chloride in paint and coating removal.
    d. Requiring a respiratory protection program, including PPE, air
monitoring, and either a supplied-air respirator of APF 1,000 or 10,000
or an air exposure limit of 1 part per million (ppm) achieved through
engineering controls or ventilation, in commercial facilities where
methylene chloride is used for paint and coating removal under TSCA
section 6(a)(5) for the commercial uses proposed for regulation.
Another regulatory option that EPA considered for the commercial uses
of methylene chloride for paint and coating removal proposed for
regulation was to require risk reduction through an occupational
respiratory protection program, which would include air monitoring,
medical monitoring, and respiratory protection through use of a
supplied-air respirator with an APF of 1,000 or 10,000, depending on
the methods used for paint and coating removal with methylene chloride
and other workplace characteristics, with a performance-based
alternative of meeting an air concentration level of 1 ppm as an
exposure limit for methylene chloride. A full-facepiece (or helmet/
hood) self-contained breathing apparatus (SCBA) when used in the
pressure demand mode or other positive pressure mode has an APF of
10,000. EPA's analysis showed that use of a SCBA with an APF of 10,000
would, in all scenarios evaluated, control the exposure of methylene
chloride to levels that allow for meeting the benchmarks for non-cancer
and cancer risks. Exposures in most workplaces proposed for regulation
could be reduced with an APF of 1,000 to exposure levels that reduce
risks to benchmark levels (Ref. 19). It is important to note that
current OSHA requirements for dermal and eye protection when using
methylene chloride in any way would be maintained under this approach,
in addition to other requirements for work practices, training, and
hazard communication put forth in OSHA's Methylene Chloride Standard
(29 CFR 1910.1052). It is also important to note that any respirator
used would need to be a supplied-air respirator, since methylene
chloride can clog or damage filters or cartridges for air-purifying
respirators, rendering them non-protective (Ref. 19).
    Although respirators, specifically SCBAs, could reduce exposures to
levels that are protective of non-cancer and cancer risks, not all
workers may be able to wear respirators. Individuals with impaired lung
function due to asthma, emphysema, or chronic obstructive pulmonary
disease, for example, may be physically unable to wear a respirator.
Determination of adequate fit and annual fit testing is required for
tight fitting full-face piece respirators to provide the required
protection. Individuals with facial hair, like beards or sideburns that
interfere with a proper face-to-respirator seal, cannot wear tight
fitting respirators. In addition, respirators may also present
communication problems, vision problems, worker fatigue, and reduced
work efficiency (63 FR 1152, January 8, 1998). According to OSHA,
``improperly selected respirators may afford no protection at all (for
example, use of a dust mask against airborne vapors), may be so
uncomfortable as to be intolerable to the wearer, or may hinder vision,
communication, hearing, or movement and thus pose a risk to the
wearer's safety or health.'' (63 FR 1189-1190). Nonetheless, OSHA views
respiratory protection as a backup method which is used to protect
employees from toxic materials in those situations where feasible
engineering controls and work practices are not available or are
insufficient to protect employee health (63 FR 1156-1157). The OSHA
respiratory protection standard (29 CFR 1910.134) requires employers to
establish and implement a respiratory protection program to protect
their respirator-wearing employees. This OSHA standard contains several
requirements, e.g., for program administration; worksite-specific
procedures; respirator selection; employee training; fit testing;
medical evaluation; respirator use; respirator cleaning, maintenance,
and repair; and other provisions.
    In addition, OSHA adopted a hierarchy of controls established by
the industrial hygiene community and used to protect employees from
hazardous airborne contaminants, such as methylene chloride (29 CFR
1910.1052). According to this hierarchy, substitution of less toxic
substances, engineering controls, administrative controls, and work
practice controls are the preferred method of compliance for protecting
employees from airborne contaminants and are to be implemented first,
before respiratory protection is used. OSHA permits respirators to be
used where engineering controls are not feasible or during an interim
period while such controls are being implemented.
    Given equipment costs and the costs of establishing a respiratory
protection program, which involves training, respirator fit testing,
and the establishment of a medical monitoring program, EPA anticipates
that most companies would choose to switch to substitutes instead of
adopting a program for this type of PPE to continue using methylene
chloride for paint and coating removal because this type of PPE program
is not cost-effective. Further, even if cost were not an impediment,
there are many limitations to the successful implementation of
respirators with an APF of 1,000 or 10,000 in a workplace. As
recommended by the SBAR panel, EPA is requesting comment on and
information about workplace experience with respiratory protection
programs and air monitoring for methylene chloride (Ref. 27).
Specifically, EPA seeks comment on whether companies would opt to
substitute an alternate chemical or process instead of implementing a
worker protection program for PPE. EPA also requests comment on the
scientific and technical support used for development of the 1 ppm air
exposure limit (Ref. 21) for methylene chloride and the feasibility of
implementing and enforcing this performance-based approach.
Additionally, EPA is requesting comment on the cost to achieve reduced
exposures in the workplace or to transition to alternative chemicals or
technologies.
    EPA also considered requiring a combination of local exhaust
ventilation and supplied-air respirators with APF of 1,000 or 50, with
a performance-based alternative to the respirator of an air exposure
limit of 1 ppm as an eight-hour TWA. When properly executed, this
option would reduce risks to the health benchmarks for workers and
bystanders (Refs. 19, 21, and 38). However, while this option has the
benefit of incorporating engineering controls and the use of
respirators with a lower APF, the limitations to successful
implementation of the use of supplied-air respirators in the workplace
discussed previously are still present. EPA is requesting comment on

whether this alternate option of allowing industrial use at specified
exposure levels and with appropriate personal protective equipment
should be adopted. Specifically, EPA seeks information on whether this
alternative approach would incentivize industry to eliminate methylene
chloride use in paint and coating removal wherever technically feasible
while minimizing disruptive impacts to those processes where
technically feasible substitutes are currently unavailable.
    Furthermore, neither of the variations of relying upon respiratory
protection for commercial paint and coating removal with methylene
chloride addresses consumer risks. EPA does not have the authority to
require that consumers change use practices or wear PPE. Even if this
approach were coupled with a TSCA section 6(a)(2) prohibition on the
manufacture, processing and distribution in commerce of methylene
chloride for consumer use in paint and coating removal, this would not
protect consumers because they would foreseeably continue to buy and
use paint and coating removal products containing methylene chloride
intended for commercial users, e.g., via the Internet or home
improvement or automotive supply retailers. Consumers would continue to
be exposed far above the established health benchmarks when using
methylene chloride for paint and coating removal (Ref. 20).
    Therefore, considering the increased complexity of a respiratory
protection program involving supplied-air respirators as well as the
general inability to require that consumers adhere to a respiratory
protection program resulting in little mitigation of risks to
consumers, an option focusing on respiratory protection would not
address the unreasonable risks presented by these uses.

D. Adverse Health Effects and Related Impacts That Would Be Prevented
by the Proposed Option

    The proposed option would prevent exposure to methylene chloride
from paint and coating removal and thus would prevent the risks of
adverse effects and associated impacts. As discussed in Unit II.C., the
range of adverse health effects includes effects on the nervous system,
liver, respiratory system, kidneys, and reproductive systems (Ref. 2).
These health effects associated with exposure to methylene chloride are
serious and can have impacts throughout a lifetime. The following is a
discussion of the impacts of significant acute, chronic non-cancer, and
cancer effects associated with methylene chloride exposure during paint
and coating removal, including the severity of the effect, the
manifestation of the effect, and how the effect impacts a person during
their lifetime.
    1. Nervous system effects--acute exposures. The methylene chloride
risk assessment and EPA's 2011 IRIS assessment identified nervous
system effects as the critical effect of greatest concern for acute
exposure to methylene chloride. Specifically, these assessments
identified sensory impairment and incapacitation (loss of
consciousness) as the critical effect of acute exposures (Refs. 2 and
5). Exposure to methylene chloride can rapidly cause death as a result
of nervous system depression, but even exposures that may in some cases
result only in dizziness or fainting can be fatal if the individual who
is disoriented or has fainted is alone. Several individuals have died
after becoming incapacitated during paint and coating removal with
methylene chloride; after losing consciousness, their nervous system is
overcome by the continued accumulation of volatile fumes. As described
in a recent report on deaths caused by methylene chloride, ``. . . the
danger posed by methylene chloride is its one-two punch when fumes
accumulate. Because it turns into carbon monoxide in the body, it can
starve the heart of oxygen and prompt an attack. The chemical also acts
as an anesthetic at high doses: Its victims slump over, no longer
breathing, because the respiratory centers of their brains switch
off.'' (Ref. 7).
    There are increased risks of death and nervous system effects for
many of the approximately 17,600 workers in 8,600 commercial facilities
or companies that use methylene chloride for paint and coating removal
for the commercial uses proposed to be regulated, as well as for the
estimated 1.3 million consumers and residential bystanders who use or
are exposed to paint and coating removers containing methylene chloride
each year (Ref. 4).
    Although the fact that deaths occur as a result of exposure to
methylene chloride is well documented, the exact number of deaths
specifically attributable to methylene exposure is unclear. In 2012,
the Centers for Disease Control and Prevention Morbidity and Mortality
Weekly Report (MMWR) published results of an investigation into deaths
among bathtub refinishers using methylene chloride. The authors of the
investigation and the MMWR editors emphasized that the reported number
of deaths due to methylene chloride is an underestimate and subject to
at least three limitations: A lack of reporting to the OSHA incident
database by self-employed individuals, no equivalent database to track
consumer incidents and fatalities, and the likelihood that deaths due
to methylene chloride exposures are misattributed to heart disease,
since the pathology is similar (Ref. 33).
    Based on data from OSHA, CPSC, state records, and publicly reported
information, EPA has identified 49 fatalities since 1976 resulting from
consumer or commercial worker exposure to methylene chloride during
paint and coating removal, including for uses not proposed for
regulation. However, as described earlier, this is likely an
underestimate of the deaths that have occurred. As highlighted in the
MMWR report from 2012 and OSHA alert from 2016, health effects from
methylene chloride exposure are often misattributed to other causes
(Refs. 32 and 33). For example, in several cases, workers were seen in
hospital emergency rooms with symptoms of solvent exposure, were not
properly diagnosed, and were sent back to the same work that ultimately
killed them (Ref. 32).
    Thus, EPA is unable to quantify the precise number or frequency of
deaths that occur as a result of exposure to methylene chloride during
paint and coating removal. However, the sporadically-occurring deaths
outside of bathtub refinishing that have been documented as caused by
methylene chloride, and the undocumented deaths that have been
misattributed to heart disease should not be ignored merely because
they cannot be monetized. Death following exposure to methylene
chloride during paint and coating removal are characterized by family
members as suddenly tragic, particularly when the deceased is young. In
1986 in Colorado, a worker died two hours into his first day on the job
using methylene chloride to remove coatings from furniture (Ref. 40).
In 2014 in New York, a 20-year old worker died while helping his father
with a job refinishing a hotel bathtub (Ref. 41).
    Fatalities have also occurred among more experienced workers. In
1990 in Georgia, a worker died while repairing a plastic-coated metal
rack; he was found to have fainted and fallen into the tank of
methylene chloride the company used to strip rack coatings (Ref. 7). In
several instances, pairs of workers were killed while working on the
same paint removal project with methylene chloride, such as renovating
a squash court or the floor tile of a bathroom in a federal office
building (Ref. 40).
    In other cases, workers died when helping co-workers in distress.
In South Carolina, in 1986, several workers were

killed or hospitalized in one incident: Two workers went to check on a
colleague in a basement using a paint remover with methylene chloride;
all three died. Five emergency responders arrived at the scene, and
three were hospitalized due to inhalation of fumes (Ref. 7).
    These sudden, unexpected deaths are not limited to commercial users
or occupational bystanders exposed to methylene chloride during paint
and coating removal. Consumer fatalities have been recorded, such as
the woman who died in her house in 1990 in Ohio after removing paint
from furniture with methylene chloride, as reported to the American
Association of Poison Control Centers (Ref. 7). Consistent with the
underreporting of commercial deaths, EPA estimates there are unreported
consumer deaths due to exposure to methylene chloride during paint and
coating removal.
    These deaths clearly have a significant impact on families,
workplaces, and communities, and yet not all of them can be monetized.
Similarly, the serious health effects and lifetime impacts on workers
who do not die but who are hospitalized with heart failure, coma, or
other effects also cannot be quantified or monetized. However, the
impacts of these effects should not be ignored. One example is a case
in 2012 in California, where one man attempted to save a co-worker who
had collapsed while cleaning a paint-mixing tank. The collapsed worker
died, and the man attempting to rescue him was incapacitated within
several seconds and lost consciousness. Though he survived, he required
resuscitation, hospitalization for four days, and lengthy follow-up
treatments (Ref. 7). The impacts on workers with severe but non-fatal
nervous system impacts include monetary, personal health, and emotional
suffering costs that cannot be quantified or monetized, but again,
should not be ignored. These severe nervous system impacts can include
coma and heart failure (Ref. 2).
    Even when less severe, the nervous system effects of acute exposure
to methylene chloride can have considerable adverse consequences on an
individual, particularly if one is exposed as a bystander who is
unaware of why these nervous system effects are occurring. Commercial
and consumer users as well as bystanders in workplaces and residences
are at risk of dizziness and sensory impairment during most uses of
methylene chloride for paint and coating removal. Similarly, chronic
exposure to methylene chloride presents risks to the nervous system of
commercial users, consumer users, and bystanders exposed to methylene
chloride in paint and coating removal.
    2. Nervous system effects--chronic exposures. The methylene
chloride risk assessment identified nervous system effects as adverse
effects of chronic exposure to methylene chloride exposure in paint and
coating removal. There are increased health risks for nervous system
effects for many of the approximately 17,600 workers in 8,600
commercial facilities or companies that use methylene chloride for
paint and coating removal for the commercial uses proposed to be
regulated (Ref. 4).
    Chronic exposures in occupational settings put users and bystanders
at risk of cognitive impairment (affecting eye-hand coordination,
tracking tasks, auditory vigilance); adverse effects on autonomic,
neuromuscular, and sensorimotor functions (Ref. 2); and long-term
effects on specific cognitive-neurological measures (i.e., attention
and reaction time) (Ref. 5).
    3. Liver toxicity. The methylene chloride risk assessment
identified liver toxicity and liver cancer as adverse effects of
chronic exposure to methylene chloride exposure in paint and coating
removal. There are increased health risks for liver toxicity and liver
cancer for many of the approximately 17,600 workers in 8,600 commercial
facilities or companies that use methylene chloride for paint and
coating removal for the commercial uses proposed to be regulated (Ref.
4).
    Specific effects to the liver include hepatic vacuolation and non-
alcoholic fatty liver disease (NAFLD) (Ref. 2). Some form of liver
disease impacts at least 30 million people, or 1 in 10 Americans.
Included in this number is at least 20% of those with NAFLD. NAFLD
tends to impact people who are overweight/obese or have diabetes.
However, an estimated 25% do not have any risk factors. The danger of
NAFLD is that it can cause the liver to swell, which may result in
cirrhosis over time and could even lead to liver cancer or failure
(Ref. 42). The most common known causes to this disease burden are
attributable to alcoholism and viral infections, such as hepatitis A,
B, and C. These known environmental risk factors of hepatitis infection
may result in increased susceptibility of individuals exposed to
organic chemicals such as methylene chloride.
    Chronic exposure to methylene chloride can also lead to liver
cancers including hepatocellular carcinomas (HCC), hepatocellular
adenomas, and biliary tract cancer (Ref. 2). The monetizable benefits
associated with reducing the risk of liver cancers associated with
methylene chloride exposure are discussed in Unit VII.B. However, the
impacts of these cancers should not be measured only as dollar
valuations. For example, because HCC is frequently diagnosed only after
an individual's health has deteriorated, survival is usually measured
in months. As a result, ``HCC is responsible for a large proportion of
cancer deaths worldwide . . . HCC classically arises and grows in
silent fashion, making its discovery challenging prior to the
development of later stage disease'' (Ref. 43). Recommended treatments
are aggressive interventions such as the removal of the tumors or
sections of the liver; the life expectancy of patients with HCC is a
mean survival rate of 6 to 20 months. Advanced cases can metastasize to
any organ system, and tends to spread to bones and lungs. Bone pain
related to metastasis is frequently the initial presenting symptom of
HCC (Ref. 43).
    Additional medical and emotional costs are associated with cancer
and non-cancer liver toxicity following chronic exposure to methylene
chloride in paint and coating removal, although these costs cannot be
quantified. These costs include medical visits and medication costs. In
some cases, the ability to work can be affected, which in turn impacts
the ability to get proper medical care. Liver toxicity can lead to
jaundice, weakness, fatigue, weight loss, nausea, vomiting, abdominal
pain, impaired metabolism, and liver disease.
    Depending upon the severity of the jaundice, treatments can range
significantly. Simple treatment may involve avoiding exposure to
methylene chloride and other solvents; however, this may impact an
individual's ability to continue to work. In severe cases, liver
toxicity can lead to liver failure, which can result in the need for a
liver transplant. Even if a donor is available, liver transplantation
is expensive (with an estimated cost of $575,000) and there are
countervailing risks for this type of treatment (Ref. 44). The mental
and emotional toll on an individual and their family as they try to
identify the cause of sickness and possibly experience an inability to
work, as well as the potential monetary cost of medical treatment
required to regain health, are significant.
    4. Hematopoietic cancers. EPA's 2011 IRIS assessment for methylene
chloride found that it is a likely human carcinogen. Chronic inhalation
exposure to methylene chloride such as during paint and coating removal
has been shown to result in increased risk for non[hyphen]Hodgkin's
lymphoma (NHL) or multiple myeloma in workers (Ref. 5). There are
increased risks for NHL or

multiple myeloma for many of the approximately 17,600 workers in 8,600
commercial facilities or companies that use methylene chloride for
paint and coating removal for the commercial uses proposed to be
regulated (Ref. 4).
    NHL is a form of cancer that originates in the lymphatic system.
Approximately 19 new cases per 100,000 adults per year are diagnosed,
with approximately 6.2 deaths per 100,000 adults annually (Ref. 45).
NHL is the seventh most common form of cancer (Ref. 46). Other factors
that may increase the risk of NHL are medications that suppress a
person's immune system, infection with certain viruses and bacteria, or
older age (Ref. 47).
    Symptoms of NHL are swollen lymph nodes in the neck, armpits or
groin, abdominal pain or swelling, chest pain, coughing or trouble
breathing, fatigue, fever, night sweats, and weight loss. Depending on
the rate at which the NHL advances, treatment may consist of
monitoring, chemotherapy, radiation, stem cell transplant, medications
that enhance the immune system's ability to fight cancer, or
medications that deliver radiation directly to cancer cells (Ref. 47).
    Multiple myeloma is a related hematopoietic cancer, formed by
malignant plasma cells. Multiple myeloma is characterized by low blood
counts, bone and calcium problems, infections, kidney problems, light
chain amyloidosis, and various forms of abnormal plasma cell growth.
Often, multiple myeloma has no clinical symptoms until it reaches an
advanced stage (Ref. 48).
    Treatments for NHL or multiple myeloma result in substantial costs
for hospital and doctors' visits in order to treat the cancer.
Treatments for NHL or multiple myeloma can also have countervailing
risks and can lead to patients' higher susceptibility for secondary
malignancies (Refs. 47 and 48). The emotional and mental toll from
wondering whether a treatment will be successful, going through the
actual treatment, and inability to do normal activities, or work will
most likely be high (Ref. 49). This emotional and mental toll could
extend to the person's family and friends as they struggle with the
diagnosis and success and failure of a treatment regime.
    5. Brain cancer. EPA's 2011 IRIS assessment for methylene chloride
found that it is a likely human carcinogen. Chronic inhalation exposure
to methylene chloride has been shown to result in brain cancer (Ref.
5). There are increased risks for brain cancer for many of the
approximately 17,600 workers in 8,600 commercial facilities or
companies that use methylene chloride for paint and coating removal for
the commercial uses proposed to be regulated (Ref. 4).
    Researchers at the National Cancer Institute found that
``associations of astrocytic brain cancer were observed with likely
exposure to carbon tetrachloride, methylene chloride,
tetrachloroethylene, and trichloroethylene, but were strongest for
methylene chloride. . . . Risk of astrocytic brain tumors increased
with probability and average intensity of exposure, and with duration
of employment in jobs considered exposed to methylene chloride . . .
These trends could not be explained by exposures to the other
solvents'' (Ref. 50).
    Cancers that originate in the brain, which include astrocytic brain
cancers, are relatively rare. Astrocytic brain cancers are estimated to
have an incidence of approximately 10 cases per 1 million people per
year, depending on how these types of cancers are defined (Ref. 51).
Astrocytic tumors are characterized by varying degrees of growth
potential and infiltration into nearby tissues. They include tumors
that can spread quickly through the brain stem (brain stem gliomas);
affect the pineal gland, which controls the sleeping and waking cycle
(pineal astrocytic tumors); grow slowly and can be relatively easily
cured (pilocytic astrocytoma); grow slowly but often spread into nearby
tissues (diffuse astrocytoma); grow quickly and spread into nearby
tissues (anaplastic astrocytoma); and grow quickly, spread quickly into
nearby tissues, and usually cannot be cured (glioblastoma) (Ref. 51).
    For astrocytic brain cancers, like other primary malignant brain
tumors, initial clinical symptoms are frequently headaches and
seizures. Lower-grade tumors may persist undetected for years, whereas
the faster-growing or faster-spreading tumors may rapidly provoke
neurological decline. Other symptoms may include nausea, vomiting,
headache, and confusion as a result of increased intracranial pressure
(Ref. 51).
    Treatment for astrocytic brain cancers varies by the type and stage
of the tumor; it can include pharmacological treatment (for many
patients, this includes steroids and anti-convulsants if they are
experiencing seizures), surgery (depending on location of the tumor,
they may be removed or separated from the brain), chemotherapy, hormone
modulation, or combinations of these treatments (Ref. 51). Like most
cancer treatments, these can have countervailing risks. Additionally,
the emotional and mental tolls described in earlier sections are
relevant to these cancer treatments as well (Ref. 49).
    6. Lung cancer. EPA's 2011 IRIS assessment for methylene chloride
found that it is a likely human carcinogen. Chronic inhalation exposure
to methylene chloride has been shown to result in bronchoalveolar
carcinomas (BAC) or bronchoalveolar adenomas, which are forms of lung
cancer (Ref. 5). There are increased risks for these lung cancers for
many of the approximately 17,600 workers in 8,600 commercial facilities
or companies that use methylene chloride for paint and coating removal
for the commercial uses proposed to be regulated (Ref. 4).
    BAC is a small percent of lung cancers (between 2% to 4%) and has
unique characteristics. It is notable for its weak relationship with
cigarette smoking; about one-third of patients in the United States
with BAC were never smokers. Additionally, because it rarely spreads
outside the lungs, it is often initially diagnosed as pneumonia or
other lung inflammations (Ref. 52). Most patients do not present
clinical symptoms (Ref. 52) and are only diagnosed following
radiography or biopsy. Treatment requires surgery (Ref. 52). This has
clear countervailing risks, and even if successful in removing any
tumors present, the BAC may return.
    7. Mammary tumors. Exposure to methylene has been shown to result
in significant increases in the incidence of adenomas, fibroadenomas,
or fibromas in or near the mammary gland (Refs. 2 and 5). These are
largely benign tumors (Ref. 2). Though many benign tumors do not
require invasive procedures, doctors recommend removing fibroadenomas.
Patients need to undergo a biopsy to identify the carcinogenic risk of
the tumor, and have the tumors removed if they continue to grow, change
the shape of the breast, or are carcinogenic (Ref. 53). If removal is
necessary, the procedure may also require the removal of nearby healthy
mammary tissue, resulting in scarring and changed shape and texture of
the breast (Ref. 53). Women with fibroadenomas and adenomas also have
an increased risk of breast cancer, estimated to be approximately 1.5
to 2.0 times the risk of women with no breast changes (Ref. 54).
    8. Reproductive effects. EPA's 2011 IRIS assessment for methylene
chloride found that exposure can have reproductive effects that include
testicular and ovarian atrophy (Ref. 5). At very high exposures,
chronic inhalation of methylene chloride during paint and coating
removal can result in these reproductive effects, which are related to
decreased fertility (Ref. 55).

There are increased risks for these reproductive effects for many of
the approximately 17,600 workers in 8,600 commercial facilities or
companies that use methylene chloride for paint and coating removal for
the commercial uses proposed to be regulated (Ref. 4). Similar to
effects discussed previously, while neither the precise reduction in
individual risk of developing this disorder from reducing exposure to
methylene chloride or the total number of cases avoided can be
estimated, EPA still considers their impact.
    9. Kidney toxicity. EPA's 2011 IRIS assessment for methylene
chloride identified kidney effects from exposure to methylene chloride;
these effects include renal tubular degeneration (Ref. 5). At very high
exposures, chronic inhalation exposure to methylene chloride during
paint and coating removal can result in kidney toxicity. There are
increased risks for these kidney effects for many of the approximately
17,600 workers in 8,600 commercial facilities or companies that use
methylene chloride for paint and coating removal for the commercial
uses proposed to be regulated (Ref. 4).
    Exposure to methylene chloride can lead to changes in the proximal
tubules of the kidney. This damage may result in signs and symptoms of
acute kidney failure that include; decreased urine output, although
occasionally urine output remains normal; fluid retention, causing
swelling in the legs, ankles or feet; drowsiness; shortness of breath;
fatigue; confusion; nausea; seizures or coma in severe cases; and chest
pain or pressure. Sometimes acute kidney failure causes no signs or
symptoms and is detected through lab tests done for another reason.
    Kidney toxicity means the kidney has suffered damage that can
result in a person being unable to rid their body of excess urine and
wastes. In extreme cases where the kidney is impaired over a long
period of time, the kidney could be damaged to the point that it no
longer functions. When a kidney no longer functions, a person needs
dialysis and ideally a kidney transplant. In some cases, a non-
functioning kidney can result in death. Kidney dialysis and kidney
transplantation are expensive and incur long-term health costs if
kidney function fails (Ref. 56).
    The monetary cost of kidney toxicity varies depending on the
severity of the damage to the kidney. In less severe cases, doctor
visits may be limited and hospital stays unnecessary. In more severe
cases, a person may need serious medical interventions, such as
dialysis or a kidney transplant if a donor is available, which can
result in high medical expenses due to numerous hospital and doctor
visits for regular dialysis and surgery if a transplant occurs. The
costs for hemodialysis, as charged by hospitals, can be upwards of
$100,000 per month (Ref. 57).
    Depending on the severity of the kidney damage, kidney disease can
impact a person's ability to work and live a normal life, which in turn
takes a mental and emotional toll on the patient. In less severe cases,
the impact on a person's quality of life may be limited while in
instances where kidney damage is severe, a person's quality of life and
ability to work would be affected. While neither the precise reduction
in individual risk of developing kidney toxicity from reducing exposure
to methylene chloride during paint or coating removal or the total
number of cases avoided can be estimated, these costs must still be
considered because they can significantly impact those exposed to
methylene chloride.
    10. Disproportionate impacts on environmental justice communities.
An additional factor that cannot be monetized is the disproportionate
impact on environmental justice communities. As described in Unit
VI.C.1.b., Hispanic and foreign-born workers, who may have limited
English proficiency, are disproportionately over-represented in
construction trades (Ref. 4), in which methylene chloride is used for
paint and coating removal. Because they are disproportionately over-
represented in this industry, these populations are disproportionately
exposed to methylene chloride during paint and coating removal, and are
disproportionately at risk to the range of adverse health effects
described in this unit.

E. Availability of Alternatives

    For almost every situation in which methylene chloride is used to
remove paints or coatings, EPA is aware of technically and economically
feasible chemical substitutes or alternative methods that are
reasonably available. The two situations for which EPA does not know of
technically and economically feasible alternatives are the uses that
EPA proposes are critical for national security, described in more
detail in Unit VIII., and commercial furniture refinishing, discussed
in more depth in Unit XI. With respect to the specific coating removal
uses that EPA proposes are critical for national security, described in
Unit VIII., EPA does not believe that technically and economically
feasible alternatives are reasonably available at this time. With
respect to the furniture refinishing uses described in Unit XI., EPA is
still investigating whether economically feasible alternatives are
reasonably available.
    EPA considered chemical substitutes and alternative methods
consistent with the requirements of TSCA section 6(c)(2)(C) and as
similarly recommended by the SBAR panel (Ref. 27). A full industry
profile characterizing manufacturers, processors and end users of
methylene chloride for paint and coating removal and a use and
substitutes analysis are included in sections 2 and 3 of EPA's economic
assessment (Ref. 4). As described below, EPA proposes that alternatives
are technologically feasible, economically feasible, reasonably
available, and present fewer hazards to human health than methylene
chloride in paint and coating removal. EPA requests comment on whether
its conclusion that substitutes for methylene chloride identified are
available and technically and economically feasible is accurate and
whether its consideration of alternatives was sufficient to satisfy the
requirements of TSCA section 6(c)(2)(C).
    Research into the efficacy of chemical substitutes has identified
products currently available for commercial and consumer users of
methylene chloride for paint and coating removal, for a variety of
coatings on numerous substrates (Refs. 58 and 59). Research by the
European Association for Safer Coating Removal in 2006 found that for
every use that was studied of methylene chloride in paint and coating
removal, there was a suitable substitute (Ref. 60). Other non-chemical
methods of paint removal are also available (Ref. 31). Additionally, in
most commercial sectors, users have voluntarily adopted substitute
chemicals or methods, either due to financial considerations, customer
requests, concern for worker or individual health and safety, decreased
discharges to air and water, reduced clean-up costs, or reduced cost of
protective equipment and respiratory protection programs (Ref. 22).
    Many producers of paint and coating removal products containing
methylene chloride also produce paint and coating removal products with
substitute chemicals (Ref. 4). This was emphasized by a small business
who makes such products (Ref. 22); other small businesses separately
described the limitations of many alternatives (Ref. 27). Thus, there
is already precedent for producers reformulating products to meet
demand from commercial or individual customers. Additionally, methylene
chloride is prohibited from use in graffiti removal in California,

Connecticut, Delaware, the District of Columbia, Illinois, Indiana,
Maine, Maryland, Massachusetts, Michigan, New York, and Rhode Island
(Ref. 12). The fact that 11 states and the District of Columbia have
specifically prohibited the use of methylene chloride in graffiti
removal supports a finding that it is not critical for this use and
that there are efficacious substitutes.
    Based on the frequent use of substitute chemicals or alternative
methods for paint and coating removal in all industries discussed here,
and the formulation and distribution of substitute chemicals for paint
and coating removal by all formulators of products containing methylene
chloride (Ref. 4), EPA finds that technically and economically feasible
alternatives to methylene chloride are reasonably available for all
uses proposed for regulation.
    Primary chemical substitutes for methylene chloride in paint and
coating removal include products formulated with benzyl alcohol;
dibasic esters; acetone, toluene, and methanol (collectively ATM); and
caustic chemicals. EPA evaluated these products for efficacy, toxicity,
relative hazards compared to methylene chloride, and other hazards that
might be introduced by use of these products (such as environmental
toxicity, increased global warming potential, and increased
flammability or other hazards to users). Overall, while the efficacies
of the substitutes are comparable to the efficacy of methylene
chloride, none of the substitute chemicals already available has the
level of toxicity associated with methylene chloride.
    Products based on benzyl alcohol formulations have been identified
as efficacious paint and coating removers in various industry sectors
(Refs. 22 and 27). Consumer products containing benzyl alcohol are
available for sale (Refs. 22, 27, 35, 58, 59, and 61). There are fewer
hazard concerns compared to methylene chloride-based products, and the
levels at which benzyl alcohol causes toxicity are higher than for
methylene chloride, suggesting lower toxicity (Ref. 34). The relative
inhalation exposure potential is lower for benzyl alcohol than for
methylene chloride. The relative dermal exposure potential of benzyl
alcohol is similar to methylene chloride (Ref. 34). Benzyl alcohol-
based paint removers are expected to result in lower risks than
methylene chloride products, primarily due to lower toxicity (Ref. 29).
    Dibasic ester products can include dimethyl succinate, dimethyl
glutarate and dimethyl adipate. They are generally viewed as
efficacious products by commercial users in several sectors, though,
because they evaporate slowly, they require a longer dwell time than
methylene chloride (Ref. 22, 27). In general, the hazards associated
with dibasic esters are less severe and occur at concentrations higher
than methylene chloride (Ref. 34). Regarding differential exposures
between dibasic esters and methylene chloride, the relative inhalation
exposure potential is lower for dibasic esters than for methylene
chloride (Ref. 34). The relative dermal exposure potentials of dibasic
esters are similar to methylene chloride. Taken together, dibasic
ester-based paint removers are expected to result in lower risks than
methylene chloride products, primarily due to lower toxicity (Ref. 34).
    ATM products contain acetone, toluene, and methanol. Products
containing these chemicals may remove coatings very quickly, but may
not be effective on every type of coating (Refs. 22 and 27). Acetone,
toluene, and methanol evaporate quickly and are very flammable (Ref.
62). However, it is important to note that acetone, toluene, and/or
methanol are present in most paint removers that contain methylene
chloride, as co-solvents (Ref. 34). As a result, the main difference
between paint removers that contain methylene chloride (and typically
also contain acetone, toluene, and/or methanol) and ATM products is the
absence of methylene chloride. Acetone is readily absorbed via
inhalation and the relative inhalation exposure potential is similar to
methylene chloride (Ref. 34). Acetone in particular is significantly
less toxic than methylene chloride. Toluene and methanol are readily
absorbed via inhalation, but the relative inhalation exposure potential
is lower than for methylene chloride (Ref. 34). Dermal exposure to
acetone, toluene and methanol is slightly less than for methylene
chloride (Ref. 34). Taken together, ATM-based paint removers are
expected to result in lower cancer risks (Ref. 36).
    Products with caustic chemicals typically include calcium hydroxide
or magnesium hydroxide. In many uses, they can be effective products,
particularly when multiple coatings are being removed from a substrate.
Caustic products have been reported to remove up to 30 coats in 24
hours, and in some cases, they have no increased dwell time compared to
methylene chloride (Ref. 23). In contrast to methylene chloride-based
products, there are no cancer or other repeat dose endpoints of concern
associated with caustic products (Ref. 34). Caustic products pose acute
concerns due to their physical chemical properties and can cause
chemical burns (Ref. 36). It is important to note that products
containing methylene chloride may also cause chemical burns.
Additionally, the risks associated with caustic-based products are
entirely acute, and can be mitigated by appropriate protective
equipment more easily than the acute and chronic risks presented by
methylene chloride.
    In summary, when NMP is excluded from consideration, the most
likely chemical substitutes for methylene chloride in paint and coating
removal do not pose a risk of cancer to users, generally have lower
exposure potential than methylene chloride, and when acute risks are
present, as in the case of caustic chemicals, those risks are self-
limiting by the nature of the adverse effects (since a user
experiencing those effects is likely to take immediate action to
mitigate or cease the effect of the caustic chemical). The chemical
formulations that seem to present some risks of concern are ATM
products, since they contain toluene and methanol. However, these
chemicals are also present in most paint removers that contain
methylene chloride, as co-solvents. As a result, no additional risks
would be introduced were users to substitute a typical methylene
chloride product (which would likely contain acetone, toluene, and/or
methanol as co-solvents) with ATM products.
    In addition to examining toxicity to humans, EPA reviewed available
data on the chemicals in the baseline and alternative products for
aquatic toxicity, persistence and bioaccumulation data, as a basis for
examining potential environmental toxicity. Only one chemical evaluated
(citrus terpenes) may have significant impacts on aquatic toxicity,
with concern for environmental persistence and/or bioaccumulation. This
chemical is contained in NMP-based paint removal products (Ref. 34).
    EPA is also mindful of the risks that may be introduced by
substitute chemicals or methods to increase global warming, and has
examined the global warming potential of the chemical components of
likely chemical substitutes for methylene chloride in paint and coating
removal. Methylene chloride presents concerns for global warming; it
has a GWP of 8.7 (see Unit II.D.2.). The GWP values of likely
substitute chemicals in paint and coating removal are: 0 GWP (benzyl
alcohol, ATM) or not assessed (caustics, dibasic esters) (Ref. 23). As
such, EPA has not identified any increased risk of global warming that
would be introduced by use of chemical products

as substitutes for methylene chloride in paint and coating removal.
    In addition to human and environmental toxicity, other hazards
associated with chemical methods for paint and coating removal are
risks of fire due to flammability of the chemical product, and
poisoning or acute injury. Risks of fire are serious when using
solvents such as paint and coating removal chemicals. The flammability
of methylene chloride is lower than some of the substitute organic
solvents. However, many paint and coating removal products containing
methylene chloride also contain more flammable chemicals as part of the
formulation (Ref. 34). Paint and coating removal products sold to
consumers that contain methylene chloride frequently have flammability
warnings prominently on them (Ref. 35). Other chemical paint and
coating removal products, such as those based on benzyl alcohol and
dibasic esters, have low flammability and do not present an increased
risk of fire from products containing methylene chloride (Ref. 23).
Even among products that fall within the same general product
composition category, there is meaningful variability in the specific
formulations of paint remover products, and thus in their flammability.
Furthermore, it is impracticable for EPA to predict the specific
product formulations for which use will increase as a result of
prohibitions on methylene chloride in paint and coating removal. It is
therefore impracticable for EPA to forecast whether the flammability of
popular paint and coating removers would generally increase or decrease
as a result of the proposed rule.
    In addition to using substitute chemical products, non-chemical
methods for paint and coating removal are frequently used. These
include thermal removal, sanding, hydroblasting, abrasive blasting, and
laser removal (Refs. 22 and 31). Acute and chronic physical hazards
(e.g., burns, injuries to bodily parts) to workers and consumers can
occur, in addition to any lead-related risks that should be considered
when using these methods with lead-based paint.
    In this overview, when considering alternatives to methylene
chloride that would be available, NMP generally was not considered
because, under the first co-proposed option for NMP in this proposed
rule, this chemical would also be prohibited from use in paint and
coating removal. However, under the second co-proposed approach for
reducing the risks of NMP in paint and coating removal, products
containing NMP would be available for commercial and consumer paint and
coating removal, with restrictions. Details of the two co-proposed
options are in Unit XVI.3. EPA identified developmental risks following
acute exposures for consumers and acute and chronic exposures for
commercial users of paint and coating removal products containing NMP
following exposure through dermal contact, inhalation, and vapor-
through-skin. More information on the risks EPA identified related to
NMP are in Unit XVI.B.1.

F. Impacts of the Proposed and Alternative Regulatory Options

    This unit describes the estimated costs of the proposed and
alternative regulatory actions that EPA considered for methylene
chloride in paint and coating removal. More information on the benefits
and costs of this proposal as a whole can be found in Unit XXIII.
    1. Proposed approach for methylene chloride in paint and coating
removal. The costs of the proposed approach are estimated to include
product reformulation costs, downstream notification costs,
recordkeeping costs, and Agency costs. The costs of paint and coating
removal product reformulations are estimated to be approximately
$10,000 to $20,000 per year (annualized at 3% over 20 years) and
$14,000 to $24,000 (annualized at 7% over 20 years). The cost for
reformulation includes a variety of factors such as identifying the
appropriate substitute chemical for methylene chloride in the
formulation, assessing the efficacy of the new formulation and
determining shelf-life. Under the first co-proposed approach for NMP,
where the manufacturing, processing, distribution, and commercial use
of paint and coating removal products containing NMP would be
prohibited, the costs to users of paint and coating removers containing
methylene chloride are $4,217,000 to $23,436,000 using a 3% discount
rate and $4,592,000 to $23,485,000 at the 7% discount rate (both rates
annualized over 20 years). The costs of downstream notification and
recordkeeping on an annualized basis over 20 years are $40 and $60
using 3% and 7% discount rates respectively (Ref. 4). Agency costs for
enforcement are estimated to be approximately $114,401 and $111,718
annualized over 20 years at 3% and 7%, respectively. The total cost of
the proposed approach for paint and coating removers containing
methylene chloride under the first co-proposed approach for NMP is
estimated to be $4,247,000 to $23,446,000 and $4,612,000 to $23,495,000
annualized over 20 years at 3% and 7%, respectively (Ref. 4). Under the
second co-proposed approach for NMP, where paint and coating removal
products containing NMP would be available with some restrictions, the
costs to users of paint and coating removers containing methylene
chloride are $67,087,960 to $68,726,960 using a 3% discount rate and
$67,369,940 to $69,006,940 at the 7% discount rate (both rates
annualized over 20 years). The costs of downstream notification and
recordkeeping on an annualized basis over 20 years are the same as
under the first co-proposed approach for NMP. Agency costs for
enforcement are estimated to be the same as under the first co-proposed
approach for NMP. The total cost of the proposed approach for paint and
coating removers containing methylene chloride under the second co-
proposed approach for NMP is estimated to be $67,098,000 to $68,747,000
and $67,384,000 to $69,034,000 annualized over 20 years at 3% and 7%,
respectively (Refs. 4 and 127).
    2. Options that require personal protective equipment for methylene
chloride in paint and coating removal. Given equipment costs and the
requirements associated with establishing a respiratory protection
program which involves training, respirator fit testing and the
establishment and maintenance of a medical monitoring program, EPA
considers the proposed approach more cost-effective than options that
require person protective equipment. This is because EPA anticipates
that companies would choose to switch to substitute chemicals instead
of adopting a program for PPE, including with a performance-based
option of meeting an air concentration level of 1 ppm as an exposure
limit for methylene chloride in paint and coating removal. The
estimated annualized costs of switching to a respiratory protection
program requiring PPE of APF 1,000 are $13,775,000 to $26,535,000 at 3%
and $14,202,000 to $26,708,000 at 7% over 20 years (Ref. 4). In
addition, there would be higher EPA administration and enforcement
costs with a respiratory protection program under the proposed
approach.
    3. Options that exclude downstream notification. For those options
that exclude downstream notification, the options are less effective
and more to challenging to implement. The downstream notification
(e.g., via SDS) provides additional information on the prohibitions
under the proposed option for processors and distributors of methylene
chloride or products containing methylene chloride other than paint and
coating removers, and

provides an efficient way for those entities to recognize themselves as
affected by the regulation, which contributes to a more effective
regulation (Ref. 63). In this way, the downstream notification
component of the supply chain approach contributes to the use no longer
presenting an unreasonable risk because it streamlines and aids in
compliance and implementation (Ref. 64).

G. Summary

    The proposed approach is necessary so that methylene chloride in
paint and coating removal no longer presents an unreasonable risk. It
is also more cost effective than other regulatory options the Agency
identified as potentially reducing risks so that they are no longer
unreasonable, because it achieves the benefits of reducing the
unreasonable risks so they are no longer unreasonable for a lower cost
than the primary alternative option. For more information, see section
6 in the Economic Analysis (Ref. 4).
    As stated previously in this notice, the proposed approach
includes:
     Prohibiting manufacturing (including import), processing,
and distribution in commerce of methylene chloride for consumer paint
and coating removal and commercial paint and coating removal for the
uses proposed for regulation;
     Prohibiting commercial use of methylene chloride for paint
and coating removal for the uses proposed for regulation;
     Requiring that any products containing methylene chloride
intended or used for paint and coating removal be distributed in
volumes no less than 55-gallon containers;
     Requiring downstream notification of the prohibition on
manufacturing (including import) processing, and distribution of
methylene chloride for paint and coating removal for the prohibited
uses; and
     Requiring limited recordkeeping.
    Technically and economically feasible substitutes to methylene
chloride for paint and coating removal are reasonably available for the
uses proposed to be regulated. The supply chain approach ensures
protection of consumers from the unreasonable risk by precluding the
off-label purchase of commercial products by consumers.
    The proposed approach is relatively easy to enforce because key
requirements are directly placed on a small number of suppliers and
because the supply chain approach minimizes to the greatest extent the
potential for methylene chloride products to be intentionally or
unintentionally misdirected into the prohibited uses. Enforcement under
the other options would be much more difficult since the key
requirements are directly placed on the large number of product users.
As described in a recent article on designing more effective rules and
permits, ``the government can implement rules more effectively and
efficiently when the universes of regulated sources are smaller and
better-defined. This is because, other factors being equal, governments
can more easily identify, monitor, and enforce against fewer, rather
than more, entities'' (Ref. 63). Under other options, enforcement
activities must target firms that might perform the activity where a
use of methylene chloride is restricted or prohibited. Identifying
which establishments might use paint and coating removers is difficult
because paint and coating removal is not strictly specific to any
industry (Ref. 4).

VII. Costs and Monetized Benefits of the Methylene Chloride Component
of the Proposed Rule, the Alternatives EPA Considered, and Comparison
of Costs and Benefits

    EPA proposes that the identified risks from methylene chloride and
in paint and coating removal are unreasonable risks. Apart from that
proposed determination, EPA has evaluated the potential costs and
benefits of the proposed approach and alternative approaches.

A. Costs

    The details of the costs of the proposed approach for use of
methylene chloride in paint and coating removal by consumers and in
commercial uses proposed for regulation are discussed in Unit I.E. and
in the Economic Analysis (Ref. 4). Under the proposed option for
methylene chloride and the first co-proposed option for NMP, costs to
users of paint and coating removal products containing methylene
chloride are $4,217,000 to $23,436,000 annualized for 20 years at a
discount rate of 3% and $4,592,000 to $23,485,000 at a discount rate of
7%. Costs of paint and coating removal product reformulations are
estimated to be approximately $10,000 to $20,000 per year (annualized
at 3% over 20 years) and $14,000 to $24,000 (annualized at 7% over 20
years). Costs of downstream notification and recordkeeping on an
annualized basis over 20 years are $40 and $60 using 3% and 7% discount
rates respectively. Agency costs for enforcement are estimated to be
approximately $114,401 and $111,718 annualized over 20 years at 3% and
7%, respectively (Ref. 4).
    Total costs of the proposed rule relevant to methylene chloride in
paint and coating removal under the first co-proposed option for NMP
are estimated to be $4,247,000 to $23,446,000 annualized over 20 years
at 3% and $4,612,000 to $23,495,000 annualized over 20 years at 7%
(Ref. 4).
    Under the proposed option for methylene chloride and the second co-
proposed option for NMP, costs to users of paint and coating removal
products containing methylene chloride are $67,087,960 to $68,726,960
annualized for 20 years at a discount rate of 3% and $67,369,940 to
$69,006,940 at a discount rate of 7%. Costs of paint and coating
removal product reformulations, costs of downstream notification, and
Agency costs for enforcement are estimated to be the same as under the
first co-proposed option for NMP (Refs. 4 and 127).
    Total costs of the proposed rule relevant to methylene chloride in
paint and coating removal under the second co-proposed option for NMP
are estimated to be $67,098,000 to $68,747,000 annualized over 20 years
at 3% and $67,384,000 to $69,034,000 annualized over 20 years at 7%
(Refs. 4 and 127).
    Alternatives that EPA considered include the use of PPE as well as
an option that would prohibit the use of methylene chloride in paint
and coating removal for consumers and for the commercial uses proposed
for regulation without the companion prohibition on manufacture,
processing, or distribution in commerce for these uses or the
downstream notification requirements. As discussed in Unit VI.C.3., EPA
found that PPE options did not address the risks presented by methylene
chloride in paint and coating removal so that the risks would no longer
be unreasonable. This is because consumers could not be required to
adopt PPE, resulting in a significant gap in protection for consumers.
In addition, EPA also assumed that no commercial users would adopt PPE
because the per-facility costs were prohibitively expensive.
    EPA also found that a use prohibition alone without downstream
notification requirements would not address the unreasonable risks. EPA
estimated the costs of this option to be $4,239,000 to $23,442,000
annualized over 20 years at 3% and $4,604,000 to $23,491,000 annualized
over 20 years at 7% (Ref. 4).

B. Benefits

    EPA is not fully able to quantify the full monetary benefits that
would accrue from preventing all deaths due to methylene chloride in
paint and coating

removal. Similarly, EPA is not able to monetize the benefits that would
accrue from preventing non-fatal and non-cancer effects from exposure
to methylene chloride in paint and coating removal. The subset of
benefits that can be monetized from mitigating the risks from methylene
chloride in paint and coating removal for consumer uses and for the
commercial uses proposed for regulation are estimated to be $14,363,000
to $14,565,000 (annualized at 3% over 20 years) and $13,796,000 to
$13,921,000 (annualized at 7% over 20 years) (Ref. 4). Although the
alternatives considered are unlikely to result in the same health
benefits as the proposed option, EPA was unable to quantify the
differences.

C. Comparison of Benefits and Costs

    The monetized subset of benefits for preventing the risks resulting
from methylene chloride in paint and coating removal by consumers and
by commercial workers for the uses proposed for regulation do not
outweigh the estimated monetary costs. EPA believes that the balance of
costs and benefits cannot be fairly described without considering the
additional, non-monetized benefits of mitigating the non-cancer adverse
effects as well as cancer. As discussed previously, the multitude of
potential adverse effects associated with methylene chloride in paint
and coating removal can profoundly impact an individual's quality of
life. Some of the adverse effects associated with methylene chloride
exposure can be immediately experienced and can result in sudden death;
others can have impacts that are experienced for a shorter portion of
life, but are nevertheless significant in nature. While the risk of
non-cancer health effects associated with methylene chloride exposure
during paint and coating removal cannot all be quantitatively
estimated, the qualitative discussion highlights how some of these non-
cancer effects may be as severe as cancer and thus just as life
altering. These effects include not only medical costs but also
personal costs such as emotional and mental stress that are impossible
to accurately measure. Considering only monetized benefits would
significantly underestimate the impacts of methylene chloride-induced
non-cancer adverse outcomes on a person's quality of life.
    Thus, considering costs; the subset of benefits that can be
monetized (risk of cancer and risk of death in some sectors); and the
remaining benefits that cannot be quantified and subsequently monetized
(risk of nervous system effects, liver toxicity, reproductive effects,
and kidney toxicity), including benefits related to the severity of the
effects and the impacts on a person throughout a lifetime in terms of
medical costs, effects on earning power and personal costs, emotional
and psychological costs, and the disproportionate impacts on Hispanic
communities and individuals with limited English proficiency; the
benefits of preventing exposure to methylene chloride in paint and
coating removal by an estimated 1.3 million consumers and estimated
17,600 commercial workers for the uses proposed for regulation outweigh
the costs.

D. Impacts on the National Economy, Small Businesses, Technological
Innovation, the Environment, and Public Health

    As described in Unit V.B. and in the Economic Analysis, EPA
considered the anticipated effects of this proposal on the national
economy. While the impacts of this rule as a whole are described in
Unit XXIII.C. and the impacts of the methylene chloride component of
this proposal are described in more detail in Unit VII.A. and in
Section 9.3 of the Economic Analysis (Ref. 4), EPA does not anticipate
these impacts having an effect on the overall national economy. EPA
anticipates that a majority of small businesses will have cost impacts
of less than one percent of the annual revenue, and the majority of
small business bathtub refinishing facilities and professional
contractors will have cost impacts greater than one percent of annual
revenue.
    The proposed approach is anticipated to drive technological
innovation by formulators of paint and coating removal products
containing methylene chloride, as they continue to develop substitute
products, and refine such products already available. It is also
anticipated to drive technological innovation by formulators of
chemical paint and coating removal products with different chemistries
as well as manufacturers and retailers of alternative methods of paint
and coating removal. See also section 9.3 in the Economic Analysis
(Ref. 4).
    The proposed approach is anticipated to have a positive impact on
public health, as described in Unit VI.D. There is anticipated to be a
positive impact on the environment, as a result of decreased use of
methylene chloride, which is a hazardous air pollutant, as described in
Unit III.A.

VIII. Uses of Methylene Chloride for Paint and Coating Removal Critical
for National Security

    As part of interagency collaboration with the Department of Defense
(DOD) on this proposed rule, EPA is aware that there are specific
military uses for which methylene chloride is essential for paint and
coating removal and for which there are no technically feasible
alternatives currently available. The military readiness of DOD's
warfighting capability is paramount to ensuring national security,
which includes ensuring the maintenance and preservation of DOD's
warfighting assets. DOD has identified mission-critical uses for
methylene chloride for ensuring military aviation and vessel readiness.
These mission-critical items require the use of methylene chloride for
the removal of coatings from mission-critical corrosion-sensitive
components on military aviation and vessels, including safety-critical
components made of specialty metallic, nonmetallic, and composite
materials. As described in this section, EPA proposes to exempt these
uses from the regulations proposed on methylene chloride in paint and
coating removal. This exemption is proposed for an initial ten-year
period from the publication date of a final rule. EPA will engage with
DOD to identify any potential extension that may need to be granted, by
further rulemaking, after those ten years.
    DOD has actively sought to reduce its use of methylene chloride in
paint and coating removal since 1990. DOD has replaced most of its
usage of methylene chloride for paint and coating removal with
mechanical methods, benzyl alcohol products, other solvents, and laser
ablation. For instance, the Navy's Fleet Readiness Center Southwest has
undertaken a successful 20-year effort and eliminated all but a single
use on safety-critical components. In an effort to reduce the use of
all HAPs such as methylene chloride, the Army has conducted tests to
identify and test the effectiveness of HAP-free paint and coating
removers on military high-performance coatings (Ref. 61). In another
example, the Air Force in December 2015 significantly reduced the use
of methylene chloride for removing coatings on flight control parts and
is now using substitute chemical products, primarily those with benzyl
alcohol formulations (Ref. 65). This phase-out was driven by worker
safety concerns and the destructive impact the methylene chloride
product had on the installation's industrial wastewater treatment
processes. The Air Force

sought alternatives for this use of methylene chloride for paint and
coating removal in this industrial process and was successful at
qualifying an alternative that met technical requirements (Ref. 65).
    In light of these efforts to identify and adopt alternative
chemicals or methods, it is unlikely that DOD has overlooked potential
substitutes. DOD continues and will continue to pursue potential
substitutes. However, for mission-critical corrosion-sensitive
components on military aviation and vessels, including safety-critical
components, DOD has found that currently available substitute chemicals
for paint and coating removal have one or more technical limitations.
In these critical and essential applications, currently available
substitute chemicals cannot completely remove specific military high
performance or chemical resistant coatings, resulting in improperly
applied, incompletely adhering replacement coatings. The impacts of
this are early coating failure, corrosion of underlying critical parts,
shortened service life for critical components (some of which are no
longer manufactured), and reduced availability and mission readiness of
military aircraft and vessels.
    Substitute chemicals currently available are also incompatible with
underlying metallic, nonmetallic and composite materials, resulting in
material damage to critical components (e.g. hydrogen embrittlement)
creating immediate damage or longer-term susceptibility to stress
fracturing and corrosion. The impacts of this are shortened service
life for critical components (some of which are no longer
manufactured), reduced availability and mission readiness of military
aircraft and vessels, and an increased risk of catastrophic failure of
safety critical parts.
    Additionally, substitute chemicals or methods currently available
do not support the coating removal requirements of safety inspection,
non-destructive inspection, material assessment, or field repair
processes. This results in an inability to properly perform safety
inspections for critical components, leading to undetected fractures
and defects. The impacts of this are increased risk of catastrophic
failure of safety critical parts.
    Under TSCA section 6(g)(1)(B), EPA may grant an exemption from a
requirement of a TSCA section 6(a) rule for a specific condition of use
of a chemical substance or mixture if compliance with the requirement
would significantly disrupt the national economy, national security, or
critical infrastructure. Based on discussions and information provided
by DOD, EPA has analyzed the need for the exemption and concurs with
DOD that compliance with the proposed regulations on the use of
methylene chloride in paint and coating removal would significantly
impact national security. DOD has demonstrated that the reduced mission
availability of aircraft and vessels for military missions or, in the
worst case, the loss of individual military aircraft and vessels, are
potential impacts to military readiness that could result from the
proposed prohibition of methylene chloride in paint and coating
removal. Due to the importance of these military systems for national
security, EPA has determined that these uses of methylene chloride for
removal of specialized coatings from military aviation and vessel
mission-critical corrosion-sensitive components, including safety-
critical components, is critical for national security and the safety
of personnel and assets. EPA includes in this exemption corrosion-
sensitive military aviation and vessel mission-critical components such
as landing gear, gear boxes, turbine engine parts, and other military
aircraft and vessel components composed of metallic materials
(specifically high-strength steel, aluminum, titanium, and magnesium)
and composite materials that not only require their coatings be removed
for inspection and maintenance but also would be so negatively affected
by the use of technically incompatible, substitute paint removal
chemicals or methods that the safe performance of the vessel or
aircraft could be compromised.
    EPA proposes to grant this exemption for a period of 10 years from
the date of promulgation of a final rule, with a potential for
extension, by further rulemaking, after review by EPA in consultation
with DOD. The conditions for this exemption would be: (1) The use of
methylene chloride for coating removal by DOD or its contractors
performing this work only for DOD projects is limited to the mission-
critical corrosion-sensitive components on military aviation and
vessels, including safety-critical components; and (2) this paint and
coating removal must be conducted at DOD installations, at Federal
industrial facilities, or at DOD contractor facilities performing this
work only for DOD projects. This exemption granted under
TSCA(6)(g)(1)(B) does not impact or lessen any requirements for
compliance with other statutes under which the use, disposal, or
emissions of methylene chloride is regulated.
    As described in Unit VI.C.3., under the proposed approach, any
paint and coating removal products containing methylene chloride would
be required to be distributed in packaged volumes no less than 55-
gallon containers. As part of the exemption for uses identified as
critical for national security, for those formulations specifically
manufactured for DOD, suppliers may provide paint and coating removal
products containing methylene chloride to DOD in containers with a
volume no less than 5 gallons. Allowing selective use for national
security purposes does not disrupt the efficacy of the supply chain
approach described in Unit VI.C.3.
    In addition to the exemption described in this unit, EPA will
consider granting additional time-limited exemptions, under the
authority of TSCA section 6(g), for a specific condition of use for
which EPA can obtain documentation: that the specific condition of use
is a critical or essential use for which no technically and
economically feasible safer alternative is available, taking into
consideration hazard and exposure; that compliance with the proposed
rule would significantly disrupt the national economy, national
security, or critical infrastructure. To this end, EPA requests comment
on a process for receiving and evaluating petitions and requesting EPA
promulgate critical-use exemption rules. Under this process, entities
who believe that their specific condition of use is a critical or
essential use under TSCA section 6(g) would submit a petition for an
exemption rulemaking with supporting documentation that they believe
demonstrates that the use meets the statutory criteria. EPA would
review the petition for completeness and, if the documentation warrants
further action, respond to the petition by publishing a proposal in the
Federal Register inviting comment on a proposed exemption. EPA would
consider the comments received, along with any additional information
reasonably available, and then take final action on the proposed
exemption. EPA requests comment on the specific kinds of documentation
that should be required from entities seeking an exemption rulemaking
in order to facilitate EPA's and later, the public's review. EPA also
requests comment on the appropriate timeframes for EPA action, given
that the documentation for any given use could be technical and
extensive, and that EPA may also need to develop additional
information, such as economic estimates, in order to promulgate an
exemption rule under TSCA section 6(g). Finally, members of

the potentially regulated community who believe that their operation is
a critical or essential use should provide as much detail as possible
to EPA about their operation during this comment period, including
information on any evaluations of alternatives, the costs to transition
to another chemical or process, and any other relevant information.
This would assist EPA in reviewing the specific condition of use, as
well as in establishing provisions for future exemption petitions.

IX. Overview of Uncertainties for Methylene Chloride in Paint and
Coating Removal

    A discussion of the uncertainties associated with this proposed
rule can be found in the methylene chloride risk assessment (Ref. 2)
and in the additional analyses for methylene chloride in commercial and
consumer paint and coating removal (Refs. 19, 20, and 38). A summary of
these uncertainties follows.
    EPA used a number of assumptions in the methylene chloride risk
assessment and supporting analysis to develop estimates for
occupational and consumer exposure scenarios and to develop the hazard/
dose[hyphen]response and risk characterization. EPA recognizes that the
uncertainties may underestimate or overestimate actual risks. These
uncertainties include the likelihood that releases of and exposures to
methylene chloride vary from one paint and coating removal project to
the next. EPA attempted to quantify this uncertainty by evaluating
multiple scenarios to establish a range of releases and exposures. In
estimating the risk from methylene chloride in paint and coating
removal, there are uncertainties in the number of workers, bystanders,
and consumers exposed to methylene chloride and in the inputs to the
models used to estimate exposures.
    In addition to the uncertainties in the risks, there are
uncertainties in the cost and benefits. The uncertainties in the
benefits are most pronounced in estimating the benefits from preventing
deaths due to methylene chloride that have been underreported in most
commercial sectors. Additional significant uncertainties in benefits
include the entirety of prevention of the non-cancer adverse effects,
including underreported deaths (described in Unit VI.E.), because these
benefits generally cannot be monetized due to the lack of concentration
response functions in humans leading to the ability to estimate the
number of population-level non-cancer cases and limitations in
established economic methodologies. Additional uncertainties in benefit
calculations arose from EPA's use of a forecast from an industry expert
to estimate the categories of alternatives that users might choose to
adopt and the potential risks for adverse health effects that the
alternatives may pose. While there are no products or methods that have
comparable cancer or lethal risks, these substitute products and
alternative methods do present hazards. Without information on what
alternative methods or chemicals users of methylene chloride for paint
and coating removal are likely to switch to, and estimates of the
exposures for those alternatives, EPA is unable to quantitatively
estimate any change in non-cancer risks due to use of substitute
chemicals or alternative methods instead of using methylene chloride
for commercial or consumer paint and coating removal.
    Additional uncertainties include any benefits accrued by commercial
users of methylene chloride for paint and coating removal who would
benefit from using substitute chemicals and alternative processes.
These users would be able to reduce or eliminate costs incurred for
emissions control, hazardous waste disposal, or wastewater treatment,
which are all required for commercial users of methylene chloride for
any purpose.
    In addition to these uncertainties related to benefits, there are
uncertainties related to the cost estimates. As noted earlier, there is
uncertainty in EPA's estimates of which chemical substitutes or
alternative methods users may adopt instead of methylene chloride for
paint and coating removal, which in turn produces uncertainty as to the
cost of those substitutes or methods. EPA has estimated the cost of
substitute chemicals, and, in some sectors, some increase in costs due
to increased labor required by some substitute methods, but is not able
to fully characterize the total costs to all sectors for using
substitute chemicals or alternative products. It is possible that some
users with paint removal projects that require removing multiple layers
of coatings may ultimately save time by switching to a substitute
chemical that is more effective than methylene chloride for this
particular use. However, changes in time gained or lost during paint
and coating removal projects cannot be estimated for all users
potentially affected by this proposed rule. In addition, under certain
assumptions EPA's economic analysis estimates that some users of
methylene chloride for paint and coating removal will see a cost
savings when switching to substitutes. Standard economic theory
suggests that financially rational companies would choose technologies
that maximize profits so that regulatory outcomes would not typically
result in a cost savings for the regulated facilities. There could be
several reasons that cost savings might occur in the real world.
Potential reasons include lack of complete information or barriers to
obtaining information on the cost savings associated with alternatives
as well as investment barriers or higher interest rates faced by firms.
Additionally, there may be costs associated with these alternatives
that are not adequately accounted for in the analysis. To evaluate the
effect of this uncertainty, EPA has included a sensitivity analysis
that sets the cost savings to zero for these compliance alternatives
(Ref. 4 at Section 7). EPA also recognizes that these firms might
experience positive costs of compliance rather than zero costs, so that
the actual total costs could be higher than those in the sensitivity
analysis. However, EPA has no current basis to estimate these
potentially higher costs, since the available data appear to show that
there are lower cost substitutes available. EPA requests comments on
these assumptions.
    Additionally, there are uncertainties due to the estimates of the
number of affected commercial and consumer users, and for numbers of
processors and distributors of methylene chloride-containing products
not prohibited by the proposed rule who are required to provide
downstream notification and/or maintain records.
    EPA will consider additional information received during the public
comment period. This includes scientific publications and other input
submitted to EPA during the comment period.

X. Major Provisions and Enforcement of the Proposed Rule for Methylene
Chloride in Paint and Coating Removal

    This proposal relies on general provisions in the proposed Part
751, Subpart A, which can be found at 81 FR 91592 (December 16, 2016).

A. Prohibitions and Requirements

    The rule, when final, would (1) prohibit the manufacturing,
processing, and distribution in commerce of methylene chloride for
paint and coating removal for consumer uses and for all commercial uses
excluding for commercial furniture refinishing (see Unit XI.) and
exempting those defined as critical for national security (see Unit
VIII.); (2) prohibit commercial use of methylene chloride for paint and
coating removal except for commercial

furniture refinishing and for uses defined as critical for national
security; (3) require any paint and coating removal products containing
methylene chloride to be distributed in containers with a volume no
less than 55-gallons, except for formulations manufactured specifically
for the Department of Defense; (4) require manufacturers, processors,
and distributors of methylene chloride and all products containing
methylene chloride, excluding retailers, to provide downstream
notification of the prohibitions; and (5) require recordkeeping
relevant to these prohibitions. As described in Unit XI., EPA intends
to issue separately a proposal to regulate the risks presented by
methylene chloride in commercial furniture refinishing so that those
risks are no longer unreasonable; EPA intends to finalize that separate
proposal and this proposal together.
    The prohibition on manufacturing, processing, and distributing in
commerce methylene chloride for consumer paint and coating removal
would take effect 180 days after publication of a final rule.
Similarly, the prohibition on manufacturing, processing, and
distributing in commerce methylene chloride for any non-prohibited
paint and coating removal commercial uses in containers with volumes
less than 55 gallons would take effect 180 days after publication of a
final rule. The prohibition on commercial use of methylene chloride for
paint and coating removal except in furniture refinishing or for
critical national security uses would take effect 270 days after
publication of a final rule. These are reasonable transition periods
because, as noted in Unit VI.E. and by the small businesses
participating in the SBAR process, many formulators of paint and
coating removers containing methylene chloride also manufacture
products for this use that do not contain methylene chloride (Ref. 27).
In addition, alternative paint removal products exist at comparable
expense for users to purchase. Six months from publication of the final
rule is sufficient time to allow for existing stocks to move through
the market place and to allow manufacturers, processers and
distributors and users to plan for and implement product substitution
strategies.

B. Downstream Notification

    EPA has authority under TSCA section 6 to require that a substance
or mixture or any article containing such substance or mixture be
marked with or accompanied by clear and adequate minimum warnings and
instructions with respect to its use, distribution in commerce, or
disposal or with respect to any combination of such activities. Many
manufacturers and processors of methylene chloride are likely to
manufacture or process methylene chloride or products containing
methylene chloride for other uses that would not be regulated under
this proposed rule. Other companies may be strictly engaged in
distribution in commerce of methylene chloride, without any
manufacturing or processing activities, to customers for uses that are
not regulated. EPA is proposing a requirement for downstream
notification by manufacturers, processors, and distributors of
methylene chloride for any use to ensure compliance with the
prohibition on manufacture, processing, distribution in commerce, and
commercial use of methylene chloride for the uses proposed for
regulation. Downstream notification is necessary for effective
enforcement of the rule because it provides a record, in writing, of
notification on use restrictions throughout the supply chain, likely
via modifications to the Safety Data Sheet. Downstream notification
also increases awareness of restrictions on the use of methylene
chloride for paint and coating removal, which is likely to decrease
unintentional uses of methylene chloride by these entities. Downstream
notification represents minimal burden and is necessary for effective
enforcement of the rule. The estimated cost of downstream notification
on an annualized basis over 20 years is $40 and $60 using 3% and 7%
discount rates respectively (Ref. 4).
    The effective date of the requirement for this notification would
be 45 days after publication of the final rule. This is a reasonable
transition period because regulated entities would only need to provide
additional information on their SDS, which are routinely produced and
updated.

C. Enforcement

    Section 15 of TSCA makes it unlawful to fail or refuse to comply
with any provision of a rule promulgated under TSCA section 6.
Therefore, any failure to comply with this proposed rule when it
becomes effective would be a violation of section 15 of TSCA. In
addition, section 15 of TSCA makes it unlawful for any person to: (1)
Fail or refuse to establish and maintain records as required by this
rule; (2) fail or refuse to permit access to or copying of records, as
required by TSCA; or (3) fail or refuse to permit entry or inspection
as required by section 11 of TSCA.
    Violators may be subject to both civil and criminal liability.
Under the penalty provision of section 16 of TSCA, any person who
violates section 15 could be subject to a civil penalty for each
violation. Each day in violation of this proposed rule when it becomes
effective could constitute a separate violation. Knowing or willful
violations of this proposed rule when it becomes effective could lead
to the imposition of criminal penalties for each day of violation and
imprisonment. In addition, other remedies are available to EPA under
TSCA.
    Individuals, as well as corporations, could be subject to
enforcement actions. Sections 15 and 16 of TSCA apply to ``any person''
who violates various provisions of TSCA. EPA may, at its discretion,
proceed against individuals as well as companies. In particular, EPA
may proceed against individuals who report false information or cause
it to be reported.

XI. Furniture Refinishing (Methylene Chloride)

    At this time, following input from small entity representatives
received during the SBAR process, and based on the SBAR panel
recommendations, EPA is not proposing to regulate methylene chloride
when used in paint and coating removal in commercial furniture
refinishing, also referred to as professional furniture refinishing
(Ref. 27). Although EPA proposes to determine that risks to workers
using methylene chloride for commercial furniture refinishing are
unreasonable, EPA is seeking additional information about this industry
to inform development of future proposed restrictions on methylene
chloride in commercial furniture refinishing.

A. Description of Commercial Furniture Refinishing

    Commercial furniture refinishing consists of several processes,
including but not limited to repair, reupholstery, repainting, and
depainting or removing paints and coatings, sometimes referred to as
furniture stripping. EPA has defined furniture stripping as paint and
coating removal from furniture; it includes application of a chemical
or use of another method to remove, loosen, or deteriorate any paint,
varnish, lacquer, graffiti, surface protectants, or other coating from
wood, metal, or other types of furniture, doors, radiators, or
cabinets. Furniture stripping can be conducted separately or as a part
of furniture refinishing. EPA has defined commercial furniture
stripping as furniture stripping conducted in a commercial facility
performed by an

individual, government entity, or company for which an individual,
government entity, or company receives remuneration or other form of
payment.
    As described in the methylene chloride risk assessment, to carry
out furniture stripping, or to remove paint, lacquer, varnish, or other
coatings from wood or metal furniture (or similar items such as doors,
radiators, and cabinets), chemical paint and coating removal products
may be applied to the furniture by either dipping the furniture in an
open tank containing the chemicals, brushing or spraying the product
onto the furniture surface, or manually applying the chemical product
with a brush, rag, or aerosol spray. Larger furniture refinishing
facilities conducting furniture stripping may pump the chemical product
through a brush. The application method depends on the size and
structure of the furniture as well as the capabilities of the facility
(Ref. 2). Some firms may use alternative methods of paint and coating
removal, such as sanding or heat/thermal guns, but EPA's information to
date indicates that paint and coating removal on furniture is primarily
conducted with chemical removers (Refs. 22, 27, 31, 66 and 27).
    The area where furniture refinishing workers conducting furniture
stripping apply paint and coating removal chemicals typically has a
sloped surface to allow for collection and recycling of unused chemical
product. Larger facilities use a flow tray to apply the paint and
coating removal product or chemical to parts. The flow tray is a
sloped, shallow tank with a drain at the lower end. Some facilities may
use a dip tank to immerse whole pieces or parts of furniture in the
chemical product (Refs. 2 and 22).
    After a worker applies the chemical product or immerses the piece
of furniture in it, the paint and coating remover is left to soak, or
``dwell,'' on the furniture surface to soften the paint, coating, or
varnish. Once soaking is complete, a worker manually scrapes or brushes
the unwanted coating from the furniture surface. The worker then
transfers the furniture to a washing area where they wash the waste
chemical and paint or coating sludge from the furniture. Workers can
wash the treated furniture with low-pressure washing operations or
high-pressure water jets or high-pressure wands. Wash water may contain
oxalic acid to brighten the wood surface. Wash water is collected and
either recycled or disposed of as waste. After washing, the worker
transfers the furniture to a drying area where it is allowed to dry
before being transferred to other refinishing processes (e.g., sanding,
painting, reupholstery) (Ref. 2).
    Based on industry research and discussions with stakeholders, EPA
is aware that most commercial furniture refinishing firms primarily use
chemical methods for paint and coating removal, and that methylene
chloride or methylene chloride-based products are the types of chemical
paint removers primarily and, in some firms, exclusively, used. Some
commercial furniture refinishers, including some small businesses
participating in the SBAR process, have said that although they make
limited use of acetone for some types of furniture, they have not found
any workable substitutes for methylene chloride as a primary paint and
coating removal method (Refs. 22 and 27). More information on the
potential use of substitutes for furniture refinishing is provided in
Unit XI.E.

B. Risks Associated With Furniture Refinishing

    The methylene chloride risk assessment and additional supplemental
analyses identified acute and chronic risks from inhalation of
methylene chloride during paint and coating removal by consumers,
commercial users, and bystanders in residences or workplaces
(individuals not using the paint and coating remover but nearby a user)
(Refs. 2, 19, 20, and 38). This includes an assessment of the risks
from methylene chloride when used in commercial furniture refinishing.
EPA estimates that, annually, there are approximately 15,000 workers at
4,900 commercial refinishing operations conducting paint and coating
removal with methylene chloride (Ref. 4).
    1. Exposures assessed to methylene chloride during commercial
furniture refinishing and immersion stripping. Exposures assessed for
workers in commercial furniture refinishing include acute and chronic
exposures to methylene chloride for paint and coating removal, as
described in the methylene chloride risk assessment (Ref. 2). The
exposure pathways of interest included dermal contact and inhalation,
but, due to limitations described in the risk assessment, the
assessment was based only on the inhalation route of exposure.
Different exposure scenarios were evaluated for workers, occupational
bystanders, consumers, and residential bystanders (Ref. 2). Not
included in the assessment but important to note are bystanders in
commercial refinishing operations that are located in workshops or
other parts of residences; here, the bystanders may include not only
workers but also children and occupants of the home.
    In addition to estimating likely exposures under current use
patterns, for both commercial and consumer users, EPA assessed a number
of exposure scenarios associated with risk reduction options in order
to identify variations in methylene chloride exposure during paint and
coating removal. All variations in the scenarios were applied to
industry-specific exposure inputs and evaluated with exposure
parameters that were modified to reflect either a reasonable worst-case
scenario (also called the baseline) or a scenario in which exposures
were moderated by several factors (also called the central tendency
scenario). The risk reduction options varied between scenarios and
included engineering controls and use of personal protective equipment
(PPE), as well as combinations of these options (Ref. 19).
     Under the PPE risk reduction option exposure scenarios,
EPA evaluated respirators with APF 10 to 10,000 for acute and chronic
risks, including cancer risks.
     For the engineering controls risk reduction option
exposure scenarios, EPA evaluated using local exhaust ventilation (LEV)
to improve ventilation near the activity of workers in furniture
refinishing operations, with an assumed 90% reduction in exposure
levels.
    Overall, EPA evaluated several distinct exposure scenarios for
paint and coating removal with methylene chloride for commercial
furniture refinishing. Additionally, EPA evaluated several distinct
exposure scenarios for miscellaneous paint and coating removal
conducted by immersion of the object in vats or tanks of methylene
chloride (dip methods), since this has been reported as a method of
paint and coating removal during furniture refinishing (Refs. 19 and
27).
    The results of these evaluations of exposure scenarios demonstrate
that the scenarios meeting all relevant health benchmarks for all
scenarios of methylene chloride in paint and coating removal in
commercial furniture refinishing requires: (1) A respiratory protection
program using a supplied-air respirator with APF of 1,000 or 10,000,
depending on type of method used for applying methylene chloride or
workplace characteristics, such as the size of the facility; (2)
reducing exposures with LEV that can achieve 90% efficiency in air flow
plus worker respiratory protection with APF 1,000; or (3) elimination
of exposure to methylene chloride by using an alternative method of
paint and coating removal (Ref. 19). Although non-cancer risks and
cancer risks were estimated using separate measures, exposure

reduction that is protective against non-cancer risks from methylene
chloride is also protective against cancer risks.
    2. Risks assessed from methylene chloride during commercial
furniture refinishing and immersion methods. Exposure to methylene
chloride is associated with death, neurotoxicity, liver toxicity, and
cancer in humans and animals. To estimate non-cancer risks for acute
and chronic exposures, the methylene chloride risk assessment used
MOEs. Exposure scenarios with MOEs below the benchmark MOE have risks
of concern, as explained in detail in the methylene chloride risk
assessment. For acute and chronic exposure scenarios, the benchmark MOE
is 10 (Ref. 2). The benchmark MOE identifies a risk of concern for a
given endpoint; it is obtained by multiplying the total uncertainty
factors associated with each health endpoint's point of departure. For
more information on uncertainty factors, see Unit IV.B.
    The acute inhalation risk assessment used central nervous system
effects to evaluate the acute risks for occupational, consumer, and
bystander exposure during paint and coating removal with methylene
chloride. A risk of concern was identified if the MOE estimate was less
than the benchmark MOE of 10 (Ref. 2).
    EPA assessed acute risks for central nervous system effects from
inhalation for workers using methylene chloride for commercial
furniture refinishing and for immersion methods of paint and coating
removal for various objects, including furniture. Acute risks were
estimated in this sector, even in the presence of respirators with APF
10 or APF 25. MOEs for acute risks in commercial furniture refinishing
ranged from a central tendency of 0.08 to 0.035, with a high end of
0.0063 (workplaces engaged in paint and coating removal using immersion
methods). In general, these workplaces are estimated to present
exposure levels between 125 times to greater than 1,500 times more than
those that are expected to produce no risks of concern. Not only
workers, but also occupational bystanders, or workers engaged in tasks
other than paint and coating removal, would be at acute risk for
central nervous system effects.
    EPA also assessed risks of chronic exposure to workers using
methylene chloride for commercial furniture refinishing. The methylene
chloride risk assessment used liver toxicity as the critical endpoint
for chronic exposure. The selected exposure scenarios represented
inhalation exposures with a range of conservative assumptions. As
described earlier, the assumptions were then varied, such as use of PPE
(supplied-air or other respirator) and duration of time spent in
contact with the product (days and years). EPA assessed risks for liver
toxicity (with effects that include vacuolation and fatty liver) for
occupational and bystander exposure scenarios of paint and coating
removal with methylene chloride.
    Workers and occupational bystanders in this industry were estimated
to be at risk of non-cancer liver toxicity as a result of chronic
exposure to methylene chloride during paint and coating removal under
typical exposure scenarios. When workers' exposures were estimated at
facilities repeatedly reporting moderate or high methylene chloride air
concentration levels, EPA estimated that there were risks of concern
for these workers, even for scenarios evaluated with workers wearing
respiratory protection with APF 50. Among all of the occupational
scenarios, the greatest risk of concern is for workers engaging in
long-term use of the product (i.e., 250 days/year for 40 years) with no
respiratory protection. For those workers, MOEs for chronic exposures
were 0.025, or reflective of risks 400 times greater than the
benchmark. Even for workers assumed to have lower exposure, MOEs did
not reach 10. In most workplaces engaged in commercial furniture
refinishing, MOEs for chronic exposure ranged from a central tendency
of 0.60 to 0.3. Additionally, in EPA's risk assessment scenarios, which
are not necessarily reflective of industry-wide work practices, for
workers and bystanders assumed to have the lowest exposure (respirator
APF 50, limited exposure duration, and moderate air concentration),
MOEs for chronic exposure were 5, or one-half of the benchmark (Ref.
2).
    For commercial users and bystanders, EPA also assessed cancer risks
as a result of chronic exposure to methylene chloride in paint and
coating removal in commercial furniture refinishing. Methylene chloride
is a likely human carcinogen; cancer risks determine the incremental
increased probability of an individual in an exposed population
developing cancer over a lifetime following exposure to the chemical
under specified use scenarios. Common cancer benchmarks used by EPA and
other regulatory agencies are an increased cancer risk of one in one
million or one in ten thousand (i.e., 1 x 10-\6\ or 1 x
10-\4\). Estimates of cancer risk should be interpreted as
the incremental increased probability of an individual in an exposed
population developing cancer over a lifetime as a result of exposure to
the potential carcinogen (i.e., incremental or excess individual
lifetime cancer risk) (Ref. 2).
    In the methylene chloride risk assessment, when exposure for
workers and occupational bystanders was estimated in facilities
conducting commercial furniture refinishing, EPA identified excess
cancer risks if these workers and bystanders were exposed to paint and
coating removal with methylene chloride for 250 days per year for 40
years with no respiratory protection. Cancer risks ranged from 2 in
10,000 to 8 in 10,000, with a maximum of 5 in 1,000 (workplaces using
immersion methods) (Ref. 2).
    For commercial users and occupational bystanders in commercial
furniture refinishing, acute and chronic risks were assessed based on
the typical occupational exposure parameters, which may include several
hours per day of exposure over several years of work. For these
reasons, any risk mitigation measures must address not only acute
risks, but also chronic risks, including both cancer and non-cancer
effects. For these reasons, the most sensitive endpoint for risk
mitigation must be considered, whether it derives from acute or chronic
exposure.
    3. Impacts of the exposures. As discussed for other commercial uses
in Unit VI.E., exposure to methylene chloride in paint and coating
removal, when conducted in commercial furniture refinishing and for
other purposes, is associated with a range of adverse health effects,
which include impacts on the nervous system, liver, respiratory system,
kidneys, and reproductive systems. In some instances, these effects may
appear relatively mild, such as dizziness, which occurs early in
exposure and at low exposure levels. However, with increasing levels of
exposure or increasing duration, these effects can take the form of
generally irreversible health effects such as cognitive impairment,
sensory impairment, coma, heart failure, liver toxicity, brain cancer,
liver cancer, non-Hodgkin lymphoma, and multiple myeloma.
    Acute exposure to methylene chloride during paint and coating
removal can be fatal; since 1980, at least seven workers have died
while using methylene chloride for commercial furniture refinishing.
Data from OSHA indicate that the circumstances of death vary. For
example, some workers collapse while conducting paint and coating
removal over or near dip tanks, frequently falling into the tanks and
subsequently dying. This was the case in 1985 in Pennsylvania, 1986 in
Colorado, 1990 in Connecticut, and

2000 in Pennsylvania (Ref. 7). The worker in Connecticut earlier
complained that the vapors were making him dizzy, and shortly after
slumped into the dip tank and died; the worker in 2000 in Pennsylvania
was found face-down in the dip tank next to the shutters from which he
was attempting to remove paint (Ref. 7). Other workers in commercial
furniture refinishing facilities lose consciousness at their workplace,
but die sometime later, such as a worker in 1991 in Colorado, and in
1999 in Tennessee (Ref. 68).
    These are likely not the only deaths in commercial furniture
refinishing due to methylene chloride; as discussed in Unit VI.E., many
deaths due to methylene chloride have not been recorded due to a lack
of reporting to the OSHA incident database by self-employed individuals
and the likelihood that deaths due to methylene chloride exposures are
misattributed to heart disease, since the pathology is similar (Ref.
33).
    In addition to fatalities, methylene chloride exposure during
commercial wood refinishing has caused acute effects, such as the 1996
case of a cabinet manufacturer employee who experienced chronic
headaches found to be due to methylene chloride exposure when the doors
at his facility were closed in the winter months (Ref. 69).
    In most commercial furniture refinishing facilities using methylene
chloride for paint and coating removal, worker and occupational
bystander exposure concentrations are orders of magnitude above what
would be necessary to achieve the benchmark MOE of 10 for acute and
chronic non-cancer effects. For acute health effects such as nervous
system impacts, EPA estimated an MOE of 0.08 for workers in commercial
furniture refinishing. For chronic non-cancer health effects such as
liver toxicity, workers in this industry have an MOE of 0.6 to 0.3
(Ref. 2). For a description of MOEs and their use in risk assessment,
see Unit IV.B.
    In each case, workers in commercial furniture refinishing using
methylene chloride for paint and coating removal are exposed at a level
that is generally 125 to 1,500 times higher than what EPA has found to
be a level that would not present acute or chronic non-cancer risks of
concern. These risks of concern are for effects such as death, multiple
adverse chronic health effects, and the subsequent lifetime impacts
from these effects. Additionally, individuals occupationally exposed to
methylene chloride in paint and coating removal may also be impacted by
an increased risk for several types of cancer. The cancer risks to
workers in commercial furniture refinishing using methylene chloride
for paint and coating removal range from 8 cases in 10,000 people to 5
cases in 1,000 people (workplaces using immersion methods) (Ref. 2).
    EPA's risk estimates are corroborated by research conducted
independently investigating working conditions at commercial furniture
refinishing and OSHA enforcement of their methylene chloride standard.
In 1990, as a result of several cases of methylene chloride poisoning
during paint and coating removal in commercial furniture refinishing in
Colorado, occupational medicine specialists from the University of
Colorado surveyed the 21 small shops in the Denver area engaged in
commercial furniture refinishing. These researchers found that of the
21 shops, no workers wore respirators at all in seven shops, and in 14
facilities, workers occasionally wore half-face respirators with
organic vapor cartridges (which do not provide respiratory or eye
protection from methylene chloride). In ten of the 21 shops, workers
experienced acute nervous system effects, such as dizziness or nausea
while working to remove coatings from furniture. The researchers
concluded that ``current safety practices in small-scale furniture-
stripping shops may be inadequate to keep methylene chloride exposure
levels in compliance with latest recommendations, and serious or fatal
overexposure can occur'' (Ref. 70).
    When considering the benefits of preventing exposure to methylene
chloride in paint and coating removal in commercial furniture
refinishing, EPA considered the type of effect, the severity of the
effect, the duration of the effect, and costs and other impacts of the
health endpoint. The health endpoints associated with exposure to
methylene chloride are serious. Unit VI.E. presents a detailed
discussion of the impacts of the most significant acute, chronic non-
cancer, and cancer effects associated with methylene chloride exposure
during paint and coating removal, including the severity of the effect,
the manifestation of the effect, and how the effect impacts a person
during their lifetime. These effects include nervous system effects
resulting from acute exposures, such as sensory impairment,
incapacitation (loss of consciousness), and death; and effects
resulting from chronic, occupational exposures including liver toxicity
and liver cancer, hematopoietic cancers, brain cancer, lung cancer,
reproductive effects, and kidney toxicity.
    There are increased risks of death, nervous system effects, and
liver, lung, brain, reproductive, and kidney effects for the
approximately 15,000 workers in 4,900 commercial facilities or
companies that use methylene chloride for paint and coating removal
during commercial furniture refinishing each year (Ref. 4).

C. Approaches That Could Reduce the Risks of Methylene Chloride Used in
Furniture Refinishing to Benchmark Levels

    Although EPA is not proposing to regulate the use of methylene
chloride in paint and coating removal for commercial furniture
refinishing, EPA has identified potential requirements for methylene
chloride in paint and coating removal for commercial furniture
refinishing that could reduce exposures so that the risks presented
would no longer be unreasonable. EPA is providing advanced notice of
these potential approaches and is seeking comment on them.
    1. Prohibition on manufacturing, processing, distribution, and use
of methylene chloride in commercial furniture refinishing. Similar to
the approach proposed for regulation of methylene chloride in other
commercial paint and coating removal (see Unit V.), EPA has identified
a prohibition on manufacturing, processing, distribution, and use of
methylene chloride in commercial furniture refinishing as an option for
reducing risks in this industry to benchmark levels, under TSCA
sections 6(a)(2) and 6(a)(5). This approach could also require
manufacturers, processors, and distributors to provide downstream
notification of the prohibitions under TSCA section 6(a)(3), and could
require recordkeeping relevant to these prohibitions under TSCA section
6(a)(4).
    Under this approach, exposures to methylene chloride during paint
and coating removal in commercial furniture refinishing would be
completely eliminated. As a result, not only non-cancer risks, but also
cancer risks would be eliminated.
    2. Requiring a respiratory protection program, including PPE, air
monitoring, and either a supplied-air respirator of APF 1,000 or 10,000
or an air exposure limit of 1 part per million (ppm) achieved through
engineering controls or ventilation, in commercial facilities for
furniture refinishing using methylene chloride for paint and coating
removal under TSCA section 6(a)(5). Another regulatory approach that
EPA has considered for the use of methylene chloride for paint and
coating removal in commercial furniture refinishing would be to require
risk reduction through an occupational respiratory

protection program, which would include air monitoring, medical
monitoring, and respiratory protection through use of a supplied-air
respirator with an APF of 1,000 or 10,000, depending on the methods
used for paint and coating removal with methylene chloride and other
workplace characteristics, with a performance-based option of meeting
an air concentration level of 1 ppm as an exposure limit for methylene
chloride.
    A full-face (or helmet/hood) self-contained breathing apparatus
(SCBA) when used in the pressure demand mode or other positive pressure
mode has an APF of 10,000. EPA's analysis found that use of a SCBA with
an APF of 10,000 would, in all scenarios evaluated, control the
methylene chloride exposure to levels that allow for meeting the
benchmarks for non-cancer and cancer risks. In some commercial
furniture refinishing facilities using methylene chloride for paint and
coating removal, workers with a supplied-air respirator with an APF of
1,000 would experience reduced exposures to methylene chloride such
that their risks would be reduced to benchmark levels (Ref. 19). It is
important to note that current OSHA requirements for dermal and eye
protection when using methylene chloride in any way would be maintained
under this approach, in addition to other requirements for work
practices, training, and hazard communication put forth in OSHA's
Methylene Chloride Standard (29 CFR 1910.1052).
    EPA seeks comment on whether commercial furniture refinishing
operations have these types of respiratory protection programs in
place, any experiences in complying with the current OSHA methylene
chloride standard, methods of reducing costs associated with these
programs, and recommended approaches for small businesses considering a
respiratory protection program that would include supplied-air
respirators.
    EPA also considered requiring a combination of local exhaust
ventilation and respirators with APF of 1,000 or 50, with a
performance-based option of an air exposure limit of 1 ppm as an eight-
hour TWA. When properly executed, this option would reduce risks to the
health benchmarks for workers and bystanders (Refs. 19 and 38).
However, while this option has the benefit of incorporating engineering
controls and the use respirators with a lower APF, the limitations to
successful implementation of the use of supplied-air respirators in the
workplace discussed previously are still present.
    Further, this option would also require the use of prescriptive and
expensive engineering controls to ensure that the exposures are below
the benchmark cancer risks (Ref. 19). In an examination of the impacts
of its methylene chloride standard, OSHA in 2010 found that furniture
refinishing facilities in particular have not installed ventilation
systems that would lower worker exposures to methylene chloride (Ref.
68). OSHA's assessment found that this is largely due the fact that
most of these facilities are part of small businesses, and they tend to
be less able to have sufficient capital to purchase the ventilation
systems. Additionally, this type of ventilation requires make-up air
systems, which have an additional cost and which, in cold climates,
would need to heat the air and thus increase energy costs (Ref. 68).
    Even if these engineering controls were installed, research
conducted by the National Institutes of Occupational Safety and Health
(NIOSH), as well as independent researchers, has indicated that
ventilation alone is generally not able to reduce methylene chloride
exposures below 25 ppm (Refs. 68 and 71), and there is no indication
that a level close to 1 ppm (an acceptable exposure limit) could be
reached.
    3. Approaches that do not mitigate the risks of methylene chloride
in commercial furniture refinishing to benchmark levels. As described
in Units IV.B. and IV.C., EPA evaluated dozens of distinct exposure
scenarios across consumer and commercial uses of methylene chloride for
paint and coating removal, including in commercial furniture
refinishing. The results of EPA's evaluation indicate that regulatory
approaches for occupational exposures in commercial furniture
refinishing such as reducing the concentration of methylene chloride in
products used for paint and coating removal and using local exhaust
ventilation to improve ventilation, in the absence of PPE, could not
achieve the target MOE benchmarks for non-cancer endpoints for acute
and chronic exposures and standard cancer risk benchmarks for chronic
exposures (Refs. 26 and 29). The results also demonstrate that all risk
reduction options meeting the benchmark MOEs and cancer benchmarks for
methylene chloride in paint and coating removal in commercial furniture
refinishing require the use of a supplied-air respirator, whether used
alone or in conjunction with additional levels of protection.
Therefore, EPA found that setting a maximum concentration of methylene
chloride in products under section 6(a)(2) could not reduce exposures
so that risks from paint and coating removal with methylene chloride in
commercial furniture refinishing would be reduced to benchmark levels.
Options found not to meet the risk benchmarks are documented in EPA's
supplemental technical reports on methylene chloride in paint and
coating removal (Refs. 19, 20, 21, and 38).

D. Costs of EPA's Potential Approach for Regulation

    EPA is at this time seeking additional information to inform its
consideration of the reasonably ascertainable economic consequences of
an action that would address the risks of commercial furniture
refinishing so that they are no longer unreasonable, as required under
TSCA section 6(c)(2)(A)(iv). This section presents the information EPA
currently has and identifies the information that EPA is seeking. While
the costs of potential risk management actions are not a legally
permissible basis for EPA to reassess its proposed unreasonable risk
determination, see TSCA section 6(b)(4)(A), costs are relevant to
deciding among alternative risk management approaches that reduce risk
so that a chemical substance no longer presents unreasonable risk and
in establishing compliance dates for a risk management approach that is
ultimately selected.
    1. Information available to EPA. Based on industry research and
information provided by stakeholders, including during informal
discussions and more formally from small entity representatives
participating in the SBAR process (described in more detail in Unit
XXIII.), EPA has learned that there may not be any substitute chemicals
or alternative practices frequently in use for paint and coating
removal in commercial furniture refinishing other than chemical paint
and coating removal with methylene chloride (Refs. 22 and 27).
    Primary chemical substitutes for methylene chloride in commercial
paint and coating removal more generally include products formulated
with benzyl alcohol; dibasic esters; acetone, toluene, and methanol
(ATM); and caustic chemicals. These substitute chemicals, their
hazards, and their environmental impacts are described in more detail
in Unit VI.E. EPA has learned that these chemicals are generally not
suitable for paint and coating removal in furniture refinishing since
they either are ineffective at removing particular coatings frequently
found on furniture (such as varnish, lacquer, or older paint
formulations in multiple layers); are formulated to include large
amounts of water and thus

incompatible with wood objects that can become saturated and damaged
(as is the case with many products containing benzyl alcohol); or are
chemically incompatible with wood and can result in damage or raising
the grain on the object (as is the case with caustic paint and coating
removal products) (Refs. 22 and 27). Products that may be chemically
compatible with wood substrates or the paints, varnishes, or lacquers
to be removed were described by stakeholders as requiring too long a
dwell time to be efficacious for their business and thus are not used
(Refs. 22 and 27). Other than two commercial furniture refinishers who
remove paints and coatings on some solid wood objects with either
immersion in 100% acetone or an acetone-toluene-methanol blend, no
commercial wood finishing firms reported using substitute chemicals
routinely for paint and coating removal, and none felt they were able
to completely eliminate use of methylene chloride, despite being aware
of the worker health and environmental impacts (Refs. 22 and 27).
    In addition to substitute chemical products, EPA has identified
non-chemical methods for commercial paint and coating removal that can
be used more generally as alternatives to methylene chloride.
Frequently-used alternative methods to chemical paint and coating
removal include thermal removal, sanding, hydroblasting, abrasive
blasting, and laser removal (Refs. 22 and 27). These methods are
already frequently in use in various industries for paint and coating
removal (Refs. 22, 27, and 31); they and their acute and chronic
hazards to workers are described in more detail in Unit VI.E.
    For commercial furniture refinishing, EPA has learned that all
firms engage in varying amounts of mechanical or hand-sanding but do
not consider it a primary method of paint and coating removal (Refs. 22
and 27). Additionally, despite the hand scraping or brushing that is
required to remove waste paint from furniture and other objects for
which methylene chloride has been used to remove paint or coatings,
most stakeholders described sanding as too time consuming or labor
intensive to use routinely as a primary method of paint and coating
removal. Additionally, though many other commercial sectors have
adopted various soft media blasting techniques for delicate substrates,
such as using soda blasting on fiberglass vehicle parts, EPA has not
found this to be a practice used in commercial furniture refinishing
(Refs. 22 and 27).
    EPA is seeking additional information to inform its consideration
of the impacts on commercial furniture refinishing if use of methylene
chloride as a paint and coating remover were prohibited or restricted.
    2. Information sought. To aid in identifying the economic impacts
on commercial furniture refinishers of any potential prohibition or
restriction on methylene chloride for paint and coating removal, EPA is
seeking the following information related to the approach that would
prohibit the use of methylene chloride for paint and coating removal in
furniture refinishing:
     What percent of business for firms in this sector is paint
and coating removal, versus furniture repair, reupholstery, or other
furniture refinishing functions?
     How likely is it that firms in this sector would close if
methylene chloride were prohibited from use in paint and coating
removal in this sector?
     What would the impact be on this sector if all firms were
prohibited from using methylene chloride for paint and coating removal,
and thus any changes in work processes or dwell time would be
universally experienced?
     Have firms had any success with substitute chemicals or
alternative methods of paint and coating removal? If not, which aspects
of the chemical or method renders the substitute or alternative
ineffective?
    Related to the approach that would require a respiratory protection
program, including either a supplied-air respirator with either APF
1,000 or APF 10,000, or engineering controls or ventilation to reach an
exposure limit of 1 ppm:
     What is the current experience of firms in this sector
with supplied-air respirators and/or engineering controls?
     What is the current experience of firms in this sector
with ventilation systems, makeup-air systems, and other engineering
controls?
     What types of exposures do workers in firms in these
sectors currently experience?
    EPA has found that commercial furniture refinishing primarily uses
methylene chloride for paint and coating removal and that no current
chemical substitutes are seen as useful alternatives. However, in
recent decades, substitute products have been developed for other types
of paint and coating removal, and it is possible that new substitute
chemicals or products could be developed to address the special
coatings or substrates involved in commercial furniture refinishing.
Several formulators and research organizations are exploring
possibilities for efficacious and cost-effective substitute chemicals.
    Additionally, outside of the United States, commercial furniture
refinishers have adopted methods that are alternatives to chemical
paint and coating removal. For example, most paint and coating removal
in Sweden is conducted by thermal methods, such as heat guns or heat
lamps, including for commercial furniture refinishing (Ref. 72). In
Denmark, firms engaging in commercial furniture refinishing are
reported to use large microwave furnaces, which can hold large pieces
of furniture (Ref. 73).
    These alternative methods and the research into substitute
chemicals indicate that it is now and in the future may increasingly be
possible to remove paint and coatings from furniture without methylene
chloride. If that were the case, EPA would be able to more
straightforwardly identify the costs and impacts of any proposed
regulation of methylene chloride for paint and coating removal in
commercial furniture refinishing. EPA is seeking additional information
on the use and development of substitute chemicals and alternative
methods that would be useful in commercial paint and coating removal on
furniture, including information on:
     What are the current considerations when selecting a paint
and coating removal chemical for furniture refinishing or refinishing
of other wood objects or surfaces?
     What are the current considerations when selecting a paint
and coating removal method for furniture refinishing or refinishing of
other wood objects or surfaces?
     Are there substitute chemicals or alternative methods in
use beyond what EPA has identified in this notice?
     Are any new paint and coating removal product formulations
or chemistries under development?
     Are any new paint and coating removal methods in
development for furniture refinishing, or refinishing of other wood
objects or surfaces?

E. Public Engagement To Identify Impacts and Alternatives

    To learn more about paint and coating removal in furniture
refinishing, foreseeable impacts of any proposed regulations, and
alternatives to methylene chloride, EPA plans to hold a series of
stakeholder meetings. These meetings will focus on current practices