as N-Hexane and 1-bromopropane.

Jason Marshall of the Toxics Use Reduction Institute (TURI) described his group’s work in researching, 

testing, and promoting pollution prevention and alternatives to toxic chemicals used in Massachusetts 

industries and communities. TURI has worked with hundreds of companies to find safer alternatives to 

hazardous cleaning solvents.

Katy Wolf of the Institute for Research and Technical Assistance (IRTA) described uses of TCE in aerosol, 

vapor, and cold cleaning applications. IRTA believes that EPA should phase out TCE, because it poses a 

high risk to workers and community members. Safer alternatives to vapor degreasing using TCE have 

been demonstrated, and EPA should ban TCE or restrict its use to airless/airtight systems.

Wayne Ziegler of the U.S. Army Research Laboratory emphasized that when labs develop alternatives to 

vapor degreasing cleaning applications, they need to make sure that the solution does not affect

productivity and throughput. The Army is concerned about efficiency, and if an alternative does impact 

efficiency, then his lab researches what they can do to negate the effect. His advice in resolving 

questions about risks of TCE is to work with the company and end users up front to give them ownership 

of the solution, and then it will be more likely to be implemented.

Margaret Sheppard of EPA said that under the Clean Air Act there are major federal regulations 

affecting TCE and its alternatives. Air regulatory requirements affect cleaner selections. There are 

classes of available alternatives to TCE. EPA has a Significant New Alternatives Policy (SNAP) program 

that reviews alternatives. Three air programs affect solvent choice heavily:

 SNAP, ozone layer protection – this program looks at how the alternatives impact human health 

and the environment

 Hazardous air pollutants (HAPs) – this is a list of hazardous air pollutants

 Ground-level ozone and volatile organic compounds (VOC) – can regulate nitrogen and volatile 

organic compounds and a lot are solvents; with heat and sunlight smog can be generated so EPA 

has requirements that are delegated to the states through a state implementation plan.

EPA has a model rule to limit the potential for emissions from solvents. TCE is not an ozone-depleting 

substance and is listed as acceptable under the SNAP program for degreasing and aerosols. SNAP 

categories do not directly address manual cleaning. TCE is a hazardous air pollutant (HAP) and a volatile 

organic compound (VOC) under 40 CFR 51.100(s). TCE use in degreasers is subject to Halogenated 

Solvent Cleaning National Emission Standard for Hazardous Air Pollutants (NESHAP). 

David Edwards of the California Air Resources Board (ARB) discussed various programs and regulations 

in California, such as the Toxic Air Contaminant Identification and Control Program and the Airborne 

Toxic Control Measure. He also described Consumer Products Regulations from 1990 that prevent 

manufacturers from reformulating with HCFCs and TCE due to ozone-depleting potential greater than 
EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as 

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zero. A 1996 rulemaking used risk assessment as a basis for prohibiting the use of TCE and other Toxic 

Air Contaminants in approximately 90 consumer product categories. 

Case studies 

Aerosols and Cold Cleaning 

Katy Wolf of IRTA has worked with users to find alternatives for hundreds of vapor degreasing 

applications, and virtually all of the companies that they worked with converted to water-based cleaning 

systems. The case studies presented by Dr. Wolf documented how IRTA worked with companies that 

used different water-based cleaning systems based on each company’s specific needs. 

IRTA worked on finding safe aerosol alternatives and in the process ended up discovering that you could 

clean with carbon dioxide pellet blasting. IRTA worked with an energized electrical equipment cleaning 

company to switch from aerosols with chlorinated solvents to carbon dioxide pellet blasting/snow. 

IRTA’s project led to a CARB ban of chlorinated solvents and VOC content restrictions. 

Steve Bennett of the Consumer Specialty Products Association recommended that in order to reduce 

existing exposure, commercial/industrial supply chains should restrict sales, and a label should be 

prominently displayed that says “For Commercial Use Only.” TCE should have limited industrial use. 

There should be labeling and warnings that go “above and beyond” MSDS/SDS instructions. There 

should be air monitoring instructions, comprehensive hazard identification, and information about the 

proper use of PPE.

Michael Muth of Slide Products transitioned his company’s products away from TCE in 2011 after 

learning of the potential cancerous effects of TCE. The change was prompted by environmental concerns 

and human health concerns. The company engaged with chemical vendors and worked with their 

customers to figure out what could potentially work as an alternative. Then Slide Products began 

customer trials and product testing. After the transition the company found that they had to convince 

their buyers that the product switch away from TCE was a smarter and safer solution for their clients’

business as well. 

Jason Marshall’s organization, TURI, created a form called the Lab Test Request Form that includes 

introductory questions to gauge a company’s TCE use. Questions in the alternative chemical assessment 

include:

 What is the purpose of cleaning?

 What are the problems with present cleaning systems?

 What are you trying to remove (soils)? 

 What is being cleaned (substrates)?

 How are you cleaning it (equipment)?

 How do you determine how clean is clean?

Brent Ekstrand of Astro Pak is in the aerospace industry, where finding cleaning alternatives is 

challenging because of customer specifications. Astro Pak (with the help of IRTA) conducted a series of 

tests on various types of hardware used by the customer base and challenged those with a number of 

contaminants (typical contaminants encountered by customers and problem contaminants as well). 

Astro Pak then selected a general cleaning agent and cleaning system. The initial investment was 

considerable but they knew that there would be savings in the long run. 
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Astro Pak was able to achieve successful aqueous cleaning. Astro Pak found that with careful technique, 

post-cleaning contaminant levels are lower with aqueous cleaning than with solvents. There were lower 

ongoing costs with aqueous cleaning, which enhanced long-term profitability. Technique, equipment, 

and experience are critical to successfully switch to aqueous cleaning.

Vapor Degreasing 

Wayne Ziegler of the Army Research Laboratory described transitioning from TCE at military facilities. 

He described efforts at the Anniston Army Depot (ANAD) to reduce hazardous emissions and address 

environmental regulations and mandates. Tasks included demonstrations of HAP-free chemical 

depainting materials and processes and HAP-free vapor degreasing for critical weapon systems.

Heidi Wilcox of TURI noted that, when working with companies, it is important to understand the 

client’s point of view. Existing solvents work for clients and their processes because rinse and dry is not 

needed, they are readily evaporative, there are no heavy residues, they protect against corrosion, 

rusting, and the process is generally quick. There is always an alternative to TCE (aqueous, semiaqueous, media blasting, CO2). There are other options besides substitution including changing the

process, working with the supply chain to have parts or stock come in clean, and buying high-tech, 

automated machines to reduce handling of parts and exposure to chemicals.

Information on two alternative commercial products, Solstice PF by Honeywell (Ryan Hulse) and 

Naturama by Green Life Development (Manoj Patel), were presented as potential alternatives to TCE.

Barbara Kanegsberg of BFK Solutions provides process improvement assistance. She concluded that a

productive approach to finding an alternative solution is to manage the process and not the chemical. 

All cleaning processes should have a basic level of safety, environmental control, containment, and 

product safety. Ms. Kanegsberg suggests that inter-agency coordination and cooperation need to be 

increased.

Dan Teitelbaum of EPA described the Toxics Release Inventory (TRI), which compiles data submitted by 

industry on the releases and management of toxic chemicals from certain facilities. Each year companies 

have to report to EPA their releases and transfers of specific toxic chemicals and what the company is 

doing to prevent the releases. Mr. Teitelbaum gave examples of reported pollution prevention 

information. A metal plating and coating company switched from single-stabilized TCE to doublestabilized TCE, which increased the efficiency of their degreaser and reduced waste. A finishing company 

implemented additional testing for alkalinity and used additives to prolong bath life, resulting in fewer 

tank change-outs and a 19% decrease in TCE usage. 

Edward Viveiros of Eastern Research Group (ERG) presented multiple strategies to reduce worker 

exposure. Technologies that eliminate or reduce risk from TCE include bake-off ovens, water-based 

cleaning alternatives, low-solids fluxes, and inert atmosphere soldering.

Alternatives Evaluations 

Alternatives are available for all applications as demonstrated by the successful case studies of the 

panelists. Safer alternatives to vapor degreasing cleaner have been demonstrated (water-based 

cleaners) and if TCE is not banned, then TCE use should be restricted to airless/airtight systems. In cold 

cleaning applications, safer alternatives have been demonstrated. IRTA believes that aerosol solutions 

can be reformulated with safer alternatives in all cases. 
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When evaluating TCE risk reduction, it is important to acknowledge that all cleaning applications are not 

equivalent, and one should not try to replace all vapor degreasing processes with the same alternative. 

Also, the feasibility of switching to aqueous-based cleaners had no adverse results. 

EPA should also attempt to characterize what types of businesses have not made the switch and why. 

Factors to Consider 

There are many factors to consider when assessing TCE use reduction. It is important to consider the 

complete cleaning process of the company and the company’s needs. 

Is cleaning needed? 

Sometimes the cleaning process may not be needed at all. In one case, IRTA worked with a silicone 

implantable medical device company to help the company eliminate the need to clean by using an 

alternative solution. A company may be able to switch to products that do not require cleaning.

Is the current level of cleaning necessary? 

Sometimes a company has to determine how clean is clean enough. The level of cleanliness is affected 

by what the customer wants and the product functionality. 

Does the process need to be modified? 

All cleaning processes should have a basic level of safety, environmental control, containment and 

product safety. If the cleaning process does not have these, then then process needs to be modified. If 

the company is using TCE, it is important to ensure that the appropriate risk reduction strategies are in 

place in the company’s cleaning process. Processes can be modified through alternative technologies, 

engineering controls, workplace practices, and the use of PPE. 

What types of substrates and soils are being used? 

Some cleaning situations require an aggressive solvent because many soils are becoming more difficult 

to remove. In circumstances where a soil is not difficult to remove, a company may be able to switch to 

a less aggressive solvent. Every unique situation requires different alternatives. For example, in the 

Army, the lab has to find a way preserve substrate conditions of weapons when cleaning weaponry. 

Performance 

A company will be more willing to switch to an alternative if their performance is not affected. Different 

solvents have different properties that affect performance. Water-based and solvent-based cleaning 

agents have different characteristics like solubility, aggressiveness, and physical properties so TCE-like 

solvents are desirable in certain situations. 

Cost effectiveness 

A switch to an alternative may be costly up-front, but there may be savings in the long run.

Environmental Health and Safety 

TCE can potentially contaminate groundwater and drinking water if improperly disposed. As detailed by 

Michael Partain (private citizen) in the public comments, there are 132 contaminated DoD bases across 

the country, posing environmental, health, and safety risks to humans. 

Is there buy-in from management? 

Buy-in from management is essential for a company to switch to an alternative. It is important to 

consider the company culture, set up of the process, the needs of the company for the project, the 

capital they have to spend, the space that the company has, the management support, the workers’ and 
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clients’ needs, and how much testing is required for the client. Additionally, there needs to be worker

buy-in. 

Is there money? 

If the company does not have money to spend, it will be hard to make a switch to an alternative. 

The business case is important 

As illustrated by Slide Products, there may be push-back from clients until the client can be convinced 

that a switch to non-TCE products benefits them as well. Making the business case is important and this 

can include convincing the client of the benefits of performance, cost effectiveness, and environmental 

health, and safety factors.

Input of hands-on user 

Piloting an alternative with a company and understanding each company’s individual needs is 

paramount to making a switch. 

Peer feedback 

If one company makes the switch, other companies may make a switch as well.

Costs 

It is important to consider costs other than purchase price of TCE and capital costs. Other costs

associated with the use of TCE need to be considered, as outlined below:

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

Why not TCE?

 Cost of control technologies/engineering controls 

 Recordkeeping and administrative costs

 Personal protective equipment requirements 

 Waste disposal 

 Increase risk of inhalation exposure 

 Potential acute and chronic exposure effects 

 Subject to multiple regulations

 Liability costs

 

Challenges 

There are many challenges associated with finding an alternative to TCE. Challenges that must be 

addressed include flammability issues when cleaning energized electrical equipment, compatibility with 

a wide variety of substrates and materials, and functionality and effectiveness in the marketplace. 

If a company switches to an alternative, workers must be trained, which takes resources and money. 

However, IRTA found that once the new alternative is in place, workers will adapt. If there is not 

corporate support and proper funding, many companies will not be able to make a switch. Also, the DoD 

and Astro Pak illustrated that military specifications pose a challenge because the specifications need to 

be met on top of any effects that the alternative cleaners may provide. 

EPA and industry need to find viable substitutes that do not become regrettable substitutes. If a 

substitute has no data it should be avoided.
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Successes 

TURI and IRTA found that companies were more likely to make a switch to an alternative to TCE if they 

piloted the potential product with users. This included conducting systematic performance testing using 

the specific soils encountered at the facility and piloting the potential product on actual parts by the 

personnel responsible for running the cleaning process. If customers understood the risks of TCE and 

benefits of the alternatives, then they were also more likely to make a switch. Multiple phase-outs and 

reformulations have been successful as well. 

Lessons Learned 

Wayne Ziegler from the Army Lab emphasized if you work with the end users up-front to give them 

ownership of the alternative solution, they will be more likely to implement the new solvent. Heidi

Wilcox and Jason Marshall from TURI also emphasized how important it is to engage the user early on 

in the process. 

A key initial task is to characterize performance needs such as required level of cleanliness and 

throughput. Mr. Ziegler suggested defining performance based on industrial workflow and finding

solutions that will work with each workflow. In case studies outlined by the panelists, some companies 

were able to eliminate their cleaning step entirely after assessing their required level of cleanliness.

Brent Ekstrand from Astro Pak stated that when switching from cold cleaning or solvent cleaning to 

aqueous cleaning there is a learning curve because it is technique-dependent and employees will have 

to be better trained. Equipment selection, rinse techniques, and water quality are critical as well. The 

process cycle may be longer but changes in batch size and process flow can increase capacity. 

On-site lab work to showcase how the alternatives work and on-site visits to facilities to aid them in 

transitions are helpful. The work should be done on-site so that any questions or concerns by the vendor 

can be addressed immediately. An implementation plan is key to getting companies to stick to the 

alternative. 

Additional Recommendations from Panelists 

EPA’s work plan goals and information needs should include identifying potential consumer and worker 

exposures and understanding critical safety considerations (Steve Bennett).

The more that EPA can publicize information, the easier it is for companies to leverage decisions and 

explain product switches to customers (Michael Muth).

A lifecycle cost analysis was not done for TCE, and EPA needs to take into account regrettable 

substitution when suggesting alternatives (Katy Wolf).

Next Steps 

Moving forward, EPA will consider the following:

 A life cycle analysis for all substitutes

 Regulatory options to restrict TCE use

 Revaluating the PELs and RELs to be more protective

 Developing outreach materials and materials for the user community to help them switch to 

viable alternatives

 Risk reduction processes through engineering controls.
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Background 

On July 29-30, 2014, EPA held a public workshop on the use of trichloroethylene (TCE) as a degreaser, 

availability and efficacy of safer alternatives, and possible risk reduction approaches. This workshop was

held to support risk reduction activities concerning the health risks from TCE exposures to consumers 

using spray aerosol degreasers and workers using TCE as a degreaser in small commercial shops 

identified in the final risk assessment that was released on June 25, 2014.

This Workshop Summary is intended to capture the main ideas that were presented and discussed. It is 

not a transcript or a proceedings, but instead it is based on the contemporaneous notes of an 

independent scientist who attended all sessions in person, with reference to the visuals and supporting 

materials that were used by the hosts, moderators, and invited speakers. No recording or transcript was 

made of the Workshop. In all, 124 persons attended the workshop either in person or remotely via 

online webinar and audio teleconference.

Appendix A presents the Workshop Agenda, and Appendix B presents the available speaker biographies. 

Visuals (slides) and other supporting materials used or referenced by the speakers are available on the 

regulatory docket for the TCE Workshop.

Tuesday, July 29, 2014 

9:00 – 9:05 AM: Welcoming Remarks 

Brad Goodwin, American Association for the Advancement of Science, Science & Technology Policy 

Fellow hosted by EPA 

A summary of the workshop will be posted in the docket (EPA-HQ-OPPT-2014-0327). 

Wendy Cleland-Hamnett, Director, EPA Office of Pollution Prevention and Toxics (OPPT) 

Background information on the Rachel Carson Green Room was provided. Ms. Cleland-Hamnett pointed 

out that the EPA Workshop is a “step in the journey” in the existing chemicals TSCA program. The 

workshop fits into larger efforts of TCE risk reduction. In 2009 EPA and the Administration remarked that 

the 1986 TSCA regulations may not be up to the task of ensuring chemical safety in the 21st century and 

therefore, this workshop is an important step forward to ensuring chemical safety.

EPA is working toward legislative reform and has created a list of work plan chemicals to address. EPA is 

dedicated to a more transparent and systematic approach to risk management under TSCA. EPA has 

consulted with experts to develop methodology and has identified chemicals to review. This TCE risk 

assessment is the first of its kind developed by EPA under the Existing Chemicals Program list of TSCA 

Work Plan chemicals, developed in March 2012.

EPA identified risks for certain uses of TCE including TCE use in degreasers. When the risk assessment 

program started, EPA wanted to actively try to reduce risk. EPA is hoping for voluntary use reductions.

EPA will also be pursuing other ways to ensure risk reduction. The final risk assessment of TCE shows

significant risk. 
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9:05 – 9:20 AM: Findings from the TCE Risk Assessment 

Tala Henry, EPA OPPT 

Dr. Henry presented an overview of the Final TSCA Workplan Chemical Risk Assessment of TCE (CASRN 

79-01-6). The Risk Assessment focuses on TCE used in degreasing operations and the products used for 

degreasing. The TCE Risk Assessment covers commercial and consumer use of TCE. The report includes 

information about releases from facilities. 

The main risk identified from TCE for workers and occupational bystanders at small commercial 

degreasing facilities and dry cleaning facilities using TCE-based degreasers and spotting agents are 

potential cancer risk concerns and short-term and long-term non-cancer risks. The main risk identified 

from TCE for consumers and residential bystanders using TCE-containing degreasers and spray-applied 

protective coatings are potential short-term non-cancer risks. 

OPPT needed to prioritize which chemicals should be selected for a risk evaluation. OPPT selected TCE 

for a risk evaluation because of the human health hazard concerns of TCE as a human carcinogen and 

concern for TCE’s harmful non-cancerous effects. There is a high exposure potential because TCE is 

produced and imported into the U.S. in large quantities (>250 million pounds/yr). The Toxic Release 

Inventory (TRI) database reports that TCE is predominantly released to air and therefore inhalation is a 

predominant exposure pathway. Dermal exposures are also an issue but inhalation exposure is the main 

cause of concern.

Human health inhalation hazards stem from TCE commercial use as a solvent degreaser, commercial use 

as a spotting agent in dry cleaning, consumer use as a solvent degreaser, and consumer use as a clear 

protective coating spray in arts and crafts. 

Environmental risks were not evaluated as part of the TCE risk assessment due to minimal concerns for 

ecological hazards. 

EPA reviewed TCE exposure scenarios for individuals and populations of interest spanning different age 

groups for potential TCE exposure. EPA assessed exposure scenarios based on one hour of exposure. 

Both acute and chronic exposure levels were assessed. EPA referenced the 2011 TCE IRIS assessment. 

(See slide number 5 of Dr. Henry’s visuals). 

Dr. Henry examined several conceptual models of how the exposure assessment was created for a

degreasing scenario. These included: 

1. Identifying relevant industries by North American Industrial Classification System (NAICS) codes; 

2. Estimating air releases of TCE based on the National Emissions Inventory (NEI) and Toxics 

Release Inventory (TRI): 

1. Compare NEI and TRI air releases for the same year (2008)

 a) NEI air emissions are approximately 2x higher than those reported in TRI

b) Use data from 2011 TRI but scale air releases by 2x; this captures downward trends;

3. Estimating facility and operating parameters

1. Use data from the 2008 NEI to estimate

a) Number of large/small facilities

b) Number of degreasing units (machines) at large/small facilities

c) Degreasing units per large/small facility;

2. Use EPA’s draft generic scenario on vapor degreasing to estimate days and hours of operation 

per year;
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4. Estimating TCE emissions potentially escaping into the workplace;

5. Estimating potential workplace exposures

1. Use a Near-Field/Fair-Field mass balance model

2. Estimate exposures for workers and occupational non-users.

Dr. Henry showed two charts of acute and chronic workplace exposure concentrations. The information 

included potential TCE Inhalation Exposures, OSHA Monitoring Data, and Workplace Inhalation 

Exposures (see PowerPoint). The charts are not all worst case scenarios. OSHA monitoring data (39 

samples) differed from EPA estimates.

The following information is detailed in Dr. Henry’s presentation available in the docket, titled 

“Workshop Presentations” (-0008).

In the 2011 EPA IRIS Assessment there was a comprehensive review of hazard/dose-response studies of 

TCE and TCE metabolites. TCE is readily absorbed/distributed via oral, dermal, and inhalation pathways 

(metabolism occurs and plays a role in hazard) and is considered a human carcinogen. Non-cancer 

effects of TCE include neurotoxicity, and endpoints including immune systems, livers/kidneys, male 

reproductive organs and developing fetuses (the most sensitive endpoint). 

OPPT assessed hazard/dose-response for cancer effects and non-cancer TCE effects differently. EPA 

assessed non-cancerous TCE effects using different health endpoints to evaluate acute or chronic 

exposure. EPA assessed cancerous effects using the inhalation unit risk derived in the 2011 IRIS 

assessment for the worker scenario of chronic exposure. 

Dr. Henry listed chronic non-cancer risks for occupational exposures including: 

 Potential chronic non-cancer risks for a range of human health effects in both occupational 

degreaser and spot cleaning exposure scenarios (i.e., MOEs were below the benchmark MOE).

 Greatest concern was for developmental effects (i.e., fetal cardiac defects), followed by kidney 

effects and then immunotoxicity, with an overall higher chronic risk for the degreaser exposure 

scenarios. In general, this concern was irrespective of the type of exposure (typical vs. worst 

case) and the availability of room ventilation (LEV vs no LEV). 

 Potential chronic risks for reproductive effects and neurotoxicity for degreaser worker exposure 

scenarios. However, the risk concerns for these effects were reported for fewer spot cleaning 

worker/bystander scenarios and generally attributed to exposure conditions without room 

ventilation. 

 Potential chronic risks for liver effects although the risk were less prominent than those 

reported for other health effects. These risks were found only in the degreaser 

worker/bystander exposure worst case scenarios and the spot cleaning worker/bystander worst 

case scenarios with no LEV.

Dr. Henry listed acute non-cancer risks for occupational exposures including: 

 Potential acute non-cancer risks for developmental effects (i.e., cardiac defects) for most 

occupational and residential exposure scenarios (i.e., MOEs were below the benchmark 

MOE of 10.).

 Degreaser exposure scenarios showed greater acute risks for developmental effects than 

those reported for the spot cleaning exposure scenarios. 
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9:20 – 9:30 AM: Overview and Purpose of Workshop 

Jeff Morris, EPA OPPT 

The overarching purpose of this meeting is to move forward together to find practical solutions that 

address the risk concerns identified in the risk assessment and to respect the industrial process. 

Solutions for TCE have not yet been identified. EPA needs fit-for-purpose approaches for reducing the 

risks identified in the TCE risk assessment. Degrees of freedom will narrow if we go from voluntary to 

regulatory TCE approaches. EPA would like to encourage voluntary use reduction. 

9:30 – 9:55 AM: Evaluating Worker Risks and Process for Informed Substitution 

and Solvent Selection 

Julia Quint, California Department of Public Health (Retired) 

It is important to look for safe alternatives to TCE and to examine the current status of occupational 

worker limits. In California OSHA and Cal/OSHA set occupational worker limits. A lot of countries use the 

US Standards for TCE and the current limit for TCE is 10 ppb, but it is recognized as a suspected human 

carcinogen. 

OSHA proposed a 50 ppb exposure limit but currently the exposure limit is set at 100 ppb and there has 

been no Quantitative Risk Assessment (QRA). Cal/OSHA uses an advisory committee to determine the 

proposed levels and then lets people know publicly. QRAs are used to develop permissible exposure 

limits (PELs) and OSHA is responsible for demonstrating significance of risk when developing PELs.

Why should QRAs be used? OSHA published cancer risk estimates—1.2 to 2.3 excess cancers per 1,000 

workers—need to lower standard based on QRA and then it will significantly reduce the risk from 

exposure to TCE. QRA has been used for a few other carcinogens in OSHA. In 1997 Cal/OSHA created an 

Airborne Contaminants Advisory Committee to create PEL recommendations. Chemicals were identified 

from the committee as being carcinogenic. TCE was identified as a carcinogen by the committee. 

The CA Legislature created the Hazard Evaluation System & Information Service (HESIS), Occupational 

Health Branch, CDPH in 1979 to identify workplace chemical hazards and evaluate chemical risks to CA 

workers. One incident occurred where male workers were made sterile due to chemical hazards in the 

workplace and the Legislature wanted to make sure this did not happen again. The legislature wanted a 

program to monitor literature to translate “toxicology” into “practical language” so that employers and 

visitors could easily understand the warnings. Also the program is a good way to engage the public 

about statewide health. The legislature also recommends protective standards and issues “early 

warnings” on new/unrecognized hazards.

Cal OSHA has no toxicologists but they use the California EPA’s Office of Environmental Health Hazard 

Assessment (OEHHA). OEHHA develops and recommends protective exposure levels for toxic air 

contaminants to the Air Resources Board. They also list chemicals that are known to the state to cause 

cancer or reproductive harm to implement Proposition 65. 

“Proposition 65 requires the State to publish a list of chemicals known to cause cancer or 

birth defects or other reproductive harm. This list, which must be updated at least once a 

year, has grown to include approximately 800 chemicals since it was first published in 1987.” 

(Source: http://oehha.ca.gov/prop65/background/p65plain.html) 

Some key findings of the CA Occupational Health Hazard Risk Assessment Project included:
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 44 workplace chemicals listed as “known to cause cancer” did not have PELs and not everything 

on the Prop 65 List concerns people;

 5 chemicals listed as “known to cause reproductive/developmental toxicity” did not have PELs;

 62 Prop 65-listed carcinogens had PELs that were not based on cancer (no QRAs conducted);

 14 Prop 65-listed reproductive/developmental toxicants had PELs that were not explicitly based 

on this endpoint, or the PEL bases were unclear.

The CA Occupational Health Hazard Risk Assessment found that QRAs should be applied to the 

workplace and that using QRAs to develop OELs requires experts. The program was reviewed by NIOSH.

Lifetime cancer risks at existing PELs are high for many workplace chemicals and science-based OELs can 

be developed using a transparent and risk-based approach. The program should have a transparent, 

public process to determine if the Risk Assessment is feasible. 

Evaluating worker chemical risks has challenges because there are so many chemicals and there is 

limited toxicity and QRA data. One suggestion for mitigating risk in the workplace is to adjust levels 

based on the amount of air intake of workers. There are limited toxicology resources in OSHA and other 

occupational health agencies/programs; and exposure and use information is lacking, which makes 

chemical prioritization difficult. There is limited participation of key stakeholders including small 

employers and worker representatives. There are also numerous and competing worker protection 

obligations like dealing with infectious disease, heat, ergonomics, safety, etc. 

Dr. Quint outlined general guidelines for informed substitution of TCE and other toxic chemicals. The 

effective substitutes must address functional uses and an emphasis should be placed on functional use. 

If a substitute has no data, it should be avoided, and other known toxic substitutes that may be used as 

a substitute should be assessed and evaluated.

There have been regrettable TCE substitutes used in the past. N-Hexane was used in auto cleaners as a 

substitute solvent for TCE, and workers developed peripheral neuropathy that was diagnosed by an 

occupational medicine physician. (It was hard to diagnose.) However, a health advisory warning was 

then issued about n-Hexane. After that incident, industry was able to develop aerosol containers that 

did not have unsatisfactory solvents mixed in. 

1-bromopropane was another regrettable substitute for TCE. In 2003 it was learned that it was a

reproductive toxicant and it was tested for carcinogenicity. 

There are ways to prevent adverse effects on workers’ health from regrettable substitutions and these 

include requiring toxicity testing before marketing new chemicals and implementing restrictions, as 

needed, to help ensure safe use. We should integrate and coordinate strategies to protect health and 

the environment from toxic chemicals and identify and specify chemicals that cannot be used as 

substitutes for restricted toxic chemicals. We should also support/ensure the development of safer 

alternatives for specific uses of toxic chemicals that are demonstrated to be efficacious and costeffective before restricting chemical uses.

9:55-10:15 AM: Alternatives Process, Efficacy, and Health Considerations 

Jason Marshall, Lab Director at the Toxics Use Reduction Institute (TURI) 

Dr. Marshall stated that the Toxics Use Reduction Institute (TURI) researches, tests, and promotes 

pollution prevention and alternatives to toxic chemicals used in Massachusetts industries and 
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communities. The lab Dr. Marshall works in has been open since 1993 and has worked with many 

companies on TCE and other hazardous chemicals. 

His lab works to develop and promote safer alternatives to hazardous solvents and conducts processspecific testing. His lab assists industry in the search for safe cleaning processes and does so with

outreach, on-site walkthroughs, piloting (on-site and in the lab), and on-site follow-up assistance to 

industries or companies. 

The TURI lab has worked with hundreds of companies to find safer alternatives to hazardous cleaning 

solvents. TURI’s clients implement a change 3x more than the national average. (Prior to 2007, 33% of 

the companies fully adopted the lab’s recommendations and in the next two years, nearly 80% of the 

companies TURI worked with adopted the lab’s recommendations.

Dr. Marshall worked with EPA Region 1 in Rhode Island. His lab went door to door to find users of 

products containing TCE. After finding companies that used TCE, TURI conducted workshops with the 

companies and they were able to reduce the amount of TCE used substantially. 

TURI looks at alternatives assessment options for companies using TCE and analyzes performance of the 

chemical, health, and environmental concerns and cost. His company created a two page form called the

TURI Lab Test Request Form that includes introductory questions to gauge a company’s TCE use. 

Questions that TURI identified that need to be asked before an alternative chemical assessment include:

 What is the purpose of cleaning?

 What are the problems with present cleaning systems?

 What are you trying to remove (soils)? 

 What is being cleaned (substrates)?

 How are you cleaning it (equipment)?

 How do you determine how clean is clean?

After asking introductory questions, TURI works with the company to figure out an alternative. TURI will 

conduct an analysis with the item that the company is trying to clean and the equipment that will be 

used. In order to identify an alternative chemical, TURI assesses the ability of the new chemical to 

remove the contaminants, the compatibility with the surfaces to be cleaned, and the safety of the 

chemical in the environment and for the worker. 

The process is challenging because there is a lot of information from different vendors so it is hard to 

figure out what is out there and what will work for each company. There is a need for an easier selection 

method. TURI uses a performance testing process with five main steps (see Dr. Marshall’s visuals for 

details). 

In Phase 1 of finding alternatives, the TURI Lab uses a database of testing to identify safer and effective 

products and matches chemical performance based on contaminants, substrates, equipment, and 

current solvents. All of the testing that the TURI lab has done is available to the public at: 

cleanersolutions.org. TURI compares results on the website. Phase 2 is the first lab testing evaluation 

and uses basic operating conditions, coupons matching part substrate, supplied contaminants, and 

comparisons with current solvents if possible. The first two stages are based on initial safety screening.

Phase 3 is introducing a process. There is an advanced lab evaluation of alternatives and TURI uses 

client-specific operating conditions. TURI compares the new alternative with the current solvent if 

possible and determines if there are any health risks that the screening does not address. In Phase 4 of 
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Testing an Alternative, TURI conducts a pilot cleaning in a lab setting. Client-specific operating conditions 

and client supplied parts are used. If possible, TURI will send or bring parts to the client for an 

assessment. In Phase 5 of Testing an Alternative, the pilot testing is conducted at the client facility and 

the best alternative cleaning products are used. Operating conditions from lab piloting are used and 

TURI modifies the conditions if necessary. Then TURI sets up piloting off-line from the current system 

and compares the pilot cleaned parts with the current system for parts from the same manufacturing 

lot. Then they get the end user input for performance. 

TURI’s website cleanersolutions.org shows the lab testing results from their work with vendors. Vendor 

supplied data is also on the website. The public can search the results for alternative chemistries. The 

public can use the database to do a side-by-side comparison of different chemistries as well. Vendors 

can also search the database.

TCE-specific testing was done by TURI. A summary of testing conducted at a TURI Lab is available from 

1993 through 2013. 

Industry sectors that TURI has worked with include aircraft vendors, capacitor manufacturers, jewelry 

vendors, plating & metal working companies, semiconductor/electronics companies, tool vendors, wire 

& cable companies, and general manufacturers. The many types of alternatives TURI has found are 

alcohol based cleaners, alcohol-semi-aqueous, alkaline aqueous, biobased, caustic, ester, HCFC, HFE, 

neutral aqueous, nPB, organics, petroleum distillate, semi-aqueous, terpene, and volatile methyl 

siloxane alternatives. Different soils have been cleaned with the alternatives including buffing/polishing 

compounds, oil, paints/inks/coatings, waxes, and others. 

Performance, health & environment, and cost should be considered when selecting an alternative 

option. An EHS assessment should be conducted that includes safety screen scores, a comprehensive 

evaluation, and green certifications. The comprehensive evaluation should include the Pollution 

Prevention Options Assessment System developed by TURI and should systematically examine the 

potential environmental and worker impact in a comprehensive manner. It should compare options with 

current technology using quantitative and qualitative factors. 

The Assessment covers 11 categories of acute human effects and toxicology. The categories include 

inhalation LC50, PEL/TLV, IDLH, respiratory irritation, oral LD50, dermal irritation, skin absorption, 

dermal LD50, and ocular irritation. 

There should be a P20ASys Comparison Summary to figure out the final weighted score and third party 

green products like EPA DfE, Green Seal GS E4, and Ecologo to prevent pollution. 

The selection process is more than what works and is safe. Alternatives should be tested on each 

company’s specific soils. Outreach is key as well because TURI found that in Rhode Island, two 

companies were two blocks apart and using the same process and they did not know. 

Question from Audience: 

What is the cost involved in the DfE process?

Answer by Jason Marshall, TURI: 

The cost will depend on the number of products that you want to have tested—for performance it is

something they can work with—basic testing is $500 and is pretty timely. Since the work is also done at 

a university, they can maintain low labor costs. 
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10:30 AM: Session 1: Keynote & Background Lectures: Use of TCE and 

Perspectives on Application 

Chair: Doug Parsons, OPPT, EPA 

Each presentation in this session will address the following questions regarding aerosol, cold cleaning, 

and vapor degreasing uses of TCE.

 What are the current degreasing uses of TCE?

 What contaminants does TCE remove?

 What substrates is TCE compatible with?

 What properties of TCE make it an effective degreaser and preferable over alternatives?

 What other factors are important to the use of TCE as a degreaser?

 What health/safety considerations must be considered when using TCE?

 What applications/soils/substrates is TCE not appropriate for use with?

10:30 – 11:00 AM: Use of TCE as an Aerosol, Vapor & Cold Cleaner 

Katy Wolf, Institute for Research and Technical Assistance (IRTA) 

Safer Alternatives to Trichloroethylene in Vapor Degreasing, Cold Cleaning and Aerosol Applications: 

The California Experience 

Dr. Wolf’s presentation was about the use of TCE in degreasing and in cold cleaning. In California, 

policies have been adopted for restricting and eliminating the use of TCE. Safer and cost-effective 

alternatives are available and are currently being used. 

TCE is used in vapor degreasing of fabricated metal parts, in aerosol cleaning products, is an 

intermediate in production of refrigerants, and in cold cleaning of equipment, hand wipes, and spotting 

chemicals. 

Properties of TCE:

There is no flash point of TCE, which has always been a marketing point because it can be heated better 

than other chemicals and the high boiling point means better quality cleaning. It is also an aggressive 

solvent, is suitable for removing heavy oil and grease, and has a high evaporation rate. 

Vapor Degreasing: 

TCE solvent is heated to its boiling point in a vapor degreaser. The degreaser has a set of cooling coils 

and parts are generally lowered into the vapor degreaser where the hot solvent in the vapor zone 

carries the contaminants into the liquid so that the user is always cleaning with vapor which is clean. The 

many types of vapor degreasers include conveyorized, batch open top, and airless/airtight. 

Cold Cleaning:

Generally TCE is not heated when cold cleaning is used, and cold cleaning is often in an open tank or 

remote reservoir. There are no cooling coils in cold cleaning. In cold cleaning the exposure to workers is 

higher than for vapor degreasers because the solvent is not contained by cooling coils. 

Aerosol Products:

Aerosol products were usually used as a carrier solvent or cleaning solvent and the exposure in this is 

higher than cold cleaning because workers can inhale the spray from the aerosol containers. The TCE 

was then in the breathing zone. Aerosol cans generally used a propellant. 
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IRTA Approach to Safer Alternatives 

IRTA works with several companies; identifies products (alternatives) on the market; once the company 

has satisfactory alternatives and consumers accept them, they approach a regulatory agency to 

adopt/implement a regulation. This has led to regulations that have reduced hazardous substances in CA 

by more than 100 tons per day. IRTA identifies, develops, tests, and demonstrates alternatives that 

perform well and are cost effective.

Brief History of TCE Use in California

TCE was used extensively in vapor degreasing and cold cleaning in the 1960s and 1970s. TCE was used as 

a cleaner in the 60s and 70s because it was a good cleaner due to no flash point. In the late 1960s, one 

of the agencies in California identified TCE as a VOC that was contributing to California smog and in 1973 

it was labeled a carcinogen. In 1996 EPA adopted NESHAP and TCA (trichloroethane) was essentially 

banned—at the time there were 3000 vapor degreasers and most relied on TCA. Most people then 

adopted water-based cleaners and the water-based cleaning evolved and improved. Some users 

converted to regrettable substitutes. Local air districts adopted increasingly stringent VOC regulations 

on vapor degreasing and cold cleaning in the 1990s. After 2000, local air districts and CARB continued to 

adopt VOC regulations and began banning the use of chlorinated solvents (PERC, TCE, Methylene 

chloride) in many applications. 

Regulations specifically limiting TCE Use in Applications of Interest 

SCAQMD regulations set 25 grams per liter VOC limit for open top vapor degreasers and cold cleaning 

units. CARB banned the use of chlorinated solvents in automotive aerosol cleaners. 

Case Studies – Vapor Degreasing 

IRTA worked with users to find alternatives for hundreds of vapor degreasing applications and virtually 

all of the companies that they worked with converted to water-based cleaning systems. 

One of the companies that IRTA worked with, a nameplate company, converted to a conveyor waterbased system, which was much more cost effective for the company than using open-top vapor 

degreaser. Another company, a contract cleaning company, switched to ultrasonic cleaning. The 

company ended up with a contaminated site due to vapor degreasing and when IRTA first started 

working with the company, IRTA helped test the company’s parts and was able to assist the company to 

convert to an ultrasonic water-based cleaning system. A third case study presented by Dr. Wolf involved 

an Aerospace contractor that had used vapor degreasing and was able to switch to a spray cabinet 

water-based cleaning system. 

The case studies presented by Dr. Wolf showed how IRTA worked with different companies that ended 

up using different water-based cleaning systems based on the company’s specific needs. 

Cold Cleaning Case Studies

IRTA conducted EPA-sponsored projects to find alternatives to VOC solvents in repair and maintenance 

cleaning. VOC solvents are used by auto repair and industrial facilities. Some auto repair and industrial 

facilities used TCE. IRTA worked with many facilities of both types to figure out a way to optimize the 

use of water-based cleaners for applications. 

Water-based cleaning is now institutionalized in California for cold cleaning. The South Coast Air Quality 

Management District (SCAQMD) passed a regulation that became effective in 1999 and 40,000 

operations converted to water-based cleaners, which reduced VOC emissions by 18 tons per day. Over 
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the next several years, other local air districts in California adopted similar regulations, and VOC 

emissions were reduced in California by 36 tons per day. 

IRTA worked with a number of aerospace subcontractors and auto repair facilities who ended up 

adopting water-based cleaning systems. IRTA also tried to find other alternatives as well for companies

(not just water-based cleaning). For instance, IRTA worked with a silicone implantable medical device 

company to help the company eliminate the need to clean (by using an alternative solution). In some 

cases, experts can help a company figure out a way to eliminate the need to clean altogether. 

Case Studies: Aerosols

IRTA conducted EPA/Hazard Evaluation System and Information Service (HESIS)/California Air Resources 

Board (CARB) projects to find alternatives to VOCs and chlorinated solvents in automotive aerosol 

cleaning applications that are used by auto repair shops, industrial facilities, and consumers. Aerosol

products include brake cleaners, general purpose degreasers, carburetor and fuel injection system 

cleaners, and engine degreasers. IRTA worked with about 25 auto repair facilities and some consumers 

to reduce aerosol use. In California, it is against the law to restrict a specific product type, so IRTA 

needed to find alternative chemicals or solutions that could be used in aerosol cans. IRTA developed and 

tested alternatives including water-based aerosols, acetone, and soy. IRTA figured out how to put a 

water-based cleaner in an aerosol can and also tested the use of acetone. Acetone is lower in toxicity 

than all other organic solvents and is not a VOC, so it was a good solution.

IRTA worked with an automotive dealership to switch to water-based brake cleaning systems and 

worked with an auto repair facility to switch from aerosols to water-based spray bottles. IRTA worked 

on finding safe aerosol alternatives and in the process ended up discovering that users could clean with 

carbon dioxide pellet blasting. IRTA worked with an energized electrical equipment cleaning company to 

switch from aerosols with chlorinated solvents to carbon dioxide pellet blasting/snow. 

IRTA’s project led to a CARB ban of chlorinated solvents and VOC content restrictions. 

Conclusion:

IRTA believes that EPA should phase out TCE. TCE poses a high risk to workers and community members 

in vapor degreasing, cold cleaning, and aerosol applications. Alternatives are available for all 

applications as demonstrated by the successful case studies of IRTA’s work with various companies. 

There are safer alternatives to TCE for vapor degreasing that have been demonstrated, and IRTA 

believes that EPA should ban TCE or restrict its use to airless/airtight systems. 

IRTA believes EPA should ban TCE in cold cleaning applications because safer alternatives have been 

demonstrated. Even Dow Chemical, a manufacturer of TCE, no longer recommends its use in cold 

cleaning. Additionally, exposure to TCE cannot be controlled in cold cleaning applications.

IRTA believes EPA should ban TCE in aerosol applications because aerosol solutions can be reformulated 

with safer alternatives in all cases. 
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a Degreaser Workshop Summary 8/26/2014 11

11:00 – 11:30 AM: Use of TCE as a Vapor Degreaser 

Wayne Ziegler, U.S. Army Research Laboratory 

Mr. Ziegler works in the Army Research Lab and is part of the Joint Service Solvent Substitution 

Working Group (JS3). The working group is part of the U.S. Army Research, Development and 

Engineering Command (U.S. Army RDECOM). JS3 combines shared expertise in the Navy and the 

Army. As a group in the Department of Defense, they worked toward coming up with a process 

to implement alternatives to vapor degreaser use. 

Mr. Ziegler stated that his area of expertise is engineering and in his position he is researching ways to 

preserve substrate conditions of weapons when cleaning weapon material. The lab tries to approach 

cleaning solutions from a pollution prevention standpoint. 

In terms of vapor degreasing, the lab needs to make sure when they develop alternatives to vapor 

degreasing cleaning applications that the solution does not have an impact on productivity and 

throughput. The army is concerned about efficiency and any solution needs to reflect that. If an 

alternative does impact efficiency then the lab researches what they can do to negate the effect. 

The lab examines industrial processes. Mr. Ziegler’s presentation showed a visual of vapor degreasing 

basics. 

Why use vapor degreasing?

Vapor degreasing was historically used because there was a mindset that it was a simple way to clean. It 

is very effective and broadly compatible. It is reliable and excellent for cleaning complex geometries and 

relatively independent of the amount of soil. Vapor degreasing requires minimal floor space, has 

relatively low energy costs, and can be configured as a batch process or in-line. 

Why TCE:

TCE is used in vapor degreasing because it has relatively low cost, is non-flammable, has high density 

vapor, a relatively low boiling point, chemical stability, and the ability to dissolve all greases, fats, oils, 

waxes, resins, gums, and rosin fluxes generally used in metalworking operations. TCE also has broad 

compatibility with metal substrates. 

Why not to use TCE in Vapor Degreasing

The cost of control technologies/engineering controls is high for TCE use. There are record keeping and 

administrative costs involved in TCE. There are personal protective equipment (PPE) requirements for 

TCE and in general, workers don’t tend to like using PPE. TCE waste must be disposed properly and there 

are potential acute and chronic exposure effects. There is an increased risk of inhalation exposure 

routes when using TCE in vapor degreasing. Additionally, TCE is subject to multiple regulations. 

Options to Reduce TCE Risk

There are options to manage the risk and reduce TCE exposure in vapor degreasing processes. Managing 

the risk/reducing the exposure includes managing engineering controls (switch to airtight systems,

which operate different from open-air systems), manage PPE (it is important to find a way that reduces 

workers’ need to wear as much PPE), and monitoring the equipment and process. 

Replacing TCE in vapor degreasers is done by qualifying alternative chemistry, modifying equipment as 

required, and adapting work flows. 
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Lastly, to reduce TCE exposure, a company could replace the vapor degreasing workflow. However, this 

may not be possible without a capital investment. Adapting a workflow is a significant challenge upfront 

and would need to be addressed/mitigated. 

Mr. Ziegler’s lab looks at the process as a whole and asks the question of what is the end goal? It is 

important to look at the end goal of the cleaning process when determining the best option to reduce 

use of and exposure to TCE. 

Considerations for Evaluating Processes

When evaluating TCE risk reduction, it is important to acknowledge that all cleaning applications are not 

equivalent and one should not try to replace all vapor degreasing processes with the same alternative. It 

is important to define the cleaning process. It is important to realize that regulations continue to evolve 

and alternative solutions may need to evolve. Focus for evaluating processes should be on capability and 

cost. Ask the question “How clean is clean?” When possible, figure out a work plan that eliminates the 

cleaning process completely. 

Keys to Success:

Mr. Ziegler’s advice for success:

 Define performance based on your industrial workflow

 “Pursue the possible” and find solutions that will work with your workflow

 Focus on how to solve the problem 

 Work with the company/user upfront and work with the end users upfront to give them 

ownership of the solution, and then it will be more likely that they will implement it.

11:30 – 11:45 AM: Regulatory Landscape for TCE in Federal and State Air 

Programs 

Margaret Sheppard, EPA Office and Air and Radiation (OAR) 

Margaret Sheppard works in the Stratospheric Protection Division. Under the Clean Air Act there are 

major federal regulations affecting TCE and its alternatives. Air regulatory requirements affect cleaner 

selections. There are classes of available alternatives to TCE. EPA has a Significant New Alternatives 

Policy (SNAP) program that reviews alternatives. 

Three air programs affect solvent choice heavily:

 SNAP, ozone layer protection—how the alternatives impact human health and the environment

 Hazardous air pollutants (HAPs)

 Ground-level ozone and volatile organic compounds (VOC)—can regulate nitrogen and volatile 

organic compounds and a lot are solvents, with great heat and sunlight you can generate smog 

so EPA has requirements that are delegated to the states through a state implementation plan

EPA has a model rule to limit the potential to emit for solvents.

Impact of Air Regulations on Cleaners

To comply with air regulations, an assessment should be made on cleaners to determine if it is an ozonedepleting substance (ODS) to be phased out of production. 

SNAP has posted a list of acceptable cleaning alternatives (evaluated for ozone depletion):

http://www.epa.gov/ozone/snap/solvents/index.html. EPA publishes substitutes in the federal register 
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and the list is updated on the web. Industry should ensure that the cleaning method or chemical is on 

SNAP’s list of acceptable alternatives. Before a substitute can be put into commercialization or before it 

can be marketed, it needs to be reviewed by the SNAP program. 

 Is the chemical one of 187 HAPs under the Clean Air Act (CAA)? HAPs are regulated by 

industrial category. 

 Is the chemical a VOC under 40 CFR 51.100(s) or is it exempt? Regulated VOCs may be 

subject to state limits. Some chemicals are exempted because of negligible impacts on 

ground-level ozone so they are less regulated. 

Impact of Air Regulations on TCE

TCE is not an ozone depleting substance and is listed as acceptable under the SNAP program for 

degreasing and aerosols. SNAP categories do not directly address manual cleaning. TCE is a hazardous 

air pollutant (HAP) and a volatile organic compound (VOC) under 40 CFR 51.100(s). TCE use in 

degreasers is subject to Halogenated Solvent Cleaning National Emission Standard for Hazardous Air 

Pollutants (NESHAP). 

See presentation for a visual of the classes of solvent alternatives. Classes include: “no-clean” 

technology; oxygenated solvents; brominated solvents; HFCs & HFEs; hydrocarbons, terpenes; 

chlorinated solvents; semi-aqueous cleaning; and aqueous cleaning.

SNAP Program

The SNAP program sets up broad categories of alternatives for solvents and is a part of the U.S. response 

to Montreal Protocol on Ozone-Depleting Substances that Deplete the Ozone Layer. Section 612 of the 

Clean Air Act directs EPA to evaluate and list substitutes for ozone depleting substances (ODS) that 

reduce overall risk to human health and the environment. SNAP looks at certain criteria of 

environmental and health impacts and looks at exposure in different uses like using a vapor degreaser 

and a number of air quality impacts. 

SNAP covers eight industrial sectors that used ODS historically and includes cleaning solvents and 

aerosols. SNAP looks at the process and chemical substitutes. Substitutes include: alternative chemicals 

(e.g., trans-dichloroethylene), alternative technologies (e.g., aqueous cleaners); and product 

replacement (e.g., no-clean). 

SNAP Solvent Reviews

Criteria for alternatives include an assessment of ozone depletion potential, global warming potential,

local air quality, ecosystem effects, flammability, toxicity, and occupational & consumer health/safety. 

The framework to review an alternative includes assessing whether there is relative risk compared to 

other available or potentially available options and whether or not the alternative is sector-focused. 

SNAP looks at the risk and relies on a menu of options including whether the alternative will promote 

certainty and stability and encourage continuing innovation. SNAP also considers existing rules and 

standards from other government departments.

Recent SNAP solvent reviews include three chemicals there were listed as acceptable. The acceptable 

chemicals are: Trans-1-chloro-3,3,3-trifluoroprop-1-ene (cleaning, aerosols); Perfluoro-n-butyl iodide 

(cleaning); and HFE-347pcf2 (cleaning, aerosols). Current solvents under review are HFO, CFO, and HFC. 

New chemicals are also reviewed by the New Chemicals Program. 
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11:45 AM – 12:00 PM: Overview of Regulations in California on Solvent 

Degreasers 

David Edwards, Ph.D., California Air Resources Board 

California Air Resources Board Consumer Products Program: Prohibition of Trichloroethylene 

California has a Toxic Air Contaminant Identification and Control Program. In 2000 there was an 

Airborne Toxic Control Measure for Emissions of Chlorinated Toxic Air Contaminants from Automotive 

Maintenance and Repair Activities. 

California Toxic Air Contaminant Identification and Control Program

The California Toxic Air Contaminant Identification and Control Program was established pursuant to 

Assembly Bill (AB) 1807 in California. The Board identified TCE as a Toxic Air Contaminant (TAC) in 

October 1990 and a risk assessment was completed. There was no board-specified threshold exposure 

level for TCE. The Airborne Toxic Control Measure (ATCM) must reduce emissions to the lowest level 

through application of Best Available Control Technology for Toxics (T-BACT). 

2000 ATCM for Emissions of Chlorinated Toxic Air Contaminants from Automotive Maintenance 

and Repair Activities

In 2000 the ATCM reduced the emissions of perchloroethylene (perc), methylene chloride (MeCl), and 

trichloroethylene (TCE) from the following products used in automotive maintenance and repair (AMR): 

brake cleaners; carburetor cleaners; engine degreasers; and general-purpose degreasers. AMR products 

manufactured for sale in California cannot contain Perc, MeCl, or TCE as of June 30, 2001. Products 

manufactured prior to June 30, 2001 were allowed to be sold until June 30, 2002. Products were allowed 

to be used by AMR facility owners and operators until December 31, 2002. 

What are consumer products?

In California a consumer product is defined as a chemically formulated product used by household and 

institutional consumers. The types of products can include cleaning products, aerosol paints, 

antiperspirants and deodorants, household pesticides, personal care products, and automotive specialty 

products. 

Consumer Products Regulatory History

Milestone rulemakings include an Antiperspirants and Deodorants Regulation in November 1989, a 

Statewide Consumer Products Regulation in August 1990, and a regulation about Aerosol Paints in 

February 1995. Milestone accomplishments include TAC reductions over 13 tons per day, VOC 

reductions of 218 tons per day by 2015, and GHG reductions of -0.23 MMT of CO2 equivalents per year. 

Consumer Products Regulation

The Consumer Products Regulation from 1990 contains an ozone depleting provision and prevents 

manufacturers from reformulating with HCFCs and TCE due to ozone depleting potential greater than 

zero. The regulation allows compliant products already containing ozone depleting compounds to retain 

formulation. 

In 1996 the rulemaking used the risk assessment performed under the California Toxic Air Contaminant 

Identification and Control Program as a basis for prohibiting the use of TCE and other Toxic Air 

Contaminants in approximately 90 consumer product categories. The product categories for regulation 

were identified through an industry survey and a review of technical literature. 
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1:00 – 1:10: Purpose and Goals of Afternoon Discussion Sessions 

Maria J. Doa, EPA OPPT 

The purpose and goals of the afternoon discussion sessions include identifying and understanding the 

criteria that alternatives (chemical and/or no chemical) will need to satisfy to be an effective 

replacement. The sessions will showcase lessons learned from previous work that can be used to inform 

future substitutions. The panelists will identify risks.

After the sessions, we should be able to provide a summary of the conclusions reached during each of 

the two discussion sessions that will identify: key common elements that can help to transition to safer 

alternatives or implement exposure reduction measures and specific chemicals or formulations. 

The knowledge of experts will help to answer questions for unique uses of TCE.

Developing criteria to assess risk should include: a systems approach to identify the industrial process to 

improve the cleaning process; looking at the chemistry performance and productivity and throughput; 

health and environmental concerns; the cost and why to use the chemical and why not to use the 

chemical; and an analysis of the user.

Sessions 2 and 3 will address the following questions for unique uses of TCE:

 What properties and characteristics of TCE make it effective and desirable for a given 

application?

 What alternative chemicals can be substituted for TCE in a given use?

 Are there critical uses where no viable chemicals alternatives exist?

 In cases with no chemical alternatives, what other measures can be employed to reduce 

exposure to TCE?

In discussion of these questions, case studies will be used to demonstrate processes that have been 

used to reduce exposure to TCE (chemical alternatives and alternative processes/process modifications). 

These case studies should address the following questions (not all questions will be applicable to every 

case study):

 Where was TCE used and why?

 What was the impetus for seeking an alternative for TCE?

 What considerations were taken into account to identify potential alternatives?

 How was the list of potential alternatives narrowed down?

 How were alternatives evaluated for efficacy?

 How were environmental/health considerations taken into account in identifying alternatives?

 How was a final alternative selected for use?

 What lessons were learned in reducing exposure to TCE that could help inform future decision 

making?

1:10 – 2:50 PM: Session 2: Aerosols and Cold Cleaning 

Panel Chair: Eileen Sheehan, EPA Region 9 

Rapporteur: Katherine Sleasman, EPA OPPT

This session addressed issues related to the use of TCE in aerosol form and cold cleaning in both small 

commercial and consumer settings.
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1. Identification of Less Toxic TCE Alternatives in Automotive/Electronic Applications 

Katy Wolf, IRTA 

Cold cleaning applications are either repair and maintenance or batch and are used in various ways. 

Usually IRTA works on generic problems to solve a problem as a group. Dr. Wolf tries to cover as many 

variations as possible with the companies that she works with. It is challenging to find a way to make 

water-based cleaners work because people were using solvents that were not safe and people were not 

using Personal Protective Equipment (PPE). Dr. Wolf found that people do not like to use PPE. IRTA 

worked on figuring out if there is a capable cleaning product that did not require people to use gloves

when handling. 

IRTA was able to design cleaning processes that required 105 degree Fahrenheit heating, which is still 

suitable for hands but hot enough to clean. Some industrial cleaning processes require 140 degrees

Fahrenheit, which in turn requires PPE. IRTA found that a 20 to 25% concentrate water-based cleaner 

would work. IRTA then tried to focus on alternatives with neutral pH. 

IRTA found that acetone is an effective handwipe solvent and is lower in toxicity than all other solvents,

and acetone is not a VOC. 

California is not allowed to ban a whole product type (such as an aerosol product) so California has to 

find aerosol alternatives to be able to regulate the product. In other words, California can regulate 

certain chemicals, but it cannot ban aerosols as a whole. IRTA worked on a project that involved working 

on four different applications including brake cleaning, general purpose degreasing, carburetor and fuel 

injection system cleaning, and engine degreasing. Water-based cleaners seemed to be a safe alternative,

but they are difficult to use in aerosol form because they tend to foam. However, IRTA worked with one 

supplier who was able to develop a few formulations that did not foam. 

The best alternatives for brake cleaning and general purpose degreasing are water-based brake cleaning 

systems or water-based cleaners in spray bottles. IRTA also developed two different solvent blends and 

packaged them in aerosol cans. For carburetor and fuel injection system cleaning, IRTA developed a 

blend of acetone and soy and packaged it in aerosol cans. 

In aerosols for engine degreasing, detailers routinely use water-based cleaning systems and highpressure water systems. Water-based cleaners in spray bottles can also be used. IRTA tested alternative 

propellants and found that nitrogen oxide did not work. IRTA found that carbon dioxide was a very good 

high-pressure propellant and was lower in cost than hydrocarbon propellants. Also carbon dioxide can 

reduce VOC content in products. Now many companies rely on carbon dioxide propellants for cleaning.

Dr. Wolf worked on a project in California on film cleaning for motion pictures. In the past to clean film, 

TCA-111 (1,1,1-trichloroethane) was used. Then industry moved to Perc and then to hydro fluro ethers 

to clean. However, these were regrettable substitutes. Now to clean film, ethyl alcohol or IPA can be 

used. 

In addition to research, Dr. Wolf also looked at a material safety data sheets for information when 

determining alternatives. There are other degreasing formulations for aerosol applications and perhaps 

other alternatives. There are many other chemicals that are safer than TCE to use in aerosol 

formulations that can be used for degreasing. 
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2. Balancing Functionality with Efficacy 

Steve Bennett, Consumer Specialty Products Association (CSPA) 

Information Needs

CSPA supports more robust reporting of chemical uses under TSCA. Under EPA’s work plan goals, 

information needs include identifying potential consumer and worker exposures and understanding 

critical safety considerations. Information that was provided was intended to ensure a more accurate 

understanding of uses, assist EPA in refining their assessment, identify appropriate stewardship 

activities and clarify safety considerations (critical uses). Information needs also include a better way to 

figure out how chemicals are used. Dr. Bennett also suggested that when creating a risk assessment it 

should be narrowed down to figure out specific areas of interest. The risk assessment should include 

what needs to be done in the workplace. 

Usage of TCE as a degreaser

TCE should have limited industrial use. As a solvent degreaser TCE is used in large commercial/industrial 

settings and/or small commercial settings, i.e., small shops. TCE characteristics include non-flammability 

and effectiveness. Therefore flammable alternatives that may cause fire or explosive hazards and waterbased alternatives that may cause electrical hazards need to be assessed for effectiveness. 

Stewardship Activities to Reduce Existing Exposure

In order to reduce existing exposure, sales should be restricted. Commercial/industrial supply chains 

should restrict sales and a label should be clear and prominently displayed that says “For Commercial 

Use Only.” There should also be labeling and warnings that go above and beyond MSDS/SDS 

instructions. For instance, there should be specific warnings to fire-fighters about decomposition 

products. There should be air monitoring instructions, comprehensive hazard identification, and 

information about the proper use of PPE. 

3. Reformulation of a Product Line to Remove Chlorinated Solvents 

Michael Muth, Slide Products 

Slide Products is a 61 year old, small family-owned business with 15 employees. The company is a 

chemical formulator and aerosol packaging firm. Slide Products transitioned its products away from TCE 

in 2011 because they learned of the potential cancerous effects of TCE and wanted to keep employees 

safe. 

Prior to 2011, the company used TCE in their products but Slide Products was able to eliminate all 

chlorinated chemicals from their product line and was able to retain their customer base. It was a 2-year 

effort to get rid of TCE.

Some of Slide Products’ customers are plastic processors and makers of medical molds and some make 

food packaging items. Slide’s typical aerosol ingredient, TCE, was the primary solvent in formulations. 

Slide Products used chlorinated substances because they had great solvency and evaporated quickly. 

The change from solvents was prompted by environmental concerns and human health concerns. 

In 2009 the former owner of the company was diagnosed with lung cancer and this prompted the 

company to eliminate any expected or known carcinogens from their product line. First, the company

engaged chemical vendors and reviewed positive and negative characteristics of chemicals. Slide 

Products worked with their customers to figure out what could potentially work as an alternative. Then 
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the company began customer trials and product testing. Slide created a new product devoid of TCE 

based on the consumer surveys.

In 2011 Slide Products was challenged with a new customer complaint. The new product had higher 

flammability rates but Slide estimated that for 90 percent of customers flammability was not a concern. 

In response to the complaint, the company added safety labels noting extreme flammability.

Slide Products fielded a large volume of emails with customer complaints that the new aerosol cans 

were too light. The weight of the new product dropped in half because the new solvent was less dense 

then the original solvent. Mr. Muth had to explain to customers that lighter did not equate to less 

solvent. One analogy that worked for his firm was to compare the lighter weight of white bread vs. the 

heavier weight of wheat bread and explain that the customer was getting just as much bread in each 

scenario. 

The company actually sent customers pint cans with the new solvent brand and the old to show 

customers that they were getting the same amount of product. Now the company does not receive any 

questions about the weight of the cans. Customers have been transitioned to new products.

Mr. Muth also had to convince companies that the product switch was a smarter and safer solution for

their business as well. 

Following his company’s switch, EPA published TCE criteria in 2011 outlining risk. Now Slide Products 

uses the EPA report to back up and validate the company’s switch to non-TCE products. Slide Products

issued a white paper and sent it to industry media, customers, and distributors outlining the risk and 

describing their new product, and the EPA information became integral in marketing. 

Slide Products sells to the US and internationally. There are more business opportunities for Slide 

Products because of the lack of TCE in the product line. 

4. Experiences in Evaluating Cold Cleaning Alternatives to TCE, Successes and Failures 

Jason Marshall, Toxics Use Reduction Institute (TURI) 

Manufacturing Process:

The manufacturer had a six-step process to clean their product. The first step was mounting the

materials with wax by heating up a 12-inch plate of glass to 200 to 300 F and applying wax. Lens paper 

was applied over the wax and then another layer of wax was applied and then the materials were 

mounted onto the second layer of wax. Then the plate was sent to be lapped or polished in a process 

that uses lapping oil and one of two abrasives. After being lapped/polished, the oil was removed with 

TCE wipes and the newly cleaned materials were polished and cleaned by hand with a wet paper towel 

followed by an acetone wipe. The dismount and final cleaning process required the plate being reheated 

to the 200 to 300 F range and the materials being slid off of the surface. The final cleaning focused on 

wax removal using TCE for up to 10 minutes and following the de-waxing, two 5-minute ultrasonic 

aqueous cleaning stages were performed. Cleaning was then finished off with a methanol bath rinse for 

up to 4 minutes.

Clean, polish, clean was the company’s process, which meant that the product was cleaned twice. TURI 

wanted to find a way to reduce the number of steps in the company’s cleaning process. 

Lab work:

In the lab, TURI identified alternatives for wax removal because the company identified cleaning waxes 

as their hardest challenge in the cleaning process. 
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The client’s parts were made from a wide range of materials including alumina nitride, alumina, fused 

silica, lithium fluoride, glass, and stainless steel and there were lots of variables to consider about the 

soils on the materials. TCE was used by the client as a cleaner because it was a compatible and effective 

cleaner on all of the materials. In the lab TURI looked at what exactly was being cleaned by the company 

and TURI attempted to figure out alternatives that could be used to clean at least half of the company’s 

materials that needed cleaning. 

TURI used pilot cleaners on parts that the vendor supplied, so that the vendor would be able to compare 

the pilot-cleaned parts with their original cleaning process.

Outcome:

The facility only had 8 gallons of TCE remaining after TURI’s analysis and were not intending on 

purchasing more. The employees were all happy to hear that TCE would not be used any more. A month 

later the company was using alternative products. Dr. Marshall believes this story was a success because 

TURI did the more painstaking work for the company, making it easier for the company to make a 

switch. Dr. Marshall felt that it was beneficial for the vendor to see the testing done and be involved in 

the process. 

Conclusion:

Dr. Marshall believes that success without worker buy-in is not likely. Keys to success include conducting 

systematic performance testing using the specific soils encountered at the facility and piloting the 

potential product on actual parts by the personnel responsible for running the cleaning process. The 

work should be done on-site so that any questions or concerns by the company can be met in real time. 

Additionally, if the work is done on-site, the lab can identify the company’s cleaning process, eliminate 

steps in the cleaning process, and keep the cleaning at a satisfactory level.

5. Case Studies on Use of Aqueous Cleaners 

Brent Ekstrand, Astro Pak 

Astro Pak was founded in 1959 and the main customer base was the aerospace industry. Since then they 

have diversified. In the aerospace industry, finding cleaning alternatives is challenging because of 

customer specifications. This limits the ability to choose cleaning procedures and cleaning agents 

because Astro Pak does not control the specifications that they work toward. In some cases Astro Pak 

works to improve the efficacy of cleaning agents due to the complexity of working with specifications. 

Astro Pak must convince customers to update their specifications if Astro Pak detects a better 

alternative. 

In the 1990s, Astro Pak Owner and President Ken Verheyen saw that restrictions on solvent use and 

availability were going to continue (at the time Astro Pak did cold cleaning) but customers needed a 

variety of cleaning modalities. Mr. Verheyen wanted Astro Pak to set the green standard and Astro Pak 

made the switch away from solvents as a class to stay ahead of changing solvent regulations.

Astro Pak needed to be able to convince customers to use aqueous cleaning because Mr. Verheyen 

realized that it was a smart long-term business to switch to aqueous due to lower chemical costs. The 

risks of using solvent cleaning are unacceptable from both a moral and financial perspective to Astro Pak 

due to the human health risks and environmental risks. 

Astro Pak engaged Dr. Katy Wolf at IRTA for assistance and guidance. Over a period of six or nine 

months, Astro Pak conducted a series of tests on various types of hardware used by the customer base 

and challenged those with a number of contaminants (typical contaminants encountered by customers 
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and problem contaminants as well). Astro Pak then selected a general cleaning agent and selected a 

large, three-tank ultrasonic cleaning system, drying oven, and upgraded deionized water system as the 

alternative. In precision cleaning the deionized water matters so Astro Pak had to upgrade their water 

system as well. The initial investment was considerable, but they knew that there would be savings in 

the long run. 

Lessons Learned

When switching over from cold cleaning or solvent cleaning to aqueous cleaning, there is a learning 

curve because it is technique-dependent and employees will have to be better trained. The company 

will have to control the process more than with solvent cleaning, but this pays off. The equipment 

selection, rinse techniques, and water quality are critical as well. The process cycle may be longer but 

changes in batch size and process flow can increase capacity. 

Astro Pak was able to achieve successful aqueous cleaning. Astro Pak found that with careful technique, 

post-cleaning contaminant levels are lower with aqueous cleaning than with solvents. A/20 levels were 

achieved, which is 50 mcg per square cm. There were lower ongoing costs with aqueous cleaning, which 

enhanced profitability for the company. Technique, equipment, and experience are critical to 

successfully switch to aqueous cleaning. 

 

Questions and Discussion from Session 2: Aerosols and Cold Cleaning 

Question from Christian Rodriguez, Biosubs:

So far we have alternatives for applications that are water-based but what would be the alternatives for 

dry cleaning in industrial processes?

Answer by Dr. Katy Wolf, IRTA: 

IRTA is figuring out alternative methods and that is the equivalent for generating utilities and 

transmission lines and if it isn’t very dirty and if you are just moving particulates then it won’t 

conduct. If you can get away from using deionized water, which is what they use for 

transmission lines, you can use carbon dioxide pellet blasting for transformers or carbon dioxide 

snow device ($1,200 investment) but aerosol products are very expensive as well. Everything 

but halogenated solvents has a flash point, so you have to move to other things that have flash 

points if you are going to use solvent cleaning.

Question for Brent Ekstrand by audience member: 

The question is about the careful technique. Is it precision of the technique or more time or a 

combination of both?

Answer by Brent Ekstrand, Astro Pak: 

You have to make sure that temperatures are measured to a narrower band than you do with 

solvents. You have to make sure exposure times are adhered to and proper application of 

ultrasonics. You have to make sure you are cleaning properly—make sure power settings are 

correct, exposure times are monitored correctly, etc. With aqueous technologies you cannot 

leave solvent overnight, so there are more variables that you have to worry about with 

ultrasonics than with solvent cleaning. It is also important to properly train employees with 

ultrasonics, whereas vapor degreasing has a lot more tolerance for people doing a process

improperly. 
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Question from Eileen Sheehan, EPA Region 9, Chair:

EPA is really interested in the critical performance criteria and especially fast evaporation as a critical

performance criterion and how to avoid foaming. Also EPA has questions of cost performance, cost of 

investing in equipment, and any other criteria that EPA should keep in mind.

Answer by Brent Ekstrand, Astro Pak: 

There are criteria for the performance of the cleaner such as non-foaming aerosols or 

performance as a cleaner (post contamination levels). There is cleaning and precision cleaning 

and measuring post-cleaning residue and particulate levels in precision cleaning as well as

particle count to get particle distribution and details for different particle levels. 

Answer by Dr. Katy Wolf, IRTA: 

Gross cleaning operations that are not precision-based and water-based cleaning systems are 

pretty simple and you do not have to worry about as much with systems that do not need 

precision cleaning. When you adopt alternative methods of cleaning you have to start from 

scratch and look at total organic carbon measurements. If you base testing based on how you 

are doing it now, then you will believe you are not doing it as well but instead you need to look 

at things with an open mind. Companies can often clean better with alternatives. 

Answer by Michael Muth, Slide Products: 

EPA should look at processes and examine efficiency and productivity. Customers generally do

not have time to take processes down in time for regulations, and solvents allow for fast 

efficient cleaning, and companies will not have the opportunities they currently have if they 

have to slow cleaning time down. 

Question from Maria Doa, EPA: 

Are any lessons critical for EPA to keep in mind when considering next steps for rules and existing 

regulations based on the key lessons learned from switching from TCE to an alternative?

Answer by Michael Muth, Slide Products: 

The more that EPA can publicize information through non-traditional outlets, outside of the CFR 

notifications, the more that information can be publicized, and the easier it is for companies to 

leverage decisions. If EPA publishes easy-to-read information, that is a way to explain and back 

up information or product switches to customers. 

Answer by Steve Bennett, Consumer Specialty Products Association: 

It is also important to keep in mind the involvement of stakeholders. 

Answer by Jason Marshall, TURI: 

The military says that we have to do things a certain way. Dr. Marshall wants companies/military 

to realize that the current way something is being done does not need to be the way something 

is always done. It would be good if companies looked into chemical levels and if companies did 

the research to realize what the specifications really are (example of the military not 

understanding their own specifications). 

Answer by Dr. Katy Wolf, IRTA: 

There are a million references from the military and how the military had to change their specs. 

There should be a movement toward qualifying a specific task and when something expires, you 

should be able to test it and show that you can use something else. 
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Answer by Wayne Ziegler, DoD:

There is a challenge in the DoD because there are historical documents that tell the military how 

to do things (some specifications may be vague—like a specification will say that something has 

to be cleaned but will not verify how). The DoD is not able to go around to every shop to verify

that every company is not using TCE. Companies are going to keep using TCE if they think that 

they need to keep using it. Revising documents is a long process but it needs to be done. 

Companies say that they are not using TCE but there is a possibility that they still may be using 

it. Government specs are part of the solution and problem. 

Question from Michael Partain: 

Mr. Partain was born at a military base highly contaminated with TCE and the legacy of TCE is still in 

areas even though DoD has stopped using it. The exposures at Camp Lejeune are still there and there is 

vapor intrusion. What is being done to look at the true costs of the alternatives (environmental and 

human health)?

Answer by Dr. Katy Wolf, IRTA: 

Hardly anyone (very few companies) have enough money or the sophistication to do a full lifecycle cost analysis, so hardly anyone does. A life-cycle cost was not done for TCE and we need to 

take into account regrettable substitution when you decide to use something else in place of 

what you are using now. Companies need to take the best option that is known at the time. It all

depends on the application and what the company is doing. 

Answer by Steve Bennett, Consumer Specialty Products Association: 

All stakeholders should be able to have their viewpoints out there and should be able to 

disseminate as much information as possible so that users and customers can be directed to 

appropriate products.

Question from Pat Rizzuto:

How critical is it that they had people working with the company to do facility-specific work because 

there are so many small businesses?

Answer by Maria Doa, EPA: 

This expert workshop is the start of the process to gather the experts to make the tools and 

framework available to others, and what is important to begin with is to get the expertise and to 

see the different ways that people made a switch from TCE to alternatives. EPA is cautious of 

moving forward as EPA does not want to move to a different solvent that may not be a good 

alternative. Different folks approach the problem differently as well.

Question from Audience:

Some coatings use high-density polyethylene. Are there other chemical solutions to engineering issues? 

Answer by Dr. Katy Wolf, IRTA: 

If you use proper control for the particulates you can hand-sand things off. There are many nonchemical technologies that can be used as alternatives. 

Comment from Maria Doa, EPA: 

Part of what is noteworthy is the different way that companies have approached issues. Mr. Muth did 

not do precision cleaning. Mr. Marshall had a matrix approach. There is an overlap of factors that the 

different companies have used. 
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Answer by Michael Muth, Slide Products: 

A major concern from the customer’s perspective is the need to remove oil-based 

contaminants. Customers needed to know if new solutions would produce the level of cleaning 

necessary. Flammability and cost were also issues. 

Answer by Jason Marshall, TURI: 

It depends on who you are working with and why they are doing it and then you figure out what 

alternatives could work. 

Answer by Michael Muth, Slide Products: 

Customers who used flames in their manufacturing process were identified as being problematic 

when using the new product. 

Comment from audience member: 

It is a matter of efficiency for industry and companies.

Question from Doug Parsons, EPA: 

How can EPA get information to small businesses who still use TCE? 

Answer by Jason Marshall, TURI: 

It may take people going door to door and working with them to fix the solution. In Rhode 

Island, there was a 90 percent reduction of TCE use in the area that TURI identified over a two 

year period because TURI went door-to-door. However, this approach needs funding. 

Answer by Michael Muth, Slide Products: 

It is important to educate customers over and over again and there needs to be education in the

marketing message. There needs to be governmental education and it is important to get the 

right ear to hear the message. It is important to know why a company made the change away 

from TCE and the company’s customers need to understand. For Mr. Muth’s company there was 

an economic benefit in switching to TCE and now his company is more profitable. 

Answer by Brent Ekstrand, Astro Pak: 

The short-term cost or immediate cost is not the complete cost, and companies must look at the 

risk of the cost to the environment and what it will cost to remediate if TCE is used. There is an 

acquisition and disposal cost and labor for the use is nowhere near the complete cost of a 

switch. Mr. Ekstrand encourages EPA that risk for the company should be part of the 

assessment. 

Answer by Dr. Katy Wolf, IRTA: 

Dr. Wolf is a strong supporter of regulation, because people in facilities are concerned with 

compliance. If you let people voluntarily choose to switch chemicals, not as many people would

switch, compared to the number who would switch if it is banned. A way to get the message out 

fast is by passing the regulation because then everybody has to know about it.

Question from EPA to panelists: 

Do you see competitors switching once you make the switch?

Answer by Michael Muth, Slide Products: 

Competitors are still marketing that they are offering TCE products and saying that the non-TCE 

products are weaker. His company needs to market the health concerns. 
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Answer by Brent Ekstrand, Astro Pak: 

The aerospace industry is a niche industry with competitors and his competitors are smaller. His 

company has corporate marketing advertising a “green” benefit. There have been some copycat 

behaviors from smaller companies. Dr. Ekstrand believes that other companies will follow in 

using an alternative if they see an economic value. In a competitive market people think 

carefully before they release information. For instance a company is going to question whether 

releasing information is going to give a benefit to the competition, but some switches were 

voluntary and there is a moral imperative so going away from toxicity is a good thing.

Answer by Steve Bennett, Consumer Specialty Products Association: 

As a trade association, the trade members compete against each other. Voluntary efforts are 

cheaper than efforts due to regulatory changes. The association has a good understanding of 

what is going on so that members can make a good decision. 

Question from EPA to panelists: 

Is there less sick leave due to a switch to a safer alternative, and has anything lowered corporate 

insurance cost and employment for occupational insurance?

Answer by Brent Ekstrand, Astro Pak: 

There is no data from his company to answer that question. 

Answer by Michael Muth, Slide Products: 

There is no evidence of decreased sick leave or insurance rates even though the insurance 

company knows they have switched over. 

Answer by Dr. Katy Wolf, IRTA: 

From auto aerosol cleaning alternatives a lot of the guys thought that if a product did not smell 

bad then it is not going to work, but the younger generation is more interested in the new 

product. Dr. Wolf found that in auto repair facilities, once you institutionalize the change people 

do not remember the old way.

3:00 – 4:30 PM: Session 3: Vapor Degreasing 

Panel Chair: Ward Penberthy, OPPT, EPA 

Rapporteur: Brad Goodwin, AAAS S&T Policy Fellow hosted by EPA

This session addressed issues related to the use of TCE in vapor degreasing applications in small 

commercial settings. 

Potential Outcomes: 

1) List of criteria that potential alternatives will need to satisfy if they are to be used as 

replacements for TCE. 

2) What key lessons were learned in transitioning from TCE to an alternative that could help inform 

future substitutions? 

3) Are there generalizations that can be made so that future substitutions are easier to conduct? 

4) Are there any characteristics, or combinations of characteristics that resulted in no viable 

alternatives to TCE? 

5) List measures other than chemical substitution that can be used to reduce exposure to TCE as a 

vapor degreaser.
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1. Transitioning from TCE in Vapor Degreasing Applications at Military Facilities 

Wayne Ziegler, U.S. Army Research Laboratory 

How alternatives are implemented (methodology) is critical. Lots of great work may not go anywhere 

because there is no focus on implementation. 

JS3 worked with the Anniston Army Depot (ANAD) that performed depot-level maintenance for combat 

tanks, tracked combat vehicles, small arms weapons and components, and optical and electronic fire 

control systems. ANAD has a large production capability. In order to reduce hazardous emissions at 

ANAD and to address environmental regulations and mandates, ARL and the NDCEE directly supported 

efforts at ANAD through two tasks: Task 0512: Dem/Val of HAP-Free Chemical Depainting Materials and 

Processes Thrust Area and Task 0527-A2: HAP-Free Vapor Degreasing for Critical Weapon Systems 

Applications. The goal was to go to HAP-Free chemical depainting and HAP-free vapor degreasing. 

EPA proposed Residual Risk standards under the NESHAP for Halogenated Solvent Cleaning (August 

2006) to limit facility-wide emissions of perchloroethylene, trichloroethylene (TCE), and methylene 

chloride used in solvent cleaning. Over 90% of TCE use in the DoD is from ANAD. Current operations at 

ANAD include TCE vapor degreasing of small arms and miscellaneous components of combat vehicles. 

ANAD will be unable to comply with the proposed TCE limit without installing costly and burdensome 

pollution control devices. JS3 needed to identify and downselect alternative degreasing/cleaning 

technologies for three applications of interest to ANAD. Then JS3 needed to conduct bench-scale testing 

on downselected alternatives. Up to two selected technologies would undergo full-scale testing at 

ANAD. JS3 tested small arms degreasing, plating wax removal, and the best system for degreasing. The 

best system was an ultrasonics system. 

Performance of the ultrasonics system exceeded the TCE bench mark and ANAD was very excited that 

time requirements were met well under expectations. The ultrasonics system performed well. 

JS3 conducted a SPOTA Solvent Thrust Technical Review and ANAD TCE Alternatives Demonstration. All 

of the solvents that were tested in the bench scale were compatible with the metals tested. All of the 

solvents cleaned in the range of or better than n-propyl bromide. The results may vary with other 

materials, contaminants, and hardware configurations. 

2. Alternatives Evaluation 

Heidi Wilcox, TURI 

Ms. Wilcox works with Jason Marshall of TURI. This presentation examines reality vs. theory and how to 

work in the field with experimental data and different companies’ cultures and needs. TURI takes the lab 

“to the streets” and works with companies first hand. 

When TURI is contacted by a company or connected with a company, TURI sends out a test request form 

to understand the company’s cleaning process. TURI then sees what is done before and after cleaning. 

Then TURI emails the company rep about other information needed and conducts a database and 

internet search for options. 

From the presentations earlier in the day, Ms. Wilcox took away that the user is key and solutions do not 

get implemented if the company is not on board with the implementation. Cutting edge technology 

does not matter if we do not get implementation from customers. 
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Reality of the substitution 

The reality of TCE is that it has great solvency and cost is relatively low. TCE does not need rinsing and 

drying. While TCE is hazardous, companies already know how to work with it and they have bought 

machines that have helped them deal with it. Therefore one interim step is solvent substitutions (mostly 

nPB), because it has good solvency and the cost is not out of reach. 

The first connection with customers is to meet them and listen to them (what are their concerns, what 

do they need, what are the issues, etc.). It is important to make the relationship work and determine 

what the company has tried and what they have worked with. It is important to gauge whether 

management will want to switch.

Originally TURI transferred a lot of people to nPB as a solvent substitution and in the future TURI expects

to see it regulated. Customers will have to move solutions again but as long as there are solid 

relationships with the company, the company will be more responsive. Listening to companies’ and 

workers’ concerns is key to gaining a strong relationship and acknowledging that they are the experts in 

their own process. TURI took smaller steps to work with the company to make gradual switch and made 

sure that the company knew that TURI was there as a resource. 

Needs of Process in Reality

When working with companies, it is important to understand the client’s point of view. The solvent 

process is known while an alternative process is unknown. Solvents work for clients and their processes 

because rinse and dry is not needed, they are readily evaporative, there are no heavy residues, they 

protect against corrosion, rusting, the process is quick generally, and it is forgiving from the training 

perspective. Aqueous or semi-aqueous processes are unknown, so it is scary for the client to want to 

make a switch. 

Lessons Learned

TURI learned that solutions need to be on a case-by-case basis with companies and there are not many 

generalizations. It is important to consider the company culture, set up of the process, the needs of the 

company for the project, the capital they have to spend (if the money is not there it will be hard to make 

a switch), the space that the company has, the management support (if it is there or not), the workers’

and clients’ needs, and how much testing is required for the client. Gauge the corporate backing to 

understand if the company leaders are able to make the switch. Additionally, there needs to be workerbuy in. Also, it is important to talk to a client about their fears because aqueous solution can be done in 

some cases, but it may scare the customer. 

In reality there is always an alternative (aqueous, semi-aqueous, media blasting, CO2). There are other 

options besides substitution including change process, work with supply chain to have parts or stock 

come in clean, ask the customer to clean parts instead of you, and buy high tech, automated machines 

to reduce handling of parts and exposure to chemicals. 

3. Alternative Solvent Development 

Ryan Hulse, Honeywell 

Honeywell uses a new solvent that replaces TCE. Solstice PF is labeled by Honeywell as the next 

generation solvent. It has solvency for a wide variety of solutes like oils and greases, solder fluxes, etc. 

The solvent has a low surface tension. Honeywell asserts that it meets or exceeds regulatory and safety 

requirements and is non-flammable and has good OEL. It may be a suitable replacement for TCE, nbromopropane (nPB), Stoddard Solvents, Vertrel, and Ak 225. 
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When determining an alternative solvent for TCE, it is important to analyze the performance, 

environmental risks, safety risks, and human health risks involved. The solvent must perform for the 

customer’s needs or there will be no switch to a new solvent. 

Mr. Hulse’s visuals have a detailed chart about the environmental and safety properties of Solstice PF. 

Compared to TCE, Solstice PF has no vapor flame limits. The solvent is also non-flammable, which is an 

important safety feature. 

OEL is important to measure as well and the company should determine how much solvent can be 

dripped on the floor before reaching an OEL level. It takes about 70 drops for TCE to reach OEL, 

assuming a 400 square foot room. The OEL for Solstice PF is much higher and takes about 6200 drops to 

reach the OEL. Once you add ventilation to a room it reduces the exposure rate for a chemical, which 

will help with safety. Solstice PF has no flash point. Additionally Solstice PF is VOC-exempt and TCE is a 

VOC and HAP. 

Environmental properties should be assessed for global warming potential when selecting an alternative 

solvent to TCE. Environmental properties that should be assessed include looking at an alternative’s 

atmospheric lifetime, global warming potential, VOC exemption, flashpoint, vapor flame limits, OEL 

(ppm), and odor. The atmospheric lifetime for Solstice PF is still relatively short at 26 days compared to 

TCE’s atmospheric lifetime of 6 to 8 days, but the Global Warming Potential (GWP100) is 1 for Solstice 

PF compared to TCE’s GWP100 of 140. 

Solstice PF utilizes cost effective equipment. Clients will not have to spend a fortune on equipment to be 

able to safely use the solvent. 

Solstice PF is available in the U.S. It is on the TSCA inventory and it is listed on the U.S. EPA SNAP list of 

acceptable substitutes for solvents. Solstice PF is also registered in the EU (REACH), Japan, Canada, 

Australia, and South Korea. 

A lot of Honeywell customers are using TCE to clean bearings. However, Solstice PF has additional 

cleaning properties that TCE does not have and has better safety and environmental properties. Solstice 

PF is a new product that can be used as an alternative to TCE. 

4. Alternative to TCE 

Manoj Patel, Green Life Development, Inc. 

Green Life Development, Inc. was the first dry cleaning chain in CA to use water-based cleaning 

methods. The company had two employees (partners) who got cancer and that motivated the company 

to switch to safer cleaning solutions. TCE has negative health effects and Green Life wanted to avoid 

health challenges instead of just providing gear. Providing gear does not mean that you are solving a 

problem. Also, Green Life believes that products like TCE as clean-up products are more harmful to the 

environment than the oil that they are meant to eliminate. 

Demonstration

Mr. Patel demonstrated his product, Naturama, to the workshop participants by setting up two beakers. 

One beaker had beach sand, water, and oil on top and the other beaker had no sand and just oil and 

water. Mr. Patel mixed the solution with oil and the two beakers and let them sit for the rest of his 

presentation. As Mr. Patel’s presentation was ending, it was clear that his product was able to separate 

the oil in the two beakers from his demonstration.
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The product is non-toxic and bio-degradable and “safer than toothpaste” since it is made from botanical 

& mineral extracts. This means that it is safe to the human touch. Mr. Patel spoke about the Deepwater 

Horizon Spill and how researchers from the Georgia Institute of Technology and the Universidad 

Autonoma de Aguacalientes (UAA) have discovered that the chemical dispersants used to treat the oil 

and break it down have actually increased the toxicity of the oil by as much as 52 times. The increased 

toxicity has negatively affected animal life and increased mortality rates in wildlife, so it is imperative to 

find a safer alternative to cleaning up oil. 

TCE Health Effects

An alternative for TCE needs to be found because TCE can affect someone when it is inhaled and by 

passing through the skin and it should be handled as a carcinogen. TCE can cause reproductive damage 

and irritate the skin, throat, nose, and eyes. Damage to the nervous system, heart, liver, and kidneys 

may also be caused by TCE. Many people use protective gear when handling TCE but using protective 

gear means that the chemical is still hazardous and they may not be fully protected by the gear. 

Use of Naturama

One manufacturer used a 30,000-gallon tank to heat and separate industrial waste and was able to use 

Naturama instead. In another case, the company found that one 28 oz. bottle of Naturama does the 

work of over 12 cans of aerosol-based cleaners. Naturama is non-toxic, non-ionic, non-caustic, nonflammable, ozone-safe, and has no CFCs. 

Industries like automotive repair, manufacturing, rail, and marine oil drilling could use Naturama to 

clean. The product is more cost-effective and reduces environmental impact because Naturama-based

products can be used over and over again for cleaning. 

5. Process Based Risk Reduction for Cleaning 

Barbara Kanegsberg, BFK Solutions LLC (via webinar) 

BFK Solutions LLC provides process improvement assistance and not product sales. They have industry 

involvement with JS3 (military), PC, ASTM, ISO delegate, EPA, and FDA. BFK tries their best to provide 

accurate, up-to-date information and tries to reconfirm all technical and regulatory information from 

the appropriate supplier or regulatory agency. 

Soils and Dirt

Ms. Kanegsberg spoke about whether something is soil or whether it is considered dirt. There are lots of 

different types of soils. Soils may include solder flux (rosin, organic acid, low residue), oils, greases, 

metal working fluids, lapping, polishing compounds, particles (metal fines, chips, skin flakes, polishing 

grit), acids, water, solvents, product assortment, residual product/breakdown (in processing equipment, 

deposited cleaning agent residue (including flux residue), rust-preventive, bacteria, mold, and life-forms 

(alive or dead). 

Soil is matter that is out of place and cleaning is a process that is removing matter out of place. In terms 

of critical cleaning, there is value added and if the company does not do it, then the product quality 

suffers. Any step can be critical, and critical cleaning happens in small and large companies. The cleaning 

process is influenced by chemical exposure and chemical emissions.

Different Processes and Chemicals Used to Clean

Degreasing in manufacturing is a confusing term because it can mean the chemical function and 

sometimes can refer to aqueous cleaning. Degreasing can also refer to the equipment plus the chemical. 

A vapor degreaser can refer to the vapor phase or reduced pressure system. 
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There is no universal cleaning chemistry or cleaning process. Sometimes a company has to determine 

how clean is clean enough. The level of cleanliness is affected by what the customer wants and the 

product functionality.

The size of the cleaning system is not always proportional to the number of employees. The company 

has to consider the soil and the substrate when choosing a cleaning system. The division between large 

and small manufacturers and their needs is decreasing and the supply chain is becoming more complex. 

Manufacturers need effective degreasing tools. Technical manufacturing challenges include complex 

electronics, miniature products, 3D printing, high value products (medical, military, aeronautics), 

increased product lifetime expectation (e.g., implantable medical devices), and soils that are difficult to 

remove. 

There is no such thing as a “one-size fits all” cleaning solution. Processes that are needed are aqueousbased processes, organic solvent-based processes, and biobased processes. Some cleaning situations 

require an aggressive solvent because many soils are becoming more difficult to remove. Aggressive 

solvents are sometimes necessary. 

Water-based and solvent-based cleaning agents have different characteristics like solubility, 

aggressiveness, and physical properties, so TCE-like solvents are desirable in certain situations. A TCElike solvent is desirable in instances where a complex shaped part needs cleaning, if the part needs to be 

rapidly cleaned and dried, if there needs to be a wide solvency range, the wettability of the product, and 

if the product needs a low cleaning agent residue.

Aqueous cleaning agents use water and organic and inorganic chemical additives like surfactants, 

builders, chelating agents (sequestrants), and corrosion inhibitors. Aqueous cleaning agents are often 

used for polar and mixed soils. 

Value of Case Studies

Ms. Kanegsberg has published many case studies about solvent substitutes. Case studies have value 

because they showcase approaches to cleaning process change. However, she has found that successful 

case studies are often reported while case studies with limited success are often not reported. 

Experimental failures are less likely to be published. Limitations of success include costs, cleaning 

efficacy, process reliability, energy usage, and actual implementation. 

For instance, at a conference Ms. Kanegsberg attended, there was a presentation about the success of 

an aqueous in-line system, but once Ms. Kanegsberg asked about details about the case study, it was 

revealed that the company had limited success because there was a limited use in production and 

mismanagement of waste streams. Another success story with aqueous cleaning, complex tubing, was 

reported at a conference, but once Ms. Kanegsberg visited the facility she found that a very highpressure system was required and parts were flying across the room. 

Ms. Kanegsberg pointed out that “success stories” are not always a “success” and when there are 

success stories reported there may be limitations. 

What Should be Done

Unfortunately, it is not a solution to ban or strictly control toxic chemicals and force manufacturers to 

choose an alternative because some alternatives have a 50/50 chance of being just as toxic and the 

alternative will have to be regulated as well.
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An alternative that is safe and has low environmental impact is desired. There is an assumption that 

chemical combinations are additive but replacement blends may have non-additive effects and 

unexpected environmental and human health impacts. Substitution or reformulation is not always the 

answer because aggressive chemicals are needed for certain applications and substitution chemicals 

may have negative effects as well. Solvent substitution may not be a sustainable approach and product 

reformulation is disruptive. 

Diversity of chemicals is necessary for alternatives because not one chemical or process works for 

everything but going on a chemical “witch-hunt” to find the perfect chemical does not work because it is 

never-ending and not sustainable. Competitive manufacturing needs to be safe, sustainable, high quality 

and cost effective. 

A productive approach to finding an alternative solution is to manage the process and not the chemical. 

All cleaning processes should have a basic level of safety, environmental control, containment, and 

product safety. Ms. Kanegsberg suggests that inter-agency coordination and cooperation need to be 

increased. Inter-agency coordination will be more effective in finding alternatives and will conserve

governmental resources. A joint effort will allow technology to develop. 

6. Reducing TCE Waste in the Fabricated Metals Sector and Overview of P2 Reporting: 

Using TRI to Identify and Report Sustainable Practices 

Dan Teitelbaum, EPA 

Dan Teitelbaum is the Pollution Prevention lead for the Toxics Release Inventory (TRI) Program Office of 

Environmental Information. 

What is the Toxics Release Inventory (TRI)

The Toxics Release Inventory (TRI) compiles data submitted by industry on the releases and 

management of toxic chemicals from certain facilities. TRI can tell the public about releases, waste 

transfers, recycling, and pollution prevention. Each year companies have to report to EPA their releases 

and transfers of specific toxic chemicals and what the company is doing to prevent the releases. 

Requirements of a Facility to Report to TRI

A facility must be in a TRI-covered industry sector or category to be required to report to TRI. These 

facilities include manufacturing industries, coal/oil electricity generation industries, certain mining 

facilities, hazardous waste management industries, and federal facilities. The facility must have the 

equivalent of at least 10 full-time employees. The facility must manufacture, process, or use more than a 

certain amount of a TRI-listed toxic chemical per year. 

Pollution Prevention (P2) Data

TRI has Pollution Prevention (P2) data that is reported to TRI. P2 information includes source reduction 

activities (codes) and optional P2 information (free-text). P2 also includes reporting of the waste 

management quantities of recycling, energy recovery, treatment and disposal, and other releases. There 

is a full accounting of each piece of P2 data. Risk reduction approaches should be reported. Here is a link 

to P2 Resources.

Mr. Teitelbaum gave examples of reported P2 information. One metal heat treating facility reported 

that they reduced TCE waste by maximizing the load size on their degreasers to improve efficiency and 

later eliminated TCE by switching to aqueous degreasing.
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A metal plating and coating company switched from single-stabilized TCE to double-stabilized TCE, which 

increased the efficiency of their degreaser and reduced waste. A finishing company implemented 

additional testing for alkalinity and used additives to prolong bath life, resulting in fewer tank changeouts and a 19% decrease in TCE usage. 

Facilities have reported more P2 information since EPA increased emphasis on P2 reporting on the TRI 

form. There are certain codes to report certain types of P2 practices. In 2010 there were only 5,175 (7%) 

companies that reported P2 activity codes and in 2012 there were 7,218 (10%) companies with P2 

activity codes. In 2010 there were 1,769 (2%) companies with optional P2 descriptions and in 2012 there 

were 7,166 (10%) companies with optional P2 descriptions. Some companies switched from solvent 

cleaners to aqueous cleaners. EPA is still encouraging the facilities to report trends. 

There is a P2 activity list on EPA’s website. Mr. Teitelbaum’s visuals include a chart of P2 in TRI’s National 

Analysis that examines the top parent companies based on newly implemented source reduction 

activities in 2012. 

The TRI website has a P2 Search tool: http://www.epa.gov/enviro/facts/tri/p2.html. The public can use 

search criteria that includes: industry(s); chemical(s) or chemical group(s); year(s); and state(s). The 

public can display a facility comparison report to see each facility’s waste management quantities and 

trends. 

TRI also has a pollution prevention reporting tipsheet to inform the public about TRI information: 

http://www2.epa.gov/toxics-release-inventory-tri-program/tri-p2-reporting-tip-sheet. 

Other EPA resources about P2 data from the EPA website include:

 http://www2.epa.gov/toxics-release-inventory-tri-program/pollution-prevention-p2-and-tri (TRI 

P2 webpage)

 http://www.epa.gov/p2/ (Information on EPA’s P2 Program)

 http://www2.epa.gov/toxics-release-inventory-tri-program (TRI homepage).

 

Question and Discussion Period for Session 3: 

Question from Ward Penberthy, EPA, for Wayne Ziegler, DoD: 

How did you decide which substances to evaluate at JS3, and what criteria were you looking for in your 

evaluation? How did you test the efficacy?

Answer by Wayne Ziegler, DoD: 

The DoD conducted a literature review, worked with the working group, and spoke with 

companies to figure out their needs. The literature review identified substances and shows 

customers. There was an economics aspect about the testing and what was economically 

feasible. In engineering the company has to have an understanding of their own process. JS3 

evaluated which substance was most successful out of the ones determined in the literature 

report. 

Question from Maria Doa, EPA: 

Cost, health, time, safety, and performance are determining factors for selecting an alternative. Can EPA 

do a better job of figuring out the tolerances of companies and what people are willing to accept? Is it 

clear what factors the companies struggle with?
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Answer by Heidi Wilcox, TURI: 

When working with a company, factors come out upfront as well as what factors affect the 

company. Over time, Ms. Wilcox has figured out the specific questions that she needs to ask a 

company in order to figure out what affects each company. Customers have a lot of fears. EHS is 

always critical. Use database and screening tools to figure out what a company needs. For 

example, if VOC is an issue because of air permits, metrics can be worked out with the specific 

issue. The most important thing is that there needs to be a connection on some level with the 

customer in order to figure out their needs. A lot of the times companies struggle with cost, 

toxicity, and performance. If a chemical has the lowest possible toxicity but the chemical does

not perform, then it means nothing. Cost performance is very important to companies. Most of 

the time it comes down to having the necessary people skills to be able to connect with the 

companies. 

Answer by Ryan Hulse, Honeywell: 

If you have EHS problem—people can articulate that immediately—a cleaning issue is harder for 

people to articulate—in that situation you should watch the process/production.

Answer by Wayne Ziegler, DoD: 

What tools can EPA help people articulate their needs? Questionnaires are valuable and tools 

out there that EPA can leverage and if EPA helps with the tools and how do you figure out total 

ownership.

Answer by Barbara Kanegsberg, BFK Solutions LLC: 

There is no substitute for sitting down and talking with customer. How do we get the regulatory 

community involved in a productive way? When Margaret Sheppard first joined the EPA, she 

conducted on-site visits of various sites and observed different processes. In general, we need to 

get people less frightened of government.

Question from Maria Doa, EPA: 

What are some of the tools and business cases (P2 cases) of how people have shifted their processes? 

Do you think that when people see similar companies make the switch, their companies will make the 

switch as well? 

Answer by Heidi Wilcox, TURI: 

Yes, companies see other companies switch and it influences them. How clean do you have to 

be? There is a big difference between a visual clean and a microscopic clean. The TURI database 

has thousands of tests and TURI works hard to keep database running. Learning from each other 

(other companies) is huge and peer-to-peer contact is invaluable. Holding a conference for peerto-peer communication instead of just experts would be helpful to connect to people to let 

companies know that a switch can be done.

Question from Paul Lewis, EPA: 

The focus of this type of workshop is understanding the tools and strategies using worker exposure. 

There are measures other than substitution for moving from TCE to another chemical. Are there any 

reactions to other methods besides that? 
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Answer by Wayne Ziegler, DoD: 

JS3 tries to understand what cleaning processes companies have and attempts to keep 

communication open to figure out a solution where the company can get rid of the cleaning step 

in their process. 

Answer by Heidi Wilcox, TURI: 

Sometimes people are over-cleaning, and that’s another issue. 

Answer by unknown participant: 

The first thing we always start with is if a step is really important or not. Sometimes there needs 

to be more of a shift. For instance, sometimes if you clean soil immediately you can save a lot of 

time down the line. Every once in a while you can go through the supply chain and switch from 

one aqueous to another aqueous.

Question from Jennifer Sass, NRDC: 

Do you have statistics or numbers of what the market penetration is of the alternatives? There was 

discussion that CA is a leader and other markets have moved away from TCE, so what is left in the 

market?

Answer by Ward Penberthy, EPA: 

The market of TCE left is what is reported to TRI. 

Question from Jennifer Sass, NRDC: 

What percentage of TCE is being used in each sector? 

Answer by Dan Teitelbaum, EPA: 

In the database you can break down by state and which sector. TRI can give you that 

information. 

Question from Jennifer Sass, NRDC: 

Are companies that still use TCE cleaners the holdout companies, and what percentages are holdout 

companies? 

Answer by Heidi Wilcox, TURI: 

That is a hard question to answer because in different sectors there are little small businesses 

and it is hard to find them. Massachusetts has similar reporting requirements that require 

companies with a drum and a half to report. There are a lot of ways around the reporting 

requirements for some companies, so it is frustrating to figure out which small companies still 

use TCE cleaners. It is easier to find out for the bigger companies and sometimes bigger 

companies are on the cutting edge and some are forced to switch due to community outreach. 

Question from Jennifer Sass, NRDC: 

If you had data on just the big companies and not the small ones that would be helpful as well. What 

percentage is left for TCE and the cleaning operations?

Answer by Heidi Wilcox, TURI: 

Maybe more than 10%. 

Question from Paul John, NY State DEC Region 2: 

Is anyone evaluating manufacturing using 3D printing and robots in a sealed environment?
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Answer by Barbara Kanegsberg, BFK Solutions, LLC: 

You can do 3D printing when you end with a plastic part and one where you use metal and come 

up with a metal part and you can do that in an enclosed system. One of the issues with metal 

parts is: does it requires cleaning and does this require TCE? Dr. Kanegsberg did not know if it 

requires TCE. It would be hard to get rid of all of the cleaning problems. Aerospace and 

aeronautics industries are looking at how 3D printing works. We can say that there are mostly 

particles but add to that manufacturing and manufacturing has its own challenges.

Answer by Wayne Ziegler, DoD: 

Additive manufacturing is so diverse and complex that they have not really defined their 

process, so no one is really addressing that in any organized manner. 

4:30 – 5:00 PM: Public Comment 

Paul Lewis, EPA, opened the public comment period. 

Public comments may be posted to the public docket. 

Public Comment by Michael Partain, private citizen: 

Michael Partain is a public citizen and one of the one million marines poisoned at Camp Lejeune from 

TCE. Seven years ago he was diagnosed with male breast cancer due to his exposures at Camp Lejeune. 

A total of 84 men from the camp were diagnosed with male breast cancer. It is believed that there is a 

correlation between TCE exposure and the disease. There was TCE in the drinking water at Camp 

Lejeune. 

Mr. Partain stated that it was refreshing to hear the dialogue between EPA and industry trying to find 

solutions. There are 132 DoD contaminated bases across the country. It is important to have a dialogue 

between business and the community. 

On Jan. 13, 2013, Senator Kravitz sponsored two bills charging EPA with protecting citizens from toxic 

exposures from chemicals. Mr. Partain found contradictions of the senator’s public comments. EPA has a 

history of poor management of scientific process and public leaders want to appear to protect public 

health, but when the agency moves to protect the public good then EPA transforms into an inept 

agency. Protecting the public health is important and Mr. Partain fully expects that any action by EPA 

can be countered by the National Academies of Science.

The exposures at the base and the diseases were said to have a limited link. News of a contract dissolved 

this limited link. Honeywell oversaw peer review comments and comments were not addressed. The 

NRC report on Camp Lejeune was supported by actual science. In two reports released this year NRC 

found health effects from TCE that corresponds with what EPA addressed in the risk assessment. TCE 

was heavily used as a degreaser at Camp Lejeune and exposures were through drinking water, vapor 

intrusion, and open air vats. At the camp, the chemical was used to clean personal weapons and barrels.

EPA cannot do its job if industry is against them. TCE has been found harmful for decades. It was found 

harmful in 1932 and 1952. In 1932 it was reported that any manufacturer trying to use the chemical can 

find favorable chemical qualities but the company should be aware that TCE has harmful effects. 

Often industry comments on TCE day in and day out but it is not often that EPA hears from the public. 

Male breast cancer is a rare disease that Mr. Partain and 83 other men on the base have due to 

exposure to TCE. 
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Public Comment by Dr. Richard (Rick) Reiss, Exponent: 

Dr. Reiss reviewed the exposure assessment and risk assessment. His report has been submitted to the 

docket. His overall conclusion is that the exposure assessment is inadequate to make exposure 

evaluations. EPA made assumptions about the number of small facilities using degreasers and there are 

significant uncertainties in the exposure assessment and a lack of assumptions to evaluate the 

calculations. In the absence of actual emission numbers, EPA estimated them instead.

The TRI database only includes larger facilities. EPA used the 2008 NEI and 2011 TRI reports to report 

emissions and this is not enough to determine emissions. The public cannot rely on the EPA data 

presented in the Risk Assessment. 

Critical assumptions in the risk assessment do not add up. There are inconsistencies and assumptions in 

the report. EPA should gather more information about the facilities that use TCE before finalizing the 

Risk Assessment. 

Public Comment by Jennifer Sass, NRDC: 

Ms. Sass works in the health program as a scientist at NRDC. Ms. Sass stated that her final comments 

will be provided to the docket. 

The NRDC is pleased that EPA has used its authority under TSCA and is not surprised that science said 

that there is an unexpectedly high health risk from TCE exposure. The developmental effects were the 

most concerning. Ms. Sass thinks that based on the science behind the risk assessment and EPA’s 

analysis that EPA should regulate TCE and a ban on TCE use is the most effective risk reduction strategy. 

Ventilation is inadequate as a safety measure. There are safer alternatives that are being used and 

applied. NRDC believes that there is no excuse to use TCE anymore.

NRDC is also worried about bystander risk. There are serious and unexpected health problems that have 

been documented. FDA banned TCE in food in 1977 and EPA spent 25 years reviewing TCE. EPA has been 

delayed in banning TCE. There are holdout companies who still use TCE and by not banning the 

substance it has proved the benefit to them of their inaction. EPA must not allow substitutes that may 

have their own health issues.

There are very serious health effects like fetal heart abnormalities. 

EPA’s review of asbestos is similar to that of TCE. EPA reviewed asbestos and was able to make industry 

change. 

EPA’s scientific work is seen as flawed. EPA drafted an external charge. The Johnson et al. study (2003) 

underwent peer review and there was an expert consensus about TCE. EPA’s overall assessment is 

strong and the peer review charge questions were actually developed by multiple EPA staff. 

TSCA should identify unsafe exposures.

Closing Remarks: 

Paul Lewis, EPA. 

The discussion was informative and interactive and EPA is looking forward to continuing discussion 

tomorrow.
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Wednesday, July 30, 2014 

8:30 – 9:00 AM: Welcoming Remarks 

Brad Goodwin, AAAS S&T Policy Fellow hosted by EPA 

There was a small change to the agenda and the continued discussion was moved until after the first 

talk of the day. The next session is an introduction to exposure reduction options other than chemical 

substitution. EPA will be looking at other types of methods to be put into place that will reduce exposure 

for workers. 

8:30 – 9:30 AM: Strategies to Reduce Worker Exposure 

Edward Viveiros, Eastern Research Group (ERG) 

EPA’s risk assessment identified health risks from use of TCE as a degreaser primarily through inhalation. 

TCE health risks were from commercial and consumer use of TCE as a solvent degreaser, from 

commercial use of TCE as a spotting agent at dry-cleaning facilities, and from consumer use of TCE as an 

arts and crafts spray coating. 

TCE use concerns are based on frequent application of TCE at high concentrations and high potential for 

human exposure through inhalation (predominant route due to TCE’s volatility and skin absorption). To 

manage TCE risks, EPA developed an outreach document to inform commercial stakeholders of risk 

reduction options. 

Degreasing with TCE in Commercial Facilities: Protecting Workers

The guide, Degreasing with TCE in Commercial Facilities: Protecting Workers, provides a set of practical 

and relevant options for reducing TCE risks. Risk reduction options are based on literature reviews and 

interviews with experts. Mr. Viveiros helped EPA develop the outreach document to inform commercial 

stakeholders of risk reduction options. The document can be used by industry to reduce exposures. The 

document is not intended to be read cover to cover but instead is a guide for shops to figure out what 

alternatives they can use.

The document identifies how TCE is typically used as a degreaser and the typical commercial settings 

(for targeted communication of risk reduction options) and addresses who are the shops using TCE and 

the technologies that can be used to eliminate or reduce TCE risks. Four key risk reduction areas are: 

technologies to reduce TCE risks, engineering controls, workplace practices, and PPE. The basis for the 

key risk reduction areas is the hierarchy of hazard control, which starts with PPE, then workplace 

practices, then engineering controls, substitution, and then elimination. 

Typical degreasing methods are spot cleaning, cold cleaning, and vapor degreasing. 

Spot Cleaning

In spot cleaning, components are cleaned by spraying degreaser directly onto components and wiping 

with a rag that has been dabbed or soaked in the degreaser. This method typically applies degreasers in 

excess amounts and readily produces TCE vapors during subsequent air drying. 

Cold Cleaning:

Cold cleaning components are cleaned in a non-boiling (“cold”) solvent. Cleaning occurs by spraying, 

brushing, flushing, and immersion.
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Vapor Degreasing:

A vapor degreaser is boiled to produce hot vapors and components are suspended in the vapor for a set 

period of time. Vapors gradually condense on the component’s surface, cleaning it in the process.

Typical degreaser users are repair shops, fabrication shops, metal plating shops, and electronics 

assembly shops. Degreasing is used at a repair shop to clean service components before they are 

reinstalled in a product. At a fabrication shop, degreasing is used to clean parts before the direct sale or 

installation into final products. At a metal plating shop, degreasing is used to clean parts before they are 

electroplated and then sold. At an electronics assembly shop, degreasing is used to clean the circuit 

board assemblies before the direct sale or installation into final products. 

The document does not just focus on the four types of typical degreaser shops. The document will be 

helpful to any shop that is spot cleaning, cold cleaning, or vapor degreasing. 

Technologies that Eliminate or Reduce Risk from TCE

Technologies that eliminate or reduce risks from TCE include PPE, workplace practices, engineering 

controls, substitution, and elimination. For a given shop, the document speaks to the processes that the 

shop is already using. The most suitable option for a shop can depend on the cleaning process already in 

use, the nature of the components being cleaned (material, shape, texture), the types of contaminants 

being removed (oils, greases, dirt, salts) and the required level of cleaning. Because degreasing 

processes, settings, and deciding factors are varied, it is difficult for EPA to provide detailed 

recommendations. Therefore, the guide highlights practical and relevant technologies that shops can 

consider implementing. Ultimately, shops must work with vendors to identify the most suitable option. 

A bake-off oven can produce smaller volumes of waste compared to liquid cleaning alternatives. It 

decomposes dirt and grease, leaving behind dry residues that can be brushed off. Bake-off ovens can 

only be used on components that can withstand high heat. 

Water-based cleaning applies to any type of shop and could eliminate the use of TCE and solvents. The 

degree of elimination ranges from complete (aqueous cleaning) to partial (semi-aqueous cleaning). 

Water-based cleaning utilizes the following cleaning methods: manual cleaning, hot soap washing (hot 

tank washing), spray cleaning, and ultrasonic cleaning. 

Low-solids fluxes apply to electronics repair and assembly shops and are used similarly to conventional 

fluxes. They dry rapidly and leave behind little or no residue, eliminating the need for cleaning with TCE. 

Inert atmosphere soldering applies to electronics repair and assembly shops and soldering occurs in an 

oxygen-free environment (typically in nitrogen gas). The inert environment prevents formation of oxide 

contaminants, eliminating the need for cleaning with TCE. The suitability of this technology is casespecific and flux may still be required even if soldering in an inert environment.

Closed loop vapor degreasing applies to any shop type and cleans components in an air-tight chamber,

which significantly reduces emissions and improves overall cleaning and product quality. It reduces 

exposures by exhausting vapors before workers can open the chamber door. It also reduces vapor 

emissions by as much as 98% compared to the conventional vapor degreasers. 

Engineering Controls

In spot cleaning the engineering controls are mechanical ventilation and local exhaust ventilation. 

Because of the direct nature of spot cleaning, engineering control options for preventing direct contact 

with TCE are limited to ventilation.
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In cold cleaning, the escape of TCE vapors from the cleaning tank can be limited by installing vapor-tight 

covers (rolling covers are preferable since hinged covers can expel TCE vapors when they swing closed), 

covering solvent baths with a 2-to-4-inch water layer, and installing lateral exhaust systems. If using 

spray equipment, consider using a solid-fluid stream sprayer and avoiding atomizing or shower sprayers 

(which generate more TCE vapors).

In vapor cleaning, TCE vapors from a degreaser can be limited by installing vapor-tight covers, installing 

a second set of cooling coils, installing lateral exhaust systems, and installing a pressure gauge to identify 

leaks. When feasible, consider using automated controls like a condenser coolant thermostat switch, 

solvent level control switch, and vapor level control switch. Closed loop vapor degreasing applies to any 

shop type. 

Workplace Practices

In the workplace, when reducing risks with spot cleaning, isolate cleaning activities and physically 

separate the cleaning station from the rest of the shop. Establish guidelines on when it is absolutely 

necessary to clean components with TCE and when to prohibit its use otherwise. Encourage or require 

employees to brush or scrape off caked-on solids prior to cleaning components. 

When reducing risk for cold cleaning and vapor degreasing in the workplace, keep the tank or degreaser 

covers closed whenever is possible. Rack components in a manner that minimizes drag-out losses. 

Cleaned components should be drained for at least 15 seconds or until dripping stops and avoid 

subjecting degreasing stations to drafts, which can carry TCE vapors into surroundings. An appropriate 

freeboard ratio should be maintained as well.

Personal Protective Equipment (PPE)

PPE is the “last line of defense” to mitigate or reduce exposures if you exhaust the other three ways to 

reduce risk (workplace practices, engineering controls, and elimination). Gloves and coveralls can 

effectively protect skin against TCE, and specific materials and brands are listed in the document. 

Chemical splash goggles and face shields should be worn to protect eyes. Eye wash stations (although 

not technically PPE) near degreasing areas with unobstructed access should be provided and when 

exposed, the worker should rinse his or her eyes for at least 15 minutes. There should be adequate 

respiratory protection like a NIOSH certified respirator. The most effective respirators for TCE include 

full face piece respirators with positive pressure supplied air and self-contained breathing apparatus. 

Dust masks and N95 respirators do not protect against TCE. One contractor was found to be using dust 

masks to protect workers from vapor but the masks do not protect against vapor. 

Questions and Discussion about Strategies to Reduce Worker Exposure: 

Question from Doug Parsons, EPA, to Edward Viveiros, ERG: 

When you are surveying people in the field, were there practices that people were implementing more 

often than not, and what are the common practices that you saw currently?

Answer by Edward Viveiros, ERG: 

Water-based cleaning and low flux residue technology are examples, but low flux residue 

technology was not as prevalent as water based cleaning. 

Question from Brad Goodwin, AAAS S&T Policy Fellow hosted by EPA: 

There are requirements for control practices in vapor degreasers and cold cleaning above 2 gallons. Do 

these go beyond those requirements or is it the same information found in the requirements?
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Answer by Edward Viveiros, ERG: 

It is around the same type of advice. 

Question from Julia Quint, California Department of Public Health (Retired): 

Right now the permissible exposure limits for TCE are quite high and one of the health effects of concern 

is developmental toxicity and pregnancy. Some exposures could happen very rapidly or in an acute 

manner. When you are talking about options, are the local exhaust systems capable of bringing the risk 

level down? If you are using engineering controls instead of substitution, how do you protect against the 

pregnant worker who has been exposed? You really need a policy in the workplace to protect against 

that population. 

Answer by Edward Viveiros, ERG: 

The broad perspective is that ventilation needs to be provided but the document does not list 

how to get to that level. The document is a description of materials related to do this, but local 

exhaust ventilation should reduce exposure.

Question from Julia Quint, California Department of Public Health (Retired): 

What is presented in the document is controls for industrial hygiene and there should be more 

information along with it. Because the levels for TCE are high right now and legal, the document is not in 

sync with the EPA risk assessment, so that’s a gray area for workers right now and this is a cautionary 

note to do outreach in tandem with more information. 

Answer by Edward Viveiros, ERG: 

The document itself does not go to that level of detail. 

Question from Brad Goodwin, AAAS S&T Policy Fellow hosted by EPA: 

Yesterday the discussion was about getting buy-in from the workers about substitution. Did you hear 

anything in the interviews about practices that were more readily accepted by workers or practices that

received push back?

Answer by Edward Viveiros, ERG: 

There is a mindset that “we can’t use this chemical so let’s just use another one.” They want to 

use substitutions. 

Question from Brad Goodwin, AAAS S&T Policy Fellow hosted by EPA: 

Are any practices more likely to be accepted or not?

Answer by Edward Viveiros, ERG: 

Mostly it is about what types of PPE people could encounter in the field. 

Question from Rob Lee, DuPont Chemical: 

Is there any interest by EPA or others in lowering the exposure limits or developing guidelines? Seems 

confusing to folks whether they should substitute or keep going with work practices?

Answer by Paul Lewis, EPA: 

In this stage, EPA is looking at risk mitigation and risk reduction strategies that EPA can take and 

understanding and characterizing risk. 

Question from Doug Parsons, EPA: 

When you look at TCE products, there are a lot of different labels on products. Did you compare the 

labels to what people are using in the field?
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Answer by Edward Viveiros, ERG: 

Labels were not evaluated. 

Question from Niva Kramek, EPA, as relayed by Brad Goodwin, AAAS S&T Policy Fellow hosted by 

EPA, to audience: 

EPA is interested in getting feedback on the document and whether it represents reality. EPA would like 

to know whether the document is implementable, and EPA is happy to hear public comments on the 

document.

Answer by Manoj Patel, Green Life Development, Inc.: 

There is confusion between California levels and federal levels, and what we have found is that 

people are looking for a substitute for what they are used to, and a substitute that can eliminate 

challenges such as cost (one company spent $1,200 a month on hazardous waste disposal). 

Companies want to substitute methods. 

Answer by Christina Franz, American Chemistry Council: 

In response to whether the strategies represent reality, the ACC encourages EPA to reach out to 

the Small Business Association (SBA) and the ACC does not think this has been done by EPA. This 

would help in answering the question. 

Question by Brad Goodwin, AAAS S&T Policy Fellow hosted by EPA: 

Did companies have a preferred approach and was there any sense of what they thought the reductions 

in exposure were from the changes that they made?

Answer by Edward Viveiros, ERG: 

All interviews we conducted were with people who worked with the companies. 

Answer by Julia Quint, California Department of Public Health (Retired): 

Ms. Quint did not see a caveat in the document that EPA is not recommending to start with 

substitution. The OSHA recommendation is to start with engineering controls and then with 

substitutions. EPA should mention in writing that substitution is the first order of business in 

terms of hierarchy of controls and then respiratory protection, PPE, and eye washes.

Comment by Eileen Sheehan, EPA Region 9:

The document does not reflect input from yesterday at the conference and does not reflect the 

substitutions that Julia Quint brought up. 

Comment by Doug Parsons, EPA:

This document focused on exposure and risk reduction. 

10:00 – 10:30 AM: Discussion and Conclusions from Sessions 2 and 3 

Chair: Maria J. Doa, OPPT, EPA 

The potential outcomes of Sessions 2 and 3 were to create a list of criteria that potential alternatives will 

need to satisfy if they are to be used as replacements for TCE and to address the key lessons learned in 

transitioning from TCE to an alternative that can help inform future substitutions. 

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. There were case studies on the use of aqueous cleaners and 
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presentations by Slide Products, Astro Pak, TURI, and IRTA. Alternatives evaluations and transitioning 

away from TCE in vapor degreasing were discussed. 

Factors to consider

In the sessions there was some discussion about considering the complete process and not just the 

cleaning step. It is necessary to question whether the cleaning process is really needed and whether the 

process needs to be modified. Performance, cost effectiveness, environmental health, and safety are 

factors to consider when evaluating an alternative.

Heidi Wilcox and Jason Marshall from TURI spoke about the importance of buy-in from management. 

Questions that arise are whether or not there is money to make a change and if there is a commitment 

from management to make a change. Making the business case is important.

The input of hands-on users is necessary as well. Peer feedback is extremely important. 

Cost

It is important to consider costs other than price of TCE and the capital costs. EPA and industry need to 

consider other costs associated with the use of TCE and EPA can use the DoD construct about why

companies use TCE and why companies should not use TCE as documented by Wayne Ziegler from the 

DoD.

Why not TCE?

 There are costs beyond the cost of the chemical including the cost of control 

technologies/engineering controls

 There are recordkeeping and administrative costs

 There are PPE requirements, and some workers do not like to use PPE

 Proper waste disposal needs to occur

 TCE use increases the risk of inhalation exposure

 There are potential acute and chronic exposure effects

 TCE is subject to multiple regulations. 

Challenges

There were a number of key challenges including flammability, compatibility, functionality, worker 

training, military specifications, and corporate support and funding. 

Successes

The panelists showcased successes. Examples included piloting the potential product with users and 

receiving positive feedback and cases showing how educating customers is helpful to getting the 

customer onboard with a switch away from TCE. Companies may make switches through intermediate 

steps (i.e., moving from one alternative to another).

Lessons learned

The user needs to be engaged early on and needs to be able to characterize performance needs. On-site 

visits to facilities aid the company in transition. There should be an implementation plan in place to 

assist a company to make a switch. There was also feedback on how to make the ERG draft report more 

useful and putting into context the substitutes and looking at vulnerable populations. EPA appreciates 

any comments. 
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Final Discussion

Question from Maria Doa, EPA, to Audience: 

Are there any other points that are not captured here but are important to take away from the 

meeting?

Answer by Eileen Sheehan, EPA: 

It was helpful to have the summary of the meeting, but one thing that is not reflected is the 

extent to which many businesses have already shifted. Ms. Sheehan would like to clarify in the 

section called lessons learned that a lot of businesses have already shifted for a variety of 

reasons and not just in California where they are required to. 

Another point to capture under “Why Not TCE” is that the one thing missing is the liability and 

life cycle of TCE, which is what has prompted a lot of people to shift away from TCE. A lot of 

parties have already had to pay the cost of superfund cleanups and have paid the price. 

Comment from Maria Doa, EPA: 

EPA would like to look at how companies have reported in the past, what sectors businesses are 

in, and what their processes are. 

Comment from Julia Quint, California Department of Public Health (Retired): 

EPA should add information about regrettable substitutions. 

Comment from Maria Doa, EPA: 

The summary will be updated to add information about regrettable substitutions. 

Question from Chris Rodriquez, Biosolids: 

Has EPA considered putting information on the website about alternatives for TCE?

Answer by Maria Doa, EPA: 

EPA has considered putting information on the website about TCE alternatives and it will be 

added to the TCE Workshop summary slides. 

Comment from Eileen Sheehan, EPA: 

A rule or a regulation can make a difference, and EPA would be remiss if EPA did not acknowledge this. 

Comment from Julia Quint, California Department of Public Health (Retired): 

A lot of this is about workers in the particular applications, and there should be follow up with OSHA and 

NIOSH with the PEL. 

Comment from Maria Doa, EPA: 

EPA wants to thank everyone again for the information and expertise. EPA will be taking this and 

determining next steps and putting revised materials up on the website. EPA wants highlight the 

successes and tools and work with TURI to see if there are tools and materials that we can target to a 

variety of users to make more useful. EPA will continue to work across the agency and sister agencies. 

10:30 – 11:00 AM: Public Comment 

Introductions by Loraine Passe from EPA. 

Introductions to the public comment period. 
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Public Comment by Christina Franz, Senior Director of Technical Affairs, American 

Chemistry Council 

ACC member companies do not sell TCE into the use applications that were the focus of the TCE use risk 

assessment. ACC members sell into places where it is well regulated. After listening to the presentations 

and discussions, thoughts and observations, the ACC supports EPA’s effort toward reduction and the

supporting model of continuous improvement and refinements of EPA’s risk assessment. The ACC wants

to work with EPA to refine the risk assessment.

Efforts should help to identify actual risk posed. The ACC supports EPA’s openness and engagement with 

stakeholders in the workshop. 

Risk reduction does not always mean that an alternative is not always the most appropriate risk 

reduction measure. Alternatives not the only thing that should be considered. There is no one-size-fitsall fix. The industries impacted should be fully engaged so that their business needs are fully understood. 

EPA should work with small businesses. 

EPA may have overestimated or underestimated risk. The SBA should be able to identify small 

degreasers to work with the agency to figure out how to best manage or reduce risk. 

11:00 – 11:30 AM Wrap Up and Next Steps 

Closing Statements by Maria Doa, EPA 

EPA thanks everyone for attending the workshop and appreciates the experts for sharing their 

knowledge and experience. 
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Appendix A: Workshop Agenda 

Expert Public Workshop on Alternatives and 

Risk Reduction Approaches to Trichloroethylene (TCE)

Use as a Degreaser

Date: Tuesday, July 29, 2014, 9:00 a.m. to 5:00 p.m.

Wednesday, July 30, 2014, 8:30 a.m. to Noon

Location: Environmental Protection Agency (EPA)

Rachel Carson Green Room, William Jefferson Clinton South (3rd floor) 

1201 Constitution Ave., NW, Washington, DC 20460

Background:

On July 29-30, EPA will hold a public workshop on the use of trichloroethylene (TCE) as a 

degreaser, availability and efficacy of safer alternatives, and possible risk reduction 

approaches. This workshop is being held to support risk reduction activities concerning 

the health risks from TCE exposures to consumers using spray aerosol degreasers and 

workers using TCE as a degreaser in small commercial shops identified in the final risk 

assessment that was released on June 25, 2014. 

Goals of the Workshop:

The goals are to generate information from experts on TCE when used as a degreaser to 

better understand the risk reduction considerations when transitioning to safer 

alternatives and other cleaning strategies. These risk reduction approaches could be 

regulatory, non-regulatory, or a combination of both. 

This workshop will examine TCE use as a degreaser in various applications, including cold 

cleaning, vapor degreasing, or as an aerosol used by consumers or by workers at small 

commercial shops. Industry, government, non-governmental organizations, academic 

experts, states, and others will discuss alternatives and risk reduction approaches to the 

degreasing uses of TCE. The workshop will include presentations by EPA, keynote lectures 

by subject matter experts, and sessions focused on vapor degreasing, cold cleaning, and 

aerosol degreasing. There will be an opportunity for the public to comment, as well. The 

workshop will examine the following uses: 
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 TCE Use in Small Commercial Settings for Degreasing--This use category will 

focus on the smaller commercial shops that use TCE for degreasing, including 

vapor and heated degreasing, cold cleaning and aerosol.

 TCE Use by Consumers or Hobbyists for Degreasing--This use category will focus 

on the consumers and hobbyists that use TCE as a degreaser, including cold 

cleaning and aerosol uses.

For more information and any background documents, please visit: 

http://www.epa.gov/oppt/existingchemicals/pubs/workplans.html, or contact Katherine 

Sleasman on 202-564-7716, sleasman.katherine@epa.gov or Douglas Parsons on 202-564-

0341, parsons.douglas@epa.gov

Instructions to register for the workshop, or participate by webinar, can be found here:

https://www.eventbrite.com/e/epa-workshop-alternatives-and-risk-reduction-fortrichloroethylene-tce-tickets-11540137863
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Conference Agenda

All events are in the Rachel Carson Green Room, 

William Jefferson Clinton South Building (3rd floor)

Tuesday, July 29

8:30 - 9:00 Registration

9:00 – 9:30 Opening Session

9:00 - 9:05 Welcome Remarks 

Wendy Cleland-Hamnett, Director 

Office of Pollution Prevention and Toxics (OPPT), 

EPA

9:05 - 9:20 Findings from the TCE Risk Assessment

Tala Henry, OPPT, EPA

9:20 - 9:30 Overview and Purpose of Workshop

Jeff Morris, OPPT, EPA

9:30 – 10:15 Opening Keynote Lectures

9:30 – 9:55 Keynote Lecture: Evaluating worker risks and 

process for informed substitution and solvent 

selection

Julia Quint, (Retired) California Department of 

Health

9:55 - 10:15 Keynote Lecture: Alternatives process, efficacy and 

health considerations

Jason Marshall, Toxics Use Reduction Institute 

(TURI) 

10:15 – 10:30 Break 
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10:30 – 12:00 Session 1: Keynote & Background Lectures: Use 

of TCE and perspectives on application 

Chair: Doug Parsons, OPPT, EPA

Each presentation in this session will address the following questions 

regarding aerosol, cold cleaning, and vapor degreasing uses of TCE.

 What are the current degreasing uses of TCE?

 What contaminants does TCE remove?

 What substrates is TCE compatible with?

 What properties of TCE make it an effective degreaser and preferable over 

alternatives?

 What other factors are important to the use of TCE as a degreaser?

 What health/safety considerations must be considered when using TCE?

 What applications/soils/substrates is TCE not appropriate for use with?

10:30 – 11:00 Keynote Lecture: Use of TCE as an aerosol, vapor & 

cold cleaner 

Katy Wolf, Institute for Research and Technical 

Assistance (IRTA) 

11:00 – 11:30 Keynote Lecture: Use of TCE as a vapor degreaser 

Wayne Ziegler, U.S. Army Research, Development 

and Engineering Command, Army Research 

Laboratory

11:30 – 11:45 Regulatory Landscape for TCE in Federal and State 

Air Programs

Margaret Sheppard, Office and Air and Radiation 

(OAR), EPA

11:45 – 12:00 Overview of Regulations in California on Solvent 

Degreasers

David Edwards, California Air Resources Board (via 

webinar)

12:00 - 1:00 Lunch

1:00 - 1:10 Purpose and Goals of Afternoon Discussion 

Sessions 

Maria J. Doa, OPPT, EPA
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Sessions 2 and 3 will address the following questions for unique uses of 

TCE: 

 What properties and characteristics of TCE make it effective and desirable 

for a given application?

 What alternative chemicals can be substituted for TCE in a given use? 

 Are there critical uses where no viable chemical alternatives exist? 

 In cases with no chemical alternatives, what other measures can be 

employed to reduce exposure to TCE?

In discussion of these questions, case studies will be used to demonstrate 

processes that have been used to reduce exposure to TCE (chemical 

alternatives and alternative processes/process modifications). These case 

studies should address the following questions (not all questions will be 

applicable to every case study):

 Where was TCE used and why?

 What was the impetus for seeking an alternative for TCE?

 What considerations were taken into account to identify potential 

alternatives?

 How was the list of potential alternatives narrowed down?

 How were alternatives evaluated for efficacy?

 How were environmental/health considerations taken into account in 

identifying alternatives?

 How was a final alternative selected for use?

 What lessons were learned in reducing exposure to TCE that could help 

inform future decision making?
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1:10 – 2:50 Session 2: Aerosols and Cold Cleaning

Panel chair: Eileen Sheehan, EPA Region 9

Rapporteur: Katherine Sleasman, OPPT, EPA

This session will address issues related to the use of TCE in aerosol form 

and cold cleaning in both small commercial and consumer settings. The 

panelists will be followed by discussion. 

Short panel presentations: 

1. Identification of less toxic TCE alternatives in automotive/electronic 

applications,

Katy Wolf, IRTA

2. Balancing functionality with efficacy 

Steve Bennett, Consumer Specialty Products Association

3. Reformulation of product line to remove chlorinated solvents 

Michael Muth, Slide Company 

4. Experiences in evaluating cold cleaning alternatives to TCE, successes and 

failures, Jason Marshall, TURI

5. Case studies on use of aqueous cleaners, 

Brent Ekstrand, Astro Pak

Potential Outcomes: 

1) List of criteria that potential alternatives will need to satisfy if they are to 

be used as replacements for TCE. 

2) What key lessons were learned in transitioning from TCE to an 

alternative that could help inform future substitutions? 

3) Are there generalizations that can be made so that future substitutions 

are easier to conduct? 

4) Are there any characteristics, or combinations of characteristics that 

resulted in no viable alternatives to TCE? 

5) List of measures other than chemical substitution that can be used to 

reduce exposure to TCE. 

2:50 – 3:00 Break
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3:00 – 4:30 Session 3: Vapor Degreasing

Panel chair: Ward Penberthy, OPPT, EPA

Rapporteur: Brad Goodwin, AAAS S&T Policy Fellow 

hosted by EPA 

This session will address issues related to the use of TCE in vapor 

degreasing applications in small commercial settings. The panelists will be 

followed by discussion.

Short panel presentations: 

1. Transitioning from TCE in vapor degreasing applications at military 

facilities, Wayne Ziegler, Department of Defense

2. Alternatives evaluation 

Heidi Wilcox, TURI 

3. Alternative solvent development 

Ryan Hulse, Honeywell

4. Alternative to TCE 

Manoj Patel, Green Life Development Company

5. Process based risk reduction for cleaning 

Barbara Kanegsberg, BFK Solutions LLC (via webinar)

6. Reducing TCE Waste in the Fabricated Metals Sector and Overview of P2 

reporting, Dan Teitelbaum, EPA

Potential Outcomes: 

1) List of criteria that potential alternatives will need to satisfy if they are to 

be used as replacements for TCE. 

2) What key lessons were learned in transitioning from TCE to an 

alternative that could help inform future substitutions? 

3) Are there generalizations that can be made so that future substitutions 

are easier to conduct? 

4) Are there any characteristics, or combinations of characteristics that 

resulted in no viable alternatives to TCE? 

5) List measures other than chemical substitution that can be used to 

reduce exposure to TCE as a vapor degreaser.

4:30 - 5:00 Public Comment

Chair: Paul Lewis, OPPT, EPA

5:00 Adjourn Day 1
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Wednesday, July 30

8:30 - 9:30 Continued Discussion of Sessions 2 and 3 

9:30 - 9:50 Strategies to reduce worker exposure

Edward Viveiros, Eastern Research Group (ERG) 

9:50 - 10:00 Break 

10:00 - 11:30 Discussion and Conclusions from Sessions 2 and 

3

Chair: Maria J. Doa, OPPT, EPA

Suggestions for discussion topics: 

1) Summary of case studies 

2) Summary of key challenges

3) Summary of key successes

4) Summary of lessons learned

5) Summary of non-chemical exposure reduction options

Potential Outcome: Identify key common elements that can help 

manufacturers, distributors, users and others to transition to safer 

alternatives.

11:30 - 11:45 Public Comment

Chair: Loraine Passe, OPPT, EPA

11:45 – 12:00 Wrap Up and Next Steps

Chair: Maria J. Doa, OPPT, EPA

Potential Outcome: Identification of next steps, 

challenges, and opportunities to transition away 

from TCE and promote risk reduction

12:00 Adjourn Workshop

 
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Appendix B: Speaker Biographies 

Steve Bennett, Consumer Specialty Products Association (CSPA) 

Dr. Bennett serves as Senior Director of Scientific Affairs and Sustainability and is responsible for 

managing the Scientific Affairs Committee and all of its related task forces and issues while leading 

CSPA’s green chemistry and sustainability efforts, primarily through its product stewardship initiative –

Product Care®. He is tasked with bolstering the Association’s scientific affairs activities related to the 

environmental health and safety issues facing the industry and works with issues pertaining to chemical 

management under TSCA, the EPA’s Endocrine Disruptor Screening Program, California’s Proposition 65, 

poison prevention and providing technical support to the seven CSPA divisions. Dr. Bennett holds a Ph.D. 

in Inorganic Chemistry from the University of Delaware and a Bachelor of Science in Chemistry from Lock 

Haven University (Pennsylvania).

Wendy Cleland-Hamnett, EPA 

Ms. Cleland-Hamnett is the Director for the Office of Pollution Prevention and Toxics (OPPT) in EPA’s 

Office of Chemical Safety and Pollution Prevention. She served as the Acting Director of OPPT from 

January 2009 through February 2010 and prior to that served as the Deputy Director of OPPT from April 

2004 to December 2008. Ms. Cleland-Hamnett began her career at EPA in 1979 and spent her first ten 

years with the Agency in a variety of jobs within OPPT, including as Attorney-Advisor, Branch Chief, and 

Deputy Division Director positions.

Prior to re-joining OPPT, Ms. Cleland-Hamnett served as the Deputy Director of the Office of Information 

Collection, in the Office of Environmental Information (OEI), upon the creation of the Office in 1999. In 

that position, she led the successful effort to create EPA’s Central Data Exchange for electronic reporting 

of environmental data, a key element of the Agency’s E-Government Strategy. She also co-chaired 

efforts with State partners to design and implement the National Environmental Exchange Network, a 

cutting-edge approach to improving the quality, quantity and accessibility of environmental and 

program data shared among EPA, States and other Federal partners. 

Prior to the creation of OEI, she held several positions in the Office of Policy, including: Director of the 

Center for Environmental Information and Statistics (April 1998 to Oct. 1999); Director of the Office of 

Sustainable Ecosystems and Communities (1995 to 1998), and Deputy Director of the Office of 

Regulatory Management and Evaluation (1992 to 1995). 

From 1989 to 1992, Ms. Cleland-Hamnett was a Special Assistant in the Office of the EPA Administrator. 

Her assignments included work on pesticides and toxics programs, research and development issues, 

the Agency’s Risk Assessment Council, the EPA Science Advisory Board, and a special panel reporting to 

the Administrator on the quality of science at EPA.

Ms. Cleland-Hamnett attended Bates College in Lewiston, Maine, and received a B.A. in Political Science 

from Earlham College in Richmond, Indiana. She received a law degree from George Washington 

University and is a member of the District of Columbia Bar.

David Edwards, California Air Resources Board (CARB) 

Dr. Edwards currently works at the California Air Resources Board (ARB) as the Manager of the 

Consumer Product Implementation Section. In this capacity he leads projects that include the consumer 

and commercial Products Survey, Charcoal Lighter Material Certifications and Innovative Product 

Exemptions. Prior to working in this program at ARB, Dr. Edwards was Manager of the Climate Change 

Reporting Section which was responsible for collecting greenhouse gas emissions data from major 
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industrial sectors in the State of California. Before joining ARB, Dr. Edwards was an assistant Professor of 

Chemistry and Physics at the Wesleyan College in Macon, GA where he developed the Environmental 

Science Program. Dr. Edwards received his M.A. and Ph.D. in Chemistry from Princeton University and 

his B.S. in Chemistry from St. Mary’s College of California. He also received a certification in Science, 

Technology and Environmental Policy from the Woodrow Wilson School of Public Policy at Princeton.

Brent Ekstrand, Astro Pak 

Dr. Ekstrand serves as the corporate Vice President of Technology & Quality. As one of Astro Pak's 

research scientists, Brent has explored the efficacy of existing and novel passivation chemistries and 

cleaning agents. Brent's seventeen years of experience with Astro Pak Corporation gives him a solid 

technical background to serve as a key technical advisor for complex cleanroom, aerospace, and biopharmaceutical projects. He served on an advisory panel, comprised of industry leaders and NASA 

personnel, that spearheaded the effort to update the Kennedy Space Center’s main cleaning and 

validation document. Brent also provided consultation services on the subject of precision cleaning for 

JPL / NASA for the Mars Science Laboratory / Curiosity project. He is currently engaged in a consultation 

project with one of the new private launch providers. Dr. Ekstrand also conducts industry presentations, 

and has co-authored technical papers on subjects including precision cleaning and passivation. Brent 

completed a study of the efficacy of passivation using a gel-based citric acid formulation in order to 

demonstrate the viability of alternatives to the more toxic nitric acid based passivation formulations. He 

received his doctorate from the University of the Pacific. 

Tala Henry, EPA 

Dr. Henry has been with the United States Environmental Protection Agency (EPA) for 20+ years. She is 

currently Director of the Risk Assessment Division in the Office of Pollution Prevention and Toxics where 

she leads several Agency Programs that assess the health and environmental hazards, exposures and 

risks of new and existing chemicals, microorganisms and applications of biotechnology. Much of 

Dr. Henry’s professional experience with EPA has been as a Toxicologist. She has worked in a variety of

programs at the EPA including conducting research on the toxicity of chemicals, conducting risk 

assessments for hazardous waste sites, and developing Water Quality Criteria. Dr. Henry has also served 

as the United States representative and technical expert for a number of international chemical 

assessment and management activities. Dr. Tala Henry received a B.A. in Biology from the College of St. 

Scholastica, a Ph.D. in Pharmacology from the University of Minnesota and completed a Post-Doctoral 

Fellowship at the University of Wisconsin-Madison.

Ryan Hulse, Honeywell 

Dr. Hulse is a Sr. Technical manager in the Fluorine Products division of PMT at Honeywell. In this role he

has global responsibility for launching new solvent and aerosol products. Solstice PF and Solstice 

Propellant have been recently introduced into the market as high performance, safe and 

environmentally preferable alternatives to current solvents and aerosols. A key goal in this role is to 

work with customers to identify and qualify processes for the newly developed low global warming 

potential solvents and aerosols. 

During his time at Honeywell, Dr. Hulse has directed the properties and new applications groups which 

measured the physical properties needed for new product design and process support. He has been 

involved in a variety of projects including new refrigerant development, process design, fumigants, and 

electrolytes for super-capacitors. This work has resulted in 10 US patents and 10+ pending patent 

applications. He continues to evaluate competitive offerings and looks to determine value-added 
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opportunities. Dr. Hulse holds a bachelor of science and Ph.D. in Chemical Engineering from Brigham 

Young University. 

Barbara Kanegsberg, BFK Solutions 

Barbara Kanegsberg, President of BFK Solutions, LLC, is a recognized expert in critical/industrial cleaning 

and contamination control. As an independent consultant, she develops critical cleaning processes, 

resolves product-related regulatory issues, and assures that processes meet worker safety and 

environmental requirements. She works with manufacturers and with their suppliers in such areas as 

engineered coatings, electronics, metals, and optics. Barbara publishes extensively and lectures for 

practicing engineers and manufacturers. She is a co-editor of and contributor to the two-volume 

"Handbook For Critical Cleaning,” CRC Press, 2011. Barbara is active in ASTM and IPC standard/guidance 

development. She is an appointed United States Expert to ISO/TC 209 WG 12: “Cleaning of surfaces to 

achieve defined levels of cleanliness in terms of particle and chemical classifications.” As a member of 

JS3, an interagency military group, she participates in development of non-HAP, low/no VOC standards 

for mission-critical product. Barbara received a U. S. EPA Stratospheric Ozone Protection Award.

Jason Marshall, Toxics Use Reduction Institute (TURI) 

Dr. Marshall directs the services of the Toxics Use Reduction Institute Cleaning Lab. The lab works with 

companies, communities and citizens to evaluate the performance of cleaning chemistries and 

equipment. Recent projects include: promoting the adoption of alternatives to trichloroethylene for 

businesses in Massachusetts and Rhode Island; promoting safer ingredients in cleaning products 

resulting in recognition from EPA’s Safer Detergent Stewardship Initiative at the Champion Level; 

participating member of the Toxics Reduction Task Force Massachusetts Executive Order No. 515 

establishing an Environmental Purchasing Policy to examine specific areas of environmental 

procurement and provide targeted technical assistance and guidance to agencies as needed. 

Jeff Morris, EPA 

Mr. Morris is Deputy Director of the United States Environmental Protection Agency’s Office of Pollution 

Prevention and Toxics, which regulates industrial chemicals under the Toxic Substances Control Act as 

well as administers the Pollution Prevention Act. Mr. Morris has worked as a federal public servant for 

25 years. In his 22-year career at EPA, he has held a number of positions across the agency, including 

serving as acting director of the Office of Science Policy and as a National Program Director for 

Nanotechnology Research.

Michael Muth, Slide Products 

Mr. Muth is President of Slide Products, Inc. Slide Products is a 61-year old, family-owned specialty 

chemical manufacturer located in Wheeling, IL, 30 miles north of Chicago. The company is a chemical 

formulator and aerosol packaging firm that traditionally blends lubricating oils, solvents, and propellant 

gases into their aerosol products. Slide Products transitioned its product line away from TCE and all 

other chlorinated solvents in early 2011.

Manoj Patel, Green Life Development 

Mr. Patel’s exposure to TCE’s started when he ventured in a small dry-cleaning business while still in 

college, which eventually he grew it to a multi store chain. His was the first chain in the state of 

California to use 100% water based cleaning methods as opposed to the industry standard 

perchloroethylene. Subsequently he helped develop the regional guidelines and initiatives to eliminate 

the use of PERC in AVAQMD. These guidelines became the model for other air quality districts 

throughout California. Over the last 17 years, Mr. Patel has been a strategy consultant for various 
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breakthrough technologies and instrumental in developing successful ventures teaming with industry 

leaders from software to green technologies. Today at Green Life Development, his team is developing 

solutions for industry with the objective of decreasing environmental impact and eliminating toxic 

exposure. Green Life Development’s flagship product Naturama, is used as a natural replacement for 

TCE in many applications.

Julia Quint, California Department of Public Health (Retired) 

Dr. Quint is retired from the California Department of Public Health (CDPH) where she was a Research 

Scientist and Chief of the Hazard Evaluation System and Information Service (HESIS), an occupational 

health program. She has a Ph.D. in Biochemistry from the University of Southern California. Throughout 

her career in public health, Julia has initiated, developed, and contributed to projects and policies that 

are focused on protecting workers, communities, and the environment from toxic chemicals, and on 

promoting the development and use of safer alternatives to toxic chemicals. She has served on a 

number of scientific advisory committees, including committees of the National Academy of Sciences 

(NAS) on tetrachloroethylene and health impact assessment and the Cal/OSHA Health Experts Advisory 

Committee. She currently serves on the NAS Committee on Safer Chemical Substitutes, the California 

Department of Toxic Substances Green Ribbon Science Panel, the Scientific Guidance Panel of the 

California Biomonitoring Program, and the CDC/NIOSH World Trade Center Scientific and Technical 

Advisory Committee. Julia has authored many peer-reviewed scientific articles and reports, and is the 

recipient of several awards for her work in public health.

Margaret Sheppard, EPA 

Ms. Sheppard is an Environmental Scientist and team lead for the USEPA’s Significant New Alternatives 

Policy (SNAP) Program. She has been reviewing the health and environmental impacts of alternatives for 

ozone depleting substances since 2000, with specialization in solvent cleaning and aerosols. She has 

worked at EPA since 1990 on a number of issues including protecting the ozone layer, reducing acid rain, 

improving air quality, and assessing risks from radioactive waste and from chemicals in drinking water. 

Ms. Sheppard earned a B.A. in physics from Wesleyan University and an M.S. in Environmental Planning 

and Management from the Johns Hopkins University.

Dan Teitelbaum, EPA 

Mr. Teitelbaum is the Pollution Prevention Staff Lead for the Toxics Release Inventory Program in EPA’s 

Office of Environmental Information. In this role he promotes the collection, dissemination, and use of 

information about environmental performance and effective P2 practices. He joined the EPA as a 

Presidential Management Fellow in 2009 and has also worked in the Sustainability Program for EPA 

Region 2. He holds an MPA in Environmental Science and Policy from Columbia University and a B.A. in 

Economics from Brown University.

Edward Viveiros, Eastern Research Group 

Mr. Viveiros is an environmental consultant with Eastern Research Group, Inc. (ERG), a privately held, 

multidisciplinary consulting company. Over the past six years, he has served as a consultant to EPA, 

performing exposure assessments in support of risk assessments for new and existing chemicals 

management under the Toxic Substances Control Act. His expertise centers on evaluating chemical 

processes and determining how they can lead to environmental releases and worker exposures. 

Recently he supported EPA in the development of the “Options to Protect Workers” guide on 

degreasers, for which he is the primary author. He holds a master’s degree in Chemical Engineering from 

Northeastern University.
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Heidi Wilcox, Toxics Use Reduction Institute (TURI) 

Ms. Wilcox helps run the Toxics Use Reduction Institute Cleaning Lab and is the primary field specialist 

whose work focus is to bridge the gap between the theory of what happens in the laboratory and 

translating the data into the reality of finding something that works in every facility's culture and 

process. One size does not fit all and Ms. Wilcox's passion is on how to find what works as well as the 

easiest way to train and transition companies ensuring TUR implantations are successful. Currently her 

work focus is on the sectors using the MA designated high hazard substances TCE and PCE as well as the 

newly listed nPB. 

Ms. Wilcox is also heavily involved in the Custodial Green Cleaning Industry and sits on many 

committees such as the MA TUR Taskforce to help state agencies comply with EO 515 and adopt green 

cleaning chemicals and technology as well as rebid committees for new interstate purchasing programs. 

Training, demonstrating equipment and new cleaning systems as well as working closely with vendors to

make sure they are servicing and training customers in MA and beyond is also a major part of her work. 

She earned a Bachelor's of Science degree in Microbiology from UMass Amherst, a Master of Science in 

Environmental Studies, Atmospheric Concentration from UMass Lowell and currently is finishing up her 

doctoral work in Cleaner Production / Process Engineering.

Katy Wolf, Institute for Research and Technical Assistance (IRTA) 

Dr. Wolf is director of the Institute for Research and Technical Assistance (IRTA), a nonprofit 

organization established in 1989. IRTA identifies, develops, tests and demonstrates safer alternatives for 

industrial and consumer product applications. IRTA also performs emerging and advanced technology on 

solvent alternatives in cleaning, dry cleaning, electronics, paint stripping, coatings, lubricants, paint 

thinners and adhesives. Over the last 25 years, IRTA’s projects have led to a reduction in the use of 

hazardous substances in California of more than 100 tons per day. Dr. Wolf spent fourteen years at the 

Rand Corporation, where she performed research on alternatives to ozone depleting substances and 

chlorinated solvents. Dr. Wolf has authored more than 200 publications. She has a Ph.D. in Chemical 

Physics.

Wayne Ziegler, U.S. Army Research Laboratory 

Mr. Ziegler is a Materials Engineer at the Army Research Laboratory (ARL). He has over 30 years of

experience in materials property and environmental technology evaluation, failure analysis, and 

materials information management. Mr. Ziegler started his career providing failure analysis support to 

the M1 and HMMWV development programs. As new system development slowed he moved into 

development and evaluation of environmentally preferred products and processes. This focus led to an 

understanding of the importance of materials process and property data in particularly focused on 

restricted materials data. He is currently the project lead for the development of the Army Materials 

Selection & Analysis Tool (MSAT), the Army lead for solvent substitution and co-chair of the Joint Service 

Solvent Substitution Working Group (JS3).