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U.S. EPA Issues Draft TSCA Risk Evaluation for N-methylpyrrolidone (NMP); “Unreasonable Risk” Determination Poses Significant Implications for Lithium ion Battery Manufacturers

The U.S. EPA recently published its draft TSCA Risk Evaluation (draft RE) for N-methylpyrrolidone (NMP) (CAS RN 872-50-4). NMP is a substance used in the manufacture of lithium ion batteries. The draft RE identifies industrial and commercial uses that EPA has deemed to present an unreasonable risk to the health of workers or consumers. Unreasonable risk is the trigger for TSCA regulation. Of particular interest to the lithium ion battery industry, EPA made an unreasonable risk determination for industrial and commercial use of NMP “[a]s a solvent (for cleaning or degreasing) use in electrical equipment, appliance and component manufacturing and for other uses in manufacturing lithium ion batteries.” Because NMP is used in the manufacturing of lithium ion batteries, manufacturers of lithium ion batteries will be considered “processors” under TSCA.

While an unreasonable risk determination does not necessarily mean that EPA will automatically ban NMP for lithium ion battery manufacturing, the Agency has taken such an approach on chemicals previously determined to present unreasonable risks. Instead, EPA could require certain types of control measures to mitigate risks associated with the manufacture of lithium ion batteries. Risk management measures may include requirements to use personal protective equipment (PPE) or other requirements EPA considers appropriate to lower exposure to susceptible populations. Once NMP’s RE is finalized, the risk management process will begin and can be expected to take two to three years to complete.

EPA is accepting comments on the draft RE through Monday, January 6, 2020. Additionally, EPA’s Science Advisory Committee on Chemicals (SACC) is hosting an in-person meeting on December 5-6, 2019 to review the draft RE.

More information on the upcoming meetings can be found here.

Contact PRBA Executive Director George Kerchner for questions on PRBA’s planned comments on this EPA proposal.