Earlier this month, the U.S. Environmental Protection Agency (EPA) announced the availability of the draft risk evaluation for N-methylpyrrolidon (NMP) under the Toxic Substances Control Act (TSCA). The purpose of a risk evaluation is to determine whether a chemical substance presents an unreasonable risk of injury to health or the environment under the conditions of its use and to analyze the risks from potential exposure. The draft risk evaluation will be peer-reviewed by the TSCA Science Advisory Committee on Chemicals (SACC) on December 5- 6, 2019 with a final regulation likely to be put in effect in mid-2020. Prior to the SACC peer-review, the EPA has requested public comments on the draft risk evaluation by November 26, 2019 to allow SACC time to review and consider them before the peer review meeting.

NMP, also known as N-Methyl-2-Pyrrolidone, is a chemical that is widely utilized during the manufacturing and production of polymers, pharmaceuticals, agrichemicals, and petroleum products. The chemical is also utilized in various products including adhesives, sealants, paints, paint and coating removers, adhesive removers, and degreasers.

The EPA’s draft risk evaluation preliminarily found unreasonable risks associated with exposures to NMP among different classes of potential users, including occupational workers, occupational non-users, and consumers. The EPA determined that the conditions of use that presented unreasonable risks to workers included the processing of NMP into formulations or mixtures, and many industrial or commercial uses as a solvent or degreaser. The evaluation also found that there were risks presented to occupational non-users — those who work in the vicinity of those direct occupational processes involving the chemical — for exposures to NMP. Furthermore, the EPA found that the following uses that present an unreasonable risk to consumers include the use of NMP for paints, coatings, and paint and coating removers, and the use of NMP for cleaning and furniture care products, such as wood cleaners and gasket removers. The EPA evaluated consumers for potential risks from inhalation, dermal, and vapor through skin exposures and determined that there was an unreasonable risk of adverse effects to consumers, including fetal mortality. 

In light of these risks, several well-known multi-national companies have already committed to ban and/or eliminate the use of NMP from their products. In the meantime, the EPA has strongly recommended that NMP users carefully follow instructions on product labels and material safety data sheets and that workers appropriately use personal protective equipment. We’ll continue to track the developments of the risk evaluation on NMP.