# 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 2 6 , 2014 Workshop Summary D ocket EPA

- HQ

- OPPT

- 2014

- 0327EPA’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 & Backg round Lectures: Use of TCE and P erspectives on A pplication

............. 8 Use of TCE as an A erosol , V apor & C old C leaner

................................ ................................ ............. 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 D iscussion 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

................................ ................................ ................................ . 5 3EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as 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 t he workshop was to develop criteria that potential alternatives to TCE will need to satisfy

. E xpert panelists examined key lessons learned in transitioning from TCE to various alternative s that could he l p inform future substitutions. The sessions looked at general principles and guidelines so that future subst itutions are easier to conduct. P anelists also attempted to create a l ist 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 transcr ipt, 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 (sl ides) , other supporting materials used or referenced by the speakers , and public comments are available on the regulatory docket for the TCE Workshop

. 

## Final TCE R isk Assessment In her welcome address, Wendy Cleland

- Hamnett of EPA noted that t he w orkshop 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 f indings 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 risk s identified from TCE for workers and occupational bystanders at small commercial degreasing facilities and dry cleaning facilities using TCE

- based d egreasers 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 t he 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

.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 iv S olutions for TCE have not yet been identified

. EPA need s 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 genera l 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. R egrettable 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 pr evention 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. S afer alternatives to vapor degreasing using TCE have bee n 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 i f 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 i s to w ork with the company and end users up front to give them ownership of the solution, and then it will be more likely to be implement ed

. Margaret Sheppard of EPA said that u nder 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. T hree a ir p rograms affect solvent choic e h eavily:

 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 c ompounds and a lot are solvents; with heat and sunlight smog can be generate d so EPA has requirements that are delegated to the states throu gh a state implementation plan

. EPA has a model rule to limit th e 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) dis cussed 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 re formulating with HCFCs and TCE due to ozone

- depleting potential greater thanEPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 v 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 stud i es 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 cou ld 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 solv ents and VOC content restrictions.
Steve Bennett of the Consumer Specialty Products Association recommended that i n order to reduce existing exposure, commercial/industrial supply chains should restrict sales , and a label should be prominently displayed t hat 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 inform ation 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 concern s. The c ompany 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 client s ’ business as well.
Jason Marshall’s organiza tion, TURI , created a form called the Lab Test Request Form that includes intro ductory 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 cle aning 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 altern atives 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 encounte red 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.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 vi Astro Pak was able to achieve succ essful 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

. Techniq ue, 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

- f ree chemical d epainting m aterials and p rocesses and HAP

- f ree v apor d egreasing for c ritical w eapon s ystems.
Heidi Wilcox of TURI noted that, w hen working with companies, it is important to understand the client’s point of view. Existing s olvents work for clients and their processes because rinse and dry is not needed, they are readily evaporative, there are no heavy residues, they p rotect against corrosion, rusting, and the process is generally quick. T here is always an alternative to TCE (aqueous, semi

aqueous , media blasting, CO 2 ). There are other options besides substitution including chang ing the process, work ing with the supply chain to have parts or stock come in clean, and buy ing high

- tech, automated machines to reduce hand l ing of parts and exposure to chemicals.
Information on t wo 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

- ag ency coordination and cooperation need to be increased.
Dan Te i telbaum 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 to xic 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 double

stabilized TCE, which increase d 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 Easte rn Research Group (ERG) presented multiple strategies to reduce worker exposure. T echnologies that eliminate or reduce risk from TCE include bake

- off ovens, water

- based cleaning alternatives, low

- solids fluxes , and inert atmosphere soldering. 

## Alternatives E valuations Alternatives are available for all applications as demonstrated by the successful case studies of the panelists. S afer alternatives to vapor degreasing cleaner have been demonstrated (water

- based cleaners) and if TCE is not banned , then TCE us e should be restricted to airless/airtight systems

. In cold cleaning applications , safer alternatives have been demonstrate d. I RTA believes that a erosol solutions can be reformulated with safer alternatives in all cases.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 vii 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 feas ibility of switching to aqueous

- based cleaners had no adverse resu lts. 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 alte rnative 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 custome r 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, wo rkplace 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 solubil ity, 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 risk s to humans.
Is there b uy - 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 h ave to spend, the space that the company has, the management support, the workers ’ andEPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 viii 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 i mportant As illustrated by Slide Products , there may be push

- back from clients until the client can be convinced that a switch to non

- TC E 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 alternat ive with a company and understanding each company’s individual needs is paramount to making a switch. Peer feed back If one company makes the switch, other companies may make a switch as well.
Costs It is i mportant to consider costs other than purchase pri ce of TCE and capital costs . O ther 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 p rotective 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 com pany switches to an alternative, w orker s 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 a ble to make a switch. Also, the DoD and Astro Pak illustrated that military s pecifications pose a challenge because the specifications need to be met on top of any effects that the alternative cleaners may provide.
EPA and i ndustry need to find v iable sub stitutes that do not become regrettable substitutes. If a substitute has no data it should be avoided.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 ix 

### Successes TURI and IRTA found that companies were more likely to make a switch to an alternative to TCE if they p ilot ed t he 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 risk s of TCE and benefits of the alternatives, then they were also more likely to make a switch. Multiple phase

- out s 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 i s to characterize performance needs such as required leve l of cleanliness and throughput. Mr. Ziegler suggested defining performance based on industrial workflow and find ing 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 learnin g 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 o n
- site visits to facilities to aid them in transition s are helpful . The work should be done on

- site so that any questions or concerns by the vendor can be addressed immediately. An i mplementation 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 an d 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 cyc l e analysis for all substitutes

 Regulat ory options to restrict TCE use

 Revaluating the PELs a nd RELs to be more protective

 Developing outreach materials and materials for the user community to help the m switch to viable alternatives

 Ri sk reduction processes through engineering controls.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 x This page left blank intentionally.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 1 

# 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 r eduction 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 a n 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

, A merican A ssociation for the A dvancement of S cience, 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) B ackground 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
w orkshop fits into larger efforts of TCE risk reduction. In 2009 EPA and the Administration remarked that the 1986 TSCA r egulations may not be up to the task of ensuring chemical safety in the 21 st 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 chemica ls to address. EPA is dedicated to a more transparent and systematic approach t o risk management under TSCA. EPA has
c onsulted 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 i dentified risks for certain uses of TCE including TCE use in degreasers. When the risk assessment program started, EPA wanted to activel y try to reduce risk

. EPA is h oping for voluntary use reductions

. EPA will also be pursuing other ways to ensure risk reduction

. Th e final risk assessment of TCE shows significant risk

.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 2 

## 9:05

– 9:20 AM: Findings from the TCE Risk Assessment Tala Henry, EPA OPPT Dr. Henry presented an o verview of the Final TSCA Workplan Chemical Risk Assessment of TCE ( CASRN 79

- 01

- 6 )

. The Risk Assessment focuse s on TCE use d in degreasing operations and the products used for degreasing. The TCE Risk Assessment covers commerci al 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 deg reasers 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 a re 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 t o 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
a s 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 expos ure
. 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

. ( S ee slide number 5 of Dr. Henry’s visuals ). Dr. Henry examined s everal 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 ai r 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 dat a from 2011 TRI but scale air releases by 2x; this captures downward trends ; 3. Estimating facility and op erating parameters 1. Use data from the 2008 NEI to estimate a) Number of large/small facilities b) Number of degreasing units (machines) at large/sm all 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;EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 3

4. Estimating TCE emissions potentia lly 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 I nhalation 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 c omprehensive 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 reproduct ive organs and devel oping 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 a ssessed 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 c hronic 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 w ithout 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 residen tial 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.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 4 

## 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

. S olutions for TCE hav e not yet been identified

. EPA need s 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 red uction. 

## 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 h uman 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 k now publicly

. QRAs are used to develop per missible exposure limits (PEL s ) 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 1,00 0 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 rec ommendations. 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 work place and the Legislature wanted to make sure this did n o t 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

. Th e legislature also r ecommend s protective standards and issues “early warnings” on new/unrecognized hazards.
Cal OSHA has no toxicologists but they use the California EPA’s O ffice of E nvironmental Health Hazard A ssessment (OEHHA)

. OEHHA develops and recomme nds 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 li st 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:EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 5

 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 Pro p 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 Haz ard Risk Assessment found that Q RAs should be applied t o the workplace and that using Q RAs 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 ha ve 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 wor kplace 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 diffic ult. 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

. Quin t 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 othe r 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 n o t have unsati sfactory solvents mixed in.
1

- br o mopropane 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 en vironment 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 demonstra ted to be efficacious and cost

effective 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 t he Toxi cs Use Reduction Institute (TURI) researches, tests , and promotes pollution prevention and alternatives to toxic chemicals used in Massachuse tts industries andEPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 6 communities. The lab Dr. Marshall works in has been open since 1993 and has worked with many
com panies on TCE and o ther hazardous chemicals

. His lab works to develop and promote safer alternatives to hazardous solvents and conducts process

specific testing

. His lab assists industry in the search for safe cleaning processes and does so with outreach, on
- site walk through s , 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

. ( P rior to 2007, 33% of the companies fully adopt ed the lab’s recommendations and in the next two years, near ly 80% of the companies TURI worked with adopted the lab’s recommendations.
Dr. Marshall worked with EPA R egion 1 i n 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 use d 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 intro ductory 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 (soi ls)?

 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 t he 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 su rfaces 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 i s hard to figure out what is out there and what will work for each c ompany
. 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: cleanersol utions.org . TURI compare s results on the website

. Phase 2 is the first lab testing evaluation and uses basic operating conditions, coupons matching part substrate, supplied contaminants , and compar isons with current solvents if possible. The first two stag es are based on initial safety screening. Phase 3 is introducing a process. There is an advanced lab evaluation of al ternatives and TURI uses client

- specific operating conditions. TURI compares the new alternative with the current solvent if possible and d etermines if there are any health risks that the screening does not address. In Phase 4 ofEPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 7 Testing an Alternative, TURI conducts a pilot cl eaning in a lab setting. Client

- specific operating conditions and client supplied parts are used. If possible, TURI w ill 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 TU RI 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 pub lic 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.
Indus try sectors that TURI has worked with include aircraft vendors, capacitor m anu f actu r ers , jewelry vendors, plating & metal working companies, semiconduc tor/electronics companies, tool vendors, wire & cable companies , and general manufacturers

. The many type s of alternatives TURI has found are alcoh ol 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.

P erformance, health & environment , and cost should be considered when selecting an alternative option

. An EHS a ssessment should be conducted that includes safety screen scores, a comprehensive evaluation , and green certifications. The comprehensive evaluati on 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 quanti tative 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 ocula r 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

. A lternatives 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: W hat is the cos t involve d 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 t he work is also done at
a u niversity , they can maintain low labor costs

.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 8 

## 10:30 AM: Session 1: Keynote & Backg round Lectures: Use of TCE and P erspectives on A pplication Chair: Doug Parsons, OPPT, EPA Each presentation in this session will address the fol lowing 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 degreas er 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 A erosol , V apor & C old C leaner Katy Wolf, Institute for Research and Technical Assistance (IRTA) Safer Alternatives to Trichloroethylene in Vapor Degreasing, Cold Cleaning and Aerosol Applications: The California Experien ce 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 us ed. 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 n o flash point of TCE , which has always been a marketing point because it can be heat ed 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 , an d has a high evaporation rate. 

### Vapor Degreasing: TCE s olvent is heated to its boi ling 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
ca rries the contaminants into the liquid so that the user is always cle aning 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 clean ing is used , and cold cleaning is often in an open tank or remote reservoir . There are n o 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.


### A erosol Products: Aerosol products were u sually used as a carrier solvent or clean ing 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. Aer osol cans generally used a propellant.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 9 

### IRTA Approach to Safer Altern atives IRTA works with several companies; identifies products (alternatives) on the market; once the company has satisfactory alternatives and consumers accept them, they approach a regu latory agency to adopt/implement a regulation

. This has l ed 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 H istory 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 wer e 3000 vapor degr easers 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 regulat ions 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 specif ically limiting TCE Use in Applications of Interest SCA Q MD regulations set 25 gram s 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

– Vapo r 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 c onveyor water

based 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
c ompany 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 d ifferent water

- based cleaning systems based on the company’s specific needs

. 

### Cold Cleaning Case Studies IRTA conducted EPA

- sponsored projects to f ind 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 i s 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. OverEPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 10 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 w orked with a number of aerospace sub contractors 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 devic e 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 VOC s 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 cleane rs, 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 c ould 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 solve nts and is not a VOC , so it was a good solution.
IRTA worked with an automotive dealershi p to switch to water

- based br ak e 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 chlorina ted solvents to carbon dioxide pellet blasting/snow

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


### Conclusion : IRTA b elieves 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 manuf acturer 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 saf er alternatives in all cases.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as 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 solu tions from a pollution prevention standpoint

. In terms of v apor degreasing , the lab needs to make sure when they develop alternatives to vapor degreasing cleaning applications that the solution does n o t have an impact on productivity and throughp u t

. The a rmy 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 vi sual 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 als o 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 protec tive 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 us ing 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 th at reduces workers ’ need to wear as much PPE ), and monitoring the equipment and process. Replacing TCE i n vapor degreasers is done by qualifying alternative chemistry, modifying equipment as required , and adapting work flows.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 12 Lastly, to reduce TCE exposure, a company could replace the vapor degreasing workflow

. However, this may not be possible without a ca pital investment

. Adapting a workflow is a significant challenge upfront and would need to be addressed/mitigated

. Mr. Ziegler’s lab l ooks 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 E valuating Processes When evaluating TCE risk reduction, it is important to acknowledge that all cleaning applications are not equivalent and on e should n ot try to replace all vapor degreasing process es 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 eva luating processes should be on capabil ity and cost. Ask the question “ How clean is clean? ” W hen possible, f igure out a work plan that eliminates th e cleaning process completely. 

### Keys to Success: Mr. Ziegler’s advice for success:

 Define performance ba sed o n your industrial workflow

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

 Focus on how to solve the problem

 W ork with the company/user upfront and work with the end users upfront to give them
owne rship of the solution , and the n it will be more likely that t hey will implement it. 

## 11:30

– 11:45 AM: Regulatory Landscape for TCE in Federal and State Air Programs Margaret Shep p ard, 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 Poli cy (SNAP) program that reviews alternatives.

T hree a ir p rograms affect solvent choice h eavily:

 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 throu gh a state implementation plan
EPA has a m odel 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 ozone

depleting 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 regist erEPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 13 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 ex empted 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 ac ceptable 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 Pol lutants (NESHAP). See presentation for a visual of the classes of solvent alternatives. Classes include: “no

- clean” technology; oxygenated solvents; bro minated solvents; HFCs & HFEs; h ydrocarbons, terpenes; chlorinated solvents; semi

- aqueous cleaning; and aqueous cleaning. 

### SNAP Program The SNAP program sets up broad categorie s 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 dire cts 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 environmenta l and health impacts and looks at exposure in different uses like usin g 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 chem icals (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 potentia lly 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 rul es 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 (cleanin g) ; and HFE

- 347pcf2 (cleaning, aerosols) . Current solvents under review are HFO, CFO, and HFC. New chemicals are also reviewed by the New Chemicals Program.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 14 

## 11:45 AM

– 12:00 PM: Overview of Regulations in California on Solvent Degreasers David Edwards

, P h.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 a nd 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 we re 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 ho usehold and institutional consumers. The types of products can include cleaning products, ae rosol paints, antiperspirants and deodorants, household pesticides, personal care products , and automotive specialty products.


### Consumer Produc ts 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 manuf acture r s 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

.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 15 

## 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 fr om 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 co mmon 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 wh y 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 chemi cals 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, c ase 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 ap plicable 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 i nform future decision making? 

## 1:10

– 2:50 PM: Session 2: Aerosols and Cold Cleaning Panel Chair: Eileen Sheehan, EPA Region 9 Rapp orteur: Kath e rine 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.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 16 

### 1. Identification of Less Toxic TCE Alternatives in Aut omotive/Electronic Applications Katy Wolf , IRTA Cold cleaning applications are either r epair and maintenance or batch and a re used in various ways. Usu ally IRTA work s on generic problems to solve a problem as a group. Dr. Wolf t ries 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 so lvents 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 h ands but hot enough to clean. Some industrial cleaning process es require 140 degrees Fahrenheit , which in turn requires PPE. IRT A fo und that a 20 to 25% concentrate water

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

. IRTA f ound that acetone is an effective handwipe solvent and is lower in t oxicity th a n 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 alterna tives to be able to regulate the product. In other words, California can regulate certain chemicals, but it cannot ban aerosol s as a whole. IRT A worked on a project that involved working on four different applications including brake cleaning, general purpose degreasing, carburetor and fuel inject ion 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 degrea sing 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 a nd soy and packaged it in aerosol cans.
In aerosol s for e ngine degreasing , detailers routinely use water

- based cleaning systems and high

pressure water systems

. W ater

- based cleaners in spray bottles can also be used. IRTA tested alternative propellants an d found that nitrogen oxide did not work. IRTA found that carbon dioxide was a very good high

- pressure propellant and was low er 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. I n 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 sheet s for info rmation when determining alternatives. There are other degreasing formulations for aerosol applications and perhaps other alternatives

. There are m any other chemicals that are safer than TCE to use in aerosol formulations that can be used for degreasing.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 17 

### 2. Balancing Functionality with Efficacy Steve Bennett, Consumer Specialty Products Association (CSPA) 

### Information Nee ds CSPA supports more robust reporting of chemical uses under TSCA. Under EPA’s work plan goals, information needs include identifying po tential 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
ac tivities and clarify safety considerations (critical uses)

. Information n eeds 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 specif ic area s of interest

. The risk assessment should include
w hat 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 comme rcial settings, i.e., small shops. TCE characteristics include non
- f lammability and effectiveness. Therefore flammable alternatives that may cause fire or explosive hazards and water

based alternatives that may cause electrical hazards need to be assessed for effective ness
. 

### 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 sa ys “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 w ith 15 employees. The company is a
c hemical formul ator 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 20 11, the company u se d 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 ar e p lastic 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 u sed chlorinated substances because they had great solvency and evaporated quickly.
The c hange 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 w orked with their customers to figure out what could potentially work as an alternative . ThenEPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 18 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 challenge d 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 flammab i l ity

. Slide Products f ielded a large volume of emails with customer complaints that the new aerosol cans were t oo lig ht

. The weight of the new product d ropped in half because the new solvent was less dense then the original solvent. Mr. Muth h ad to explain to customers that lighter did not equate to less solvent. One analogy that worked for his firm was to compare the li ghter 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 th ey 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 smart er and saf er sol ution 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 s ells to the US and internationally

. There are more b usines s opportunities for Slide Products because of the lack of TCE in the product line

. 

### 4. E xperiences in Evaluating Cold C leaning A lternatives 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 ap plied 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 ne wly 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, pol ish, c lean 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.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 19 T he client’s parts were made from a wide range of materials including alumina nitride, alumina, fuse d 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 sup plied , so that the vendor would be able to compare the pilot

- cleaned parts with their orig inal cleaning process.


### Outcome: T he 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 systemat ic 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 i dentify 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 Aqueou s Cleaners Brent Ekstrand, Astro P ak 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 n o t 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 customer s to update their specifications if Astro Pak detects a better alternative

. In the 1990s , Astro Pak O wner 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
m ade the switch away from solvents as a class to stay ahead of changing solvent regulations.
Astro Pak n eeded to be able to convince cu stomer s to use aqueous cleaning because Mr. Verheyen realized that it was a smart long

- term business to switch to aqueous due to lower c hemical 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 condu cted 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 customersEPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 20 and problem contaminants as well)

. Astro Pak then selected a general clea ning ag ent and selected a large, three

- tank ultras onic cleaning system, drying oven, and upgraded deionized water system as the alternative

. In precision cleaning the deionized water matters so Astro Pak had to upgrad e 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 tech nique

- 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 ar e 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 criti cal 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 alter natives for dry cleaning in industrial processes?
Answer by Dr. Katy Wolf

, IRTA : IRTA is f iguring out alternative methods and that is the equivalent for generating utilities and transmission li nes and if it isn’t very dirty and if you are just moving particulate s 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 pro duc ts are very expensive as well. Every thi ng but halogenated solvents has a flash point, so you have to move to other things that have fla sh points if you are going to use solvent cleaning

. Question for Brent E

kstrand by a udience m ember: The question is a bout the careful technique . I s it precision of the technique or more time or a combination of both?
Answer by Brent E

k strand, Astro Pak: You h ave to make sure that temperature s are measured to a narrower band than you do with solvents . Y ou have to make s ure exposure times are adhered to and proper application of ultrasonics

. Y ou have to make sure you are cleaning properly

— make sure power settings are correct, exposure times are monitored correctly , etc

. W ith aqueous technologies you can no t 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

.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 21 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 q uestions of cost perf ormance, cost of investing in equipment, and any other criteria that EPA should keep in mind.
Answer by Brent Ekstrand , Astro Pak : There are c riteria for the performance of the cleaner such as non

- foaming aerosols or performance as a clean er (post contami nation levels)

. T here is cleaning an d precision cleaning and measuring post

- cleaning residue and particulat e levels in precision cleaning as well as particle coun t to get particle distribution and details for different particle levels.
Answer by Dr. Katy Wolf

, IRTA : G ross cleaning oper ations that are not precision

- based and water

- based clea ning systems are pretty simple and you do n o t have to worry about as much with systems that do n o t ne ed precision cleaning. W hen you adopt alternative methods of cleani ng you have to start from scratch and look at total organic carbon measurements

. I f 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 loo k at things with an open mind

. Companies c an often clean better with alternatives

. Answer by Michael Muth, Slide Products : EPA should look at processes and examine efficiency and productivity

. C ustomers generally do
n o t 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 m ind 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, t he 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, Co nsumer 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 companie s/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 militar y 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 tow ard qualifying a specific task and when something expires, you should be able to test it and show that you can use something else

.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 22

A nswer 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 t hat they need to keep using it

. R evising documents is a long process but it needs to be done. Companies say that they are not usi ng TCE but there is a possibility that they still may be using it

. Government specs are par t of the solution and problem. Question from Mich ael Parta in : Mr. Parta in 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 an d there is vapor intr usion

. W hat is being done to look at the true costs of the alte rnatives (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 life

cycle cost analysis, so hardly anyone doe s
. A life

- c ycle 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 know n at the time. It all depends on the appl ication and what the company is doing.
Answer by Steve Bennett, Consumer Specialty Products Association: A ll stakeholders should be able to h ave their viewpoints out there and should be able to disseminate as much information as possible so that users an d customers can be directed to appropriate products

. Question from Pat Rizzuto : H ow critical is it that they had people working with the company t o do facility

- specific work because the re are so many small businesses?
Answer by Maria Doa, EPA : T his ex pert 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 alternative s. EPA is cautious of moving forward as EPA does not want to move to a different solvent that may not be a good alternative

. D ifferent folks approach the problem differently as well.
Q uestion 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 non
chemical technologies t hat can be used as alte rnatives.
Comment from Maria Doa, EPA : Part of what is noteworthy is the different way that companies have approached issues. M r. Muth did not do precision cleaning. Mr. Marshall had a matrix approach

. There is an overlap of factors that the different c ompanies have used.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 23

Answer by Michael Muth, Slide Products : A major concern from the customer’s perspective is the need to remove oil

- based contaminants. C ustomers needed to know if new solutions would produ ce 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 fl ames in their manufacturing process were identified as being problematic when using the new product

. Comment from a udience member: It is a matter of efficie ncy for industry and companies. Question from Doug P arsons, EPA: H ow can EPA get information to sm all business es who still use TCE?
A nswer 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 ye ar 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 th e 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 rem ediate 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. E k strand encourages EPA that risk for the company should be part of the assessment.
Answer by Dr. Katy Wolf

, IRTA : D r. Wolf is a strong supporter of regulation , because people in facilities are concerned with compliance. I f you let people voluntari ly choose to switch chemicals, not as many people would switch , compared to the number who would switch if it is banned. A w ay 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 : C ompetitors are still marketing that they are offering TCE products and saying that th e non
- TCE products are weaker

. His company need s to market the health concerns.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 24

Answer by Brent Ekstrand, Astro Pak : The aerospace industry is a niche industry with competitors and hi s 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 econo mic value

. I n a competitive market people think carefully before the y 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 i s 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

. V oluntary efforts are cheaper than efforts due to reg ulatory 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: I s there less sick leave due to a switch to a safer alternative , and has anything lowered corporate insurance cost and employment for occ upational 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 n o t 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 no t 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 address ed issues related to the use of TCE in vapor degreasing applications in small commercial settings.
Potential Outcomes: 1) List of criteria t hat 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 m ade 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 t o TCE as a vapor degreaser.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 25 

### 1. Transitioning from TCE in Vapor Degreasing Applications at Military F acilities Wayne Ziegler, U.S. Army Research Laboratory How alternatives are implemented (methodology) is critical

. L ots of great work may n o t go anywhere because there is no focus on implementation. JS3 worked with the Anniston Army De pot (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 g oal was to go to H AP

- Free chemical depaintin g and HAP

- free vapor degreasing. EPA proposed Residual Ris k 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. Curren t 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 ide ntify and downselect alter n ative degreasing/cleaning technologies for three applications of interest to ANAD

. Then JS3 needed to conduct bench

- scale testing on downselected alternatives

. U p to two select ed technologies would undergo full

- scale testing at A NAD. 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 ul trasonics system performed well.
JS 3 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 compan ie s ’ cultures and needs. TURI takes the lab “to the streets” and works with companies first hand. When TURI is contacted by a c ompany 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 datab ase 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

. C utting edge technology does n o t matter if we do n o t get implementation from customers.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 26 

### Reality of the substitution The reality of TCE is that it has great solvency and cost is relatively low. TCE does n o t 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

. C ustomers 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 p e rspective. 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 i s 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 n o t there it will be hard to make a switch), the space that the company has, the management suppor t (if it is there or not), the workers ’ and clients’ needs , and how much testing is required for the client. G auge the corporate backing to understand if the company leaders are able to make the switch. Additionally, there needs to be worker

buy 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 (aque ous, semi

- aqueous , media blasting, CO 2 ). There are other options beside s 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 hand l ing of parts and exposure to chemicals. 

### 3. Alternati ve 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 s olvent 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, n

bromopropane (nPB), Stoddard Solvents, Vertrel , and Ak 225

.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 27 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 m easure 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 n o 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, fla shpoint, 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 Potent ial (GWP100) is 1 for Solstice PF compared t o 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 i n 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 bearing s. However, Solstice PF has a dditional 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 a n 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 eff ects 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 mor e harmful to the environment tha n the oil that they are meant to eliminate.


### Demonstration Mr. Patel demonstrated his product, Naturama, to the workshop participants by setting up two beakers. O ne 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.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 28 The produc t is non

- toxic and bio

- degradable and “safer than toothpaste” since it is made from botanical & mineral extra cts. 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 Technolog y 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 affect ed 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 thro ugh 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 N aturama instead

. In another case, the company found that one 28 oz. bottle of N aturama does the work of over 12 cans of aerosol

- based cleaners

. Naturama is non

- toxic, non

- ionic, non

- caustic, non

flammable, ozone

- safe , and has no CFCs.
Industries like auto motive repair, manufacturing, rail, and marine oil drilling could use Naturama to clean

. The product is more cost

- effective and reduces enviro nmental impact because Naturama

- based products can be used over and over again for cleaning. 

### 5. Process Based Ris k Reduction for Cleaning Bar bara 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 trie s 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 criti cal cleaning happens in small and large companies

. The c leaning 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 chemi cal 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.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 29 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 comp any 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 t he supply chain is becoming more complex. Manufacturers need effective degreasing tools

. T echnical manufacturing challenges include complex electronics, miniature products, 3D printing, high value products (medical, military, aeronautics), increased product lifetime expectation (e

. g. , i mplantable medical devices), and soils that are difficult t o remove. There is no such thing as a “one

- size fits all” cleaning solution

. Processes that are needed are aqueous

based processes, organic solvent

- based processes, and biobased processes. Some cleaning situations require an aggressive solvent because m an y 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 TCE

like 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 o f 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 age nts 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 l imit ed success are often not reported

. Experimental failures are less likely to be published. Limitations of success include costs, cleaning efficacy, process reliability, energy usage , an d actual implementation.
For instan ce, at a conference Ms. Kanegsbe rg attended, there was a presentation about the success of an aqueous in

- line system , but once Ms. Kanegsbe rg 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. Kane gsbe rg visited the faci lity she found that a very high

pressure system w as 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.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 30 An alternative th at 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.
Divers ity 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 n o t work because it is
never
- ending and not sustainable. Competitive manufacturin g 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, co ntainment , and product safety. Ms. Kanegsberg suggests that inter

- agency coordination and cooper ation need to be increased. Inter

- agency coordination will be more effective in finding alternatives and will conserve governmental resources. A joint effort wi ll 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 R elease 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 facil ities, 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 informat ion (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. Her e 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 degre asers to improve efficiency and later eliminated TCE by switching to aqueous degreasing.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 31 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 change

outs 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 P 2 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 wer e 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 th e facilities to report trends.

T here 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 t ool: 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 f acility 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 : Q uestion 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? H ow did you test the efficacy?
Answer by Wayne Ziegler, DoD : The DoD conducted a literature review , worked with the working group , and spoke with compani es to figure out their needs. The literature review identified substances and shows customer s
. There was an economics aspect about the testing and what was economically feasible

. In engineering the company has to have an under standing of their own process. JS3 evaluat ed which substance was most successful out of the ones determined in the literature report

. Question from Maria Doa, EPA : C ost, health , time, safety , and performance are determining factors for selecting an alternative. C an 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?EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 32

Answer by Heidi Wilcox, TURI: When working with a company, factors come out upfront as well as what factors affect the
co mpany. 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. U se database and screening tool s to figure out what a company needs

. For example, i f VOC is an issue because of air permit s , metric s 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 h as the lowest possible toxicity but the chemical does
n o t perform , then it means nothing

. C ost 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 : I f you have EHS problem

— people can articulate that immediately

— a cleaning issue is harder for people to articulate

— in that situation you shou ld watch the process/production.
Answer by Wayne Ziegler, DoD : W hat 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 y ou figure out t otal ownership.
A nswe r by Barbara K

anegsberg

, BFK Solutions LLC

: There is no substitute for sitting d own and talking with customer. H ow do we get the regulatory community involved in a productive way? When Margaret S h eppard first joined the EPA, she conduc ted 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: W hat are some of the tools and business cases ( P2 cases ) of how people have shifted th eir processes? Do you think that when people see similar companies make the switch , the ir companies will make the switch as well ?
Answer by Heidi Wilcox, TURI: Y es, 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 work s hard to keep database running

. L earning from each other (other companies) is huge and peer
- to

- peer contact is invaluable

. Hold ing a conference for peer

to

- 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 f ocus of this type of workshop is understanding the tools and strategies using work er exposure. There are m e asures other than substitution for moving from TCE to a nother chemical. Are there any reactions to other methods besides that?EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 33

Answer by Wayne Ziegler, DoD: JS3 tries to understand what cleaning processes comp anies 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: S ometimes people are ov er
- 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. S ometimes the re 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. E very once in a while y ou can go through the supply chain and switch from one aqueous to another aqueous

. Question from Jennifer Sass, NRDC : D o you have statistics or numbers of what the market penetra tion is of the alternatives ? There was discussion that CA is a leader and other markets have moved a way 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: W hat 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 T CE cleaners the h old out companies , and what percen tages are hold out companies?
Answer by Heidi Wilcox, TURI : T hat 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 dru m 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
co mpanies are on the cutting edge and some are forced to switch due to community outreach

. Question from Jennifer S ass , NRDC: I f 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 an d the cleaning operations?
Answer by Heidi Wilcox, TURI: Maybe more than 10%. Question from Paul John, NY State DEC Region 2: I s anyone evaluating manufacturing using 3D printing and robots in a sealed environment?EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 34

Answer by Barbara Kanegsberg, BFK Solutions, LLC: Y ou 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

. O ne of the issues with metal parts is : does it require s 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 lo oking at how 3D printing works. We can say that there are mostly p articles but add to that manufacturing and manufacturing has its own challenges.
Answer by Wayne Ziegler, DoD: A dditive manufacturing is so diverse and complex that they have n o t really defined their process , so no one is really addressing that i n any org anized manner

. 

## 4:30

– 5:00 PM: Public Comment Paul Lewis, EPA, opene d the public comment period. P ublic 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 L ejeune 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
cor relation 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 acro ss 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 mov es to protect the public good then EPA transforms into an inept agency. P rotecting the public health is important and Mr. Partain fully expect s that any action by EPA can be countered by the National Academies of S cience

. The exposures at the base and the diseases were said to have a limited link

. News of a contract dissolved this limited l ink. Honeywell oversaw peer review comments and comments were not addressed

. The NRC report on C amp L ejeune was supported by actual science

. I n two reports released this year NRC found health effects from TCE that correspond s with what EPA addressed in the risk assessment. TCE
was heavily used as a degreaser at C amp Lejeune and exposures were through drinking water, vapor intrusion , and open air vats . At the camp, the chemical was used to clea n personal weapons and barrels. EPA cannot do its jo b 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 har mful effects

. Often industry comments on TCE day in and day out but it is not often that EPA hear s 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.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 35 

### Public Comment by Dr. Richard (Rick) Reiss, Exponent: Dr. Reiss reviewed the exposure assessment and risk assessment

. His report ha s been submitted to the docket. His overall conclusion is that the exposure assessment is inadequate to make exposure evaluations

. EPA made assump tions about the number of small f acilities using degreasers and there are significant uncertainties in the exposure assessment and a lack of assumption s to evaluate the calculations

. I n the absence of actual em ission numbers, EPA estimated them instead.
Th e 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 i n 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 h ealth risk from TCE exposure
. The developmental effects were the most concerning

. Ms. Sass thinks that based on t he 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 s afer alternatives that are being used and applied

. NRDC believes that there is no excuse to use TCE anymore.
NRDC is a lso 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 d elayed in banning TCE

. There are h old out 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 v ery 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 u nsafe exposures. 

### Closing Remarks : Paul Lewis, EPA. The discussion was informative and interactive and EPA is looking forward to continuing discussion tomorrow.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 36 

# Wednesday, July 30, 2014

8:30

– 9:00 AM: Welcoming Remarks
Brad Good win

, 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 expos ure 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 risk s 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 inh alation (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 reducti on 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 documen t 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 th e typical commercial settings (for targeted communication of r isk reduction options) and addresses who are the shops using TCE and the technologies that can be use d 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, col d cleaning , a nd vapor degreasing. 

### Spot Cleaning In spot cleaning, c omponents 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 an d 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.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 37 

### Vapor Degreasing: A vapor degreaser is boile d 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, fabrica tion 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. A t 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.
Th e document does n o t 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 elim inate or reduce risks from TCE include PPE, workplace practices, engineering controls, substitution , and elimination. F or 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 t he 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 mos t suitable option.
A bake

- off oven can pr oduce 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 wi thstand 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 fo llowing 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 l eave 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 case

specific 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 emi ssions 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 con trol options for preventing direct contact with TCE are limited to ventilation.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 38 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 T CE vapors when they swing closed), covering solvent baths with a 2

- to

- 4

- in ch 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 generat e 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 feasib le, 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 risk s 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 mann er 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 coveral ls 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 respirator s do not protect against TCE

. One c ontractor was found to be using dust masks to protect workers from v apor but the masks do not protect against vapor. 

### Questions and Discussion about Strat egies to Reduce Worker Exposure: Question from Dou g P arsons, EPA , to Edward Viveiros, ERG : W hen you are surveying people in the field, were there practices that people w ere implementing more often than not , and what are the common practices that you saw currently?
Answer by Edward V

iveiros, 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 degr easers and cold cleaning above 2 gallons. D o these go beyond those requirements or is it the same info rmation found in the requirements ?EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 39

Answer by Edward Viveiros, ERG: It is around the same type of advice.
Question from Juli a Quint

, California Department of Public Health (Retired) : R ight now the permissible exposure limits for TCE are quite high and one of the health effects of conc ern is developmental toxicity and pregnancy

. S ome exposures could happen very rapidly or in an acute
manner
. W hen you are talking about options, are the local exhaust systems capable o f 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 ? Yo u really need a policy in the workplace to protect against that population

. A nsw er by Edward Viveiros, ERG: The broad perspecti ve is that ventilation needs to be provided but the document does n o t list how to get to that level. The doc ument is a description o f 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 c ontrols 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 E PA 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 n o t 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. D id 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, Du P ont 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 a nd risk reduction strategies that EPA can take and understanding and characterizing risk.
Questi on from Doug Parsons, EPA: W h en you look at TCE products, there are a lot of diff erent labels on products. Did you compare the labels to wha t people are using in the field?EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 40

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 doc ument and whether it represents reality. EPA would like to know whether the doc ument is implementable , and EPA is happy to hear public comment s on the doc ument.
Answer by Manoj Patel, Green Life Development, Inc.: There is confusion between California levels and fed eral 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)

. C ompani es want to substit ute methods.
Answer by Christina Franz, American Chemistry Council: I n 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 mad e?
Answer by Edward Viveiros, ERG: A ll 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 re spiratory p rotection, PPE , and eye washes. Comment by Eileen Sheehan , EPA Region 9 

### : The doc ument does n o t reflect input from yesterday at the conf erence and does n o t reflect the substit utions that Julia Quint brought up. Comment by Doug Parsons, EPA : T his doc ument focused on exposure and risk reduction

. 

## 10:00

– 10:30 AM: Discussion and Conclusions from Sessions 2 and 3 Chair: Maria J. Doa, O PPT, EPA The potential outcomes of Sessions 2 and 3 were to create a l ist 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 T his session addressed issues related to the use of TCE in aerosol form and cold cleaning in both small
co mmercial and consumer settings

. There were case studies on the use of aqueous cleaners andEPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 41 presentations by Slide Products, Astro P ak, TURI, and IRTA

. A lternatives evaluations and transitioning
a way from TCE in vapor degreasing were discussed

. 

### Factors to consider In the sessions there was s ome 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 need s 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 man agement. 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 i nput of hands

- on user s is necessary as well. Peer feed back is extrem ely 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 r ecord keeping and ad ministrative costs

 There are PPE requirements , and some workers do not like to use PPE

 Proper w aste disposal needs to occur

 TCE use i ncrease s the risk of inhalation exposure

 There are p otential acute and chronic exposure effects

 TCE is s ubject 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 show cased successes. Examples include d piloting the potential product with users and receiving positive feedback and cases showing how educating customers is he lpful to getting the customer on board with a switch away from TCE. Companies may make switches through intermediate steps (i

. e ., movi ng 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 i mplementation plan in place t o assist a company to make a switch

. There was also feedback on how to m ake the ERG draft report more useful and putting into context the substitutes and look ing at vulnerable populations. EPA appreciates any comments

.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 42 

### Final Discussion Question from Maria Doa, EPA, to Audience: Are there a ny 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 bu sinesses have already shifted

. Ms. Sheehan would like to clarify in the section called les sons learned that a lot of businesses have already shifted for a variety of reasons and not just in California whe re they are required to

. Another point to captur e under “ Why N ot TCE ” is that the one thing missing is the liability and life cycle of TCE , which is what has pro mpted a lot of people to shift away from TCE. A lot of parties have already had to pay the cos t of superfund clean ups and have paid the price

. Comment from Maria Doa, EPA: EPA would like to look at how companies have reported in the past , what sect ors 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 a nd 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 n o t acknowledge this

. Comment from Julia Quint, California Department of Public Health (Retired) : A lot of this is about workers in the particular app lications , 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 variet y of users to make more us eful. EPA will continue to work across t he agency and sister agencies. 

## 10:30

– 11:00 AM: Public Comment Introductions by Loraine Passe from EPA

. Introductions to the public comment period.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 43 

### Public Comment by Christina Franz, Senior D irector of T echnical A ffairs , American Chemistry C ouncil ACC member companies do not sell TCE into the use applications that were the f ocus of the TCE use risk assessment

. ACC members sell into pla ces where it is well regulated

. A fter listening to the presentations and discussions, thoughts and observations, the ACC supp orts EPA’s effort to ward reduction and the supporting m odel of continuous improvement and refinements of EPA’s risk assessment. The ACC want s to work with EPA to refine the risk assessme nt. 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 . Alt ernatives not the only thing that should be considered . There is n o one
- size

- fits

all fix

. The industries impacted should be fully engaged so that their busi ness 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 eve ryone for attending the workshop and appreciates the experts for sharing their knowledge and experience

.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 44 This page left blank intentionallyEPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 45 

## 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 (3 rd 

### 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 safe r 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 use s 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 work shop will examine the following uses:EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 46 

###  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 Us e 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 Dou glas 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

- for

trichloroethylene

- tce

- tickets

- 11540137863EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 47 

## Conference Agenda All events are in the Rachel Carson Green Room, William Jefferson Clinton South Building (3 rd 

## 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 BreakEPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 48



### 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, EPAEPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 49



### 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 th ere 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 e nvironmental/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?EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 50



### 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 alter natives 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. Experien ces in evaluating cold cleaning alternatives to TCE, successes and failures, Jason Marshall, TURI 5. Case studies on use of aqueous cleaners, Brent Ekstrand, Astro P ak
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 ge neralizations 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 t hat can be used to reduce exposure to TCE. 2:50

– 3:00 BreakEPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 51



### 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, Departme nt 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 Ove rview of P2 reporting, Dan Teit e l baum, 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 characteristic s, 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 1EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 52 

## 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, O PPT, 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 reductio n 12:00 Adjourn WorkshopEPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 53 

## 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 c hemistry 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 industr y 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 p ositions.
Prior to re

- joining OPPT, Ms. Cleland

- Hamnett served as the Depu ty 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
o f 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 a ccessibility 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 Stati stics (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 Specia l 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 Certif ications 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 majorEPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 54 industrial sectors in the Sta te 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 Princ eton 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. Ek strand 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 bio

pharmaceutical projects. He served on an advisory panel, comprised of industry leaders and NASA personnel, that spear headed 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 th e 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 Henr y , 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 a ssess the health and environmental hazards, exposures and risks of new and existing chemicals, microorganisms and application s 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 exper t 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 processe s 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 eva luate competitive offerings and looks to determine value

- addedEPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 55 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 Sol utions, 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 perfor mance 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 fr om 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 indu strial 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 sp ecialty 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 ini tiatives 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 variousEPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 56 breakthrough technologies and instrumenta l 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 tox ic 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 Heal th (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 pub lic 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 chem icals. 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 Techni cal 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 M s. 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 s ince 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 thi s 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 Reg ion 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 Contr ol 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.EPA’s Expert Public Workshop on Alternatives and Risk Reduction Approaches to Trichloroethylene (TCE) Use as a Degreaser Workshop Summary 8/26/2014 57 

### Heidi Wilcox, Toxics Use Reduction Institute (TURI) Ms. Wilcox helps run the Toxics Use Reduction Institute Cleaning Lab and is the primary field sp ecialist 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 / Proces s 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 demonstr ates 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 adhesive s. 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 progra ms
. 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 restri cted 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)

.