News from the Small Business Environmental Assistance Program
EPA Seeking Small Business Input on Risk Management Rules
The U.S. Environmental Protection Agency (EPA) is inviting small businesses, governments, and not-for-profits to participate as Small Entity Representatives (SERs) to provide advice and recommendations to two Small Business Advocacy Review (SBAR) panels. There will be one panel for methylene chloride and one panel for 1-bromopropane.
Each panel will focus on the agency’s development of proposed rules to address unreasonable risks to human health identified in EPA’s recently completed Toxic Substances Control Act (TSCA) risk evaluations for these chemicals.
Nominate yourself
Nominations must be received by September 30, 2020.
Your input is wanted to inform and help develop regulations that are practical and protective. There are many regulatory options available to the EPA, including:
- Require workplace monitoring, record keeping, or training.
- Mandate specific engineering controls, ventilation requirements and PPE at occupational sites.
- Change concentrations/weight fractions of products containing the chemicals.
- Prohibit, limit or restrict how the chemical is used.
- Require specific labeling and instructions on containers.
As a small entity representative, you will provide comments on behalf of your organization and advise the panel on the potential impacts of the proposed rule on small entities. SERs participate in consultations with the SBAR Panel via telephone, webinar, or in person in one or two meetings and are given an opportunity to submit written comments to the panel.
The self-nomination process is extremely easy and should take a few minutes of your time. It consists of sending an e-mail to the EPA with your name, name and size of your small company, governmental jurisdiction, or not-for-profit organization, address, and contact information. If representing a business, give the North American Industry Classification System (NAICS) code for your firm and either average annual receipts or average annual employment for your firm, corresponding to the definition of small for your NAICS code. Other representatives, such as trade associations that exclusively or at least primarily represent potentially regulated small entities, may also serve as SERs. Note that not all nominees may be selected to provide input.
Before applying, make sure you qualify as “small” under the Small Business Administration’s definition AND expect to be directly subject to requirements of the proposed rule OR that you meet qualifications for other representatives.
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The Toxic Substances Control Act (TSCA) requires the EPA to evaluate the risks of existing chemicals to human health and the environment. During an evaluation, they look at how a chemical is used in many different settings, or “conditions of use”, from manufacturing, processing and distribution, to industrial, commercial and consumer use, and disposal. They review workplace monitoring and modeling data, studies on occupational exposure, and studies on human health and environmental hazards associated with the chemical.
Methylene chloride
Uses: Methylene chloride has a wide range of uses, including as a solvent, propellant, processing aid, or functional fluid in the manufacturing of other chemicals. A variety of commercial and consumer products use methylene chloride as a solvent, including sealants, automotive products, and paint and coating removers.
Risk: The EPA found unreasonable risk in 47 out of 53 conditions of use for methylene chloride, including to workers for many commercial uses, and including to those working nearby and not in direct contact with methylene chloride (occupational non-users). The unreasonable risk determinations are based on health hazards to the central nervous system from acute inhalation and hazards to the liver from chronic inhalation. (source)
1-Bromopropane (1-BP)
Uses: 1-BP is used as a solvent in vapor degreasing, in adhesives and sealants, and in dry cleaning. Industrial and commercial products that may use 1-BP include automotive care products (engine degreaser, brake cleaner, refrigerant flush), anti-adhesive agents (mold cleaning and release product), degreasers and cleaners for electronic and metal products.
Risk: 1-BP has unreasonable risk for 16 out of 25 conditions of use, including to workers and occupational non-users during occupational exposures and consumers and bystanders during exposures to consumer uses. The unreasonable risk determinations are due to developmental toxicity from acute exposures, and developmental toxicity and cancer from chronic exposures. (source)
Center for Energy and Environment (CEE), a local nonprofit with expertise in energy efficiency, can help your business reduce energy use and earn rebates through cost-effective lighting, HVAC, or refrigeration upgrades. CEE offers the following programs for small businesses:
FREE smart thermostat installations
Replacing your existing thermostats with Wi-Fi enabled smart thermostats will help you manage your energy use and earn annual bill credits from Xcel Energy. Visit mncee.org/smart-thermostat to schedule your installation.
One-Stop Efficiency Shop® for Lighting and HVAC
Sponsored by Xcel Energy, this full-service lighting and HVAC rebate program provides one-stop service for businesses’ biggest efficiency needs. Bonus rebates covering up to 75% of project costs are available for lighting projects until December! Learn more and sign up for your free assessment at mncee.org/business.
Xcel Energy Commercial Refrigeration Efficiency Program
This program, administered by CEE, can help you identify energy-saving improvements and earn rebates for refrigeration upgrade projects. Learn more and sign up for your free assessment at mncee.org/business.
Center for Energy and Environment implements the One-Stop Efficiency Shop® and Minnesota Commercial Refrigeration Efficiency program on behalf of Xcel Energy.
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