Changing Your Parts Cleaning Process to Meet New EPA Rules

Tim Pennington: Let’s discuss the recent announcement by the EPA on changes regarding what will be allowed regarding cleaning processes.

Jeff DavisJeff Davis: I initially planned on going through the updates that we’ve seen on all the different solvents, whether it be chlorinated, fluorinated, brominated, and where things stand currently. But I think what has happened most recently is we had the EPA administrator announce that for trichloroethylene, or TCE, there was going to be a comment period in trying to curb the amount of usage, eliminate as best they could the use of trichloroethylene in consumer and industrial applications.

Most recently, the EPA sent through a plan to eliminate trichloroethylene in all applications without exception. Now, they’re saying they would typically give people a year to change to something else or eliminate the use of trichloroethylene. But there will be some industrial, commercial, and federal applications — whether it be military or things like that — related to electric vehicles or whatever that may have an extended period to make changes.

I think it’s going to be something that they’ll continue to put more and more pressure on some of these solvents, and trichloroethylene is just the one that is most current and the most recent updates and elimination, if you will, that we’ve seen in the last probably two or three years.

TP: This is something that everybody expected. And I know you all have been trying to educate people about losing some of these things they have been using. 

Jeff Davis: The Toxic Substance Control Act in 2016 identified ten potentially hazardous chemicals. The ones of most note are the classification of chlorinated solvents as trichloroethylene perchloroethylene or PCE and methylene chloride or MEC. Those, along with N-Propyl bromide or 1-Bromyl propane, which is a brominated solvent in the same family as the chlorides, are all under EPA’s evaluation of what they call unreasonable risk to human health. That’s typically been the purview of OSHA. And now we see that OSHA always regulated worker safety over an 8-hour time-weighted average.

Now the EPA is saying these solvents are an unreasonable risk to human health. So, they’ve proposed what they’re calling Existing Chemical Exposure Limits over eight hours, and they’re significantly reduced from where they have been from OSHA, who will take the lead from the American Conference of Industrial Hygienists for exposure levels. So historically, for instance, trichloroethylene’s most recent threshold limit value for 8-hour exposure is 25 parts per million. The EPA’s ECEL brings it down to 0.004 parts per million, which is almost unattainable. And we will see similar classifications for all four of those brominated or chlorinated solvents.

What we’re seeing is probably the elimination in the not-too-distant future of the use of these chemicals in open-top degreasers. That means there’s a larger air solvent interface; even if they’ve got refrigeration, programmable hoists, or automatic closures, those are not emissions or airless machines, so they are exposed to the environment. I don’t see how they will achieve any of those thresholds in any equipment, quite honestly, including the open-tops.

EPA Accelerating Cleaning Changes

TP: You mentioned OSHA, EPA, and a couple of other groups and regulations. They all move in different ways sometimes, but it does seem like the EPA has accelerated this action.

Jeff Davis: It’s not new to any of us. I think we’ve been preparing for the different solvents changes over the past 30 or 40 years, and the equipment has improved considerably in the last 20 years. That being said, there are alternatives to some of these solvents, and we’re always urging our customers to constantly be on the lookout and to test and trial different solvents that you potentially can drop into a machine. You may have to retrofit, or you may need to purchase new emission-less degreasers where there is very limited exposure to some of those solids.

TP: Hubbard-Hall has been doing a lot to prepare the manufacturers and industries for this, so it seems like it’s getting closer every month. What are some things that you would advise manufacturers and shops to do if they’re facing this? And certainly, if they haven’t already started looking at alternatives, what can they start doing?

Jeff Davis: It’s interesting because I’d first recommend people not to put their heads in the sand. It won’t go away, so let’s address it head-on. We’ve been providing some assistance for customers for several years, and most recently, we recommend that they have a cleaning audit, if you will, or a degreasing audit. Let’s see. Do you need that solvent you’re currently using? Are there alternatives?

I would say 90% of the time, there are suitable alternatives. There are tradeoffs, however, potentially in cleanliness, processing time, and, obviously, economic trade-offs. There’s the value of some of the new solvents — the designer solvents —that are blends or fluorocarbons with some other chlorinated solids. Work extremely well in certain machinery with certain substrates and certain soils.

I mean, there are always those caveats; don’t go it alone, is what I would say, and don’t ignore the fact that it’s not going to come knocking at your door soon, and we’d be more than ready, willing, and able to try to help our customers get to that next step. Whether it’s equipment or solvents — or even water-based cleaning —we currently recommend to many of our customers to find some alternative to providing that industrial and suitable cleaning alternative.

TP: I know you’ve all been very busy working with end users and other manufacturers, and so you’ve probably seen what the substrates are, what the contaminants are, and you pretty much have worked up a solution that would work for many people. So, it might be something that could be almost a turnkey solution that you all have already dealt with before. If someone calls and tells you this is the substrate, this is the contamination, you’ve probably already seen that.

Jeff Davis: We’ve seen a lot of that, and, there are more exotic soils potentially, or there are more demands on cleanliness. If you’re looking at precision cleaning applications —medical, military, aviation, or aerospace — there will always be some challenge.

But I think the availability of new equipment tends to slow people down. It’s going to be hard to replace those thousands of degreasers out in the field quickly, and I think it will be the cost of some of the alternatives. So, that obviously will slow people down; I don’t want to put a new solvent in an old machine if it won’t be as efficient.

That is part of one of the metrics we’re trying to measure for customers: can we clean it? Can we make sure it’s sustainable? And the beautiful thing about solvents is they’re infinitely recyclable, meaning you don’t have to introduce water. And it’s something that, as long as you’re maintaining the solvents with stabilizers and testing the equipment, you can use relatively for years without replacing the solvent.

Look for Cleaning Alternatives Now

TP: A shop owner told me about replacing or upgrading, “The most effective piece of equipment is a pen and paper,” meaning it’s best to jot down what he’d like to do and figure out some costs. He can figure out what things are costing him and where he can either save money or save additional money by spending it because he knows they’ll get a good return on investment. Is that what you see in many customers you’re dealing with?

Jeff Davis: That is an excellent point. I think people always underestimate what they’re going to need. We’ve been trying for several years to promote that you need to look at alternatives. But people think, “If it’s not broken, why fix it?” But there are outside forces now, and they’re demanding you look at alternative chemistry for whatever reason, whether it’s solvents or you can’t dispose of waste, whatever the issue may be. But when we talk to many customers, it seems we provide may be the eye-opening piece of bad news, if you will: we’re trying to give them a reality that here are your alternatives, none of which may be attractive because they hadn’t budgeted for it. And as you said, it will cost a lot of money, but it could help through the long term because you won’t use as many resources, or the machinery will last for decades.

The problem is that once we have broached that subject, put it on the line, and told them the reality, they go, and some customers will shut down because it’s too overwhelming. And then two to three years later, they want to go and revisit it and — like we said earlier — ask how long it will take for me to get the equipment in place. How long is it going to take to modify my process? It becomes an overwhelming prospect. So, I think you’re right, sitting down and trying to plan what your needs are today on pen and paper. What they’re going to be in the future is, and I always recommend, to share that with your vendors because they can help you kind of get to that point in time, and you can make those investments.