Downstream Notification and Recordkeeping Requirements with EPA Ban of Consumer Sales of Methylene Chloride Paint Removers
May 30, 2019
The U.S. Environmental Protection Agency (EPA) recently issued a final rule to prohibit the manufacturing, processing, and distribution of Methylene Chloride in all paint removers for consumer use. This restriction also covers imported items into the U.S. The EPA was prompted to take this action because of the acute fatalities that have been caused by exposure to Methylene Chloride.
Beginning November 22, 2019, paint removal products containing Methylene Chloride will no longer be sold at any retail or distribution establishments that have e-commerce or consumer sales. This deadline gives retailers selling this chemical to consumers time to comply with the EPA’s ban. Additionally, starting August 26, 2019, the EPA is also requiring manufacturers, processors, and distributors to notify retailers and others in their supply chains of the prohibitions.
Importantly, the rule includes downstream notification and recordkeeping requirements that apply to any use of Methylene Chloride, not simply paint removal uses. The notification and recordkeeping provisions are designed to ensure that downstream entities are aware of the prohibitions and that the entire supply chain is compliant. It will also enhance enforcement of the rule for the EPA. Separately, the EPA is planning to issue additional interpretive guidance to assist with meeting the regulatory requirements.
To read the EPA’s final rule on Methylene Chloride, click here.
Please contact Dr. Steve Bennett, Senior Vice President, Scientific Affairs, at sbennett@thehcpa.org for additional comments or questions.
The U.S. Environmental Protection Agency (EPA) recently issued a final rule to prohibit the manufacturing, processing, and distribution of Methylene Chloride in all paint removers for consumer use. This restriction also covers imported items into the U.S. The EPA was prompted to take this action because of the acute fatalities that have been caused by exposure to Methylene Chloride.
Beginning November 22, 2019, paint removal products containing Methylene Chloride will no longer be sold at any retail or distribution establishments that have e-commerce or consumer sales. This deadline gives retailers selling this chemical to consumers time to comply with the EPA’s ban. Additionally, starting August 26, 2019, the EPA is also requiring manufacturers, processors, and distributors to notify retailers and others in their supply chains of the prohibitions.
Importantly, the rule includes downstream notification and recordkeeping requirements that apply to any use of Methylene Chloride, not simply paint removal uses. The notification and recordkeeping provisions are designed to ensure that downstream entities are aware of the prohibitions and that the entire supply chain is compliant. It will also enhance enforcement of the rule for the EPA. Separately, the EPA is planning to issue additional interpretive guidance to assist with meeting the regulatory requirements.
To read the EPA’s final rule on Methylene Chloride, click here.
Please contact Dr. Steve Bennett, Senior Vice President, Scientific Affairs, at sbennett@thehcpa.org for additional comments or questions.