United States
Environmental Protection
.Agency
Air and Radiation
Stratospheric Protection Division
6205J
October 1995
Rev. 7
Qs & As ON OZONE-DEPLETING SOLVENTS AND THEIR
SUBSTITUTES
This factsheet provides an overview of regulations
governing production, use and replacement of two
ozone-depleting solvents, CFC-113 and methyl
chloroform. The factsheet also discusses regulations on
substitutes and provides information on how to find a
substitute.
A. SOLVENTS COVERED UNDER THE PHASEOUT OF
OZONE-DEPLETING CHEMICALS
1. Q: I heard that methyl chloroform and CFC-113
are being phased out. Is that true?
A: Yes. Under the Clean Air Act, the U.S. is
phasing out production of methyl chloroform and
CFC-113 by January 1, 1996.
2. Q: Is 1,1,1-trichloroethane ("TCA" or "1,1,1")
part of the phaseout?
A: Yes. 1,1,1 is just another name for methyl
chloroform (MCF). .
,3. Q How are HCFC solvents covered under the
phaseout?
A: HCFC-141b has a production phaseout date of
January 1, 2003 and HCFC-225 has a production
phaseout date of January 1, 2015. In addition to
the production phaseout, EPA has also issued
certain use restrictions on HCFC solvents as
discussed, below.
4. Q: Does "phaseout" mean I can't use ozone-
depleting chemicals (ODSs) after that date?
, A: No. The phaseout applies to chemical
production and imports, not use. This means, for
instance, that although virgin CFC-113 cannot be
manufactured after January 1, 1996, any materials
held in inventory or recycled would be available for
. use. However, as a particular chemical's
production phaseout date approaches, it will get
• more and more difficult-and expensive—to. buy.
Note also that even though "phaseout" refers to the
upcoming ban on chemical production, certain uses
of ODSs are also restricted. For example, recycling
of CFCs used as refrigerants is in certain cases
required. More specifically in the solvents area,
EPA has proposed use restrictions on HCFC-141b
and a few other ODSs based on high OOP and on
the' availability of other substitutes. These
use restrictions are discussed later in this
factsheet.
5. Q: Are perchloroethylene, methylene chloride, or
trichloroethylene part of the production phaseout?
A: No. Although these chemicals are chlorinated
solvents like MCF and CFC-113, their atmospheric
lifetimes are very short and they decompose before'
they can reach the ozone layer and do damage. As
a result, they are not considered to u" -rone
depleters and are not regulated under that part of
the Clean Air Act.
B. SNAP STATUS AND REVIEW PROCESS
1. Q: What does "SNAP" stand for?
A; EPA's Significant New Alternatives Policy
program. The SNAP program implements Section
612 dif the Clean Air Act.
2. Q: What is EPA doing.under the SNAP program?
A: Under SNAP, EPA is evaluating substitutes that
companies want to use instead of the ozone-
depleting chemicals, and making sure that they
won't cause greater damage to human health and
the environment than the ozone depleters they are
replacing or than other available substitutes. Based
on this evaluation, EPA then adds these substitutes
to its lists of acceptable or unacceptable
substitutes.
3. Q: Has EPA come out yet with the lists of
substitutes that are either approved or restricted
under SNAP?
A: Yes, EPA published its first set of SNAP
decisions in the Federal Register (FR) on March 18,
1994 (59 FR 13044). EPA updates the lists
regularly. Past FR updates with listings relevant to
solvent substitutes are 59 FR 44^-4-G (August 26,
1994), 59 FR 49108 (September 26, 1994), 60
FR 3318 (January 13, 1995), 60 FR 31092 (June
13,1995), 60 FR 38729 (July 28, 1995), and 60 i
FRM 51383 (October 2, 1995).
You can request copies of comprehensive listings
of SNAP decisions from the Stratospheric Ozone
Protection Hotline at the number listed below.
4. Q: Do I have to check with EPA to make sure each
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substitute solvent or process for every single use
of CFC-113 or MCF is approved under SNAP?
A: No. EPA currently only reviews substitutes for
ODS solvents in three key use sectors. Those
three are solvent cleaning, aerosols, and adhesives,
coatings and inks. EPA is not planning to review
substitutes for more minor uses of CFC-113 and
MCF unless a significant environmental risk can be
shown to exist. Uses currently not subject to
review include:
- Bearer media (for example, a substitute for
CFC-113 in depositing lubricants on medical
catheters)
- Hydraulic system testing
- Plasma etching
- Mold release agents (for nonaerosol
applications).
5. Q: I'm confused about what types of cleaning are
covered under the "solvents cleaning sector." For
instance, is textile cleaning or maintenance
cleaning covered?-
A: The solvents cleaning sector is defined to cover
replacements for ODSs in degreasing or cold
cleaning machines. Handwiping is not covered
under SNAP, since it falls neither in the solvents
cleaning definition nor is it an aerosol application.
6. Q: I sell a solvent substitute for cleaning that I
want to get EPA approval for. What should I do?
A: You should first check the list of acceptable
substitutes under SNAP for cleaning. If your
substitute is already on the list, you don't need to
request EPA approval. Please be aware that EPA
does not certify individual companies' products.
Instead, the approvals are for specific solvents
(e.g., trichloroethylene) or for classes of substitutes
(e.g., aqueous cleaners).
If your substitute is not on the list, you must
submit it for EPA review by writing to:
SNAP Coordinator >;; ,;;,
Stratospheric 'Protection Division, 6205 J
U.S. Environmental Protection Agency
401 M Street, SiW.
Washington, D.C. 20460.
.You can also call or fax to:
(202) 233-9152
FAX (202) 233-9577.
7. Q: I sell, a solvent cleaning substitute. How can
EPA help me get information on my product out to-
potential users?
A: In addition to the SNAP lists, EPA has a list of
vendors selling cleaning substitutes'. Once you '
request the vendor list from EPA, you'll see that it
has a form you can send in to add your company to
the list.
C. ACCEPTABLE CLEANING SUBSTITUTES UNDER
SNAP
1. Q: Which cleaning substitutes for CFC-113 or
MCF are approved under the SNAP program?
A: EPA has already approved most solvent
cleaning substitutes, including:
- Aqueous and semi-aqueous cleaners
(including those based on terpenes or
petroleum-based hydrocarbons)
- Non-ozone depleting chlorinated solvents
(methylene chloride, trichloroethylene,
.perchloroethylene),
- Organic solvents used without water
(terpenes, petroleum, hydrocarbons, and
oxygenated organic solvents such as esters,
ethers, alcohols, etc.)
- Volatile methyl siloxanes
- Trans-1,2-dichloroethylene
- No-clean processes such as those used in
manufacturing printed circuit boards
- Various hi-tech processes such as '
supercritical fluid cleaning, UV-ozone.
cleaning, plasma cleaning.
2. 0.: Does "acceptable under SNAP" mean that a
. substitute is safe and that I can use it any way I
want? . , , ': . ;
A: No. If a chemical has other regulations that
cover it, you still have to follow those regs. For
example, if you use a substitute that is a VOC, you
still have to follow whatever controls your state
requires you to adopt.
3. Q: Since perchloroethylene, methylene chloride
and trichloroethylene ("perc", "meth" and "trike")
are being approved under SNAP and they're not
covered under the phaseout, can I use these
chemicals any way I want?
A: No. These chemicals are regulated under other
laws for a number of reasons:
_ '\
- Worker health: All three are considered'
toxic to human health. As a result, the
Occupational Safety and Health
Administration has set workplace standards
for use of these chemicals. To find out
about these standards, ask a distributor who
sells these chemicals to show you the
Materials Safety Data Sheet (MSDS). The
MSDS wjll describe relevant workplace
standards.
- Environmantal releases of air toxins: The
Clean Air Act lists these three chemicals'
due to .their toxicity as Hazardous Air
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Pollutants IHAPs) under Title HI. EPA has to
develop Maximum Achievable Control
Technology (MACT) standards for HAPs
.used in major industrial source categories.
EPA recently issued the MACT for use of
perc, meth, and trike in vapor degreasing.
The Federal Register citation is 59 FR
61801, December 2, 1994.
In addition, your state or local air board may
have other regulations controlling emissions
of these chemicals due to their toxicity.
Perc and trike are regulated under
federal law (Title I of the Clean Air Act) as
VOCs. Meth is exempt. EPA has been
investigating exempting perc as we"
However, you should check with your state
or local air board to see if it has its own regs
that control these chemicals as VOCs.
. - Waste- All three are regulated as hazardous
wastes under the federal Resource
Conservation and Recovery Act.(RCRA).
Again, your state may have additional waste
disposal requirements. This means that you
'. ," may have to pay special fees to dispose of .
any spent solvent if you decide to use these
chemicals.
4. Q: How do I get more information on the MACT
•• standard for vapor degreasing?
{'';-?'--'.A: You can call EPA's Office of Air Quality
I arid Standards (OAQPS). The name of the
it working on this regulation is Paul
• '; ,Alrn6dovar. His number is 9} 9-541 -0283.
5. Q: And if I need more information on VOC
. regulations?
A: CallBill Johnson at 919-541-5245 in OAQPS
for general information on federal VOC standards.
You can also contact your state EPA or local air
board to find out the exact regulations for your
; community; • \
D. CLEANING SUBSTITUTES WITH RESTRICTIONS
UNDER SNAP
1. Q: Which solvent substitutes are restricted under,
SNAP? ,
A: Several cleaning substitutes are subject to
restrictions under SNAP, including HCFC-141 b,
perfluorocarbons, HCFC-225, and dibromomethane.
In addition, several other solvents have proposed
restrictions on them.
2. Q: I'm interested in HCFC-141 b. How does the
ban on use for cleaning under SNAP work?
A: In the FR notice of March. 1994, EPA listed
141 b as .unacceptable for cleaning. The only
.exception is that existing users of 141b for vapor
degreasing/cold cleaning are permitted to use 141b
. until January 1, 1996. To be an "existing user,"
you must have been using HCFC-141 b before April
18,1994. The net result is that as of January 1 -,•
1996, there is a complete ban on HCFC-141 b in
cleaning equipment.
These restrictions are necessary because 141b has
nearly the same ozone depletion potential as MCF,
so there's little or no environmental benefit to
switching from CFC-113 or MCF to 141 b.
Users should also remember thatHCFC-141 b is
included in.the accelerated production phaseout
• regulations for ozone-depleting substances, and will
be phased out of production by January 1, 2003.
Furthermore, sales of most aerosol products
containing HCFCs were prohibited after January 1,
. 1994'by regulations EPA developed under section
610(d) of the Clean Air Act (the Nonessential
Products Ban). , ,_. ' ' ;
3. Q: I had heard that EPA was going to postpone
the date for the ban on HCFC-141 b for solvent
cleaning. Is that true?
A: Only partially. EPA is proposing an amendment
to the use ban, but the only change is that existing
uses in precision cleaning and in high-performance
electronics cleaning would be permitted for an .
additional year until January 1, 1997. No new •
substitutions into 141b would be permitted and
uses of 141b in metals cleaning and basic,
electronics cleaning would still have to end as of
January 1,1996. ,, •;;(;, .q,
EPA decided to extend the permissible period of
use for 141b in the precision and high-performance
electronics cleaning applications based on its
determination that even though alternatives now
' exist for nearly all of these applications, users need'
more time to complete .the stringent qualification
process that any new alternative for these
• applications must pass through.
4. . Q: What is meant by "high performance electronics
and precision cleaning"? •
A: This type of cleaning is distinct from basic
electronics and metals cleaning in that it concerns
high-value parts with technologically sophisticated N
designs or substrates where performance failure, is
directly 'associated with extreme hazard to public
safety or health or catastrophic loss of equipment
or materiel. " • •
Examples of "high-performance electronics and
precision cleaning" would include cleaning of high-.
value added parts for aerospace, military, or
medical applications such as precision ball bearings
for navigat'onal devices, hybrid circuits, or medical
devices;. Examples of types of cleaning excluded
would be cleaning of basic, formed metal parts
such as car doors or hardware-store quality hinges
and latches. Also excluded would be cleaning of
electronics for home appliances, toys or consumer
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etectronics.
5. Q: When will the extension for high-performance
and precision cleaning users become official?
A: Once the proposal is finalized through the
rulemaking process, which can take up to six
months. The extension is currently undergoing
internal EPA review.
6. Q: What happens if the extension isn't final before
January 1, 1996?
A: EPA's enforcement policy will take into account
any'delays in the rulemaking process and will
recognize efforts resulting in concrete progress
towards implementing a substitute.
7. Q: Once the extension for permissible use is
granted, will a company who qualifies for the
extension need to file any forms?
A: No. Once the rule is modified, companies that
qualify may avail themselves of the extension
without any reporting.
8. Q: How does the ban on HCFC use in nonessential
products under section 610(d) tie in with the SNAP
. • , restrictions?
A: EPA issued the ban on HCFCs in nonessential
products on December 30, 1993 (58 FR 69638),
and it became effective on January 1, 1994. This
regulation bans, among other things, use of HCFCs
in aerosol products. However, section 610
, authorizes EPA to grant exemptions from the ban
based on lack of alternatives and concerns for
flammability arid worker safety. EPA has
exempted the following products with HCFC
solvent or propellents from the section 610{d) ban:
. Medical devices listed in 21 CFR'2.125(e)
Lubricants, coatings or cleaning fluids for
electrical or electronic equipment, which
contain class II substances for solvent
purposes, but Which contain no other class II
substances;
• . Lubricants, coatings or cleaning fluids used for
aircraft maintenance, which contain class II
substances for solvent purposes but which
contain no other class II substances;
Mold release.agents used in the production of
plastic and elastomeric materials, which
• contain class II substances for solvent
purposes but which contain no other class II
,,- /- substances, and/or mold release agents that
contain HCFC-22 as a propellant where
evidence of good faith efforts to secure
alternatives indicates that, other than a class I
substance, there are no suitable alternatives;
Spinnerette lubricants/cleaning sprays used in
the production of synthetic fibers, which
contain class I) substances for solvent
purposes and/or contain class II substances for
propellant purposes;
Document preservation sprays which contain
HCFC-141 b as a solvent, but which contain no
other class II substance; and/or which contain
HCFC-22 as a propellant, but which contain no
other class II substance and which are used
solely on thick books, books with coated,
dense or paper and tightly bound documents
Wasp and hornet sprays for use near high-
tension'power lines that contain a class II
substance for solvent purposes only, but which
contain no other class II substances.
Although SNAP lists HCFC-141 b as an acceptaL j
aerosol solvent, the existence of the 610 ban
means for practical purposes that the only
allowable uses of 141b are in the above
applications. For these aerosol applications, the
SNAP program will not add further HCFC 1 r 1 b
restrictions, since the exemptions are based on a
determination that HCFC-141 b is necessary.
If you have further questions on the Nonessential
Products Ban under section 610, you should
request the related factsheet from the
Stratospheric .Ozone Protection Hotline at the
number listed below.
9. Q: I'm interested in perfluorocarbons. What's the
SNAP policy for solvent cleaning on those?
A: Under SNAP, perfluorocarbons (PFCs) are listed
as "acceptable subject to narrowed use limits," and
may only be used in electronics and precision
cleaning for high-performance, precision-engineered
applications where companies have made
reasonable efforts to ascertain that other
alternatives are not technically feasible due to
performance or safety requirements.
These restrictions are necessary' because the
perfluorocarbons have extremely long atmospheric
lifetimes, and are potent greenhouse gases.
Examples of the types of specialized parts that
may need to be cleaned wi.th PFCs are
gyroscopes, direct access storage devices for
computers, and electro-optical devices for ^
weapons-targeting systems. Other examples of
parts and equipment that may need to be cleaned
with PFCs can be found in the SNAP regulation.
The SNAP regulation also discusses characteristics
of parts and equipment that may indicate the need
for a PFC (unusually stringent paniculate
standards, highly complex geometric
configurations, etc.) As with 141b, PFCs are not
necessary for cleaning basic metal parts or most
printed circuit boards, since many other
substitutes are available.
10. Q: If I want to use a perfluorocarbon, what do I
have to do to prove that no other alternative is
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technically feasible? Do I have to fill out any
forms?
A: No. The goal of the SNAP listing is to make
sure that you've adequately explored other
alternatives before selecting a RFC. This means
contacting actual vendors or even testing parts
with other cleaning substitutes. Although you are
not required to fill out any special forms or report
your findings to'EPA, you must keep the results of
your findings on file for future reference. Your
search for alternatives should take into account
that it will sometimes take a few tries for a vendor
to be able to tailor a substitute to your application.
EPA's review of uses'of PFCs will take into
account a user's effort to give other substitutes a
fair shake.
If you want more information on perfluorocarbons .
and their restrictions, you should contact EPA
directly.
11. Q: What are the restrictions on HCFC-225?
A: HCFC-225 is a relatively new chemical. It is
actually a blend of two isomers, HCFC-225ca and'
HCFC-225cb. Although both isomers have some
ozone depletion potential, the ODPs are relatively
small. In addition, its global warming potential is
minimal since 225's atmospheric lifetimes are
short-approximately 1.6 years for the ca-isomer
, and 5.1 years for the cb-isomer.
The ca isomer has, however, shown some adverse
effects in toxicity tests, and it has a company-set
exposure limit of 25 ppm. As a result, EPA has
adopted as federal law (60 FR 31092; June. 13,
1996) the 25 ppm exposure limit for HCFC-225ca
when used for electronics and precision cleaning.
Since HCFC-225 is sold as a blend of the ca isomer
with the less toxic cb-isomer, EPA expects that
companies interested in this chemical will readily
be able to meet the exposure limit for the ca
isomer. For companies' ease of monitoring, the
manufacturer of HCFC-225 has calculated that a
exposure level for HCFC-225 of 50 ppm must be
achieved in order to meet the 25 ppm standard for
the ca-isomer. Achieving the limit is also made
more feasible by the fact that this chemical is of
greatest interest for precision cleaning applications
where high-performance cleaning equipment is the
norm. .
HCFC-225 has not been approved for metals
cleaning applications, and is under investigation for
aerosbls uses.-
12. Q: What about monochlorotoluenes and
benzotrifluorides?
A: These are chemicals that are of commercial :
interest due to their solvency properties. Their use
in cleaning applications is relatively new. EPA's
toxicological review of the chemicals has led us to
propose a workplace standard of 50 ppm for
monochlorotoluenes and 25 ppm for
benzotrifluorides.
E. SUBSTITUTES PENDING REVIEW UNDER SNAP
1. Q.: Several cleaning substitutes are listed as
"pending" under SNAP. Why is that?
A: For certain substitutes EPA is either still
reviewing the data or has requested additional data
that the vendors are in the process of collecting.
2. Q: What is chlorobromomethane' and why is it
listed as pending? I've never even heard of it.
A: Chlorobromomethane (CBM) is a component of
a CFC-113/MCF substitute that is of commercial
in*-rest. EPA has indicated concern both about the
•chemical's OOP as well as its toxicity.
On the OOP front, the most recent research points
to an OOP of around 0.^ for chlorobromomethane.
However, this value, is preliminary and will heed to
undergo further empirical study before EPA can use
• it as a basis for, regulation. If the OOP is confirmed
at 0.1, this would suggest the need for regulation
comparable to either methyl chloroform or HCFC-
141b.
Less is known about the chronic toxicity of
chlorobromomethane. Although this chemical does
have an existing PEL of 200ppm, this? level was set
when chlorobromomethane was being used as a
fire extinguishing agent-meaning that concerns
about worker exposure focused on acute toxicity
rather than chronic effects as would be the case in
solvent cleaning. (Chlorobromomethane is also
known as Halon 1011.) In addition, the PEL was
set in the 1970s, and more recent toxicological
research indicates that, in fact,
chlorobromomethane may be implicated in
carcinogenesis. foxicologists familiar with
chlorobromomethane point out that this chemical is
only minimally different structurally from methyl
bromide, which is an acute biocide, or methylene
chloride, which is a well-known carcinogen and'has
a workplace standard of 25ppm.
The vapor pressure of this chemical may be low
enough to offset some of these environmental
concerns, but it is not yet clear what the SNAP
decision or production phaseout schedule for CBM
will-be. ' ^
3. Q: The SNAP tables list HFC-4310 as "pending."
What's its status?
A: EPA is currently processing a FR notice for
HFC-4310 that would propose a federal workplace
standard of 200 ppm and an exposure ceiling of
400ppm. These levels are the same as the
manufacturer's own corporate exposure limits for
this chemical.' The ceiling is necessary due to a
concern for central nervous system effects that are
acute but reversible.
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Since MFCs clean better than PFCs and generally
have much shorter lifetimes and global warming
potentials, they are appealing prospective •
alternatives for cleaning applications where PFCs
currently are the only viable substitutes.
MFCs are of interest not just for precision and
electronics cleaning, but also for other targeted
applications such as film cleaning and as a carrier
solvent.
4. Q: What is the status of hydrofluoroethers?
A: They have just been submitted to EPA for joint
review under the PMN and the SNAP programs,
and a decision is expected by the end of the year.
Like the MFCs, they are appealing a'ternatives to
PFCs since they offer both improved solvency and
lower GWPs.
F. HOW TO GET HELP FINDING A SOLVENT
CLEANING SUBSTITUTE
1. Q:, How do I find out about substitutes for cleaning
with methyl chloroform (1,1,1-trichloroethane) or
CFC-113?
A: EPA has written a series of manuals in
cooperation with the Industry Cooperative on
Ozone Layer Protection (ICOLP) that describe
alternatives to cleaning with MCF and CFC>113.
These manuals exist for:
\ - Metals cleaning .
-' Precision cleaning
- Electronics cleaning
- Aircraft maintenance cleaning
- No-clean processes for electronics assembly
- Reducing use of CFC-113 and MCF through
conservation practices.
2. Q: How can I get those manuals?
A: You can request them from the Stratospheric
Ozone Protection Hotline.
, ' , , ; M ( ,. i. Lf F1.'
3. Q: How do 1 find out who sells different solvent
cleaning substitutes?
A: EPA has lists of vendors selling substitutes for
metals cleaning, electronics cleaning', and precision
cleaning. You can request these lists from the
Stratospheric Ozone Protection Hotline.
4. Q: How can I make sureTm not just buying
another substitute that has MCF or CFC-113 in it?
A; We also have a list of trade names of products
; with MCF and CFC-113 in them. You can request
that from'the Hotline, tao.
FOK DOCUMENTS AND MORE INFORMATION ON
FEDERAL REGULATIONS UNDER THE STRATOSPHERIC
OZONE PROTECTION PROGRAM, PLEASE CALL THE
STRA TOSPHERIC OZONE PROTECTION HOTLINE A T
1-800-296-1996. INTERNATIONAL CALLERS SHOULD
CALL 202-775-6677.
OAR/OAP/SPD/SARB/N JB: 10/17/95
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