by Dennis J. DeilyOn January 19, 2017, the U.S. Environmental Protection Agency (EPA) published a proposed rule to use its authority under TSCA Section 6 to restrict the manufacture (and Import), processing and distribution in commerce of Methylene Chloride (MC) and N-Methylpyrrolidone (NMP) for consumer and most types of commercial paint and coating removal. Manufacturers, processors and distributors must keep records of MC and NMP transactions and provide downstream user notifications of the prohibitions. Note: retailers of MC and NMP for ANY use are exempted.A time limited exemption is proposed for both MC and NMP in coating removal processes critical to national security.An alternative proposal is offered for NMP that allows users to establish worker protection programs (dermal and respiratory) and NOT use formulations containing NMP in excess of 35%. Processors would also have an opportunity to reformulate products to contain 35% or less of NMP and to provide workers with effective glove protection. Products would also need to have labelling with warning and instructions.NOTE:1. This action proposing a TSCA Section 6(a) Rule would make NMP and MC subject to TSCA Section 12(b) Export Notification requirements and could affect TSCA Section 13 Import Certifications for some entities.2. The proposed Sct. 6 rule is significant in that EPA’s use of its Sct. 6 authority has rarely been exercised since the promulgation of TSCA.Comments on this proposed rule must be received by the EPA on or before March 19, 2017.ReferenceEnvironmental Protection Agency: Methylene Chloride and N-Methylpyrrolidone; Regulation of Certain Uses Under TSCA Section 6(a), Federal Register 82 (January 19, 2017) 7464-7533: https://www.federalregister.gov/documents/2017/01/19/2017-01222/methylene-chloride-and-n-methylpyrrolidone-regulation-of-certain-uses-under-tsca-section-6a