What’s going on with nPB (1-BP)? Change Your Solvent Not Your Whole Operation!
What is going on with nPB (1-bromopropane)?
On July 31, 2024, the USEPA proposed a Final Regulation for n-Propyl Bromide (nPB) also known as 1-Bromopropane (1-BP) prepared under the Toxic substances control act (TSCA).
https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/risk-evaluation-1-bromopropane-1-bp
nPB is a widely used solvent in a variety of occupational and consumer applications, including vapor degreasing, aerosol degreasing, adhesives and sealants. For the purposes of this blog post, we are going to focus on nPB in vapor degreasing applications as it is a very effective part cleaner with benefits of being non-flammable, non-chlorinated, economically priced and has been used for replacing TCE & other chlorinated solvents for years.
In January of 2022, nPB became considered a Hazardous Air Pollutant (HAP) and thus regulated under NESHAP. In July of 2024, the USEPA proposed new testing, reporting and use requirements for 1-BP.
The new Regulation, as proposed, is fairly complex but in overview it will require:
1. Initial testing to establish operator exposure,
2. The utilization of various types of PPE depending on testing outcomes, and
3. Reporting
The USEPA proposal provides that n Propyl Bromide (nPB) can continue to be used for vapor degreasing and other specified cleaning applications subject to user requirements outlined below.
Do I need to stop using nPB?
The EPA is not proposing a complete ban on the use of 1-BP
The rule proposes to allow certain uses of 1-BP (including use in vapor degreasing) to continue provided that sufficient worker protections are in place to address the unreasonable risk for certain occupational conditions of use. The EPA understands that some workplaces – like those that are vapor degreasing – may already have the existing controls to reduce exposure enough to meet the inhalation exposure concentration of .05ppm. Note at this point, Federal OSHA does not currently have a specific PEL exposure standard for 1-BP.
The economic impact of prohibiting use of 1-BP for vapor degreasing is unclear because some users may not be able to continue using their current (older) vapor degreasing equipment.
What now that the EPA is proposing a Final Regulatory Ruling on nPB?
In order to continue to use 1-BP (nPB) in your vapor degreasing and cleaning operation your company will need to follow specific reporting, monitoring, and H&S requirements outlined in the final EPA regulatory ruling.
Keeping in mind that the proposed ECEL (Existing chemical exposure limit) is .05 parts per million (ppm) (.25 mg/m3) for inhalation exposures to 1-BP as an 8-hour TWA and this is the upper limit that personnel can be exposed to of the 1-BP. To continue to use nPB, a WCPP needs to be implemented to ensure that this limit is not exceeded.
Implement a Workplace Chemical Protection Program (WCPP).
A WCPP needs to be in place that would address the risk from 1-BP to potentially exposed persons directly handling the chemical or in the area where the chemical is being used. This is a brief summary of a potential WCPP would include:
Monitoring Requirements are a key component of implementing the proposed WCPP.
a. Initial monitoring for baseline exposure
b. Periodic monitoring
c. Additional monitoring if a change in production, process or work practices that may result in new additional exposures
Other monitoring requirements:
o Ensure that their methods are accurate to 95% confidence level
o Maintain records that include monitoring event data
o Use of methods for sampling
o Notification of monitoring results to interested parties
Provide PPE – Personal Protective Equipment including respiratory protection and dermal protection and PPE training.
a. Respiratory: NIOSH approved respirators must be used to the appropriate level depending on the ppm exposure of the work area.
b. Dermal: including chemically resistant gloves made of supported polyvinyl alcohol or multiple layer laminated materials that are
OSHA/NIOSH approved.
c. Training
Why change your cleaning process when you can just simply change your solvent?
Health & Safety Profile | AeroTron™-AV | n-Propyl Bromide |
---|---|---|
Hazardous Air Pollutant (HAP) | No - Not a HAP | Yes - Is a HAP |
USEPA ECEL Workplace Exposure | 150 ppm – 8 hour TWA | .05 ppm* – 8 hour TWA (Proposed Workplace ECEL) |
USEPA SNAP Program | SNAP Approved for Solvent Cleaning | Requires EH&S changes to continue to use |
NESHAP Regulated | Not - NESHAP Regulated | Yes - NESHAP Regulated |
Transportation | Not Regulated for Shipping | Regulated for Shipping |
Waste Disposal | Not Hazardous for Disposal | Hazardous for Disposal |
Conclusion
Clearly the USEPA is interested in protecting the environment and the people working around and with nPB. To this end, changes are coming. So, being prepared with a plan is a must.
If you are interested in staying with nPB - Reliance can help. We have been a manufacturer of nPB for many years and will continue to be. So please give us a call to discuss your operation and how to continue to use nPB.
If you are concerned about the future of nPB and its EH&S impacts – there are other solvents and alternative cleaning processes that you can explore. Our Advanced solvents allow you to keep vapor degreasing and are as effective as 1-BP. Or you can move out of solvent based cleaning all together and consider aqueous systems or alternative solvent cleaning combinations.
And this is where we here at Reliance are a bit biased, vapor degreasing is still a very efficient, effective way to clean lots of parts, fast and completely…so exploring our 1-BP replacement solvent, or upgrading your equipment still might be a smarter move than getting out of vapor degreasing altogether.
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Give us a call or contact us to discuss your application and how Reliance’s comprehensive vapor degreasing package can support your industrial parts cleaning operation. We can test clean parts in our lab and share our recommendations for optimized cleaning.
At Reliance, we take a comprehensive, systemic approach to supporting our customers to finding solution to their cleaning needs. Reliance Technical Support Department at 847-640-8923. We are glad to be of assistance.