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pdfEconomic Analysis of the
Regulation of Trichloroethylene
Under TSCA Section 6(a)
November
2024
DRAFT
of June
2023
Office of
of Pollution
Pollution Prevention
Prevention and
and Toxics
Toxics U.S.
U.S. Environmental
Environmental Protection
Protection Agency
Agency
Office
*** EO12866/13563 Review Draft – Deliberative – Do Not Cite, Quote or Release During
the Review ***
Acknowledgement
EPA acknowledges the analytical and draft preparation support of Abt of Rockville, Maryland, provided
under Contract No. 68HERH22A0018/68HERH23F0085 in the preparation of this report.
Notice
This document was prepared to provide economic information for the rulemaking
process, and to meet various administrative and legislative requirements. Due to the
nature of the information available to EPA, the document contains various assumptions
that may not reflect how all regulated entities would comply with the rule's requirements.
Persons seeking information on regulatory requirements as they apply to specific
facilities should consult 40 CFR part 751, the preamble for the regulatory action, and EPA
guidance documents.
i
CONTENTS
Executive Summary .............................................................................................................. ES-1
Introduction ................................................................................................................. ES-1
Background ................................................................................................................. ES-3
Regulatory Options Analyzed ...................................................................................... ES-5
Estimated Number of Affected Entities and Individuals............................................... ES-8
Estimated Incremental Costs ...................................................................................... ES-9
Estimated Incremental Benefits ................................................................................ ES-14
Estimated Incremental Net Benefits .......................................................................... ES-21
Environmental Justice Impacts ................................................................................. ES-29
Estimated Small Business Impacts ........................................................................... ES-32
1.
Introduction .................................................................................................................. 1-1
1.1 Background ........................................................................................................... 1-3
1.2 Regulatory Options Analyzed ................................................................................ 1-4
1.3 Organization of this Document .............................................................................. 1-8
2.
Problem Definition/Market Failure .............................................................................. 2-1
2.1 Trichloroethylene Problem .................................................................................... 2-1
2.2 Regulatory Background ......................................................................................... 2-4
2.3 Justification for Risk Management Action for TCE ................................................ 2-4
3.
Profile of Affected Industries ...................................................................................... 3-1
4.
Products Formulated with TCE ................................................................................... 4-1
5.
Use and Alternatives Analysis .................................................................................... 5-1
5.1 Overview of Use and Alternatives Analysis Approach .......................................... 5-1
5.2 Use Categories and COUs Not Considered in the Use and Alternatives
Analysis ................................................................................................................. 5-4
5.3 Vapor Degreasing ................................................................................................. 5-9
5.4 Mold Release and Aerosol Spray Cleaning/Degreasing: Mold Releases and
Cleaners .............................................................................................................. 5-15
5.5 Liquid Cleaners and Degreasers and Aerosol Spray Cleaning/Degreasing:
AC Coil Cleaners ................................................................................................. 5-19
5.6 Liquid Cleaners and Degreasers and Aerosol Spray Cleaning/Degreasing:
Energized Electrical Equipment Degreasers ....................................................... 5-23
5.7 Lubricants and Greases ...................................................................................... 5-26
5.8 Adhesives, Sealants, Paints and Coatings: Adhesives ....................................... 5-30
5.9 Adhesives, Sealants, Paints and Coatings: Cold pipe insulation ........................ 5-34
5.10 Spot Removers.................................................................................................... 5-38
5.11 Pepper Spray ...................................................................................................... 5-44
6.
Baseline Analysis ......................................................................................................... 6-1
6.1 Baseline TCE Consumption Volumes by Use Category ....................................... 6-1
6.2 Number of Affected Facilities and Individuals Exposed in Occupational
Settings ............................................................................................................... 6-14
6.3 Estimated Number of Exposed Consumers ........................................................ 6-35
Contents
ii
7.
Cost Analysis ............................................................................................................... 7-1
7.1 Description of Options ........................................................................................... 7-2
7.2 Timeline for the Analysis ....................................................................................... 7-4
7.3 Summary of Number of Affected Entities .............................................................. 7-8
7.4 Industry Wage Rates ............................................................................................. 7-9
7.5 Rule Familiarization and Downstream Notification Costs .................................... 7-13
7.6 Reformulation Costs ............................................................................................ 7-15
7.7 Costs for Switching to Alternatives to TCE Vapor Degreasing (and TCE Batch
Cold Cleaning) .................................................................................................... 7-23
7.8 Costs of the Dermal Protection Component of the WCPP .................................. 7-77
7.9 Costs of the Respiratory Protection Component of the WCPP ........................... 7-81
7.10 Total WCPP Costs .............................................................................................. 7-97
7.11 Prescriptive Control Costs for Energized Electrical Cleaning ............................ 7-103
7.12 Unquantified Costs and Uncertainty in the Cost Estimates ............................... 7-104
7.13 Total Annualized Costs ..................................................................................... 7-110
8.
Benefits Analysis ......................................................................................................... 8-1
8.1 Summary of Regulatory Options Considered ........................................................ 8-2
8.2 Number of Individuals with Exposure Reduction ................................................... 8-7
8.3 Exposure Values from Risk Evaluation Used in the Benefits Analysis .................. 8-8
8.4 Excess Cancer Risk Estimates ........................................................................... 8-22
8.5 Microrisk Reductions for Kidney Cancer, Non-Hodgkin Lymphoma, and Liver
Cancer per Individual Attributable to Reducing TCE Exposure Under the
Regulatory Options.............................................................................................. 8-23
8.6 Value of Microrisk Reductions for Kidney Cancer, Non-Hodgkin Lymphoma,
and Liver Cancer ................................................................................................. 8-25
8.7 Total Benefits ...................................................................................................... 8-26
8.8 Benefits for Reducing Cancer Risks for Consumer Users of TCE Products ....... 8-54
8.9 Qualitative Discussion of the Benefits of Non-Cancer Risk Reductions .............. 8-57
9.
Comparison of Costs and Benefits and Monetized Net Benefits ............................ 9-1
10.
Economic Impact Analyses ....................................................................................... 10-1
10.1 Protection of Children from Environmental Health Risks and Safety Risks......... 10-1
10.2 Small Entity Impacts ............................................................................................ 10-1
10.3 Employment Effects ............................................................................................ 10-9
10.4 Paperwork Burden Analysis .............................................................................. 10-13
10.5 Unfunded Mandates Reform Act (UMRA) ......................................................... 10-20
10.6 Executive Order 12898 – Environmental Justice Impacts ................................. 10-20
10.7 Impacts on Technological Innovation and the National Economy ..................... 10-52
10.8 Executive Order 13132 – Federalism ................................................................ 10-53
10.9 Executive Order 13175 – Tribal Implications ..................................................... 10-53
11.
References ................................................................................................................... R-1
Appendix A - Chemical Ranking Procedure and Calculations ........................................... A-1
Contents
iii
Appendix B - Estimated Costs for Respirator PPE for 2023 TSCA Risk Management
Economic Analyses ............................................................................................................................. B-1
Contents
iv
List of Acronyms and Abbreviations
EPA
U.S. Environmental Protection Agency
TSCA
Toxic Substances Control Act
TCE
Trichloroethylene
COU
Conditions of Use
HCL
Hydrochloric Acid
EDC
Ethylene Dichloride
WCPP
Workplace Chemical Protection Program
ONU
Occupational Non-Users
CNS
Central Nervous System
CDC
Centers for Disease Control and Prevention
NHL
non-Hodgkin's lymphoma
QWI
Quarterly Workforce Indicators
CHDs
Congenital Heart Defects
TRI
Toxics Release Inventory
NATA
National Air Toxics Assessment
HFC
Hydrofluorocarbons
EJ
Environmental Justice
CDR
Chemical Data Reporting
NEI
National Emissions Inventory
ACS
American Community Survey
SBA
U.S. Small Business Administration
AIM
Innovation and Manufacturing Act
PPE
Personal Protective Equipment
TWA
Time Weighted Average
NESHAP
National Emission Standards for Hazardous Air Pollutants
RCRA
Resource Conservation and Recovery Act
CPSC
U.S. Consumer Product Safety Commission
FDA
Food and Drug Administration
OSHA
Occupational Safety and Health Administration
NIOSH
National Institute for Occupational Safety and Health
PEL
Permissible Exposure Limit
STEL
Short Term Exposure Limit
VOC
Volatile Organic Compound
Contents
v
REACH
Registration, Evaluation, Authorization and Restriction of Chemicals
OEL
Occupational Exposure Limit
ECEL
Existing Chemical Exposure Limit
HOC
Hierarchy of Controls
NAICS
North American Industry Classification System
CPID
Consumer Product Information Database
SDS
Safety Data Sheet
SCAQMD
South Coast Air Quality Management District
OTC
Ozone Transport Commission
TURI
Toxics Use Reduction Institute
HSP
Hansen Solubility Parameters
CARB
California Air Resources Board
SBAR
Small Business Advocacy Review
BLS
U.S. Bureau of Labor Statistics
ECEC
Employer Costs for Employee Compensation
PVC
Polyvinyl chloride
PVA
Polyvinyl alcohol
AL
Action Level
ODC
Other Direct Costs
CIH
Certified Industrial Hygienist
APF
Assigned Protection Factors
LADC
Lifetime Average Daily Concentration
VSL
Value of a Statistical Life
RFA
Regulatory Flexibility Act
SBREFA
Small Business Regulatory Enforcement Fairness Act
GDP
Gross Domestic Product
EJSCREEN Environmental Justice Screening and Mapping Tool
OTVD
Open Top Vapor Degreasers
CVD
Conveyorized Vapor Degreasers
EVD
Enclosed Vapor Degreasers
WVD
Web Vapor Degreasers
NCA
National Cleaners Association
DLI
Dry Cleaning and Laundry Institute
CBP
County Business Patterns
DMR
Discharge Monitoring Report
RTI
Research Triangle Institute
Contents
vi
IRIS
Integrated Risk Information System
UMRA
Unfunded Mandates Reform Act
Contents
vii
List of Tables
Table ES-1: Use Categories Considered in the Economic Analysis Mapped to the Conditions of Use
(COUs) Defined in the Risk Evaluation ................................................................................................. ES-1
Table ES-2: Summary of Regulatory Options by Use Category ............................................................ ES-7
Table ES-3: Summary of Occupational and Consumer Users ................................................................ ES-9
Table ES-4: Total 2% 20-Year Annualized Costs Under the Regulatory Options by Use Category (2022$)
.............................................................................................................................................................. ES-10
Table ES-5: Total 3% 20-Year Annualized Costs Under the Regulatory Options by Use Category (2022$)
.............................................................................................................................................................. ES-11
Table ES-6: Total 7% 20-Year Annualized Costs Under the Regulatory Options by Use Category (2022$)
.............................................................................................................................................................. ES-13
Table ES-7: Total 20-Year Annualized Benefits by Use Category and Regulatory Option (2 Percent
Discount Rate) ...................................................................................................................................... ES-15
Table ES-8: Total 20-Year Annualized Benefits by Use Category and Regulatory Option (3 Percent
Discount Rate) ...................................................................................................................................... ES-17
Table ES-9: Total 20-Year Annualized Benefits by Use Category and Regulatory Option (7 Percent
Discount Rate) ...................................................................................................................................... ES-19
Table ES-10: Total 20-Year Annualized Net Benefits by Use Category and Regulatory Option (Low
Benefits Estimate, 2 Percent Discount Rate) ........................................................................................ ES-22
Table ES-11: Total 20-Year Annualized Net Benefits by Use Category and Regulatory Option (High
Benefits Estimate, 2 Percent Discount Rate) ........................................................................................ ES-23
Table ES-12: Total 20-Year Annualized Net Benefits by Use Category and Regulatory Option (Low
Benefits Estimate, 3 Percent Discount Rate) ........................................................................................ ES-24
Table ES-13: Total 20-Year Annualized Net Benefits by Use Category and Regulatory Option (High
Benefits Estimate, 3 Percent Discount Rate) ........................................................................................ ES-25
Table ES-14: Total 20-Year Annualized Net Benefits by Use Category and Regulatory Option (Low
Benefits Estimate, 7 Percent Discount Rate) ........................................................................................ ES-26
Table ES-15: Total 20-Year Annualized Net Benefits by Use Category and Regulatory Option (High
Benefits Estimate, 7 Percent Discount Rate) ........................................................................................ ES-27
Table ES-16: Total 20-Year Annualized Net Benefits by Regulatory Option, (Millions, 2022$)........ ES-28
Table ES-17: Demographics of Communities Within 1-, 3-, and 5-mile Radii of Trichloroethylene
Facilities, Population Weighted Averages ............................................................................................ ES-30
Table ES-18: Total Number of Other TRI Facilities Within 1, 3 and 5 Miles of Facilities Using TCE to
Manufacture HFCs ................................................................................................................................ ES-30
Table ES-19: Community Demographics Near Mexichem Fluor, St. Gabriel, LA .............................. ES-31
Table ES-20: Summary of Small Business Impacts ............................................................................. ES-33
Table 1-1: Use Categories Considered in the Economic Analysis Mapped to the Conditions of Use
(COUs) Defined in the Risk Evaluation .................................................................................................... 1-2
Contents
viii
Table 1-2: Summary of Regulatory Options by Use Category .................................................................. 1-7
Table 2-1: Summary of Regulatory Options by Use Category .................................................................. 2-3
Table 3-1: Industry Statistics ..................................................................................................................... 3-2
Table 3-2: Small Business Determinations of Identified Affected Parent Companies, by Use Category3-27
Table 4-1: Companies and Types of Products Containing Trichloroethylene by Product Type ............... 4-2
Table 5-1: Use Categories Mapped to Applicable Section of Chapter ...................................................... 5-1
Table 5-2: Conditions of Use from the TCE TSCA Risk Evaluation Which Are Not Analyzed Further in
This Use and Alternatives Analysis ........................................................................................................... 5-5
Table 5-3: Sizes, Cleaning Categories, and Cleaning Methods Considered in the Vapor Degreasing
Alternatives Analysis ............................................................................................................................... 5-10
Table 5-4: Size and Cleaning Categories and Applicable Alternative Cleaning Methods ...................... 5-11
Table 5-5: Baseline and Alternative Cleaning Methods and their Definitions ........................................ 5-12
Table 5-6: Reviewed Mold Release and Mold Cleaner Products: Safety Data Sheets and Solvent
Ingredients with Concentrations 5% or Higher........................................................................................ 5-16
Table 5-7: Estimated Percentage Share of Solvent Ingredients for Reviewed Mold Release and Mold
Cleaner Products ...................................................................................................................................... 5-17
Table 5-8: VOC Content for Mold Release and Mold Cleaner Products Based on Information in SDSs or
Technical Data Sheets .............................................................................................................................. 5-17
Table 5-9: Flash Point and Flammability Ratings for Mold Release and Mold Cleaner Products Based on
Information in SDSs or Technical Data Sheets ....................................................................................... 5-18
Table 5-10: Pricing and Customer Review Information for Mold Release and Mold Cleaner Products
Based on Manufacturer and Retailer Web Pages ..................................................................................... 5-19
Table 5-11: Safety Data Sheets and Solvent Ingredients with Concentrations 5% or Higher for Reviewed
AC Coil Cleaners ..................................................................................................................................... 5-20
Table 5-12: Estimated Percentage Market Share of Solvent Ingredients for AC Coil Cleaners.............. 5-21
Table 5-13: VOC Content for AC Coil Cleaners Based on Information in SDSs or Technical Data Sheets
................................................................................................................................................................. 5-21
Table 5-14: Flash Point and Flammability Ratings for AC Coil Cleaners Based on Information in SDSs or
Technical Data Sheets .............................................................................................................................. 5-22
Table 5-15: Pricing and Customer Review Information for AC Coil Cleaners Based on Manufacturer and
Retailer Web Pages .................................................................................................................................. 5-23
Table 5-16: Safety Data Sheets and Solvent Ingredients with Concentrations 5% or Higher for Reviewed
Energized Electrical Equipment Degreasers ............................................................................................ 5-24
Table 5-17: Estimated Percentage Share of Solvent Ingredients for Reviewed Energized Electrical
Equipment Degreasers ............................................................................................................................. 5-25
Table 5-18: VOC Content for Energized Electrical Equipment Degreasers Based on Information in SDSs
or Technical Data Sheets ......................................................................................................................... 5-25
Table 5-19: Flash Point and Flammability Ratings for Energized Electrical Equipment Degreasers Based
on Information in SDSs or Technical Data Sheets................................................................................... 5-25
Contents
ix
Table 5-20: Pricing and Customer Review Information for Energized Electrical Equipment Degreasers
Based on Manufacturer and Retailer Web Pages ..................................................................................... 5-26
Table 5-21: Safety Data Sheets and Solvent Ingredients with Concentrations 5% or Higher for Reviewed
Multi-Purpose Lubricants ........................................................................................................................ 5-27
Table 5-22: Estimated Percentage Share of Solvent Ingredients for Reviewed Multi-Purpose Lubricants 528
Table 5-23: VOC Content for Multi-Purpose Lubricants Based on Information in SDSs or Technical Data
Sheets ....................................................................................................................................................... 5-28
Table 5-24: Flash Point and Flammability Ratings for Multi-Purpose Lubricants Based on Information in
SDSs......................................................................................................................................................... 5-29
Table 5-25: Pricing and Customer Review Information for Multi-purpose Lubricants Based on
Manufacturer and Retailer Web Pages..................................................................................................... 5-30
Table 5-26: Safety Data Sheets and Solvent Ingredients with Concentrations 5% or Higher for Reviewed
Adhesives ................................................................................................................................................. 5-31
Table 5-27: Estimated Percentage Share of Solvent Ingredients for Reviewed Adhesive Applications Only
................................................................................................................................................................. 5-32
Table 5-28: VOC Content for Adhesives Based on Information In SDSs or Technical Data Sheets ...... 5-33
Table 5-29: Flash Point and Flammability Ratings for Adhesives Based on Information in SDSs Or
Technical Data Sheets .............................................................................................................................. 5-33
Table 5-30: Pricing and Customer Review Information for Adhesives Based on Manufacturer and Retailer
Web Pages................................................................................................................................................ 5-34
Table 5-31: Safety Data Sheets and Solvent Ingredients with Concentrations 5% or Higher for Reviewed
Cold Pipe Insulation Products .................................................................................................................. 5-35
Table 5-32: Estimated Percentage Share of Solvent Ingredients for Reviewed Cold Pipe Insulation
Products ................................................................................................................................................... 5-36
Table 5-33: VOC Content for Cold Pipe Insulation Products Based on Information in SDSs or Technical
Data Sheets .............................................................................................................................................. 5-36
Table 5-34: Flash Point and Flammability Ratings for Cold Pipe Insulation Products Based on
Information in SDSs or Technical Data Sheets ....................................................................................... 5-37
Table 5-35: Pricing and Customer Review Information for Cold Pipe Insulation Products Based on
Manufacturer and Retailer Web Pages..................................................................................................... 5-37
Table 5-36: Safety Data Sheets and Solvent Ingredients with Concentrations 5% or Higher for Reviewed
Spot Cleaners ........................................................................................................................................... 5-39
Table 5-37: Estimated Percentage Share of Solvent Ingredients for Reviewed Spot Cleaners ............... 5-40
Table 5-38: VOC Content for Spot Cleaners Based on Information in SDSs or Technical Data Sheets 5-41
Table 5-39: Flash Point and Flammability Ratings for Spot Cleaners Based on Information in SDSs or
Technical Data Sheets .............................................................................................................................. 5-42
Table 5-40: Pricing and Customer Review Information for Spot Cleaners Based on Manufacturer and
Retailer Web Pages .................................................................................................................................. 5-43
Table 5-41: Safety Data Sheets and Solvent Ingredients for Reviewed Products ................................... 5-45
Contents
x
Table 5-42: VOC Content, Based on Information in SDSs ..................................................................... 5-46
Table 5-43: Flash Point and Flammability Ratings, Based on Information in SDSs or Technical Data
Sheets ....................................................................................................................................................... 5-46
Table 5-44: Pricing Information for Pepper Spray Products Based on Manufacturer and Retailer Web
Pages ........................................................................................................................................................ 5-47
Table 6-1: TCE Emission Factors .............................................................................................................. 6-4
Table 6-2: Point Source Annual Volume of TCE Consumed .................................................................... 6-6
Table 6-3: Solvent Usage Projections in the U.S. ...................................................................................... 6-7
Table 6-4: Crosswalk of Freedonia Solvent, Product, and Use Categories ............................................... 6-8
Table 6-5: Total Use Category Annual Solvent Demand ........................................................................ 6-10
Table 6-6: TCE Speciation Factors .......................................................................................................... 6-12
Table 6-7: Non-Point Sources Annual Volume of TCE Consumed ........................................................ 6-13
Table 6-8: Summary of TCE Consumption Volume Estimates, by Use Category .................................. 6-13
Table 6-9: Number of TCE Facilities for Select Use Categories ............................................................. 6-15
Table 6-10: Number of Workers and ONUs per Facility for Select Use Categories ............................... 6-15
Table 6-11: Number of TCE Facilities for Laboratory Uses ................................................................... 6-17
Table 6-12: Estimated Number of Vapor Degreasers Using TCE ........................................................... 6-17
Table 6-13: Number of Workers and ONUs per Vapor Degreaser Facility............................................. 6-18
Table 6-14: Number of Mold Release Firms and Individuals.................................................................. 6-18
Table 6-15: Number of Lubricants and Greases Firms and Individuals .................................................. 6-20
Table 6-16: Number of Aerosol Spray Cleaning/Degreasing Firms and Individuals .............................. 6-27
Table 6-17: Number of Adhesive, Sealants, Paints and Coatings Firms and Individuals........................ 6-29
Table 6-18: Number of Liquid Cleaners and Degreasers Firms and Individuals..................................... 6-31
Table 6-19: Number of Disposal Firms and Individuals.......................................................................... 6-34
Table 6-20: Summary of Affected Firms and Employees ....................................................................... 6-34
Table 6-21: Estimated number of Consumer Users ................................................................................. 6-36
Table 7-1: Summary of Regulatory Options by Use Category .................................................................. 7-3
Table 7-2: Summary of Timing of Requirements under the Rule and the Analysis by Use Category ...... 7-6
Table 7-3: Number of Sites, Workers, and ONUs Affected by TCE Risk Management ........................... 7-9
Table 7-4: Industry Wage Rates (2022$) ................................................................................................. 7-11
Table 7-5: Total Rule Familiarization Costs (2022$) .............................................................................. 7-14
Table 7-6: Example Cost Components, by Reformulation Approach ..................................................... 7-17
Table 7-7: Crosswalk of Per-Formula Component Cost Estimates (2022$) - Minor Modification1 ....... 7-20
Table 7-8: Crosswalk of Per-Formula Component Cost Estimates (2022$) - Major Modification1........ 7-21
Table 7-9: Reformulation Costs Used in this Analysis (2022$) .............................................................. 7-22
Contents
xi
Table 7-10: Reformulation Costs by Use Category ................................................................................. 7-23
Table 7-11: Total Reformulation Costs by Use Category ........................................................................ 7-23
Table 7-12: Sizes, Cleaning Categories, and Cleaning Methods Considered in the Vapor Degreasing Cost
Analysis ................................................................................................................................................... 7-25
Table 7-13: Cleaning Methods and Their Definitions ............................................................................. 7-26
Table 7-14: Categories of Costs Considered in the Vapor Degreasing Cost Analysis ............................ 7-29
Table 7-15: Estimated Baseline Mix for Size and Type .......................................................................... 7-30
Table 7-16: Process Development for Identifying and Implementing the Alternative Cleaning Process 7-31
Table 7-17: Initial Capital Costs for New Machine, by Size, Cleaning Category, and Alternative Cleaning
Method ..................................................................................................................................................... 7-32
Table 7-18: Other Initial Capital Costs by Size, Cleaning Category, and Alternative Cleaning Method 7-36
Table 7-19: Cleaning Agent Costs: Initial Fill by Size, Cleaning Category, and Alternative Cleaning
Method ..................................................................................................................................................... 7-40
Table 7-20: Cleaning Agent Costs: Cleaning Agent Costs: Baseline Annual Replacement (2022$) ...... 7-44
Table 7-21: Cleaning Agent Costs by Size, Cleaning Category, and Alternative Cleaning Method: Annual
Replacement (2022$) ............................................................................................................................... 7-45
Table 7-22: Baseline Waste Disposal Costs by Size and Cleaning Category (2022$) ............................ 7-51
Table 7-23: Annual Waste Disposal Costs, by Size, Cleaning Category and Alternative Cleaning Method
(2022$) ..................................................................................................................................................... 7-52
Table 7-24: Annual Maintenance Costs, by Size, Cleaning Category, and Alternative Cleaning Method
(2022$) ..................................................................................................................................................... 7-58
Table 7-25: Baseline Labor Costs (2022$) Size and Cleaning Category ................................................. 7-62
Table 7-26: Annual Labor Costs (2022$) ................................................................................................ 7-63
Table 7-27: Annual Electricity Costs by Size, Cleaning Category, and Alternative Cleaning Method
(2022$) ..................................................................................................................................................... 7-66
Table 7-28: Annual Additional Floorspace Costs, by Size, Cleaning Category, and Alternative Cleaning
Method (2022$) ....................................................................................................................................... 7-69
Table 7-29: Initial and Recurring Costs by Alternative Cleaning Method: Small/General Cleaning (2022$)
................................................................................................................................................................. 7-71
Table 7-30: Initial and Recurring Costs by Alternative Cleaning Method: Medium/General Cleaning
(2022$) ..................................................................................................................................................... 7-72
Table 7-31: Initial and Recurring Costs by Alternative Cleaning Method: Large/General Cleaning (2022$)
................................................................................................................................................................. 7-72
Table 7-32: Initial and Recurring Costs by Alternative Cleaning Method: Small/High Precision (2022$) 773
Table 7-33: Initial and Recurring Costs by Alternative Cleaning Method: Medium/High Precision (2022$)
................................................................................................................................................................. 7-73
Table 7-34: Initial and Recurring Costs by Alternative Cleaning Method: Large/High Precision (2022$) 774
Contents
xii
Table 7-35: Initial and Recurring Costs by Alternative Cleaning Method: Small/Safety Critical (2022$) . 774
Table 7-36: Initial and Recurring Costs by Alternative Cleaning Method: Medium/Safety Critical (2022$)
................................................................................................................................................................. 7-75
Table 7-37: Initial and Recurring Costs by Alternative Cleaning Method: Large/Safety Critical (2022$) . 775
Table 7-38: Initial and Recurring Costs by Alternative Cleaning Method: Small/R&D Safety Critical
(2022$) ..................................................................................................................................................... 7-76
Table 7-39: Initial and Recurring Costs by Alternative Cleaning Method: Medium/R&D Safety Critical
(2022$) ..................................................................................................................................................... 7-76
Table 7-40: Summary of Incremental Costs for Vapor Degreasing: Including Trans-DCE (2022$) ...... 7-77
Table 7-41: Summary of Incremental Costs for Vapor Degreasing: Excluding Trans-DCE (2022$) ..... 7-77
Table 7-42: Develop Dermal Exposure Control Program (per facility)................................................... 7-78
Table 7-43: Conduct Dermal Protection Training (per worker) .............................................................. 7-78
Table 7-44: Unit Cost per Pair of Gloves (2022$) ................................................................................... 7-79
Table 7-45: Annual Per-Worker Cost for Dermal PPE (2022$) .............................................................. 7-79
Table 7-46: Total Dermal Protection Costs, by Use Category (2022$) ................................................... 7-80
Table 7-47: Monitoring Threshold Requirements.................................................................................... 7-82
Table 7-48. Example for Determining the Distribution of Exposure Threshold Categories Across Entities
with 8-hour and 15-minute TWA Exposure Data .................................................................................... 7-84
Table 7-49: Count of Entities, by Use Category and Exposure Threshold .............................................. 7-87
Table 7-50: Count of Employees, by Use Category, Worker Type, and Exposure Threshold ................ 7-88
Table 7-51: Summary of Costs Associated with an Exposure Evaluation of TCE at a Simple Worksite (10
workers sampled, 2022$) ......................................................................................................................... 7-91
Table 7-52: Summary of Per Facility and Per Employee Costs Associated with an Exposure Evaluation of
TCE (2022$) ............................................................................................................................................ 7-91
Table 7-53: Per Facility Monitoring Costs (2022$) ................................................................................. 7-92
Table 7-54: Per Worker/ONU Monitoring Costs (2022$) ....................................................................... 7-92
Table 7-55: Per Facility Notification and Recordkeeping Costs (2022$) ................................................ 7-93
Table 7-56: Per Worker Notification and Recordkeeping Costs (2022$) ................................................ 7-93
Table 7-57: PPE Costs per Worker or ONU by Sector and threshold (2022$) ........................................ 7-94
Table 7-58:Summary of Initial and Recurring Per Worker Monitoring and Respiratory WCPP Costs, by
Threshold and Sector (2022$) .................................................................................................................. 7-95
Table 7-59: Summary of Per Facility Respiratory WCPP Costs, by Threshold ...................................... 7-96
Table 7-60: Total WCPP Costs (Dermal and Respiratory) by Threshold and Use Category (2022$)..... 7-98
Table 7-61: Total Initial and Annual APF 50 Respirator Costs for Energized Electrical Cleaners ....... 7-103
Table 7-62: Total Annual Dermal Control Costs for Energized Electrical Cleaners ............................. 7-103
Contents
xiii
Table 7-63: Total Initial and Recurring Energized Electrical Cleaning Prescriptive Control Costs ..... 7-103
Table 7-64: Total 2% 20-Year Annualized Costs Under the Regulatory Options by Use Category (2022$)
............................................................................................................................................................... 7-111
Table 7-65: Total 3% 20-Year Annualized Costs Under the Regulatory Options by Use Category (2022$)
............................................................................................................................................................... 7-113
Table 7-66: Total 7% 20-Year Annualized Costs Under the Regulatory Options by Use Category (2022$)
............................................................................................................................................................... 7-114
Table 8-1: Summary of Regulatory Options by Use Category .................................................................. 8-3
Table 8-2: Summary of Timing of Requirements under the Rule and the Analysis by Use Category ...... 8-5
Table 8-3: Number of Individuals with TCE Exposure ............................................................................. 8-7
Table 8-4: Number of Individuals with Estimated Benefits for Occupational TCE Exposure Reductions,
by Exposure Type ...................................................................................................................................... 8-8
Table 8-5: Adjustment to Exposure to Account for Baseline PPE Use ..................................................... 8-9
Table 8-6: Mean Increase in LADC from One Year of Baseline Occupational Exposure, by Use Category
and Exposure Type .................................................................................................................................. 8-10
Table 8-7: Exposure Under the WCPP as a Percentage of Baseline Exposure, by Monitoring Threshold . 812
Table 8-8: Estimated Percentage of Workers and ONUs by ECEL Threshold Category ........................ 8-14
Table 8-9: Estimated Baseline Increase in LADC from One Year of Occupational Exposure, by Facility
ECEL Threshold Category (adjusted for baseline PPE Use) ................................................................... 8-16
Table 8-10: Estimated Post-Compliance Increase in LADC from One Year of Occupational Exposure
Under a WCPP, by Facility ECEL Threshold Category .......................................................................... 8-18
Table 8-11: Estimated Incremental Reduction in LADC from One Year of Occupational Exposure Under
a WCPP, by Facility ECEL Threshold Category1 .................................................................................... 8-20
Table 8-12: Excess Cancer Risk .............................................................................................................. 8-22
Table 8-13: Reduced Microrisk Per Exposed Individual from Eliminating One Year of Exposure, by
cancer site ................................................................................................................................................ 8-24
Table 8-14: Reduced Microrisk Per Exposed Individual from One Year of Reduced Exposure Under a
WCPP, by Option and cancer site ............................................................................................................ 8-25
Table 8-15: Value for Microrisk Reductions (2022$).............................................................................. 8-26
Table 8-16: Total Cancer Benefits from Eliminating 1 Year of Occupational Exposure, by Cancer Site,
Use Category and Exposure Type (Low Estimate, 2% Discount Rate, 2022$) ....................................... 8-30
Table 8-17: Total Cancer Benefits from Eliminating 1 Year of Occupational Exposure, by Cancer Site,
Use Category and Exposure Type (High Estimate, 2% Discount Rate, 2022$) ...................................... 8-31
Table 8-18: Total Cancer Benefits from Eliminating 1 Year of Occupational Exposure, by Cancer Site,
Use Category and Exposure Type (Low Estimate, 3% Discount Rate, 2022$) ....................................... 8-32
Table 8-19: Total Cancer Benefits from Eliminating 1 Year of Occupational Exposure, by Cancer Site,
Use Category and Exposure Type (High Estimate, 3% Discount Rate, 2022$) ...................................... 8-33
Table 8-20: Total Cancer Benefits from Eliminating 1 Year of Occupational Exposure, by Cancer Site,
Use Category and Exposure Type (Low Estimate, 7% Discount Rate, 2022$) ....................................... 8-34
Contents
xiv
Table 8-21: Total Cancer Benefits from Eliminating 1 Year of Occupational Exposure, by Cancer Site,
Use Category and Exposure Type (High Estimate, 7% Discount Rate, 2022$) ...................................... 8-35
Table 8-22: Total Cancer Benefits from 1 Year of WCPP, by Cancer Site, Use Category and Exposure
Type (Low Estimate, 2% Discount Rate, 2022$) .................................................................................... 8-36
Table 8-23: Total Cancer Benefits from 1 Year of WCPP, by Cancer Site, Use Category and Exposure
Type (High Estimate, 2% Discount Rate, 2022$) .................................................................................... 8-37
Table 8-24: Total Cancer Benefits from 1 Year of WCPP, by Cancer Site, Use Category and Exposure
Type (Low Estimate, 3% Discount Rate, 2022$) .................................................................................... 8-40
Table 8-25: Total Cancer Benefits from 1 Year of WCPP, by Cancer Site, Use Category and Exposure
Type (High Estimate, 3% Discount Rate, 2022$) .................................................................................... 8-42
Table 8-26: Total Cancer Benefits from 1 Year of WCPP, by Cancer Site, Use Category and Exposure
Type (Low Estimate, 7% Discount Rate, 2022$) .................................................................................... 8-44
Table 8-27: Total Cancer Benefits from 1 Year of WCPP, by Cancer Site, Use Category and Exposure
Type (High Estimate, 7% Discount Rate, 2022$) .................................................................................... 8-46
Table 8-28: Total 20-Year Annualized Benefits by Use Category and Regulatory Option (2 Percent
Discount Rate) ......................................................................................................................................... 8-48
Table 8-29: Total 20-Year Annualized Benefits by Use Category and Regulatory Option (3 Percent
Discount Rate) ......................................................................................................................................... 8-50
Table 8-30: Total 20-Year Annualized Benefits by Use Category and Regulatory Option (7 Percent
Discount Rate) ......................................................................................................................................... 8-52
Table 8-31: Number of Consumer Users with TCE Exposure ................................................................ 8-54
Table 8-32: TCE Exposure for Consumer Users ..................................................................................... 8-55
Table 8-33: Estimated Cancer Microrisk Reductions Per Person from Eliminating 1 Year of Consumer
Exposures ................................................................................................................................................. 8-55
Table 8-34: Estimated Values for Consumer Microrisk Reductions (2022$) .......................................... 8-56
Table 8-35: Total Estimated 20-Year Annualized Benefits for Consumer Microrisk Reductions (2022$). 857
Table 8-36: Estimated Annual Number of Pregnant Workers and ONUs ............................................... 8-59
Table 9-1: 20-Year Stream of Annual Undiscounted Costs, Benefits, and Net Benefits (millions, 2022$) 92
Table 9-2: Total 20-Year Annualized Net Benefits by Use Category and Regulatory Option (Low Benefits
Estimate, 2 Percent Discount Rate, 2022$)................................................................................................ 9-3
Table 9-3: Total 20-Year Annualized Net Benefits by Use Category and Regulatory Option (High
Benefits Estimate, 2 Percent Discount Rate, 2022$) ................................................................................. 9-4
Table 9-4: Total 20-Year Annualized Net Benefits by Use Category and Regulatory Option (Low Benefits
Estimate, 3 Percent Discount Rate, 2022$)................................................................................................ 9-5
Table 9-5: Total 20-Year Annualized Net Benefits by Use Category and Regulatory Option (High
Benefits Estimate, 3 Percent Discount Rate, 2022$) ................................................................................. 9-6
Table 9-6: Total 20-Year Annualized Net Benefits by Use Category and Regulatory Option (Low Benefits
Estimate, 7 Percent Discount Rate, 2022$)................................................................................................ 9-7
Contents
xv
Table 9-7: Total 20-Year Annualized Net Benefits by Use Category and Regulatory Option (High
Benefits Estimate, 7 Percent Discount Rate, 2022$) ................................................................................. 9-8
Table 9-8: Total 20-Year Annualized Net Benefits by Regulatory Option, (Millions, 2022$) ................. 9-9
Table 10-1: Number of Affected Small Entities for Use Categories Estimated from Individual Affected
Entities ..................................................................................................................................................... 10-4
Table 10-2: Number of Affected Firms and Small Firms Estimated from Census Data ......................... 10-6
Table 10-3: Per Firm Cost Impacts for Small Businesses........................................................................ 10-8
Table 10-4: Summary of Small Business Impacts ................................................................................... 10-9
Table 10-5: Industry Statistics for Sectors Affected by WCPP Requirements and Summary of
Employment at Affected Facilities ........................................................................................................ 10-11
Table 10-6: Paperwork Burden and Cost Associated with Rule Familiarization, Downstream Notification,
and Dermal Exposure Control ............................................................................................................... 10-15
Table 10-7: Paperwork Burden and Labor Cost Associated with Respiratory Monitoring ................... 10-16
Table 10-8: Paperwork Burden and Labor Cost Associated with Respiratory Recordkeeping ............. 10-17
Table 10-9: Paperwork Burden and Labor Cost Associated with Respiratory Notification .................. 10-18
Table 10-10: Paperwork Non-Labor Cost Associated with Respiratory Monitoring ............................ 10-19
Table 10-11: Summary of Three-Year Average Incremental Burden Hours and Costs for Primary Option
............................................................................................................................................................... 10-20
Table 10-12: Demographics of Communities Within 1-, 3-, and 5-mile Radii of Trichloroethylene
Facilities, Population Weighted Averages ............................................................................................. 10-23
Table 10-13: Demographics of Communities Within 1-, 3-, and 5-mile Radii of Facilities Manufacturing
TCE ........................................................................................................................................................ 10-24
Table 10-14: Total Number of Other TRI Facilities Within 1, 3 and 5 Miles of Facilities Manufacturing
TCE ........................................................................................................................................................ 10-25
Table 10-15: Community Demographics Near Occidental Chemical Holding Corp., Wichita, KS ...... 10-26
Table 10-16: Community Demographics Near Westlake facility, Westlake, LA .................................. 10-27
Table 10-17: Characteristics of General Worker Populations at National Level and Sector Worker
Populations in Areas Nearby Facilities Manufacturing TCE ................................................................. 10-28
Table 10-18: Demographics of Communities Within 1-, 3-, and 5-mile Radii of Facilities Using TCE to
Manufacture HFCs, Population-Weighted Averages ............................................................................. 10-29
Table 10-19: Total Number of Other TRI Facilities Within 1, 3 and 5 Miles of Facilities Using TCE to
Manufacture HFCs ................................................................................................................................. 10-30
Table 10-20: Community Demographics Near Mexichem Fluor, St. Gabriel, LA ................................ 10-30
Table 10-21: Community Demographics Near Arkema, Calvert City, KY ........................................... 10-31
Table 10-22: Characteristics of General Worker Populations at National Level and Sector Worker
Populations in Areas Nearby Facilities Manufacturing HFCs Using TCE ............................................ 10-32
Table 10-23: Demographics of Communities Within 1, 3, and 5 miles of Facilities Using TCE as a
Process Solvent for Manufacturing Battery Separators, Population Weighted Averages ..................... 10-33
Contents
xvi
Table 10-24: Community Demographics Near Battery Manufacturer Entek International, LLC., Lebanon,
OR .......................................................................................................................................................... 10-34
Table 10-25: Community Demographics Near Battery Manufacturer Microporous, LLC., Piney Flats, TN
............................................................................................................................................................... 10-35
Table 10-26: Total Number of Other TRI Facilities Within 1, 3 and 5 Miles of Facilities Using TCE in
Battery Manufacture .............................................................................................................................. 10-35
Table 10-27: Characteristics of General Worker Populations at National Level and Sector Worker
Populations in Areas Nearby Facilities Using TCE to Manufacture Batteries ...................................... 10-37
Table 10-28: Demographics of Communities Within 1-, 3-, and 5-mile Radii of TCE Vapor Degreasing
Facilities, Population-Weighted averages .............................................................................................. 10-38
Table 10-29: Demographics of Communities Within 1-, 3-, and 5-mile Radii of Chicago Metropolitan
TCE Vapor Degreasing Facilities, Population-Weighted Averages ...................................................... 10-39
Table 10-30: Total Number of Other TRI Facilities Within 1, 3 and 5 Miles of Chicago Metropolitan TCE
Vapor Degreasing Facilities ................................................................................................................... 10-40
Table 10-31: Characteristics of General Worker Populations at National Level and Sector Worker
Populations in Areas Nearby Chicago Metropolitan TCE Vapor Degreasing Facilities ....................... 10-43
Table 10-32: Demographics of Communities Within 1-, 3-, and 5-mile Radii of Facilities Vapor
Degreasing of Narrow Tubes ................................................................................................................. 10-45
Table 10-33: Total Number of Other TRI Facilities Within 1, 3 and 5 Miles of Facilities Manufacturing
TCE ........................................................................................................................................................ 10-46
Table 10-34: Community Demographics Near Salem Tube, Inc., Greenville, PA ................................ 10-46
Table 10-35: Community Demographics Near Superior Tube, Co., Collegeville, PA .......................... 10-47
Table 10-36: Community Demographics Near Summerhill Hill Precision Tube, Scottdale, PA .......... 10-48
Table 10-37: Community Demographics Near Ametek Specialty Metal Products, Wallingford, CT ... 10-48
Table 10-38: Community Demographics Near Handytube Corp., Camden, PA ................................... 10-49
Table 10-39: Characteristics of General Worker Populations at National Level and Sector Worker
Populations in Areas Nearby Facilities Vapor Degreasing of Narrow Tubes........................................ 10-50
Table 10-40: Demographics of Communities Within 1-, 3-, and 5-mile Radii ..................................... 10-51
Table 10-41: Total Number of Other TRI Facilities Within 1, 3 and 5 Miles of Facilities Manufacturing
TCE ........................................................................................................................................................ 10-51
Table 10-42: Characteristics of General Worker Populations at National Level and Sector Worker
Populations in Areas Nearby Facilities Manufacturing Synthetic Paper ............................................... 10-52
Contents
xvii
Executive Summary
Introduction
The U.S. Environmental Protection Agency (EPA) is finalizing a rule under section 6(a) of the Toxic
Substances Control Act (TSCA) for trichloroethylene (TCE) to address the unreasonable risk of injury to
human health under its conditions of use (COUs). This report estimates and evaluates the costs, benefits,
and impacts expected to result from the rule to regulate manufacture (including import), processing,
distribution in commerce, industrial and commercial use, and disposal of TCE to address unreasonable
risks so that they are no longer unreasonable. EPA is finalizing the regulation under the authority of
TSCA section 6(a) after completing a risk evaluation under TSCA section 6(b) and determining that the
chemical substance presents an unreasonable risk of injury to human health. The rule, “Regulation of
Trichloroethylene Under TSCA Section 6(a),” addresses the unreasonable risk EPA determined is
presented by TCE under the COUs. These COUs are presented below in Table ES-1. Table ES-1 also lists
the use categories (or categories of TCE use that are considered in the economic analysis) and defines
how the economic analysis use categories map to the COUs.
Table ES-1: Use Categories Considered in the Economic Analysis Mapped to the Conditions of Use
(COUs) Defined in the Risk Evaluation
Use Category
Laboratory Use
Manufacturing
Import/Repackage
Battery and Synthetic Paper Processing Aid
Condition of Use (COU)
Industrial and commercial use in hoof polish; gun scrubber; pepper spray;
other miscellaneous industrial and commercial uses1
Manufacturing: domestic manufacture
Manufacturing: import
Processing: repackaging
Industrial and commercial use as processing aids in process solvent used in
battery manufacture; process solvent used in polymer fiber spinning,
fluoroelastomer manufacture and Alcantara manufacture; extraction solvent
used in caprolactam manufacture; precipitant used in beta-cyclodextrin
manufacture2
HFC Manufacturing
Processing: processing as a reactant/intermediate3
Intermediate in HCl Production4
Processing: processing as a reactant/intermediate3
Fluoroelastomer Manufacture
Open-Top Vapor Degreasing
Enclosed Vapor Degreasing
Conveyorized Vapor Degreasing
Web Vapor Degreasing
Batch Cold Cleaning
Disposal to Wastewater5
Energized Electrical Cleaners
Incorporation Into Formulation, Mixture, or
Reaction Product
Executive Summary
Industrial and commercial use as processing aids in process solvent used in
battery manufacture; process solvent used in polymer fiber spinning,
fluoroelastomer manufacture and Alcantara manufacture; extraction solvent
used in caprolactam manufacture; precipitant used in beta-cyclodextrin
manufacture2
Industrial and commercial use as a solvent for open-top batch vapor
degreasing
Industrial and commercial use as a solvent for closed-loop batch vapor
degreasing
Industrial and commercial use as a solvent for in-line conveyorized vapor
degreasing
Industrial and commercial use as a solvent for in-line web cleaner vapor
degreasing
Industrial and commercial use as a solvent for cold cleaning
Processing: recycling
Disposal
Industrial and commercial use as a solvent for aerosol spray degreaser/cleaner
and mold release6
Processing: incorporation into a formulation, mixture or reaction product
ES-1
Table ES-1: Use Categories Considered in the Economic Analysis Mapped to the Conditions of Use
(COUs) Defined in the Risk Evaluation
Use Category
Mold Release
Condition of Use (COU)
Industrial and commercial use as a solvent for aerosol spray degreaser/cleaner
and mold release6
Consumer use as a solvent in mold release
Industrial and commercial use in hoof polish; gun scrubber; pepper spray;
other miscellaneous industrial and commercial uses1
Liquid Cleaners and Degreasers
Consumer use as a solvent in liquid electronic degreaser/cleaner
Consumer use as a solvent in liquid degreaser/cleaner
Consumer use as a solvent in liquid gun scrubber
Aerosol Spray Cleaning/Degreasing7
Industrial and commercial use as a solvent for aerosol spray degreaser/cleaner
and mold release6
Industrial and commercial use in hoof polish; gun scrubber; pepper spray;
other miscellaneous industrial and commercial uses1
Industrial and commercial use in automotive care products in brake and parts
cleaner
Consumer use as a solvent in brake and parts cleaner
Consumer use as a solvent in aerosol electronic degreaser/cleaner
Consumer use as a solvent in aerosol spray degreaser/cleaner
Consumer use as a solvent in aerosol gun scrubber
Industrial and commercial use as a lubricant and grease in tap and die fluid
Lubricants and Greases
Industrial and commercial use as a lubricant and grease in penetrating
lubricant
Consumer use as a lubricant and grease in tap and die fluid
Consumer use as a lubricant and grease in penetrating lubricant
Adhesives, Sealants, Paints and Coatings
Industrial and commercial use as an adhesive and sealant in solvent-based
adhesives and sealants; tire repair cement/sealer; mirror edge sealant
Consumer use as an adhesive and sealant in solvent-based adhesives and
sealants
Consumer use as an adhesive and sealant in tire repair cement/sealer
Industrial and commercial use in paints and coatings as a diluent in solventbased paints and coatings
Industrial and commercial use in corrosion inhibitors and anti-scaling agents
Spot Removers
Industrial and commercial use in cleaning and furniture care products in
carpet cleaner and wipe cleaning
Industrial and commercial use in laundry and dishwashing products in spot
remover
Consumer use as a cleaning and furniture care product in carpet cleaner
Consumer use as a cleaning and furniture care product in aerosol spot remover
Consumer use as a cleaning and furniture care product in liquid spot remover
Executive Summary
ES-2
Table ES-1: Use Categories Considered in the Economic Analysis Mapped to the Conditions of Use
(COUs) Defined in the Risk Evaluation
Use Category
Pepper Spray
Distribution in Commerce
Condition of Use (COU)
Industrial and commercial use in hoof polish; gun scrubber; pepper spray;
other miscellaneous industrial and commercial uses1
Consumer use in pepper spray
Distribution in commerce
Processing: incorporation into articles
Uses where no active users were identified
(costs and benefits are not estimated)
Industrial and commercial use as processing aids in process solvent used in
battery manufacture; process solvent used in polymer fiber spinning,
fluoroelastomer manufacture and Alcantara manufacture; extraction solvent
used in caprolactam manufacture; precipitant used in beta-cyclodextrin
manufacture2 (Only battery manufacture and fluoroelastomer manufacture are
believed to be active uses)
Industrial and commercial use in arts, crafts, and hobby materials in fixatives
and finishing spray coatings
Industrial and commercial use in hoof polish; gun scrubber; pepper spray;
other miscellaneous industrial and commercial uses1 (no active users of TCE
for industrial and commercial use of hoof polish were identified)
Industrial and commercial use in apparel and footwear care products in shoe
polish
Industrial and commercial use as a functional fluid in heat exchange fluid
Industrial and commercial use as ink, toner and colorant products in toner aid
Consumer use as a solvent in liquid tire cleaner
Consumer use as a solvent in aerosol tire cleaner
Consumer use as an adhesive and sealant in mirror edge sealant
Consumer use in fabric spray
Consumer use in arts, crafts, and hobby materials in fixative and finishing
spray coatings
Consumer use in apparel and footwear products in shoe polish
Consumer use in toner aid
Consumer use in film cleaner
Consumer use in hoof polish
1Multiple use categories map to this COU: (1) Laboratory Use, (2) Pepper Spray, (3) Liquid Cleaners and Degreasers, (4) Aerosol
Spray Cleaning/Degreasing, and (5) inactive uses
2Multiple use categories map to this COU: (1) Battery and Synthetic Paper Processing Aid, and (2) Fluoroelastomer Manufacture,
(3) inactive uses.
3Multiple use categories map to this COU: (1) Hydrofluorocarbon (HFC) Manufacturing, and (2) Hydrochloric Acid Production in
Ethylene Dichloride (EDC) Manufacturing and Refineries
4TCE is a byproduct of the EDC production process, where it is either sold as TCE or converted to hydrochloric acid (HCl). Some
refineries also use TCE as a chloriding agent providing a source of Chloride Ion (Cl-) which acts as a catalyst promoter.
5The disposal of TCE to industrial pre-treatment, industrial treatment, or publicly owned treatment works are the uses prohibited
under the regulatory options.
6Multiple use categories map to this COU: (1) Aerosol Spray Cleaning/Degreasing, and (2) Mold Release
7The Aerosol Spray Cleaning/Degreasing Use Category is broken out into Energized Electrical Cleaners and Aerosol Spray
Cleaning/Degreasing (except EEC) in some tables and combined in a single row in other tables.
Background
TCE is a volatile organic compound (VOC) used in industry as well as in commercial and consumer
products. The primary use of TCE is as an intermediate during the manufacture of refrigerants,
specifically HFC-134a, which accounts for about 83.6% of TCE’s annual production volume (EPA
2020e). TCE is also used as a solvent, frequently in cleaning and degreasing (including spot cleaning,
Executive Summary
ES-3
vapor degreasing, cold cleaning, and aerosol degreasing), which accounts for another 14.7% of TCE
production volume, leaving approximately 1.7% for other uses.
TCE is also a widely used solvent in a variety of commercial and consumer applications including
lubricants, adhesives and sealants, paints and coatings, and other miscellaneous products. The total
aggregate annual production volume ranged from 100 to 250 million pounds between 2016 and 2019
according to CDR (EPA 2016-2019).
Under TSCA section 6(a), if the Administrator determines, through a TSCA section 6(b) risk evaluation
that the manufacture (including import), processing, distribution in commerce, use, or disposal of a
chemical substance or mixture, or any combination of such activities, presents an unreasonable risk of
injury to health or the environment, EPA must by rule apply one or more of the following requirements to
the extent necessary so that the chemical substance or mixture no longer presents such risk.
•
Prohibit or otherwise restrict the manufacturing, processing, or distribution in commerce of the
substance or mixture, or limit the amount of such substance or mixture which may be manufactured,
processed, or distributed in commerce (section 6(a)(1)).
•
Prohibit or otherwise restrict the manufacturing, processing, or distribution in commerce of the
substance or mixture for a particular use or above a specific concentration for a particular use (section
6(a)(2)).
•
Limit the amount of the substance or mixture which may be manufactured, processed, or distributed
in commerce for a particular use or above a specific concentration for a particular use specified
(section 6(a)(2)).
•
Require clear and adequate minimum warning and instructions with respect to the substance or
mixture or any article containing the substance or mixture’s use, distribution in commerce, or
disposal, or any combination of those activities, to be marked on or accompanying the substance or
mixture (section 6(a)(3)).
•
Require manufacturers and processors of the substance or mixture to make and retain certain records
or conduct certain monitoring or testing (section 6(a)(4)).
•
Prohibit or otherwise regulate any manner or method of commercial use of the substance or mixture
(section 6(a)(5)).
•
Prohibit or otherwise regulate any manner or method of disposal of the substance or mixture, or any
article containing such substance or mixture, by its manufacturer or processor or by any person who
uses or disposes of it for commercial purposes (section 6(a)(6)).
•
Direct manufacturers or processors of the substance or mixture to give notice of the unreasonable risk
determination to distributors, certain other persons, and the public, and to replace or repurchase the
substance or mixture (section 6(a)(7)).
EPA analyzed how the TSCA section 6(a) requirements could be applied to address the unreasonable risk
found to be present in the 2020 Risk Evaluation for TCE and the final revised unreasonable risk
determination, so that TCE no longer presents such unreasonable risk. This document presents an
economic analysis of EPA’s regulatory action (Option 1) and an alternative regulatory action (Option 2).
Executive Summary
ES-4
Regulatory Options Analyzed
Table ES-2 summarizes the regulatory options by use category. Pursuant to TSCA section 6(b), EPA
determined that TCE presents an unreasonable risk of injury to health, without consideration of costs or
other nonrisk factors, including an unreasonable risk to a potentially exposed or susceptible subpopulation
(PESS) identified as relevant to the 2020 Risk Evaluation for TCE by EPA, under the conditions of use
(EPA 2020e, EPA 2022c). Accordingly, to address the unreasonable risk, EPA is finalizing a regulation
under TSCA section 6(a), to:
(i) prohibit the manufacture (including import) and processing of TCE for all uses (including all
consumer uses), with longer compliance timeframes for manufacture, processing, and distribution in
commerce related to certain industrial and commercial uses;
(ii) prohibit the industrial and commercial use of TCE with longer compliance timeframes for certain
uses;
(iii) Prohibit the manufacture (including import) and processing of TCE as an intermediate for the
manufacturing of hydrofluorocarbon134a (HFC-134a), following an 8.5-year phaseout;
(iv) Prohibit the industrial and commercial use of TCE as a solvent for closed-loop batch vapor
degreasing for rayon fabric scouring for end use in rocket booster nozzle production by Federal
agencies and their contractors, following a 10-year phaseout;
(v) Prohibit the manufacture (including import), processing, distribution in commerce, and use of
TCE as a laboratory chemical for asphalt testing and recovery, following a 10-year phaseout;
(vi) Prohibit the manufacture (including import), processing, distribution in commerce, and industrial
and commercial use of TCE as a solvent in batch vapor degreasing for essential aerospace parts and
components and narrow tubing used in medical devices, following a 7-year TSCA section 6(g)
exemption;
(vii) Prohibit the manufacture (including import), processing, distribution in commerce, and
industrial and commercial use of TCE as a solvent in closed loop vapor degreasing necessary for
rocket engine cleaning by Federal agencies and their contractors, following a 7-year TSCA section
6(g) exemption;
(viii) For vessels of the Armed Forces and their systems, and in the maintenance, fabrication, and
sustainment for and of such vessels and systems, prohibit the industrial and commercial use of TCE
as: potting compounds for naval electronic systems and equipment; sealing compounds for high and
ultra-high vacuum systems; bonding compounds for materials testing and maintenance of underwater
systems and bonding of nonmetallic materials; and cleaning agents to
satisfy cleaning requirements (which includes degreasing using wipes, sprays, solvents and vapor
degreasing) for: materials and components required for military ordinance testing; temporary resin
repairs in vessel spaces where welding is not authorized; ensuring polyurethane adhesion for
electronic systems and equipment repair and installation of elastomeric materials; various naval
combat systems, radars, sensors, equipment; fabrication and prototyping processes to remove coolant
and other residue from machine parts; machined part fabrications for naval systems; installation of
topside rubber tile material aboard vessels; and vapor degreasing required for substrate surface
preparation prior to electroplating processes, following a 10-year TSCA section 6(g) exemption;
(ix) Prohibit the emergency industrial and commercial use of TCE in furtherance of the NASA
Executive Summary
ES-5
mission for specific conditions which are critical or essential and for which no technically and
economically feasible safer alternative is available, following a 10-year TSCA section 6(g)
exemption;
(x) Prohibit the manufacture (including import), processing, distribution in commerce, disposal, and
use of TCE as a processing aid for manufacturing battery separators for lead acid batteries, following
a 20-year TSCA section 6(g) exemption;
(xi) Prohibit the manufacture (including import), processing, distribution in commerce, disposal, and
use of TCE as a processing aid for manufacturing specialty polymeric microporous sheet materials
following a 15-year TSCA section 6(g) exemption;
(xii) Prohibit the manufacture (including import), processing, distribution in commerce,
and use of TCE as a laboratory chemical for essential laboratory activities and some research
and development activities, following a 50-year TSCA section 6(g) exemption;
(xiii) Require strict workplace controls to limit exposure to TCE, including compliance with a TCE
workplace chemical protection program (WCPP), which would include requirements for an interim
existing chemical exposure limit (ECEL) revised from the proposed rule, as well as dermal
protection, for conditions of use with long term phaseouts or time-limited exemptions under TSCA
section 6(g) or prescriptive workplace controls;
(xiv) Prohibit the disposal of TCE to industrial pre-treatment, industrial
treatment, or publicly owned treatment works through a phaseout allowing for longer timeframes for
disposal necessary for certain industrial and commercial uses along with a 50-year TSCA section 6(g)
exemption for cleanup projects before prohibition and interim requirements for wastewater worker
protection for such activities; and
(xv) Establish recordkeeping and downstream notification requirements.
The primary alternative regulatory option, Option 2, follows EPA’s proposed regulatory option and
includes the following requirements that differ from than the Option 1 requirements:
•
A lower ECEL of 0.0011 ppm.
•
Laboratory use for asphalt testing is prohibited sooner.
•
The exemption for battery separator manufacture is 10 years instead of 15 for lead acid batteries
and 5 years for lithium batteries; the processing aid use for synthetic paper is not included in the
exemption.
•
The use as an intermediate in HCl manufacture is subject to prohibition and interim WCPP
requirements.
•
Disposal to wastewater is prohibited.
•
Energized Electrical Cleaners (EEC) are prohibited six months after the effective date of the rule,
Table ES-2: Summary of Regulatory Options by Use Category
Executive Summary
ES-6
Option 1 (ECEL of 0.2 ppm)
Option 2 (ECEL of 0.0011ppm)
WCPP followed by prohibition1
Prohibition/WCPP followed by prohibition2
Use Category
1Asphalt
Laboratory Use
Manufacturing
Import/Repackage
Battery and Synthetic
Paper Processing Aid
HFC Manufacturing
2Asphalt Testing: Prohibited. Other lab uses:
Testing: WCPP for 10 years followed
by prohibition (10-year 6g exemption). Other lab Exempt for 50 years, interim requirements of
uses: Exempt for 50 years, interim requirements
Workplace Chemical Protection Program
of Workplace Chemical Protection Program
(WCPP) 6 months after rule finalization.
(WCPP) 6 months after rule finalization.
WCPP for limited uses until prohibited3
3Interim requirements of Workplace Chemical Protection Program (WCPP) 6 months after rule
finalization.
WCPP followed by prohibition5
WCPP followed by prohibition4
415-year
510-year exemption with WCPP 6 months after
exemption with WCPP 6 months after
rule finalization for lead acid battery separators.
rule finalization for battery separator
5-year exemption with WCPP 6 months after
manufacture. Synthetic paper use prohibited.
rule finalization for lithium battery
separators.15-year exemption with WCPP 6
months after rule finalization for synthetic paper.
Long-Term Phase Out with WCPP followed by Prohibition6
6Long-term
phase out to prohibition over 8.5 years, interim requirements of WCPP.
Not Subject to Rule
WCPP followed by prohibition7
Intermediate in HCl
Production
Fluoroelastomer
Manufacture
Open-Top Vapor
Degreasing
Enclosed Vapor
Degreasing
Conveyorized/Web
Vapor Degreasing
Batch Cold Cleaning
Disposal to Wastewater
Executive Summary
7WCPP
6 months to 2 years after rule
finalization followed by prohibition.
WCPP followed by Prohibition8
8WCPP
6 months to 2 years after rule finalization followed by prohibition.
Prohibition with Interim WCPP for Exemptions9
9A
6(g) exemption for 7 years applies to OTVD for narrow tubes for aerospace or medical device
use. A 6(g) exemption for 10 years applies to naval combat systems, radars, sensors, equipment, and
fabrication and prototyping processes for OTVDs. A 6(g) exemption for 7 years applies to humanrated rocket engine cleaning in EVDs by Federal agencies and their contractors. A 6(g) exemption
for 10 years applies to rayon fabric scouring in EVDs for rocket booster nozzle production for
Federal agencies and their contractors.
Prohibition11
Prohibition 1 year after rule finalization with
WCPP requirements for POTWs exceeding a
11One year after rule finalization.
water screening level and worker protection
requirements for cleanup sites and industrial
treatment/pre-treatment. 10
10For POTWs above the water screening level,
WCPP would be required (with the interim
occupational exposure limit (ECEL)). For
cleanup site workers and industrial
treatment/pre-treatment, use TSCA regulatory
limit (new interim occupational exposure limit
(ECEL)) within the framework of existing
OSHA HAZWOPER requirements.
ES-7
Table ES-2: Summary of Regulatory Options by Use Category
Use Category
Option 1 (ECEL of 0.2 ppm)
Option 2 (ECEL of 0.0011ppm)
Prohibition13
Prohibition with Interim APF50 Respirator
Requirement12
Energized Electrical
Cleaners
Incorporation into
Formulation, Mixture,
or Reaction Product
Commercial Use Pepper
Spray
Incorporation into
Articles
Mold Release
Liquid Cleaners and
Degreasers
Aerosol Spray
Cleaning/Degreasing
(except EEC)
Lubricants and Greases
Adhesives, Sealants,
Paints and Coatings
Functional Fluids
Spot Removers
Film Cleaner
Toner Aid
13Six
months after rule finalization.
12Prohibit
3 years after rule finalization with
interim prescriptive respiratory protection
requirements of APF 50 respirator use.
Prohibition14,15
14Prohibition
six months after rule finalization.
15Adhesives
and Sealants for Aerospace uses have a 5-year exemption with interim WCPP. Since
the numbers of workers affected by the exemption is unknown, the exemption is not accounted for
in the analysis and the costs and benefits from prohibition are assumed for all affected users of
adhesives, sealants, paints, and coatings.
Polish
Estimated Number of Affected Entities and Individuals
Table ES-3 presents a summary of the number of firms using TCE and the number of occupational and
consumer users 1 exposed to TCE for each use category. Occupational users include workers working
directly with TCE and occupational non-users (ONUs). Sections 6.2 and 6.3 describes the approach used
to estimate the number of affected entities and individuals.
0F
1
Note that EPA was unable to estimate the number of bystanders that might be exposed during consumer uses.
Executive Summary
ES-8
Table ES-3: Summary of Occupational and Consumer Users
Number of
Number of Sites
Use Category
Workers
Using TCE
Exposed to TCE
Laboratory Use
Manufacturing
Import/Repackage
Processing Aid (Battery and
Synthetic Paper)
HFC Manufacturing
Intermediate in HCl Production
Fluoroelastomer Manufacture
Open-Top Vapor Degreasing
Enclosed Vapor Degreasing
Conveyorized Vapor Degreasing
Web Vapor Degreasing
Batch Cold Cleaning
Disposal to Wastewater
Incorporation Into Formulation,
Mixture, or Reaction Product
Mold Release
Liquid Cleaners and Degreasers
Aerosol Spray Cleaning/Degreasing
Lubricants and Greases
Adhesives, Sealants, Paints and
Coatings
Spot Removers
Film Cleaner
Toner Aid
Polish
Pepper Spray
Total
Number of
ONUs Exposed
to TCE
Number of
Consumers
251
2
9
251
140
18
2259
68
9
-
3
51
24
-
2
28
2
350
7
8
1
52
739
38
532
34
2,100
42
48
6
312
9,607
18
252
16
1,400
28
32
4
208
3,695
-
28
448
140
17
11,815
4,366
345
371
16,053
5,852
1,751
44
1,667
696
76
67
190
12,089
3,159
65
616
288
2,184
4,980
23,070
14,940
53,210
3,735
14,659
2,911
20,600
Estimated Incremental Costs
Table ES-4 Table ES-5 and Table ES-6 present the total 20-year annualized costs for 3 and 7 percent
discount rates, respectively. Note that EPA was unable to estimate costs of prohibition for four use
categories that have a prohibition requirement under one of the options (Battery and Synthetic Paper
Processing Aid, HFC Manufacturing, Intermediate in HCl Manufacture, and Fluoroelastomer
Manufacture). Since the costs of prohibition are unknown, the costs of compliance with a WCPP are used
a lower bound estimate for prohibition in these instances.
Costs are presented in 2022 dollars.
Executive Summary
ES-9
Table ES-4: Total 2% 20-Year Annualized Costs Under the Regulatory Options by Use Category
(2022$)
Use Category
Laboratory Use
Manufacturing
Battery and Synthetic Paper
Processing Aid
HFC Manufacturing
Intermediate in HCl Production
Fluoroelastomer Manufacture
Open-Top Vapor Degreasing
Enclosed Vapor Degreasing
Conveyorized Vapor Degreasing
Web Vapor Degreasing
Option 1 (ECEL 0.20 ppm)
Total
Annualized
Notes
Cost
$1,020,962
20-Years of WCPP Costs
$257,925
$271,592
9-Years of WCPP Costs3
Not subject to rule under
Option 1
$181,062 20-Years of WCPP Costs4
$36,605
$45,445,026 Alternatives cost from Table
7-41 with WCPP costs
$917,124 incurred during transition to
prohibition under exemptions5
$1,037,791
$129,724
Batch Cold Cleaning
$6,745,641
Disposal to Wastewater
$7,077,581
Energized Electrical Cleaners7
20-Years of WCPP Costs1
$575,451
Alternatives cost from Table
7-41
20-Years of WCPP Costs6
1 year of Prescriptive
Control costs followed by
prohibition
Option 2 (ECEL 0.0011 ppm)
Total
Annualized
Notes
Cost
$1,020,962
20-Years of WCPP Costs
$496,593
$311,972
20-Years of WCPP Costs2
$71,153
9-Years of WCPP Costs3
$1,916,912
20-Years of WCPP Costs4
$207,982 20-Years of WCPP Costs4
$45,493,389 Alternatives cost from Table
7-41 with WCPP costs
incurred during transition to
$921,179 prohibition under
exemptions5
$1,037,791
Alternatives cost from
$129,724
Table 7-41
$6,745,641
$18,630,260
$575,451
Mold Release7
$52,573
$52,573
Liquid Cleaners and Degreasers7
Aerosol Spray
Cleaning/Degreasing (except
EEC) 7
$75,756
$75,756
$99,119
$99,119
Lubricants and Greases7
$28,124
Adhesives, Sealants, Paints and
Coatings7
$60,332
$60,332
Spot Removers7
$38,715
$38,715
$3,754
$64,054,859
$3,754
Pepper
Spray7
Total
Costs of rule familiarization
and reformulation.
-
$28,124
$77,917,383
20-Years of WCPP Costs6
Estimated as Option 1 Costs
Costs of rule familiarization
and reformulation.
-
1TCE
use is prohibited after 15 years, but since the costs of TCE alternatives are unknown, the WCPP costs are used as a lower
bound estimate.
2TCE use is prohibited after 10 years for battery separator manufacture and in six months for synthetic paper, but since the costs of
TCE alternatives are unknown, the WCPP costs are used as a lower bound estimate.
3TCE use is prohibited after 8.5 years. It is unknown what the cost implications of a 8.5 year phase out would be, so the costs
reflect 9 years of WCPP costs under both options.
4Since the regulatory costs of prohibition under this use are unknown, the analysis uses the WCPP costs as a proxy for the
prohibition costs to calculate total costs. Thus, the total costs are estimated as the 20-year annualized costs of WCPP compliance.
Interim WCPP requirements apply for 2 years under both options for these use categories.
5There is longer term compliance timeframe applicable to five Open-Top Vapor Degreasers using TCE for narrow tubes and
medical device (7 years), one Open-Top Vapor Degreaser using TCE in naval combat systems, radars, sensors, equipment, and
fabrication and prototyping processes (10 years), one enclosed vapor degreasing application using TCE to scour rayon fabric for
use in rocket booster engine nozzles (10 years). WCPP compliance is required for 7 years, followed by prohibition for industrial
and commercial use of TCE in closed loop vapor degreasing necessary for human-rated rocket engine cleaning by Federal
agencies and their contractors. The analysis accounts for one enclosed vapor degreaser and one Open-Top Vapor Degreaser with 9
Executive Summary
ES-10
years of WCPP costs and prohibition costs in years 10-20, One enclosed vapor degreaser and five Open-Top Vapor Degreaser
with 6 years of WCPP costs and prohibition costs in years 7-20. Other vapor degreasers have prohibition costs starting at “time
zero”.
6Since the regulatory costs of prohibition under this use are unknown, the analysis uses the WCPP costs as a proxy for the
prohibition costs to calculate total costs. Thus, the total costs are estimated as the 20-year annualized costs of WCPP compliance.
7The costs for the Import/Repackage and Incorporation into Formulation, Mixture, or Reaction Product use categories are
accounted under the respective end-use categories for their products.
Table ES-5: Total 3% 20-Year Annualized Costs Under the Regulatory Options by Use Category
(2022$)
Use Category
Laboratory Use
Manufacturing
Battery and Synthetic Paper
Processing Aid
HFC Manufacturing
Intermediate in HCl Production
Fluoroelastomer Manufacture
Open-Top Vapor Degreasing
Enclosed Vapor Degreasing
Conveyorized Vapor Degreasing
Web Vapor Degreasing
Option 1 (ECEL 0.20 ppm)
Total
Annualized
Notes
Cost
$1,019,851
20-Years of WCPP Costs
$257,227
$270,832
9-Years of WCPP Costs3
Not subject to rule under
Option 1
$180,554 20-Years of WCPP Costs4
$51,402,026
Alternatives cost from Table
$1,011,662 7-41 with WCPP costs
incurred during transition to
prohibition under exemptions5
$38,271
$1,175,495
$146,937
Batch Cold Cleaning
$7,640,714
Disposal to Wastewater
$7,076,676
Energized Electrical Cleaners7
20-Years of WCPP Costs1
$622,687
Alternatives cost from Table
7-41
20-Years of WCPP Costs6
1 year of Prescriptive
Control costs followed by
prohibition
Option 2 (ECEL 0.0011 ppm)
Total
Annualized
Notes
Cost
$1,019,851
20-Years of WCPP Costs
$495,780
$313,678
20-Years of WCPP Costs2
$74,458
9-Years of WCPP Costs3
$1,913,754
20-Years of WCPP Costs4
$209,118 20-Years of WCPP Costs4
$51,454,277 Alternatives cost from Table
7-41 with WCPP costs
incurred during transition to
$1,016,091 prohibition under
exemptions5
$1,175,495
Alternatives cost from
$146,937
Table 7-41
$7,640,714
$18,606,842
$622,687
Mold Release7
$57,453
$57,453
Liquid Cleaners and Degreasers7
Aerosol Spray
Cleaning/Degreasing (except
EEC) 7
$82,789
$82,789
$108,321
$108,321
Costs of rule familiarization
and reformulation.
Lubricants and Greases7
$30,735
Adhesives, Sealants, Paints and
Coatings7
$65,933
$65,933
Spot Removers7
$42,309
$42,309
Pepper
Spray7
Total
$4,103
$71,234,573
$30,735
20-Years of WCPP Costs6
Estimated as Option 1 Costs
Costs of rule familiarization
and reformulation.
$4,103
-
$85,081,323
-
1TCE
use is prohibited after 15 years, but since the costs of TCE alternatives are unknown, the WCPP costs are used as a lower
bound estimate.
2TCE use is prohibited after 10 years for battery separator manufacture and in six months for synthetic paper, but since the costs of
TCE alternatives are unknown, the WCPP costs are used as a lower bound estimate.
3TCE use is prohibited after 8.5 years. It is unknown what the cost implications of a 8.5 year phase out would be, so the costs
reflect 9 years of WCPP costs under both options.
Executive Summary
ES-11
4Since
the regulatory costs of prohibition under this use are unknown, the analysis uses the WCPP costs as a proxy for the
prohibition costs to calculate total costs. Thus, the total costs are estimated as the 20-year annualized costs of WCPP compliance.
Interim WCPP requirements apply for 2 years under both options for these use categories.
5There is longer term compliance timeframe applicable to five Open-Top Vapor Degreasers using TCE for narrow tubes and
medical device (7 years), one Open-Top Vapor Degreaser using TCE in naval combat systems, radars, sensors, equipment, and
fabrication and prototyping processes (10 years), one enclosed vapor degreasing application using TCE to scour rayon fabric for
use in rocket booster engine nozzles (10 years). WCPP compliance is required for 7 years, followed by prohibition for industrial
and commercial use of TCE in closed loop vapor degreasing necessary for human-rated rocket engine cleaning by Federal
agencies and their contractors. The analysis accounts for one enclosed vapor degreaser and one Open-Top Vapor Degreaser with 9
years of WCPP costs and prohibition costs in years 10-20, One enclosed vapor degreaser and five Open-Top Vapor Degreaser
with 6 years of WCPP costs and prohibition costs in years 7-20. Other vapor degreasers have prohibition costs starting at “time
zero”.
6Since the regulatory costs of prohibition under this use are unknown, the analysis uses the WCPP costs as a proxy for the
prohibition costs to calculate total costs. Thus, the total costs are estimated as the 20-year annualized costs of WCPP compliance.
7The costs for the Import/Repackage and Incorporation into Formulation, Mixture, or Reaction Product use categories are
accounted under the respective end-use categories for their products.
Executive Summary
ES-12
Table ES-6: Total 7% 20-Year Annualized Costs Under the Regulatory Options by Use Category
(2022$)
Use Category
Laboratory Use
Manufacturing
Battery and Synthetic Paper
Processing Aid
HFC Manufacturing
Intermediate in HCl Production
Fluoroelastomer Manufacture
Open-Top Vapor Degreasing
Enclosed Vapor Degreasing
Conveyorized Vapor Degreasing
Web Vapor Degreasing
Batch Cold Cleaning
Disposal to Wastewater
Energized Electrical Cleaners7
Mold Release7
Liquid Cleaners and Degreasers7
Aerosol Spray
Cleaning/Degreasing (except
EEC) 7
Lubricants and
Greases7
Option 1 (ECEL 0.20 ppm)
Total
Annualized
Notes
Cost
$1,015,018
20-Years of WCPP Costs
$254,189
$267,524
20-Years of WCPP Costs1
9-Years of WCPP Costs3
Not subject to rule under
Option 1
$178,349 20-Years of WCPP Costs4
$77,266,553
Alternatives cost from Table
$1,409,320 7-41 with WCPP costs
incurred during transition to
prohibition under exemptions5
$44,392
$1,774,397
$221,800
$11,533,580
$7,072,738
$820,958
Alternatives cost from Table
7-41
20-Years of WCPP Costs6
1 year of Prescriptive
Control costs followed by
prohibition
Option 2 (ECEL 0.0011 ppm)
Total
Annualized
Notes
Cost
$1,015,018
20-Years of WCPP Costs
$492,243
$321,094
20-Years of WCPP Costs2
$86,691
9-Years of WCPP Costs3
$1,900,018
20-Years of WCPP Costs4
$214,063 20-Years of WCPP Costs4
$77,335,094 Alternatives cost from Table
7-41 with WCPP costs
incurred during transition to
$1,415,334 prohibition under
exemptions5
$1,774,397
Alternatives cost from
$221,800
Table 7-41
$11,533,580
$18,504,991
$820,958
$78,680
$78,680
$113,376
$113,376
$148,340
$148,340
$42,090
Costs of rule familiarization
and reformulation.
$42,090
Adhesives, Sealants, Paints and
Coatings7
$90,292
$90,292
Spot Removers7
$57,941
$57,941
Pepper
Spray7
Total
$5,618
$102,395,154
20-Years of WCPP Costs6
Estimated as Option 1
Costs
Costs of rule
familiarization and
reformulation.
$5,618
-
$116,171,618
-
1TCE
use is prohibited after 15 years, but since the costs of TCE alternatives are unknown, the WCPP costs are used as a lower
bound estimate.
2TCE use is prohibited after 10 years for battery separator manufacture and in six months for synthetic paper, but since the costs of
TCE alternatives are unknown, the WCPP costs are used as a lower bound estimate.
3TCE use is prohibited after 8.5 years. It is unknown what the cost implications of a 8.5 year phase out would be, so the costs
reflect 9 years of WCPP costs under both options.
4Since the regulatory costs of prohibition under this use are unknown, the analysis uses the WCPP costs as a proxy for the
prohibition costs to calculate total costs. Thus, the total costs are estimated as the 20-year annualized costs of WCPP compliance.
Interim WCPP requirements apply for 2 years under both options for these use categories.
5There is longer term compliance timeframe applicable to five Open-Top Vapor Degreasers using TCE for narrow tubes and
medical device (7 years), one Open-Top Vapor Degreaser using TCE in naval combat systems, radars, sensors, equipment, and
fabrication and prototyping processes (10 years), one enclosed vapor degreasing application using TCE to scour rayon fabric for
use in rocket booster engine nozzles (10 years). WCPP compliance is required for 7 years, followed by prohibition for industrial
and commercial use of TCE in closed loop vapor degreasing necessary for human-rated rocket engine cleaning by Federal
agencies and their contractors. The analysis accounts for one enclosed vapor degreaser and one Open-Top Vapor Degreaser with 9
years of WCPP costs and prohibition costs in years 10-20, One enclosed vapor degreaser and five Open-Top Vapor Degreaser
Executive Summary
ES-13
with 6 years of WCPP costs and prohibition costs in years 7-20. Other vapor degreasers have prohibition costs starting at “time
zero”.
6Since the regulatory costs of prohibition under this use are unknown, the analysis uses the WCPP costs as a proxy for the
prohibition costs to calculate total costs. Thus, the total costs are estimated as the 20-year annualized costs of WCPP compliance.
7The costs for the Import/Repackage and Incorporation into Formulation, Mixture, or Reaction Product use categories are
accounted under the respective end-use categories for their products.
Unquantified Costs
This economic analysis does not include quantified cost estimates for all costs under the regulatory
options. Although certain costs cannot be quantified, this does not mean that they are less important than
the quantified costs. Additional unquantified costs are discussed in more detail in section 7.11, but the
unquantified costs include the following:
•
Applications where TCE is more effective, reducing labor time and wait time that this analysis was
unable to quantify.
•
Potential facility closures resulting from challenges to switching to TCE alternatives
•
Costs associated with developing and testing alternatives to TCE for rocket booster nozzles
•
Under the Option 1, the disposal of TCE to industrial pre-treatment, industrial treatment, or publicly
owned treatment work is prohibited after the 6(g) exemption ends, 50 years after the rule is finalized.
Cleanup sites would need to identify and implement alternative disposal or treatment methods. The
information to estimate how often these costs might be incurred or what the specific costs would be
per site when they are incurred is not available.
•
Unquantified costs associated with implementing a respirator program, since respirators have been
found to interfere with many physiological and psychological aspects of task performance (Johnson
2016).
•
The costs of switching to alternatives to TCE are unknown for battery separator manufacture,
synthetic paper manufacture, HFC manufacturing, use as an intermediate in HCl production (affected
under Option 2), and fluoroelastomer manufacture (see section 7.12.7).
Estimated Incremental Benefits
The health benefits monetized in this analysis include the cancer endpoints considered in EPA’s (EPA
2020e) risk evaluation: (1) liver cancer, (2) kidney cancer, and (3) non-Hodgkin’s lymphoma (NHL). The
benefits for reducing other health risks associated with TCE exposure were not estimated. The risk
evaluation identified other potential health effects of TCE exposure, including effects on the central
nervous system (CNS), liver, and immune system.
Table ES-7, Table ES-8, and Table ES-9 present the low and high estimates for the total monetized cancer
benefits by regulatory option and use category, using 2, 3 and 7 percent discount rates respectively.
Benefits are presented in 2022 dollars.
Executive Summary
ES-14
Table ES-7: Total 20-Year Annualized Benefits by Use Category and Regulatory Option (2 Percent Discount Rate)
Low Estimate
High Estimate
Notes1
Use Category
Option 1
Option 2
Option 1
Option 2
Option 1
Option 2
Manufacturing
$9,955
$11,144
$10,091
$11,296
WCPP
WCPP
$1,329
$1,329
$1,347
$1,347
Prohibit
Prohibit
Import/Repackage
Battery and Synthetic Paper Processing Aid
$55,169
$56,344
$55,921
$57,112
WCPP/Prohibit2
WCPP/Prohibit2
3
$1,349
$1,510
$1,367
$1,531
WCPP
WCPP3
HFC Manufacturing
$42,384
$42,962
WCPP/Prohibit 4
Intermediate in HCL Production
4
$37,513
$37,564
$38,024
$38,076
WCPP/Prohibit
WCPP/Prohibit 4
Fluoroelastomer Manufacture
5
Open-Top Vapor Degreasing
$6,580,750
$6,594,356
$6,670,446
$6,684,237
WCPP/Prohibit
WCPP/Prohibit 5
6
$2,875
$3,012
$2,914
$3,053
WCPP/Prohibit
WCPP/Prohibit 6
Enclosed Vapor Degreasing
$195,973
$195,973
$198,644
$198,644
Prohibit
Prohibit
Conveyorized Vapor Degreasing
$6,236
$6,236
$6,321
$6,321
Prohibit
Prohibit
Web Vapor Degreasing
Batch Cold Cleaning
$610,659
$610,659
$618,982
$618,982
Prohibit
Prohibit
Disposal to Wastewater
$860,405
$859,919
$872,142
$871,650
WCPP
WCPP
Energized Electrical Cleaners
$77,160
$77,351
$78,232
$78,426
APF50/Prohibit 7
Prohibit
Incorporation Into Formulation, Mixture, or
$33,066
$33,075
$33,517
$33,526
Prohibit
Prohibit
Reaction Product
Mold Release
$389,330
$389,330
$394,637
$394,637
Prohibit
Prohibit
Liquid Cleaners and Degreasers
$2,225,301
$2,225,301
$2,255,632
$2,255,632
Prohibit
Prohibit
Aerosol Spray Cleaning/Degreasing (except
$6,239,196
$6,239,196
$6,325,863
$6,325,863
Prohibit
Prohibit
EEC)
$1,833,653
$1,833,653
$1,858,645
$1,858,645
Prohibit
Prohibit
Lubricants and Greases
Adhesives, Sealants, Paints and Coatings
$849,532
$849,532
$861,111
$861,111
Prohibit
Prohibit
Dry Cleaning and Spot Removers
$2,846,209
$2,846,209
$2,885,745
$2,885,745
Prohibit
Prohibit
Total
$22,855,659
$22,914,077
$23,169,579
$23,228,794
Prohibit
Prohibit
1Notes indicate how benefits were estimated and do not necessarily directly correspond to the option requirements. See Table 7-2 for more detail about differences between
requirements under the options and the analysis assumptions.
2WCPP for 16 years and then prohibition for 4.
3WCPP for 9 years and then no benefits (elimination in the baseline is assumed starting in year 10).
4WCPP for 1 year and then prohibition for 19.
5Five OTVDs are assumed to have 6 years of WCPP and 14 years of prohibition. One OTVD is assumed to have 9 years of WCPP and 11 years of prohibition. Other OTVDs
are assumed to have 20 years of prohibition.
6One enclosed vapor degreaser is assumed to have 6 years of WCPP and 14 years of prohibition and one enclosed vapor degreaser is assumed to have 9 years of WCPP and 11
years of prohibition. Other vapor degreasers are assumed to have 20 years of prohibition.
7The benefits are split into Energized Electrical Cleaner (EEC) users and other aerosol degreaser users. EEC users are estimated to be 20.53% of all aerosol degreaser users
(see Table 6-20). Using the estimates presented in Table 8-5, the benefits from using APF50 respirators for 2 years are estimated as 97.92% of the benefits of eliminating all
Executive Summary
ES-15
exposure (97.92% = 1-(95%/50+3%/50+0%/50+1%/50+1%/1000+0%/10000)/(95%/1+3%/10+0%/25+1%/50+1%/1000+0%/10000)). In addition, EEC users are assumed to
be exposed once monthly instead of 250 days per year; thus, the aerosol user benefits are adjusted by 4.8% (4.8%=12/250).
Executive Summary
ES-16
Table ES-8: Total 20-Year Annualized Benefits by Use Category and Regulatory Option (3 Percent Discount Rate)
Low Estimate
High Estimate
Notes1
Use Category
Option 1
Option 2
Option 1
Option 2
Option 1
Option 2
Manufacturing
$7,952
$8,902
$8,065
$9,029
WCPP
WCPP
$1,061
$1,061
$1,077
$1,077
Prohibit
Prohibit
Import/Repackage
Battery and Synthetic Paper Processing Aid
$47,589
$45,005
$48,270
$45,649
WCPP/Prohibit2
WCPP/Prohibit2
3
$1,130
$1,264
$1,146
$1,283
WCPP
WCPP3
HFC Manufacturing
$33,854
$34,339
Prohibit/ WCPP 4
Intermediate in HCL Production
4
$29,960
$30,005
$30,389
$30,434
WCPP/Prohibit
Prohibit/WCPP4
Fluoroelastomer Manufacture
5
Open-Top Vapor Degreasing
$5,255,545
$5,267,311
$5,330,782
$5,342,718
WCPP/Prohibit
WCPP/Prohibit 5
6
$2,288
$2,406
$2,321
$2,440
WCPP/Prohibit
WCPP/Prohibit 6
Enclosed Vapor Degreasing
$156,535
$156,535
$158,776
$158,776
Prohibit
Prohibit
Conveyorized Vapor Degreasing
$4,981
$4,981
$5,053
$5,053
Prohibit
Prohibit
Web Vapor Degreasing
Batch Cold Cleaning
$487,770
$487,770
$494,753
$494,753
Prohibit
Prohibit
Disposal to Wastewater
$687,113
$686,726
$696,596
$696,203
WCPP
WCPP
Energized Electrical Cleaners
$61,398
$61,563
$62,264
$62,431
APF50/Prohibit7
Prohibit
Incorporation Into Formulation, Mixture, or
$26,411
$26,419
$26,789
$26,797
Prohibit
Prohibit
Reaction Product
Mold Release
$310,982
$310,982
$315,434
$315,434
Prohibit
Prohibit
Liquid Cleaners and Degreasers
$1,777,483
$1,777,483
$1,802,929
$1,802,929
Prohibit
Prohibit
Aerosol Spray Cleaning/Degreasing (except
$4,965,691
$4,965,691
$5,035,708
$5,035,708
Prohibit
Prohibit
EEC)
$1,464,649
$1,464,649
$1,485,617
$1,485,617
Prohibit
Prohibit
Lubricants and Greases
Adhesives, Sealants, Paints and Coatings
$678,573
$678,573
$688,287
$688,287
Prohibit
Prohibit
Dry Cleaning and Spot Removers
$2,265,259
$2,265,259
$2,297,199
$2,297,199
Prohibit
Prohibit
Total
$18,232,371
$18,276,440
$18,491,456
$18,536,156
Prohibit
Prohibit
1Notes indicate how benefits were estimated and do not necessarily directly correspond to the option requirements. See Table 7-2 for more detail about differences between
requirements under the options and the analysis assumptions.
2WCPP for 16 years and then prohibition for 4.
3WCPP for 9 years and then no benefits (elimination in the baseline is assumed starting in year 10).
4WCPP for 1 year and then prohibition for 19.
5Five OTVDs are assumed to have 6 years of WCPP and 14 years of prohibition. One OTVD is assumed to have 9 years of WCPP and 11 years of prohibition. Other OTVDs
are assumed to have 20 years of prohibition.
6One enclosed vapor degreaser is assumed to have 6 years of WCPP and 14 years of prohibition and one enclosed vapor degreaser is assumed to have 9 years of WCPP and 11
years of prohibition. Other vapor degreasers are assumed to have 20 years of prohibition.
7The benefits are split into Energized Electrical Cleaner (EEC) users and other aerosol degreaser users. EEC users are estimated to be 20.53% of all aerosol degreaser users
(see Table 6-20). Using the estimates presented in Table 8-5, the benefits from using APF50 respirators for 2 years are estimated as 97.92% of the benefits of eliminating all
Executive Summary
ES-17
exposure (97.92% = 1-(95%/50+3%/50+0%/50+1%/50+1%/1000+0%/10000)/(95%/1+3%/10+0%/25+1%/50+1%/1000+0%/10000)). In addition, EEC users are assumed to
be exposed once monthly instead of 250 days per year; thus, the aerosol user benefits are adjusted by 4.8% (4.8%=12/250).
Executive Summary
ES-18
Table ES-9: Total 20-Year Annualized Benefits by Use Category and Regulatory Option (7 Percent Discount Rate)
Low Estimate
High Estimate
Notes1
Use Category
Option 1
Option 2
Option 1
Option 2
Option 1
Option 2
Manufacturing
$3,805
$4,260
$3,867
$4,329
WCPP
WCPP
$508
$508
$516
$516
Prohibit
Prohibit
Import/Repackage
Battery and Synthetic Paper Processing Aid
$22,296
$21,535
$22,658
$21,884
WCPP/Prohibit2
WCPP/Prohibit2
3
$635
$711
$645
$723
WCPP
WCPP3
HFC Manufacturing
$16,199
$16,462
WCPP/Prohibit4
Intermediate in HCL Production
4
$14,329
$14,357
$14,561
$14,590
WCPP/Prohibit
WCPP/Prohibit4
Fluoroelastomer Manufacture
5
Open-Top Vapor Degreasing
$2,512,991
$2,520,450
$2,553,722
$2,561,302
WCPP/Prohibit
WCPP/Prohibit 5
6
$1,079
$1,151
$1,096
$1,170
WCPP/Prohibit
WCPP/Prohibit6
Enclosed Vapor Degreasing
$74,903
$74,903
$76,117
$76,117
Prohibit
Prohibit
Conveyorized Vapor Degreasing
$2,384
$2,384
$2,422
$2,422
Prohibit
Prohibit
Web Vapor Degreasing
Batch Cold Cleaning
$233,402
$233,402
$237,185
$237,185
Prohibit
Prohibit
Disposal to Wastewater
$329,139
$328,953
$334,474
$334,285
WCPP
WCPP
Energized Electrical Cleaners
$29,406
$29,511
$29,860
$29,967
APF50/Prohibit7
Prohibit
Incorporation Into Formulation, Mixture, or
$12,637
$12,642
$12,842
$12,847
Prohibit
Prohibit
Reaction Product
Mold Release
$148,807
$148,807
$151,219
$151,219
Prohibit
Prohibit
Liquid Cleaners and Degreasers
$850,540
$850,540
$864,325
$864,325
Prohibit
Prohibit
Aerosol Spray Cleaning/Degreasing (except
$2,380,373
$2,380,373
$2,417,138
$2,417,138
Prohibit
Prohibit
EEC)
$700,847
$700,847
$712,206
$712,206
Prohibit
Prohibit
Lubricants and Greases
Adhesives, Sealants, Paints and Coatings
$324,703
$324,703
$329,965
$329,965
Prohibit
Prohibit
Dry Cleaning and Spot Removers
$1,085,883
$1,085,883
$1,102,655
$1,102,655
Prohibit
Prohibit
Total
$8,728,666
$8,752,119
$8,867,475
$8,891,308
Prohibit
Prohibit
1Notes indicate how benefits were estimated and do not necessarily directly correspond to the option requirements. See Table 7-2 for more detail about differences between
requirements under the options and the analysis assumptions.
2WCPP for 16 years and then prohibition for 4.
3WCPP for 9 years and then no benefits (elimination in the baseline is assumed starting in year 10).
4WCPP for 1 year and then prohibition for 19.
5Five OTVDs are assumed to have 6 years of WCPP and 14 years of prohibition. One OTVD is assumed to have 9 years of WCPP and 11 years of prohibition. Other OTVDs
are assumed to have 20 years of prohibition.
6One enclosed vapor degreaser is assumed to have 6 years of WCPP and 14 years of prohibition and one enclosed vapor degreaser is assumed to have 9 years of WCPP and 11
years of prohibition. Other vapor degreasers are assumed to have 20 years of prohibition.
7The benefits are split into Energized Electrical Cleaner (EEC) users and other aerosol degreaser users. EEC users are estimated to be 20.53% of all aerosol degreaser users
(see Table 6-20). Using the estimates presented in Table 8-5, the benefits from using APF50 respirators for 2 years are estimated as 97.92% of the benefits of eliminating all
Executive Summary
ES-19
exposure (97.92% = 1-(95%/50+3%/50+0%/50+1%/50+1%/1000+0%/10000)/(95%/1+3%/10+0%/25+1%/50+1%/1000+0%/10000)). In addition, EEC users are assumed to
be exposed once monthly instead of 250 days per year; thus, the aerosol user benefits are adjusted by 4.8% (4.8%=12/250).
Executive Summary
ES-20
Unquantified Benefits
Both animal and human studies demonstrate that TCE exposure can result in either autoimmune/immune
enhancement responses or immunosuppression. There is also evidence of both systemic and localized
hypersensitivity resulting in skin sensitization and autoimmune hepatitis. Overall, immunotoxicity in the
form of both autoimmunity and immune suppression following TCE exposure are supported by the
weight of evidence (EPA 2020e).
As discussed in EPA’s risk evaluation (EPA 2020e), there is positive overall evidence that TCE may
produce congenital heart defects (CHDs) in humans (based on positive evidence from epidemiology
studies, ambiguous evidence from animal toxicity studies, and stronger positive evidence from
mechanistic studies). This analysis is unable to quantify the magnitude of avoided risk of
autoimmune/immune enhancement responses or immunosuppression or CHDs due to reductions in TCE
exposure under the rule, and thus is unable to develop monetized estimates of the benefits of non-cancer
risk reductions. However, section 8.9 presents a qualitative discussion of non-cancer endpoints, potential
social costs, and the potential number of pregnant individuals exposed to TCE.
Estimated Incremental Net Benefits
Quantified net benefits are estimated by subtracting the total annualized quantified cost of the regulatory
options (see Chapter 7) from the total annualized quantified benefits (see Chapter 8). Total quantified
costs reflect costs of compliance with the regulatory options, including requirements for prohibition and
WCPP requirements, for those uses where costs could be estimated. Total quantified benefits reflect the
benefits of reduced risk for kidney, liver and NHL cancer. Costs, benefits, and net benefits are presented
in 2022 dollars in this document unless otherwise noted.
Table ES-10 and Table ES-11 present the net benefits by use category estimated using a 2 percent
discount rate using the low and high benefits estimates, respectively. Table ES-12 and Table ES-13
present the net benefits by use category estimated using a 3 percent discount rate using the low and high
benefits estimates, respectively. Table ES-14 and Table ES-15 present the net benefits by use category
estimated using a 7 percent discount rate using the low and high benefits estimates, respectively Table
ES-16 summarizes the four net benefits estimates that were estimated.
Note that as discussed in Chapter 7, section 7.11, there are additional unquantified costs that affect all
options. Similarly, Chapter 8 notes that there are also unquantified benefits. Therefore, it is not clear
whether the monetized net benefits presented in the tables below under- or over-estimate the true social
net benefits of the regulatory options.
Executive Summary
ES-21
Table ES-10: Total 20-Year Annualized Net Benefits by Use Category and Regulatory Option (Low Benefits Estimate, 2 Percent Discount
Rate)
Costs
Benefits
Net Benefits
Use Category
Laboratory Use
Manufacturing
Battery and Synthetic Paper Processing Aid
HFC Manufacturing
Intermediate in HCl Production
Fluoroelastomer Manufacture
Open-Top Vapor Degreasing
Enclosed Vapor Degreasing
Conveyorized Vapor Degreasing
Web Vapor Degreasing
Batch Cold Cleaning
Disposal to Wastewater
Energized Electrical Cleaners (EEC)
Mold Release1
Liquid Cleaners and Degreasers1
Aerosol Spray Cleaning/Degreasing1
Lubricants and Greases1
Adhesives, Sealants, Paints and Coatings1
Spot Removers1
Pepper Spray1
Total
Option 1 (Final
Rule)
$1,020,962
$257,925
$271,592
$36,605
$181,062
$45,445,026
$917,124
$1,037,791
$129,724
$6,745,641
$7,077,581
$575,451
$52,573
$75,756
$99,119
$28,124
$60,332
$38,715
$3,754
$64,054,859
Option 2
$1,020,962
$496,593
$311,972
$71,153
$1,916,912
$207,982
$45,493,389
$921,179
$1,037,791
$129,724
$6,745,641
$18,630,260
$575,451
$52,573
$75,756
$99,119
$28,124
$60,332
$38,715
$3,754
$77,917,383
Option 1 (Final
Rule)
$9,955
$55,169
$1,349
$37,513
$6,580,750
$2,875
$195,973
$6,236
$610,659
$860,405
$79,514
$392,326
$2,227,169
$6,249,562
$1,839,215
$857,989
$2,848,077
$924
$22,855,659
Option 2
$11,144
$56,344
$1,510
$42,384
$37,564
$6,594,356
$3,012
$195,973
$6,236
$610,659
$859,919
$79,714
$396,232
$2,226,780
$6,249,548
$1,837,103
$857,419
$2,847,688
$493
$22,914,077
Option 1 (Final
Rule)
($1,020,962)
($247,970)
($216,423)
($35,256)
($143,549)
($38,864,276)
($914,249)
($841,818)
($123,488)
($6,134,983)
($6,217,177)
($495,937)
$339,753
$2,151,412
$6,150,443
$1,811,092
$797,657
$2,809,362
($2,830)
($41,199,199)
Option 2
($1,020,962)
($485,449)
($255,629)
($69,644)
($1,874,528)
($170,418)
($38,899,033)
($918,167)
($841,818)
($123,488)
($6,134,983)
($17,770,341)
($495,737)
$343,659
$2,151,023
$6,150,429
$1,808,979
$797,087
$2,808,972
($3,261)
($55,003,306)
1Note
that costs and benefits for import/repackage and incorporation into formulation, mixture, or reaction product are accounted for under the use categories for the formulated
products. These costs and benefits are aggregated under the use categories for the formulated products here so that benefits and costs are comparable. This is why the costs and
benefits presented in this table are larger for the use categories for the formulated products compared to values in the cost and benefits summary tables.
Table ES-11: Total 20-Year Annualized Net Benefits by Use Category and Regulatory Option (High Benefits Estimate, 2 Percent
Discount Rate)
Costs
Benefits
Net Benefits
Use Category
Executive Summary
Option 1 (Final
Rule)
Option 2
Option 1 (Final
Rule)
Option 2
Option 1 (Final
Rule)
Option 2
ES-22
Table ES-11: Total 20-Year Annualized Net Benefits by Use Category and Regulatory Option (High Benefits Estimate, 2 Percent
Discount Rate)
Costs
Benefits
Net Benefits
Use Category
Laboratory Use
Manufacturing
Battery and Synthetic Paper Processing Aid
HFC Manufacturing
Intermediate in HCl Production
Fluoroelastomer Manufacture
Open-Top Vapor Degreasing
Enclosed Vapor Degreasing
Conveyorized Vapor Degreasing
Web Vapor Degreasing
Batch Cold Cleaning
Disposal to Wastewater
Energized Electrical Cleaners (EEC)
Mold Release1
Liquid Cleaners and Degreasers1
Aerosol Spray Cleaning/Degreasing1
Lubricants and Greases1
Adhesives, Sealants, Paints and Coatings1
Spot Removers1
Pepper Spray1
Total
Option 1 (Final
Rule)
$1,020,962
$257,925
$271,592
$36,605
$181,062
$45,445,026
$917,124
$1,037,791
$129,724
$6,745,641
$7,077,581
$575,451
$52,573
$75,756
$99,119
$28,124
$60,332
$38,715
$3,754
$64,054,859
Option 2
$1,020,962
$496,593
$311,972
$71,153
$1,916,912
$207,982
$45,493,389
$921,179
$1,037,791
$129,724
$6,745,641
$18,630,260
$575,451
$52,573
$75,756
$99,119
$28,124
$60,332
$38,715
$3,754
$77,917,383
Option 1 (Final
Rule)
$10,091
$55,921
$1,367
$38,024
$6,670,446
$2,914
$198,644
$6,321
$618,982
$872,142
$80,618
$397,674
$2,257,525
$6,336,370
$1,864,284
$869,683
$2,887,638
$936
$23,169,579
Option 2
$11,296
$57,112
$1,531
$42,962
$38,076
$6,684,237
$3,053
$198,644
$6,321
$618,982
$871,650
$80,820
$401,632
$2,257,131
$6,336,356
$1,862,143
$869,106
$2,887,244
$500
$23,228,794
Option 1 (Final
Rule)
($1,020,962)
($247,835)
($215,671)
($35,238)
($143,038)
($38,774,581)
($914,210)
($839,147)
($123,403)
($6,126,659)
($6,205,439)
($494,833)
$345,101
$2,181,769
$6,237,251
$1,836,160
$809,351
$2,848,923
($2,818)
($40,885,279)
Option 2
($1,020,962)
($485,297)
($254,861)
($69,623)
($1,873,950)
($169,906)
($38,809,152)
($918,126)
($839,147)
($123,403)
($6,126,659)
($17,758,610)
($494,630)
$349,059
$2,181,374
$6,237,237
$1,834,019
$808,773
$2,848,528
($3,254)
($54,688,590)
1Note
that costs and benefits for import/repackage and incorporation into formulation, mixture, or reaction product are accounted for under the use categories for the formulated
products. These costs and benefits are aggregated under the use categories for the formulated products here so that benefits and costs are comparable. This is why the costs and
benefits presented in this table are larger for the use categories for the formulated products compared to values in the cost and benefits summary tables.
Table ES-12: Total 20-Year Annualized Net Benefits by Use Category and Regulatory Option (Low Benefits Estimate, 3 Percent Discount
Rate)
Costs
Benefits
Net Benefits
Use Category
Executive Summary
Option 1 (Final
Rule)
Option 2
Option 1 (Final
Rule)
Option 2
Option 1 (Final
Rule)
Option 2
ES-23
Table ES-12: Total 20-Year Annualized Net Benefits by Use Category and Regulatory Option (Low Benefits Estimate, 3 Percent Discount
Rate)
Costs
Benefits
Net Benefits
Use Category
Laboratory Use
Manufacturing
Battery and Synthetic Paper Processing Aid
HFC Manufacturing
Intermediate in HCl Production
Fluoroelastomer Manufacture
Open-Top Vapor Degreasing
Enclosed Vapor Degreasing
Conveyorized Vapor Degreasing
Web Vapor Degreasing
Batch Cold Cleaning
Disposal to Wastewater
Energized Electrical Cleaners (EEC)
Mold Release1
Liquid Cleaners and Degreasers1
Aerosol Spray Cleaning/Degreasing1
Lubricants and Greases1
Adhesives, Sealants, Paints and Coatings1
Spot Removers1
Pepper Spray1
Total
Option 1 (Final
Rule)
$1,019,851
$257,227
$270,832
$38,271
$180,554
$51,402,026
$1,011,662
$1,175,495
$146,937
$7,640,714
$7,076,676
$622,687
$57,453
$82,789
$108,321
$30,735
$65,933
$42,309
$4,103
$71,234,573
Option 2
$1,019,851
$495,780
$313,678
$74,458
$1,913,754
$209,118
$51,454,277
$1,016,091
$1,175,495
$146,937
$7,640,714
$18,606,842
$622,687
$57,453
$82,789
$108,321
$30,735
$65,933
$42,309
$4,103
$85,081,323
Option 1 (Final
Rule)
$7,952
$47,589
$1,130
$29,960
$5,255,545
$2,288
$156,535
$4,981
$487,770
$687,113
$63,278
$313,375
$1,778,975
$4,973,971
$1,469,093
$685,328
$2,266,751
$738
$18,232,371
Option 2
$8,902
$45,005
$1,264
$33,854
$30,005
$5,267,311
$2,406
$156,535
$4,981
$487,770
$686,726
$63,450
$316,494
$1,778,664
$4,973,960
$1,467,406
$684,873
$2,266,440
$394
$18,276,440
Option 1 (Final
Rule)
($1,019,851)
($249,275)
($223,243)
($37,141)
($150,594)
($46,146,482)
($1,009,374)
($1,018,959)
($141,955)
($7,152,944)
($6,389,562)
($559,409)
$255,921
$1,696,185
$4,865,650
$1,438,358
$619,395
$2,224,442
($3,365)
($53,002,202)
Option 2
($1,019,851)
($486,878)
($268,673)
($73,193)
($1,879,899)
($179,114)
($46,186,966)
($1,013,685)
($1,018,959)
($141,955)
($7,152,944)
($17,920,116)
($559,237)
$259,041
$1,695,875
$4,865,639
$1,436,671
$618,940
$2,224,131
($3,709)
($66,804,883)
1Note
that costs and benefits for import/repackage and incorporation into formulation, mixture, or reaction product are accounted for under the use categories for the formulated
products. These costs and benefits are aggregated under the use categories for the formulated products here so that benefits and costs are comparable. This is why the costs and
benefits presented in this table are larger for the use categories for the formulated products compared to values in the benefits summary tables.
Table ES-13: Total 20-Year Annualized Net Benefits by Use Category and Regulatory Option (High Benefits Estimate, 3 Percent
Discount Rate)
Costs
Benefits
Net Benefits
Use Category
Executive Summary
Option 1 (Final
Rule)
Option 2
Option 1 (Final
Rule)
Option 2
Option 1 (Final
Rule)
Option 2
ES-24
Table ES-13: Total 20-Year Annualized Net Benefits by Use Category and Regulatory Option (High Benefits Estimate, 3 Percent
Discount Rate)
Costs
Benefits
Net Benefits
Use Category
Laboratory Use
Manufacturing
Battery and Synthetic Paper Processing Aid
HFC Manufacturing
Intermediate in HCl Production
Fluoroelastomer Manufacture
Open-Top Vapor Degreasing
Enclosed Vapor Degreasing
Conveyorized Vapor Degreasing
Web Vapor Degreasing
Batch Cold Cleaning
Disposal to Wastewater
Energized Electrical Cleaners (EEC)
Mold Release1
Liquid Cleaners and Degreasers1
Aerosol Spray Cleaning/Degreasing1
Lubricants and Greases1
Adhesives, Sealants, Paints and Coatings1
Spot Removers1
Pepper Spray1
Total
Option 1 (Final
Rule)
$1,019,851
$257,227
$270,832
$38,271
$180,554
$51,402,026
$1,011,662
$1,175,495
$146,937
$7,640,714
$7,076,676
$622,687
$57,453
$82,789
$108,321
$30,735
$65,933
$42,309
$4,103
$71,234,573
Option 2
$1,019,851
$495,780
$313,678
$74,458
$1,913,754
$209,118
$51,454,277
$1,016,091
$1,175,495
$146,937
$7,640,714
$18,606,842
$622,687
$57,453
$82,789
$108,321
$30,735
$65,933
$42,309
$4,103
$85,081,323
Option 1 (Final
Rule)
$8,065
$48,270
$1,146
$30,389
$5,330,782
$2,321
$158,776
$5,053
$494,753
$696,596
$64,170
$317,861
$1,804,442
$5,044,106
$1,490,124
$695,139
$2,298,713
$748
$18,491,456
Option 2
$9,029
$45,649
$1,283
$34,339
$30,434
$5,342,718
$2,440
$158,776
$5,053
$494,753
$696,203
$64,345
$321,025
$1,804,127
$5,044,095
$1,488,413
$694,677
$2,298,397
$399
$18,536,156
Option 1 (Final
Rule)
($1,019,851)
($249,161)
($222,561)
($37,125)
($150,166)
($46,071,244)
($1,009,341)
($1,016,718)
($141,884)
($7,145,961)
($6,380,080)
($558,516)
$260,408
$1,721,653
$4,935,786
$1,459,390
$629,206
$2,256,403
($3,354)
($52,743,118)
Option 2
($1,019,851)
($486,751)
($268,028)
($73,175)
($1,879,415)
($178,684)
($46,111,560)
($1,013,650)
($1,016,718)
($141,884)
($7,145,961)
($17,910,639)
($558,342)
$263,572
$1,721,338
$4,935,774
$1,457,678
$628,744
$2,256,088
($3,703)
($66,545,167)
1Note
that costs and benefits for import/repackage and incorporation into formulation, mixture, or reaction product are accounted for under the use categories for the formulated
products. These costs and benefits are aggregated under the use categories for the formulated products here so that benefits and costs are comparable. This is why the costs and
benefits presented in this table are larger for the use categories for the formulated products compared to values in the cost and benefits summary tables.
Table ES-14: Total 20-Year Annualized Net Benefits by Use Category and Regulatory Option (Low Benefits Estimate, 7 Percent Discount
Rate)
Costs
Benefits
Net Benefits
Use Category
Executive Summary
Option 1 (Final
Rule)
Option 2
Option 1 (Final
Rule)
Option 2
Option 1 (Final
Rule)
Option 2
ES-25
Table ES-14: Total 20-Year Annualized Net Benefits by Use Category and Regulatory Option (Low Benefits Estimate, 7 Percent Discount
Rate)
Costs
Benefits
Net Benefits
Use Category
Laboratory Use
Manufacturing
Battery and Synthetic Paper Processing Aid
HFC Manufacturing
Intermediate in HCl Production
Fluoroelastomer Manufacture
Open-Top Vapor Degreasing
Enclosed Vapor Degreasing
Conveyorized Vapor Degreasing
Web Vapor Degreasing
Batch Cold Cleaning
Disposal to Wastewater
Energized Electrical Cleaners (EEC)
Mold Release1
Liquid Cleaners and Degreasers1
Aerosol Spray Cleaning/Degreasing1
Lubricants and Greases1
Adhesives, Sealants, Paints and Coatings1
Spot Removers1
Pepper Spray1
Total
Option 1 (Final
Rule)
$1,015,018
$254,189
$267,524
$44,392
$178,349
$77,266,553
$1,409,320
$1,774,397
$221,800
$11,533,580
$7,072,738
$820,958
$78,680
$113,376
$148,340
$42,090
$90,292
$57,941
$5,618
$102,395,154
Option 2
$1,015,018
$492,243
$321,094
$86,691
$1,900,018
$214,063
$77,335,094
$1,415,334
$1,774,397
$221,800
$11,533,580
$18,504,991
$820,958
$78,680
$113,376
$148,340
$42,090
$90,292
$57,941
$5,618
$116,171,618
Option 1 (Final
Rule)
$3,805
$22,296
$635
$14,329
$2,512,991
$1,079
$74,903
$2,384
$233,402
$329,139
$30,304
$149,952
$851,254
$2,384,335
$702,973
$327,935
$1,086,597
$353
$8,728,666
Option 2
$4,260
$21,535
$711
$16,199
$14,357
$2,520,450
$1,151
$74,903
$2,384
$233,402
$328,953
$30,414
$151,445
$851,105
$2,384,330
$702,165
$327,717
$1,086,449
$188
$8,752,119
Option 1 (Final
Rule)
($1,015,018)
($250,384)
($245,227)
($43,757)
($164,021)
($74,753,562)
($1,408,241)
($1,699,494)
($219,416)
($11,300,178)
($6,743,599)
($790,654)
$71,272
$737,878
$2,235,995
$660,883
$237,643
$1,028,657
($5,265)
($93,666,488)
Option 2
($1,015,018)
($487,983)
($299,559)
($85,980)
($1,883,819)
($199,706)
($74,814,643)
($1,414,183)
($1,699,494)
($219,416)
($11,300,178)
($18,176,037)
($790,544)
$72,765
$737,729
$2,235,989
$660,076
$237,425
$1,028,508
($5,430)
($107,419,499)
1Note
that costs and benefits for import/repackage and incorporation into formulation, mixture, or reaction product are accounted for under the use categories for the formulated
products. These costs and benefits are aggregated under the use categories for the formulated products here so that benefits and costs are comparable. This is why the costs and
benefits presented in this table are larger for the use categories for the formulated products compared to values in the cost and benefits summary tables.
Table ES-15: Total 20-Year Annualized Net Benefits by Use Category and Regulatory Option (High Benefits Estimate, 7 Percent
Discount Rate)
Costs
Benefits
Net Benefits
Use Category
Executive Summary
Option 1 (Final
Rule)
Option 2
Option 1 (Final
Rule)
Option 2
Option 1 (Final
Rule)
Option 2
ES-26
Table ES-15: Total 20-Year Annualized Net Benefits by Use Category and Regulatory Option (High Benefits Estimate, 7 Percent
Discount Rate)
Costs
Benefits
Net Benefits
Use Category
Laboratory Use
Manufacturing
Battery and Synthetic Paper Processing Aid
HFC Manufacturing
Intermediate in HCl Production
Fluoroelastomer Manufacture
Open-Top Vapor Degreasing
Enclosed Vapor Degreasing
Conveyorized Vapor Degreasing
Web Vapor Degreasing
Batch Cold Cleaning
Disposal to Wastewater
Energized Electrical Cleaners (EEC)
Mold Release1
Liquid Cleaners and Degreasers1
Aerosol Spray Cleaning/Degreasing1
Lubricants and Greases1
Adhesives, Sealants, Paints and Coatings1
Spot Removers1
Pepper Spray1
Total
Option 1 (Final
Rule)
$1,015,018
$254,189
$267,524
$44,392
$178,349
$77,266,553
$1,409,320
$1,774,397
$221,800
$11,533,580
$7,072,738
$820,958
$78,680
$113,376
$148,340
$42,090
$90,292
$57,941
$5,618
$102,395,154
Option 2
$1,015,018
$492,243
$321,094
$86,691
$1,900,018
$214,063
$77,335,094
$1,415,334
$1,774,397
$221,800
$11,533,580
$18,504,991
$820,958
$78,680
$113,376
$148,340
$42,090
$90,292
$57,941
$5,618
$116,171,618
Option 1 (Final
Rule)
$3,867
$22,658
$645
$14,561
$2,553,722
$1,096
$76,117
$2,422
$237,185
$334,474
$30,773
$152,383
$865,051
$2,421,164
$714,367
$333,250
$1,103,380
$359
$8,867,475
Option 2
$4,329
$21,884
$723
$16,462
$14,590
$2,561,302
$1,170
$76,117
$2,422
$237,185
$334,285
$30,884
$153,900
$864,900
$2,421,159
$713,546
$333,029
$1,103,229
$191
$8,891,308
Option 1 (Final
Rule)
($1,015,018)
($250,322)
($244,866)
($43,747)
($163,788)
($74,712,831)
($1,408,223)
($1,698,279)
($219,377)
($11,296,395)
($6,738,264)
($790,185)
$73,703
$751,675
$2,272,824
$672,277
$242,958
$1,045,440
($5,259)
($93,527,680)
Option 2
($1,015,018)
($487,914)
($299,210)
($85,969)
($1,883,557)
($199,473)
($74,773,791)
($1,414,164)
($1,698,279)
($219,377)
($11,296,395)
($18,170,706)
($790,074)
$75,220
$751,524
$2,272,819
$671,457
$242,736
$1,045,289
($5,427)
($107,280,310)
1Note
that costs and benefits for import/repackage and incorporation into formulation, mixture, or reaction product are accounted for under the use categories for the formulated
products. These costs and benefits are aggregated under the use categories for the formulated products here so that benefits and costs are comparable. This is why the costs and
benefits presented in this table are larger for the use categories for the formulated products compared to values in the cost and benefits summary tables.
Executive Summary
ES-27
Table ES-16: Total 20-Year Annualized Net Benefits by Regulatory Option, (Millions, 2022$)
Estimate
Costs
Benefits
Option 1 (Final
Rule)
Low Benefits, 2 Percent Discount Rate
High Benefits, 2 Percent Discount Rate
Low Benefits, 3 Percent Discount Rate
High Benefits, 3 Percent Discount Rate
Low Benefits, 7 Percent Discount Rate
High Benefits, 7 Percent Discount Rate
Executive Summary
$64
$64
$71
$71
$102
$102
Option 1 (Final
Rule)
Option 2
$78
$78
$85
$85
$116
$116
$23
$23
$18
$18
$9
$9
Net Benefits
Option 1 (Final
Rule)
Option 2
$23
$23
$18
$19
$9
$9
($41)
($41)
($53)
($53)
($94)
($94)
Option 2
($55)
($55)
($67)
($67)
($107)
($107)
ES-28
Environmental Justice Impacts
EPA’s “Technical Guidance for Assessing Environmental Justice in Regulatory Analysis” provides
recommendations that encourage analysts to conduct the highest quality analysis feasible, recognizing
that data limitations, time and resource constraints, and analytic challenges will vary by media and
circumstance (EPA 2016b). This analysis presents information about the facilities, workforce, and
communities potentially affected by the regulatory options under current conditions. It draws on
publicly available data provided by EPA and U.S. Census, including the Toxics Release Inventory
(TRI), Chemical Data Reporting (CDR), National Emissions Inventory (NEI), the American
Community Survey (ACS), and the Quarterly Workforce Indicators (QWI).
The purpose of this analysis is to characterize the baseline conditions faced by communities and
workers affected by the regulation to identify the potential for disproportionate impacts on minority
and low-income populations. The EJ analysis first characterizes the average demographic
characteristics of communities near all TCE facilities compared to national and rural averages. The
baseline characterization across all facilities establishes typical demographics near these facilities and
provides a useful point of departure for examining specific subsets of facilities of special interest. The
analysis then delves into the characteristics of communities near facilities associated with highlighted
COUs.
This data is presented in Table ES-17. The table presents average information on communities
surrounding all identified facilities likely to be affected by the regulation compared to both the overall
national average and the national average for rural areas. The analysis uses socioeconomic and
demographic data from the American Community Survey 1-year data release for 2020 (the most
recent year available). The values in the last three columns reflect population-weighted averages
across the Census block groups within a 1-, 3-, and 5- mile radius of each facility. The table presents
rural in addition to overall national statistics for comparison because 1,412 of the 2,595 facilities are
located in rural communities. The table also includes the national air toxics assessment (NATA)
national average respiratory hazard score. These indices are developed as part of EPA’s Air Toxics
Screening Assessment (https://www.epa.gov/AirToxScreen). The respiratory hazard index is the sum
of hazard indices of air toxics with reference concentrations based on respiratory endpoints, where
each hazard index (HI) is the ratio of exposure concentration in the air to the health-based reference
concentration set by EPA. A hazard index of 1 or lower means air toxics are unlikely to cause adverse
noncancer health effects over a lifetime of exposure. However, an HI greater than 1 does not
necessarily mean adverse effects are likely. The cancer risk is an estimate of the lifetime cancer risk
from inhalation of air toxics (meaning the risk of developing cancer due to inhalation exposure to
each air toxic compound over a normal lifetime of 70 years), as risk per lifetime per million people 2.
1F
2
The Air Toxics Screening Assessment results are most meaningful when viewed at the state or national level.
These results alone are not sufficient to draw conclusions about local concentrations and risk (EPA 2017h).
Results are presented to give an indication of the baseline cancer and respiratory risk due to exposure to a
wide variety of air toxics for communities near a TCE facility.
Executive Summary
ES-29
Table ES-17: Demographics of Communities Within 1-, 3-, and 5-mile Radii of
Trichloroethylene Facilities, Population Weighted Averages
Demographic
Median Household
Income
National
Urban
1 Mile
Average
Rural
3 Mile
Average
5 Mile
Average
$64,994
$71,293
$51,878
$74,374
$77,378
$77,984
White
70.4%
66.5%
87.6%
63.0%
62.5%
62.7%
Black
12.6%
14.2%
5.8%
13.1%
14.1%
15.0%
American Indian
0.8%
0.6%
1.7%
0.6%
0.6%
0.6%
Asian
5.6%
6.6%
1.2%
8.9%
8.9%
8.3%
Pacific Islander
0.2%
0.2%
0.1%
0.2%
0.2%
0.2%
Other
5.1%
6.1%
0.8%
8.3%
7.8%
7.5%
2 or More Races
5.2%
5.7%
2.8%
5.9%
5.8%
5.7%
Hispanic
18.2%
21.7%
2.4%
23.2%
23.1%
22.4%
2x Poverty Line
29.8%
30.6%
26.0%
33.7%
31.6%
31.0%
Below Poverty Line
12.8%
13.6%
9.6%
15.7%
14.3%
13.9%
NATA Cancer Risk
20
-
-
30
30
31
NATA Respiratory
Hazard Score
0.3
-
-
0.4
0.4
0.4
-
-
-
8,558,151
55,806,017
106,394,429
Total Population
The analysis then explores the characteristics of communities near facilities associated with several
COUs. These COUs were selected for a number of reasons described in the respective analyses for
each of the uses. The analysis also presents an assessment of worker demographics for each of these
COUs. These uses include:
•
•
•
•
manufacturing of TCE (Section 10.6.2),
use of TCE as an intermediate in the manufacture of HFCs (Section 10.6.3),
use as a process solvent in the manufacture of battery separators Section 10.6.4), and
use in vapor degreasing (Section 10.6.5).
In the analysis, EPA also presents information on the number of facilities that may pose potential risk
to individuals living in close proximity to facilities releasing toxic chemicals according to TRI data
from 2020 for each of the uses covered. This shows whether TCE facilities are in areas with
clustering of TRI sites. However, assessing cumulative impacts on communities requires
understanding what is being emitted and what risks these facilities pose, which does not exactly
correspond to facility counts.
Presented as an example, Table ES-18 examines TRI facilities clustering around facilities associated
with the use of TCE as an intermediate in the manufacture of HFCs.
Table ES-18: Total Number of Other TRI Facilities Within 1, 3 and 5 Miles of Facilities
Using TCE to Manufacture HFCs
Facility Name
Location
Arkema, Inc.
Marshall, KY
Mexichem Fluor, Inc.
Iberville, LA
Executive Summary
Other TRI Facilities Other TRI Facilities
Within 1 Mile
Within 3 Miles
5
11
4
14
Other TRI Facilities
Within 5 Miles
11
21
ES-30
Data from EJSCREEN, EPA's environmental justice mapping and screening tool, are also presented.
Specifically, two environmental indicators from EJSCREEN are included: the air toxics cancer risk
and the air toxics respiratory hazard index, averaged across the geographic areas for facilities of
interest.
The benefits chapter (Chapter 8) does not discuss the sociodemographic characteristics of the affected
workers and ONUs. While EPA lacks information on the characteristics of the workers and ONUs in
the specific regulated facilities, this analysis provides sociodemographic information on workers in
the affected industries and locations as a proxy for the likely characteristics of affected workers and
ONUs. It also provides information on the sociodemographic characteristics of nearby communities
and general population.
Table ES-19 provides a sample of how demographic and EJSCREEN data was presented in the
analysis. Specifically, it addresses the Mexichem Fluor, Inc. facility in Louisiana, which uses TCE as
an intermediate in the manufacture of HFCs.
Table ES-19: Community Demographics Near Mexichem Fluor, St. Gabriel, LA
Demographic
Median
Household
Income
National
Rural
1 mile
3 miles
5 miles
$64,994
$51,878
$54,613
$52,868
$67,954
White
70.4%
87.60%
21.5%
29.7%
45%
Black
12.6%
5.80%
77.5%
68.5%
51%
American Indian
0.8%
1.70%
0.0%
0.0%
0%
Asian
5.6%
1.20%
0.1%
0.1%
0%
Pacific Islander
0.2%
0.10%
0.0%
0.0%
0%
2 or more races
5.1%
-
0.0%
0.3%
1%
Other
5.2%
3.60%
0.8%
1.4%
2%
Hispanic
18.2%
2.40%
2.4%
2.0%
4%
2x Below
Poverty Level
29.8%
26.00%
45.3%
38.4%
33%
Below Poverty
Level
12.8%
9.60%
20.3%
16.9%
15%
NATA Cancer
20
-
200
200
180
0.3
-
0.6
0.61
0.59
-
-
304
4,252
8,287
NATA
Respiratory
Total
Population
This analysis characterizes baseline conditions, so it does not provide information about the relative
merits of the primary alternative regulatory options. The EPA found unreasonable risk for numerous
uses of trichloroethylene. The regulatory options considered both would prohibit the manufacture
(including import), processing, distribution in commerce, industrial and commercial use, and disposal
of trichloroethylene in the short term for most of these uses. The risk evaluation did not evaluate
Executive Summary
ES-31
potential unreasonable risk to the general population from ambient air, water and disposal and
pathways for any condition of use for trichloroethylene.
Data limitations prevent EPA from conducting a more comprehensive EJ analysis that would identify
the incremental impacts of the regulatory options and assess the extent to which they mitigate or
exacerbate any disproportionate impacts in communities with environmental justice concerns.
Uncertainties include the sociodemographic characteristics of the specific individuals affected by the
use categories and the substitute technologies and practices that would be adopted at regulated entities
in response to the rule. While the final regulation is anticipated to eliminate unreasonable risks from
exposure to TCE, EPA is not able to quantify the distribution of the change in risk across affected
workers, communities, or demographic groups. EPA is also unable to quantify the changes in risks to
workers, communities, and demographic groups from non-TCE-using technologies, substitutes, or
practices that firms may adopt in response to the regulation to determine whether any such changes
could pose environmental justice concerns.
Overall, the baseline characterization established in this analysis suggests that workers (including
ONUs) in affected industries and regions, as well as residents of nearby communities, are often more
likely people of color than the general population in affected geographic areas. Further, the data
suggest that there are differentials in the demographics in communities surrounding most facilities
subject to this regulation compared to national averages. These include both race and ethnicity as well
as income. Battery separator manufacturing facilities are located near communities with larger
percentages of White populations when compared to the national average. Although one facility
identified has a higher percent American Indian population nearby, the facility is not within 5 miles of
tribal lands. Most facilities are in areas where there is a high density of other TRI facilities, which
could mean there is a cumulative risk to populations in the surrounding areas. Also, almost all
facilities are in areas where both the NATA Cancer Risk and NATA Respiratory Hazard Scores are
greater than the national average, with the highest NATA Cancer score of any facility investigated in
this EJ analysis at 10x the national average.
Estimated Small Business Impacts
Table ES-20 presents a summary of the small business impacts overall and for each of the use
categories where small business impacts were estimated.
Executive Summary
ES-32
Table ES-20: Summary of Small Business Impacts
Use Category
Laboratory Use
Import/Repackage
Battery and Synthetic Paper Processing Aid
Vapor Degreasing and Batch Cold Cleaning
Uses
Incorporation Into Formulation, Mixture, or
Reaction Product
Energized Electrical Cleaners
Disposal and Recycling
Mold Release
Liquid Cleaners and Degreasers
Aerosol Spray Cleaning/Degreasing
Lubricants and Greases
Adhesives, Sealants, Paints and Coatings
Spot Removers
Total
Executive Summary
5
1
Average Cost
Per Small
Firm (2022$,
7% Discount
Rate)
$4,044
$25
$89,175
330
$129,916
Number of
Small
Firms
25
16
651
17
15
11,574
3,626
332
58
4,949
21,599
$2,371 - $61,637
$107
$9,571
$8
$8
$8
$8
$8
$8
$8 - $129,916
Number and Percent of Firms by CostRevenue Impact Threshold
<1%
1-3%
>3%
25 (100%)
5 (100%)
1 (100%)
-
-
-
-
330 (100%)
16 (100%)
651 (100%)
17 (100%)
15 (100%)
11,574 (100%)
3,626 (100%)
332 (100%)
58 (100%)
4,949 (100%)
21,269 (98.5%)
-
330 (1.5%)
ES-33
1. Introduction
The U.S. Environmental Protection Agency (EPA) is undertaking rulemaking under section 6(a) of
the Toxic Substances Control Act (TSCA) for TCE after completing a risk evaluation and
determining that the chemical substance presents unreasonable risk under the conditions of use
(COU). This report estimates and evaluates the costs, benefits, and impacts expected to result from
the final rule to regulate manufacture (including import), processing, distribution in commerce and
industrial, commercial, and consumer use of TCE. EPA is finalizing the regulation under the authority
granted by Section 6 of TSCA. The final rule, “Regulation of Trichloroethylene Under TSCA Section
6(a),” addresses the unreasonable risk from TCE. These COUs are presented below in Table 1-1.
Table 1-1 also lists the use categories (or categories of TCE use that are considered in the economic
analysis) and defines how the economic analysis use categories map to the COUs.
Table 1-1: Use Categories Considered in the Economic Analysis Mapped to the Conditions of
Use (COUs) Defined in the Risk Evaluation
Introduction
1-1
Option 1 (ECEL of 0.2 ppm)
Option 2 (ECEL of 0.0011ppm)
WCPP followed by prohibition1
Prohibition/WCPP followed by prohibition2
Use Category
1Asphalt
Laboratory Use
Manufacturing
Import/Repackage
Battery and Synthetic
Paper Processing Aid
HFC Manufacturing
2Asphalt Testing: Prohibited. Other lab uses:
Testing: WCPP for 10 years followed
by prohibition (10-year 6g exemption). Other lab Exempt for 50 years, interim requirements of
uses: Exempt for 50 years, interim requirements
Workplace Chemical Protection Program
of Workplace Chemical Protection Program
(WCPP) 6 months after rule finalization.
(WCPP) 6 months after rule finalization.
WCPP for limited uses until prohibited3
3Interim requirements of Workplace Chemical Protection Program (WCPP) 6 months after rule
finalization.
WCPP followed by prohibition5
WCPP followed by prohibition4
415-year
510-year exemption with WCPP 6 months after
exemption with WCPP 6 months after
rule finalization for lead acid battery separators.
rule finalization for battery separator
5-year exemption with WCPP 6 months after
manufacture. Synthetic paper use prohibited.
rule finalization for lithium battery
separators.15-year exemption with WCPP 6
months after rule finalization for synthetic paper.
Long-Term Phase Out with WCPP followed by Prohibition6
6Long-term
phase out to prohibition over 8.5 years, interim requirements of WCPP.
Not Subject to Rule
WCPP followed by prohibition7
Intermediate in HCl
Production
Fluoroelastomer
Manufacture
Open-Top Vapor
Degreasing
Enclosed Vapor
Degreasing
Conveyorized/Web
Vapor Degreasing
Batch Cold Cleaning
Disposal to Wastewater
Energized Electrical
Cleaners
Incorporation into
Introduction
7WCPP
6 months to 2 years after rule
finalization followed by prohibition.
WCPP followed by Prohibition8
8WCPP
6 months to 2 years after rule finalization followed by prohibition.
Prohibition with Interim WCPP for Exemptions9
9A
6(g) exemption for 7 years applies to OTVD for narrow tubes for aerospace or medical device
use. A 6(g) exemption for 10 years applies to naval combat systems, radars, sensors, equipment, and
fabrication and prototyping processes for OTVDs. A 6(g) exemption for 7 years applies to humanrated rocket engine cleaning in EVDs by Federal agencies and their contractors. A 6(g) exemption
for 10 years applies to rayon fabric scouring in EVDs for rocket booster nozzle production for
Federal agencies and their contractors.
Prohibition11
Prohibition 1 year after rule finalization with
WCPP requirements for POTWs exceeding a
11One year after rule finalization.
water screening level and worker protection
requirements for cleanup sites and industrial
treatment/pre-treatment. 10
10For POTWs above the water screening level,
WCPP would be required (with the interim
occupational exposure limit (ECEL)). For
cleanup site workers and industrial
treatment/pre-treatment, use TSCA regulatory
limit (new interim occupational exposure limit
(ECEL)) within the framework of existing
OSHA HAZWOPER requirements.
Prohibition with Interim APF50 Respirator
Requirement12
Prohibition13
13Six
months after rule finalization.
12Prohibit
3 years after rule finalization with
interim prescriptive respiratory protection
requirements of APF 50 respirator use.
Prohibition14,15
1-2
Table 1-1: Use Categories Considered in the Economic Analysis Mapped to the Conditions of
Use (COUs) Defined in the Risk Evaluation
Use Category
Option 1 (ECEL of 0.2 ppm)
Option 2 (ECEL of 0.0011ppm)
Formulation, Mixture,
or Reaction Product
Commercial Use Pepper
Spray
Incorporation into
Articles
Mold Release
Liquid Cleaners and
Degreasers
Aerosol Spray
Cleaning/Degreasing
(except EEC)
Lubricants and Greases
Adhesives, Sealants,
Paints and Coatings3
Functional Fluids
Spot Removers
Film Cleaner
Toner Aid
14Prohibition
six months after rule finalization.
15Adhesives
and Sealants for Aerospace uses have a 5-year exemption with interim WCPP. Since
the numbers of workers affected by the exemption is unknown, the exemption is not accounted for
in the analysis and the costs and benefits from prohibition are assumed for all affected users of
adhesives, sealants, paints, and coatings.
Polish
1.1 Background
TCE is a volatile organic compound (VOC) used in industry as well as in commercial and consumer
products. The primary use of TCE is as an intermediate during the manufacture of refrigerants,
specifically HFC-134a, which accounts for about 83.6% of TCE’s annual production volume (EPA
2020e). TCE is also used as a solvent, frequently in cleaning and degreasing (including spot cleaning,
vapor degreasing, cold cleaning, and aerosol degreasing), which accounts for another 14.7% of TCE
production volume, leaving approximately 1.7% for other uses.
TCE is also a widely used solvent in a variety of commercial and consumer applications including
lubricants, adhesives and sealants, paints and coatings, and other miscellaneous products. The total
aggregate annual production volume ranged from 100 to 250 million pounds between 2016 and 2019
according to CDR (EPA 2016-2019).
Under TSCA section 6(a), if the Administrator determines, through a TSCA section 6(b) risk
evaluation that the manufacture (including import), processing, distribution in commerce, use, or
disposal of a chemical substance or mixture, or any combination of such activities, presents an
unreasonable risk of injury to health or the environment, EPA must by rule apply one or more of the
following requirements to the extent necessary so that the chemical substance or mixture no longer
presents such risk.
•
Prohibit or otherwise restrict the manufacturing, processing, or distribution in commerce of the
substance or mixture, or limit the amount of such substance or mixture which may be
manufactured, processed, or distributed in commerce (section 6(a)(1)).
•
Prohibit or otherwise restrict the manufacturing, processing, or distribution in commerce of the
substance or mixture for a particular use or above a specific concentration for a particular use
(section 6(a)(2)).
Introduction
1-3
•
Limit the amount of the substance or mixture which may be manufactured, processed, or
distributed in commerce for a particular use or above a specific concentration for a particular use
specified (section 6(a)(2)).
•
Require clear and adequate minimum warning and instructions with respect to the substance or
mixture or any article containing the substance or mixture’s use, distribution in commerce, or
disposal, or any combination of those activities, to be marked on or accompanying the substance
or mixture (section 6(a)(3)).
•
Require manufacturers and processors of the substance or mixture to make and retain certain
records or conduct certain monitoring or testing (section 6(a)(4)).
•
Prohibit or otherwise regulate any manner or method of commercial use of the substance or
mixture (section 6(a)(5)).
•
Prohibit or otherwise regulate any manner or method of disposal of the substance or mixture, or
any article containing such substance or mixture, by its manufacturer or processor or by any
person who uses or disposes of it for commercial purposes (section 6(a)(6)).
•
Direct manufacturers or processors of the substance or mixture to give notice of the unreasonable
risk determination to distributors, certain other persons, and the public, and to replace or
repurchase the substance or mixture (section 6(a)(7)).
EPA analyzed how the TSCA section 6(a) requirements could be applied to address the unreasonable
risk found to be present in the 2020 Risk Evaluation for TCE and the final revised unreasonable risk
determination, so that TCE no longer presents such unreasonable risk. This document presents an
economic analysis of EPA’s final regulatory action (Option 1) and an alternative regulatory action
(Option 2).
1.2 Regulatory Options Analyzed
Table 1-2 summarizes the regulatory options by use category. Pursuant to TSCA section 6(b), EPA
determined that TCE presents an unreasonable risk of injury to health, without consideration of costs
or other nonrisk factors, including an unreasonable risk to a potentially exposed or susceptible
subpopulation (PESS) identified as relevant to the 2020 Risk Evaluation for TCE by EPA, under the
conditions of use (EPA 2020e, EPA 2022c). Accordingly, to address the unreasonable risk, EPA is
finalizing a regulation under TSCA section 6(a), to:
(i) Prohibit the manufacture (including import) and processing of TCE for all uses (including all
consumer uses), with longer compliance timeframes for manufacture, processing, and distribution
in commerce related to certain industrial and commercial uses;
(ii) Prohibit the industrial and commercial use of TCE with longer compliance timeframes for
certain uses;
(iii) Prohibit the manufacture (including import) and processing of TCE as an intermediate for the
manufacturing of hydrofluorocarbon134a (HFC-134a), following an 8.5-year phaseout;
(iv) Prohibit the industrial and commercial use of TCE as a solvent for closed-loop batch vapor
degreasing for rayon fabric scouring for end use in rocket booster nozzle production by Federal
agencies and their contractors, following a 10-year phaseout;
(v) Prohibit the manufacture (including import), processing, distribution in commerce, and use of
Introduction
1-4
TCE as a laboratory chemical for asphalt testing and recovery, following a 10-year phaseout;
(vi) Prohibit the manufacture (including import), processing, distribution in commerce, and
industrial and commercial use of TCE as a solvent in batch vapor degreasing for essential
aerospace parts and components and narrow tubing used in medical devices, following a 7-year
TSCA section 6(g) exemption;
(vi) Prohibit the manufacture (including import), processing, distribution in commerce, and
industrial and commercial use of TCE as a solvent in closed loop vapor degreasing necessary for
rocket engine cleaning by Federal agencies and their contractors, following a 7-year TSCA
section 6(g) exemption;
(viii) For vessels of the Armed Forces and their systems, and in the maintenance, fabrication, and
sustainment for and of such vessels and systems, prohibit the industrial and commercial use of
TCE as: potting compounds for naval electronic systems and equipment; sealing compounds for
high and ultra-high vacuum systems; bonding compounds for materials testing and maintenance
of underwater systems and bonding of nonmetallic materials; and cleaning agents to satisfy
cleaning requirements (which includes degreasing using wipes, sprays, solvents and vapor
degreasing) for: materials and components required for military ordnance testing; temporary resin
repairs in vessel spaces where welding is not authorized; ensuring polyurethane adhesion for
electronic systems and equipment repair and installation of elastomeric materials; various naval
combat systems, radars, sensors, equipment; fabrication and prototyping processes to remove
coolant and other residue from machine parts; machined part fabrications for naval systems;
installation of topside rubber tile material aboard vessels; and vapor degreasing required for
substrate surface preparation prior to electroplating processes, following a 10-year TSCA section
6(g) exemption;
(ix) Prohibit the emergency industrial and commercial use of TCE in furtherance of the NASA
mission for specific conditions which are critical or essential and for which no technically and
economically feasible safer alternative is available, following a 10-year TSCA section 6(g)
exemption;
(x) Prohibit the manufacture (including import), processing, distribution in commerce, disposal,
and use of TCE as a processing aid for manufacturing battery separators for lead acid batteries,
following a 20-year TSCA section 6(g) exemption;
(xi) Prohibit the manufacture (including
import), processing, distribution in commerce, disposal, and use of TCE as a processing aid for
manufacturing microporous speciality film following a 15-year TSCA section 6(g) exemption;
(xii) Prohibit the manufacture (including import), processing, distribution in commerce,
and use of TCE as a laboratory chemical for essential laboratory activities and some research
and development activities, following a 50-year TSCA section 6(g) exemption;
(xiii) Require strict workplace controls to limit exposure to TCE, including compliance with a
TCE workplace chemical protection program (WCPP), which would include requirements for an
interim existing chemical exposure limit (ECEL) revised from the proposed rule, as well as
dermal protection, to limit exposure to TCE, for conditions of use with long term phaseouts or
time-limited exemptions under TSCA section 6(g) or prescriptive workplace controls.
(xiv) Prohibit the disposal of TCE to industrial pre-treatment, industrial
Introduction
1-5
treatment, or publicly owned treatment works through a phaseout allowing for longer timeframes
for disposal necessary for certain industrial and commercial uses along with a 50-year TSCA
section 6(g) exemption for disposal for cleanup before prohibition, and interim requirements for
wastewater worker protection; and
(xv) Establish recordkeeping and downstream notification requirements.
The primary alternative regulatory option, Option 2, follows EPA’s proposed regulatory option and
includes the following requirements that differ from than the Option 1 requirements:
•
A lower ECEL of 0.0011 ppm.
•
Laboratory use for asphalt testing is prohibited.
•
The exemption for battery separator manufacture is 10 years instead of 15 for lead acid
batteries and 5 years for lithium batteries; the processing aid use for synthetic paper is not
included in the exemption.
•
The use as an intermediate in HCl manufacture is subject to prohibition and interim WCPP
requirements
•
Disposal to wastewater is prohibited
•
Energized Electrical Cleaners (EEC) are prohibited six months after prohibition
Table 1-2: Summary of Regulatory Options by Use Category
Introduction
1-6
Option 1 (ECEL of 0.2 ppm)
Option 2 (ECEL of 0.0011ppm)
WCPP followed by prohibition1
Prohibition/WCPP followed by prohibition2
Use Category
1Asphalt
Laboratory Use
Manufacturing
Import/Repackage
Battery and Synthetic
Paper Processing Aid
HFC Manufacturing
2Asphalt Testing: Prohibited. Other lab uses:
Testing: WCPP for 10 years followed
by prohibition (10-year 6g exemption). Other lab Exempt for 50 years, interim requirements of
uses: Exempt for 50 years, interim requirements
Workplace Chemical Protection Program
of Workplace Chemical Protection Program
(WCPP) 6 months after rule finalization.
(WCPP) 6 months after rule finalization.
WCPP for limited uses until prohibited3
3Interim requirements of Workplace Chemical Protection Program (WCPP) 6 months after rule
finalization.
WCPP followed by prohibition5
WCPP followed by prohibition4
420-year
510-year exemption with WCPP 6 months after
exemption with WCPP 6 months after
rule finalization for lead acid battery separators.
rule finalization for battery separator
5-year exemption with WCPP 6 months after
manufacture. Synthetic paper use prohibited.
rule finalization for lithium battery
separators.15-year exemption with WCPP 6
months after rule finalization for synthetic paper.
Long-Term Phase Out with WCPP followed by Prohibition6
6Long-term
phase out to prohibition over 8.5 years, interim requirements of WCPP.
Not Subject to Rule
WCPP followed by prohibition7
Intermediate in HCl
Production
Fluoroelastomer
Manufacture
Open-Top Vapor
Degreasing
Enclosed Vapor
Degreasing
Conveyorized/Web
Vapor Degreasing
Batch Cold Cleaning
Disposal to Wastewater
Energized Electrical
Cleaners
Incorporation into
Introduction
7WCPP
6 months to 2 years after rule
finalization followed by prohibition.
WCPP followed by Prohibition8
8WCPP
6 months to 2 years after rule finalization followed by prohibition.
Prohibition with Interim WCPP for Exemptions9
9A
6(g) exemption for 7 years applies to OTVD for narrow tubes for aerospace or medical device
use. A 6(g) exemption for 10 years applies to naval combat systems, radars, sensors, equipment, and
fabrication and prototyping processes for OTVDs. A 6(g) exemption for 7 years applies to humanrated rocket engine cleaning in EVDs by Federal agencies and their contractors. A 6(g) exemption
for 10 years applies to rayon fabric scouring in EVDs for rocket booster nozzle production for
Federal agencies and their contractors.
Prohibition11
Prohibition 1 year after rule finalization with
WCPP requirements for POTWs exceeding a
11One year after rule finalization.
water screening level and worker protection
requirements for cleanup sites and industrial
treatment/pre-treatment. 10
10For POTWs above the water screening level,
WCPP would be required (with the interim
occupational exposure limit (ECEL)). For
cleanup site workers and industrial
treatment/pre-treatment, use TSCA regulatory
limit (new interim occupational exposure limit
(ECEL)) within the framework of existing
OSHA HAZWOPER requirements.
Prohibition with Interim APF50 Respirator
Requirement12
Prohibition13
13Six
months after rule finalization.
12Prohibit
3 years after rule finalization with
interim prescriptive respiratory protection
requirements of APF 50 respirator use.
Prohibition14,15
1-7
Table 1-2: Summary of Regulatory Options by Use Category
Use Category
Option 1 (ECEL of 0.2 ppm)
Formulation, Mixture,
or Reaction Product
Commercial Use Pepper
Spray
Incorporation into
Articles
Mold Release
Liquid Cleaners and
Degreasers
Aerosol Spray
Cleaning/Degreasing
(except EEC)
Lubricants and Greases
Adhesives, Sealants,
Paints and Coatings3
Functional Fluids
Spot Removers
Film Cleaner
Toner Aid
14Prohibition
Option 2 (ECEL of 0.0011ppm)
six months after rule finalization.
15Adhesives
and Sealants for Aerospace uses have a 5-year exemption with interim WCPP. Since
the numbers of workers affected by the exemption is unknown, the exemption is not accounted for
in the analysis and the costs and benefits from prohibition are assumed for all affected users of
adhesives, sealants, paints, and coatings.
Polish
1.3 Organization of this Document
Chapter 2 presents a discussion of the problems with TCE uses that are addressed through the final
rule. Chapter 3 presents general industry statistics for the sectors expected to be affected under the
regulatory options. Chapter 4 presents information on the products formulated with TCE identified by
EPA and the producers of those products. Section 5 discusses the availability of alternatives for the
different categories of TCE usage and considers the costs and efficacy of the available alternatives.
Chapter 6 presents a baseline analysis of the volume of TCE consumption and the numbers of firms,
employees, and consumers using TCE. The estimated costs, benefits, and net benefits of the
regulatory options are presented in Chapter 7, 8, and 9, respectively. Chapter 10 presents various
impact analyses. Finally, the references are listed in Chapter 11.
Introduction
1-8
2. Problem Definition/Market Failure
This report estimates and evaluates the costs and benefits expected to result from the final rule
limiting the use of TCE by the U.S. Environmental Protection Agency (EPA) under the authority
granted by Section 6 of the Toxic Substances Control Act (TSCA). The final rule, “Trichloroethylene
(TCE); Rulemaking Under TSCA Section 6(a)” addresses the unreasonable risk from TCE under the
conditions of use (COUs).
2.1 Trichloroethylene Problem
2.1.1 Sources of Exposure
Exposure to TCE occurs through the chemical substance’s COU. TSCA Section 3(4) defines a
chemical substance’s conditions of use as ‘‘the circumstances, as determined by the Administrator,
under which a chemical substance is intended, known, or reasonably foreseen to be manufactured,
processed, distributed in commerce, used, or disposed of.” EPA’s 2020 Risk Evaluation for TCE
evaluated whether exposure resulting from TCE’s conditions of use presents an unreasonable risk to
health and/or the environment (EPA 2020e).
2.1.2 Health Effects of TCE Exposure
TCE has a large database of human health toxicity data. The 2020 Risk Evaluation for TCE identified
several endpoints, such as kidney toxicity, immunotoxicity, or developmental toxicity, and often a
single endpoint was examined by multiple studies. For acute exposures, EPA evaluated non-cancer
effects (developmental toxicity and mortality due to immunosuppression). For chronic exposures,
EPA evaluated non-cancer effects (liver toxicity, kidney toxicity, neurotoxicity, autoimmunity,
reproductive toxicity, and developmental toxicity) as well as cancer (liver, kidney, and non-Hodgkin
Lymphoma), most strongly supported by the data on kidney cancer. (EPA 2020e). As discussed in the
preamble, the 2020 Risk Evaluation for TCE contains quantitative risk estimates using several points
of departure (PODs), including both the immunotoxicity endpoints as well as the more sensitive
developmental toxicity endpoints, specifically fetal cardiac defects, and both demonstrate that TCE
presents unreasonable risk.
2.1.3 Regulatory Approaches for Primary and Alternative Options
Under TSCA section 6(a), if the EPA pursuant to TSCA section 6(b)(4)(A) determines that a
chemical substance presents an unreasonable risk of injury to health or the environment, without
consideration of costs or other non-risk factors, including an unreasonable risk to a potentially
exposed or susceptible subpopulation identified as relevant to the Agency’s risk evaluation, under the
conditions of use, EPA must by rule apply one or more requirements to the extent necessary so that
the chemical substance no longer presents such risk.
The TSCA section 6(a) requirements can include one or more, or a combination of, the following
actions:
• Prohibit or otherwise restrict, or limit the manufacturing, processing, or distribution in
commerce of the substance or mixture (TSCA section 6(a)(1)).
• Prohibit or otherwise restrict, or limit the manufacturing, processing, or distribution in
commerce of the substance or mixture for particular uses or above a specific concentration
for a particular use (TSCA section 6(a)(2)).
• Require clear and adequate minimum warning and instructions with respect to its use,
distribution in commerce, or disposal of the substance or mixture (TSCA section 6(a)(3)).
Problem Definition/Market Failure
2-1
• Require record keeping, monitoring or testing by manufacturers and processors (TSCA
6(a)(4)).
• Prohibit or regulate any manner or method of commercial use of the substance or mixture
(TSCA section 6(a)(5)).
• Prohibit or otherwise regulate any manner or method of disposal of the substance or mixture
(TSCA section 6(a)(6)).
• Direct manufacturers or processors to give notice of the determination of risk to distributors
and users and replace or repurchase the substance or mixture (TSCA section 6(a)(7)).
EPA considered all of the regulatory mechanisms described above, but EPA believes only a few
would be effective in addressing the identified unreasonable risk. The regulatory mechanisms that are
being utilized as part of this rulemaking include the following:
• Prohibitions: The final rule considers specific prohibitions on TCE for the use categories
indicated in Table 2-1.
• Workplace Chemical Protection Program (WCPP): The rule requires a workplace chemical
protection program as an interim measure until the prohibition that includes setting an interim
existing chemical exposure limit (ECEL) of 0.2 ppm for inhalation exposures to TCE (8-hr timeweighted average (TWA)) for the use categories indicated in Table 2-1 (EPA 2021a). Firms would be
required to monitor potentially exposed persons 3 to ensure they are not exposed to the chemical at a
level that exceeds the exposure limit. The method of reducing exposure to this limit would be left to
the firm, but it may include respiratory and dermal personal protective equipment (PPE) or other
engineering controls.
2F
The regulatory action that EPA chose for TCE under this rulemaking, as well as an alternative option,
are summarized in Table 2-1 (see Table 1-1 for a map between the Use Categories and the COUs).
Both EPA’s final rule and an alternative option were considered in this Economic Analysis.
Table 2-1: Summary of Regulatory Options by Use Category
3
EPA uses the term “potentially exposed person” in this economic analysis and in the regulatory text to include
workers, ONUs, employees, independent contractors, employers, and all other persons in the work area
who may be exposed to TCE under the conditions of use for which a WCPP would apply.
Problem Definition/Market Failure
2-2
Option 1 (ECEL of 0.2 ppm)
Option 2 (ECEL of 0.0011ppm)
WCPP followed by prohibition1
Prohibition/WCPP followed by prohibition2
Use Category
1Asphalt
Laboratory Use
Manufacturing
Import/Repackage
Battery and Synthetic
Paper Processing Aid
HFC Manufacturing
2Asphalt Testing: Prohibited. Other lab uses:
Testing: WCPP for 10 years followed
by prohibition (10-year 6g exemption). Other lab Exempt for 50 years, interim requirements of
uses: Exempt for 50 years, interim requirements
Workplace Chemical Protection Program
of Workplace Chemical Protection Program
(WCPP) 6 months after rule finalization.
(WCPP) 6 months after rule finalization.
WCPP for limited uses until prohibited3
3Interim requirements of Workplace Chemical Protection Program (WCPP) 6 months after rule
finalization.
WCPP followed by prohibition5
WCPP followed by prohibition4
420-year
510-year exemption with WCPP 6 months after
exemption with WCPP 6 months after
rule finalization for lead acid battery separators.
rule finalization for battery separator
5-year exemption with WCPP 6 months after
manufacture. Synthetic paper use prohibited.
rule finalization for lithium battery
separators.15-year exemption with WCPP 6
months after rule finalization for synthetic paper.
Long-Term Phase Out with WCPP followed by Prohibition6
6Long-term
phase out to prohibition over 8.5 years, interim requirements of WCPP.
Not Subject to Rule
WCPP followed by prohibition7
Intermediate in HCl
Production
Fluoroelastomer
Manufacture
Open-Top Vapor
Degreasing
Enclosed Vapor
Degreasing
Conveyorized/Web
Vapor Degreasing
Batch Cold Cleaning
Disposal to Wastewater
Energized Electrical
Cleaners
7WCPP
6 months to 2 years after rule
finalization followed by prohibition.
WCPP followed by Prohibition8
8WCPP
6 months to 2 years after rule finalization followed by prohibition.
Prohibition with Interim WCPP for Exemptions9
9A
6(g) exemption for 7 years applies to OTVD for narrow tubes for aerospace or medical device
use. A 6(g) exemption for 10 years applies to naval combat systems, radars, sensors, equipment, and
fabrication and prototyping processes for OTVDs. A 6(g) exemption for 7 years applies to humanrated rocket engine cleaning in EVDs by Federal agencies and their contractors. A 6(g) exemption
for 10 years applies to rayon fabric scouring in EVDs for rocket booster nozzle production for
Federal agencies and their contractors.
Prohibition11
Prohibition 1 year after rule finalization with
WCPP requirements for POTWs exceeding a
11One year after rule finalization.
water screening level and worker protection
requirements for cleanup sites and industrial
treatment/pre-treatment. 10
10For POTWs above the water screening level,
WCPP would be required (with the interim
occupational exposure limit (ECEL)). For
cleanup site workers and industrial
treatment/pre-treatment, use TSCA regulatory
limit (new interim occupational exposure limit
(ECEL)) within the framework of existing
OSHA HAZWOPER requirements.
Prohibition with Interim APF50 Respirator
Requirement12
Prohibition13
13Six
months after rule finalization.
12Prohibit
3 years after rule finalization with
interim prescriptive respiratory protection
requirements of APF 50 respirator use.
Incorporation into
Problem Definition/Market Failure
Prohibition14,15
2-3
Table 2-1: Summary of Regulatory Options by Use Category
Use Category
Option 1 (ECEL of 0.2 ppm)
Formulation, Mixture,
or Reaction Product
Commercial Use Pepper
Spray
Incorporation into
Articles
Mold Release
Liquid Cleaners and
Degreasers
Aerosol Spray
Cleaning/Degreasing
(except EEC)
Lubricants and Greases
Adhesives, Sealants,
Paints and Coatings3
Functional Fluids
Spot Removers
Film Cleaner
Toner Aid
14Prohibition
Option 2 (ECEL of 0.0011ppm)
six months after rule finalization.
15Adhesives
and Sealants for Aerospace uses have a 5-year exemption with interim WCPP. Since
the numbers of workers affected by the exemption is unknown, the exemption is not accounted for
in the analysis and the costs and benefits from prohibition are assumed for all affected users of
adhesives, sealants, paints, and coatings.
Polish
2.2 Regulatory Background
Because of its potential health effects, TCE is subject to numerous state, federal, and international
regulations restricting and regulating its use. For a full description see Appendix A of the Risk
Evaluation (EPA 2020e).
2.3 Justification for Risk Management Action for TCE
This section provides legal and economic justification of the final rule to regulate TCE in the United
States at the federal level of government. Section 2.3.1 indicates the statutory authority for EPA to
take risk management action, Section 2.3.2 identifies market failure in the industries where TCE is
used, Section 2.3.3 discusses regulatory remedies to address market failure from negative
externalities, and Section 2.3.4 provides justification for regulation at the federal level specifically.
2.3.1 Statutory Authority
The Frank R. Lautenberg Chemical Safety for the 21st Century Act amended the Toxic Substances
Control Act (TSCA), the nation’s primary chemicals management law, in June 2016. 4 Under the
amended statute, EPA is required, under TSCA section 6(b), to conduct risk evaluations to determine
whether a chemical substance presents an unreasonable risk of injury to health or the environment,
including an unreasonable risk to potentially exposed or susceptible subpopulations identified as
relevant to the Risk Evaluation under the conditions of use, without consideration of costs or other
non-risk factors. If unreasonable risk is found, the agency must apply one or more of the risk
management options listed in TSCA 6(a) to the extent necessary to reduce or eliminate these risks.
3F
4
See https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/frank-r-lautenberg-chemical-safety21st-century-act.
Problem Definition/Market Failure
2-4
2.3.2 Market Failure
The private market is a mechanism that can allocate resources efficiently. However, the market’s
allocation of resources will not always be desirable from the standpoint of society. The market will
fail to achieve a socially efficient outcome when differences exist between private market values and
social values.
Welfare economics states that a socially efficient outcome is achieved if no alternative allocation of
society’s resources can make at least one person better off without making another one worse off.
This is referred to as a Pareto optimal outcome. If the private market fails to achieve this efficient
outcome, too little or too much is produced, resulting in a loss in economic welfare. This is referred to
as a market failure.
However, Pareto optimality is a strict condition and can allow for very unequal allocations. It does
not address redistributive actions, in which one group is made worse off and another group is made
better off. A less strict criteria for measuring economic improvement is Kaldor-Hicks efficiency.
Under this criterion, economic efficiency is improved if those who benefit from an action gain more
than those who lose from that action. 5 This is the fundamental efficiency criterion of benefit-cost
analysis: society is considered to be better off (in terms of economic efficiency) if the benefits of an
action outweigh the cost of undertaking it.
4F
Government regulation of a private market is justified when the market fails to deliver a socially
efficient outcome. If a regulation can produce benefits that exceeds its cost, then economic efficiency
has been improved. The economic literature has identified the following common causes of market
failure and economic inefficiency:
•
Existence of externalities (negative and positive);
•
Under-provision of common property resources, and public goods;
•
Market power (e.g., monopolies);
•
Inadequate or asymmetric information
This section discusses how negative externalities are present in the market for the chemical regulated
under this rule. 6 By understanding how the market is affected by this market failure, more effective
regulations can be designed.
5F
A negative externality occurs when one party’s action imposes an uncompensated negative effect on
another party. For example, the manufacturer, processor, or consumer of a good may impose costs on
another party if the good causes an adverse health impact that is not known or factored into the
market transaction. Since these external costs are not internalized by the manufacturer, processor, or
5
The Kaldor-Hicks criterion is also referred to as the potential Pareto criterion or the potential compensation
principle because it implies that economic efficiency is improved if those who benefit from an action could
fully compensate those who lose from that action, and still be better off. In other words, it is theoretically
possible to achieve a Pareto improvement – in which some are made better off, and no one is made worse
off – if those who benefit from a regulation were to fully compensate those who pay the cost. The word
“potential” is used because the compensation does not have to actually occur, it just has to be theoretically
possible to do so for this to be a social improvement.
6
This discussion focuses on negative externalities because this is the market failure addressed by this
regulation. Please refer to EPA Guidelines for Preparing Economic Analyses (EPA 2014a) for a discussion on
additional sources of market failure identified in the literature.
Problem Definition/Market Failure
2-5
user, they are not considered in the production (or processing, use) and pricing decisions. As a result,
the societal cost of these goods is under-valued and the level of output produced (or processed, used)
is higher than the social optimal output level. In other words, a negative externality occurs when a
firm makes decisions based on private costs instead of social costs, leading to an excess of product in
the market.
EPA believes that the cause of market failure in the market for TCE subject to this rule stems from
negative externalities and imperfect information. A negative externality occurs when one party’s
action imposes an uncompensated negative effect on an affected party. For example, the
manufacturer, processor, or consumer of a good may impose uncompensated healthcare costs or
damages that are not reflected in the cost of that good. Even when both parties have full information
about the magnitude of the health damages—which is not always the case in the context of hazardous
chemical exposures—the private market is likely to reach an efficient outcome only when bargaining
is possible and transaction costs are low (Coase 1960). While many of the adverse health effects from
exposure to TCE are well established (EPA 2020d), some effects are difficult to quantify in humans
and to predict at the individual level. (EPA 2011b). Bargaining is not possible because neither party
has the information or skill to predict the risk accurately. Even if the EPA provided this information,
transaction costs are high because of the effort required for workers and employers to determine the
correct risk-adjusted wage for each site. Therefore, the adverse health effects of TCE exposure are
imposed on workers who may not be fully compensated for the additional burden from increased
health risks and are thus not internalized by those manufacturing, processing, distributing, or using
the chemical.
Because these adverse health effects are not internalized by the manufacturer, processor, or user, they
are therefore not considered in the production (or processing, use) and pricing decision of the
manufacturer, processor or user. As a result, costs are under-valued and the level of output produced
(or processed, used) is higher than the socially optimal output level. Therefore, a negative externality
occurs when a firm has made decisions based on private costs instead of social costs, leading to an
excess of product in the market (EPA 2011).
While it is theoretically possible to force manufactures, processers, distributers, and users to
internalize the external costs of TCE (for example, thorough a pollution tax or tradable permit
program), EPA believes that this is not the right approach for addressing the negative externality in
this market. This approach would be administratively burdensome and impose high transaction costs
in a market with a multitude and varied conditions of use. Instead, EPA’s approach is to decrease the
volume of TCE in the market closer to what would be socially optimal and, thereby, reduce the
negative externality of health impacts caused by exposure to the chemical.
Society will experience health benefits from regulatory measures that limit or eliminate the
manufacture, processing, distribution, use, and disposal of TCE. However, society will experience net
benefits from these regulatory measures only up to the point where the benefits of reducing these
negative externalities are less than the costs of achieving them. If the costs of these regulatory
measures on manufacturers, processors, and users of TCE are greater than the external costs imposed
by their use, the regulation is too strict and the new state is also suboptimal. Social welfare would be
decreased by any regulatory measure that goes beyond the point where the volume of TCE has been
reduced to the same point as if the externalities were internalized. The economically efficient level of
control is where the additional (marginal) cost of further control equals society’s willingness to pay
for the next increment of control. Adverse effects may still occur at this level, but additional
regulatory costs to further reduce or eliminate these effects would not be Pareto optimal. Conversely,
if post-rule, the cost to society from release and exposure to TCE remains greater than costs to
regulated firms, the rule would also not produce a Pareto optimal outcome.
Problem Definition/Market Failure
2-6
2.3.3 Regulatory Remedies to Reduce Negative Externalities
As discussed in Section 2.1.3, the regulatory options detail various requirements that will reduce the
negative human health costs associated with the negative externality. Prohibition of the chemical,
Existing Chemical Exposure Limit (ECEL), and Monitoring and Hierarchy of Controls (HOC)
requirements all eliminate or reduce (for long-term phaseouts and longer compliance timeframes)
exposure of TCE to third parties. EPA contends that these measures are sufficient to reduce negative
externalities associated with TCE.
2.3.4 Justification for Regulation at Federal Level
The chemical and products associated with this rulemaking are distributed in commerce across state
lines, and thus they fall under the federal jurisdiction of regulation under TSCA. It is more efficient
for companies manufacturing, processing, distributing, using and disposing of these products to
comply with a single federal standard rather than a patchwork of different state regulations. EPA
acknowledges that because of its health effects, TCE is subject to numerous State, Federal, and
international regulations restricting and regulating its use.
Problem Definition/Market Failure
2-7
3. Profile of Affected Industries
Table 3-1 shows the industry statistics for each NAICS code, indicates which use categories are
applicable for each NAICS, and presents the estimated numbers of firms and employment for firms
defined as small businesses according to the SBA definitions (SBA 2023).
NAICS codes were identified for the use categories as follows:
•
Manufacturing; import/repackaging, and HFC manufacturing; NAICS were identified using
2020 CDR data (EPA 2020j). Additional processing as a reactant/intermediate NAICS were
identified using 2020 TRI (EPA 2022b) and 2017 NEI data (EPA 2020a).
•
Vapor degreasing NAICS were identified in EPA’s risk evaluation (EPA 2020e).
•
Incorporation into formulation, mixture, or reaction product NAICS were identified through
product searches (see Chapter 4).
•
Battery manufacturing; mold release; liquid cleaners and degreasers; and adhesives, sealants,
paints, and coatings NAICS were identified using 2017 NEI data (EPA 2020a). Additional
NAICS for adhesives, sealants, paints, and coatings were also identified from EPA’s risk
evaluation (EPA 2020e).
•
Aerosol spray cleaning/degreasing and spot removers NAICS were assumed to be the same as
those identified in EPA’s Economic Analysis of Proposed TSCA Section 6 Action on
Trichloroethylene in Dry Cleaning Spot Removers and Aerosol Degreasers (EPA 2017a).
•
NAICS for remaining use categories were selected based on EPA best judgement.
Table 3-2 presents company information and the small business determinations for any parent
companies identified by EPA as potentially affected under the regulatory options. Companies using
TCE were identified using 2020 CDR data (EPA 2020j), 2020 TRI data (EPA 2022b), 2017 NEI data
(EPA 2020a), and EPA’s risk evaluation (EPA 2020e). Companies producing TCE products were
identified as described below in Chapter 4. Company information was obtained from the Dun and
Bradstreet Hoovers database (Dun & Bradstreet 2022) and the Experian Business Target IQ database
(Experian 2023). The small business determinations were made using SBA’s small business
thresholds (SBA 2023).
Profile of Affected Industries
3-1
Table 3-1: Industry Statistics
Use
Categories
NAICS
Profile of Affected Industries
Small
Business
Threshold
Number of
Firms1
All
SBADefined
Small
Number
of
Establishments1
Employment
All
SBADefined
Small
Annual
Payroll
(thousands,
2022$)
Preliminary
Receipts
(thousands,
2022$)
3-2
Table 3-1: Industry Statistics
Use
Categories
Laboratory Use
Manufacturing
Import/
Repackage
NAICS
211120: Crude Petroleum Extraction
313310: Textile and Fabric Finishing
Mills
541715: Research and Development
in the Physical, Engineering, and Life
Sciences (except Nanotechnology and
Biotechnology)
541720: Research and Development
in the Social Sciences and
Humanities
611210: Junior Colleges
611310: Colleges, Universities and
Professional Schools
928110: Other Similar Organizations
(except Business, Professional,
Labor, and Political Organizations)
221112: Fossil Fuel Electric Power
Generation
325180: Other Basic Inorganic
Chemical Manufacturing
325199: All Other Basic Organic
Chemical Manufacturing
325411: Medicinal and Botanical
Manufacturing
325180: Other Basic Inorganic
Chemical Manufacturing
325510: Paint and Coating
Manufacturing
325520: Adhesive Manufacturing
423840: Industrial Supplies Merchant
Wholesalers
424690: Other Chemical and Allied
Products Merchant Wholesalers
Profile of Affected Industries
Small
Business
1,250
Employees
1,000
Employees
1,000
Employees
$28 Million
$32.5
Million
$34.5
Million
N/A
950
Employees
1,000
Employees
1,250
Employees
1,000
Employees
1,000
Employees
1,000
Employees
550
Employees
125
Employees
175
Employees
Number of
Firms1
Number
of
Annual
Payroll
Employment
Preliminary
Receipts
4,570
4,524
5,333
85,169
53,015
$11,661,714
$192,535,137
650
633
678
20,556
13,385
$781,035
$5,827,994
8,019
7,641
10,032
465,680
147,517
$78,501,616
$115,647,395
1,732
1,661
1,946
44,665
14,027
$3,725,397
$8,493,643
443
369
806
61,685
23,407
$2,320,900
$7,016,534
2,433
1,463
4,450
1,867,444
88,804
$99,365,452
$305,158,514
N/A
N/A
N/A
N/A
N/A
N/A
N/A
231
169
1,700
75,470
16,472
$9,185,713
$90,013,617
363
302
626
39,878
16,307
$4,345,440
$38,167,323
591
511
814
67,603
24,105
$7,870,579
$91,550,816
451
429
492
27,160
16,464
$2,775,937
$13,188,303
363
302
626
39,878
16,307
$4,345,440
$38,167,323
998
964
1,197
39,139
22,907
$2,989,102
$32,768,919
403
346
559
24,231
9,109
$1,966,229
$17,661,519
5,811
5,495
9,463
105,490
52,940
$8,601,821
$91,461,027
6,069
5,767
9,418
126,009
50,790
$12,168,548
$234,995,872
3-3
Table 3-1: Industry Statistics
Use
Categories
Battery and
Synthetic
Paper
Processing Aid
HFC
Manufacturing
Intermediate in
HCl
Production
Fluoroelastomer
Manufacture
Open-Top
Vapor
Degreasing
NAICS
325998: All Other Miscellaneous
Chemical Product and Preparation
Manufacturing
326291: Rubber Product
Manufacturing for Mechanical Use
335911: Storage Battery
Manufacturing
325180: Other Basic Inorganic
Chemical Manufacturing
325411: Medicinal and Botanical
Manufacturing
221118: Other Electric Power
Generation
324110: Petroleum Refineries
325110: Petrochemical
Manufacturing
325180: Other Basic Inorganic
Chemical Manufacturing
325193: Ethyl Alcohol
Manufacturing
325199: All Other Basic Organic
Chemical Manufacturing
325211: Plastics Material and Resin
Manufacturing
562212: Solid Waste Landfill
321911: Wood Window and Door
Manufacturing
326220: Rubber and Plastics Hoses
and Belting Manufacturing
333415: Air-Conditioning and Warm
Air Heating Equipment and
Commercial and Industrial
Refrigeration Equipment
Manufacturing
333515: Cutting Tool and Machine
Profile of Affected Industries
Small
Business
650
Employees
750
Employees
1,250
Employees
1,000
Employees
1,000
Employees
650
Employees
1,500
Employees
1,300
Employees
1,000
Employees
1,000
Employees
1,250
Employees
1,250
Employees
$47 Million
1,000
Employees
800
Employees
1,250
Employees
500
Number of
Firms1
Number
of
Annual
Payroll
Employment
Preliminary
Receipts
1,064
982
1,230
36,900
17,820
$3,363,541
$26,088,857
346
315
411
30,895
14,720
$1,733,734
$9,086,527
123
112
164
22,805
7,104
$1,499,462
$8,866,515
363
302
626
39,878
16,307
$4,345,440
$38,167,323
451
429
492
27,160
16,464
$2,775,937
$13,188,303
36
33
54
150
125
$45,289
$44,407
70
44
155
63,594
5,381
$9,364,769
$571,414,981
28
17
44
9,369
1,691
$1,466,152
$63,239,154
363
302
626
39,878
16,307
$4,345,440
$38,167,323
121
107
210
11,276
5,583
$894,727
$38,210,789
591
511
814
67,603
24,105
$7,870,579
$91,550,816
852
668
768
631
1,125
1,439
75,998
18,711
34,018
6,044
$8,264,736
$1,454,084
$106,880,973
$9,117,835
961
932
1,110
54,943
20,728
$2,927,323
$14,686,172
196
177
273
19,713
8,697
$1,186,280
$6,330,711
705
1,285
653
1,253
841
1,347
89,119
26,940
28,842
20,611
$5,670,644
$1,555,905
$38,502,337
$6,244,600
3-4
Table 3-1: Industry Statistics
Use
Categories
NAICS
Tool Accessory Manufacturing
333612: Speed Changer, Industrial
High-Speed Drive and Gear
Manufacturing
333912: Air and Gas Compressor
Manufacturing
333914: Measuring, Dispensing, and
Other Pumping Equipment
Manufacturing
333921: Elevator and Moving
Stairway Manufacturing
333922: Conveyor and Conveying
Equipment Manufacturing
333923: Overhead Traveling Crane,
Hoist and Monorail System
Manufacturing
333924: Industrial Truck, Tractor,
Trailer and Stacker Machinery
Manufacturing
333991: Power-Driven Hand Tool
Manufacturing
333992: Welding and Soldering
Equipment Manufacturing
333993: Packaging Machinery
Manufacturing
333994: Industrial Process Furnace
and Oven Manufacturing
333995: Fluid Power Cylinder and
Actuator Manufacturing
333996: Fluid Power Pump and
Motor Manufacturing
333997: Scale and Balance
Manufacturing
333999: All Other Miscellaneous
General Purpose Machinery
Manufacturing
Profile of Affected Industries
Small
Business
Employees
750
Employees
1,000
Employees
750
Employees
1,000
Employees
500
Employees
1,250
Employees
900
Employees
950
Employees
1,250
Employees
600
Employees
500
Employees
800
Employees
1,250
Employees
700
Employees
700
Employees
Number of
Firms1
Number
of
Employment
Annual
Payroll
Preliminary
Receipts
194
176
230
11,926
7,046
$713,824
$3,991,472
261
238
297
18,362
8,437
$1,655,285
$10,999,105
457
410
576
37,181
11,735
$3,055,087
$19,698,490
166
158
176
8,545
5,015
$644,430
$4,088,596
718
683
779
37,082
24,636
$2,878,058
$11,783,275
268
255
303
19,299
8,356
$1,380,271
$8,109,698
311
287
333
27,533
11,576
$1,894,944
$12,378,097
123
110
130
7,246
2,374
$431,216
$4,062,356
341
331
363
16,213
6,225
$1,182,351
$6,664,593
471
440
518
20,826
12,357
$1,826,335
$8,329,437
317
302
344
10,868
7,984
$750,978
$3,045,889
253
221
317
22,529
8,816
$1,675,845
$8,571,075
132
116
157
10,484
4,092
$892,979
$5,175,264
73
68
83
3,707
1,686
$231,853
$1,230,627
1,558
1,467
1,645
55,552
29,610
$4,522,513
$19,556,021
3-5
Table 3-1: Industry Statistics
Use
Categories
NAICS
334416: Capacitor, Resistor, Coil,
Transformer, and Other Inductor
Manufacturing
334417: Electronic Connector
Manufacturing
334418: Printed Circuit Assembly
(Electronic Assembly) Manufacturing
334419: Other Electronic Component
Manufacturing
334512: Automatic Environmental
Control Manufacturing for
Residential, Commercial and
Appliance Use
334513: Instruments and Related
Products Manufacturing for
Measuring, Displaying, and
Controlling Industrial Process
Variables
334515: Instrument Manufacturing
for Measuring and Testing Electricity
and Electrical Signals
335110: Electric Lamp Bulb and Part
Manufacturing
335121: Residential Electric Lighting
Fixture Manufacturing
335122: Commercial, Industrial and
Institutional Electric Lighting Fixture
Manufacturing
335129: Other Lighting Equipment
Manufacturing
335311: Power, Distribution and
Specialty Transformer Manufacturing
335312: Motor and Generator
Manufacturing
335313: Switchgear and Switchboard
Apparatus Manufacturing
Profile of Affected Industries
Small
Business
550
Employees
1,000
Employees
750
Employees
750
Employees
Number of
Firms1
Number
of
Employment
Annual
Payroll
Preliminary
Receipts
334
311
371
17,270
9,717
$1,090,752
$4,304,247
161
144
204
18,962
7,153
$1,575,672
$7,122,743
753
713
808
50,868
30,425
$3,500,909
$21,949,716
1,131
1,059
1,236
51,084
28,209
$3,935,327
$14,584,976
650
Employees
261
234
274
12,197
5,237
$965,146
$3,562,841
750
Employees
750
710
816
33,789
16,453
$2,946,063
$12,926,459
710
664
753
30,275
13,750
$3,918,430
$13,738,113
66
61
74
4,518
3,368
$197,019
$1,796,597
258
253
262
6,300
3,363
$325,620
$2,046,560
423
403
455
20,089
11,413
$1,238,897
$6,894,528
268
252
276
12,462
6,565
$812,364
$5,463,104
216
190
242
18,502
6,516
$1,399,079
$6,156,990
372
339
424
28,980
9,911
$2,030,495
$11,827,046
413
390
484
31,048
13,584
$2,514,090
$14,094,089
750
Employees
1,250
Employees
750
Employees
600
Employees
1,250
Employees
800
Employees
1,250
Employees
1,250
Employees
3-6
Table 3-1: Industry Statistics
Use
Categories
NAICS
335314: Relay and Industrial Control
Manufacturing
335921: Fiber Optic Cable
Manufacturing
335991: Carbon and Graphite Product
Manufacturing
336310: Motor Vehicle Gasoline
Engine and Engine Parts
Manufacturing
336320: Motor Vehicle Electrical and
Electronic Equipment Manufacturing
336330: Motor Vehicle Steering and
Suspension Components (except
Spring) Manufacturing
336340: Motor Vehicle Brake System
Manufacturing
336350: Motor Vehicle Transmission
and Power Train Parts Manufacturing
336360: Motor Vehicle Seating and
Interior Trim Manufacturing
336370: Motor Vehicle Metal
Stamping
336390: Other Motor Vehicle Parts
Manufacturing
336411: Aircraft Manufacturing
336412: Aircraft Engine and Engine
Parts Manufacturing
336413: Other Aircraft Part and
Auxiliary Equipment Manufacturing
336415: Guided Missile and Space
Vehicle Propulsion Unit and
Propulsion Unit Parts Manufacturing
336510: Railroad Rolling Stock
Manufacturing
337127: Institutional Furniture
Profile of Affected Industries
Small
Business
750
Employees
1,000
Employees
900
Employees
1,050
Employees
1,000
Employees
1,000
Employees
1,250
Employees
1,500
Employees
1,500
Employees
1,000
Employees
1,000
Employees
1,500
Employees
1,500
Employees
1,250
Employees
1,250
Employees
1,500
Employees
500
Number of
Firms1
Number
of
Annual
Payroll
Employment
Preliminary
Receipts
795
735
873
34,975
17,276
$2,563,167
$12,488,311
87
77
92
6,974
2,683
$479,625
$3,506,576
120
109
151
8,718
3,421
$709,415
$4,215,876
706
654
758
58,120
16,149
$4,188,464
$39,164,777
565
513
624
62,867
20,363
$3,635,019
$32,932,311
220
192
261
38,255
14,076
$2,087,719
$17,933,893
139
118
179
23,359
9,684
$1,247,985
$13,488,749
390
346
474
73,386
19,121
$4,999,215
$48,004,088
307
273
429
72,273
24,943
$3,839,997
$36,931,706
597
550
757
107,888
53,521
$5,958,475
$43,657,001
1,268
1,145
1,483
148,076
56,090
$8,488,570
$75,669,654
262
236
317
166,716
10,736
$19,959,658
$174,304,589
319
289
410
67,207
16,938
$7,488,721
$44,249,951
750
692
921
103,133
26,327
$8,610,442
$41,415,958
16
7
33
16,635
219
$2,417,490
$9,799,835
153
574
131
554
229
596
29,532
24,464
6,983
18,646
$2,061,548
$1,226,940
$15,265,739
$5,865,029
3-7
Table 3-1: Industry Statistics
Use
Categories
NAICS
Manufacturing
339113: Surgical Appliance and
Supplies Manufacturing
339114: Dental Equipment and
Supplies Manufacturing
339910: Jewelry and Silverware
Manufacturing
339993: Fastener, Button, Needle and
Pin Manufacturing
339999: All Other Miscellaneous
Manufacturing
488190: Other Support Activities for
Air Transportation
811212: Computer and Office
Machine Repair and Maintenance
811310: Commercial and Industrial
Machinery and Equipment (except
Automotive and Electronic) Repair
and Maintenance
331210: Iron and Steel Pipe and Tube
Manufacturing from Purchased Steel
331221: Rolled Steel Shape
Manufacturing
Enclosed
Vapor
Degreasing
331222: Steel Wire Drawing
332721: Precision Turned Product
Manufacturing
332722: Bolt, Nut, Screw, Rivet and
Washer Manufacturing
332911: Industrial Valve
Manufacturing
332912: Fluid Power Valve and Hose
Fitting Manufacturing
332913: Plumbing Fixture Fitting and
Trim Manufacturing
Profile of Affected Industries
Small
Business
Employees
800
Employees
750
Employees
700
Employees
750
Employees
550
Employees
Number of
Firms1
Number
of
Employment
Annual
Payroll
Preliminary
Receipts
1,651
1,592
1,867
86,837
38,259
$8,060,278
$43,237,782
557
544
579
15,040
8,167
$1,107,904
$5,838,867
1,967
1,954
1,986
23,813
16,523
$1,061,332
$8,608,096
103
97
110
3,992
1,595
$211,581
$1,067,437
5,738
5,681
5,755
52,935
41,053
$2,377,517
$14,439,605
$40 Million
3,197
3,052
3,894
85,531
30,184
$6,424,300
$21,511,890
$34 Million
5,068
5,014
5,454
33,730
22,877
$1,713,860
$5,383,666
19,986
19,238
21,814
200,268
101,827
$13,758,532
$47,179,941
180
144
241
23,495
11,670
$1,787,070
$12,548,156
170
147
204
8,126
5,502
$619,227
$6,926,084
210
186
252
14,585
9,090
$831,628
$6,322,048
3,670
3,582
3,791
103,249
81,265
$6,369,088
$22,589,437
650
619
774
37,940
20,892
$2,394,029
$12,956,800
385
337
490
34,425
14,175
$2,465,073
$13,889,921
294
261
363
36,324
12,240
$2,795,840
$12,901,153
94
87
106
8,536
3,854
$592,260
$5,767,598
$12.5
Million
1,000
Employees
1,000
Employees
1,000
Employees
500
Employees
600
Employees
750
Employees
1,000
Employees
1,000
Employees
3-8
Table 3-1: Industry Statistics
Use
Categories
NAICS
332919: Other Metal Valve and Pipe
Fitting Manufacturing
332991: Ball and Roller Bearing
Manufacturing
332992: Small Arms Ammunition
Manufacturing
332993: Ammunition (except Small
Arms) Manufacturing
332994: Small Arms, Ordnance, and
Ordnance Accessories Manufacturing
332996: Fabricated Pipe and Pipe
Fitting Manufacturing
332999: All Other Miscellaneous
Fabricated Metal Product
Manufacturing
331210: Iron and Steel Pipe and Tube
Manufacturing from Purchased Steel
331221: Rolled Steel Shape
Manufacturing
Conveyorized
Vapor
Degreasing
331222: Steel Wire Drawing
331410: Nonferrous Metal (except
Aluminum) Smelting and Refining
331420: Copper Rolling, Drawing,
Extruding, and Alloying
331491: Nonferrous Metal (except
Copper and Aluminum) Rolling,
Drawing and Extruding
331492: Secondary Smelting,
Refining, and Alloying of Nonferrous
Metal (except Copper and
Aluminum)
332111: Iron and Steel Forging
332112: Nonferrous Forging
Profile of Affected Industries
Small
Business
750
Employees
1,250
Employees
1,300
Employees
1,500
Employees
1,000
Employees
550
Employees
750
Employees
1,000
Employees
1,000
Employees
1,000
Employees
1,000
Employees
1,050
Employees
900
Employees
850
Employees
750
Employees
950
Employees
Number of
Firms1
Number
of
Annual
Payroll
Employment
Preliminary
Receipts
217
189
232
13,100
7,569
$880,283
$4,637,735
104
88
162
20,744
3,822
$1,196,188
$7,415,023
148
140
154
13,229
1,960
$788,231
$5,165,006
43
35
53
11,441
625
$1,333,021
$3,207,404
388
377
403
20,333
9,988
$1,509,226
$7,543,375
644
606
712
27,077
17,665
$1,619,065
$7,679,763
3,514
3,458
3,593
66,842
56,916
$3,923,793
$16,669,247
180
144
241
23,495
11,670
$1,787,070
$12,548,156
170
147
204
8,126
5,502
$619,227
$6,926,084
210
186
252
14,585
9,090
$831,628
$6,322,048
129
113
146
7,908
3,738
$628,839
$11,933,969
164
138
247
24,375
10,955
$1,623,662
$26,573,554
227
202
255
15,488
4,606
$1,189,857
$7,987,055
183
166
220
9,305
6,199
$704,523
$8,660,900
324
295
376
19,681
9,072
$1,347,767
$9,162,151
50
39
60
6,753
1,717
$451,852
$3,465,437
3-9
Table 3-1: Industry Statistics
Use
Categories
NAICS
332114: Custom Roll Forming
332117: Powder Metallurgy Part
Manufacturing
332119: Metal Crown, Closure, and
Other Metal Stamping (except
Automotive)
332215: Metal Kitchen Cookware,
Utensil, Cutlery, and Flatware (except
Precious) Manufacturing
332216: Saw Blade and Handtool
Manufacturing
Web Vapor
Degreasing
Batch Cold
Cleaning
332710: Machine Shops
332721: Precision Turned Product
Manufacturing
332722: Bolt, Nut, Screw, Rivet and
Washer Manufacturing
331110: Iron and Steel Mills and
Ferroalloy Manufacturing
324110: Petroleum Refineries
325612: Polish and Other Sanitation
Good Manufacturing
325992: Photographic Film, Paper,
Plate and Chemical Manufacturing
327420: Gypsum Product
Manufacturing
331110: Iron and Steel Mills and
Ferroalloy Manufacturing
331210: Iron and Steel Pipe and Tube
Manufacturing from Purchased Steel
332119: Metal Crown, Closure, and
Other Metal Stamping (except
Automotive)
332721: Precision Turned Product
Profile of Affected Industries
Small
Business
600
Employees
550
Employees
500
Employees
1,000
Employees
750
Employees
500
Employees
500
Employees
600
Employees
1,500
Employees
1,500
Employees
900
Employees
1,500
Employees
1,500
Employees
1,500
Employees
1,000
Employees
500
Employees
500
Number of
Firms1
Number
of
Annual
Payroll
Employment
Preliminary
Receipts
344
308
407
18,050
11,441
$1,080,586
$8,143,768
114
104
134
9,416
5,313
$475,096
$2,788,621
1,288
1,231
1,385
51,465
38,579
$2,828,653
$13,796,615
207
195
213
7,430
3,892
$440,404
$3,878,405
864
845
930
26,889
18,722
$1,622,697
$7,542,339
17,829
17,686
18,100
228,373
209,790
$13,711,558
$43,605,091
3,670
3,582
3,791
103,249
81,265
$6,369,088
$22,589,437
650
619
774
37,940
20,892
$2,394,029
$12,956,800
369
325
522
93,552
17,946
$8,294,778
$109,616,435
70
44
155
63,594
5,381
$9,364,769
$571,414,981
419
396
458
15,779
10,287
$1,366,012
$7,441,941
189
175
204
8,712
2,547
$467,524
$7,965,732
127
116
202
9,618
949
$839,940
$7,120,689
369
325
522
93,552
17,946
$8,294,778
$109,616,435
180
144
241
23,495
11,670
$1,787,070
$12,548,156
1,288
3,670
1,231
3,582
1,385
3,791
51,465
103,249
38,579
81,265
$2,828,653
$6,369,088
$13,796,615
$22,589,437
3-10
Table 3-1: Industry Statistics
Use
Categories
NAICS
Manufacturing
332811: Metal Heat Treating
332812: Metal Coating, Engraving
(except Jewelry and Silverware), and
Allied Services to Manufacturers
332994: Small Arms, Ordnance, and
Ordnance Accessories Manufacturing
332999: All Other Miscellaneous
Fabricated Metal Product
Manufacturing
334511: Search, Detection,
Navigation, Guidance, Aeronautical,
and Nautical System and Instrument
Manufacturing
336111: Automobile Manufacturing
336214: Travel Trailer and Camper
Manufacturing
336412: Aircraft Engine and Engine
Parts Manufacturing
336414: Guided Missile and Space
Vehicle Manufacturing
336415: Guided Missile and Space
Vehicle Propulsion Unit and
Propulsion Unit Parts Manufacturing
336611: Ship Building and Repairing
339991: Gasket, Packing, and Sealing
Device Manufacturing
423510: Metal Service Centers and
Other Metal Merchant Wholesalers
493190: Other Warehousing and
Storage
811219: Other Electronic and
Precision Equipment Repair and
Profile of Affected Industries
Small
Business
Employees
750
Employees
600
Employees
1,000
Employees
750
Employees
1,350
Employees
1,500
Employees
1,000
Employees
1,500
Employees
1,300
Employees
Number of
Firms1
Number
of
Annual
Payroll
Employment
Preliminary
Receipts
617
589
774
21,545
16,349
$1,192,719
$5,808,978
2,338
2,275
2,590
54,860
39,406
$3,097,271
$16,081,694
388
377
403
20,333
9,988
$1,509,226
$7,543,375
3,514
3,458
3,593
66,842
56,916
$3,923,793
$16,669,247
421
379
549
126,636
10,417
$14,333,232
$60,777,797
162
144
175
82,780
2,754
$10,640,547
$124,938,819
601
585
729
54,221
17,342
$3,295,403
$21,162,015
319
289
410
67,207
16,938
$7,488,721
$44,249,951
22
12
42
35,386
679
$6,250,662
$19,339,215
16
7
33
16,635
219
$2,417,490
$9,799,835
503
478
588
99,963
22,304
$7,931,248
$29,829,971
490
449
562
28,575
10,851
$2,345,444
$8,525,934
1,250
Employees
1,300
Employees
600
Employees
200
Employees
$36.5
Million
6,965
6,647
9,421
147,441
81,185
$11,080,171
$238,413,323
1,424
1,001
2,701
60,681
11,392
$4,509,754
$8,469,484
$34 Million
2,787
2,702
3,421
35,369
15,943
$3,221,485
$9,965,767
3-11
Table 3-1: Industry Statistics
Use
Categories
Disposal to
Wastewater
NAICS
Maintenance
812332: Industrial Launderers
562211: Hazardous Waste Treatment
and Disposal
562920: Materials Recovery
Facilities
313210: Broadwoven Fabric Mills
313220: Narrow Fabric Mills and
Schiffli Machine Embroidery
Incorporation
Into
Formulation,
Mixture, or
Reaction
Product
324110: Petroleum Refineries
325211: Plastics Material and Resin
Manufacturing
325412: Pharmaceutical Preparation
Manufacturing
326299: All Other Rubber Product
Manufacturing
327110: Pottery, Ceramics, and
Plumbing Fixture Manufacturing
331110: Iron and Steel Mills and
Ferroalloy Manufacturing
332119: Metal Crown, Closure, and
Other Metal Stamping (except
Automotive)
332216: Saw Blade and Handtool
Manufacturing
332710: Machine Shops
332811: Metal Heat Treating
332812: Metal Coating, Engraving
(except Jewelry and Silverware), and
Allied Services to Manufacturers
332813: Electroplating, Plating,
Polishing, Anodizing and Coloring
Profile of Affected Industries
Small
Business
Number of
Firms1
$47 Million
380
356
1,544
63,811
12,149
$3,225,682
$10,323,507
$47 Million
414
359
873
34,341
3,475
$2,891,985
$10,640,229
$25 Million
1,000
Employees
550
Employees
1,500
Employees
1,250
Employees
1,300
Employees
650
Employees
1,000
Employees
1,500
Employees
1,004
900
1,389
20,279
11,156
$1,182,011
$7,583,229
269
257
295
16,912
10,752
$660,186
$4,707,435
176
173
184
5,624
4,765
$242,031
$1,079,208
70
44
155
63,594
5,381
$9,364,769
$571,414,981
852
768
1,125
75,998
34,018
$8,264,736
$106,880,973
1,007
942
1,280
147,442
52,343
$18,786,983
$184,572,754
565
508
666
29,771
15,816
$1,912,224
$12,089,006
566
556
585
12,508
8,262
$623,944
$2,662,007
369
325
522
93,552
17,946
$8,294,778
$109,616,435
1,288
1,231
1,385
51,465
38,579
$2,828,653
$13,796,615
864
845
930
26,889
18,722
$1,622,697
$7,542,339
17,829
17,686
18,100
228,373
209,790
$13,711,558
$43,605,091
617
589
774
21,545
16,349
$1,192,719
$5,808,978
2,338
2,275
2,590
54,860
39,406
$3,097,271
$16,081,694
2,068
2,032
2,169
51,056
42,608
$2,583,952
$8,564,178
500
Employees
750
Employees
500
Employees
750
Employees
600
Employees
500
Employees
Number
of
Employment
Annual
Payroll
Preliminary
Receipts
3-12
Table 3-1: Industry Statistics
Use
Categories
NAICS
333515: Cutting Tool and Machine
Tool Accessory Manufacturing
333519: Rolling Mill and Other
Metalworking Machinery
Manufacturing
333993: Packaging Machinery
Manufacturing
334513: Instruments and Related
Products Manufacturing for
Measuring, Displaying, and
Controlling Industrial Process
Variables
424690: Other Chemical and Allied
Products Merchant Wholesalers
424950: Paint, Varnish, and Supplies
Merchant Wholesalers
525990: Other Financial Vehicles
541720: Research and Development
in the Social Sciences and
Humanities
551112: Offices of Other Holding
Companies
921110: Other Similar Organizations
(except Business, Professional,
Labor, and Political Organizations)
326211: Tire Manufacturing (except
Retreading)
Mold Release
326212: Tire Retreading
332919: Other Metal Valve and Pipe
Fitting Manufacturing
335220: Major Household Appliance
Manufacturing
336320: Motor Vehicle Electrical and
Electronic Equipment Manufacturing
336390: Other Motor Vehicle Parts
Profile of Affected Industries
Small
Business
500
Employees
500
Employees
600
Employees
750
Employees
175
Employees
150
Employees
$40 Million
$28 Million
$45.5
Million
N/A
1,500
Employees
500
Employees
750
Employees
1,500
Employees
1,000
Employees
1,000
Number of
Firms1
Number
of
Annual
Payroll
Employment
Preliminary
Receipts
1,285
1,253
1,347
26,940
20,611
$1,555,905
$6,244,600
390
363
410
13,635
10,218
$908,332
$4,648,896
471
440
518
20,826
12,357
$1,826,335
$8,329,437
750
710
816
33,789
16,453
$2,946,063
$12,926,459
6,069
5,767
9,418
126,009
50,790
$12,168,548
$234,995,872
1,012
784
957
761
1,916
794
20,851
3,144
8,754
2,266
$1,653,368
$977,221
$22,235,804
$1,642,985
1,732
1,661
1,946
44,665
14,027
$3,725,397
$8,493,643
5,973
4,230
6,431
113,687
36,849
$13,777,640
$48,497,110
N/A
N/A
N/A
N/A
N/A
N/A
N/A
81
63
114
45,509
2,569
$3,320,091
$21,713,321
261
241
373
6,568
3,379
$329,305
$1,756,248
217
189
232
13,100
7,569
$880,283
$4,637,735
127
108
162
42,464
1,968
$2,636,742
$22,969,050
565
1,268
513
1,145
624
1,483
62,867
148,076
20,363
56,090
$3,635,019
$8,488,570
$32,932,311
$75,669,654
3-13
Table 3-1: Industry Statistics
Use
Categories
NAICS
Manufacturing
812332: Industrial Launderers
313230: Nonwoven Fabric Mills
333514: Special Die and Tool, Die
Set, Jig and Fixture Manufacturing
334310: Audio and Video Equipment
Manufacturing
441110: New Car Dealers
441120: Used Car Dealers
Liquid
Cleaners and
Degreasers
451110: Sporting Goods Stores
811111: General Automotive Repair
811112: Automotive Exhaust System
Repair
811113: Automotive Transmission
Repair
811118: Other Automotive
Mechanical and Electrical Repair and
Maintenance
811121: Automotive Body, Paint and
Interior Repair and Maintenance
811122: Automotive Glass
Replacement Shops
811191: Automotive Oil Change and
Lubrication Shops
811198: All Other Automotive Repair
and Maintenance
811211: Consumer Electronics
Repair and Maintenance
811212: Computer and Office
Machine Repair and Maintenance
811213: Communication Equipment
Repair and Maintenance
Profile of Affected Industries
Small
Business
Employees
Number of
Firms1
Number
of
$47 Million
850
Employees
500
Employees
750
Employees
200
Employees
$30.5
Million
$26.5
Million
$9 Million
380
356
1,544
63,811
12,149
$3,225,682
$10,323,507
195
171
230
17,440
7,680
$1,147,607
$8,703,456
2,293
2,240
2,337
44,454
35,069
$2,955,594
$10,620,091
462
452
474
8,902
7,276
$757,699
$3,367,569
17,423
16,559
21,636
1,177,984
750,891
$76,197,101
$1,082,556,180
23,627
22,991
25,512
154,136
94,791
$8,388,749
$121,263,038
16,233
79,072
16,102
78,287
21,422
83,216
240,816
358,905
96,677
307,596
$6,415,905
$17,196,451
$53,651,547
$60,981,693
$9 Million
1,521
1,521
1,575
4,996
4,996
$192,377
$727,761
$9 Million
4,206
4,196
4,320
16,300
15,939
$713,511
$2,637,445
$9 Million
3,027
3,000
3,384
14,620
12,218
$626,191
$2,418,837
$9 Million
$17.5
Million
32,696
32,098
35,387
243,020
180,877
$13,550,246
$45,723,127
4,764
4,744
6,051
29,811
28,419
$1,453,118
$5,114,646
$11 Million
4,467
4,368
8,236
61,501
32,632
$2,060,614
$6,935,359
$10 Million
3,637
3,596
4,007
17,686
10,639
$877,843
$2,854,891
$34 Million
1,746
1,728
1,845
12,636
7,510
$571,485
$1,752,730
$34 Million
5,068
5,014
5,454
33,730
22,877
$1,713,860
$5,383,666
$34 Million
1,738
1,712
2,036
17,740
9,574
$1,488,811
$7,258,425
Employment
Annual
Payroll
Preliminary
Receipts
3-14
Table 3-1: Industry Statistics
Use
Categories
NAICS
811219: Other Electronic and
Precision Equipment Repair and
Maintenance
811310: Commercial and Industrial
Machinery and Equipment (except
Automotive and Electronic) Repair
and Maintenance
811411: Home and Garden
Equipment Repair and Maintenance
811490: Other Personal and
Household Goods Repair and
Maintenance
313230: Nonwoven Fabric Mills
333514: Special Die and Tool, Die
Set, Jig and Fixture Manufacturing
334310: Audio and Video Equipment
Manufacturing
441110: New Car Dealers
441120: Used Car Dealers
Aerosol Spray
Cleaning/
Degreasing
451110: Sporting Goods Stores
811111: General Automotive Repair
811112: Automotive Exhaust System
Repair
811113: Automotive Transmission
Repair
811118: Other Automotive
Mechanical and Electrical Repair and
Maintenance
811121: Automotive Body, Paint and
Interior Repair and Maintenance
811122: Automotive Glass
Replacement Shops
Profile of Affected Industries
Small
Business
Number of
Firms1
Number
of
Employment
Annual
Payroll
Preliminary
Receipts
$34 Million
2,787
2,702
3,421
35,369
15,943
$3,221,485
$9,965,767
$12.5
Million
19,986
19,238
21,814
200,268
101,827
$13,758,532
$47,179,941
$9 Million
1,704
1,698
1,722
4,559
4,317
$143,378
$733,505
$9 Million
850
Employees
500
Employees
750
Employees
200
Employees
$30.5
Million
$26.5
Million
$9 Million
9,938
9,864
10,643
36,437
29,621
$1,401,390
$5,040,083
195
171
230
17,440
7,680
$1,147,607
$8,703,456
2,293
2,240
2,337
44,454
35,069
$2,955,594
$10,620,091
462
452
474
8,902
7,276
$757,699
$3,367,569
17,423
16,559
21,636
1,177,984
750,891
$76,197,101
$1,082,556,180
23,627
22,991
25,512
154,136
94,791
$8,388,749
$121,263,038
16,233
79,072
16,102
78,287
21,422
83,216
240,816
358,905
96,677
307,596
$6,415,905
$17,196,451
$53,651,547
$60,981,693
$9 Million
1,521
1,521
1,575
4,996
4,996
$192,377
$727,761
$9 Million
4,206
4,196
4,320
16,300
15,939
$713,511
$2,637,445
$9 Million
3,027
3,000
3,384
14,620
12,218
$626,191
$2,418,837
$9 Million
$17.5
Million
32,696
32,098
35,387
243,020
180,877
$13,550,246
$45,723,127
4,764
4,744
6,051
29,811
28,419
$1,453,118
$5,114,646
3-15
Table 3-1: Industry Statistics
Use
Categories
Energized
Electrical
Cleaners
Lubricants and
Greases
NAICS
811191: Automotive Oil Change and
Lubrication Shops
811198: All Other Automotive Repair
and Maintenance
811211: Consumer Electronics
Repair and Maintenance
811212: Computer and Office
Machine Repair and Maintenance
811213: Communication Equipment
Repair and Maintenance
811219: Other Electronic and
Precision Equipment Repair and
Maintenance
811310: Commercial and Industrial
Machinery and Equipment (except
Automotive and Electronic) Repair
and Maintenance
811411: Home and Garden
Equipment Repair and Maintenance
811490: Other Personal and
Household Goods Repair and
Maintenance
332321: Metal Window and Door
Manufacturing
332322: Sheet Metal Work
Manufacturing
332323: Ornamental and
Architectural Metal Work
Manufacturing
332410: Power Boiler and Heat
Exchanger Manufacturing
332420: Metal Tank (Heavy Gauge)
Manufacturing
332431: Metal Can Manufacturing
332439: Other Metal Container
Profile of Affected Industries
Small
Business
Number of
Firms1
Number
of
Employment
Annual
Payroll
Preliminary
Receipts
$11 Million
4,467
4,368
8,236
61,501
32,632
$2,060,614
$6,935,359
$10 Million
3,637
3,596
4,007
17,686
10,639
$877,843
$2,854,891
$34 Million
1,746
1,728
1,845
12,636
7,510
$571,485
$1,752,730
$34 Million
5,068
5,014
5,454
33,730
22,877
$1,713,860
$5,383,666
$34 Million
1,738
1,712
2,036
17,740
9,574
$1,488,811
$7,258,425
$34 Million
2,787
2,702
3,421
35,369
15,943
$3,221,485
$9,965,767
$12.5
Million
19,986
19,238
21,814
200,268
101,827
$13,758,532
$47,179,941
$9 Million
1,704
1,698
1,722
4,559
4,317
$143,378
$733,505
$9 Million
750
Employees
500
Employees
9,938
9,864
10,643
36,437
29,621
$1,401,390
$5,040,083
875
831
1,029
52,263
24,857
$3,235,329
$14,858,651
3,752
3,670
4,045
106,102
82,263
$6,775,964
$27,320,163
2,322
2,294
2,366
36,724
29,346
$2,323,837
$9,404,073
268
236
313
22,770
11,080
$1,760,652
$8,281,667
636
601
734
33,637
24,825
$2,276,549
$9,713,135
66
261
50
240
185
295
16,618
10,717
2,081
5,401
$1,721,524
$657,295
$17,878,846
$3,962,430
500
Employees
750
Employees
750
Employees
1,500
Employees
600
3-16
Table 3-1: Industry Statistics
Use
Categories
NAICS
Manufacturing
332510: Hardware Manufacturing
332613: Spring Manufacturing
332618: Other Fabricated Wire
Product Manufacturing
332710: Machine Shops
332721: Precision Turned Product
Manufacturing
332722: Bolt, Nut, Screw, Rivet and
Washer Manufacturing
332911: Industrial Valve
Manufacturing
332912: Fluid Power Valve and Hose
Fitting Manufacturing
332913: Plumbing Fixture Fitting and
Trim Manufacturing
332919: Other Metal Valve and Pipe
Fitting Manufacturing
332991: Ball and Roller Bearing
Manufacturing
332992: Small Arms Ammunition
Manufacturing
332993: Ammunition (except Small
Arms) Manufacturing
332994: Small Arms, Ordnance, and
Ordnance Accessories Manufacturing
332996: Fabricated Pipe and Pipe
Fitting Manufacturing
332999: All Other Miscellaneous
Fabricated Metal Product
Manufacturing
333111: Farm Machinery and
Equipment Manufacturing
Profile of Affected Industries
Small
Business
Employees
750
Employees
600
Employees
500
Employees
500
Employees
500
Employees
600
Employees
750
Employees
1,000
Employees
1,000
Employees
750
Employees
1,250
Employees
1,300
Employees
1,500
Employees
1,000
Employees
550
Employees
750
Employees
1,250
Employees
Number of
Firms1
Number
of
Annual
Payroll
Employment
Preliminary
Receipts
568
541
614
28,626
15,980
$1,803,213
$10,124,195
312
297
375
17,047
10,851
$964,972
$4,715,302
680
647
764
21,457
15,446
$1,142,155
$6,192,053
17,829
17,686
18,100
228,373
209,790
$13,711,558
$43,605,091
3,670
3,582
3,791
103,249
81,265
$6,369,088
$22,589,437
650
619
774
37,940
20,892
$2,394,029
$12,956,800
385
337
490
34,425
14,175
$2,465,073
$13,889,921
294
261
363
36,324
12,240
$2,795,840
$12,901,153
94
87
106
8,536
3,854
$592,260
$5,767,598
217
189
232
13,100
7,569
$880,283
$4,637,735
104
88
162
20,744
3,822
$1,196,188
$7,415,023
148
140
154
13,229
1,960
$788,231
$5,165,006
43
35
53
11,441
625
$1,333,021
$3,207,404
388
377
403
20,333
9,988
$1,509,226
$7,543,375
644
606
712
27,077
17,665
$1,619,065
$7,679,763
3,514
3,458
3,593
66,842
56,916
$3,923,793
$16,669,247
1,054
1,031
1,141
60,554
30,267
$4,279,212
$29,768,753
3-17
Table 3-1: Industry Statistics
Use
Categories
NAICS
333112: Lawn and Garden Tractor
and Home Lawn and Garden
Equipment Manufacturing
333120: Construction Machinery
Manufacturing
333131: Mining Machinery and
Equipment Manufacturing
333132: Oil and Gas Field Machinery
and Equipment Manufacturing
333241: Food Product Machinery
Manufacturing
333242: Semiconductor Machinery
Manufacturing
333243: Sawmill, Woodworking, and
Paper Machinery Manufacturing
333244: Printing Machinery and
Equipment Manufacturing
333249: Other Industrial Machinery
Manufacturing
333314: Optical Instrument and Lens
Manufacturing
333316: Photographic and
Photocopying Equipment
Manufacturing
333318: Other Commercial and
Service Industry Machinery
Manufacturing
333413: Industrial and Commercial
Fan and Blower and Air Purification
Equipment Manufacturing
333414: Heating Equipment (except
Warm Air Furnaces) Manufacturing
333415: Air-Conditioning and Warm
Air Heating Equipment and
Commercial and Industrial
Refrigeration Equipment
Profile of Affected Industries
Small
Business
1,500
Employees
1,250
Employees
900
Employees
1,250
Employees
500
Employees
1,500
Employees
550
Employees
750
Employees
750
Employees
1,000
Employees
Number of
Firms1
Number
of
Employment
Annual
Payroll
Preliminary
Receipts
148
138
166
18,727
5,006
$957,196
$10,458,667
651
616
743
59,684
25,323
$4,342,795
$38,121,362
224
206
262
11,081
5,290
$1,069,933
$4,398,437
502
469
611
33,066
17,568
$2,746,983
$14,853,528
432
411
470
16,175
10,855
$1,395,377
$5,807,266
140
126
157
17,407
5,709
$2,921,043
$8,665,874
337
326
371
12,603
8,155
$1,004,111
$3,956,210
263
257
277
7,215
5,922
$428,085
$2,254,072
1,811
1,742
1,866
53,766
42,042
$3,955,833
$17,341,401
390
363
413
14,658
7,178
$1,463,018
$5,355,644
1,000
Employees
180
170
186
3,777
2,638
$230,350
$1,834,046
1,000
Employees
1,231
1,174
1,316
52,148
31,141
$4,051,583
$21,760,953
401
374
475
23,406
11,429
$1,533,364
$6,717,282
362
337
394
15,660
9,503
$987,929
$5,325,971
705
653
841
89,119
28,842
$5,670,644
$38,502,337
500
Employees
500
Employees
1,250
Employees
3-18
Table 3-1: Industry Statistics
Use
Categories
NAICS
Manufacturing
333511: Industrial Mold
Manufacturing
333514: Special Die and Tool, Die
Set, Jig and Fixture Manufacturing
333515: Cutting Tool and Machine
Tool Accessory Manufacturing
333517: Machine Tool
Manufacturing
333519: Rolling Mill and Other
Metalworking Machinery
Manufacturing
333611: Turbine and Turbine
Generator Set Unit Manufacturing
333612: Speed Changer, Industrial
High-Speed Drive and Gear
Manufacturing
333613: Mechanical Power
Transmission Equipment
Manufacturing
333618: Other Engine Equipment
Manufacturing
333912: Air and Gas Compressor
Manufacturing
333914: Measuring, Dispensing, and
Other Pumping Equipment
Manufacturing
333921: Elevator and Moving
Stairway Manufacturing
333922: Conveyor and Conveying
Equipment Manufacturing
333923: Overhead Traveling Crane,
Hoist and Monorail System
Manufacturing
333924: Industrial Truck, Tractor,
Trailer and Stacker Machinery
Profile of Affected Industries
Small
Business
500
Employees
500
Employees
500
Employees
500
Employees
500
Employees
1,500
Employees
750
Employees
750
Employees
1,500
Employees
1,000
Employees
750
Employees
1,000
Employees
500
Employees
1,250
Employees
900
Employees
Number of
Firms1
Number
of
Employment
Annual
Payroll
Preliminary
Receipts
1,392
1,347
1,442
35,364
27,243
$2,167,065
$7,620,834
2,293
2,240
2,337
44,454
35,069
$2,955,594
$10,620,091
1,285
1,253
1,347
26,940
20,611
$1,555,905
$6,244,600
787
761
818
27,289
18,430
$2,059,888
$9,115,633
390
363
410
13,635
10,218
$908,332
$4,648,896
115
96
165
35,634
6,615
$2,668,163
$15,317,660
194
176
230
11,926
7,046
$713,824
$3,991,472
200
173
236
15,749
6,236
$1,118,467
$5,258,691
261
225
319
35,396
7,100
$2,710,197
$29,543,357
261
238
297
18,362
8,437
$1,655,285
$10,999,105
457
410
576
37,181
11,735
$3,055,087
$19,698,490
166
158
176
8,545
5,015
$644,430
$4,088,596
718
683
779
37,082
24,636
$2,878,058
$11,783,275
268
255
303
19,299
8,356
$1,380,271
$8,109,698
311
287
333
27,533
11,576
$1,894,944
$12,378,097
3-19
Table 3-1: Industry Statistics
Use
Categories
NAICS
Manufacturing
333991: Power-Driven Hand Tool
Manufacturing
333992: Welding and Soldering
Equipment Manufacturing
333993: Packaging Machinery
Manufacturing
333994: Industrial Process Furnace
and Oven Manufacturing
333995: Fluid Power Cylinder and
Actuator Manufacturing
333996: Fluid Power Pump and
Motor Manufacturing
333997: Scale and Balance
Manufacturing
333999: All Other Miscellaneous
General Purpose Machinery
Manufacturing
336111: Automobile Manufacturing
336112: Light Truck and Utility
Vehicle Manufacturing
336120: Heavy Duty Truck
Manufacturing
336211: Motor Vehicle Body
Manufacturing
336212: Truck Trailer Manufacturing
336213: Motor Home Manufacturing
336214: Travel Trailer and Camper
Manufacturing
336310: Motor Vehicle Gasoline
Engine and Engine Parts
Manufacturing
336320: Motor Vehicle Electrical and
Profile of Affected Industries
Small
Business
950
Employees
1,250
Employees
600
Employees
500
Employees
800
Employees
1,250
Employees
700
Employees
700
Employees
1,500
Employees
1,500
Employees
1,500
Employees
1,000
Employees
1,000
Employees
1,250
Employees
1,000
Employees
1,050
Employees
1,000
Number of
Firms1
Number
of
Annual
Payroll
Employment
Preliminary
Receipts
123
110
130
7,246
2,374
$431,216
$4,062,356
341
331
363
16,213
6,225
$1,182,351
$6,664,593
471
440
518
20,826
12,357
$1,826,335
$8,329,437
317
302
344
10,868
7,984
$750,978
$3,045,889
253
221
317
22,529
8,816
$1,675,845
$8,571,075
132
116
157
10,484
4,092
$892,979
$5,175,264
73
68
83
3,707
1,686
$231,853
$1,230,627
1,558
1,467
1,645
55,552
29,610
$4,522,513
$19,556,021
162
144
175
82,780
2,754
$10,640,547
$124,938,819
49
36
66
99,097
470
$9,691,986
$228,961,336
74
59
87
26,487
3,512
$2,137,807
$31,533,599
632
590
733
47,964
20,101
$2,900,334
$17,246,267
379
363
432
37,081
17,618
$2,006,578
$13,190,742
41
36
49
11,943
1,761
$636,169
$6,590,197
601
585
729
54,221
17,342
$3,295,403
$21,162,015
706
565
654
513
758
624
58,120
62,867
16,149
20,363
$4,188,464
$3,635,019
$39,164,777
$32,932,311
3-20
Table 3-1: Industry Statistics
Use
Categories
NAICS
Electronic Equipment Manufacturing
336330: Motor Vehicle Steering and
Suspension Components (except
Spring) Manufacturing
336340: Motor Vehicle Brake System
Manufacturing
336350: Motor Vehicle Transmission
and Power Train Parts Manufacturing
336360: Motor Vehicle Seating and
Interior Trim Manufacturing
336370: Motor Vehicle Metal
Stamping
336390: Other Motor Vehicle Parts
Manufacturing
336411: Aircraft Manufacturing
336412: Aircraft Engine and Engine
Parts Manufacturing
336413: Other Aircraft Part and
Auxiliary Equipment Manufacturing
336414: Guided Missile and Space
Vehicle Manufacturing
336415: Guided Missile and Space
Vehicle Propulsion Unit and
Propulsion Unit Parts Manufacturing
336419: Other Guided Missile and
Space Vehicle Parts and Auxiliary
Equipment Manufacturing
336510: Railroad Rolling Stock
Manufacturing
336611: Ship Building and Repairing
336612: Boat Building
336991: Motorcycle, Bicycle and
Parts Manufacturing
Profile of Affected Industries
Small
Business
Employees
1,000
Employees
1,250
Employees
1,500
Employees
1,500
Employees
1,000
Employees
1,000
Employees
1,500
Employees
1,500
Employees
1,250
Employees
1,300
Employees
1,250
Employees
1,050
Employees
1,500
Employees
1,300
Employees
1,000
Employees
1,050
Employees
Number of
Firms1
Number
of
Annual
Payroll
Employment
Preliminary
Receipts
220
192
261
38,255
14,076
$2,087,719
$17,933,893
139
118
179
23,359
9,684
$1,247,985
$13,488,749
390
346
474
73,386
19,121
$4,999,215
$48,004,088
307
273
429
72,273
24,943
$3,839,997
$36,931,706
597
550
757
107,888
53,521
$5,958,475
$43,657,001
1,268
1,145
1,483
148,076
56,090
$8,488,570
$75,669,654
262
236
317
166,716
10,736
$19,959,658
$174,304,589
319
289
410
67,207
16,938
$7,488,721
$44,249,951
750
692
921
103,133
26,327
$8,610,442
$41,415,958
22
12
42
35,386
679
$6,250,662
$19,339,215
16
7
33
16,635
219
$2,417,490
$9,799,835
33
24
37
3,338
467
$466,089
$1,365,767
153
131
229
29,532
6,983
$2,061,548
$15,265,739
503
478
588
99,963
22,304
$7,931,248
$29,829,971
833
815
875
37,337
23,117
$2,088,802
$12,226,390
423
416
428
9,899
4,644
$533,159
$8,624,700
3-21
Table 3-1: Industry Statistics
Use
Categories
NAICS
336992: Military Armored Vehicle,
Tank and Tank Component
Manufacturing
336999: All Other Transportation
Equipment Manufacturing
337124: Metal Household Furniture
Manufacturing
313210: Broadwoven Fabric Mills
313320: Fabric Coating Mills
321992: Prefabricated Wood
Building Manufacturing
322220: Paper Bag and Coated and
Treated Paper Manufacturing
324199: All Other Petroleum and
Coal Products Manufacturing
325510: Paint and Coating
Manufacturing
Adhesives,
Sealants, Paints
and Coatings
325520: Adhesive Manufacturing
325998: All Other Miscellaneous
Chemical Product and Preparation
Manufacturing
326140: Polystyrene Foam Product
Manufacturing
326150: Urethane and Other Foam
Product (except Polystyrene)
Manufacturing
326211: Tire Manufacturing (except
Retreading)
326212: Tire Retreading
326220: Rubber and Plastics Hoses
and Belting Manufacturing
326299: All Other Rubber Product
Profile of Affected Industries
Small
Business
1,500
Employees
1,000
Employees
950
Employees
1,000
Employees
1,000
Employees
500
Employees
750
Employees
950
Employees
1,000
Employees
550
Employees
650
Employees
1,000
Employees
750
Employees
1,500
Employees
500
Employees
800
Employees
650
Number of
Firms1
Number
of
Employment
Annual
Payroll
Preliminary
Receipts
38
31
53
9,289
1,528
$1,103,726
$7,405,233
390
380
399
13,699
4,508
$869,605
$9,218,532
261
253
272
9,623
4,918
$485,026
$2,431,245
269
257
295
16,912
10,752
$660,186
$4,707,435
152
140
163
6,982
5,498
$452,519
$2,842,231
543
524
635
17,299
9,686
$992,783
$4,746,456
575
509
740
48,193
20,732
$3,701,901
$24,671,717
66
54
84
3,021
1,330
$289,472
$4,549,602
998
964
1,197
39,139
22,907
$2,989,102
$32,768,919
403
346
559
24,231
9,109
$1,966,229
$17,661,519
1,064
982
1,230
36,900
17,820
$3,363,541
$26,088,857
308
281
438
26,968
13,245
$1,496,959
$11,457,424
445
401
653
32,428
16,138
$1,738,902
$13,045,820
81
63
114
45,509
2,569
$3,320,091
$21,713,321
261
241
373
6,568
3,379
$329,305
$1,756,248
196
565
177
508
273
666
19,713
29,771
8,697
15,816
$1,186,280
$1,912,224
$6,330,711
$12,089,006
3-22
Table 3-1: Industry Statistics
Use
Categories
NAICS
Manufacturing
331523: Nonferrous Metal DieCasting Foundries
332321: Metal Window and Door
Manufacturing
332812: Metal Coating, Engraving
(except Jewelry and Silverware), and
Allied Services to Manufacturers
332813: Electroplating, Plating,
Polishing, Anodizing and Coloring
332993: Ammunition (except Small
Arms) Manufacturing
332994: Small Arms, Ordnance, and
Ordnance Accessories Manufacturing
332999: All Other Miscellaneous
Fabricated Metal Product
Manufacturing
333515: Cutting Tool and Machine
Tool Accessory Manufacturing
333914: Measuring, Dispensing, and
Other Pumping Equipment
Manufacturing
334417: Electronic Connector
Manufacturing
334511: Search, Detection,
Navigation, Guidance, Aeronautical,
and Nautical System and Instrument
Manufacturing
335312: Motor and Generator
Manufacturing
335931: Current-Carrying Wiring
Device Manufacturing
336211: Motor Vehicle Body
Manufacturing
336213: Motor Home Manufacturing
Profile of Affected Industries
Small
Business
Employees
700
Employees
750
Employees
600
Employees
500
Employees
1,500
Employees
1,000
Employees
750
Employees
500
Employees
750
Employees
1,000
Employees
1,350
Employees
1,250
Employees
600
Employees
1,000
Employees
1,250
Employees
Number of
Firms1
Number
of
Annual
Payroll
Employment
Preliminary
Receipts
351
321
396
33,674
18,214
$1,627,554
$9,053,959
875
831
1,029
52,263
24,857
$3,235,329
$14,858,651
2,338
2,275
2,590
54,860
39,406
$3,097,271
$16,081,694
2,068
2,032
2,169
51,056
42,608
$2,583,952
$8,564,178
43
35
53
11,441
625
$1,333,021
$3,207,404
388
377
403
20,333
9,988
$1,509,226
$7,543,375
3,514
3,458
3,593
66,842
56,916
$3,923,793
$16,669,247
1,285
1,253
1,347
26,940
20,611
$1,555,905
$6,244,600
457
410
576
37,181
11,735
$3,055,087
$19,698,490
161
144
204
18,962
7,153
$1,575,672
$7,122,743
421
379
549
126,636
10,417
$14,333,232
$60,777,797
372
339
424
28,980
9,911
$2,030,495
$11,827,046
357
320
395
25,444
12,764
$1,597,032
$9,979,913
632
590
733
47,964
20,101
$2,900,334
$17,246,267
41
36
49
11,943
1,761
$636,169
$6,590,197
3-23
Table 3-1: Industry Statistics
Use
Categories
NAICS
336350: Motor Vehicle Transmission
and Power Train Parts Manufacturing
336360: Motor Vehicle Seating and
Interior Trim Manufacturing
336390: Other Motor Vehicle Parts
Manufacturing
336411: Aircraft Manufacturing
336415: Guided Missile and Space
Vehicle Propulsion Unit and
Propulsion Unit Parts Manufacturing
Spot Removers
336611: Ship Building and Repairing
337110: Wood Kitchen Cabinet and
Counter Top Manufacturing
337121: Upholstered Household
Furniture Manufacturing
337122: Nonupholstered Wood
Household Furniture Manufacturing
337211: Wood Office Furniture
Manufacturing
339113: Surgical Appliance and
Supplies Manufacturing
339920: Sporting and Athletic Goods
Manufacturing
339991: Gasket, Packing, and Sealing
Device Manufacturing
481111: Scheduled Passenger Air
Transportation
928110: Other Similar Organizations
(except Business, Professional,
Labor, and Political Organizations)
561740: Carpet and Upholstery
Cleaning Services
812310: Coin-Operated Laundries
and Drycleaners
Profile of Affected Industries
Small
Business
1,500
Employees
1,500
Employees
1,000
Employees
1,500
Employees
Number of
Firms1
Number
of
Annual
Payroll
Employment
Preliminary
Receipts
390
346
474
73,386
19,121
$4,999,215
$48,004,088
307
273
429
72,273
24,943
$3,839,997
$36,931,706
1,268
1,145
1,483
148,076
56,090
$8,488,570
$75,669,654
262
236
317
166,716
10,736
$19,959,658
$174,304,589
16
7
33
16,635
219
$2,417,490
$9,799,835
503
478
588
99,963
22,304
$7,931,248
$29,829,971
5,907
5,886
5,981
91,250
62,626
$4,383,244
$17,107,293
963
941
1,051
65,529
29,353
$2,695,193
$14,414,742
2,024
2,014
2,049
26,512
20,648
$894,231
$4,722,473
307
294
320
13,183
6,426
$566,474
$3,128,959
1,651
1,592
1,867
86,837
38,259
$8,060,278
$43,237,782
1,586
1,567
1,649
39,326
27,983
$2,215,681
$12,298,212
490
449
562
28,575
10,851
$2,345,444
$8,525,934
306
274
1,872
421,206
12,988
$42,177,184
$205,880,657
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
$8.5 Million
7,306
7,259
7,501
36,361
33,045
$1,393,222
$4,085,480
$13 Million
9,725
9,690
10,798
40,419
36,847
$962,688
$5,174,885
1,250
Employees
1,300
Employees
750
Employees
1,000
Employees
750
Employees
1,000
Employees
800
Employees
750
Employees
600
Employees
1,500
Employees
3-24
Table 3-1: Industry Statistics
Use
Categories
Film Cleaner
Small
Business
NAICS
812320: Drycleaning and Laundry
Services (except Coin-Operated)
512110: Motion Picture and Video
Production
Number of
Firms1
Number
of
Employment
Annual
Payroll
Preliminary
Receipts
$8 Million
18,087
17,953
20,643
131,543
113,492
$2,281,059
$9,510,408
$40 Million
13,850
13,680
14,394
135,557
45,274
$13,833,359
$83,599,451
Sources: U.S. Census Bureau 2021; U.S. Census Bureau 2023; U.S. Bureau of Economic Analysis 2023c; SBA 2023
Table 3-2: Small Business Determinations of Identified Affected Parent Companies, by Use Category
Use Category
Laboratory Use
Manufacturing
Company Name
611310: Colleges, Universities, and Professional Schools
$217.41 M
5,000
$34.5 Million
No
561990: All Other Support Services
$407.75 K
9
$16.5 Million
Small
N/A
N/A
2,768,886
N/A
N/A
TRC Companies, Inc.
561320: Temporary Help Services
$740 M
4,865
$34 Million
No
California State
University System
611310: Colleges, Universities, and Professional Schools
$2.84 B
45,000
$34.5 Million
No
Chevron Corporation
324110: Petroleum Refineries
$162.47 B
42,595
211120: Crude Petroleum Extraction
$26.31 B
11,678
$186.07 M
175
175 Employees
Small
$109.45 B
115,124
100 Employees
No
$11.77 M
15
150 Employees
Small
$135 M
53
175 Employees
Small
Occidental Petroleum
Corporation
Allchem Industries
Holding Corp
Itochu Corporation
Import/Repackage
Small
Business
Status
Revenue
New Mexico State
University
International Textile
Group
Government Of the
United States
First Continental
International Inc.
Greenchem Industries
LLC
Profile of Affected Industries
424690: Other Chemical and Allied Products Merchant
Wholesalers
423990: Other Miscellaneous Durable Goods Merchant
Wholesalers
424950: Paint, Varnish, and Supplies Merchant
Wholesalers
424690: Other Chemical and Allied Products Merchant
Wholesalers
Employees
SBA Small
Business
Threshold
NAICS Description
1,500
Employees
1,250
Employees
No
No
3-25
Table 3-2: Small Business Determinations of Identified Affected Parent Companies, by Use Category
Use Category
Company Name
Superior Industrial
Solutions, Inc.
Chemical Solvents Inc.
Norman, Fox & Co.
Univar Solutions Inc.
Battery and Synthetic
Paper Processing Aid
HFC Manufacture
Intermediate in HCl
Production
Asahi Kasei
Corporation
Microporus
NAICS Description
424690: Other Chemical and Allied Products Merchant
Wholesalers
424690: Other Chemical and Allied Products Merchant
Wholesalers
424690: Other Chemical and Allied Products Merchant
Wholesalers
424690: Other Chemical and Allied Products Merchant
Wholesalers
325998: All Other Miscellaneous Chemical Product and
Preparation Manufacturing
326291: Rubber Product Manufacturing for Mechanical
Use
Revenue
Employees
SBA Small
Business
Threshold
Small
Business
Status
$290.01 M
300
175 Employees
No
$99.45 M
110
175 Employees
Small
$44.88 M
63
175 Employees
Small
$9.54 B
9,450
175 Employees
No
$21.91 B
46,751
650 Employees
No
$45.49 M
153
750 Employees
Small
PPG
325510: Paint and Coating Manufacturing
$16.80 B
49,300
1,000
Employees
No
Kaluz, S.A. De C.V.
551112: Offices of Other Holding Companies
$7.60 B
30,000
$45.5 Million
No
Arkema
551112: Offices of Other Holding Companies
$134.84 M
4,500
$45.5 Million
No
Formosa Plastics Corp
424690: Other Chemical and Allied Products Merchant
Wholesalers
$9.79 B
7,436
175 Employees
No
Westlake Corporation
325211: Plastics Material and Resin Manufacturing
$11.78 B
14,550
Occidental Petroleum
Corporation
211120: Crude Petroleum Extraction
$26.31 B
11,678
Olin Corp
325180: Other Basic Inorganic Chemical Manufacturing
$8.91 B
8,000
325412: Pharmaceutical Preparation Manufacturing
$52.14 B
100,802
325199: All Other Basic Organic Chemical
Manufacturing
$18.47 B
24,069
Dow Inc.
325211: Plastics Material and Resin Manufacturing
$54.97 B
35,700
Nippon Shokubai Co.,
Ltd.
325199: All Other Basic Organic Chemical
Manufacturing
$3.29 B
4,526
Bayer
Aktiengesellschaft
Shin-Etsu Chemical
Co., Ltd.
Profile of Affected Industries
1,250
Employees
1,250
Employees
1,000
Employees
1,300
Employees
1,250
Employees
1,250
Employees
1,250
Employees
No
No
No
No
No
No
No
3-26
Table 3-2: Small Business Determinations of Identified Affected Parent Companies, by Use Category
Use Category
Fluoroelastomer
Manufacture
Vapor Degreasing
Company Name
NAICS Description
Revenue
Employees
SBA Small
Business
Threshold
Small
Business
Status
Ameresco, Inc.
238210: Electrical Contractors and Other Wiring
Installation Contractors
$1.22 B
1,272
$19 Million
No
Republic Services, Inc.
562212: Solid Waste Landfill
$11.30 B
35,000
$47 Million
No
Saudi Arabian Oil
Company
The Chemours
Company
213112: Support Activities for Oil and Gas Operations
$400.47 B
68,000
$47 Million
No
325998: All Other Miscellaneous Chemical Product and
Preparation Manufacturing
$6.35 B
6,400
650 Employees
No
Poet, LLC
325193: Ethyl Alcohol Manufacturing
$950 M
350
Exxonmobil Corp
324110: Petroleum Refineries
$285.64 B
63,000
Saint Paul Park
Refining Co LLC
N/A
N/A
N/A
Phillips 66 Company
324110: Petroleum Refineries
$114.85 B
14,000
HF Sinclair
Corporation
324110: Petroleum Refineries
$21.32 B
13,407
Andersen Corp
321911: Wood Window and Door Manufacturing
$1.78 B
10,000
336390: Other Motor Vehicle Parts Manufacturing
$3.47 B
14,300
336411: Aircraft Manufacturing
$3.4 B
14,000
332812: Metal Coating, Engraving (except Jewelry and
Silverware), and Allied Services to Manufacturers
$430.0 K
3
600 Employees
Small
335921: Fiber Optic Cable Manufacturing
$355.0 M
3,800
1,000
Employees
No
$90.0 M
1,200
750 Employees
No
$103.0 M
270
500 Employees
Small
Gates Industrial
Corporation PLC
Spirit Aerosystems
Holdings, Inc.
Kopacz Industrial
Painting Inc
General Cable
Technologies
Corporation
Acorn Engineering
Company
Valence Surface
Technologies LLC
Profile of Affected Industries
332999: All Other Miscellaneous Fabricated Metal
Product Manufacturing
332813: Electroplating, Plating, Polishing, Anodizing,
and Coloring
1,000
Employees
1,500
Employees
N/A
1,500
Employees
1,500
Employees
1,000
Employees
1,000
Employees
1,500
Employees
Small
No
N/A
No
No
No
No
No
3-27
Table 3-2: Small Business Determinations of Identified Affected Parent Companies, by Use Category
Use Category
Company Name
Integer Holdings
Corporation
Allied Motion
Technologies Inc.
Watlow Electric
Manufacturing
Company
Paint Work,
Incorporated
Superior Technology
Corp.
Advanced Heat Treat
Corp.
East - Lind Heat Treat,
Inc.
Castle Metal Finishing
Corp.
Streamwood Plating Co
NAICS Description
Revenue
Employees
SBA Small
Business
Threshold
Small
Business
Status
332119: Metal Crown, Closure, and Other Metal
Stamping (except Automotive)
$1.0 B
7,500
500 Employees
No
335312: Motor and Generator Manufacturing
$366.0 M
1,600
1,250
Employees
No
$586.0 M
2,000
750 Employees
No
$600.0 K
10
600 Employees
Small
$14.0 M
120
500 Employees
Small
332811: Metal Heat Treating
$12.0 M
90
750 Employees
Small
332811: Metal Heat Treating
$5.6 M
36
750 Employees
Small
$2.5 M
24
500 Employees
Small
$724.0 K
9
500 Employees
Small
334513: Instruments and Related Products Manufacturing
for Measuring, Displaying, and Controlling Industrial
Process Variables
332812: Metal Coating, Engraving (except Jewelry and
Silverware), and Allied Services to Manufacturers
332813: Electroplating, Plating, Polishing, Anodizing,
and Coloring
332813: Electroplating, Plating, Polishing, Anodizing,
and Coloring
332813: Electroplating, Plating, Polishing, Anodizing,
and Coloring
Ametek, Inc.
335312: Motor and Generator Manufacturing
$4.5 B
16,000
1,250
Employees
No
Godfrey & Wing Inc.
339999: All Other Miscellaneous Manufacturing
$19.0 M
50
550 Employees
Small
336412: Aircraft Engine and Engine Parts Manufacturing
$79.0 B
174,000
1,500
Employees
No
335991: Carbon and Graphite Product Manufacturing
$1.1 B
40
900 Employees
Small
Carpenter Tech
331110: Iron and Steel Mills and Ferroalloy
Manufacturing
$1.8 B
4,100
The Boeing Company
336411: Aircraft Manufacturing
$58.0 B
141,000
Chattanooga Armature
Works, Inc.
811310: Commercial and Industrial Machinery and
Equipment (except Automotive and Electronic) Repair
and Maintenance
$4.3 M
40
General Electric
Company
Morgan Advanced
Materials PLC
Profile of Affected Industries
1,500
Employees
1,500
Employees
$12.5 Million
No
No
Small
3-28
Table 3-2: Small Business Determinations of Identified Affected Parent Companies, by Use Category
Use Category
Company Name
Tubacex, SA
Energizer Holdings Inc.
Accurate Forming, LLC
MPC Plating Inc.
NAICS Description
331210: Iron and Steel Pipe and Tube Manufacturing
from Purchased Steel
332215: Metal Kitchen Cookware, Utensil, Cutlery, and
Flatware (except Precious) Manufacturing
332119: Metal Crown, Closure, and Other Metal
Stamping (except Automotive)
332813: Electroplating, Plating, Polishing, Anodizing,
and Coloring
Revenue
Employees
SBA Small
Business
Threshold
1,000
Employees
1,000
Employees
Small
Business
Status
$18.0 M
22
$3.1 B
5,500
$9.1 M
47
500 Employees
Small
$12.5 M
110
500 Employees
Small
$9.6 M
52
650 Employees
Small
Small
No
Mullins Rubber
Products, Inc.
326299: All Other Rubber Product Manufacturing
Droitcour Company
332721: Precision Turned Product Manufacturing
$8.1 M
80
500 Employees
Small
ATW Companies, Inc.
333517: Machine Tool Manufacturing
$87.5 M
390
500 Employees
Small
Whittet-Higgins
Company
332722: Bolt, Nut, Screw, Rivet, and Washer
Manufacturing
423940: Jewelry, Watch, Precious Stone, and Precious
Metal Merchant Wholesalers
423510: Metal Service Centers and Other Metal
Merchant Wholesalers
$7.2 M
50
600 Employees
Small
$4.0 M
35
125 Employees
Small
$10.4 M
40
200 Employees
Small
$54.2 M
300
1,250
Employees
Small
$8.0 M
24
500 Employees
Small
$45.1 M
155
500 Employees
Small
$66.6 M
372
500 Employees
Small
$862.0 K
6
500 Employees
Small
$31.6 M
110
500 Employees
Small
$2.7 M
23
500 Employees
Small
Mel-Co-Ed, Inc.
Parts Cleaning
Technologies, LLC
McMillan Electric
Company
Milwaukee Plating
Company
E. C. Styberg
Engineering Company
Viking Drill & Tool,
Inc.
FJC Services, LLC
159585 Canada Inc
Helical Line Products
Co
Profile of Affected Industries
335312: Motor and Generator Manufacturing
332813: Electroplating, Plating, Polishing, Anodizing,
and Coloring
332119: Metal Crown, Closure, and Other Metal
Stamping (except Automotive)
333515: Cutting Tool and Machine Tool Accessory
Manufacturing
332813: Electroplating, Plating, Polishing, Anodizing,
and Coloring
333515: Cutting Tool and Machine Tool Accessory
Manufacturing
332618: Other Fabricated Wire Product Manufacturing
3-29
Table 3-2: Small Business Determinations of Identified Affected Parent Companies, by Use Category
Use Category
Company Name
Great Lakes Friction
Products, Inc.
Model Finishing Co.,
Inc.
Genesis Marketing
Group, Ltd.
Plymouth Tube
Company
Amilan Distributors
Colonial Coatings, Inc.
BRC Rubber &
Plastics, Inc.
Rock River Arms, Inc.
Berteau-Lowell Plating
Works, Inc.
Kangas Enameling, Inc.
D & B Metal Finishing
Preci-Manufacturing
Inc
Craftsman Plating &
Tinning Corporation
Able Electropolishing
Company, Inc.
Steel Partners Holdings
L.P.
Hu Friedy
Manufacturing Co, Inc
Clybourn Metal
Finishing Co
Profile of Affected Industries
NAICS Description
Revenue
Employees
SBA Small
Business
Threshold
Small
Business
Status
336340: Motor Vehicle Brake System Manufacturing
$8.7 M
27
1,250
Employees
Small
332999: All Other Miscellaneous Fabricated Metal
Product Manufacturing
$1.8 M
15
750 Employees
Small
332312: Fabricated Structural Metal Manufacturing
$1.6 M
14
500 Employees
Small
$188.1 M
700
1,000
Employees
Small
$2.9 M
7
600 Employees
Small
$8.4 M
45
500 Employees
Small
$95.9 M
500
650 Employees
Small
$10.6 M
60
1,000
Employees
Small
$2.2 M
33
500 Employees
Small
$570.0 K
6
700 Employees
Small
$292.0 K
6
500 Employees
Small
$10.3 M
92
1,250
Employees
Small
$4.9 M
48
500 Employees
Small
$16.4 M
150
500 Employees
Small
$1.52 B
4,300
600 Employees
No
339114: Dental Equipment and Supplies Manufacturing
$61.5 M
500
750 Employees
Small
332813: Electroplating, Plating, Polishing, Anodizing,
and Coloring
$520.0 K
13
500 Employees
Small
331210: Iron and Steel Pipe and Tube Manufacturing
from Purchased Steel
332812: Metal Coating, Engraving (except Jewelry and
Silverware), and Allied Services to Manufacturers
332813: Electroplating, Plating, Polishing, Anodizing,
and Coloring
326299: All Other Rubber Product Manufacturing
332994: Small Arms, Ordnance, and Ordnance
Accessories Manufacturing
332813: Electroplating, Plating, Polishing, Anodizing,
and Coloring
339910: Jewelry and Silverware Manufacturing
332813: Electroplating, Plating, Polishing, Anodizing,
and Coloring
336413: Other Aircraft Parts and Auxiliary Equipment
Manufacturing
332813: Electroplating, Plating, Polishing, Anodizing,
and Coloring
332813: Electroplating, Plating, Polishing, Anodizing,
and Coloring
332812: Metal Coating, Engraving (except Jewelry and
Silverware), and Allied Services to Manufacturers
3-30
Table 3-2: Small Business Determinations of Identified Affected Parent Companies, by Use Category
Use Category
Company Name
Light Logic LLC
Dial Tool Industries,
Inc.
MJ Celco International,
LLC
NN, Inc.
Dixon Valve Coupling
Co
Stella
Vermögensverwaltungs
GmbH
Autotrol Corporation
Chem Processing, Inc.
Milton Industries, Inc.
NAICS Description
Revenue
Employees
SBA Small
Business
Threshold
Small
Business
Status
335121: Residential Electric Lighting Fixture
Manufacturing
$438.4 M
8
750 Employees
Small
332111: Iron and Steel Forging
$19.2 M
100
750 Employees
Small
$1.1 M
13
500 Employees
Small
$477.6 M
3,172
500 Employees
No
332721: Precision Turned Product Manufacturing
$5.1 M
50
500 Employees
Small
332999: All Other Miscellaneous Fabricated Metal
Product Manufacturing
$1.2 M
9
750 Employees
Small
335312: Motor and Generator Manufacturing
$16.2 M
100
1,250
Employees
Small
$12.8 M
75
500 Employees
Small
$22.2 M
120
1,000
Employees
Small
332119: Metal Crown, Closure, and Other Metal
Stamping (except Automotive)
332119: Metal Crown, Closure, and Other Metal
Stamping (except Automotive)
332813: Electroplating, Plating, Polishing, Anodizing,
and Coloring
332912: Fluid Power Valve and Hose Fitting
Manufacturing
General Machinery &
Manufacturing Co
332721: Precision Turned Product Manufacturing
$4.0 M
15
500 Employees
Small
Union Special, LLC
333249: Other Industrial Machinery Manufacturing
$22.7 M
110
750 Employees
Small
Plano Metal Specialties,
Inc.
Lenzing
Aktiengesellschaft
American/Jebco
Corporation
TWR Service
Corporation
332813: Electroplating, Plating, Polishing, Anodizing,
and Coloring
325220: Artificial and Synthetic Fibers and Filaments
Manufacturing
332722: Bolt, Nut, Screw, Rivet, and Washer
Manufacturing
332813: Electroplating, Plating, Polishing, Anodizing,
and Coloring
$950.0 K
10
500 Employees
Small
$2.6 B
7,614
1,050
Employees
No
$21.1 M
130
600 Employees
Small
$2.1 M
14
500 Employees
Small
Smalley Steel Ring Co.
332618: Other Fabricated Wire Product Manufacturing
$86.8 M
450
500 Employees
Small
Smalley Steel Ring Co.
332618: Other Fabricated Wire Product Manufacturing
$86.8 M
450
500 Employees
Small
Profile of Affected Industries
3-31
Table 3-2: Small Business Determinations of Identified Affected Parent Companies, by Use Category
Use Category
Company Name
Bycap, Inc.
Universal Coating, Inc.
Ohio Screw Products,
Inc.
The Nordam Group
LLC
Spirit Aerosystems Inc
NAICS Description
334416: Capacitor, Resistor, Coil, Transformer, and
Other Inductor Manufacturing
332812: Metal Coating, Engraving (except Jewelry and
Silverware), and Allied Services to Manufacturers
332721: Precision Turned Product Manufacturing
336413: Other Aircraft Parts and Auxiliary Equipment
Manufacturing
336413: Other Aircraft Parts and Auxiliary Equipment
Manufacturing
Revenue
Employees
SBA Small
Business
Threshold
Small
Business
Status
$2.1 M
20
550 Employees
Small
$9.3 M
55
600 Employees
Small
$13.4 M
75
500 Employees
Small
$500.0 K
2,413
$8.6 M
6
1,250
Employees
1,250
Employees
No
Small
U S Ring Binder, L.P.
323111: Commercial Printing (except Screen and Books)
$4.3 M
30
650 Employees
Small
Textron Inc.
336411: Aircraft Manufacturing
$12.4 B
33,000
1,500
Employees
No
Marquette Tool and Die
Company
333511: Industrial Mold Manufacturing
$4.8 M
35
500 Employees
Small
$5.3 M
2
500 Employees
Small
$447.6 K
4
750 Employees
Small
$50.0 M
230
336412: Aircraft Engine and Engine Parts Manufacturing
$15.4 B
51,700
332813: Electroplating, Plating, Polishing, Anodizing,
and Coloring
$6.0 M
48
3p Acquisition Inc
Precision Micro
Component
Globe Engineering Co.,
Inc
Rolls-Royce Holdings
PLC
Anaplex Corporation
332813: Electroplating, Plating, Polishing, Anodizing,
and Coloring
332410: Power Boiler and Heat Exchanger
Manufacturing
336413: Other Aircraft Parts and Auxiliary Equipment
Manufacturing
1,250
Employees
1,500
Employees
500 Employees
Small
No
Small
Ironform Holdings Co.
332996: Fabricated Pipe and Pipe Fitting Manufacturing
$121.5 M
289
550 Employees
Small
Cheniere Energy, Inc.
493110: General Warehousing and Storage
$15.9 B
1,550
$34 Million
No
Mercury Products Corp.
332996: Fabricated Pipe and Pipe Fitting Manufacturing
$104.7 M
255
550 Employees
Small
Melrose Industries PLC
336413: Other Aircraft Parts and Auxiliary Equipment
Manufacturing
$11.3 B
Not provided
1,250
Employees
No
Morse Rubber, L.L.C.
326299: All Other Rubber Product Manufacturing
$4.0 M
30
650 Employees
Small
Profile of Affected Industries
3-32
Table 3-2: Small Business Determinations of Identified Affected Parent Companies, by Use Category
Use Category
Incorp. into.: Mold
Release
Incorp. into.: Liquid
Cleaners and
Degreasers
Incorp. into.: Aerosol
Spray
Cleaning/Degreasing
Incorp. into.:
Energized Electrical
Cleaners
Company Name
The Sherwin Williams
Company
Plastic Process
Equipment, Inc.
NAICS Description
Revenue
Employees
SBA Small
Business
Threshold
Small
Business
Status
325510: Paint and Coating Manufacturing
$19.94 B
61,031
1,000
Employees
No
333249: Other Industrial Machinery Manufacturing
$10.63 M
28
750 Employees
Small
IMS Company
423830: Industrial Machinery and Equipment Merchant
Wholesalers
$25.10 M
60
100 Employees
Small
NM Z Parent Inc.
525990: Other Financial Vehicles
$980 M
2,300
$40 Million
No
Delta Foremost
Chemical Corporation
American Industries
Inc.
325612: Polish and Other Sanitation Good Manufacturing
$34.87 M
150
900 Employees
Small
424690: Other Chemical and Allied Products Merchant
Wholesalers
$3.74 M
14
175 Employees
Small
ITW Brands
333993: Packaging Machinery Manufacturing
$14.46 B
45,000
600 Employees
No
Berryman
424690: Other Chemical and Allied Products Merchant
Wholesalers
$147.70 M
35
175 Employees
Small
Brownells
423710: Hardware Merchant Wholesalers
$187.15 M
241
150 Employees
No
NM Z Parent Inc.
525990: Other Financial Vehicles
$980 M
2,300
$40 Million
No
Nu-Calgon
424690: Other Chemical and Allied Products Merchant
Wholesalers
$72.90 M
52
175 Employees
Small
325612: Polish and Other Sanitation Good Manufacturing
$6.22 M
40
900 Employees
Small
333995: Fluid Power Cylinder and Actuator
Manufacturing
$14.35 B
54,640
800 Employees
No
325120: Industrial Gas Manufacturing
$770 M
350
1,200
Employees
Small
Pro Chem
424690: Other Chemical and Allied Products Merchant
Wholesalers
$24.48 M
100
175 Employees
Small
The Sherwin Williams
Company
325510: Paint and Coating Manufacturing
$19.94 B
61,031
1,000
Employees
No
Pro Chem
424690: Other Chemical and Allied Products Merchant
Wholesalers
$24.48 M
100
175 Employees
Small
The Sherwin Williams
Company
325510: Paint and Coating Manufacturing
$19.94 B
61,031
1,000
Employees
No
Omega Industrial
Supply, Inc.
Parker Hannifin
Corporation
Plz Aeroscience
Corporation
Profile of Affected Industries
3-33
Table 3-2: Small Business Determinations of Identified Affected Parent Companies, by Use Category
Use Category
Company Name
Berwind Corporation
Incorp. into.:
Lubricants and
Greases
Incorp. into.: Dry
Cleaning and Spot
Removers
Employees
SBA Small
Business
Threshold
Small
Business
Status
4,500
$34 Million
No
$39.34 M
150
175 Employees
Small
$7.46 M
15
175 Employees
No
325120: Industrial Gas Manufacturing
$770 M
350
1,200
Employees
Small
525990: Other Financial Vehicles
$2.98 B
1,490
$40 Million
No
Newstar Adhesives Inc
N/A
N/A
N/A
N/A
N/A
Parker Hannifin
Corporation
Scigrip Smarter
Adhesive Solutions
Stahlgruber Otto
Gruber Ag
Steel Partners Holdings
L.P.
Midwest Motor Supply
Company
333995: Fluid Power Cylinder and Actuator
Manufacturing
$14.35 B
54,640
800 Employees
No
561499: All Other Business Support Services
$7.95 M
35
$21.5 Million
Small
551112: Offices of Other Holding Companies
$1.06 B
6,897
$45.5 Million
No
332812: Metal Coating, Engraving (except Jewelry and
Silverware), and Allied Services to Manufacturers
$1.52 B
4,300
600 Employees
No
339993: Fastener, Button, Needle, and Pin Manufacturing
$129.40 M
670
750 Employees
Small
K-Chem, Inc
423840: Industrial Supplies Merchant Wholesalers
$4.49 M
11
125 Employees
Small
325180: Other Basic Inorganic Chemical Manufacturing
$7.48 M
35
1,000
Employees
Small
325120: Industrial Gas Manufacturing
$770 M
350
1,200
Employees
Small
424690: Other Chemical and Allied Products Merchant
Wholesalers
$36 M
172
175 Employees
Small
325612: Polish and Other Sanitation Good Manufacturing
$3.10 M
17
900 Employees
Small
424690: Other Chemical and Allied Products Merchant
Wholesalers
$39.34 M
150
175 Employees
Small
Brodi Specialty
Products
Plz Aeroscience
Corporation
Centerbridge Partners,
L.P.
Mid-American
Research Chemical
Corp.
Plz Aeroscience
Corporation
Questspecialty
Corporation
A.L. Wilson Chemical
Co.
R.R. Street & Co. Inc.
Profile of Affected Industries
531190: Lessors of Other Real Estate Property
Revenue
$1.87 B
R.R. Street & Co. Inc.
Incorp. into.:
Adhesives, Sealants,
Paints, and Coatings
NAICS Description
424690: Other Chemical and Allied Products Merchant
Wholesalers
424690: Other Chemical and Allied Products Merchant
Wholesalers
3-34
Table 3-2: Small Business Determinations of Identified Affected Parent Companies, by Use Category
Use Category
Company Name
NAICS Description
Revenue
Employees
SBA Small
Business
Threshold
Small
Business
Status
1An
establishment is a single physical location at which business is conducted or services or industrial operations are performed. A firm is a business organization consisting of
one or more domestic establishments in the same geographic area and industry that were specified under common ownership or control. Therefore, a firm can own multiple
establishments.
Sources: Companies using TCE were identified using 2020 CDR data (EPA 2020j), 2020 TRI data (EPA 2022b), 2017 NEI data (EPA 2020a), and EPA’s risk evaluation (EPA
2020e). Companies producing TCE products were identified as described in Chapter 4. Company information was obtained from Dun and Bradstreet Hoovers database (Dun &
Bradstreet 2022), and the Experian Business Target IQ database (Experian 2023). The small business determinations were made using SBA’s small business thresholds (SBA
2023).
Profile of Affected Industries
3-35
4. Products Formulated with TCE
This chapter presents the results from EPA’s search to identify products that might contain TCE and
discusses some of the implications of the prohibition of TCE use in these products. The search was
conducted using the Consumer Product Information Database (CPID), at www.whatsinproducts.com,
retail websites that sell related products (e.g., www.grainger.com), and the websites of the
manufacturers with products that were identified from the CPID, retailer websites, and EPA risk
evaluation support documents (EPA 2017c, EPA 2017d, EPA 2017e, EPA 2017f, EPA 2017g).
EPA expects that the manufacturers who already have alternative products would respond to a
regulatory option that prohibits or restricts TCE use by discontinuing the TCE product without
replacing it with a new product line. 7 Thus, such businesses would not be expected to incur any direct
compliance costs. Businesses may incur indirect costs through reduced sales, but these are likely to at
least be partially offset by some customers shifting to another one of their products. Since any
reduced sales they experience are likely to be a competitor’s gain, the net change in producer surplus
across all producers is uncertain. Similarly, the net effects on upstream and downstream producers,
distributors, and retailers are likely to be close to zero as purchasers shift to an alternative to the
prohibited product.
6F
By eliminating some of the choices that purchasers have available to them, there is likely to be a
consumer surplus welfare loss that would result from regulatory options that restrict or limit these
products. However, the specific value cannot be estimated without knowing the quantity of the
prohibited product that is sold and the elasticity of demand for the specific product that would be
prohibited. However, when a wide variety of close substitutes are available, the demand for a specific
product is likely to be elastic (i.e., a relatively small increase in price is likely to result in customers
shifting demand to different products instead). Thus, although EPA is unable to quantify the
consumer surplus loss that would result from a regulatory option prohibiting TCE, the welfare loss is
likely to be small, because products with similar prices and efficacy are widely available.
Table 4-1 shows the companies and types of products containing TCE by product type.
7
EPA’s reformulation cost estimates, presented in section 7.6, assume that reformulation costs are incurred for
all existing TCE products, including formulators with existing TCE-free alternatives.
Products Formulated with TCE
4-1
Table 4-1: Companies and Types of Products Containing Trichloroethylene by Product Type
Product Type
Parent Company Name
The Sherwin Williams
Company
Product Name
MR™351 Mold Cleaner Aerosol
Budget Paintable Mold Release (BPR-016)
30-35
Yes
Carnauba Wax Paintable Mold Release (CW-165)
70-80
Yes
95-100
Yes
>90
Yes
85-95
Yes
Economic Heavy Duty Non-Flammable Mold Cleaner (EMC-18)
Multi-Visc Silicone Spray Mold Release
Liquid Cleaners and
Degreasers
Aerosol Spray
Cleaning/Degreasing
46.5
65%
Yes
Non-Flammable Silicone Spray Mold Release (NS-125)
50-60
Yes
Econo-Spray Paintable Mold Release (EP-161)
45-50
Yes
Super Lecithin Paintable Mold Release (L-175)
45-50
Yes
Non-Flammable Paintable Mist Mold Release (NP-121)
50-60
Yes
45
Yes
White 2000 Non-Flammable Mold Cleaner
85-98
Yes
Non-Flammable Economy Mold Cleaner
85-97
Yes
90-<100
Yes
Neutral Oil Paintable Spray Mold Release (NOP-169)
IMS Company
Has Existing
TrichloroethyleneFree Alternative
Yes
Economic Heavy-Duty Mold Cleaner (EMC-55)
Mold Release
%
Average
68.9
Heavy Duty Mold Cleaner (DMC-20)
Plastic Process Equipment,
Inc.
% Trichloroethylene
NM Z Parent Inc.
Top Solv
Delta Foremost Chemical
Corporation
Foremost 582 Safety Solvent II
Proprietary
Foremost 510 Carburetor Cleaner
Proprietary
Yes
American Industries Inc.
Blast Away
Yes
ITW Brands
LPS HDX (Aerosol)
70-100
90-100
Yes
Berryman
Electric Motor Cleaner
>90
Yes
Brownells
TCE Degreaser
Not provided
Parts Cleaner
Not provided
Yes
A07310 ZEP AEROSOLVE II 018101 20N20
>=90 - <=100
Yes
NM Z Parent Inc.
Products Formulated with TCE
95%
84%
Yes
No
4-2
Table 4-1: Companies and Types of Products Containing Trichloroethylene by Product Type
Product Type
Parent Company Name
Product Name
A07311 ZEP PRO NF SLVT DGRS R12201 20N20
A07328 ZEP PARTS CLNR 003601 20N20
A07311 ZEP POWER SOLV II 020301 20N20
Zep 45 Aero DZ
Zep Top Solv
Lubricants and
Greases
%
Average
Has Existing
TrichloroethyleneFree Alternative
>=90 - <=100
Yes
>=30 - <=50
Yes
>=90 - <=100
Yes
>=30 - <60
Yes
>=90 - <=100
Yes
95-98
Yes
Nu-Calgon
Nu-Blast Aerosol
Omega Industrial Supply, Inc.
Parker Hannifin Corporation
A1065 Blast
Blast-A-Coil
60-100
60-100
Yes
Yes
Solvent Degreaser
90-100
Yes
Industrial C 60 Solvent Degreaser SW 064
90-100
Yes
Fusing Machine Cleaner
SW C60 SOLVENT DEGREASER
40-60
50-100
Yes
Yes
Pro Chem
Pro Tools NF Solvent Degreaser
90-100
Yes
The Sherwin Williams
Company
MR 351 Mold Cleaner Aerosol
50-75
Yes
SP 709 Chlorinated Brake and Parts Cleaner Aerosol
Electro Blast
90-98
Yes
90-100
Yes
90-100
90-98
90-98
Yes
Yes
Yes
40-60
Yes
15.7-25.8
No
PLZ Aeroscience Corporation
Energized Electronic
Cleaner
% Trichloroethylene
Pro Chem
Electro Solv
The Sherwin Williams
Company
EL 848 Heavy Duty Flash Free Electrical Solvent Aerosol
EL 2001 Electric Contact Cleaner and Protectant Aerosol
Midwest Motor Supply
Company
Ultra Cut Cutting Tool Coolant`
K-Chem, Inc
Nut Buster
Mid-American Research
Chemical Corp.
Marc 100 Pen-A-Lube
PLZ Aeroscience Corporation
Products Formulated with TCE
Penetrating Lube
Moisture Guard
7-13
21%
No
>= 5 - < 10
No
>=5-<10
No
4-3
Table 4-1: Companies and Types of Products Containing Trichloroethylene by Product Type
Product Type
Parent Company Name
Product Name
Zep 45
Adhesives, Sealants,
Paints and Coatings
QuestSpecialty Corporation
Loose Srew
Berwind Corporation
TERAND COLD PIPE INSULATION
R.R. Street & Co. Inc.
ANTI-SWEAT V2.0 COLD PIPE INSULATION - HVAC-882
Has Existing
TrichloroethyleneFree Alternative
>=30 - <50
No
7-13
Yes
40-60
No
25-<50
No
Not provided
No
25-<50
Yes
5-15
No
Pipe Wrap
PLZ Aeroscience Corporation
Sprayway Cold Pipe Insulation
Centerbridge Partners, L.P.
SCIGRIP® 3 Low VOC Solvent Cement for Acrylic
NewStar Adhesives Inc
EverStrong ES132 Contact Adhesive – Air Assist Canister
70-80
Yes
Parker Hannifin Corporation
CHEMLOK 218
20-25
Yes
SCIGRIP Smarter Adhesive
Solutions
SCIGRIP® 4 Solvent Cement for Acrylic
40-60
Special Cement BL (Non-Flammable)
80-95
Yes
OTR Special BL Cement (Non-Flammable)
80-95
Yes
Thermopress MTR Solution
75-90
Yes
Rim & Bead Sealer (Non-Flammable)
75-90
Yes
Innerliner Repair Sealant (Non-Flammable)
70-85
Yes
>80
Yes
15-40
Yes
3-10
Yes
15% ≤ - ≤ 25%
Yes
SC2000 Black Cement (Non-Flammable)
Steel Partners Holdings L.P.
A.L. Wilson Chemical Co.
Film Cleaner
%
Average
Brodi Specialty Products
Stahlgruber Otto Gruber AG
Spot Removers
% Trichloroethylene
R.R. Street & Co. Inc.
Hurst Chemical Company
Products Formulated with TCE
STA'-PUT S100 Contact Adhesive
STA'-PUT S170/S171 Contact Adhesive
TarGo Dry
Puro
> 75
Picrin
> 75
Film Cleaner 90
95
55%
57%
No
Yes
Yes
95%
No
4-4
5. Use and Alternatives Analysis
This Chapter discusses the uses and alternatives for TCE. Section 5.1 presents the overview of the use and
alternatives analysis presented in this Chapter. The remainder of the chapter is organized according to the
product categories considered in the analysis and Table 5-1 presents a map between the use categories and
the sections of the chapter where they are discussed.
Table 5-1: Use Categories Mapped to Applicable Section of Chapter
Use Category
• Laboratory Use
Use and Alternatives Analysis
• Not considered/applicable, see section 5.2, Use Categories and COUs Not Considered
in the Use and Alternatives Analysis.
• Import/Repackage
• Not considered/applicable, see section 5.2, Use Categories and COUs Not Considered
in the Use and Alternatives Analysis.
• Not considered/applicable, see section 5.2, Use Categories and COUs Not Considered
in the Use and Alternatives Analysis.
• Battery and Synthetic Paper
Processing Aid
• Not considered/applicable, see section 5.2, Use Categories and COUs Not Considered
in the Use and Alternatives Analysis.
• Manufacturing
• HFC Manufacturing
• Intermediate in HCl Production
• Fluoroelastomer Manufacture
• Disposal to Wastewater
• Vapor Degreasing (open top,
enclosed, conveyorized and web)
and Batch Cold Cleaning
• Mold Release
• Liquid Cleaners and Degreasers
• Not considered/applicable, see section 5.2, Use Categories and COUs Not Considered
in the Use and Alternatives Analysis.
• Not considered/applicable, see section 5.2, Use Categories and COUs Not Considered
in the Use and Alternatives Analysis.
• Not considered/applicable, see section 5.2, Use Categories and COUs Not Considered
in the Use and Alternatives Analysis.
• Not considered/applicable, see section 5.2, Use Categories and COUs Not Considered
in the Use and Alternatives Analysis.
• See section 5.3, Vapor Degreasing
• See section 5.4, Mold Release and Aerosol Spray Cleaning/Degreasing: Mold
Releases and Cleaners
• See sections 5.5, Liquid Cleaners and Degreasers and Aerosol Spray
Cleaning/Degreasing: AC Coil Cleaners, and 5.6, Liquid Cleaners and Degreasers and
Aerosol Spray Cleaning/Degreasing: Energized Electrical Equipment Degreasers
• Aerosol Spray Cleaning/Degreasing
• See sections 5.5, Liquid Cleaners and Degreasers and Aerosol Spray
Cleaning/Degreasing: AC Coil Cleaners, and 5.6, Liquid Cleaners and Degreasers and
Aerosol Spray Cleaning/Degreasing: Energized Electrical Equipment Degreasers
• Lubricants and Greases
• See section 5.7, Lubricants and
• Adhesives, Sealants, Paints and
Coatings
• See sections 5.8, Adhesives, Sealants, Paints and Coatings: Adhesives, and 5.9,
Adhesives, Sealants, Paints and Coatings: Cold pipe insulation
• Spot Removers
• See section 5.10, Spot Removers
• Pepper Spray
• See section 5.11, Pepper Spray
• Uses believed to be inactive or fully
overlap with other conditions of use
1
• Toner Aid1
• Film Cleaner1
• Polish1
Based on market research, EPA believes these are inactive uses.
5.1 Overview of Use and Alternatives Analysis Approach
Products discussed in this chapter were identified through a series of online searches, or through an
inventory of products described in Chapter 4. The searches encompassed products available for purchase
Use and Alternatives Analysis
5-1
either by large and small businesses or by individual consumers. Certain product categories are relevant
only for industrial or commercial use, while others are relevant for both.
This review provides a representative, but not exhaustive, listing of commercially available products for
each product category evaluated. Therefore, the calculated market share percentages, price ranges, and
conclusions about efficacy factors would likely change if more products were included in the review of
various product categories. These changes would be most significant for broad product categories with
numerous sub applications such as adhesives, caulks, and conventional press washes. The products
included in the analysis were the products with the largest number of online customer reviews for
products. This measure was used as a proxy for quantity of use. Products with relatively few or no online
customer reviews were omitted from the analysis if several products with a higher number of customer
reviews were available. Products with no online customer reviews were sometimes included, especially if
there were limited products available with customer reviews within a product category.
For each product, the Safety Data Sheet (SDS) was obtained and was used as the source of information
for ingredients, ingredient concentrations, VOC content, evaporation rate, flash point, other fire safety
information, and substrate compatibility in some cases. It is worth noting that SDSs sometimes contain
inconsistencies or inaccuracies, but additional data sources for these data points were not reviewed,
except where specifically noted. In addition, SDSs sometimes provide a range of ingredient
concentrations, rather than providing an exact formulation. The search for SDSs was not exhaustive for
each product; therefore, additional SDS versions may exist for the same products.
5.1.1 Substitute Chemicals
For any effort to eliminate or replace a TCE, several approaches may be possible. Options include drop-in
substitution; reformulation; process change; upstream changes; or elimination of the activity requiring the
use of the chemical. For example, for the use of TCE in degreasing applications, an example of a drop-in
substitution would be adoption of an alternative organic solvent that does not require any change in
equipment or processes. An example of a process change would be a shift from an aerosol spray to an
aqueous cleaning system using different equipment. An example of an upstream change would be a
change in the use of oils or greases, shifting to a material that is easier to remove from parts. Similarly, a
degreasing step can sometimes be eliminated entirely by changing oils or greases upstream.
Where applicable, this analysis examines drop-in solvent substitutes. In some cases, the analysis includes
products that would be associated with a process change. It is important to note that in many cases,
additional process change options are available to both businesses and consumers. Other TSCA priority
chemicals were not considered as viable substitutes.
5.1.2 Analysis Sections for Each Product Category
The following analysis sections were included for each product category. For ease of reviewing the
analysis, the rows are shaded orange in all tables for products containing TCE and are shaded grey for
products containing another one of the first 10 TSCA work plan chemicals. All rows with products
containing other alternatives are not shaded.
5.1.2 (A) Description
A brief description of the product used in the product category is provided.
5.1.2 (B) Solvent Ingredients
The solvent ingredients are provided for each of the products reviewed. The solvent names and
concentrations were obtained from product Safety Data Sheets (SDSs). In some cases, it may not be clear
if the primary function of a particular ingredient is as a solvent, or an ingredient may serve additional
functions, such as acting as an emulsifier. If the listed ingredient appeared to have a solvency role, it was
included.
Use and Alternatives Analysis
5-2
5.1.2 (C) Chemical Ranking/ Market Share
A chemical ranking procedure was developed as a proxy for market share percentage of the chemicals
used in products. This procedure provides a coarse estimate of 1) market share percentage of chemicals
used within the current marketplace, and 2) the anticipated market share percentage of alternative
chemicals if TCE were restricted for a certain product category. This procedure is further described in
Appendix A. Note that the estimated "market share" refers to the amount of solvent/chemicals used in a
particular product category, not the number of products based on a particular chemistry.
For several product categories, there were many more alternative products commercially available than
products with TCE. When including only products with higher number of customer reviews, the number
of alternative products excluded from the analysis was greater than for methylene chloride products.
Consequently, the current market share percentage may be overstated for the TCE products in these
product categories. However, this would have no impact on the estimated market share percentage after
TCE restrictions.
Water is often not included in product SDSs. For this evaluation, water was included as an ingredient
only if it was listed in the SDS or the product description specifically states that the product is water
based. Otherwise, it was not assumed that water is an ingredient. It is likely that some products may have
water as an ingredient and the product description may not state water based. Therefore, the approximate
market share percentages calculated with this procedure may understate the actual representation of water
used in products.
5.1.2 (D) Volatile Organic Content
This section provides VOC regulatory limits established by the U.S. EPA at the federal level, the South
Coast Air Quality Management District (SCAQMD) at the regional level, and the Ozone Transport
Commission (OTC) at the state level. The regulatory definition of VOCs used by the U.S. EPA is as
follows: "Any compound of carbon, excluding carbon monoxide, carbon dioxide, carbonic acid, metallic
carbides or carbonates, and ammonium carbonate, which participate in atmospheric photochemical
reactions" (Tucker 2001). OTC is a multi-state organization that was created under the Clean Air Act.
OTC is responsible for advising the U.S. EPA on transport issues and for developing and implementing
regional solutions to the ground-level ozone problem in the Northeast and Mid-Atlantic regions (OTC
2020). SCAQMD is the regulatory agency responsible for improving air quality for large areas of Los
Angeles, Orange County, Riverside and San Bernardino counties (SCAQMD 2021). In addition to this
regulatory information, the VOC information available in product SDSs is provided for each of the
products reviewed. In some cases, VOC information was absent from the SDS but was present in a
technical data sheet for the same product.
Methylene chloride and perchloroethylene are VOC exempt chemicals, while 1-bromopropane, NMP, and
TCE are not VOC exempt chemicals. Commonly used solvents in chemical product formulations that are
VOC exempt include water, acetone, dimethyl carbonate, methyl acetate, parachlorobenzotrifluoride,
propylene carbonate, and tert butyl acetate.
5.1.2 (E) Fire Safety
The products reviewed were mainly composed of liquid solvents. "Flash point" is defined by the U.S.
Occupational, Safety and Health Administration and the U.S. Department of Transportation in the U.S.
Code of Federal Regulations as: "The minimum temperature at which a liquid gives off vapor within a
test vessel in sufficient concentration to form an ignitable mixture with air near the surface of the liquid"
(OSHA 2009, U.S. Department of Transportation 2009). Under the Federal Hazardous Substances Act
label requirements, the Consumer Product Safety Commission (CPSC) classifies a liquid with a flash
point less than 20 °F as "Extremely Flammable"; greater than 20 °F and less than 100 °F as "Flammable";
and 100 °F to 150 °F as "Combustible." Products with flash points greater than 150 F are considered nonflammable. There are other definitions for flammable and combustible liquids. For example, OSHA
Use and Alternatives Analysis
5-3
designates liquids used in the construction industry with flash points up to 140 F as flammable and liquids
with flash points up to 200 F as combustible (OSHA 2010). This analysis used the flash points found in
product SDSs or technical data sheets and translated those to ratings based on CPSC flammability
classifications.
The primary way to mitigate fire hazard for products containing organic solvents is to utilize solvents
with higher flash points, so that the overall product has a flash point that would be considered either
combustible or non-flammable. In some cases, there is also the option to incorporate evaporation barrier
additives that diminish the evaporation rate of the solvents. Paint and coating removal products often
contain evaporation barriers, as the objective is to keep the product from evaporating to extend contact
time. No evidence was found that evaporation barrier additives are used for the other product categories
reviewed.
Flash points found in product SDSs or technical data sheets are provided for each of the products
reviewed. Note that a flammability rating given on an SDS may be based on a different system than the
CPSC ratings used in this analysis. For example, the SDS may list a product as combustible, while under
the CPSC system it is non-flammable.
5.1.2 (F) Pricing and Customer Reviews
Pricing and customer review information obtained from publicly available websites are provided. This
includes product prices, the number of customer reviews, and the average rating level for each of the
products reviewed. It is important to note that prices can change over time, and are affected by a range of
factors, including demand, availability of raw materials, and economies of scale, among other factors. In
addition, products may be sold as concentrates or ready to use. Price comparisons assume that a similar
amount of product would be used compared with the TCE product for any given application. Thus, they
do not account for differences in effectiveness between products that effects the amount of product
needed per use.
5.1.2 (G) Conclusion
The conclusion to each section summarizes findings and assesses whether any efficacy elements (e.g.,
VOC and fire safety), or cost barriers exist to using the alternative products as replacements for products
containing TCE.
5.2 Use Categories and COUs Not Considered in the Use and Alternatives
Analysis
The use categories and the COUs not considered in the use and alternatives analysis and the reasons they
excluded are presented in Table 5-2 below. Sections 5.1-5.3 provide more information on certain uses and
why alternatives are not more fully considered.
Use and Alternatives Analysis
5-4
Table 5-2: Conditions of Use from the TCE TSCA Risk Evaluation Which Are Not Analyzed
Further in This Use and Alternatives Analysis
Use Category
Laboratory Use
Conditions of Use (COUs)
• Industrial and commercial use in
hoof polish; gun scrubber; pepper
spray; other miscellaneous
industrial and commercial uses
Manufacturing
• Manufacturing: domestic
manufacture
• Manufacturing: import
Import/Repackage
• Processing: repackaging
Processing Aid
(Battery and Synthetic
Paper)
HFC Manufacturing
Intermediate in HCl
Production
Fluoroelastomer
Manufacture
Disposal to
Wastewater
• Industrial and commercial use as
processing aids in process solvent
used in battery manufacture;
process solvent used in polymer
fiber spinning, fluoroelastomer
manufacture and Alcantara
manufacture; extraction solvent
used in caprolactam manufacture;
precipitant used in betacyclodextrin manufacture
• Processing: processing as a
reactant/intermediate
• Processing: processing as a
reactant/intermediate
• Industrial and commercial use as
processing aids in process solvent
used in battery manufacture;
process solvent used in polymer
fiber spinning, fluoroelastomer
manufacture and Alcantara
manufacture; extraction solvent
used in caprolactam manufacture;
precipitant used in betacyclodextrin manufacture
• The disposal of TCE by industrial
pre-treatment, industrial
treatment, or publicly owned
treatment works
Use and Alternatives Analysis
Explanation
Alternatives for TCE as a lab standard were not
considered because EPA is not prohibiting or restricting
laboratory uses in a manner substantially preventing
activities in this use category until a viable alternative
becomes available in the future. EPA has not identified
any currently technically or economically feasible
alternatives for TCE use as a laboratory chemical for
essential laboratory uses. Note that methylene chloride
and 1-bromopropane are alternatives that can be used to
test hot mix asphalt binder content. Other alternatives
include different testing methods. The alternative
methods are Nuclear Asphalt Content (NAC) Gauge and
the Ignition Method.
Domestic manufacturing and import are alternatives for
one another. The neat chemical must either be made
domestically or imported into the United States.
Chemical alternatives to TCE are accounted for in later
stages of the chemical’s life cycle based on specific
uses.
The alternative for domestic repackaging is importing a
repackaged product. Therefore, chemical alternatives for
this COU are not identified.
EPA has focused this assessment on alternative chemical
ingredients performing the same or similar functions as
TCE in products for consumer or commercial/industrial
use. For these COUs, EPA did not find it practicable to
consider whether there are alternative processes that
directly replace TCE with an alternative chemical or
represent larger changes in multiple process steps in the
production of a given chemical, due to the complexity of
the analysis. However, EPA has included some
information regarding the lack of alternatives for these
uses where available. The lack of known alternatives for
these COUs is accounted for in the development of the
regulatory options.
In assessing the scenarios in which there is market
adoption of these alternative commercial and consumer
products that do not contain TCE, the earlier and later
life cycle stages are no longer relevant to the
assessment: these COUs for TCE are dependent on
continued use in the commercial and consumer life cycle
stages. As such, this Alternatives Assessment excludes
manufacturing (including import), processing,
distribution in commerce, disposal, and recycling. EPA
did not identify alternative disposal options in the case
of disposal of TCE to industrial pre-treatment, industrial
5-5
Table 5-2: Conditions of Use from the TCE TSCA Risk Evaluation Which Are Not Analyzed
Further in This Use and Alternatives Analysis
Use Category
Incorporation into
Formulation, Mixture,
or Reaction Product
Toner Aid
Polish
Conditions of Use (COUs)
• Processing: incorporation into a
formulation, mixture or reaction
product
• Industrial and commercial use as
ink, toner and colorant products in
toner aid
• Consumer use in toner aid
• Consumer use in hoof polish
Explanation
treatment, or publicly owned treatment works for the
purposes of cleanup projects of TCE-contaminated
groundwater and other wastewater. Approaches used for
cleanup of TCE-contaminated water are specific to the
specific circumstances of individual sites and
information is not available to determine what those
approaches may be.
The alternatives are the processing or
industrial/commercial use of a solvent to make products
that do not contain TCE. Therefore, chemical
alternatives to TCE are accounted for in later stages of
the chemical’s life cycle.
There is evidence that TCE has historically been used in
select products in this category. Based on market
research, EPA was unable to find reasonably available
information in support of the ongoing use of TCE for
this use category (other than uses that fall under other
conditions of use).
There is evidence that TCE has historically been used in
select products in this category. Based on market
research, EPA was unable to find reasonably available
information in support of the ongoing use of TCE for
this use category (other than uses that fall under other
conditions of use).
5.2.1 Battery Separator Manufacture
EPA received two 6(g) exemption requests for the use of TCE as a process solvent in battery separator
manufacture, one from Microporous, LLC and one from ENTEK 8 . Microporous is a manufacturer of Pb
acid battery separators and ENTEK manufactures both Pb acid and lithium-ion battery separators and
both use TCE as a process solvent. Both companies included information on alternatives in their
exemption requests (ENTEK International LLC 2021b , Microporous 2022).
7F
Both companies use a wet process to manufacture battery separators and indicated that TCE is used in the
extraction of process oil from extruded battery separator sheets. When the process oil is removed, the
solvent is evaporated/removed from the separator to yield the required porosity to allow ion flow in the
finished battery. One characteristic of TCE noted by both companies is that TCE reliably produces pores
in the separator sheet in the range of 9-12 micrometer (µm) which is the choice for electric vehicle
applications (ENTEK 2021b; Microporous 2022 ).
Within their submissions, the companies indicate that an alternative to battery separators manufactured in
the U.S. would include imported battery separators, which could result in additional costs to users and
also could affect national security by affecting the domestic supply chain. They also indicated that battery
separators manufactured using a dry process (or mechanical process for creating pores) might be
considered an alternative, however, the necessary porosity needed for some applications cannot be
reliably achieved through this process. (ENTEK 2021b; Microporous 2022)
8
According to their submission, ENTEK International LLC, produces separators for lead-acid batteries, and
ENTEK Membranes LLC, produces separators for lithium-ion batteries. They are collectively referred to as
ENTEK here as well as in their submission. (ENTEK 2021a)
Use and Alternatives Analysis
5-6
ENTEK also included an “Analysis of Alternatives for the Use of Trichloroethylene as an Extraction
Solvent for Removal of Process Oil and Formation of the Porous Structure in Polyethylene Based
Separators Used in Lead-Acid Batteries “(ENTEK 2021a) identifying 17 chemicals or mixtures of
chemicals (within a product) as potential alternatives to TCE as process solvent. The analysis was
developed for ENTEK’s submission for authorization in Europe under the Registration, Evaluation,
Authorisation and Restriction of Chemicals program (“REACH”). Potential alternatives included nhexane, methylene chloride, perchloroethylene, HFE-72DE (1,2-transdichloroethylene), Vertrel® SDG,
N-Propyl Bromide, D-Limonene, and acetone. Microporous also identified some of these as potential
alternatives (Microporous 2022). None of the named potential alternatives are drop-in alternatives and
would likely require process changes including replacement of equipment and process reengineering.
Most have only been tested at a lab scale. Additionally, there are concerns with respect to human health
and the environment with each potential alternative, some having significant flammability concerns. In
general, given the technical and economic considerations, the conclusion from both submitters was that
no suitable alternatives were available at this time.
5.2.2 Synthetic Paper Processing Aid
EPA received a 6(g) exemption request for the use of TCE as a process solvent in battery separator
manufacture from PPG. PPG is a global maker of paints, coatings and specialty materials. Information in
this section is based on information provided in PPG’s exemption request (PPG 2023).
One of PPG’s specialty materials, TESLIN substrate, is a unique polymeric microporous sheet material
that is a fundamental component in a wide range of products including but not limited to:
•
Secure credentials, ID cards, Driver Licenses and Passports / e-Passports
•
Durable labels and tags having stringent requirements, including blood bag labels and chemical
drum labels
•
Energy recovery ventilators
•
Filtration elements and cartridges especially for challenging oil/water and bilge water separations
TCE is used in the production process to facilitate the controlled removal of process oil required in order
to achieve a microporous film. TCE possesses the following properties that allows its use, recovery, and
reuse:
•
Non-flammable
•
Rapidly extracts process (mineral) oil from sheet
•
Amenable to separation via distillation allowing reuse of TCE and oil
•
Low solubility in water and higher density than water that enables water/solvent separation for
recovery
•
Vapor pressure that allows for evaporation but can be condensed from steam atmosphere
TCE is used in the production process to extract oil from the synthetic paper sheet. The solvent displaces
the process oil from the pores of the precipitated silica, transforming the oil-filled sheet into a
sheet/substrate with the required micro-porosity and other physical properties which are key to the
performance attributes and value in essentially all end-use applications. The sheet filled with process oil is
converted to sheet filled with TCE. In the reverse-process direction, process solvent is converted into a
process solvent/process oil mixture, which is subsequently separated in a distillation system by taking
advantage of the relatively low boiling point of TCE as compared to oil. The pure TCE that comes off of
Use and Alternatives Analysis
5-7
the distillation system is fed back into the extractor, and the process oil that comes off of the distillation
system is fed into a process oil storage tank where it is re-used for subsequent TESLIN mixes. The
process oil and process solvent TCE are both recycled and reused.
Withing their submission, they summarized the following potential alternative solvents and asserted that
none are technically or economically feasible alternatives to TCE in their production process:
•
Trans-1,2-dichloroethylene
•
3M Novec 73DE
•
Chemours Vertrel MCA
•
Chemours Vertrel CCA
•
NuGenTec FluoSolv CX
•
Chemours Opteon SF79
•
Cemours Opteon SF80
•
Aero-Tron 100
•
Hexane
5.2.3 HFC Manufacture
The majority of the annual production volume of TCE processed as an intermediate under this condition
of use goes almost entirely toward the manufacture of one HFC, HFC-134a (EPA 2020e). HFC-134a can
also be manufactured using perchloroethylene as a feedstock. While it would appear that
perchloroethyene could be an alternative to TCE, it is not a drop-in substitute and facilities that currently
use TCE would need to make major changes to their production equipment and processes to switch to
perchloroethylene from TCE. According to one of the manufacturers, Koura, the plant design would be
drastically different and, while some parts of a facility might be able to be used in both processes, the
“heart of the process” could not without costly retrofitting and would probably not be a reasonable
alternative given the response to the phasedown of HFC-134a resulting from the AIM Act (EPA 2021b).
5.2.4 Fluoroelastomer Production
In Europe, TCE was identified as a solvent in the synthesis of crosslinking agents for fluoropolymers. A
single request for authorization under REACH was submitted for this use of TCE. As part of that request,
the submitter provided an economic analysis and an alternatives assessment evaluating over 30 chemicals
and/or products that may be potential alternatives. These two documents were used a basis to demonstrate
that there were no suitable alternatives at the time of the authorization request (Azienda Lavorazione
Prodott Ausiliari 2014) and an authorization for the use was granted. However, based on a more recent
ECHA report, there is now a viable alternative to TCE, acetonitrile, which can be used with no changes in
configuration in the specific process originally authorized needing no new plant or safety (ECHA 2022).
Regardless, EPA does not believe this to be an ongoing use of TCE in the U.S. In its 2021 Multi-Industry
Per- and Polyfluoroalkyl Substances (PFAS) Substances (PFAS) Study (Preliminary) EPA identified 2
domestic manufacturers of fluoroelastomers and one processor. None of these companies appeared in the
2020 TRI or NEI with reports for TCE, suggesting they are not using TCE in their process. While EPA
does not believe that domestic manufacture of fluoroelastomers using TCE occurs, 2 companies were
identified as those reporting TCE on TRI or NEI reports that had a NAICS code that related to an industry
where rubber-type products were potentially manufactured. Therefore, to account for the uncertainty in
knowing if this is an ongoing use, EPA conservatively used these companies to estimate impacts of the
Use and Alternatives Analysis
5-8
rule, however, has low confidence that they are using TCE as a process solvent in the manufacture of
fluoroelastomers.
5.3 Vapor Degreasing
It is anticipated that the facilities that use TCE for vapor degreasing and batch cold cleaning will
transition to technologically and economically feasible alternative cleaning methods, which could include
vapor degreasing with another solvent, aqueous cleaning, or another non-water alternative such as
hydrocarbon solvents, oxygenated solvents, terpene-based cleaners, parachlorobenzotrifluoride, volatile
methyl siloxanes, or soy-based cleaners (IRTA 2016b; 2016a). Three solvents commonly used for vapor
degreasing are also included in the first 10 TSCA work plan chemicals: methylene chloride,
perchloroethylene, and 1-bromopropane. The risk evaluations for these three chemicals all found an
unreasonable risk under TSCA for their use in vapor degreasing. Given the regulatory uncertainty while
EPA considers risk management options for these chemicals, this analysis assumes that these chemicals
would not be adopted as alternative open-top vapor degreasing solvents for TCE while this regulatory
uncertainty exists. Since the proposed perchloroethylene rule allows for its continued use in airless vapor
degreasers and EPA believes that the emissions below the ECEL under the proposed rule are achievable,
EPA believes that the use of perchloroethylene in an airless degreaser may be a popular choice as an
alternative to TCE vapor degreasing.
EPA consulted with critical cleaning experts who help manufacturers develop and/or optimize their
cleaning processes about alternatives to TCE in vapor degreasing. According to these experts, the
alternatives that would be technological and economically feasible would be dependent on:
-
the soils being removed,
-
the level of cleanliness required,
-
the characteristics of the components being cleaned,
-
the volume of components being cleaned,
-
and other factors.
The critical cleaning consultants noted that users may need to test multiple different cleaning processes
before identifying a successful process, and some users might need to transition from using TCE in vapor
degreasing to more than one alternative cleaning chemical/method.
The critical cleaning consultants considered alternatives to the use of TCE in different sized degreasers
used in the different cleaning categories in the first two columns of Table 5-3 to the different cleaning
methods presented the last column in Table 5-3.
The analysis defines Small, Medium, and Large degreasers according to the cleaning chamber tank size
(small–12 x 12 x 10; medium–36 x 36 x 22; large–60 x 42 x 36).
The critical cleaning consultants defined four “cleaning categories” that would have different processes
and cleaning requirements for switching to alternative cleaning methods to vapor degreasing with TCE:
•
•
General Cleaning is defined as having relatively low process development and low cost of
process verification. Primary costs will include equipment and performance testing.
High Precision Cleaning covers the cleaning of high value parts where very small residue is
acceptable, at best. Significant process development is needed; however, customer or other
regulatory performance standards are not the driving force.
Use and Alternatives Analysis
5-9
•
•
Safety Critical Cleaning includes product processes where performance failure is not an option.
This category will have higher costs for process verification and validation and may also cover
situations with very high-cost consequences of failure. Primary costs will include evaluation,
initial performance testing and capital costs.
Start-up/R&D Critical Cleaning covers the development process of new high precision or high
value products prior to production; these would typically not require large degreasers and would
need adaptable cleaning systems.
Table 5-4 presents the cleaning methods that are applicable for each combination of size and cleaning
category. Table 5-5 presents the descriptions of the baseline and alternative cleaning methods that would
be the most likely to be economically and technically feasible.
Table 5-3: Sizes, Cleaning Categories, and Cleaning Methods Considered in the Vapor Degreasing
Alternatives Analysis
Size
Small
Cleaning Category
General
Cleaning Method
Replace with Airless Degreaser with PCE
Medium
High Precision
Convert OTVD to use Flashpoint inerted t-DCE
Large
Safety Critical
Replace with OTVD using FlashPoint inerted t-DCE
Start-Up/R&D
Replace with Solstice system (trans-1-chloro-3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and
Alcohols
Co-Solvent, Bi-Solvent
High boiling, non-vacuum, non-rinse
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (example: Inventec, HEMO)
Use and Alternatives Analysis
5-10
Table 5-4: Size and Cleaning Categories and Applicable Alternative Cleaning Methods
Cleaning Method
Replace with Airless Degreaser
with PCE
Convert OTVD to use Flashpoint
inerted t-DCE
Replace with OTVD using
Flashpoint inerted t-DCE
Replace with Solstice system
(trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point
(<100C) Alcohol or other
flammable
OTVD for Very low flashpoint
(<0C) solvent
EVD for High Boiling Point
Combustibles (>100C)
Hydrocarbons and Alcohols
General Cleaning
Small
Medium
Large
High Precision Cleaning
Small
Medium
Large
Safety Critical Cleaning
Small
Medium
Large
Start-Up R&D
Small
Medium
Co-Solvent, Bi-Solvent
High boiling, non-vacuum, nonrinse
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec,
HEMO)
Use and Alternatives Analysis
5-11
Table 5-5: Baseline and Alternative Cleaning Methods and their Definitions
Cleaning Method
Baseline - OTVD with TCE
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted tDCE
Replace with OTVD using Flashpoint
inerted t-DCE
Replace with Solstice system (trans-1chloro-3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C)
Alcohol or other flammable
OTVD for Very low flashpoint (<0C)
solvent
EVD for High Boiling Point Combustibles
(>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Use and Alternatives Analysis
Definition
An OTVD uses heated solvent in the liquid and/or vapor phase. For this analysis, the baseline OTVD uses TCE as the solvent. An
OTVD may or may not have a cover. It may be characterized by the equipment supplier using terms like “well-sealed” or having
“minimal solvent emissions.” As defined here, OTVDs have an atmospheric air-solvent interface, which is why it is difficult to
get very low emissions. Nearly all OTVDs using TCE should be “National Emission Standards for Hazardous Air Pollutants
(NESHAP) compliant” OTVDs, in that they may have double-coils and a high freeboard ratio. An OTVD may include ultrasonic
cleaning and/or a spray wand.
An airless degreaser (sometimes referred to as an airless/airtight cleaning system) is equipment for which there is never an
atmospheric air-solvent interface. Solvent does not enter the working chamber until the product to be cleaned has been placed in
the chamber, the chamber has been sealed and air has been evacuated, usually to a level of one torr or less. Cleaning then can
occur, usually by computer control, either by immersion (with or without ultrasonics), spray, or vapor degreasing. As with
aqueous cleaning, solvent immersion cleaning could also include cyclic nucleation or cyclic cavitation, where the pressure is
changed to provide boiling cycles. Following cleaning and rinsing cycles, the solvent is pumped back into sealed reservoirs, and
the chamber is again pumped to a vacuum (sometimes through a carbon filter to capture residual traces of solvent vapors), thus
providing vacuum drying. A closed-loop degreaser is not the same as an airless degreaser. An OTVD recirculates/redistills/reuses
the solvent; but such systems have not been demonstrated to match the low level of solvent loss achieved with an airless system.
EPA believes that the emissions levels below the ECEL in the 2023 proposed section 6 regulation for PCE are achievable when
using PCE in an airless degreaser.
An OTVD uses heated solvent in the liquid and/or vapor phase. For these cleaning methods, flashpoint inerted trans-DCE is the
solvent. An OTVD may or may not have a cover. It may be characterized by the equipment supplier using terms like “wellsealed” or having “minimal solvent emissions.” Since flashpoint inerted trans DCE blends are more expensive, it may make sense
for users to replace their OTVD if their existing machine is an older, more emissive model. The fluorinated inerting agents are
also under scrutiny by the U.S. EPA and other regulators because of concerns about PFAS.
An OTVD uses heated solvent in the liquid and/or vapor phase. For these cleaning methods, flashpoint inerted trans-1-chloro3,3,3,trifluoropropene is the solvent. An OTVD may or may not have a cover. It may be characterized by the equipment supplier
using terms like “well-sealed” or having “minimal solvent emissions.” Since flashpoint inerted trans-1-chloro3,3,3,trifluoropropene blends are more expensive, it may make sense for users to replace their OTVD if their existing machine is
an older, more emissive model. The fluorinated inerting agents are also under scrutiny by the U.S. EPA and other regulators
because of concerns about PFAS.
These systems are vapor degreasers where engineering controls have been employed to eliminate ignition and oxidation sources in
order to ensure that flammable liquids can be used.
These are systems containing combustible (flashpoint > 37.8C) solvents, with boiling points greater than 100C. The solvents in
current use are either medium chain (~10-12 carbons) iso-paraffins or those that are called “modified alcohols”, such as isopropanol connected to a butane (4-carbon) chain. Because the primary concern is reducing flammability concerns rather than toxic
exposure, these systems may be the same as airless degreasers, but need not be designed to completely eliminate an atmospheric
air-solvent interface.
Flashpoint-inerted trans DCE
These are systems that use two organic solvents. For the purposes of this analysis, these terms are interchangeable. In some cases,
5-12
Table 5-5: Baseline and Alternative Cleaning Methods and their Definitions
Cleaning Method
Definition
the cleaning agent (sometimes referred to as the solvating agent) is in one chamber and the rinsing agent (sometimes referred to as
the displacement agent) is in a second tank and is used sequentially. In other designs, the washing step is a mixture of cleaning
agent and displacement agent. Nearly all current co-solvent or bi-solvent systems use flashpoint-inerted trans-DCE as the
displacement agent. The fluorinated inerting agents are also under scrutiny because of concerns about PFAS.
High boiling, non-vacuum, non-rinse
Semi-Aqueous
Replace with Aqueous Cleaning
Solvent and alcohol (cost estimates do not reflect this possibility)
If ingredients of flashpoint-inerted trans DCE were to become unavailable through regulatory actions or business decisions, cosolvent and bi-solvent systems are options. Based on Barbara Kanegsburg’s studies at Litton Guidance and Control Systems in the
late 1980s- early 1990s for what we now term safety/critical military applications, cleaning should be able to be accomplished
using cleaning agents such as d-limonene or some of the Axarel hydrocarbon blends followed by rinsing with isopropyl alcohol.
Modified alcohol could be tested as the solvating agent. There are provisos. Additional process development, including testing,
would be needed. Low flashpoint cleaning systems would be needed – this would add to equipment costs.
Examples of solvents used in such systems include d-limonene and soy methyl esters. The FP is above 37.8 deg C (100 deg F), so
they would be considered not flammable by NFPA. Equipment would consist of a dip tank, most often but not necessarily heated.
There could be ultrasonics or agitation. Depending on local regulations (notably those restricting VOC), there may or may not be
a cover. Examples:
D-limonene (aliphatic hydrocarbon classified as a cyclic monoterpene, the major component in oils from citrus rinds)
flashpoint 48 deg C
boiling point 176 Deg C
Methyl Soyate (a mixture of long-chain, typically 16-18 carbons, fatty acid methyl esters)
flashpoint 130C
boiling point 200C
A semi-aqueous cleaning process consists of a water-miscible blend, with high solvent concentration (including emulsions), used
as an immersion or spray followed by an aqueous rinse (see the description of aqueous process). Some semi-aqueous processes
are referred to as aqueous (by the supplier of cleaning agent, or cleaning equipment, or by the end-user) for marketing purposes
even though this is not an accurate description of the process.
Aqueous cleaning involves washing with a cleaning agent that could be water alone but that typically contains organic and
inorganic chemistry and typically contains significant amounts of water. Aqueous cleaning may be used at many stages of
production. The quality of the water and the amount of water used is highly variable. Depending on the application, the water
quality can range from tap water to purified water, for example, de-ionized or reverse osmosis.
What manufacturers consider to be an aqueous cleaning agent is highly variable. Aqueous formulations vary in their composition
(organic and inorganic additives) and in the concentration at which they are used. Some may have a very high pH. What is
described as an aqueous process may actually be a semi-aqueous process, in large part because it has become more acceptable to
avoid the concept of using any organic solvent for cleaning.
Heat and various types of cleaning action like ultrasonics, underwater agitation (like a jacuzzi or tubulation) may be used to
enhance cleaning. In most instances there is significant amount of rinsing with water to displace the cleaning agent. In some
Use and Alternatives Analysis
5-13
Table 5-5: Baseline and Alternative Cleaning Methods and their Definitions
Cleaning Method
Definition
instances, the rinse water may include chemicals (rust preventative (RP)) to forestall corrosion. Depending on the substrate to be
cleaned and the end-use of the product, there is most often a drying step. In our model for cost comparison, we have used a wash
tank followed by rinse tanks followed by a drying chamber. While we have used immersion tanks as a model to describe the
aqueous process to allow comparison among the cleaning processes, in fact there is an enormous variability in aqueous cleaning
processes and aqueous cleaning equipment.
Hybrid system (e.g., Inventec, HEMO)
Use and Alternatives Analysis
Here are a few non-encompassing examples of aqueous cleaning equipment that are not cleaning tanks. For general cleaning
applications, cleaning agent may be applied to the part either by spray or immersion. Rinsing, if it occurs may be as simple as
holding the part over a tap and rinsing all residue down the drain. In some metal cleaning, the part may be washed in a spray
chamber, with or without rinsing. Where rinsing occurs, it may be accomplished by placing the part over a grate and spraying
water on it. Drying may not be necessary. In-line aqueous cleaning equipment is widely used to remove “no-clean” (low residue)
flux from electronics assemblies, post-soldering. The cleaning action (washing and rinsing) typically involves spray-in-air. There
are wash, rinse, and drying chambers. In some applications such as in some hybrid cleaning water (and/or an aqueous cleaner) is
introduced into a chamber containing the parts to be cleaned. Ultrasonic cleaning and/or in cyclic cavitation (cyclic nucleation)
may be used to enhance cleaning.
Hybrid systems use two or more cleaning methods in a single piece of cleaning equipment. Sometimes, the parts are cleaned in a
single chamber and cleaning solutions are introduced. Others systems use sequential chambers. One equipment manufacturer
described the use of an aqueous cleaning step but with a solvent rinse. This would be distinguished from a semi-aqueous process
where the high-solvent cleaner is used for washing and water used for rinsing. As contrasted with co-solvent or bi-solvent
systems, hybrid systems, in our definition, use an aqueous process as one of the methods, either sequentially or together as an
emulsion.
5-14
5.4 Mold Release and Aerosol Spray Cleaning/Degreasing: Mold Releases and
Cleaners
For this report, the categories of mold releases and cleaners were combined, as they are used for similar
purposes and contain similar ingredients. Mold releases are applied to molds between molding cycles to
prevent materials from sticking to the molds. Mold cleaners are used on molds to dissolve and remove
greases, silicones, oils, and residues. Both releases and cleaners are used across a variety of applications
and on different mold materials, including plastics and rubber. The products found in the market review
were aerosols sold in volumes of 12 to 16 ounces.
5.4.1 Solvent Ingredients
The review included one product containing TCE (White 2000 Non-Flammable Mold Cleaner), one
product containing perchloroethylene (Heavy Duty Mold Cleaner), and two products containing 1Bromopropane (General Purpose Silicone Mold Release and Slide Resin Remover Aerosol). The Slide
Resin Remover Aerosol product also contains N-Methyl-2-pyrrolidone. EPA also reviewed five products
containing alternative solvents, including d-limonene, dimethyl ether, and others. Table 5-6 shows the list
of products reviewed for this report and their primary solvent ingredients.
Use and Alternatives Analysis
5-15
Table 5-6: Reviewed Mold Release and Mold Cleaner Products: Safety Data Sheets and Solvent
Ingredients with Concentrations 5% or Higher
Supplier
Product
IMS Company
White 2000 NonFlammable Mold
Cleaner
CRC
Industries, Inc.
CRC
Industries, Inc.
Heavy Duty Mold
Cleaner
General Purpose
Silicone Mold
Release
Slide Resin
Remover Aerosol
Slide Products
Inc.
SDS
SDS date
https://imscompany.com/a
ssets/pdf/sds/118308%20
White%202000%20SDS%
20091718.pdf
http://docs.crcindustries.co
m/msds/1003500E.pdf
http://docs.crcindustries.co
m/msds/1003488E.pdf
9 October 2018
Trichloroethylene
Concentration
(%)
85 - 98
13 September
2017
27 December
2016
Perchloroethylene
90 - 100
Dimethyl ether
1-Bromopropane
60 - 70
20 - 30
https://static.rshughes.com
/wm/p/wmasis/094db1b44335b0d948
f96eb51dd18482b3ab8a19
.pdf?uf=
https://www.smoothon.com/msds/files/Univers
al_Mold_Release_Aerosol
.pdf
01 January 2015
Gamma-butyrolactone
1-Methyl-2-pyrrolidone
1-Bromopropane
35 - 40
35 - 40
25 - 30
31 January 2019
Dimethyl ether
25 - 50
Solvent ingredients
Smooth-On
Universal Mold
Release
CRC
Industries, Inc.
Food Grade Mold
Release
http://docs.crcindustries.co
m/msds/1003498E.pdf
25 November
2016
Dimethyl ether
50 - 60
IMS Company
Biodegradable
Citrus Spray Mold
Cleaner
13 April 2015
D-Limonene
70 - 80
CRC
Industries, Inc.
Heavy Duty
Silicone Mold
Release
https://imscompany.com/a
ssets/pdf/sds/111598%20
Citrus%20SDS%2004131
5.pdf
http://docs.crcindustries.co
m/msds/1003492E.pdf
28 December
2016
Dimethyl ether
40 - 50
CRC
Industries, Inc.
Food Grade Silicone
Mold Release
http://docs.crcindustries.co
m/msds/1003490E.pdf
18 January 2018
Dimethyl ether
50 - 60
Note: Orange shaded row(s) indicate products that contain TCE. Grey shaded row(s) indicate products that contain another one of the
first 10 TSCA work plan chemicals.
Table 5-7 shows the anticipated, approximate market share percentage of primary solvents used in
products estimated using the chemical ranking procedure. If restrictions were implemented for TCE, then
it is anticipated that dimethyl ether would be the most prevalent solvent used in replacement products.
Use and Alternatives Analysis
5-16
Table 5-7: Estimated Percentage Share of Solvent Ingredients for
Reviewed Mold Release and Mold Cleaner Products
Solvent
Current market share
Projected after restrictions
17%
0%
Trichloroethylene
22%
0%
Perchloroethylene
6%
0%
1-Bromopropane
2%
0%
N-Methyl-2-pyrrolidone
41%
78%
Dimethyl ether
9%
18%
D-limonene
2%
4%
Other
Notes: The figures shown here are based on a proxy chemical ranking procedure, which draws
upon factors including concentration in the product and availability and quality of product
reviews. Orange shading indicates TCE. Grey shading indicates another one of the first 10
TSCA work plan chemicals.
5.4.2 Volatile Organic Compounds (VOC) Content
VOC information was reviewed in product SDSs and summarized findings are in Table 5-8. EPA did not
identify any federal or state VOC regulatory limits for mold release or mold cleaner products. The
product containing TCE did not have VOC information in the SDS. The three products containing 1Bromopropane, perchloroethylene, and N-Methyl-2-pyrrolidone had VOC information in their SDSs.
Heavy Duty Mold Cleaner had 0% VOC content, where General Purpose Silicone Mold Release and
Slide Resin Remover Aerosol both had VOC content around 100%. There was VOC information for three
of the five alternative products, ranging from 48.4% (Heavy Duty Silicone Mold Release) to 59.6% (Food
Grade Silicone Mold Release).
Table 5-8: VOC Content for Mold Release and Mold Cleaner Products Based on Information in
SDSs or Technical Data Sheets
Supplier
Product
VOC
(% weight, g/L)
IMS Company
White 2000 Non-Flammable Mold Cleaner
No information in SDS
CRC Industries, Inc.
Heavy Duty Mold Cleaner
0%, 0 g/L
Technical product sheet:
http://api.crcindustries.com/autoservices/get-pds/03315
CRC Industries, Inc.
General Purpose Silicone Mold Release
97%, 756.6 g/L
Slide Products Inc.
Slide Resin Remover Aerosol
100%
Smooth-On
Universal Mold Release
No information in SDS
CRC Industries, Inc.
Food Grade Mold Release
55.8%, 430 g/L
IMS Company
Biodegradable Citrus Spray Mold Cleaner
No information in SDS
CRC Industries, Inc.
Heavy Duty Silicone Mold Release
48.4%, 485 g/L
CRC Industries, Inc.
Food Grade Silicone Mold Release
59.6%, 448 g/L
Note: Orange shaded rows indicate products that contain TCE. Grey shaded rows indicate products that contain another one of
the first 10 TSCA work plan chemicals.
5.4.3 Fire Safety
EPA reviewed flash points and flammability ratings in product SDSs and summarized findings are in
Table 5-9. White 2000 Non-Flammable Mold Cleaner, which contains TCE, was rated non-flammable.
Heavy Duty Mold Cleaner, which contained perchloroethylene, was also rated as non-flammable. The
two products containing 1-Bromopropane did not have flammability ratings available. Four of the
Use and Alternatives Analysis
5-17
alternative products, Universal Mold Release, Food Grade Mold Release, Biodegradable Citrus Spray
Mold Cleaner, and Food Grade Silicone Mold Release were rated non-flammable. Based on the review,
there are non-flammable alternatives to choose from if TCE is restricted in mold release and cleaner
products.
Table 5-9: Flash Point and Flammability Ratings for Mold Release and Mold Cleaner Products
Based on Information in SDSs or Technical Data Sheets
Supplier
IMS Company
CRC Industries, Inc.
CRC Industries, Inc.
Slide Products Inc.
Smooth-On
CRC Industries, Inc.
IMS Company
Product
White 2000 Non-Flammable Mold Cleaner
Heavy Duty Mold Cleaner
General Purpose Silicone Mold Release
Slide Resin Remover Aerosol
Universal Mold Release
Food Grade Mold Release
Biodegradable Citrus Spray Mold Cleaner
Flash Point
Flammability Rating
None
Non-flammable
None
Non-flammable
Not available
None
Not determined
Not determined
>300 °F
Non-flammable
350 °F (176.7 °C)
Non-flammable
Flash point of
Non-flammable
propellant <0 °F
CRC Industries, Inc.
Heavy Duty Silicone Mold Release
Not determined
None
CRC Industries, Inc.
Food Grade Silicone Mold Release
> 572 °F (> 300 °C)
Non-flammable
Note: Orange shaded rows indicate products that contain TCE. Grey shaded rows indicate products that contain another one of the
first 10 TSCA work plan chemicals.
5.4.4 Pricing and Customer Reviews
Pricing and customer review information was accessed on publicly available websites in August 2021 and
summarized findings are in Table 5-10. To assist in comparing prices across various products and product
sizes, the prices were normalized to price per ounce. Pricing for products containing TCE and 1Bromopropane ranged from $0.29 (White 2000 Non-Flammable Mold Cleaner) to $1.37 (General
Purpose Silicone Mold Release) per ounce. Pricing for alternative products ranged from $0.52
(Biodegradable Citrus Spray Mold Cleaner) to $1.75 (Universal Mold Release) per ounce.
Two products containing perchloroethylene and 1-Bromopropane had customer reviews, ranging from 4
(Heavy Duty Mold Cleaner) to 4.5 (General Purpose Silicone Mold Release) with an average rating of
4.3. Three of the alternative products had reviews ranging from 4.4 (Heavy Duty Silicone Mold Release)
to 4.6 (Food Grade Mold Release and Food Grade Silicone Mold Release) with an average rating of 4.5.
The average rating of alternative products was also over 4, indicating overall customer satisfaction with
these products.
Use and Alternatives Analysis
5-18
Table 5-10: Pricing and Customer Review Information for Mold Release and Mold Cleaner Products
Based on Manufacturer and Retailer Web Pages
Supplier
IMS Company
CRC Industries,
Inc.
CRC Industries,
Inc.
Product
White 2000 NonFlammable Mold Cleaner
Heavy Duty Mold Cleaner
General Purpose Silicone
Mold Release
Slide Products
Inc.
Slide Resin Remover
Aerosol
Smooth-On
Universal Mold Release
CRC Industries,
Inc.
IMS Company
Food Grade Mold Release
0CRC
Industries, Inc.
Biodegradable Citrus
Spray Mold Cleaner
Heavy Duty Silicone
Mold Release
Retail information
https://imscompany.com/product/118308
https://www.amazon.com/CRC-HeavyDuty-Cleaner-Aerosol/dp/B00CSX3RO8
https://www.amazon.com/CRC-03300Silicone-ReleaseAerosol/dp/B0013IZSDM
https://www.rshughes.com/p/Slide-TheStripper-Resin-Remover-16-Oz-AerosolCan-14-Oz-Net-Weight-41914/41914/
https://www.amazon.com/SmoothUniversal-Mold-Releasefl/dp/B004BNHLOK
https://www.grainger.com/product/19MW
96
https://imscompany.com/product/111598
Price
per
ounce
$0.29
Customer
ratings
(out of 5)
None
Number of
customer
reviews
None
$0.91
4
2
$1.37
4.5
1,718
$0.60
None
None
$1.75
4.6
1,336
$1.18
None
None
$0.52
None
None
https://www.amazon.com/CRC-Heavy$1.54
4.4
11
Silicone-ReleaseAerosol/dp/B000R80OMO
CRC Industries,
Food Grade Silicone Mold https://www.amazon.com/CRC-03301$0.75
4.6
282
Inc.
Release
Silicone-Release-Weight/dp/B0013J3ZP4
Note: Orange shaded rows indicate products that contain TCE. Grey shaded rows indicate products that contain another one of the first
10 TSCA work plan chemicals.
5.4.5 Conclusion
The review of mold release and mold cleaning products included one product containing TCE, one
product containing perchloroethylene, two products containing 1-Bromopropane and five products
containing alternative solvents. There were no barriers around VOCs, fire safety, or customer satisfaction
that may be caused by restricting the use of TCE in this product category. Alternative products had VOC
content between 45-49%. All the alternative products with flammability information were rated nonflammable. Average customer ratings were above 4 out of 5 for alternative products, indicating overall
customer satisfaction.
5.5 Liquid Cleaners and Degreasers and Aerosol Spray Cleaning/Degreasing: AC
Coil Cleaners
Air conditioner (AC) coil cleaners are used to maintain AC systems by cleaning away dust, dirt, debris,
and buildup from coil fins. Keeping coils clean allows the AC system to transfer heat more efficiently.
Cleaning solvents may be used in conjunction with other cleaning methods, such as blowing compressed
air, vacuuming, or spraying a mixture of household detergent and water with a low-pressure sprayer. Air
conditioner cleaners are available in several forms, including self-rinsing cleaners or foaming cleaners.
These options are available for commercial or consumer use in aerosol form or in bulk form for use in
low-pressure sprayers. Some cleaners require rinsing or wiping of excess solution.
5.5.1 Solvent Ingredients
The review included two products containing TCE, one product containing methylene chloride, and five
products containing chemical alternative solvents, including, diethylene glycol ethyl ether, water, 2-
Use and Alternatives Analysis
5-19
butoxy-ethanol, and others. Table 5-11 shows the list of products reviewed for this analysis and their
primary solvent ingredients.
Table 5-11: Safety Data Sheets and Solvent Ingredients with Concentrations 5% or Higher for Reviewed
AC Coil Cleaners
Supplier
SDS
SDS date
Blast-A-Coil
https://www.parker.com/parkerimages/
Parker.com/Literature/Sporlan/Sporlan
%20pdf%20files/SDS/Blast%20A%20
Coil%20February%202019.pdf?elqTra
ckId=3832459666564432a6bdab823ec
2f110&elqaid=16362&elqat=2
https://www.nucalgon.com/media/475
7/4290-75_sds_eng_v1.pdf
https://www.nucalgon.com/media/475
1/4132-20_sds_eng_v11.pdf
08 February
2019
Evap Foam
No Rinse
Aerosol
https://www.nucalgon.com/media/475
4/4171_sds_eng_v2.pdf
Foaming
Coil Cleaner
http://docs.crcindustries.com/msds/100
3453E.pdf
07 October
2020
Water
2-butoxyethanol
1-5
Nu-Calgon
Evap Pow'r
C (4168)
https://www.nucalgon.com/media/547
9/4168_sds_eng_v1.pdf
13 March
2019
2-butoxyethanol
3-7
Nu-Calgon
Blackhawk
Foaming
Coil Cleaner
https://www.nucalgon.com/media/474
8/4127-75_sds_eng_v1.pdf
26 February
2018
Diethylene glycol
monoethyl ether
2-butoxyethanol
Water
1-5
Parker
Hannifin
Corporation
Nu-Calgon
Nu-Calgon
Nu-Calgon
CRC
Nu-Blast
Aerosol
Cal-Blast
Solvent ingredients
Concentration
(%)
Product
Trichloroethylene
Carbon Dioxide
80 - 100
1-5
Nu-Calgon
Trichloroethylene
95 - 98
26 August
2019
Methylene Chloride
80 - 100
d-Limonene
1-5
26 February
2018
Diethylene glycol
ethyl ether
2-Butoxyethanol
1-5
1-5
60 - 70
1-5
>77
Simple
https://cdn.simplegreen.com/download 1 March
Green®
s/SDS_EN2014
<10
Triethanolamine
Foaming
US_SimpleGreenFoamingCoilCleaner.
<5
Propylene glycol Butyl
pdf
Coil
ether
Cleanernon-aerosol
Note: Orange shaded rows indicate products that contain TCE. Grey shaded rows indicate products that contain another one of the first
10 TSCA work plan chemicals.
Sunshine
Makers, Inc.
Table 5-12 shows the anticipated, approximate market share percentage of primary solvents used in this
product category. This share percentage was estimated using the chemical ranking procedure. If
restrictions were implemented for TCE, then it is anticipated that aqueous and semi-aqueous solutions
would be the most used alternative in replacement products.
Use and Alternatives Analysis
5-20
Table 5-12: Estimated Percentage Market Share of Solvent Ingredients for AC Coil
Cleaners
Solvent
Current market share
Projected after restrictions
20%
0%
Trichloroethylene
20%
0%
Methylene Chloride
42%
70%
Water
7%
11%
2-butoxyethanol
7%
11%
Diethylene glycol monoethyl ether
4%
8%
Other
Notes: The figures shown here are based on a proxy chemical ranking procedure, which draws upon factors
including concentration in the product and availability and quality of product reviews. Orange shading indicates
TCE. Grey shading indicates another one of the first 10 TSCA work plan chemicals.
5.5.2 Volatile Organic Compounds (VOC) Content
VOC information was reviewed in product SDSs and summarized findings are in Table 5-13. No
regulatory VOC limits for AC coil cleaners were identified. There were no VOC content data available
for the two products containing TCE and methylene chloride. Only two products had VOC content
information listed on the SDS: Evap Foam No Rinse Aerosol (10.4%) and Simple Green® Foaming Coil
cleaner- non-aerosol (2%). It was difficult to compare VOC content between products with
trichloroethylene and methylene chloride and alternative products due to lack of VOC information in
SDSs. However, the two alternative products with information had VOC content of around 10% or less,
indicating a market share of low VOC products without TCE.
Table 5-13: VOC Content for AC Coil Cleaners Based on Information in SDSs or Technical Data
Sheets
Supplier
Product
VOC (% weight, g/L)
Parker Hannifin
Corporation
Nu-Calgon
Blast-A-Coil
Nu-Calgon
Cal-Blast
Nu-Calgon
Evap Foam No Rinse Aerosol
No information in SDS; likely high VOC content since
80 to 100% of product is TCE
No information in SDS; likely high VOC content since
95 to 98% of product is TCE
No information in SDS; likely low VOC content since
80 to 100% of product is methylene chloride
10.4%, 113.4 g/L
CRC
Foaming Coil Cleaner
No information in SDS
Nu-Calgon
Evap Pow'r C (4168)
No information in SDS
Nu-Calgon
Blackhawk Foaming Coil Cleaner
No information in SDS
Nu-Blast Aerosol
Sunshine Makers, Inc.
Simple Green Foaming Coil Cleaner- non- 2%, 20 g/L
aerosol
Note: Orange shaded rows indicate products that contain TCE. Grey shaded rows indicate products that contain another one of the
first 10 TSCA work plan chemicals.
5.5.3 Fire Safety
Flash points and flammability ratings were reviewed in product SDSs and summarized findings are in
Table 5-14. The two products containing TCE were rated non-flammable. Cal-Blast containing methylene
chloride was the only product reviewed with a rating of extremely flammable. One alternative product,
Evap Foam No Rinse Aerosol, did not have fire safety data. All other alternative products were rated nonflammable. Based on the review, restricting TCE from AC coil cleaners is unlikely to limit availability of
non-flammable products on the market.
Use and Alternatives Analysis
5-21
Table 5-14: Flash Point and Flammability Ratings for AC Coil Cleaners Based on Information in SDSs
or Technical Data Sheets
Supplier
Parker Hannifin
Corporation
Nu-Calgon
Nu-Calgon
Nu-Calgon
CRC
Nu-Calgon
Nu-Calgon
Sunshine Makers, Inc.
Product
Blast-A-Coil
Flash Point
No information in SDS
Flammability Rating
Non-flammable
Nu-Blast Aerosol
No information in SDS
Non-flammable
Cal-Blast
No information in SDS
Extremely flammable
Evap Foam No Rinse Aerosol
No information in SDS
Non-flammable
Foaming Coil Cleaner
None
No information in SDS
Evap Pow'r C (4168)
No information in SDS
Non-flammable
Blackhawk Foaming Coil Cleaner
No information in SDS
Non-flammable
Simple Green Foaming Coil Cleaner- non- > 212° F (100° C)
Non-flammable
aerosol
Note: Orange shaded rows indicate products that contain TCE. Grey shaded rows indicate products that contain another one of the
first 10 TSCA work plan chemicals.
5.5.4 Pricing and Customer Reviews
Pricing and customer review information was accessed on publicly available websites in July 2021 and
summarized findings are in Table 5-15. To assist in comparing prices across various products and product
sizes, the prices were normalized to price per ounce. Pricing for products containing TCE and methylene
chloride ranged from $0.99 (Cal-Blast) to $1.52 (Nu-Blast Aerosol) per ounce. Pricing for alternative
products ranged from $0.26 (Evap Pow'r C (4168) to $0.90 (Blackhawk Foaming Coil Cleaner) per
ounce. Assuming equal effectiveness per ounce, the price range for alternative products was lower than
price range for products containing TCE.
Cal-Blast and Simple Green Foaming Coil Cleaner- non-aerosol had fewer than 10 reviews. Ratings for
products containing TCE and methylene chloride ranged from 4.4 (Nu-Blast Aerosol) to 5 (Cal-Blast),
with an average rating of 4.7. Ratings for alternative products ranged from 3.7 to 4.6 with an average
rating of 4.2. The average customer rating for alternative products was slightly lower than that of products
with TCE. However, the average rating of alternative products was over 4, indicating overall customer
satisfaction with these products.
Use and Alternatives Analysis
5-22
Table 5-15: Pricing and Customer Review Information for AC Coil Cleaners Based on Manufacturer
and Retailer Web Pages
Supplier
Product
Parker
Hannifin
Corporation
Blast-A-Coil
Nu-Calgon
Nu-Blast
Aerosol
Cal-Blast
Nu-Calgon
Retail information
https://www.ptacsolutions.com/Parker-HannifinVirginia-KMP-BAC20-475248-Blast-A-CoilCLEANER-Case-of-18-oz-Spray-Cans-Case-of12-Cans--Sold-only-by-the-case-not-soldindividually_p_26822.html
https://www.amazon.com/Nu-Calgon-4290-7518-ounce-Condenser/dp/B00HWMXGZA
https://www.amazon.com/Nu-Calgon-4132-20Cal-Blast-Condenser-Cleaner/dp/B01FBXMI1O
https://www.amazon.com/Nu-Calgon-4171-75Rinse-Evaporator-Cleaner/dp/B00DM8KQ3I
Price
per
ounce
$1.40
Number of
Customer
Reviews
None
Customer
ratings
(out of 5)
None
$1.52
25
4.4
$0.99
5
5
$0.61
6099
4.6
Evap Foam
No Rinse
Aerosol
$0.53
545
4.4
CRC
Foaming Coil https://www.amazon.com/CRC-Foaming-CleanerCleaner
Aerosol-Yellow/dp/B009YO1FFM
$0.26
351
4.4
Nu-Calgon
Evap Pow'r C
https://www.amazon.com/Nu-Calgon-4168-08(4168)
Evap-Rinse-Cleaner/dp/B000R7ZS08
$0.90
24
4
Nu-Calgon
Blackhawk
https://www.amazon.com/Nu-Calgon-4127-75Foaming Coil Coil-Cleaner/dp/B00UNRCQQQ
Cleaner
$0.28
6
3.7
Sunshine
Simple Green https://www.amazon.com/SIMPLE-GREENMakers, Inc.
Foaming Coil Condenser-EvaporatorCleaner- non- Cleaner/dp/B01LZHDQGW
aerosol
Note: Orange shaded rows indicate products that contain TCE. Grey shaded rows indicate products that contain another one of the
first 10 TSCA work plan chemicals.
Nu-Calgon
5.5.5 Conclusion
The market review of AC coil cleaners included one product containing TCE, one product containing
methylene chloride and five products containing a variety of alternative solvents. Barriers were not found
for fire safety, pricing, or customer satisfaction that may be caused by restricting use of TCE in this
product category. VOCs were more difficult to compare, as none of the products containing TCE and
most of the alternative products lacked VOC information in their SDSs. However, two of the alternative
products had VOC content close to or lower than 10%, showing that there are alternative low VOC
options on the market. Most of the alternative products reviewed were rated non-flammable. The price
range for alternative products was lower than price range for products containing TCE. Average customer
ratings of alternative products were slightly lower than that of products containing TCE. Customer
satisfaction was still high for alternative product ratings, as average ratings were over 4 out of 5 stars. In
summary, based on the factors considered in this review, alternatives that appear to be technologically
and economically feasible for users are available for TCE for this product category.
5.6 Liquid Cleaners and Degreasers and Aerosol Spray Cleaning/Degreasing:
Energized Electrical Equipment Degreasers
Energized electrical equipment degreasers and cleaners are used to remove dust, dirt, grease, and
oxidation from electronic components that are energized while they are being cleaned or may be
energized before the solvent evaporates. These products are like general electronic degreasers but are
formulated to have high flash points and high dielectric strength (maximum electric field that the cleaner
can withstand before insulating properties break down). The product search yielded limited results for
products labeled for specialized use on energized equipment, and there is some overlap with products in
Use and Alternatives Analysis
5-23
the electronics degreasers product category (CRC's Electrical Parts Cleaner). Products are sold in aerosol
(around 12 - 19 ounces) and liquid form (1 gallon or more), both represented in the product review.
5.6.1 Solvent Ingredients
The review included one product with TCE and two products with perchloroethylene. EPA also reviewed
two products containing alternative solvents, including trans-DCE and methylcyclohexane. Table 5-16
shows the list of products reviewed for this analysis and their primary solvent ingredients.
Table 5-16: Safety Data Sheets and Solvent Ingredients with Concentrations 5% or Higher for Reviewed
Energized Electrical Equipment Degreasers
Product
SDS
SDS date
Berryman
Energized Electrical
Parts Cleaner
22 December
2020
Trichloroethylene
CRC
Lectra Clean Heavy
Duty Energized
Electrical Parts
Degreaser
Electrical Parts
Cleaner
Pow-R-Wash CZ
https://www.berrymanprodu
cts.com/assets/5B-15201540-SDS-R02.pdf
http://docs.crcindustries.com
/msds/1003182E.pdf
Concentration
(%)
>90
01 November
2017
Perchloroethylene
90 - 100
http://docs.crcindustries.com
/msds/1003236E.pdf
https://www.chemtronics.co
m/content/msds/ES7300,%2
0ES7308_United%20States
%20(US)%20SDS%20HCS
%202012_English%20(US).
pdf
25 October
2017
1 July 2019
Perchloroethylene
90 - 100
Supplier
CRC
Chemtronics
Solvent ingredients
Trans DCE
Methylcyclohexane
≥10 - ≤25
≤5
10 - 15
https://www.chemtronics.co
4 May 2015
Trans DCE
m/content/msds/DEL1681_I
SS%20SDS%20GHS%20Un
ited%20States%20(US)%20%20HCS%202012%20V4.4
_English%20(US).pdf
Note: Orange shaded rows indicate products that contain TCE. Grey shaded rows indicate products that contain another one of the first
10 TSCA work plan chemicals.
Chemtronics
Pow-R-Wash Delta
Table 5-17 shows the anticipated, approximate market share percentage of primary solvents used in
products estimated using the chemical ranking procedure. Perchloroethylene is currently the most used
solvent in energized electrical equipment degreaser products. If restrictions were implemented for TCE,
then it is anticipated that trans-DCE and methylcyclohexane would be the most prevalent solvents used in
replacement products.
Use and Alternatives Analysis
5-24
Table 5-17: Estimated Percentage Share of Solvent Ingredients for Reviewed
Energized Electrical Equipment Degreasers
Solvent
Current market share
Projected after restrictions
25%
0%
Trichloroethylene
65%
0%
Perchloroethylene
10%
100%
Trans DCE with Methylcyclohexane
0%
0%
Other
Notes: The figures shown here are based on a proxy chemical ranking procedure, which draws upon factors
including concentration in the product and availability and quality of product reviews. Orange shading
indicates TCE. Grey shading indicates another one of the first 10 TSCA work plan chemicals.
5.6.2 Volatile Organic Compounds (VOC) Content
EPA reviewed VOC information in product SDSs and summarized the findings in Table 5-18. No
regulatory VOC limits were identified specific for energized electrical equipment degreasers; however,
regulatory VOC limits were identified for electronics cleaners in several states (75%). The two products
containing perchloroethylene, Lectra Clean Heavy Duty Energized Electrical Parts Degreaser and
Electrical Parts Cleaner, had 0% VOC, and Energized Electrical Parts Cleaner containing TCE contained
less than 90% VOC. The two alternative products did not have VOC data in their SDSs. Therefore, more
research is needed to understand how availability of low VOC products on the market may be affected
with restrictions on TCE in this product category.
Table 5-18: VOC Content for Energized Electrical Equipment Degreasers Based on Information in
SDSs or Technical Data Sheets
Supplier
Product
VOC
(% weight, g/L)
Berryman
Energized Electrical Parts Cleaner
>90%
CRC
Lectra Clean Heavy Duty Energized Electrical Parts Degreaser
0%
CRC
Electrical Parts Cleaner
0%
Chemtronics
Pow-R-Wash CZ
No information in SDS
Chemtronics
Pow-R-Wash Delta
No information in SDS
Note: Orange shaded rows indicate products that contain TCE. Grey shaded rows indicate products that contain another one of
the first 10 TSCA work plan chemicals.
5.6.3 Fire Safety
EPA reviewed flash points and flammability ratings in product SDSs and summarized the findings in
Table 5-19. All five of the products reviewed were rated non-flammable. Restricting TCE in this product
category is unlikely to affect non-flammable options currently on the market as energized electrical
degreasers are formulated to have non-flammable properties.
Table 5-19: Flash Point and Flammability Ratings for Energized Electrical Equipment
Degreasers Based on Information in SDSs or Technical Data Sheets
Supplier
Berryman
CRC
Product
Flash Point
Flammability Rating
Energized Electrical Parts Cleaner
None
Non-flammable
Lectra Clean Heavy Duty Energized Electrical None
Non-flammable
Parts Degreaser
CRC
Electrical Parts Cleaner
None
Non-flammable
Chemtronics
Pow-R-Wash CZ
None
Non-flammable
Chemtronics
Pow-R-Wash Delta
>199.9° F (>93.3° C)
Non-flammable
Note: Orange shaded rows indicate products that contain TCE. Grey shaded rows indicate products that contain another one
of the first 10 TSCA work plan chemicals.
Use and Alternatives Analysis
5-25
5.6.4 Pricing and Customer Reviews
EPA accessed pricing and customer review information on publicly available websites in August and May
2022 and summarized the findings in Table 5-20. To assist in comparing prices across various products
and product sizes, the prices were normalized to price per ounce. Pricing for products containing TCE or
perchloroethylene ranged from $0.57 (Energized Electrical Parts Cleaner) to $2.31 per ounce (Lectra
Clean Heavy Duty Energized Electrical Parts Degreaser). Pricing for alternative products ranged from
$2.74 (Pow-R-Wash Delta) to $5.63 (Pow-R-Wash CZ) per ounce. The price range for alternative
products was higher than the price range for products containing TCE.
It was not possible to compare customer satisfaction between products containing TCE and alternative
products, as only two products, both containing perchloroethylene or TCE had customer review
information. Electrical Parts Cleaner had an average rating of 4.3, and Energized Electrical Parts Cleaner
had a rating of 5 (product had fewer than 10 reviews).
Table 5-20: Pricing and Customer Review Information for Energized Electrical Equipment Degreasers
Based on Manufacturer and Retailer Web Pages
Supplier
Product
Berryman
Energized Electrical
Parts Cleaner
CRC
Lectra Clean Heavy
Duty Energized
Electrical Parts
Degreaser
Electrical Parts Cleaner
Retail information
https://www.amazon.com/BerrymanProducts-1540-EnergizedElectric/dp/B072JSKVD2
https://www.amazon.com/CRC-02020CSEnergized-ElectricalDegreaser/dp/B01MYFCVIO
Price
per
ounce
$0.57
$2.31
Customer
ratings
(out of 5)
5
None
Number of
customer
reviews
4
None
$0.96
4.3
55
https://www.amazon.com/CRC-ElectricalLiquid-CleanerAerosol/dp/B000P1HKFW
$5.63
None
None
Chemtronics
Pow-R-Wash CZ
https://www.chemtronics.com/pow-rwash-cz
$2.74
None
None
Chemtronics
Pow-R-Wash Delta
https://www.chemtronics.com/pow-rwash-delta-2
Note: Orange shaded rows indicate products that contain TCE. Grey shaded rows indicate products that contain another one of the
first 10 TSCA work plan chemicals.
CRC
5.6.5 Conclusion
The review included one product containing TCE, two products containing perchloroethylene, and two
products containing alternative solvents. No barriers were found around fire safety which may be caused
by restricting use of TCE in this product category, as energized electrical degreasers are formulated to
have non-flammable properties. It was not possible to compare VOC or customer satisfaction due to lack
of information for alternative products. The price range for alternative products was higher than the price
range for products containing TCE which may be a barrier. However, the review was limited, and there
may more affordable electronics degreasers on the market that can be used on energized equipment, like
CRC's Electrical Parts Cleaner, that use alternative solvents.
5.7 Lubricants and Greases
Lubricants are used on metals to reduce friction, clean, and/ or protect against corrosion and rust. There
are many types of lubricants on the market ranging for specialized uses, such as anti-seize and wire
lubricants, to more general use lubricants, such as multi-purpose lubricants and penetrants. Products are
sold in liquid, liquid spray, and aerosol form. Many lubricants are available for commercial and consumer
use; however, these are likely available in larger quantities for industrial use as well. The review focuses
Use and Alternatives Analysis
5-26
on multi-purpose lubricants and penetrants in liquid spray or aerosol form in volumes from 11 to 14
ounces.
5.7.1 Solvent Ingredients
The review included products with perchloroethylene and TCE. Four products were also reviewed
containing alternative solvents, including heptane, LVP Aliphatic Hydrocarbon, C9-11-iso-alkanes,
petroleum distillates, and others. Table 5-21 shows the list of products reviewed for this analysis and their
primary solvent ingredients.
Table 5-21: Safety Data Sheets and Solvent Ingredients with Concentrations 5% or Higher for
Reviewed Multi-Purpose Lubricants
Supplier
Zep
Sprayway
CRC
WD-40
Product
Zep 45
L2 Moisture
Displacer Deep
Penetrant
Dry Graphite Lube
WD-40 Multi-Use
Product Aerosol
SDS
SDS date
https://zsds3.zepinc.com/e
hswww/zep/result/direct_l
ink.jsp?P_LANGU=E&P_
SYS=2&P_SSN=11337&
C001=MSDS&C002=US
&C003=E&C013=17401
&C123=SDS*
18 June 2018
https://www.spraywayinc.
com/sites/all/themes/them
e687/msds/sw290.pdf
https://docs.crcindustries.c
om/MSDS/3094.pdf
09 December
2019
13 December
2017
Solvent ingredients
Trichloroethylene
Distillates (petroleum),
hydrotreated heavy
naphthenic
Distillates (petroleum),
straight-run middle
2-(2-butoxyethoxy)
ethanol
Perchloroethylene
Heptane
Isopropyl alcohol
n-heptane
LVP Aliphatic
Hydrocarbon
Concentration
(%)
≥30 - < 50
≥20 - < 30
≥5 - < 10
≥1 - < 5
50 - <100%
30 - 40
20 - 30
10 - 20
45-50
https://images.thdstatic.co
5 March 2019
m/catalog/pdfImages/df/df
ea3209-9e1f-4185-a5966a59a2f17ff9.pdf
30 - 60
B'laster
Silicone Lubricant
https://blasterproducts.co
20 October 2020 Alkanes, C9-11-isom/wp15 - 40
Petroleum distillates,
content/uploads/2018/04/S
hydrotreated light
L-Silicone-LubricantAerosol-EN-OSHA-GHSSDS-2020-10-20.pdf
50 - 75
Super Lube
Super Lube Multihttps://images.thdstatic.co
14 August 2019
Distillates (petroleum),
Purpose Synthetic
m/catalog/pdfImages/a1/a
hydrotreated light
Lubricant
107e724-a1f8-465b-80f1a0f67e6086ff.pdf
Note: Orange shaded rows indicate products that contain TCE. Grey shaded rows indicate products that contain another one of the first
10 TSCA work plan chemicals.
Table 5-22 shows the anticipated, approximate market share percentage of primary solvents used in
products estimated using the chemical ranking procedure. Petroleum distillates is currently the most used
solvent in lubricants. If restrictions were implemented for TCE, then it is anticipated that petroleum
distillates would be the most prevalent solvent used in replacement products.
Use and Alternatives Analysis
5-27
Table 5-22: Estimated Percentage Share of Solvent Ingredients for
Reviewed Multi-Purpose Lubricants
Solvent
Current market share
Projected after restrictions
11%
0%
Trichloroethylene
24%
0%
Perchloroethylene
49%
75%
Petroleum distillates
7%
10%
Heptane
5%
8%
Isopropyl alcohol
4%
7%
Other
100%
100%
Total
Notes: The figures shown here are based on a proxy chemical ranking procedure, which draws upon
factors including concentration in the product and availability and quality of product reviews.
Orange shading indicates TCE. Grey shading indicates another one of the first 10 TSCA work plan
chemicals.
5.7.2 Volatile Organic Compounds (VOC) Content
EPA reviewed VOC information in product SDSs and summarized findings in Table 5-23. EPA identified
VOC limits for several lubricant types in several states, including multipurpose (25 - 50%) and silicone
multipurpose lubricants (60%) excluding dry lubricants (such as CRC's Dry Graphite Lube), and
penetrants (25 - 50%). The two products containing perchloroethylene and TCE did not have VOC data in
their SDSs. Only two of the alternative products had VOC content information. Dry Graphite Lube and
Silicone Lubricant had high VOC content at 97.9% and WD-40 Multi-Use Product Aerosol had lower
VOC content around 24%. VOC content could not be compared between products containing
perchloroethylene and TCE with alternative products due to lack of VOC data for alternatives. At least
one lubricant product (WD-40 Multi-Use Product Aerosol meets VOC requirements, but more research is
needed to fully determine if low VOC alternatives are available.
Table 5-23: VOC Content for Multi-Purpose Lubricants Based on Information in
SDSs or Technical Data Sheets
Supplier
Product
VOC
(% weight, g/L)
Zep
Zep 45
No information in SDS
Sprayway
L2 Moisture Displacer Deep Penetrant
No information in SDS
CRC
Dry Graphite Lube
97.9%
WD-40
WD-40 Multi-Use Product Aerosol
24.1%
B'laster
Silicone Lubricant
No information in SDS
Super Lube
Super Lube Multi-Purpose Synthetic Lubricant
No information in SDS
Note: Orange shaded rows indicate products that contain TCE. Grey shaded rows indicate products that
contain another one of the first 10 TSCA work plan chemicals.
5.7.3 Fire Safety
Flash points and flammability ratings in product SDSs were reviewed and summarized findings are in
Table 5-24. The six products reviewed had mixed flammability ratings. The two products containing
perchloroethylene and TCE, L2 Moisture Displacer Deep Penetrant and Zep 45 had ratings of
combustible and non-flammable respectively. Two of the alternative products are aerosols and were rated
extremely flammable (Dry Graphite Lube and Super Lube Multi-Purpose Synthetic Lubricant) and two
were rated combustible. It is unclear how restriction of TCE in this product category will affect fire
safety, which depends, in part, on whether products utilize aerosol delivery. The review shows one nonflammable option and one combustible option that would be eliminated, leaving behind combustible and
Use and Alternatives Analysis
5-28
extremely flammable options. The review was limited and may not have captured the alternative products
with the lowest flammability ratings available.
Table 5-24: Flash Point and Flammability Ratings for Multi-Purpose Lubricants Based on Information
in SDSs
Supplier
Zep
Sprayway
CRC
WD-40
B'laster
Super Lube
Product
Flash Point
Flammability Rating
Zep 45
Not applicable
Non-flammable
L2 Moisture Displacer Deep Penetrant
>106 °F (> 41 °C)
Combustible
Dry Graphite Lube
-20.2 °F (-29 °C)
Extremely flammable, aerosol
WD-40 Multi-Use Product Aerosol
138 °F (59 °C)
Combustible
Silicone Lubricant
130 °F (54 °C)
Combustible
Super Lube Multi-Purpose Synthetic
No information in SDS
Extremely flammable, aerosol
Lubricant
Note: Orange shaded rows indicate products that contain TCE. Grey shaded rows indicate products that contain another one of the first
10 TSCA work plan chemicals.
5.7.4 Pricing and Customer Reviews
Pricing and customer review information was assessed on publicly available websites in May 2022 and a
summary of the findings are in Table 5-25. To assist in comparing the prices across various products and
product sizes, the prices were normalized to price per ounce. Pricing for products containing
perchloroethylene and TCE ranged from $1.08 (L2 Moisture Displacer Deep Penetrant) to $1.21 per
ounce (Zep 45). Pricing for alternative products ranged from $0.41 (Silicone Lubricant) to $1.10 (Dry
Graphite Lube) per ounce. Three alternative products (Silicone Lubricant, WD-40, and Super Lube) had
lower prices than any of the products containing TCE.
All products in the review had customer reviews. The ratings for products containing perchloroethylene
and TCE ranged from 4.1 (L2 Moisture Displacer Deep Penetrant, note this product had fewer than 10
reviews) to 4.8 (Zep 45) with an average rating of 4.5. Customer ratings for alternative products ranged
from 3.9 (WD-40 Multi-Use Product Aerosol) to 4.9 (Super Lube Multi-Purpose Synthetic Lubricant)
with an average of 4.6. Based on the similar average customer ratings for both groups of products,
products containing alternative solvents may have similar customer satisfaction as products containing
TCE.
Use and Alternatives Analysis
5-29
Table 5-25: Pricing and Customer Review Information for Multi-purpose Lubricants Based on
Manufacturer and Retailer Web Pages
Supplier
Product
Zep
Zep 45
Sprayway
L2 Moisture
Displacer Deep
Penetrant
Dry Graphite Lube
CRC
WD-40
WD-40 Multi-Use
Product Aerosol
B'laster
Silicone Lubricant
Retail information
https://www.amazon.com/Zep-LubricantPenetrant-Aerosol-374301/dp/B082Q6DNLV
https://www.amazon.com/Sprayway-SW290Moisture-Displacer-Penetrant/dp/B001JN0VIS
https://www.amazon.com/CRC-Graphite-LubeAerosol-Black/dp/B007I9XUD0
https://www.homedepot.com/p/WD-40-12-ozMulti-Use-Product-Multi-Purpose-LubricantSpray-with-Smart-Straw-49005/204777420
https://www.homedepot.com/p/Blaster-11-oz-Blaster-Silicone-Lubricant-16-SL/202529794
https://www.homedepot.com/p/Super-Lube-11-ozAerosol-31110/202932707
Price
per
ounce
$1.21
Customer
ratings
(out of 5)
4.8
Number of
customer
reviews
34
$1.08
4.1
3
$1.10
5
908
$0.46
3.9
451
$0.41
4.5
168
$0.63
4.9
51
Super Lube MultiPurpose Synthetic
Lubricant
Note: Orange shaded rows indicate products that contain TCE. Grey shaded rows indicate products that contain another one of the first
10 TSCA work plan chemicals.
Super Lube
5.7.5 Conclusion
The review focused only on multi-purpose lubricants and penetrants in liquid spray or aerosol form and
included one product containing TCE, one product containing perchloroethylene, and four products
containing alternative solvents. There were no barriers found around pricing and customer satisfaction.
VOC was unable to be compared due to lack of VOC information in SDSs for products containing
perchloroethylene and TCE. For fire safety, the non-aerosol alternatives are combustible which may be
acceptable replacements for product containing TCE. Three alternative products (Silicone Lubricant,
WD-40, and Super Lube) had lower prices than the product containing TCE. Average customer
satisfaction ratings were similar between the product with TCE and products using alternative solvents.
5.8 Adhesives, Sealants, Paints and Coatings: Adhesives
An adhesive is a formulated product that binds two objects together and can be applied to one or both
surfaces of the two initially separate objects. Adhesives are often referred to as "glue," "paste," or
"cement." There are many methods for curing adhesives. These include evaporative drying for solventbased adhesives, cooling for hot melt adhesives, contact, and light pressure for pressure sensitive
adhesives. Factors affecting choice of adhesive product include drying time, cure time, bond strength,
substrate compatibility, application temperature, and interior/exterior use.
The product category is vast and diverse; there are many adhesives on the market formulated for different
purposes, substrates, application methods, and users. The Chemical Economics Handbook divides
adhesives into five categories -- water emulsions, hot-melts, solvent-based, reactive, and natural
polymers. (IHS Markit 2019) It is beyond the scope of this analysis to investigate products for each
adhesive application. Instead, the analysis includes two general purpose adhesives (high strength mist
spray adhesive and high strength non-spray adhesive) and one specific purpose adhesive (for acrylic
substrate). The results for these types of adhesives may or may not be representative for other adhesive
applications.
Use and Alternatives Analysis
5-30
5.8.1 Solvent Ingredients
The review included one product containing both TCE and methylene chloride, one product containing
methylene chloride, and one product containing perchloroethylene. Four products containing alternative
solvents, including methyl acetate, toluene, acetone, and others were also reviewed. Table 5-26 shows the
list of products reviewed for this analysis and their primary solvent ingredients.
Table 5-26: Safety Data Sheets and Solvent Ingredients with Concentrations 5% or Higher for Reviewed
Adhesives
Supplier
Product
Application
Acrylic
IPS
Weld On #3
Acrylic Plastic
Cement
3M
3M™ HiStrength NonFlammable
98NF Bulk
Adhesive
High
strength
spray
E6000
E6000 MV clear
industrial
strength
adhesive
High
strength
non-spray
3M
Scotch-Weld
Low Odor
Acrylic
Adhesive
DP8810N
Acrylic
Gorilla
Heavy Duty
Spray Adhesive
High
strength
spray
Homax
All Purpose
Adhesive
Industrial
Strength Welder
High
strength
non-spray
https://www.acplasticsi
nc.com/media/WeldOn%203%20SDS.pdf
6 May 2015
Methylene Chloride
Trichloroethylene
Concentration (%)
75 - 90
5 - 15
https://multimedia.3m.c
om/mws/mediawebserv
er?mwsId=SSSSSuUn_
zu8l00xM82SNY_Bnv7
0k17zHvu9lxtD7SSSSS
S-https://images.thdstatic.
com/catalog/pdfImages/
c3/c362ff98-80804009-984e3cf4c0cde7db.pdf
https://multimedia.3m.c
om/mws/mediawebserv
er?mwsId=SSSSSuUn_
zu8l00xm8txoxmZlv70
k17zHvu9lxtD7SSSSSS
-https://gorillaglue.com.a
u/wpcontent/uploads/GorillaSpray-Adhesive-1.pdf
5 August 2019
Methylene Chloride
60 - 85
6 May 2020
Perchloroethylene
11 November
2019
Dibenzoate Propanol
24 February
2019
Methyl acetate
Acetone
Cyclohexane
10 - 30
10 - 30
10 - 30
https://bigcatrescue.org/
wpcontent/uploads/2014/0
4/HouseholdWelder.pdf
https://dm.henkeldam.com/is/content/hen
kel/sds-us-loctite-sprayadhesive-professionalperformance
21 March 2006
Toluene
30 - 60
SDS
SDS date
Solvent ingredients
≥50 - ≤72
80
30 - 60
Acetone
5 - 10
Methyl acetate
5 - 10
Naphtha, petroleum,
hydrotreated light
5 - 10
Parachlorobenzotrifluori
de
5 - 10
n-Heptane
5 - 10
Methylcyclohexane
Note: Orange shaded rows indicate products that contain TCE. Grey shaded rows indicate products that contain another one of the first
10 TSCA work plan chemicals.
Henkel
Loctite
Professional
Performance
Spray Adhesive
High
strength
spray
7 November
2018
Table 5-27 shows the anticipated, approximate market share percentage of primary solvents used in
products estimated using the chemical ranking procedure. If restrictions were implemented for TCE, then
it is anticipated that acetone would be the most prevalent solvent used in replacement products. In
Use and Alternatives Analysis
5-31
addition, a process change (e.g., adoption of a hot-melt technology) may be an option in some cases.
There are several solvents used in alternative products that contain GreenScreen Benchmark 1 chemicals
such as toluene and Parachlorobenzotrifluoride. 9 These Benchmark 1 solvents are potential regrettable
substitutions for TCE. There are numerous commercially available alternative products for adhesive
products without Benchmark 1 solvents.
8F
Table 5-27: Estimated Percentage Share of Solvent Ingredients for Reviewed
Adhesive Applications Only
Solvent
Current market share
Projected after restrictions
2%
0%
Trichloroethylene
32%
0%
Methylene Chloride
13%
0%
Perchloroethylene
15%
28%
Acetone
12%
24%
Dibenzoate propanol
8%
15%
Methyl acetate
7%
13%
Toluene
4%
8%
Cyclohexane
6%
12%
Other
Notes: The figures shown here are based on a proxy chemical ranking procedure, which draws upon
factors including concentration in the product and availability and quality of product reviews. Orange
shading indicates TCE. Grey shading indicates another one of the first 10 TSCA work plan chemicals.
5.8.2 Volatile Organic Compounds (VOC) Content
The VOC information was reviewed in product SDSs and summarized findings are in Table 5-28. The
VOC limit for mist spray adhesives is 30% in California and 65% for many other states. The VOC limit
for general purpose adhesives is 10% for the EPA and many states. A VOC limit for acrylic specific
adhesives was not identifiable, e.g., Weld On #3 Acrylic Plastic Cement.
Two of the products containing methylene chloride and TCE had VOC content data available: 3M HiStrength Non-Flammable 98NF Bulk Adhesive (0 g/L) and Weld On #3 Acrylic Plastic Cement (> 250
g/L). The 3M Hi-Strength Non-Flammable 98NF Bulk Adhesive product would meet the VOC limit for
general purpose adhesives. Two alternative products had VOC content information: Loctite Professional
Performance Spray Adhesive (38.8%), and 3M Scotch-Weld Low Odor Acrylic Adhesive DP8810N (59.4
g/L). The Loctite Professional Performance Spray Adhesive would meet the VOC limit for spray
adhesives in all states except California. VOC content information was not available for the other two
alternative products (Gorilla and Homax).
9
GreenScreen for Safer Chemicals is a method for chemical hazard assessment designed to identify chemicals of
high concern and safer alternatives. Each chemical evaluated under GreenScreen is assigned a Benchmark
between 1 and 4, with each increasing Benchmark defining progressively safer chemicals. See GreenScreen®
Method | GreenScreen® For Safer Chemicals (greenscreenchemicals.org), https://www.greenscreenchemicals.org/learn/fullgreenscreen-method.
Use and Alternatives Analysis
5-32
Table 5-28: VOC Content for Adhesives Based on Information In SDSs or Technical Data Sheets
Supplier
Product
VOC
(% weight, g/L)
IPS
Weld On #3 Acrylic Plastic Cement
250 g/L
3M
3M Hi-Strength Non-Flammable 98NF Bulk Adhesive
VOC Less H2O & Exempt Solvents: 0 g/L
E6000
E6000 MV clear industrial strength adhesive
No information in SDS
3M
Scotch-Weld Low Odor Acrylic Adhesive DP8810N
59.4 g/L
Gorilla
Heavy Duty Spray Adhesive
No information in SDS
Homax
All Purpose Adhesive Industrial Strength Welder
No information in SDS
Henkel
Loctite Professional Performance Spray Adhesive
38.8%
Note: Orange shaded rows indicate products that contain TCE. Grey shaded rows indicate products that contain another one of
the first 10 TSCA work plan chemicals.
5.8.3 Fire Safety
The flash points and flammability ratings in product SDSs were reviewed and summarized findings are in
Table 5-29. The product containing TCE and methylene chloride was rated non-flammable. The
alternative products were rated non-flammable, flammable, or extremely flammable. Restricting TCE in
this product categories may limit non-flammable options currently on the market. However, this product
review was limited, and other non-flammable adhesive options are likely to be available for other
adhesive types.
Table 5-29: Flash Point and Flammability Ratings for Adhesives Based on Information in SDSs Or
Technical Data Sheets
Supplier
Product
Flash Point
Flammability Rating
IPS
Weld On #3 Acrylic Plastic Cement
None
Non-flammable
3M
3M Hi-Strength Non-Flammable 98NF Bulk Adhesive
No flash point
Non-flammable
E6000
E6000 MV clear industrial strength adhesive
>230° F (>110° C)
Non-flammable
3M
Scotch-Weld Low Odor Acrylic Adhesive DP8810N
> 200 F
Non-flammable
Gorilla
Heavy Duty Spray Adhesive
-155° F (-104° C)
Extremely flammable
Homax
All Purpose Adhesive Industrial Strength Welder
45 °F (7° C)
Flammable
Henkel
Loctite Professional Performance Spray Adhesive
-155° F (-104° C)
Extremely flammable
Note: Orange shaded rows indicate products that contain TCE. Grey shaded rows indicate products that contain another one of the first
10 TSCA work plan chemicals.
5.8.4 Pricing and Customer Reviews
Pricing and customer review information was assessed on publicly available websites in August 2021 and
a summary of the findings is in Table 5-30. To assist in comparing prices across various products and
product sizes, the prices were normalized to price per ounce. Reviewed products ranged widely in volume
from two ounces (E6000 MV clear industrial strength adhesive and All Purpose Adhesive Industrial
Strength Welder) to 54 gallons (3M Hi-Strength Non-Flammable 98NF Bulk Adhesive).
Pricing for products containing TCE, methylene chloride and perchloroethylene ranged from $0.43 (3M
Hi-Strength Non-Flammable 98NF Bulk Adhesive; note that this product volume was 54 gallons) to
$4.24 per ounce. Pricing for alternative products ranged from $0.68 (Heavy Duty Spray Adhesive) to
$4.55 (All Purpose Adhesive Industrial Strength Welder) per ounce. The price range for alternative
products had considerable overlap with products containing TCE, methylene chloride and
perchloroethylene.
Two of the products containing TCE, methylene chloride and perchloroethylene had reviews of 4.7
(E6000 MV clear industrial strength adhesive) and 4.6 (Weld On #3 Acrylic Plastic Cement) with an
average rating around 4.7. Ratings for alternative products ranged from 3.5 to 5.0 with an average rating
Use and Alternatives Analysis
5-33
of 4.4. The average customer ratings for alternative products were slightly lower than those of products
with TCE. However, the average rating of alternative products was 4.4, indicating overall customer
satisfaction with these products.
Table 5-30: Pricing and Customer Review Information for Adhesives Based on Manufacturer and
Retailer Web Pages
Supplier
IPS
Product
Weld On #3 Acrylic
Plastic Cement
Retail information
https://www.amazon.com/Weld-AcrylicPlastic-Cement-Applicator/dp/B0149IG548
Price
per
ounce
$4.22
Customer
ratings
(out of 5)
4.6
Number of
customer
reviews
826
$0.43
None
None
3M Hi-Strength Nonhttps://www.amazon.com/3M-Scotch-WeldFlammable 98NF Bulk
98NF-Spray-Adhesive/dp/B0046VQQBG
Spray Adhesive
$4.24
4.7
4,523
E6000
E6000 MV clear
https://www.homedepot.com/p/E6000-2-flindustrial strength
oz-Clear-Adhesive-237032/203279322
adhesive
$1.13
5.0
2
3M
Scotch-Weld Low Odor
https://www.amazon.com/3M-Scotch-WeldAcrylic Adhesive
Acrylic-AdhesiveDP8810N
DP8810NS/dp/B00IOQ6W0E
$0.68
4.5
5,390
Gorilla
Heavy Duty Spray
https://www.amazon.com/dp/B0752XM8V
Adhesive
N
$4.55
4.7
170
Homax
All Purpose Adhesive
https://www.amazon.com/PurposeIndustrial Strength
Adhesive-Industrial-StrengthWelder
Welder/dp/B074M7BW62
$0.73
3.5
10
Henkel
Loctite Professional
https://www.homedepot.com/p/LoctitePerformance Spray
Professional-Performance-13-5-oz-SprayAdhesive
Adhesive-1629134/205506865
Note: Orange shaded rows indicate products that contain TCE. Grey shaded rows indicate products that contain another one of the
first 10 TSCA work plan chemicals.
3M
5.8.5 Conclusion
The market review of adhesives was limited to three representative types of adhesives. The review
included one product containing methylene chloride, one product containing both TCE and methylene
chloride, one product containing perchloroethylene, and several products containing alternative solvents.
At least one alternative product would meet the VOC limit for spray adhesives in all states except
California. Restricting TCE in the adhesives reviewed here may potentially limit non-flammable options
currently on the market. However, the product review was limited, and other non-flammable adhesive
options may be available. In addition, the review did not include non-solvent-based adhesive technologies
which may be adopted through a process change. The price range for alternative products had
considerable overlap with products containing trichlorethylene. Average customer ratings of alternative
products were slightly lower than that of products containing TCE. Customer satisfaction was still high
for alternative product ratings, as average ratings were 4.4 out of 5 stars.
5.9 Adhesives, Sealants, Paints and Coatings: Cold pipe insulation
Cold pipe insulation products are aerosols or paints used on "cold pipes," such as air conditioning lines,
refrigeration lines, to create a moisture barrier and eliminate condensation buildup resulting in sweating
and dripping. Sprays are typically used in hard-to-reach areas or odd shaped fittings. There seems to be a
limited market for these sprays and paints, as EPA identified few products to review. There are many
other methods and products used to insulate cold pipes available, particularly for lengths of straight pipe,
including flexible foam and mineral fiber insulation. Most products identified were sold in 15-ounce
Use and Alternatives Analysis
5-34
aerosol cans. However, this analysis also included two paint-on products available in liquid form and
larger volumes as potential alternatives.
5.9.1 Solvent Ingredients
EPA’s review of cold pipe insulation products identified four cold pipe insulation products containing
TCE and one product containing methylene chloride. EPA also reviewed one product containing
alternative solvents, though limited information was available on the composition of this product. Table
5-31 shows the list of products reviewed for this analysis and their primary solvent ingredients.
Table 5-31: Safety Data Sheets and Solvent Ingredients with Concentrations 5% or Higher for
Reviewed Cold Pipe Insulation Products
Supplier
Product
Brodi
Specialty
Products
CPC
Pipe Wrap
Creative
Chemical
Anti-Sweat 2.0
Cold Pipe
Insulator Spray
Sprayway
Sprayway Cold
Pipe Insulation
Quest
Specialty
Corporation
Robson
Thermal
Surround Cold
Pipe Insulation
Spray
No-Sweat FX
Terand Cold Pipe
Insulation
https://www.brodi.com/index.
php?route=product/sds/downl
oad&sds_id=276
https://www.technoms.com/mtcontent/uploads/2016/08/770sds-cold-pipe.pdf
https://www.adcosupplies.com
/index.php/product/anti-sweat2-0-cold-pipe-insulationspraycan/?attachment_id=8879&do
wnload_file=uiqar20z5v5um
https://www.spraywayinc.com
/sites/all/themes/theme687/ms
ds/sw620.pdf
http://questspecialty.com/sds/5
880_SDS_QS.pdf
08 June 2020
Solvent
ingredients
Trichloroethylene
07 June 2015
Trichloroethylene
40 - 60
28 July 2020
Trichloroethylene
25 - 50
19 Nov 2020
Trichloroethylene
25 - <50
07 February
2017
Methylene Chloride
https://www.dropbox.com/s/7
8pgtept3rud8gt/No%20Sweat
%20FX%20MSDS%20long%
20form.pdf?dl=0
3 September
2019
Water-based
SDS
SDS date
https://www.dropbo
x.com/s/cnrq7jxhkz
8pxu0/data%20shee
t-no%20sweatfx%20logo.pdf
Concentration
(%)
30 - 60
30 - 60
Not
available
Note: Orange shaded rows indicate products that contain TCE. Grey shaded rows indicate products that contain another one of the first
10 TSCA work plan chemicals.
Table 5-32 shows the estimated approximate market share percentage of primary solvents used in
products estimated using the chemical ranking procedure. Water and TCE are currently the most used
solvents in cold pipe insulation products. For this analysis EPA assumes that replacement products will
not be formulated with priority chemicals with completed final risk evaluations. Thus, it is anticipated
that water would be the most prevalent solvent used in replacement products.
Use and Alternatives Analysis
5-35
Table 5-32: Estimated Percentage Share of Solvent Ingredients for Reviewed
Cold Pipe Insulation Products
Solvent
Current market share
Projected after restrictions
38%
0%
Trichloroethylene
19%
0%
Methylene Chloride
43%
100%
Water
0%
0%
Other
Notes: The figures shown here are based on a proxy chemical ranking procedure, which draws upon
factors including concentration in the product and availability and quality of product reviews. Orange
shading indicates TCE. Grey shading indicates another one of the first 10 TSCA work plan chemicals.
5.9.2 Volatile Organic Compounds (VOC) Content
EPA reviewed VOC information in product SDSs and summarized findings in Table 5-33. No regulatory
VOC limits for cold pipe insulation products were identified. Two of the products containing TCE and
methylene chloride had VOC content data available: Terand Cold Pipe Insulation (87.8%) and Surround
Cold Pipe Insulation Spray (32%). Only one alternative product had VOC content information: No-Sweat
FX (60 g/ L). The density of the No Sweat FX product is not provided in the SDS, but it can be assumed
that the density is approximately 1,000 g per litre since it is a water-based product. Therefore, the 60 g/L
VOC content can be estimated as approximately 6% VOC which is much less than the VOC content for
the Terand Cold Pipe Insulation (87.8%) and Surround Cold Pipe Insulation Spray (32%) products.
Table 5-33: VOC Content for Cold Pipe Insulation Products Based on Information in SDSs or
Technical Data Sheets
Supplier
Product
VOC
(% weight, g/L)
Brodi Specialty Products
Pipe Wrap
No information in SDS
CPC
Terand Cold Pipe Insulation
87.8% estimated
Creative Chemical
Anti-Sweat 2.0 Cold Pipe Insulator Spray
No information in SDS
Sprayway
Sprayway Cold Pipe Insulation
No information in SDS
Quest Specialty Corporation
Surround Cold Pipe Insulation Spray
32%
Robson Thermal
No-Sweat FX
60 g/ L
Note: Orange shaded rows indicate products that contain TCE. Grey shaded rows indicate products that contain another
one of the first 10 TSCA work plan chemicals.
5.9.3 Fire Safety
EPA reviewed flash points and flammability ratings in product SDSs and summarized findings in Table
5-34. All five of the products containing TCE were rated extremely flammable. The anti-condensation
coating, No-Sweat FX was rated non-flammable, and Permaseal Damp Proof Paint had no fire safety
information in the SDS. Restricting TCE in this product category is unlikely to affect non-flammable
options currently on the market. However, the cold pipe insulator product market seems to lack nonflammable options overall.
Use and Alternatives Analysis
5-36
Table 5-34: Flash Point and Flammability Ratings for Cold Pipe Insulation Products Based on
Information in SDSs or Technical Data Sheets
Supplier
Brodi Specialty Products
CPC
Creative Chemical
Product
Pipe Wrap
Terand Cold Pipe Insulation
Anti-Sweat 2.0 Cold Pipe Insulator Spray
Flash Point
Flammability Rating
-156 °F (-104.4 °C)
Extremely flammable
-156 °F (-104.4 °C)
Extremely flammable
Estimated -156 °F
Extremely flammable
(-104.4 °C)
Sprayway
Sprayway Cold Pipe Insulation
-156 °F (-104.4 °C)
Extremely flammable
Quest Specialty Corporation Surround Cold Pipe Insulation Spray
Not determined
Flammable aerosol
Robson Thermal
No-Sweat FX
Not applicable
Non-flammable
Note: Orange shaded rows indicate products that contain TCE. Grey shaded rows indicate products that contain another one of the
first 10 TSCA work plan chemicals.
5.9.4 Pricing and Customer Reviews
EPA accessed pricing and customer review information on publicly available websites in August 2021
and the summarized findings are in Table 5-35. To assist in comparing prices across various products and
product sizes, the prices were normalized to price per ounce. The methylene chloride cold pipe insulation
spray was less expensive compared to the TCE containing products ($0.53 versus costs up to $2.35 per
ounce). However, the alternative water-based product was similar in price to the methylene chloride
product (also $0.53 per ounce).
Overall, it was difficult to compare customer satisfaction between products containing trichlorethylene
and alternative products due to lack of available information. Only one product, Anti-Sweat 2.0 Cold Pipe
Insulator Spray, had customer rating information. The product was rated 5 out of 5 by one reviewer.
Though no public reviews were available for alternative products, a representative at Roberson reported
better performance and customer satisfaction with the water-based No-Sweat FX anti-condensation paint
formula versus their original spray formula (No-Sweat Spray) containing methylene chloride.
Table 5-35: Pricing and Customer Review Information for Cold Pipe Insulation Products Based on
Manufacturer and Retailer Web Pages
Supplier
Product
Brodi Specialty
Products
CPC
Pipe Wrap
Creative
Chemical
Anti-Sweat 2.0
Cold Pipe
Insulator Spray
Sprayway Cold
Pipe Insulation
Surround Cold
Pipe Insulation
Spray
No-Sweat FX
Sprayway
Quest
Specialty
Corporation
Robson
Thermal
Terand Cold Pipe
Insulation
Retail information
https://www.brodi.com/pipewrap-anti-sweat-coldpipe-spray-on-insulating-coating
https://www.aerosolstore.com/terand-cold-pipeinsulation.html?gclid=CjwKCAjw95yJBhAgEiwA
mRrutD9tb8j95CH6H1f0ZN1brbLTLtazMLtu1niaT
JFB160Q6dTYVSmKhRoC2FsQAvD_BwE
https://www.adcosupplies.com/index.php/product/an
ti-sweat-2-0-cold-pipe-insulation-spray-can/
https://www.aerosolstore.com/sprayway-cold-pipeinsulation.html
https://www.aerosolstore.com/questspecialtysurround-cold-pipe-insulation-spray.html
Price
per
ounce
$2.35
Customer
ratings
(out of 5)
None
Number of
customer
reviews
None
$0.63
None
None
$1.07
5
1
$0.63
None
None
$0.53
None
None
$0.53
None
None
http://www.robsonthermal.com/products-and-datasheets#TOC-No-Sweat-FX-Anti-CondensationCoating---Water-BaseNote: Orange shaded rows indicate products that contain TCE. Grey shaded rows indicate products that contain another one of the first
10 TSCA work plan chemicals.
Use and Alternatives Analysis
5-37
5.9.5 Conclusion
EPA did not find barriers around fire safety or pricing that may be caused by restricting use of TCE in this
product category. There was limited VOC information available for the products reviewed and based on
this limited information it appears that replacement products can have less VOC content than products
containing TCE. Restricting TCE in cold pipe insulation products is unlikely to affect non-flammable
options on the market, as the only non-flammable option was a water-based alternative product. Most of
the products in this review were rated extremely flammable (see Table 5-34, above in section 5.9.3). The
pricing for the alternative product was similar to the TCE product. Making a reliable comparison in
customer satisfaction between product groups was not possible due to lack of available customer review
information. It is reasonable to conclude technologically, and economically viable alternatives exist in the
marketplace.
5.10 Spot Removers
Spot cleaners are used to treat stains or spots on textiles. Spot cleaners are available for a wide range of
textiles and formulated for use with commercial wet and dry cleaning solvents, and for residential use.
The analysis focused on carpet and laundry spot cleaners for commercial and consumer use. Products are
available in aerosol or liquid form, and in sizes ranging from ounces to gallons. Note that the products
containing TCE and 1-bromopropane are geared toward commercial or specialty difficult to clean
applications, whereas consumer general purpose laundry and carpet products do not contain them.
5.10.1 Solvent Ingredients
The review included three dry cleaning spot cleaners containing TCE and a carpet spot cleaner containing
1-bromopropane. Six spot cleaner products containing alternative solvents, including ethanol, water, 2butoxy-ethanol, ethoxylated isotridecyl alcohol, and others were also reviewed. Table 5-36 shows the list
of products reviewed for this analysis and their primary solvent ingredients.
Use and Alternatives Analysis
5-38
Table 5-36: Safety Data Sheets and Solvent Ingredients with Concentrations 5% or Higher for Reviewed
Spot Cleaners
Supplier
Product
Adco
Professional
Products LLC
Puro
R.R. Street &
Co. Inc.
Picrin
A.L. Wilson
Chemical Co.
TarGo Dry
Pettyjohn's
Solutions
Pettyjohn's
Solutions®
Homerun Cleaning
Fluid
A.L. Wilson
Chemical Co.
TarGo EF
Chem-Dry
Zep
Professional
Strength Spot
Remover
Instant Carpet and
Upholstery Spot
Remover
https://a1products.com/wpcontent/uploads/2016/06/P
uro-GHS-SDS.pdf
https://a1products.com/wpcontent/uploads/2016/06/P
icrin-GHS-SDS.pdf
https://www.alwilson.com
/products/targo_dry/TarGo
%20Dry%20MSDS.pdf
26 May 2015
Trichloroethylene
Concentration
(%)
>75
3 June 2015
Trichloroethylene
>75
30 August 2018
30 - 50
https://pettyjohnsolutions.
com/wpcontent/uploads/2017/08/
MSDS-HomerunCleaning-Fluid.pdf
https://www.alwilson.com
/products/targo_ef/TarGo
%20EF%20IMPROVED%20%20
MSDS.pdf
July 2012
Ethanol 2-(2butoxyethoxy)
Trichloroethylene
Methyl Isoamyl Ketone
[5-methylhexan-2-one]
1-Bromopropane
2-(2 Propoxyethoxy)
Ethanol
2-(2-Ethoxyethoxy)
Ethyl Acetate
2-(2 Butoxy Ethoxy)
Ethyl Acetate
DPNB (Dipropylene
glycol n-butylether)
Distillate Hydrotreated
Light
Water
Dipropylene glycol
methyl ether
1-methoxy-2-propanol
2-butoxyethanol
20 - 30
SDS
https://mbyc.net/MSDS/pd
f_1308896204.pdf
SDS date
09 August 2017
June 2010
Solvent ingredients
15 - 25
5 - 15
>96
15 - 25
15 - 25
10 - 20
5 - 10
60 - 100
1-5
1-5
≥5 – 10
https://images.thdstatic.co
17 September
m/catalog/pdfImages/27/2 2018
72c04c8-f1b7-4c71-93a41 – 5%
Acetone
7cd31d498fc4.pdf
N/A
Resolve
Professional Spot
https://images.thdstatic.co
05 November
No solvents listed in the
and Stain Carpet
m/catalog/pdfImages/ae/ae 2015
SDS
Cleaner
21a0d7-3b39-4395-9ba6c8311021f09f.pdf
1- 5
SC Johnson
Shout Triple-Action https://images.thdstatic.co
10 September
Ethoxylated Isotridecyl
Laundry Stain
m/catalog/pdfImages/1b/1 2018
Alcohol
Remover
b1ddf4b-f4a3-4f43-80bc942e85a6f297.pdf
30 - 100
Seventh
Laundry Stain
https://www.seventhgener
16 June 2020
Water
Generation
Remover
ation.com/sites/default/file
s/2020-07/sdsfm0000820012laundrystainremoverspr
ayen2020-06-16.pdf
Note: Orange shaded rows indicate products that contain TCE. Grey shaded rows indicate products that contain another one of the first 10
TSCA work plan chemicals.
Use and Alternatives Analysis
5-39
Table 5-37 shows the anticipated, approximate market share percentage of primary solvents used in
products estimated using the chemical ranking procedure. The current market share percentage for TCE
and 1-bromopropane may be skewed higher since there are many more products without these chemicals
that were not included in the review. If restrictions were implemented for TCE, then it is anticipated that
water would be the most prevalent solvent used in replacement products.
Table 5-37: Estimated Percentage Share of Solvent Ingredients for Reviewed Spot
Cleaners
Solvent
Current market share
Projected after restrictions
20%
0%
Trichloroethylene
11%
0%
1-Bromopropane
45%
66%
Water
5%
8%
Ethanol 2-(2-butoxyethoxy)
18%
26%
Other
Notes: The figures shown here are based on a proxy chemical ranking procedure, which draws upon factors
including concentration in the product and availability and quality of product reviews. Orange shading indicates
TCE. Grey shading indicates another one of the first 10 TSCA work plan chemicals.
5.10.2 Volatile Organic Compounds (VOC) Content
VOC information in product SDSs were reviewed and a summary of the findings are in Table 5-38. The
EPA does not have a VOC limit in spot cleaners. However, several states have limits for aerosol spot
cleaners (15-25% VOC) and non-aerosol spot cleaners (3-8% VOC). None of the product SDSs included
VOC information which makes it difficult to ascertain if any of these products are VOC compliant with
state regulations. The products containing TCE and 1-bromopropane likely have high VOC content given
their non-VOC exempt ingredients. Two alternative products (Chem-Dry and Seventh Generation)
contain significant amounts of water and likely have low VOC content.
Use and Alternatives Analysis
5-40
Table 5-38: VOC Content for Spot Cleaners Based on Information in SDSs or Technical Data
Sheets
Supplier
Product
Adco Professional Products
LLC
R.R. Street & Co. Inc.
Puro
A.L. Wilson Chemical Co.
TarGo Dry
Pettyjohn's Solutions
Pettyjohn's Solutions Homerun
Cleaning Fluid
TarGo EF
Professional Strength Spot Remover
A.L. Wilson Chemical Co.
Chem-Dry
Zep
Resolve
SC Johnson
Seventh Generation
Picrin
Instant Carpet and Upholstery Spot
Remover
Professional Spot and Stain Carpet
Cleaner
Shout Triple-Action Laundry Stain
Remover
Laundry Stain Remover
VOC
(% weight, g/L)
No information in SDS; likely high VOC content since
>75% trichloroethylene
No information in SDS; likely high VOC content since
>75% trichloroethylene
No information in SDS; likely high VOC content since
50 - 90% non-VOC exempt ingredients
No information in SDS; likely high VOC content since
>96% 1-BP
No information in SDS
No information in SDS; likely low VOC content since
contains 60 – 100% water
No information in SDS
No information in SDS
No information in SDS
Not available; likely low VOC content since contains
30 – 100% water
Note: Orange shaded rows indicate products that contain TCE. Grey shaded rows indicate products that contain another one of
the first 10 TSCA work plan chemicals.
5.10.3 Fire Safety
Flash points and flammability ratings were reviewed in product SDSs and summarized findings are in
Table 5-39. For products containing TCE, Puro and Picrin were rated non-flammable and TarGo Dry was
rated combustible. Pettyjohn's Solutions Homerun Cleaning Fluid which contains 1-Bromopropane was
rated non-flammable. All products with alternative solvents were rated non-flammable. Based on the
review, there are numerous non-flammable alternatives to products containing TCE.
Use and Alternatives Analysis
5-41
Table 5-39: Flash Point and Flammability Ratings for Spot Cleaners Based on Information in SDSs or
Technical Data Sheets
Supplier
Adco Professional Products
LLC
R.R. Street & Co. Inc.
A.L. Wilson Chemical Co.
Pettyjohn's Solutions
Product
Puro
Flash Point
No information available
Flammability Rating
Non-flammable
Picrin
No information available
Non-flammable
TarGo Dry
116° F (46.7° C)
Combustible
Pettyjohn's Solutions Homerun
None
Non-flammable
Cleaning Fluid
A.L. Wilson Chemical Co.
TarGo EF
>200° F (93.3° C)
Non-flammable
Chem-Dry
Professional Strength Spot Remover
> 212° F (100° C)
Non-flammable
Zep
Instant Carpet and Upholstery Spot
No information available
Non-flammable
Remover
Resolve
Professional Spot and Stain Carpet
>199.9° F (93.3° C)
Non-flammable
Cleaner
SC Johnson
Shout Triple-Action Laundry Stain
Does not flash
Non-flammable
Remover
Seventh Generation
Laundry Stain Remover
Not available
Non-flammable
Note: Orange shaded rows indicate products that contain TCE. Grey shaded rows indicate products that contain another one of the
first 10 TSCA work plan chemicals.
5.10.4 Pricing and Customer Reviews
The review accessed pricing and customer review information on publicly available websites in August
2021 and summarized the findings in Table 5-40. List prices for A.L. Wilson Chemical Co. were not
available online and a sales associate was contacted via phone for pricing. To assist in comparing prices
across various products and product sizes, the prices were normalized to price per ounce. Pricing for
products containing TCE and 1-Bromopropane ranged from $0.70 (Pettyjohn's Solutions Homerun
Cleaning Fluid) to $0.85 (Puro) per ounce. Pricing for alternative products ranged from $0.09 (Shout
Triple-Action Laundry Stain Remover) to $0.98 (TarGo EF) per ounce. There are four alternative
products with prices lower than the products containing TCE.
The three products containing TCE did not have customer ratings. Five of the alternative products had
customer ratings available. Ratings for alternative products ranged from 4.2 (Laundry Stain Remover) to
4.8 (Shout Triple-Action Laundry Stain Remover) with an average rating of 4.6. Though reviews could
not be compared between products with TCE and alternative products, the average rating for alternative
products was well above 4, indicating overall customer satisfaction with these alternative products.
Use and Alternatives Analysis
5-42
Table 5-40: Pricing and Customer Review Information for Spot Cleaners Based on Manufacturer
and Retailer Web Pages
Supplier
Adco
Professional
Products LLC
R.R. Street &
Co. Inc.
A.L. Wilson
Chemical Co.
Pettyjohn's
Solutions
Product
Retail information
Puro
https://garmentcleaningsupply.com/puro1-gal-adco.html
Picrin
https://garmentcleaningsupply.com/picrin1-gal-streets.html
https://www.alwilson.com/products/targo_
dry/index.html
https://pettyjohnsolutions.com/product/ho
merun-cleaning-fluid-1-gallon/
TarGo Dry
Pettyjohn's
Solutions
Homerun
Cleaning Fluid
TarGo EF
Price
per
ounce
$0.85
Customer
ratings
(out of 5)
None
Number of
customer
reviews
None
$0.85
None
None
$0.82
None
None
$0.70
None
None
$0.98
None
None
https://www.alwilson.com/products/targo_
ef/index.html
$0.78
4.7
101
Professional
https://www.amazon.com/Chem-DryStrength Spot
Professional-Strength-SpotRemover
Remover/dp/B01B02RUU4/ref=sr_1_4?dc
hild=1&keywords=dry+cleaning+spot+re
mover&qid=1628783569&s=homegarden&sr=1-4
$0.40
4.6
82
Zep
Instant Carpet
https://www.homedepot.com/p/ZEP-19and Upholstery
oz-Instant-Spot-and-Carpet-StainSpot Remover
Remover-ZUSPOT19/202858110
$0.21
4.6
238
Resolve
Professional
https://www.homedepot.com/p/ResolveSpot and Stain
32-oz-Procare-Carpet-Spot-and-StainCarpet Cleaner
Remover974022/202820652?MERCH=REC-_pip_alternatives-_-100670274-_202820652-_-N&
$0.09
4.8
241
SC Johnson
Shout Triplehttps://www.homedepot.com/p/Shout-60Action Laundry
fl-Oz-Triple-Acting-Liquid-Refill-FabricStain Remover
Stain-Remover624323/308629742#product-overview
$0.28
4.2
121
Seventh
Laundry Stain
https://www.target.com/p/seventhGeneration
Remover
generation-laundry-stain-removers-free38-clear-16-fl-oz/-/A-53346810
Note: Orange shaded rows indicate products that contain TCE. Grey shaded rows indicate products that contain another one of
the first 10 TSCA work plan chemicals.
A.L. Wilson
Chemical Co.
Chem-Dry
5.10.5 Conclusion
The spot cleaner review included three spot cleaners containing TCE, one spot cleaner containing 1bromopropane, and six spot cleaners containing alternative solvents. Barriers were not found around fire
safety, pricing, or customer satisfaction that may be caused by restricting use of TCE in this product
category. Product VOC content was difficult to compare, as none of the products had VOC information in
their SDSs. However, it is likely that the water-based alternative products will have low VOC content and
would be an improvement over products containing TCE. All the alternative products reviewed were
rated non-flammable. All alternative products had prices lower than the products containing TCE.
Customer satisfaction was high for alternative product ratings, as average ratings were over 4 out of 5
stars. Dry cleaners that convert to professional wet cleaning often switch to spot cleaners without TCE.
Use and Alternatives Analysis
5-43
These wet cleaners find they spend much less time and therefore less product on spot cleaning as
compared to the dry cleaning process.
5.11 Pepper Spray
5.11.1 Description
Pepper spray products are aerosol-based sprays used by law enforcement and also by individuals for selfdefense. These products typically contain an irritant, solvent(s), and an aerosol propellant. Some pepper
spray products contain trichloroethylene.
Numerous manufacturers and distributors sell pepper spray in stores and online. EPA called, emailed,
and/or reviewed the websites of major pepper spray manufacturers in December 2022 and January 2023.
Companies were identified via online searches and a list included in a 2021 report prepared by ICF for
EPA (ICF 2021).
5.11.2 Findings Regarding TCE/PCE in Pepper Spray
Ten major manufacturers of pepper spray were identified. Only one was identified as producing pepper
sprays that contain TCE.
The pepper spray products for which Fox Labs provides SDSs on its website (other than the four that
contain TCE as noted above) include Keychain, Serious Business Foam, Stream DB, Cone Fog DB, Mean
Green Stream, Mean Green Fog, Sudecon, Inert Fogger, and Inert Stream.
Defense Technology posts many SDSs on one webpage, but they appear to be for a number of products
other than pepper spray. SDSs were looked at for the products that were assumed to be pepper sprays,
based on the names. None of the following products reviewed have TCE listed on their SDSs:
•
•
•
•
•
•
First Defense .7% MK-EU and MK-North America
First Defense .7% MK-4 Stream OC Aerosol US
Pepper Fog CS Formulation
Pepper Fog Smoke Formulation
Pepper Fog – Flush Mix
Pepper Fog OC Formulation
Two products with TCE were selected for further review, along with two products with diethylene glycol
monobutyl ether, and one product with unknown solvent ingredients. Table 5-41 shows the safety data
sheets and solvent ingredients for reviewed pepper spray products.
Use and Alternatives Analysis
5-44
Table 5-41: Safety Data Sheets and Solvent Ingredients for Reviewed Products
Manufacturer
Fox Labs
Product
SDS URL and Date
Solvent ingredients
Concentration
Cone Fog 1.4 and
Cone Fog 5.3: OC
Fogger,
Nonflammable
https://cdn.shopify.com/s/files/1/1590/2
179/files/5.3-FogTri_4.pdf?v=1647286348
February 2018
Trichloroethylene
Fox Labs
Stream 1.4 and
Stream 5.3: OC
Stream
https://cdn.shopify.com/s/files/1/1590/2
179/files/5.3-StreamTri_4.pdf?v=1647286336
January 2014
Trichloroethylene
Weight %
proprietary
Fox Labs
Keychain 5.3:
OC/DB/PG
(Stream)
Diethylene glycol
monobutyl ether (CAS
112-34-5)
% proprietary
2-(2butoxyethoxy)ethane
(CAS 112-34-5)
20 - 40%
None listed
Not applicable
https://cdn.shopify.com/s/files/1/1590/2
179/files/5.3_Stream_2017_DB.pdf?736
4507807329022273
January 2017
Defense
First Defense .7%
https://sds.chemtel.net/docs/Safariland%
20LLCTechnology
MK Cone OC
0001221/finished_goods/Defense%20T
Aerosol-North
echnology%203035%203045%2056764
America
%2056784%20%20First%20Defense%20.7%20Percent
%20MK-North%20America.pdf
October 2018
SABRE (Security Red USA Civilian
https://images.homedepotstatic.com/catalog/pdfImages/a7/a731c5
Equipment
56-db4f-468b-9fce-46c49832ae05.pdf
Corporation)
January 2013
Note: Orange shaded rows indicate products that contain TCE.
1,1,1,2-Tetrafluoroethane
(CAS 811-97-2)
Weight %
proprietary
Weight %
proprietary
5.11.3 Volatile Organic Compounds (VOC) Content
VOC information was reviewed in product SDSs and summarized findings are in Table 5-42. No federal
or state VOC regulatory limits for pepper spray products were identified. VOC information was not
provided on any product SDS reviewed. Each of the Fox Labs and Defense Technology products
reviewed contain solvents that are not VOC exempt and therefore would contain some level of VOC
content. The Sabre product did not list any solvents and it is not known if the product contains any VOC
solvents. Restricting the use of TCE in pepper spray products does not seem to be a barrier for acceptance
of alternative products based on VOC content.
Use and Alternatives Analysis
5-45
Table 5-42: VOC Content, Based on Information in SDSs
Supplier
Fox Labs
Fox Labs
Fox Labs
Defense Technology
Product
Cone Fog 1.4 and Cone Fog
5.3
Stream 1.4 and Stream 5.3
Keychain 5.3, OC/DB/PG
(Stream)
First Defense .7% MK-North
America
Red USA Civilian
SABRE (Security Equipment
Corporation)
Note: Orange shaded rows indicate products that contain TCE.
VOC
(% weight, g/L)
Not provided on SDS
Not provided on SDS
Not provided on SDS
Not provided on SDS
Not provided on SDS
5.11.4 Fire Safety
Flash points and flammability ratings were reviewed in product SDSs and summarized findings are in
Table 5-43. All products reviewed containing TCE had a flammability rating of “non-flammable”. All
products reviewed containing alternative solvents had high flash point solvents in non-flammable aerosol
propellants and were described on the SDSs as “non-flammable”. Restricting the use of TCE in pepper
spray products is unlikely to impact the acceptance of alternative products based on fire safety.
Table 5-43: Flash Point and Flammability Ratings, Based on Information in SDSs or Technical
Data Sheets
Supplier
Product
Flash Point
Fox Labs
Cone Fog 1.4 and Cone Fog 5.3:
OC Fogger, Nonflammable
None when tested in
accordance with
DOT requirements
Non-flammable
Fox Labs
Stream 1.4 and Stream 5.3: OC
Stream
Non-flammable
Fox Labs
Keychain 5.3: OC/DB/PG
(Stream)
Defense Technology
First Defense .7% MK-North
America
None when tested in
accordance with
DOT requirements
Solvent: 78 degrees
Celsius (172 degrees
Fahrenheit)
Not Available; SDS
NFPA Fire Rating: 3
SABRE (Security Equipment
Corporation)
Red USA Civilian
>106 degrees
Celsius (228 degrees
Fahrenheit)
Flammability Rating
Class IIIA Combustible
liquid in Non-flammable
aerosol propellant
Class IIIA Combustible
liquid in Non-flammable
aerosol propellant
Class IIIB Combustible
liquid in Non-flammable
aerosol propellant
Note: Orange shaded rows indicate products that contain TCE.
5.11.5 Pricing
Pricing information was collected on publicly available websites when available. Pricing was collected
during January 2023. To assist in comparing prices across various products and product sizes, the prices
were normalized to price per ounce. Pepper spray products containing TCE had prices ranging from
$10.99 to $11.49 per ounce. Alternative products without TCE had pricing ranging from $7.33 to $44.34
per ounce for the products reviewed. Pricing was obtained for five products without TCE to get a
representative price range of alternative products.
Use and Alternatives Analysis
5-46
Table 5-44: Pricing Information for Pepper Spray Products Based on Manufacturer and Retailer Web
Pages
Supplier
Product
Retailer
Price and URL
$22.99
https://foxlabs.com/products/24fts?pr_prod_strat=use
_description&pr_rec_id=1076cbf9d&pr_rec_pid=778
6304045290&pr_ref_pid=7487914410218&pr_seq=u
niform
$21.99
https://foxlabs.com/collections/five-point-threelegacy-formula
$21.99
https://foxlabs.com/products/156mgs
$24.99
https://foxlabs.com/products/serious-business-foam
$30.15
https://www.amazon.com/Defense-TechnologyStream-OrangePepper/dp/B001LZ0DNC/ref=sr_1_4?crid=1EP3BY1
AG74TC&keywords=defense+technology+first+defe
nse+mk6+pepper+spray&qid=1673910883&sprefix=defense
+technology+first+defense+mk6+pepper+spray%2Caps%2C164&sr=8-4
$14.99 ($7.50/unit)
https://www.amazon.com/SABRE-AdvancedCompact-PepperSpray/dp/B09SBP27CF/ref=sr_1_10?crid=C688AO
W2SGOR&keywords=pepper%2Bspray&qid=16745
88140&sprefix=pepper%2Bspray%2Caps%2C93&sr
=8-10&th=1
$21.99
https://www.amazon.com/Rothco-Sabre-CrossfirePepper52Cft30/dp/B001C44824/ref=sr_1_1?crid=38YSC52
W0LRY&keywords=Sabre+Red+52CFT30+Crossfire
+Stream&qid=1673910974&sprefix=sabre+red+52cft
30+crossfire+stream%2Caps%2C222&sr=8-1
Fox Labs
1.4 Pepper Spray, 2 oz.,
Police Carry Model
Fox Labs
website
Fox Labs
5.3 Legacy Pepper
Spray, 2 oz.
Fox Labs
website
Fox Labs
Mean Green Staining
Pepper Spray – 1.5 oz.
Fox Labs
website
Fox Labs
“Serious Business” Foam
Pepper Spray, 1.7 oz.
Fox Labs
website
Defense Technology
Defense Technology
6005 First Defense MK6 Stream .7% Orange .68
oz Pepper Spray
Amazon
SABRE
Sabre Advanced Pepper
Spray, 3 in 1 Formula,
0.75 oz each, 2 pack (1.5
oz total)
Amazon
SABRE
Sabre Red 52CFT30
Crossfire Stream (MK-4)
Pepper Spray, 1.33%
MC, 3 oz.
Amazon
Price per
ounce
$11.49
$10.99
$14.66
$14.70
$44.34
$9.99
$7.33
Note: Orange shaded rows indicate products that contain TCE.
5.11.6 Conclusion
The product review included two pepper spray products containing TCE, and three products containing
alternative solvents. Barriers were not found around VOC content or fire safety that would be caused by
restricting the use of TCE in this product category. The pricing range for the alternative products
overlapped with the pricing range for the pepper spray products containing TCE. Therefore, no pricing
barriers are anticipated for switching to alternative products without TCE for this product category.
Use and Alternatives Analysis
5-47
6. Baseline Analysis
This chapter presents the estimated baseline consumption levels for TCE (section 6.1) and the estimated
number of firms and individuals with occupational exposure to TCE (section 6.2). The estimated numbers
of facilities and individuals affected under the rule presented in this chapter are used to estimate the
number of firms with cost impacts attributable to the options and the number of individuals expected to
benefit from reduced exposures under the options.
6.1 Baseline TCE Consumption Volumes by Use Category
This section presents estimates for the amount of TCE consumed for the use categories considered in the
economic analysis where sufficient data were available. EPA’s risk evaluation for TCE indicates that
approximately 172 million lbs of TCE are produced each year, based on 2016 CDR data. It further
indicates that approximately 83.6% of TCE production is used as an intermediate in the manufacture of
HFC-134a, 14.7% is used as a degreasing solvent, a 1.7% is attributed to other uses (EPA 2020e).
EPA uses several sources to derive the volume estimates, which differ according to the type of emission
source associated with the use category. Figure 6-1 presents an overview of the approach to estimating
TCE consumption volume associated with each use category.
Baseline Analysis
6-1
Figure 6-1: Overview of Approach
Baseline Analysis
6-2
6.1.1 Point Sources
This analysis uses emissions estimates reported by the 2017 National Emissions Inventory (NEI) (EPA
2020a) to estimate TCE consumption for the following use categories:
•
•
•
Vapor degreasing
Cold cleaning
Mold release
The approach for these uses consisted of the following steps:
1. Map NEI submissions to use categories
2. Estimate an emissions factor for each use category in order to convert NEI emissions estimates to
consumption estimates
3. Sum total NEI emissions by use category
4. Divide emissions from (3) by the emissions factor from (1) to estimate TCE consumption for each use
category
The next step is to estimate an emissions factor that will allow for the conversion of TCE emissions to
TCE consumption. These emission factors are presented in Table 6-1.
While many NEI submitters reported the emissions factors they used to generate their estimates, EPA was
not able to use these reported factors because the units were not provided. However, some NEI submitters
reported the input quantities (e.g., tons solvent used) that they used to calculate their emissions. In these
cases, reported emissions (Table 6-1; Column A) to estimate an emissions factor. Note that input
quantities that are not based on solvent use (e.g., “fuel”, “material”, “product”) are not included in the
average emission factor calculation because it would not be possible to use these inputs to convert
emissions to TCE input. EPA also includes identified emission factors for each use category from
WebFIRE, an EPA database of emissions factors for criteria and hazardous air pollutants (EPA 2020m).
The emissions factors in Table 6-1 vary widely, as they are affected by differences in equipment, process,
and control technologies. Because the type of equipment and controls used by both the NEI submitters
and the industries at large is not reported, the analysis uses the average of the identified emissions factors
for the analysis estimates.
Baseline Analysis
6-3
Table 6-1: TCE Emission Factors
Calculation Input
Quantity1
Total
emissions (lb)
Emission
Factor
A
B
C=B÷A
Emission
Factor2 (lb
emitted/lb
solvent)
Source
Vapor Degreasing
24,862 gal solvent
58,121
2 lb/gal
0.1869
1,453
12 lb/gal
0.9679
9 ton solvent
16,340
1816 lb/ton
0.9078
11 ton solvent
15,000
1420 lb/ton
0.7102
120 gal trichloroethylene
259 gal trichloroethylene
3,136
12 lb/gal
0.9679
2 ton solvent
3,060
1545 lb/ton
0.7727
495 gal trichloroethylene
5,994
12 lb/gal
0.9680
762 gal trichloroethylene
9,296
12 lb/gal
0.9752
952 gal trichloroethylene
11,580
12 lb/gal
0.9722
137 gal trichloroethylene
1,656
12 lb/gal
0.9682
10,680
2000 lb/ton
1.0000
5 ton make-up solvent
14 ton solvent
16
1 lb/ton
0.0006
1,054 gal solvent
12,840
12 lb/gal
0.9742
1 ton process unit
5,040
3500 lb/ton
1.7500
2 ton make-up solvent
2,120
977 lb/ton
0.4885
18 ton process unit
42,204
2398 lb/ton
1.1990
2 ton process unit
3,497
1953 lb/ton
0.9767
16 ton process unit
30,234
1898 lb/ton
0.9490
5 ton make-up solvent
9,240
2000 lb/ton
1.0000
2 ton make-up solvent
1,200
694 lb/ton
0.3468
2 ton make-up solvent
1,360
795 lb/ton
0.3977
11 ton solvent
21,620
2000 lb/ton
1.0000
6 ton product
12,700
2000 lb/ton
1.0000
4 ton make-up solvent
8,000
1988 lb/ton
0.9940
3 ton make-up solvent
5,060
1988 lb/ton
0.9940
3 ton make-up solvent
6,760
1988 lb/ton
0.9940
2 ton make-up solvent
4,334
1860 lb/ton
0.9300
13 ton process unit
25,035
1911 lb/ton
0.9555
1 ton process unit
1,020
2000 lb/ton
1.0000
1 ton make-up solvent
1,887
1320 lb/ton
0.6600
2 ton solvent
3,300
2000 lb/ton
1.0000
125 gal trichloroethylene
1,522
12 lb/gal
0.9753
2 ton make-up solvent
4,050
1999 lb/ton
0.9995
75 gal trichloroethylene
908
12 lb/gal
0.9681
3 ton make-up solvent
1,280
446 lb/ton
0.2230
3 ton trichloroethylene
5,688
2000 lb/ton
1.0000
2 ton trichloroethylene
4,720
2000 lb/ton
1.0000
9,372 lb trichloroethylene
7,440
1 lb/lb
0.7939
18,766 lb trichloroethylene
18,330
1 lb/lb
0.9768
Baseline Analysis
EPA 2020a
6-4
Table 6-1: TCE Emission Factors
Calculation Input
Quantity1
Total
emissions (lb)
Emission
Factor
15,960
1 lb/lb
Emission
Factor2 (lb
emitted/lb
solvent)
0.9673
A
B
C=B÷A
2,880
13 lb/gal
1.0464
-
-
-
0.9300
-
-
-
0.7900
-
-
-
0.9600
-
-
-
0.8300
Average Emissions Factor3
0.8770
16,500 lb solvent
220 gal trichloroethylene
Source
EPA emissions factor; OTVD
uncontrolled (EPA 2020m)
EPA emissions factor; OTVD
miscellaneous control devices
(EPA 2020m)
EPA emissions factor; CVD
uncontrolled (EPA 2020m)
EPA emissions factor; CVD
miscellaneous control devices
(EPA 2020m)
Batch Cold Cleaning
1 ton solvent
958
1680 lb/ton
0.8400
4,348
10 lb/gal
0.8139
0.06 ton solvent
120
2000 lb/ton
1.0000
0.39 ton make-up solvent
320
821 lb/ton
0.4103
2 ton solvent
4,950
2000 lb/ton
1.0000
2 ton solvent
36
20 lb/ton
0.0101
140
2000 lb/ton
1.0000
8,040
362 lb/ton
0.1808
98
1 lb/lb
1.0000
4
0.49 lb/ton
0.0002
-
-
-
0.8400
-
-
-
0.7200
-
-
-
0.8200
427 gal trichloroethylene
0.07 ton trichloroethylene
22 ton solvents: all
98 lb degreaser
7 ton solvent
Average Emissions Factor3
Mold Release
EPA 2020a
EPA emissions factor; cold
cleaning uncontrolled (EPA
2020m)
EPA emissions factor; cold
cleaning miscellaneous control
devices (EPA 2020m)
EPA emissions factor; cold
cleaning freeboard refrigeration
device (EPA 2020m)
0.6643
532 lb solvent
204
0.38 lb/lb
0.3835
EPA 2020a
1 Make-up solvent is solvent that is used to top-off a degreaser to replace solvent lost through evaporation, leakage, splashing,
etc. While input solvent may contain other chemicals in addition to TCE, EPA assumes that the input solvent is solely comprised
of TCE for the purposes of calculating an emissions factor.
2 Conversion of Column C to units of lb emitted/lb input solvent using the following conversion factors: 2000 ton/lb; 2.20462
kg/lb; 12.51 lb/gal.
3 The average emissions are calculated from values using more significant digits than presented in the table.
The next step is to categorize the remainder of the NEI submissions into a use category. For this analysis,
EPA assigned the most likely use to each facility based on the NAICS, unit type, unit description, process
description, and source classification codes reported. In some cases, the use category could not be
determined based on the reported information. These emissions were reallocated based on the assumption
that uses in metal manufacturing and primary metal production are attributed to vapor degreasing; and
Baseline Analysis
6-5
uses in plastic and rubber manufacturing and polystyrene foam manufacturing are attributed to mold
release.
Finally, the emissions by use category are summed and then divided by the average emissions factors
from Table 6-1 to estimate TCE consumption for the point sources.
6.1.1 (A) Summary and Discussion
Table 6-2 summarizes the TCE consumption estimates for the three use categories expected to be
primarily comprised of only point sources in industrial settings.
Table 6-2: Point Source Annual Volume of TCE Consumed
Average
Emission
Total Emissions
Factor2 (lb
(lbs)1
Use Category
emitted/lb
solvent)
A
B
TCE Consumption (lb)
C=A÷B
Vapor Degreasing
770,196
0.88
878,169
Batch Cold Cleaning
108,052
0.66
162,666
34,188
0.38
89,157
Mold release
1
Source: EPA 2020a
2
Source: Table 6-1 emission factors.
The limitations of this approach include the following:
•
There is some uncertainty around the emissions factors. As previously discussed, the type of control
technologies users have implemented is not known and how the calculated emissions factors relate to
those controls is also not known.
•
Due to the subjective nature of mapping NEI reports to use categories, some emissions may have
been attributed to the wrong use, some irrelevant emissions sources that are not actually a result of a
regulated use category may have been inadvertently included and/or relevant emissions sources that
should be included may have been inadvertently excluded.
•
Given NEI reporting requirements, point source TCE emissions are likely under-reported. TCE is not
required to be reported to NEI, although some states voluntarily do report. For the industries where
EPA expects TCE to be reported but it is not, NEI applies a scaling factor to reported emissions to
best estimate a complete inventory of TCE emissions (EPA 2020b). However, NEI only applies this
scaling factor to degreasing and chemical manufacturing point sources, such that emissions estimates
for the remaining point sources are comprised solely of voluntary reports (EPA 2020h).
6.1.2 Point and Non-Point Sources
This section estimates use volumes for the following use categories that EPA believes are emitted from
both point and nonpoint sources:
•
•
•
•
Aerosol spray cleaning/degreasing
Adhesives and sealants
Paint and coatings
spot removers
Baseline Analysis
6-6
•
Wipe/liquid spray cold cleaning
While many of these uses are reported in NEI as point and/or nonpoint sources, this analysis uses a
different approach to estimate the consumption volumes than that described in the previous section
because NEI may significantly underestimate nonpoint emissions of TCE. As with the point sources,
nonpoint emissions of TCE and other hazardous air pollutants are not required to be reported to NEI,
although states may voluntarily do so. NEI thus produces its own national emissions estimates for those
pollutants that are included on its Expectant Pollutant List, which lists the pollutants EPA expects to
observe for each use. If a state submits a pollutant that is not on the list for a given use, NEI will remove
it unless the state provides documentation supporting its submission (EPA 2020b). Of the relevant use
categories, EPA only lists TCE as an expected nonpoint pollutant for degreasing uses (EPA 2020i). Thus,
all nonpoint emissions of TCE reported in NEI that are not degreasing only reflect voluntary submissions
by states that provided documentation.
This analysis follows NEI’s general approach for estimating nonpoint source emissions of TCE, but
accounts for the uses that NEI does not. This approach methodology is described below.
6.1.2 (A) Methodology
The analysis approach for these uses consisted of the following steps:
1. Estimate total solvent usage
2. Allocate total solvent usage to relevant use categories
3. Apply TCE speciation factors to approximate the market share of TCE in each use category
Step 1: Estimate total solvent usage
NEI bases its emission estimates on national-level projections of solvent usage from the Freedonia Group
(The Freedonia Group 2016), which are reproduced in Table 6-3 below. These estimates encompass both
point and nonpoint sources.
Table 6-3: Solvent Usage Projections in the U.S.
Description
Paints & Coatings Solvent Demand: Architectural
Solvent Usage (Million Pounds)
2015
2017
2020
735
777
840
Paints & Coatings Solvent Demand: Other
1,318
1,321
1,325
Printing Ink Solvent Demand
1,132
1,134
1,138
Cleaning Products Solvent Demand: Household
653
657
662
Cleaning Products Solvent Demand: Industrial &
Institutional
385
390
398
Cosmetics & Toiletries Solvent Demand
628
645
670
Adhesives & Sealants Solvent Demand
572
600
643
Transportation Solvent Demand: Motor Vehicles
61
62
64
Dry Cleaning
20
18
16
Source: The Freedonia Group 2016
Step 2: Allocate total solvent usage to relevant use categories
Baseline Analysis
6-7
Because the Freedonia solvent categories in Table 6-3 are broader than the use categories in this analysis,
they need to be disaggregated into the consumption volumes of the constituent use categories. Table 6-4
provides a crosswalk of the use categories with the Freedonia categories.
This analysis uses California Air Resources Board (CARB)’s 2015 Consumer and Commercial Product
Survey to estimate the market share of each use category within the Freedonia categories (CARB 2019b).
CARB’s survey reports consumer and commercial product sales volumes for over 400 categories of
products. The survey was mandatory for consumer product manufacturers, and reflects reports of
approximately 1,400 companies and over one million products (CARB 2019a). EPA mapped the product
categories in the CARB survey data to both the Freedonia categories and the use categories (Table 6-4).
Note that this step includes any CARB product category EPA determined might reasonably include any
solvent, not just TCE, because the Freedonia estimates reflect total solvent use. The total solvent volume
attributed to each use category will be further disaggregated into the volume attributed to just TCE in the
next step.
Table 6-4: Crosswalk of Freedonia Solvent, Product, and Use Categories
Freedonia Solvent
Use Category
2015 CARB Survey Category
Category
Arts and Crafts Adhesive
Automobile Headliner Adhesive
Automotive Engine Compartment Adhesive
Carpet and Tile Adhesive
Construction, Panel, or Floor Covering Adhesive
Contact Adhesive - General Purpose
Contact Adhesive - Special Purpose
Fabric/Textiles Adhesive
Flexible Vinyl Adhesive
General Purpose Adhesive
Household Glues and Paste
Laminate Repair/Edgebanding Adhesive
Adhesives & Sealants
Solvent Demand
Mist Spray Adhesive
Adhesives and Sealants
Mounting Adhesive
Plastic Pipe Cement and Primer
Polyolefin Adhesive
Polystyrene Foam Adhesive
Rubber Cement
Screen Printing Adhesive
Specialty Automotive Adhesive
Tackifying Agent (semi-permanent)
Temporary/Removable Adhesive
Thread Locking Compound
Wallpaper Adhesive
Web Spray Adhesive
Woodworking Glue
Other adhesives
Baseline Analysis
6-8
Table 6-4: Crosswalk of Freedonia Solvent, Product, and Use Categories
Freedonia Solvent
Use Category
2015 CARB Survey Category
Category
Cold Process Roof Cement (aerosol only)
Driveway Patching Compound
Floor Seam Sealer
Insulating and Sealing Spray Foam
Painter's Putty
Pipe Thread Sealant/Pipe Joint Compound
Plumber's Putty
Rubberized Sealant
Sealant or Caulking Compound -- Chemically Curing
Sealant or Caulking Compound -- Nonchemically
Curing
Spackling Compound
Tile and Grout Sealer
Window Glazing Compound
Wood Filler
Other sealants and caulks
Tire Sealants and Inflator
Cooktop Cleaner
General Purpose Degreaser (aerosol)
Metal Polish/Cleanser (aerosol)
Oven or Grill Cleaner (aerosol)
Single Purpose Cleaner
Aerosol Spray Cleaning/Degreasing
Single Purpose Degreaser
Grill Cleaner
Electrical Cleaner
Electronic Cleaner
Other electronic-related cleaning products
Cleaning Products Solvent
Demand: Household
Multi-purpose Solvent (aerosol)
General Purpose Cleaner (nonaerosol)
General Purpose Degreaser (nonaerosol)
Jewelry Cleaner, Polish, and Soap
Metal Polish/Cleanser (nonaerosol)
Oven or Grill Cleaner (nonaerosol)
Wipe/Liquid Spray Cold Cleaning
Other cleaners and degreasers
Clean Up Solvent
Specialty Degreasers (specific use)
Multi-purpose Solvent (nonaerosol)
Cleaning Products Solvent
Demand: Industrial &
Institutional
Dry Cleaning
Baseline Analysis
General Purpose Degreaser (labeled not for retail sale)
Spot Removers
Spot Remover (aerosol)
Spot Remover (nonaerosol)
6-9
Table 6-4: Crosswalk of Freedonia Solvent, Product, and Use Categories
Freedonia Solvent
Use Category
2015 CARB Survey Category
Category
Spot Remover (aerosol)
Spot Remover (nonaerosol)
Tire or Wheel Cleaner (aerosol)
Brake Cleaner
Transportation Solvent
Demand: Motor Vehicles
Carburetor or Fuel-Injection Air Intake Cleaner
Aerosol Spray Cleaning/Degreasing
Engine Degreaser (aerosol)
Engine Degreaser (nonaerosol)
Home-Use Metal Parts Immersion Wash
Wipe/Liquid Spray Cold Cleaning
Tire or Wheel Cleaner (nonaerosol)
Based on the total sales weight of each CARB product category, the analysis then estimates the market
share of each use category as a percentage of the Freedonia solvent category. Multiplying the market
share by the total solvent consumption from Table 6-3 yields total solvent consumption by use category,
shown in Table 6-5 below.
Table 6-5: Total Use Category Annual Solvent Demand
Use Category
Aerosol Spray
Cleaning/Degreasing
Adhesives and Sealants
Paint and Coatings 3
Spot Removers
Wipe/Liquid Spray Cold
Cleaning
Freedonia Solvent
Category
Transportation Solvent
Demand: Motor
Vehicles
Cleaning Products
Solvent Demand:
Household
Adhesives & Sealants
Solvent Demand
Paints & Coatings
Solvent Demand:
Architectural
Cleaning Products
Solvent Demand:
Household
2020 Total
Solvent
Demand
(million
lbs)1
2015
CARB
Survey
Total
Solvent
Sales
(tons
per day)
A
B
2015
CARB
Survey
Use
Category
Solvent
Sales
(tons per
day)
C
Market
Share of
Solvent
Category2
Total Use
Category
Consumption
(million lbs)
D = C/B
E=AxD
64
49
15
0.55
35
662
940
11
0.03
19
643
156
156
1.00
643
840
-
-
1.00
840
940
26
0.03
18
569
0.60
400
662
1
Source: The Freedonia Group 2016
Source: CARB 2019b
3 The CARB survey did not include products in the paints and coatings category. This analysis assumes that 100 percent of the
Freedonia category “Paints & Coatings Solvent Demand: Architectural” can be attributed to this use category.
2
Baseline Analysis
6-10
Step 3: Apply TCE speciation factors to approximate the market share of TCE in each use category
This analysis follows NEI’s approach by applying a speciation factor to the Freedonia solvent usage
estimates to estimate TCE usage. The speciation factors are the estimates for the percentage of total
volatiles that TCE constitutes. The underlying assumption of this analysis is that the TCE speciation
factors are also a proxy for TCE’s market share of total solvent usage. 10 This analysis uses speciation
factors from EPA’s SPECIATE database, which is a repository of speciation factors of air pollutant
sources (EPA 2020k). The database contains approximately 95 speciation profiles for TCE, which are
mapped to the use categories (Table 6-6). The last column of Table 6-6 includes the NEI descriptive
names for the product or use that the speciation factor represents.
9F
The TCE profiles in the SPECIATE database are dated from 1994 to 2018 and may cover a range of
values for the same use category. In particular, there is a group of about 13 profiles corresponding to
CARB’s consumer product categories from 2018, and a group of equivalent profiles from 2004. The 2018
estimates are significantly lower than the 2004 factors, which is the result of regulations CARB
implemented in the intervening years that prohibit TCE use in a range of consumer product categories
(CARB 2019c). Where possible, EPA therefore uses CARB’s 2018 factors for states that regulate TCE in
a given use and CARB’s 2004 factors for states that do not have TCE regulations. The analysis identified
18 states from ISSA (2018) and EPA (2020b) that regulate TCE in adhesives, spot removers, lubricants
and greases, apparel and footwear care products, and cleaners/degreasers.
Table 6-6 presents these speciation factors for each use category.
10
This is consistent with the approach used by NEI. By applying the speciation factors directly to input solvent
volume to estimate pollutant emissions, NEI implicitly assumes that 100 percent of the solvents are emitted to
the air. Thus, by this assumption, the make-up of solvent emissions would mirror the make-up of the solvent
input.
Baseline Analysis
6-11
Table 6-6: TCE Speciation Factors
Use Category
Aerosol Spray Cleaning/Degreasing
TCE Speciation Factor
(Weight %)
State TCE
No State TCE
Limit
Limit
0.02
0.66
TCE Speciation Factor Profile Names
CONS PRD- AUTOMOTIVE BRAKE
CLEANER (2010 UPDATE)
Consumer Products: Automotive Brake Cleaners
Consumer Products: Aerosol Adhesive (Including
Industrial)
Adhesives and Sealants
0.040
0.01
Paint and Coatings
0.12
0.12
Spot Removers
0.08
10.98
Wipe/Liquid Spray Cold Cleaning
0.00
0.16
Consumer and Commercial Products: Adhesives
and Sealants: All Adhesives and Sealants
Consumer and Commercial Products: Coatings
and Related Products: All Coatings and Related
Products1
CONS PRD- SPOT REMOVER - AEROSOL
(2010 UPDATE)
Consumer Products: Spot Removers - Aerosols
Consumer Products: Solvent Parts Cleaner - NonAerosols1
1While
state limits on paint thinners were identified, no states limiting using of other types of paints and coatings were
identified. Because TCE is not present in paint thinners, only a single speciation factor for paints and coatings is used.
6.1.2 (B) Summary and Discussion
Table 6-7 summarizes the TCE consumption estimates for the use categories discussed in this section.
Note that the speciation factors are weighted by the populations of the states with and without TCE limits.
These population weights are derived from the 2018 American Community Survey (U.S. Census Bureau
2019).
Some limitations of this approach include the following:
•
The Freedonia 2020 solvent usage projections were made in 2016. While they may have attempted to
account for foreseeable changes in the market for solvents, they likely could not have fully accounted
for the regulatory and industry trends in the last five years. Their predictions therefore may not reflect
the actual solvent market in 2020.
•
This analysis relies on CARB’s 2015 consumer and commercial product survey to estimate the
market share of each use category. This necessitates several assumptions:
•
That the market share of products in California reflect those of the entire U.S.
•
That the market share of consumer and commercial products also reflects the market share of
industrial products
•
That the sales volumes of products omitted from the survey data for confidentiality reasons
are negligible
•
That the sales volumes of the overall products are proportional to the volumes of solvent used
Baseline Analysis
6-12
•
The analysis uses the speciation factors as a proxy for TCE’s share of the solvent market, but this may
be inaccurate to the extent that product categories are largely comprised of non-solvent alternatives
(i.e. TCE may be a small share of total volatile emissions, but a larger share of solvent emissions/use)
Table 6-7: Non-Point Sources Annual Volume of TCE Consumed
Use Category
Total Use
Category
Demand
(million
lbs)
A
Aerosol Spray Cleaning/Degreasing
State TCE Limit
TCE
State
Speciation
Population
Factor
Weight
(Weight %)
B
C
No State TCE Limit
TCE
State
Speciation
Population
Factor
Weight
(Weight %)
D
Annual Volume
of TCE
Consumed (lbs)
A x (0.01*B*C +
0.01*D*E) x
1,000,000
E
54
0.02
0.44
0.66
0.56
203,522
Adhesives and Sealants
643
0.04
0.44
0.01
0.56
149,491
Paint and Coatings
840
0.12
0.00
0.12
1.00
1,008,000
18
0.08
0.44
10.98
0.56
1,134,123
400
0.00
0.44
0.16
0.56
360,408
Spot Removers
Wipe/Liquid Spray Cold Cleaning
6.1.3 Summary of Consumption Volumes by Use Category
Table 6-8 summarizes the estimated consumption volume of TCE for each use category.
Table 6-8: Summary of TCE Consumption Volume Estimates, by Use Category
Source
Use Category
Total Volume (lbs)
Laboratory Use
Battery Manufacture
HFC Manufacturing
Vapor Degreasing
HCl Production
Fluoroelastomer Production
Mold release
Batch Cold Cleaning
Liquid Cleaners and Degreasers
Aerosol Spray Cleaning/Degreasing
Lubricants and Greases
Adhesives, Sealants, Paints and Coatings
(Adhesives and Sealants)
Adhesives, Sealants, Paints and Coatings
(Paint and Coatings)
Spot Removers
Disposal
Total
Baseline Analysis
Not Estimated
>53,175
135,153,510
23,038,435
Not Estimated
Not Estimated
89,157
162,666
360,408
203,522
185,000
(Descartes Datamyne 2022)
EPA 2017b; EPA 2020e
Table 6-2
Table 6-2
Table 6-2
Table 6-7
Table 6-7
EPA 2020e
149,491
Table 6-7
1,008,000
Table 6-7
1,134,123
Not estimated
161,484,312
Table 6-7
-
6-13
EPA notes that the total TCE consumption volume estimated in Table 6-8 (161,484,312 lbs) is slightly
lower than the total TCE production volume reported in the 2016 CDR (161,666,878 lbs). This may be
due to several reasons. First, as described in Section 6.1.2, uses that may be associated with point and
nonpoint sources are estimated using solvent usage projects for 2020, whereas volumes reported in CDR
are based on 2015 production volumes. And as shown in Table 6-3, solvent usage is generally expected to
increase over the period from 2015 to 2020. Second, the approach used to estimate TCE consumption
volume is subject to various limitations and involve a degree of uncertainty, as discussed in the preceding
sections. The difference in TCE consumption volume estimated by this analysis and that reported by CDR
may reflect the errors and uncertainties related to this approach.
6.2 Number of Affected Facilities and Individuals Exposed in Occupational
Settings
This section presents the number of firms and individuals exposed to TCE for each use category
considered under the regulatory options. For most use categories EPA used two general approaches for
estimating the number of firms using TCE and individuals employed at those firms that might be exposed
to TCE. The first approach was applied for use categories where facilities could be identified in CDR,
TRI, or NEI data (see 6.2.1). The second approach was generally applied for use categories defined as
using a TCE containing product and uses various sources to estimate the numbers of facilities using TCE
and OSHA enforcement data to estimate the percentage of employees per establishment with potential
exposure to TCE (see 6.2.2, 6.2.6, 6.2.8, 6.2.9, 6.2.9, and 6.2.11). Use-specific approaches were used to
develop the estimates for incorporation into formulation, mixture, or reaction product, vapor degreasing,
spot removers, and waste handling, disposal, treatment, and recycling, described in sections 6.2.3, 6.2.5,
6.2.7, and 6.2.12, respectively. The estimates are summarized in section 6.2.13.
6.2.1 Number of Affected Facilities and Individuals in Facilities Identified in CDR, TRI, and NEI data
As shown in Table 6-9, EPA used CDR, TRI, and NEI data to identify facilities producing,
importing, or releasing TCE and categorized them according to use category based on
information provided in the data or other sources. When facilities fell into multiple use
categories (e.g., an importer of TCE using the TCE as a processing aid in HFC manufacturing),
they were accounted for once under the downstream use of TCE. With respect to fluoroelastomer
production, 2 companies were identified as those reporting TCE on TRI or NEI reports and had a
NAICS code that related to an industry where rubber-type products were potentially
manufactured. However, it is not clear that these companies use TCE to manufacture
fluoroelastomers. In its 2021 Multi-Industry Per- and Polyfluoroalkyl Substances (PFAS)
Substances (PFAS) Study (Preliminary) EPA identified only 2 domestic manufacturers of
fluoroelastomers and one processor none of which appeared in the 2020 TRI or NEI with reports
for TCE, suggesting they are not using TCE in their process. While EPA does not believe that
domestic manufacture of fluoroelastomers using TCE occurs, EPA conservatively used these
companies to estimate impacts of the rule and to account for the uncertainty in knowing if this is
an ongoing use however, has low confidence that they are using TCE as a process solvent in the
manufacture of fluoroelastomers.
Baseline Analysis
6-14
Table 6-9: Number of TCE Facilities for Select Use Categories
Use Category
TCE
Facilities
Notes
Laboratory Use
10
Estimated using 2017 NEI data (EPA 2020a).
Manufacturers
2
Estimated using 2020 CDR data (EPA 2022a).
Import/Repackage
9
Estimated using 2020 CDR data (EPA 2022a).
Battery and Synthetic Paper
Processing Aid
3
Estimated using 2017 NEI data (EPA 2020a) and information
provided by affected facilities.
HFC Manufacturing
2
Estimated using 2020 CDR data (EPA 2022a).
Batch Cold Cleaning
52
Estimated using 2017 NEI data (EPA 2020a).
28
Estimated using 2020 TRI (EPA 2022b) and 2017 NEI data
(EPA 2020a).
HCl Production
Fluoroelastomer Production
2
Estimated using 2017 NEI data (EPA 2020a).
Table 6-10 shows the numbers of workers and ONUs per facility, which were derived from the TCE Risk
Evaluation, except for the laboratory use, which comes from the Perchloroethylene Risk Evaluation.
Table 6-10: Number of Workers and ONUs per Facility for Select Use Categories
ONUs
Use Category
Workers
Manufacturers
Import/Repackage
Battery Manufacture
HFC Manufacturing
70
34
2
1
17
8
19
9
Batch Cold Cleaning
HCl Production
Fluoroelastomer Production
51
31
19
9
17
8
Source: TCE Risk Evaluation (EPA 2020e)
6.2.2 Estimated Number of Workers and ONUs
For some of the use categories, EPA uses OSHA enforcement data to estimate the percentage of
employees per establishment with potential exposure to TCE. The data are updated daily and report 40
years of data on the approximately 100,000 inspections conducted annually. EPA utilizes two datasets to
make this calculation:
• Inspection dataset. The inspection dataset records information on each establishment where OSHA
performed an inspection (OSHA 2020a). OSHA may conduct inspections in response to imminent
danger situations, severe injuries and illnesses, worker complaints, referrals, targeted inspections, or
follow-up inspections (OSHA 2016c). EPA relies on the following variables from the inspection
dataset:
•
Inspection ID
•
4-digit NAICS
•
Number of employees in establishment
• Violation dataset. The violation dataset records information on each establishment where OSHA
issued a citation due to a standard violation (OSHA 2020b). OSHA issues a citation to an
establishment if there is a standard violation and if an employee has current, past, or potential exposure
Baseline Analysis
6-15
to the hazard in the previous six months (OSHA 2016a). EPA relies on the following variables from
the violation dataset:
•
Inspection ID
•
Standard
•
Number of employees exposed
•
Citation issuance date
EPA restricts data to establishments in violation of one of the following standards, which pertain to
exposure limits for TCE and other air contaminants:
•
1910.1000(b). Table Z-2. An employee’s exposure to any substance listed in Table Z-2 shall not
exceed the exposure limits specified as follows:
•
1910.1000(b)(1). 8-hour time weighted averages. An employee's exposure to any substance listed in
Table Z-2, in any 8-hour work shift of a 40-hour work week, shall not exceed the 8-hour time
weighted average limit given for that substance in Table Z-2.
•
1910.1000(b)(2). Acceptable ceiling concentrations. An employee's exposure to a substance listed in
Table Z-2 shall not exceed at any time during an 8-hour shift the acceptable ceiling concentration
limit given for the substance in the table, except for a time period, and up to a concentration not
exceeding the maximum duration and concentration allowed in the column under "acceptable
maximum peak above the acceptable ceiling concentration for an 8-hour shift."
•
1910.1000(e). To achieve compliance with paragraphs (a) through (d) of this section, administrative
or engineering controls must first be determined and implemented whenever feasible. When such
controls are not feasible to achieve full compliance, protective equipment or any other protective
measures shall be used to keep the exposure of employees to air contaminants within the limits
prescribed in this section. Any equipment and/or technical measures used for this purpose must be
approved for each particular use by a competent industrial hygienist or other technically qualified
person.
Some establishments were cited for more than one of the above standards. To avoid double-counting
these establishments, EPA kept only the citation entry with the highest number of workers potentially
exposed. EPA also restricts the data to citations issued within the last ten years (2010-2020).
For each NAICS, EPA estimates the percentage of workers exposed to TCE by dividing the number of
employees with TCE exposures by the total number of employees for each establishment. EPA then
estimates the average percentage of workers exposed per establishment across the affected NAICS for
each use category.
Unless otherwise stated in the sections below, for each use category EPA estimated the average number
of employees exposed to TCE per firm by multiplying the number of firms using TCE by the estimated
percentage of employees exposed to TCE per firm (see Section 6.2.2) and by the average number of
employees per firm, estimated using 2017 CBP data for the relevant NAICS (U.S. Census Bureau 2020).
The analysis uses estimates from the supplemental risk evaluation file for environmental releases and
occupational exposures (EPA 2020f) for the percentage of exposed employees in each use category that
are assumed to be ONUs, with the remaining percentages assumed to be exposed workers.
6.2.3 Processing: incorporation into a formulation, mixture or reaction product
Based on the list of manufacturers of products containing TCE compiled by EPA (see Chapter 4), 28
firms are estimated to process TCE for incorporation into formulation, mixture or reaction product. We
Baseline Analysis
6-16
assume there is one additional firm that reformulates a TCE-containing pepper spray. Based on EPA’s
TCE Risk Evaluation (EPA 2020e), there are 16 workers and 5 ONUs per facility exposed to TCE.
6.2.4 Laboratory Use
Using EPA’s (2020a) NEI data, 10 laboratory facilities using TCE were identified. According American
Association of State Highway and Transportation Officials (AASHTO), there are 241 laboratories in more
than 40 states that maintain accreditation for AASHTO and ASTM test methods T-164 and D-2172,
which are methods used in the testing process for asphalt pavement material (AASHTO 2023). Thus,
EPA estimates that there are 251 facilities in total under the laboratory use category. Table 6-11 presents
the estimated number of facilities for laboratory uses. Based on the Perchloroethylene Risk Evaluation
(EPA 2020j), EPA estimates that there is 1 worker and 9 ONUs per affected laboratory facility.
Table 6-11: Number of TCE Facilities for Laboratory Uses
Use Category
TCE
Facilities
Notes
Laboratory Use (except asphalt
testing)
10
Estimated using 2017 NEI data (EPA 2020a).
Laboratory Use (asphalt testing)
241
AASHTO Public Comment (AASHTO 2023).
Laboratory Use (Total)
251
-
6.2.5 Vapor Degreasing
The Institute for Research and Technical Assistance (IRTA) (2016b) estimated that approximately 15
percent of Open Top Vapor Degreasers (OTVDs) are operated with trichloroethylene (TCE), methylene
chloride (DCM), and PCE, with the other 85 percent being operated with 1-Bromopropane (1-BP).
Applying this 85:15 ratio to the estimated 2,500 vapor degreasers using 1-BP according to the final risk
evaluation for 1-BP (EPA 2020c), and assuming the mix of TCE, DCM, and PCE OTVDs is 80%, 1%,
and 19%, respectively, EPA estimates approximately 350 OTVDs use TCE (= 2,500 x 15/85 x 80%).
Using the ratio of OTVDs to enclosed vapor degreasers (EVDs) and conveyorized vapor degreasers
(CVDs) as estimated in IRTA (2016b), EPA estimates approximately 9 CVDs and 7 EVD use TCE.
Based on 2017 NEI data, there is one web vapor degreaser (WVD) that uses TCE. Table 6-12 presents the
estimated number of OTVDs, EVDs, CVDs, and WVDs.
Table 6-12: Estimated Number of Vapor Degreasers Using TCE
Estimated
Ratio of OTVDs
Number of Vapor
Vapor Degreaser
Using TCE to
Degreasers Using
OTVDs
Using 1-BP2
1-BP1
Ratio of OTVDs to
EVDs and CVDs3
Estimated Number
of Vapor
Degreasers Using
TCE
Open Top Vapor Degreasers (OTVD)
0.14
Enclosed Vapor Degreasers (EVD)
0.02
2,500
Conveyorized Vapor Degreasers (CVD)
0.025
Web Vapor Degreasers (WVD)4
Notes:
1 EPA 2020c
2 Based on an 85:15 ratio of OTVDs operated with 1-BP versus other solvents (TCE, PCE, and DCM), and 80% of these other
solvents operated with TCE (14% = 0.15/0.85 x 0.8)
3 IRTA (2016b)
4 Based on 2017 NEI data, there is one web vapor degreaser that uses TCE.
The numbers of workers and ONUs per vapor degreaser were estimated based on an OECD (2021) report
and are presented in Table 6-13.
Baseline Analysis
6-17
350
7
9
1
Table 6-13: Number of Workers and ONUs per Vapor Degreaser Facility
Use Category
ONUs
Workers
OTVD
EVD
6
4
CVD/WVD
Source: OECD 2021
6.2.6 Mold Release
A total of 17 firms are estimated to use TCE in mold release (predominantly tire and rubber companies)
based on 2017 NEI data (EPA 2020a). Section 6.2.2 describes the approach used to estimate the number
of workers and ONUs for this use category. This results in an estimated 371 workers and 44 ONUs
exposed to TCE in in mold release applications (Table 6-14).
Table 6-14: Number of Mold Release Firms and Individuals
NAICS1
NAICS Description
Total
Number of
Firms
Using
TCE1
Average
Number of
Total
Employees
per Firm2
Estimated
Percentage
of
Employees
Exposed to
TCE3
Percentage
of
Employees
that are
ONUs4
Number of
Workers
Exposed to
TCE
Number of
ONUs
Exposed to
TCE
A
B
C
D
AxBxCx
(1-D)
AxBxCxD
326211
Tire Manufacturing (except
Retreading)
0
326212
Tire Retreading
2
562
25
7%
11%
16
2
7%
11%
2
0
Other Metal Valve and Pipe
1
7%
11%
4
0
Fitting Manufacturing
60
Major Household Appliance
1
6%
11%
13
2
335220
Manufacturing
334
Motor Vehicle Electrical and
336320 Electronic Equipment
3
111
16%
11%
51
6
Manufacturing
Other Motor Vehicle Parts
336390
7
117
16%
11%
121
14
Manufacturing
812332 Industrial Launderers
2
168
49%
11%
163
19
Total Mold Release
17
132
19%
11%
371
44
Notes:
1 Based on firms identified as using TCE for mold release use from the 2017 NEI (EPA 2020a). See Section 6.1.1 for a description of how
this analysis mapped use categories to firms reporting emissions to NEI.
2 U.S. Census Bureau 2020
3 Estimated by dividing the number of employees with TCE exposures by the total number of employees for each establishment from
OSHA enforcement data (OSHA 2020a; OSHA 2020b).See Section 6.2.2 for further description.
4 Derived from Table 2-31 of EPA 2020f (11% = 1,690 ONUs/15,900 total exposed)
332919
6.2.7 Spot Removers
The Economic Analysis of the Proposed Regulation of Perchloroethylene Under TSCA Section 6(a) (EPA
2023a) estimated that about 6,000 facilities currently using perchloroethylene dry cleaning machines.
Since TCE spot removers would generally not be compatible with other dry cleaning machines, EPA
estimates that 83% of dry cleaners with perchloroethylene dry cleaning machines use TCE spotting
chemicals. This estimate is based on personal communications with the Dry Cleaning and Laundry
Institute and the National Cleaners Association (Personal Communication with Dry Cleaning and
Baseline Analysis
6-18
Laundry Institute 2015; Dry Cleaning and Laundry Institute (DLI) and National Cleaners Association
(NCA) (2017)), who estimated that 50% of dry cleaners used TCE spotting chemicals and 60% of dry
cleaning machines use perchloroethylene.
Following EPA’s (2023a) estimates, there is one worker and one ONU per dry cleaner. Thus, EPA
estimates that there are 4,980 facilities, workers, and ONUs using TCE spotting chemicals.
6.2.8 Lubricants and Greases
This use category includes penetrating lubricants and metalworking fluids. The number of firms and
workers using TCE-containing penetrating lubricants is discussed in the following Section 6.2.9.
Therefore, this section only addresses metalworking fluids. EPA identified the NAICS presented in Table
6-15 based on its judgement of industries likely to engage in metal shaping operations such as machining,
grinding, deformation, and blasting.
EPA did not identify information to estimate the number of facilities using metalworking fluids
containing TCE. However, the Trichloroethylene Market and Use Report (EPA 2017i) estimated that no
more than 1.7% of the national TCE production volume is used for “miscellaneous” uses, which includes
metalworking fluids. Therefore, EPA expects the number of sites using TCE-containing metalworking
fluids to be small and assumes that 0.5% of firms in industries that may use metalworking fluids use
metalworking fluids containing TCE. Multiplying the assumed 0.5% market share by the 69,050 total
firms in the relevant NAICS from the 2017 CBP (U.S. Census Bureau 2020) results in an estimated 345
firms using TCE.
Section 6.2.2 describes the approach used to estimate the number of workers and ONUs for this use
category. As shown in Table 6-15, 1,751 workers and 76 ONUs are estimated to be exposed to TCE from
lubricants and greases uses.
Table 6-15: Number of Lubricants and Greases Firms and Individuals
Average
Estimated
Total
Total
Estimated
Number
Percentage
Number
Number Percentage
of Total
of
of Firms
of
of Firms
Employe
Employees
Using
NAICS
Firms2
Using TCE1
es per
Exposed to
NAICS1
TCE
Description
Firm2
TCE3
A
Baseline Analysis
B
C=AxB
D
E
Percentage
of Workers
that are
ONUs4
Number
of
Workers
Exposed
to TCE
Number
of ONUs
Expose
d to
TCE
F
AxBx
DxEx
(1-F)
CxDx
ExF
6-19
Table 6-15: Number of Lubricants and Greases Firms and Individuals
Average
Estimated
Total
Total
Estimated
Number
Percentage
Number
Number Percentage
of Total
of
of Firms
of
of Firms
Employe
Employees
Using
NAICS
Firms2
Using TCE1
es per
Exposed to
NAICS1
TCE
Description
Firm2
TCE3
A
332321
332322
332323
332410
332420
332431
332439
332510
332613
332618
332710
332721
332722
332911
332912
332913
332919
332991
Metal Window and
Door
Manufacturing
Sheet Metal Work
Manufacturing
Ornamental and
Architectural Metal
Work
Manufacturing
Power Boiler and
Heat Exchanger
Manufacturing
Metal Tank (Heavy
Gauge)
Manufacturing
Metal Can
Manufacturing
Other Metal
Container
Manufacturing
Hardware
Manufacturing
Spring
Manufacturing
Other Fabricated
Wire Product
Manufacturing
Machine Shops
Precision Turned
Product
Manufacturing
Bolt, Nut, Screw,
Rivet, and Washer
Manufacturing
Industrial Valve
Manufacturing
Fluid Power Valve
and Hose Fitting
Manufacturing
Plumbing Fixture
Fitting and Trim
Manufacturing
Other Metal Valve
and Pipe Fitting
Manufacturing
Ball and Roller
Baseline Analysis
B
C=AxB
D
E
Percentage
of Workers
that are
ONUs4
Number
of
Workers
Exposed
to TCE
Number
of ONUs
Expose
d to
TCE
F
AxBx
DxEx
(1-F)
CxDx
ExF
875
0.5%
4.4
60
15%
4%
38.7
1.7
3,752
0.5%
18.8
28
15%
4%
78.5
3.4
2,322
0.5%
11.6
16
15%
4%
27.2
1.2
268
0.5%
1.3
85
8%
4%
8.4
0.4
636
0.5%
3.2
53
8%
4%
12.4
0.5
66
0.5%
0.3
252
8%
4%
6.1
0.3
261
0.5%
1.3
41
8%
4%
4.0
0.2
568
0.5%
2.8
50
10%
4%
13.1
0.6
312
0.5%
1.6
55
8%
4%
6.5
0.3
680
0.5%
3.4
32
8%
4%
8.2
0.4
17,829
0.5%
89.1
13
9%
4%
96.9
4.2
3,670
0.5%
18.4
28
9%
4%
43.8
1.9
650
0.5%
3.3
58
9%
4%
16.1
0.7
385
0.5%
1.9
89
16%
4%
25.9
1.1
294
0.5%
1.5
124
16%
4%
27.3
1.2
94
0.5%
0.5
91
16%
4%
6.4
0.3
217
0.5%
1.1
60
16%
4%
9.9
0.4
104
0.5%
0.5
199
16%
4%
15.6
0.7
6-20
Table 6-15: Number of Lubricants and Greases Firms and Individuals
Average
Estimated
Total
Total
Estimated
Number
Percentage
Number
Number Percentage
of Total
of
of Firms
of
of Firms
Employe
Employees
Using
NAICS
Firms2
Using TCE1
es per
Exposed to
NAICS1
TCE
Description
Firm2
TCE3
A
332992
332993
332994
332996
332999
333111
333112
333120
333131
333132
333241
333242
333243
Bearing
Manufacturing
Small Arms
Ammunition
Manufacturing
Ammunition
(except Small
Arms)
Manufacturing
Small Arms,
Ordnance, and
Ordnance
Accessories
Manufacturing
Fabricated Pipe and
Pipe Fitting
Manufacturing
All Other
Miscellaneous
Fabricated Metal
Product
Manufacturing
Farm Machinery
and Equipment
Manufacturing
Lawn and Garden
Tractor and Home
Lawn and Garden
Equipment
Manufacturing
Construction
Machinery
Manufacturing
Mining Machinery
and Equipment
Manufacturing
Oil and Gas Field
Machinery and
Equipment
Manufacturing
Food Product
Machinery
Manufacturing
Semiconductor
Machinery
Manufacturing
Sawmill,
Baseline Analysis
B
C=AxB
D
E
Percentage
of Workers
that are
ONUs4
Number
of
Workers
Exposed
to TCE
Number
of ONUs
Expose
d to
TCE
F
AxBx
DxEx
(1-F)
CxDx
ExF
148
0.5%
0.7
89
16%
4%
10.0
0.4
43
0.5%
0.2
266
16%
4%
8.6
0.4
388
0.5%
1.9
52
16%
4%
15.3
0.7
644
0.5%
3.2
42
16%
4%
20.4
0.9
3,514
0.5%
17.6
19
16%
4%
50.3
2.2
1,054
0.5%
5.3
57
25%
4%
71.5
3.1
148
0.5%
0.7
127
25%
4%
22.1
1.0
651
0.5%
3.3
92
25%
4%
70.5
3.1
224
0.5%
1.1
49
25%
4%
13.1
0.6
502
0.5%
2.5
66
25%
4%
39.1
1.7
432
0.5%
2.2
37
2%
4%
1.7
0.1
140
0.5%
0.7
124
2%
4%
1.9
0.1
337
0.5%
1.7
37
2%
4%
1.3
0.1
6-21
Table 6-15: Number of Lubricants and Greases Firms and Individuals
Average
Estimated
Total
Total
Estimated
Number
Percentage
Number
Number Percentage
of Total
of
of Firms
of
of Firms
Employe
Employees
Using
NAICS
Firms2
Using TCE1
es per
Exposed to
NAICS1
TCE
Description
Firm2
TCE3
A
333244
333249
333314
333316
333318
333413
333414
333415
333511
333514
333517
333519
Woodworking, and
Paper Machinery
Manufacturing
Printing Machinery
and Equipment
Manufacturing
Other Industrial
Machinery
Manufacturing
Optical Instrument
and Lens
Manufacturing
Photographic and
Photocopying
Equipment
Manufacturing
Other Commercial
and Service
Industry Machinery
Manufacturing
Industrial and
Commercial Fan
and Blower and Air
Purification
Equipment
Manufacturing
Heating Equipment
(except Warm Air
Furnaces)
Manufacturing
Air-Conditioning
and Warm Air
Heating Equipment
and Commercial
and Industrial
Refrigeration
Equipment
Manufacturing
Industrial Mold
Manufacturing
Special Die and
Tool, Die Set, Jig,
and Fixture
Manufacturing
Machine Tool
Manufacturing
Rolling Mill and
Other
Baseline Analysis
B
C=AxB
D
E
Percentage
of Workers
that are
ONUs4
Number
of
Workers
Exposed
to TCE
Number
of ONUs
Expose
d to
TCE
F
AxBx
DxEx
(1-F)
CxDx
ExF
263
0.5%
1.3
27
2%
4%
0.8
0.0
1,811
0.5%
9.1
30
2%
4%
5.8
0.3
390
0.5%
2.0
38
29%
4%
20.3
0.9
180
0.5%
0.9
21
29%
4%
5.2
0.2
1,231
0.5%
6.2
42
29%
4%
72.1
3.1
401
0.5%
2.0
58
3%
4%
3.0
0.1
362
0.5%
1.8
43
3%
4%
2.0
0.1
705
0.5%
3.5
126
3%
4%
11.6
0.5
1,392
0.5%
7.0
25
6%
4%
10.4
0.5
2,293
0.5%
11.5
19
6%
4%
13.0
0.6
787
0.5%
3.9
35
6%
4%
8.0
0.3
390
0.5%
2.0
35
6%
4%
4.0
0.2
6-22
Table 6-15: Number of Lubricants and Greases Firms and Individuals
Average
Estimated
Total
Total
Estimated
Number
Percentage
Number
Number Percentage
of Total
of
of Firms
of
of Firms
Employe
Employees
Using
NAICS
Firms2
Using TCE1
es per
Exposed to
NAICS1
TCE
Description
Firm2
TCE3
A
333515
333611
333612
333613
333618
333912
333914
333921
333922
333923
333924
333991
Metalworking
Machinery
Manufacturing
Cutting Tool and
Machine Tool
Accessory
Manufacturing
Turbine and
Turbine Generator
Set Units
Manufacturing
Speed Changer,
Industrial HighSpeed Drive, and
Gear
Manufacturing
Mechanical Power
Transmission
Equipment
Manufacturing
Other Engine
Equipment
Manufacturing
Air and Gas
Compressor
Manufacturing
Measuring,
Dispensing, and
Other Pumping
Equipment
Manufacturing
Elevator and
Moving Stairway
Manufacturing
Conveyor and
Conveying
Equipment
Manufacturing
Overhead Traveling
Crane, Hoist, and
Monorail System
Manufacturing
Industrial Truck,
Tractor, Trailer,
and Stacker
Machinery
Manufacturing
Power-Driven
Baseline Analysis
B
C=AxB
D
E
Percentage
of Workers
that are
ONUs4
Number
of
Workers
Exposed
to TCE
Number
of ONUs
Expose
d to
TCE
F
AxBx
DxEx
(1-F)
CxDx
ExF
1,285
0.5%
6.4
21
6%
4%
7.9
0.3
115
0.5%
0.6
310
1%
4%
2.6
0.1
194
0.5%
1.0
61
1%
4%
0.9
0.0
200
0.5%
1.0
79
1%
4%
1.1
0.0
261
0.5%
1.3
136
1%
4%
2.5
0.1
261
0.5%
1.3
70
12%
4%
10.4
0.5
457
0.5%
2.3
81
12%
4%
21.1
0.9
166
0.5%
0.8
51
12%
4%
4.8
0.2
718
0.5%
3.6
52
12%
4%
21.0
0.9
268
0.5%
1.3
72
12%
4%
10.9
0.5
311
0.5%
1.6
89
12%
4%
15.6
0.7
123
0.5%
0.6
59
12%
4%
4.1
0.2
6-23
Table 6-15: Number of Lubricants and Greases Firms and Individuals
Average
Estimated
Total
Total
Estimated
Number
Percentage
Number
Number Percentage
of Total
of
of Firms
of
of Firms
Employe
Employees
Using
NAICS
Firms2
Using TCE1
es per
Exposed to
NAICS1
TCE
Description
Firm2
TCE3
A
333992
333993
333994
333995
333996
333997
333999
336111
336112
336120
336211
336212
336213
336214
336310
Handtool
Manufacturing
Welding and
Soldering
Equipment
Manufacturing
Packaging
Machinery
Manufacturing
Industrial Process
Furnace and Oven
Manufacturing
Fluid Power
Cylinder and
Actuator
Manufacturing
Fluid Power Pump
and Motor
Manufacturing
Scale and Balance
Manufacturing
All Other
Miscellaneous
General Purpose
Machinery
Manufacturing
Automobile
Manufacturing
Light Truck and
Utility Vehicle
Manufacturing
Heavy Duty Truck
Manufacturing
Motor Vehicle
Body
Manufacturing
Truck Trailer
Manufacturing
Motor Home
Manufacturing
Travel Trailer and
Camper
Manufacturing
Motor Vehicle
Gasoline Engine
and Engine Parts
Manufacturing
Baseline Analysis
B
C=AxB
D
E
Percentage
of Workers
that are
ONUs4
Number
of
Workers
Exposed
to TCE
Number
of ONUs
Expose
d to
TCE
F
AxBx
DxEx
(1-F)
CxDx
ExF
341
0.5%
1.7
48
12%
4%
9.2
0.4
471
0.5%
2.4
44
12%
4%
11.8
0.5
317
0.5%
1.6
34
12%
4%
6.2
0.3
253
0.5%
1.3
89
12%
4%
12.8
0.6
132
0.5%
0.7
79
12%
4%
5.9
0.3
73
0.5%
0.4
51
12%
4%
2.1
0.1
1,558
0.5%
7.8
36
12%
4%
31.5
1.4
162
0.5%
0.8
511
2%
4%
9.9
0.4
49
0.5%
0.2
2,022
2%
4%
11.8
0.5
74
0.5%
0.4
358
2%
4%
3.2
0.1
632
0.5%
3.2
76
12%
4%
27.2
1.2
379
0.5%
1.9
98
12%
4%
21.1
0.9
41
0.5%
0.2
291
12%
4%
6.8
0.3
601
0.5%
3.0
90
12%
4%
30.8
1.3
706
0.5%
3.5
82
16%
4%
43.3
1.9
6-24
Table 6-15: Number of Lubricants and Greases Firms and Individuals
Average
Estimated
Total
Total
Estimated
Number
Percentage
Number
Number Percentage
of Total
of
of Firms
of
of Firms
Employe
Employees
Using
NAICS
Firms2
Using TCE1
es per
Exposed to
NAICS1
TCE
Description
Firm2
TCE3
A
336320
336330
336340
336350
336360
336370
336390
336411
336412
336413
336414
336415
336419
Motor Vehicle
Electrical and
Electronic
Equipment
Manufacturing
Motor Vehicle
Steering and
Suspension
Components
(except Spring)
Manufacturing
Motor Vehicle
Brake System
Manufacturing
Motor Vehicle
Transmission and
Power Train Parts
Manufacturing
Motor Vehicle
Seating and Interior
Trim
Manufacturing
Motor Vehicle
Metal Stamping
Other Motor
Vehicle Parts
Manufacturing
Aircraft
Manufacturing
Aircraft Engine and
Engine Parts
Manufacturing
Other Aircraft Parts
and Auxiliary
Equipment
Manufacturing
Guided Missile and
Space Vehicle
Manufacturing
Guided Missile and
Space Vehicle
Propulsion Unit
and Propulsion
Unit Parts
Manufacturing
Other Guided
Missile and Space
Vehicle Parts and
Baseline Analysis
B
C=AxB
D
E
Percentage
of Workers
that are
ONUs4
Number
of
Workers
Exposed
to TCE
Number
of ONUs
Expose
d to
TCE
F
AxBx
DxEx
(1-F)
CxDx
ExF
565
0.5%
2.8
111
16%
4%
46.8
2.0
220
0.5%
1.1
174
16%
4%
28.5
1.2
139
0.5%
0.7
168
16%
4%
17.4
0.8
390
0.5%
2.0
188
16%
4%
54.6
2.4
307
0.5%
1.5
235
16%
4%
53.8
2.3
597
0.5%
3.0
181
16%
4%
80.3
3.5
1,268
0.5%
6.3
117
16%
4%
110.2
4.8
262
0.5%
1.3
636
2%
4%
12.8
0.6
319
0.5%
1.6
211
2%
4%
5.1
0.2
750
0.5%
3.8
138
2%
4%
7.9
0.3
22
0.5%
0.1
1,608
2%
4%
2.7
0.1
16
0.5%
0.1
1,040
2%
4%
1.3
0.1
33
0.5%
0.2
101
2%
4%
0.3
0.0
6-25
Table 6-15: Number of Lubricants and Greases Firms and Individuals
Average
Estimated
Total
Total
Estimated
Number
Percentage
Number
Number Percentage
of Total
of
of Firms
of
of Firms
Employe
Employees
Using
NAICS
Firms2
Using TCE1
es per
Exposed to
NAICS1
TCE
Description
Firm2
TCE3
A
B
C=AxB
D
E
Percentage
of Workers
that are
ONUs4
Number
of
Workers
Exposed
to TCE
Number
of ONUs
Expose
d to
TCE
F
AxBx
DxEx
(1-F)
CxDx
ExF
Auxiliary
Equipment
Manufacturing
Railroad Rolling
336510 Stock
153
0.5%
0.8
193
16%
4%
22.0
1.0
Manufacturing
Ship Building and
336611
503
0.5%
2.5
199
6%
4%
27.5
1.2
Repairing
833
0.5%
4.2
45
6%
4%
10.3
0.4
336612 Boat Building
Motorcycle,
336991 Bicycle, and Parts
423
0.5%
2.1
23
1%
4%
0.5
0.0
Manufacturing
Military Armored
Vehicle, Tank, and
336992
38
0.5%
0.2
244
1%
4%
0.5
0.0
Tank Component
Manufacturing
All Other
Transportation
336999
390
0.5%
2.0
35
1%
4%
0.7
0.0
Equipment
Manufacturing
Metal Household
337124 Furniture
261
0.5%
1.3
37
10%
4%
4.7
0.2
Manufacturing
Total Lubricants and
69,050
0.5%
345
51
10%
4%
1,751
76
Greases
Notes:
1 EPA judgement
2 U.S. Census Bureau 2020
3 Estimated by dividing the number of employees with TCE exposures by the total number of employees for each establishment from OSHA
enforcement data (OSHA 2020a; OSHA 2020b).See Section 6.2.2 for further description.
4 Derived from Section 2.11.3.2 of EPA 2020f (4% = 2 ONUs/48 total exposed)
6.2.9 Aerosol Spray Cleaning/Degreasing
Table 6-16 presents the NAICS that are expected to use aerosol degreasers. Based on a survey by the
California Air Resources Board (CARB), approximately 73% of automotive maintenance and repair
facilities use brake cleaning products, approximately 38% of these facilities use brake cleaning products
containing chlorinated chemicals, and 5-6% of the facilities that use chlorinated products reported using
TCE-based products (CARB 2000). Using the high-end value from the CARB data, an estimated 1.7% of
facilities are estimated to use aerosol products containing TCE (1.7% = 6% x 38% x 73%). Multiplying
this 1.7% market share by an estimated 256,850 establishments in the industry (U.S. Census Bureau
2015) results in an estimated 4,366 firms using TCE-based aerosol degreasing and aerosol lubricant
products.
These data only relate to aerosol brake cleaning products used in the automotive repair industry; however,
aerosol degreasing may be used in electronics repair, industrial equipment repair, home and garden
Baseline Analysis
6-26
equipment repair, or other similar industries. Market penetration data for these industries were not
identified; therefore, in lieu of other information, EPA assumes a similar market penetration as for brake
cleaning products. EPA estimates the number of facilities using TCE aerosols for energized electrical
cleaners (EEC) are estimated as the number of TCE aerosol users in NAICS 811213 (Communication
Equipment Repair and Maintenance), 811219 (Other Electronic and Precision Equipment Repair and
Maintenance), and 811310 (Commercial and Industrial Machinery and Equipment (except Automotive
and Electronic) Repair and Maintenance). Thus, as shown in Table 6-16, 668 of the 4,366 firms using
TCE-based aerosol degreasing and aerosol lubricant products are assumed to be using EEC aerosols.
Section 6.2.2 describes the approach used to estimate the number of workers and ONUs for this use
category. As shown in Table 6-16, 5,852 workers and 696 ONUs are estimated to be exposed to TCE in
aerosol products.
Table 6-16: Number of Aerosol Spray Cleaning/Degreasing Firms and Individuals
Estimated
Total
Average
Percentage
Percentage
Number
Number of
of
of
of Firms
Total
Employees
Employees
Using
Employees
that are
NAICS1
NAICS Description
Exposed
to
TCE1
per Firm2
ONUs4
3
TCE
A
B
C
Aerosol Spray Cleaning/Degreasing, except EEC
Nonwoven Fabric Mills
4
89
10%
Special Die and Tool, Die Set, Jig and
333514
42
19
6%
Fixture Manufacturing
Audio and Video Equipment
9
19
67%
334310
Manufacturing
753
33
5%
4411
Automobile Dealers
300
15
3%
451110 Sporting Goods Stores
1,461
5
26%
811111 General Automotive Repair
28
3
26%
811112 Automotive Exhaust System Repair
78
4
26%
811113 Automotive Transmission Repair
Other Automotive Mechanical and
811118
56
5
26%
Electrical Repair and Maintenance
Automotive Body, Paint and Interior
811121
604
7
26%
Repair and Maintenance
811122 Automotive Glass Replacement Shops
88
6
26%
Automotive Oil Change and
83
14
26%
811191
Lubrication Shops
All Other Automotive Repair and
811198
67
5
26%
Maintenance
Consumer Electronics Repair and
811211
32
7
8%
Maintenance
Computer and Office Machine Repair
94
7
8%
811212
and Maintenance
Non-EEC subtotal
3,698
12
12%
EEC Aerosol Spray Cleaning/Degreasing
Communication Equipment Repair and
811213
32
10
8%
Maintenance
Other Electronic and Precision
811219
51
13
8%
Equipment Repair and Maintenance
369
10
29%
811310 Commercial and Industrial Machinery
313230
Baseline Analysis
D
Number of
Workers
Exposed
to TCE
Number of
ONUs
Exposed
to TCE
AxBxC
x (1-D)
AxBxCx
D
11%
28
3
11%
45
5
11%
98
12
11%
11%
11%
11%
11%
1,087
133
1,537
21
70
129
16
183
3
8
11%
63
7
11%
1,041
124
11%
128
15
11%
263
31
11%
76
9
11%
17
2
11%
45
5
11%
4,651
553
11%
24
3
11%
48
6
11%
958
114
6-27
Table 6-16: Number of Aerosol Spray Cleaning/Degreasing Firms and Individuals
Estimated
Total
Average
Percentage
Percentage
Number
Number of
of
of
of Firms
Total
Employees
Employees
Using
Employees
that are
NAICS1
NAICS Description
Exposed
to
TCE1
per Firm2
ONUs4
TCE3
A
B
C
D
Number of
Workers
Exposed
to TCE
Number of
ONUs
Exposed
to TCE
AxBxC
x (1-D)
AxBxCx
D
and Equipment (except Automotive and
Electronic) Repair and Maintenance
Home and Garden Equipment Repair
811411
31
3
25%
11%
19
and Maintenance
Other Personal and Household Goods
184
4
25%
11%
153
811490
Repair and Maintenance
668
8
25%
11%
1,201
EEC subtotal
All Aerosol Spray Cleaning/Degreasing
4,366
12
13%
11%
5,852
Total Aerosol Spray Cleaning/Degreasing
Notes:
1 EPA 2017a
2 U.S. Census Bureau 2020
3 Estimated by dividing the number of employees with TCE exposures by the total number of employees for each establishment from
OSHA enforcement data (OSHA 2020a; OSHA 2020b).See Section 6.2.2 for further description.
4 Derived from Table 2-31 of EPA 2020f (11% = 1,690 ONUs/15,900 total exposed)
2
18
143
696
6.2.10 Adhesives, Sealants, Paints, and Coatings
Using the approach described in Section 6.1 to map use categories to the 2017 NEI data (EPA 2020a), this
analysis identified nine firms in the NEI data that use TCE in adhesives and sealants and 31 firms that use
TCE in paints and coatings. EPA expects that this may underestimate the number of firms in these use
categories because many of these firms could be nonpoint sources of TCE and would not be identified in
the NEI data. Therefore, EPA also includes an additional 25 firms identified in the risk evaluation (EPA
2020f) for a total of 65 firms. The risk evaluation derived its estimates for the number of firms from 2014
NEI, 2016 TRI, and 2016 DMR data. Note that for the NAICS that are reported in both the risk evaluation
and the 2017 NEI data, this analysis uses the firm counts from the 2017 NEI data because they are more
recent than the data used in the risk evaluation.
Section 6.2.2 describes the approach used to estimate the number of workers and ONUs for this use
category. As shown in Table 6-17, 616 workers and 288 ONUs are estimated to be exposed to TCE in
adhesives, sealants, paints, and coatings.
Table 6-17: Number of Adhesive, Sealants, Paints and Coatings Firms and Individuals
Estimated
Total
Average
Percentage
Percentage
Number
Number of
of
of
of Firms
Total
Employees
Employees
Using
Employees
that are
NAICS1
NAICS Description
Exposed
to
TCE1
per Firm2
ONUs4
3
TCE
A
Baseline Analysis
B
C
D
Number
of
Workers
Exposed
to TCE
Number
of ONUs
Exposed
to TCE
AxBxC
x (1-D)
AxBx
CxD
6-28
Table 6-17: Number of Adhesive, Sealants, Paints and Coatings Firms and Individuals
Estimated
Total
Average
Percentage
Percentage
Number
Number of
of
of
of Firms
Total
Employees
Employees
Using
Employees
that are
NAICS1
NAICS Description
Exposed to
1
2
TCE
per Firm
ONUs4
TCE3
A
B
C
D
Number
of
Workers
Exposed
to TCE
Number
of ONUs
Exposed
to TCE
AxBxC
x (1-D)
AxBx
CxD
Broadwoven Fabric Mills
Fabric Coating Mills
Prefabricated Wood Building
Manufacturing
Paper Bag and Coated and Treated Paper
Manufacturing
All Other Petroleum and Coal Products
Manufacturing
Paint and Coating Manufacturing
Adhesive Manufacturing
All Other Miscellaneous Chemical
Product and Preparation Manufacturing
Polystyrene Foam Product
Manufacturing
Urethane and Other Foam Product
(except Polystyrene) Manufacturing
1
1
63
46
10%
53%
32%
32%
4
17
2
8
1
32
14%
32%
3
1
2
84
8%
32%
9
4
1
46
17%
32%
5
2
1
1
39
60
32%
32%
32%
32%
8
13
4
6
2
35
19%
32%
9
4
2
88
12%
32%
14
7
1
73
12%
32%
6
3
326211
Tire Manufacturing (except Retreading)
2
7%
32%
52
24
326212
Tire Retreading
Rubber and Plastics Hoses and Belting
Manufacturing
All Other Rubber Product Manufacturing
Nonferrous Metal Die-Casting Foundries
Metal Window and Door Manufacturing
Metal Coating, Engraving (except
Jewelry and Silverware), and Allied
Services to Manufacturers
Electroplating, Plating, Polishing,
Anodizing and Coloring
Ammunition (except Small Arms)
Manufacturing
Small Arms, Ordnance, and Ordnance
Accessories Manufacturing
All Other Miscellaneous Fabricated
Metal Product Manufacturing
Cutting Tool and Machine Tool
Accessory Manufacturing
Measuring, Dispensing, and Other
Pumping Equipment Manufacturing
1
7%
32%
1
1
Electronic Connector Manufacturing
1
313210
313320
321992
322220
324199
325510
325520
325998
32614
326150
326220
326299
331523
332321
332812
332813
332993
332994
332999
333515
333914
334417
334511
335312
Search, Detection, Navigation, Guidance,
Aeronautical, and Nautical System and
Instrument Manufacturing
Motor and Generator Manufacturing
Baseline Analysis
2
562
25
7%
32%
9
4
2
1
2
101
53
96
60
7%
9%
15%
32%
32%
32%
5
6
13
2
3
6
1
23
19%
32%
3
1
9
25
19%
32%
30
14
16%
32%
28
13
1
266
2
52
16%
32%
11
5
2
19
16%
32%
4
2
1
21
6%
32%
1
0
1
81
12%
32%
7
3
7%
32%
5
2
1%
32%
2
1
5%
32%
3
1
1
1
118
301
78
6-29
Table 6-17: Number of Adhesive, Sealants, Paints and Coatings Firms and Individuals
Estimated
Total
Average
Percentage
Percentage
Number
Number of
of
of
of Firms
Total
Employees
Employees
Using
Employees
that are
NAICS1
NAICS Description
Exposed to
1
2
TCE
per Firm
ONUs4
TCE3
A
B
C
D
Number
of
Workers
Exposed
to TCE
Number
of ONUs
Exposed
to TCE
AxBxC
x (1-D)
AxBx
CxD
Current-Carrying Wiring Device
1
71
7%
32%
3
2
Manufacturing
336211
Motor Vehicle Body Manufacturing
1
76
12%
32%
6
3
336213
Motor Home Manufacturing
1
291
12%
32%
24
11
Motor Vehicle Transmission and Power
336350
1
188
16%
32%
20
9
Train Parts Manufacturing
Motor Vehicle Seating and Interior Trim
1
235
16%
32%
25
12
336360
Manufacturing
Other Motor Vehicle Parts
336390
2
117
16%
32%
25
12
Manufacturing
336411
Aircraft Manufacturing
3
636
2%
32%
21
10
Guided Missile and Space Vehicle
336415
Propulsion Unit and Propulsion Unit
1
1,040
2%
32%
11
5
Parts Manufacturing
336611
Ship Building and Repairing
1
199
6%
32%
8
4
Wood Kitchen Cabinet and Counter Top
337110
1
15
10%
32%
1
0
Manufacturing
Upholstered Household Furniture
1
68
10%
32%
5
2
337121
Manufacturing
Nonupholstered Wood Household
337122
1
13
10%
32%
1
0
Furniture Manufacturing
337211
Wood Office Furniture Manufacturing
1
43
3%
32%
1
0
Surgical Appliance and Supplies
339113
1
53
15%
32%
5
3
Manufacturing
Sporting and Athletic Goods
1
25
27%
32%
5
2
339920
Manufacturing
Gasket, Packing, and Sealing Device
339991
1
58
27%
32%
11
5
Manufacturing
481111
Scheduled Passenger Air Transportation
1
1,376
19%
32%
175
82
928110
National Security
2
215
0%
32%
0
0
Total Adhesives, Sealants, Paints, and Coatings
65
154
9%
32%
616
288
Notes:
1 Based on EPA 2017a and firms identified as using TCE for adhesive and sealant use from the 2017 NEI (EPA 2020a). See Section 6.1.1
for a description of how this analysis mapped use categories to firms reporting emissions to NEI.
2 U.S. Census Bureau 2020
3 Estimated by dividing the number of employees with TCE exposures by the total number of employees for each establishment from
OSHA enforcement data (OSHA 2020a; OSHA 2020b).See Section 6.2.2 for further description.
4 Derived from Table 2-36 of EPA 2020f (32% = 1,400 ONUs/4,400 total exposed)
335931
6.2.11 Liquid Cleaners and Degreasers
EPA expects that wipe cleaning is primarily done in automobile, appliance, and electronics repair shops
and assumes that the same NAICS may potentially be affected as those identified for the aerosol spray
cleaning and degreasing use (see section 6.2.9) . EPA did not identify any information on the number or
percentage of repair shops that use wipe cleaning products containing TCE. Therefore, this analysis
Baseline Analysis
6-30
assumes a 5% market share of TCE products in repair industries. Multiplying the assumed 5% market
share by the 236,309 total firms in the relevant NAICS from the 2017 CBP (U.S. Census Bureau 2020)
results in an estimated 11,815 firms using TCE.
Section 6.2.2 describes the approach used to estimate the number of workers and ONUs for this use
category. As shown in Table 6-18, 16,053 workers and 1,667 ONUs are estimated to be exposed to TCE
from liquid cleaners and degreasers use.
Table 6-18: Number of Liquid Cleaners and Degreasers Firms and Individuals
NAICS1
313230
333514
334310
4411
451110
811111
811112
NAICS
Description
Nonwoven
Fabric Mills
Special Die
and Tool, Die
Set, Jig and
Fixture
Manufacturing
Audio and
Video
Equipment
Manufacturing
Automobile
Dealers
Sporting Goods
Stores
General
Automotive
Repair
Automotive
Exhaust
System Repair
Baseline Analysis
Total
Number
of
Firms2
Estimated
Percentage
of Firms
Using TCE1
A
B
Total
Number
of
Firms
Using
TCE
C=Ax
B
Average
Number of
Total
Employees
per Firm2
Estimated
Percentage
of
Employees
Exposed to
TCE3
Percentage
of
Employees
that are
ONUs4
Number of
Workers
Exposed
to TCE
Number
of ONUs
Exposed
to TCE
D
E
F
AxBxD
x E x (1-F)
CxDxE
xF
195
5%
10
89
10%
9%
76
8
2,293
5%
115
19
6%
9%
123
13
462
5%
23
19
67%
9%
269
28
40,769
5%
2,038
33
5%
9%
2,983
310
16,233
5%
812
15
3%
9%
364
38
79,072
5%
3,954
5
26%
9%
4,216
438
1,521
5%
76
3
26%
9%
59
6
6-31
Table 6-18: Number of Liquid Cleaners and Degreasers Firms and Individuals
NAICS1
811113
811118
811121
811122
811191
811198
811211
811212
811213
811219
811310
NAICS
Description
Automotive
Transmission
Repair
Other
Automotive
Mechanical
and Electrical
Repair and
Maintenance
Automotive
Body, Paint
and Interior
Repair and
Maintenance
Automotive
Glass
Replacement
Shops
Automotive Oil
Change and
Lubrication
Shops
All Other
Automotive
Repair and
Maintenance
Consumer
Electronics
Repair and
Maintenance
Computer and
Office Machine
Repair and
Maintenance
Communicatio
n Equipment
Repair and
Maintenance
Other
Electronic and
Precision
Equipment
Repair and
Maintenance
Commercial
and Industrial
Machinery and
Equipment
(except
Baseline Analysis
Total
Number
of
Firms2
Estimated
Percentage
of Firms
Using TCE1
A
B
Total
Number
of
Firms
Using
TCE
C=Ax
B
Average
Number of
Total
Employees
per Firm2
Estimated
Percentage
of
Employees
Exposed to
TCE3
Percentage
of
Employees
that are
ONUs4
Number of
Workers
Exposed
to TCE
Number
of ONUs
Exposed
to TCE
D
E
F
AxBxD
x E x (1-F)
CxDxE
xF
4,206
5%
210
4
26%
9%
191
20
3,027
5%
151
5
26%
9%
172
18
32,696
5%
1,635
7
26%
9%
2,855
296
4,764
5%
238
6
26%
9%
350
36
4,467
5%
223
14
26%
9%
722
75
3,637
5%
182
5
26%
9%
208
22
1,746
5%
87
7
8%
9%
47
5
5,068
5%
253
7
8%
9%
124
13
1,738
5%
87
10
8%
9%
65
7
2,787
5%
139
13
8%
9%
130
14
19,986
5%
999
10
29%
9%
2,628
273
6-32
Table 6-18: Number of Liquid Cleaners and Degreasers Firms and Individuals
NAICS1
NAICS
Description
Total
Number
of
Firms2
Estimated
Percentage
of Firms
Using TCE1
A
B
Total
Number
of
Firms
Using
TCE
C=Ax
B
Average
Number of
Total
Employees
per Firm2
Estimated
Percentage
of
Employees
Exposed to
TCE3
Percentage
of
Employees
that are
ONUs4
Number of
Workers
Exposed
to TCE
Number
of ONUs
Exposed
to TCE
D
E
F
AxBxD
x E x (1-F)
CxDxE
xF
Automotive
and Electronic)
Repair and
Maintenance
Home and
Garden
811411 Equipment
1,704
5%
85
3
25%
9%
52
5
Repair and
Maintenance
Other Personal
and Household
811490 Goods Repair
9,938
5%
497
4
25%
9%
419
43
and
Maintenance
Total Liquid Cleaners
236,309
5%
11,815
12
13%
9%
16,053
1,667
and Degreasers
Notes:
1 EPA judgement. Assumed to be the same as aerosol spray cleaning/degreasing use.
2 U.S. Census Bureau 2020
3 Estimated by dividing the number of employees with TCE exposures by the total number of employees for each establishment from OSHA
enforcement data (OSHA 2020a; OSHA 2020b).See Section 6.2.2 for further description.
4 Derived from Table 2-43 of EPA 2020f (9% = 25,300 ONUs/269,000 total exposed)
6.2.12 Disposal to Wastewater
TCE is a contaminant of concern in a significant number of cleanup sites that are managed under
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), also known as
Superfund sites, as well as under The Resource Conservation and Recovery Act (RCRA). The
remediation of these sites, including the removal and treatment of TCE-contaminated groundwater, is
critical to EPA’s mission to protect human health and the environment. Additionally, there are sites where
TCE-contaminated groundwater is being addressed under the authority of other federal environmental
laws or state and local government authorities. The disposal of wastewater that contains TCE to industrial
pre-treatment, industrial treatment, or publicly owned treatment works is an important method used in
these cleanup efforts. At many contaminated sites, TCE-contaminated wastewater is pumped out of the
ground and either sent to offsite industrial treatment or publicly owned treatment works.
According to EPA’s Superfund Enterprise Management System, (SEMS) there are 1,649 sites on the
Superfund National Priorities List (including Superfund Alternative Approach (SAA)) sites. Of these
sites, 736 (approximately 45%) have TCE in groundwater at a concentration where remediation is needed
(EPA 2023b). EPA estimates that there are 739 POTWs potentially affected by the rule, accounting for an
affected POTW for each clean-up site and 4 POTWs potentially receiving contaminated wastewater from
2 battery manufacturers and 1 synthetic paper manufacturer.
Baseline Analysis
6-33
Section 6.2.2 describes the approach used to estimate the number of workers and ONUs for this use
category. As shown inTable 6-19, 177 workers and 103 ONUs are estimated to be exposed to TCE from
the disposal use category.
Table 6-19: Number of Disposal Firms and Individuals
Use Category
Disposal to Wastewater
Number of
Sites Using
TCE
739
Workers
ONUs
9,607
3,695
6.2.13 Summary of Number of Affected Firms and Employees
Table 6-20 presents a summary of the number of affected firms and employees, by COU.
Table 6-20: Summary of Affected Firms and Employees
Number of
Use Category
Sites Using
TCE
Laboratory Use
Manufacturing
Import/Repackage
Processing Aid (Battery and Synthetic Paper)
HFC Manufacturing
Intermediate in HCl Production
Fluoroelastomer Manufacture
Open-Top Vapor Degreasing
Enclosed Vapor Degreasing
Conveyorized Vapor Degreasing
Web Vapor Degreasing
Batch Cold Cleaning
Disposal to Wastewater
Incorporation Into Formulation, Mixture, or Reaction
Product
Mold Release
Liquid Cleaners and Degreasers
Aerosol Spray Cleaning/Degreasing
Lubricants and Greases
Adhesives, Sealants, Paints and Coatings
Spot Removers
Film Cleaner
Toner Aid
Polish
Pepper Spray
Total
Number of
Workers
Exposed to TCE
Number of
ONUs Exposed
to TCE
251
2
9
3
2
28
2
350
7
8
1
52
739
251
140
18
51
38
532
34
2,100
42
48
6
312
9,607
2,259
68
9
24
18
252
16
1,400
28
32
4
208
3,695
28
448
140
17
11,815
4,366
345
65
4,980
23,070
371
16,053
5,852
1,751
616
14,940
53,210
44
1,667
696
76
288
3,735
14,659
6.3 Estimated Number of Exposed Consumers
Table 6-21 presents the estimated number of consumer users, which are estimated as a function of the
estimated TCE consumption volumes presented above in Table 6-8. The percentage of total consumption
Baseline Analysis
6-34
assumed to be for consumer use for the calculations is an assumed value based on EPA judgement, and
therefore these estimated numbers of exposed consumers should be considered highly uncertain.
Baseline Analysis
6-35
Table 6-21: Estimated number of Consumer Users
Use Category
Annual
Estimated
Volume of Percentage
Volume of TCE Product
TCE
Consumer
Consumer Concentration3
Consumed
Use2
TCE Use (oz)
(lbs)1
C = (A x B) x
A
B
D
16 oz/lb
Estimated
Median
Number of
Volume of
Consumer
Annual
Consumer
Product Use Consumer
Product Use
(oz/year) 4
Users
(oz)
E=C/D
F
G=E/F
203,522
5%
162,818
84%
193,430
16
89,157
0.05%
713
67%
1,069
16
185,000
0.05%
1,480
21%
7,108
2.25
149,491
0.05%
1,196
55%
2,184
1
1,134,123
0.05%
9,073
57%
16,011
5.5
360,408
0.05%
2,883
95%
3,035
16
Aerosol Spray
Cleaning/Degreasing
Mold Release
Lubricants and
Greases
Adhesives and
Sealants
Spot Removers
Liquid Cleaners and
Degreasers
Notes
12,089 (EPA 2011a) product category: Engine Degreasers. TCE
product concentration based on average of midpoint % TCE
in formulation for 24 aerosol cleaners/degreasers
67 (EPA 2011a) product category: Solvent-Type Cleaning
Fluids or Degreasers. TCE product concentration based on
average of midpoint % TCE in formulation for 13 mold
release products
3,159 (EPA 2011a) product category: Other Lubricants (excluding
automotive). TCE product concentration based on average
of midpoint % TCE in formulation for 7 lubricant products
(40-60, 5-10, 15.7-25.8, 5-10, 7-13, 7-13, 40-50).
2,184 (EPA 2011a) product category: Adhesives. TCE product
concentration based on average of midpoint % TCE in
formulation for 14 adhesive products
2,911 (EPA 2011a) product category: Spot removers. TCE
product concentration based on average of midpoint % TCE
in formulation for 3 dry cleaning products
190 (EPA 2011a) product category: Solvent-Type Cleaning
Fluids or Degreasers. TCE product concentration based on
average of midpoint % TCE in formulation for 3 liquid
degreasers
1See
Table 6-8.
assumption.
3See Notes Column.
4See Table 17-6 in EPA 2011a).
2EPA
Baseline Analysis
6-36
7. Cost Analysis
This chapter presents the estimated incremental costs of the options considered in this analysis across the
regulated use categories. Section 7.1 summarizes the options considered for each use category. Section
7.2 addresses the timeframe of the analysis with respect to annualized costs. Section 7.3 presents a
summary of the number of affected entities with incremental costs. Section 7.4 presents the fully loaded
wage rates used in the economic analysis. Section 7.5 presents the estimated costs associated with rule
familiarization and downstream notification. Section 7.6 presents estimated costs for the reformulation of
products containing TCE. Section 7.7 presents estimated costs for switching to alternatives to TCE in
vapor degreasing. Section 7.8 presents estimated costs for compliance with the dermal protection
component of a Workplace Chemical Protection Program (WCPP). Section 7.9 presents estimated costs
for compliance with the respiratory protection components of a WCPP. Section 7.10 summarizes the total
costs for WCPP compliance. Section 7.11 presents the estimated costs for the interim prescriptive
controls required for aerosol spray energized electrical cleaners. Section 7.12 presents a discussion of
unquantified costs and other uncertainties underlying the cost estimates. Section 7.13 presents the total
annualized costs under the options.
Figure 7-1, on the following page, presents an overview of the key elements of the cost analysis.
Figure 7-1: Overview of Key Quantified Elements of the Cost Analysis
Cost Analysis
7-1
7.1 Description of Options
Table 7-1 summarizes the regulatory options by use category. The options are described in more detail in
section 1.2.
Cost Analysis
7-2
Table 7-1: Summary of Regulatory Options by Use Category
Cost Analysis
7-3
Option 1 (ECEL of 0.2 ppm)
Option 2 (ECEL of 0.0011ppm)
WCPP followed by prohibition1
Prohibition/WCPP followed by prohibition2
Use Category
1Asphalt
Laboratory Use
Manufacturing
Import/Repackage
Battery and Synthetic
Paper Processing Aid
HFC Manufacturing
2Asphalt Testing: Prohibited. Other lab uses:
Testing: WCPP for 10 years followed
by prohibition (10-year 6g exemption). Other lab Exempt for 50 years, interim requirements of
uses: Exempt for 50 years, interim requirements
Workplace Chemical Protection Program
of Workplace Chemical Protection Program
(WCPP) 6 months after rule finalization.
(WCPP) 6 months after rule finalization.
WCPP for limited uses until prohibited3
3Interim requirements of Workplace Chemical Protection Program (WCPP) 6 months after rule
finalization.
WCPP followed by prohibition5
WCPP followed by prohibition4
420-year
510-year exemption with WCPP 6 months after
exemption with WCPP 6 months after
rule finalization for lead acid battery separators.
rule finalization for battery separator
5-year exemption with WCPP 6 months after
manufacture. Synthetic paper use prohibited.
rule finalization for lithium battery
separators.15-year exemption with WCPP 6
months after rule finalization for synthetic paper.
Long-Term Phase Out with WCPP followed by Prohibition6
6Long-term
phase out to prohibition over 8.5 years, interim requirements of WCPP.
Not Subject to Rule
WCPP followed by prohibition7
Intermediate in HCl
Production
Fluoroelastomer
Manufacture
Open-Top Vapor
Degreasing
Enclosed Vapor
Degreasing
Conveyorized/Web
Vapor Degreasing
Batch Cold Cleaning
Disposal to Wastewater
Cost Analysis
7WCPP
6 months to 2 years after rule
finalization followed by prohibition.
WCPP followed by Prohibition8
8WCPP
6 months to 2 years after rule finalization followed by prohibition.
Prohibition with Interim WCPP for Exemptions9
9A
6(g) exemption for 7 years applies to OTVD for narrow tubes for aerospace or medical device
use. A 6(g) exemption for 10 years applies to naval combat systems, radars, sensors, equipment, and
fabrication and prototyping processes for OTVDs. A 6(g) exemption for 7 years applies to humanrated rocket engine cleaning in EVDs by Federal agencies and their contractors. A 6(g) exemption
for 10 years applies to rayon fabric scouring in EVDs for rocket booster nozzle production for
Federal agencies and their contractors.
Prohibition11
Prohibition 1 year after rule finalization with
WCPP requirements for POTWs exceeding a
11One year after rule finalization.
water screening level and worker protection
requirements for cleanup sites and industrial
treatment/pre-treatment. 10
10For POTWs above the water screening level,
WCPP would be required (with the interim
occupational exposure limit (ECEL)). For
cleanup site workers and industrial
treatment/pre-treatment, use TSCA regulatory
limit (new interim occupational exposure limit
(ECEL)) within the framework of existing
OSHA HAZWOPER requirements.
7-4
Table 7-1: Summary of Regulatory Options by Use Category
Use Category
Option 1 (ECEL of 0.2 ppm)
Option 2 (ECEL of 0.0011ppm)
Prohibition13
Prohibition with Interim APF50 Respirator
Requirement12
Energized Electrical
Cleaners
Incorporation into
Formulation, Mixture,
or Reaction Product
Commercial Use Pepper
Spray
Incorporation into
Articles
Mold Release
Liquid Cleaners and
Degreasers
Aerosol Spray
Cleaning/Degreasing
(except EEC)
Lubricants and Greases
Adhesives, Sealants,
Paints and Coatings3
Functional Fluids
Spot Removers
Film Cleaner
Toner Aid
13Six
months after rule finalization.
12Prohibit
3 years after rule finalization with
interim prescriptive respiratory protection
requirements of APF 50 respirator use.
Prohibition14,15
14Prohibition
six months after rule finalization.
15Adhesives
and Sealants for Aerospace uses have a 5-year exemption with interim WCPP. Since
the numbers of workers affected by the exemption is unknown, the exemption is not accounted for
in the analysis and the costs and benefits from prohibition are assumed for all affected users of
adhesives, sealants, paints, and coatings.
Polish
7.2 Timeline for the Analysis
In selecting the number of years of the regulatory options to consider in the cost-benefit analysis, it is
important to select a timeframe sufficiently long enough to capture the important effects of the benefits
and the costs without selecting a timeframe that is so long that it adds unnecessary uncertainty. In
addition, EPA’s (2014a) Guidelines for Preparing Economic Analyses suggests the following when
selecting the time horizon:
“That is, the time horizon should be long enough that the net benefits for all future years (beyond the
time horizon) are expected to be negligible when discounted to the present. In practice, however, it is
not always obvious when this will occur because it may be unclear whether or when the policy will be
renewed or retired by policy makers, whether or when the policy will become obsolete or “nonbinding” due to exogenous technological changes, how long the capital investments or displacements
caused by the policy will persist, etc.
As a practical matter, reasonable alternatives for the time span of the analysis may be based on
assumptions regarding:
•
The expected life of capital investments required by or expected from the policy;
•
The point at which benefits and costs reach a steady state;
Cost Analysis
7-5
•
Statutory or other requirements for the policy or the analysis; and/or
•
The extent to which benefits and costs are separated by generations.”
The recommendation in EPA’s (2014a) guidance that “the time horizon should be long enough that the
net benefits for all future years (beyond the time horizon) are expected to be negligible when discounted
to the present” would imply that a fairly long time horizon would be appropriate. For example, if one
assumes that the rule never becomes obsolete or non-binding, net benefits in the 100th year of the policy
would still exceed $100,000 after discounting them back to present dollars using a 3% discount rate.
However, the probability that the rule becomes obsolete increases over time. For example, newer
chemicals or other technological advances could make TCE obsolete without any rule. Given this
uncertainty, EPA selected a shorter time horizon of 20 years for the analysis. A time period of 20 years is
short enough that the products that were reformulated to be TCE-free would probably not need to be
reformulated again during that time period. In addition, the annualized costs and benefits of the rule start
to level out at a 20-year time horizon. Thus, selecting a longer time horizon is unlikely to have a
significant effect on the relative rankings of the options under consideration.
The present discounted value for the annualized value of the 20-year stream of costs is estimated using
discount rates of 2, 3 and 7 percent. Costs are discounted (for the discount rate r = 3% and r = 7%) back to
the beginning of the 20-year period, as follows:
𝑃𝑟𝑒𝑠𝑒𝑛𝑡 𝐷𝑖𝑠𝑐𝑜𝑢𝑛𝑡𝑒𝑑 𝑉𝑎𝑙𝑢𝑒 =
(𝑈𝑛𝑑𝑖𝑠𝑐𝑜𝑢𝑛𝑡𝑒𝑑 𝑉𝑎𝑙𝑢𝑒)
(1 + 𝑟)
(1)
The present discounted value costs are annualized as follows:
(𝐴𝑛𝑛𝑢𝑎𝑙𝑖𝑧𝑒𝑑 𝐶𝑜𝑠𝑡𝑠) = (𝑃𝐷𝑉
)∗
𝑟 ∗ (1 + 𝑟)
(1 + 𝑟) − 1
(2)
7.2.1 Accounting for the timing of implementing phased-in requirements
With the exception of the prohibitions on manufacture and import for most conditions of use, most other
requirements are effective between 6 to 12 months after the rule is finalized. To simplify the calculations,
“time zero” for the analysis is 6-12 months after the rule is finalized. The timing of requirements that are
phased in over time are accounted for by rounding to the nearest year. Thus, no distinction is made for
implementation 6 to 12 months after rule finalization is made. For example, under Option 1 laboratories
using TCE for asphalt testing must comply with a WCPP starting 6 months after the rule is finalized
through 10 years after the rule is finalized. After 10 years TCE is prohibited for this use. The analysis
accounts for this as 9 years of meeting WCPP requirements and 11 years of prohibition.
It is also worth noting that the prohibition on TCE for laboratory uses goes into effect more than 20 years
after the rule is finalized, which is after the end of the analytical timeframe for our analysis. Whether
alternatives for TCE in laboratory testing will be available in 25 or 30 years is unknown, and what their
costs would be is also unknown. Therefore, this analysis does not extend its timeframe to 25 or 30 years
because the costs and benefits that would be incurred that many years in the future are highly uncertain.
Table 7-2: Summary of Timing of Requirements under the Rule and the Analysis by Use Category
Cost Analysis
7-6
Use Category
Laboratory Use
Manufacturing
Import/Repackage
Battery and Synthetic Paper
Processing Aid
Cost Analysis
Option 1 (ECEL of 0.2 ppm)
Option 2 (ECEL of 0.0011ppm)
Rule: Asphalt Testing: WCPP for 10 years
followed by prohibition (10-year 6g
exemption). Other lab uses: Exempt for 50
years, interim requirements of Workplace
Chemical Protection Program (WCPP) 6
months after rule finalization
Analysis: Asphalt Testing: WCPP for 9
years followed by prohibition (where
WCPP costs are used as a proxy for the
unknown costs of prohibition). Other lab
uses: WCPP for 20 years
Rule: Asphalt Testing: Prohibited. Other
lab uses: Exempt for 50 years, interim
requirements of Workplace Chemical
Protection Program (WCPP) 6 months
after rule finalization. Other lab uses:
Exempt for 50 years, interim requirements
of WCPP 6 months after rule finalization
Analysis: Asphalt Testing: 20 years of
prohibition (where WCPP costs are used
as a proxy for the unknown costs of
prohibition). Other lab uses: WCPP for 20
years
Rule: Limited to permitted uses with
WCPP 6 months after rule finalization
Analysis: 20 years of WCPP for
Manufacturing; other uses are
discontinued.
Rule: 10-year exemption with WCPP 6
months after rule finalization for battery
separator manufacture. 2-year exemption
with WCPP 6 months after rule
finalization for synthetic paper.
Analysis: 9 years of WCPP and 11 years
of prohibition (where WCPP costs are
used as a proxy for the unknown costs of
prohibition) for battery separator
manufacture. 20 years of prohibition
(where WCPP costs are used as a proxy
for the unknown costs of prohibition) for
synthetic paper.
Rule: Limited to permitted uses with
WCPP 6 months after rule finalization
Analysis: 20 years of WCPP for
Manufacturing; other uses are
discontinued.
Rule: 20-year exemption with WCPP 6
months after rule finalization for lead acid
batteries. 5-year exemption with WCPP 6
months after rule finalization for lithium
batteries.15-year exemption with WCPP 6
months after rule finalization for synthetic
paper.
Analysis: 14 years of WCPP and 6 years
of prohibition (where WCPP costs are
used as a proxy for the unknown costs of
prohibition). Note that the lithium ion
separator manufacturer producers the leadacid separator in the same facility.
7-7
HFC Manufacturing
Intermediate in HCl Production
Fluoroelastomer Manufacture
Open-Top Vapor Degreasing
Enclosed Vapor Degreasing
Conveyorized/Web Vapor
Degreasing
Batch Cold Cleaning
Disposal to Wastewater
Cost Analysis
Rule: Long-term phase out to prohibition
over 8.5 years, interim requirements of
WCPP
Analysis: 9 years of WCPP (no costs after
year 9 since it is a baseline phase-out).
Rule: Not subject to the rule
Analysis: Costs are zero because they are
exempt.
Rule: Exempt for 2 years (with interim
WCPP)
Analysis: 1 year of WCPP and 19 years of
prohibition (where WCPP costs are used
as a proxy for the unknown costs of
prohibition)
Rule: Prohibition 1 year after rule
finalization except for 6g exemptions. A
6g exemption for 7 years applies to narrow
tubes and medical device use. A 6g
exemption for 10 years applies to naval
combat systems, radars, sensors,
equipment, and fabrication and
prototyping processes.
Analysis: 5 OTVDs are assumed to have 6
years of WCPP and 14 years of
prohibition. 1 OTVD is assumed to have 9
years of WCPP and 11 years of
prohibition. Other OTVDs are assumed to
have 20 years of prohibition.
Rule: Prohibition 1 year after rule
finalization, except for 6g exemptions. A
6g exemption for 7 years applies to
human-rated rocket engine cleaning by
Federal agencies and their contractors. A
6g exemption for 10 years applies to rayon
fabric scouring for rocket booster nozzle
production for Federal agencies and their
contractors.
Analysis: Prohibition at time zero, except
for one vapor degreaser with 6 years of
WCPP and 14 years of prohibition and one
vapor degreaser with 9 years of WCPP and
11 years of prohibition.
Rule: Prohibition 1 year after rule
finalization
Analysis: Prohibition at “time zero”
Rule: Prohibition 1 year after rule
finalization1,2 with WCPP requirements for
POTWs exceeding a water screening level
and worker protection requirements for
cleanup sites and industrial treatment/pretreatment.
Analysis: Costs for clean-up sites are not
estimated, as these facilities are likely to
be in compliance under the baseline. Costs
are estimated as the WCPP costs for the
affected POTWs.
Rule: Long-term phase out to prohibition
over 8.5 years, interim requirements of
WCPP
Analysis: 9 years of WCPP (no costs after
year 9 since it is a baseline phase-out).
Rule: Exempt for 2 years (with interim
WCPP)
Analysis: 1 year of WCPP and 19 years of
prohibition (where WCPP costs are used
as a proxy for the unknown costs of
prohibition)
Rule: Prohibition 1 year after rule
finalization
Analysis: Prohibition at “time zero”
Rule: Prohibition 1 year after rule
finalization2
Analysis: Costs for clean-up sites are not
estimated. Costs are estimated as the
WCPP costs for the affected POTWs.
7-8
Energized Electrical Cleaners
Incorporation into Formulation,
Mixture, or Reaction Product
Commercial Use Pepper Spray
Incorporation into Articles
Mold Release
Liquid Cleaners and Degreasers
Aerosol Spray
Cleaning/Degreasing (except EEC)
Lubricants and Greases
Adhesives, Sealants, Paints and
Coatings3
Functional Fluids
Spot Removers
Film Cleaner
Toner Aid
Rule: Prohibit 3 years after rule
finalization with interim prescriptive
respiratory protection requirements3
Analysis: 2 years of APF 50 PPE and 19
years of prohibition.
Rule: Prohibit 6 months after rule
finalization3
Analysis: Prohibition at “time zero”
Rule: Prohibit 6 months after rule
finalization
Analysis: Prohibition at “time zero”
Polish
1For POTWs above the water screening level, WCPP would be required (with the interim occupational exposure limit (ECEL)).
2For cleanup site workers and industrial treatment/pre-treatment, use TSCA regulatory limit (new interim occupational
exposure limit (ECEL)) within the framework of existing OSHA HAZWOPER requirements.
3Adhesives and Sealants for Aerospace uses have a 5-year exemption with interim WCPP. Since the numbers of workers
affected by the exemption is unknown, the exemption is not accounted for in the cost analysis.
7.3 Summary of Number of Affected Entities
Table 7-3 presents the estimated numbers of sites and workers. Descriptions of how these estimates were
derived are presented in section 6.2.
Cost Analysis
7-9
Table 7-3: Number of Sites, Workers, and ONUs Affected by TCE Risk Management
Number of
Facilities
Number of
Workers
251
251
2,259
Manufacturing
2
140
68
Import/Repackage
9
18
9
Battery and Synthetic Paper Processing Aid
3
51
24
HFC Manufacturing
2
38
18
28
532
252
Fluoroelastomer Manufacture
2
34
16
Open-Top Vapor Degreasing
350
2,100
1,400
Enclosed Vapor Degreasing
7
42
28
Conveyorized Vapor Degreasing
8
48
32
Web Vapor Degreasing
1
6
4
52
312
208
Disposal to Wastewater
739
9,607
3,695
Energized Electrical Cleaners
668
1,201
143
Incorporation Into Formulation, Mixture, or Reaction Product
28
448
140
Mold Release
17
371
44
11,815
16,053
1,667
3,698
4,651
553
345
1,751
76
65
616
288
4,980
14,940
3,735
Film Cleaner
-
-
-
Toner Aid
-
-
-
Polish
-
-
-
Pepper Spray
-
-
-
23,070
53,210
14,659
Use Category
Laboratory Use
Intermediate in HCl Production
Batch Cold Cleaning
Liquid Cleaners and Degreasers
Aerosol Spray Cleaning/Degreasing
Lubricants and Greases
Adhesives, Sealants, Paints and Coatings
Spot Removers
Total
Number of
ONUs
Notes: See section 6.2 for a description of assumptions and sources used to develop the estimates.
7.4 Industry Wage Rates
Wage and fringe benefit data for each labor category (e.g., managerial, professional/technical, clerical)
are taken from the U.S. Bureau of Labor Statistics (BLS) Employer Costs for Employee Compensation
(ECEC) Supplementary Tables (BLS 2023b). In the BLS report, wages are represented by the “wages and
salaries” cost component and fringe benefits are represented by “total benefits.”
Overhead costs are assumed to equal 20% of the sum of wages plus fringe benefits. This loading factor is
described in Handbook on Valuing Changes in Time Use Induced by Regulatory Requirements and Other
U.S. EPA Actions (EPA 2020g), and is reflective of multiplier values used in prior EPA economic
analyses and information collection requests (ICRs) that are based on industry- and occupation-specific
Cost Analysis
7-10
overhead rates affected by EPA regulations. This overhead loading factor is multiplied by the total
compensation (wages plus fringe benefits). For example, the December 2022 fully loaded wage for
production labor is ($21.79 + $11.63) * 1.2 = $40.10. Table 7-4 presents the total hourly loaded wages
used in this analysis.
Cost Analysis
7-11
Table 7-4: Industry Wage Rates (2022$)
Labor Category
Manufacturing/
Managerial
Manufacturing/
Production Worker
Transportation and
Public Utilities/
Managerial
Transportation and
Public Utilities/
Maintenance and
Repair Worker
Services/
Managerial
Services/
Maintenance and
Repair Worker
Certified Industrial
Hygienist
Technical Specialist
Vapor Degreasing
Technician
Senior Engineer and
Technical Advisor
(vapor degreasing)
Cost Analysis
Data Series
BLS ECEC, Private Manufacturing industries,
“Mgt, Business, and Financial”2
BLS ECEC, Private Manufacturing Industries,
“Production occupations”2
BLS ECEC, Trade, Transportation, and
Utilities Industries, “Mgt, Business, and
Financial” 2
BLS ECEC, Trade, Transportation, and
Utilities Industries, “Installation, maintenance,
and repair"2
BLS ECEC, Service-providing Industries,
Management, professional, and related
occupations, “Mgt, Business, and Financial”
BLS ECEC, Service-providing Industries,
Natural resources, construction, and
maintenance occupations, “Installation,
maintenance, and repair"
Wage: BLS OEWS Occupational Health &
Safety Specialists (19-5011) Fringes as percent
of wage: BLS ECEC, Private Manufacturing
industries, “Professional and related
occupations” 3,4
Wage: BLS OEWS Occupational Health &
Safety Technicians (19-5012) Fringes as
percent of wage: BLS ECEC, Private
Manufacturing industries, “Professional and
related occupations” 3,4
Wage: BLS OEWS Plant and Systems
Operators (51-8000) Fringes as percent of
wage: BLS ECEC, Manufacturing industry 3,4
Wage: BLS OEWS Architectural and
Engineering Managers (11-9041) Fringes as
percent of wage: BLS ECEC, Manufacturing
Overhead
as % of
Total
Compensation1
Overhead
Hourly
Loaded
Wages
(d)
(e)=(c)*(d)
(f)=(c)+(e)
Wage
($/hour)
Fringe
Benefit
Total
Compensation
(a)
(b)
(c)
=(b)+(a)
Dec-22
$54.29
$24.66
$78.95
20%
$15.79
$94.74
Dec-22
$21.79
$11.63
$33.42
20%
$6.68
$40.10
Dec-22
$54.12
$21.82
$75.94
20%
$15.19
$91.13
Dec-22
$31.08
$15.29
$46.37
20%
$9.27
$55.64
Dec-22
$54.77
$24.99
$79.76
20%
$15.95
$95.71
Dec-22
$28.39
$13.15
$41.54
20%
$8.31
$49.85
May-22
$39.47
$19.96
$59.43
20%
$11.89
$71.32
May-22
$30.40
$15.38
$45.78
20%
$9.16
$54.93
May-22
$33.85
$17.12
$50.97
20%
$10.19
$61.16
May-22
$78.52
$39.71
$118.23
20%
$23.65
$141.88
Date
7-12
Table 7-4: Industry Wage Rates (2022$)
Labor Category
Data Series
Date
Wage
($/hour)
Fringe
Benefit
Total
Compensation
(a)
(b)
(c)
=(b)+(a)
Overhead
as % of
Total
Compensation1
Overhead
Hourly
Loaded
Wages
(d)
(e)=(c)*(d)
(f)=(c)+(e)
industry 3,4
1
An overhead rate of 20% is used based on assumptions in Handbook on Valuing Changes in Time Use Induced by Regulatory Requirements and Other U.S. EPA Actions (EPA
2020g).
2 Source: Employer Costs for Employee Compensation Historical Supplementary Tables, National Compensation Survey: December 2022 (BLS 2023b).
3 Source: Occupational Employment Statistics (Occupational Employment and Wage Statistics) for May 2022 (BLS 2023c).
4 Fringe benefits are not reported in the BLS OEWS (BLS 2023c). It is therefore assumed that fringes as a percentage of wages are 50.576%, based on the percentage for Private
Manufacturing Industries, “Professional and related” in the BLS ECEC (BLS 2023b).
Cost Analysis
7-13
7.5 Rule Familiarization and Downstream Notification Costs
7.5.1 Rule Familiarization
Firms that are not subject to WCPP requirements are assumed to incur an initial managerial labor burden
of one hour and firms that are subject to WCPP requirements are assumed to incur an initial industrial
hygienist labor burden of three hours. The additional two hours of rule familiarization for firms subject to
WCPP requirements are a result of the complexity of WCPP compliance when compared to firms subject
to prohibition requirements. The wage rates used for the Disposal to Wastewater use category are the
transportation and public utilities sector wages ($91.13). The wage rate for the Aerosol Spray
Cleaning/Degreasing and Spot Removers use categories are the service sector wages ($95.71). The
manufacturing sector wage was used for other use categories ($94.74).
Cost Analysis
7-14
Table 7-5: Total Rule Familiarization Costs (2022$)
Use Category
Number of Firms
Initial Costs
Rule Familiarization Costs for Firms Subject to Prescriptive Controls or WCPP Requirements
Laboratory Use
251
$53,704
Manufacturing
2
$428
Battery and Synthetic Paper Processing Aid
3
$642
HFC Manufacturing
2
$428
28
$5,991
Fluoroelastomer Manufacture
2
$428
Open-Top Vapor Degreasing
350
$74,886
Intermediate in HCL Production
7
$1,498
Disposal to Wastewater
739
$158,116
Energized Electrical Cleaners
668
$142,892
Enclosed Vapor Degreasing
Rule Familiarization Costs for Entities Subject to Prohibition
Import/Repackage
Open-Top Vapor Degreasing
9
$853
350
$33,159
Enclosed Vapor Degreasing
7
$663
Conveyorized Vapor Degreasing
8
$758
Web Vapor Degreasing
1
$95
52
$4,926
Disposal to Wastewater
739
$70,013
Energized Electrical Cleaners
668
$63,272
28
$2,653
Batch Cold Cleaning
Incorporation Into Formulation, Mixture, or Reaction Product
Mold Release
17
$1,611
11,815
$1,119,353
3,698
$353,950
345
$32,685
65
$6,158
Spot Removers
4,980
$476,636
Option 1 Total
23,042
$2,391,092
Option 2 Total
23,070
$2,228,405
Liquid Cleaners and Degreasers
Aerosol Spray Cleaning/Degreasing
Lubricants and Greases
Adhesives, Sealants, Paints and Coatings
Notes: Green shading indicates use categories expected to comply with WCPP requirements under Option 1 & 2.
Blue shading indicates use categories expected to comply with WCPP requirements under Option 2 only. Note
there is longer term compliance timeframe applicable to five Open-Top Vapor Degreasers using TCE for narrow
tubes and medical device (7 years), one Open-Top Vapor Degreaser using TCE in naval combat systems, radars,
sensors, equipment, and fabrication and prototyping processes (10 years), one enclosed vapor degreasing
application using TCE to scour rayon fabric for use in rocket booster engine nozzles (10 years). The analysis
accounts for one enclosed vapor degreaser and one Open-Top Vapor Degreaser with 9 years of WCPP costs and
prohibition costs in years 10-20, One enclosed vapor degreaser and five Open-Top Vapor Degreaser with 6 years
of WCPP costs and prohibition costs in years 7-20. Other vapor degreasers have prohibition costs starting at
“time zero”.
7.5.2 Downstream Notification
For conditions of use that are initially permitted to continue under this regulation, EPA is requiring that
manufacturers (including importers), processors, and distributors, excluding retailers, of TCE and TCEcontaining products provide downstream notification of the prohibitions through Safety Data Sheets
Cost Analysis
7-15
(SDSs). It is assumed that each of the 2 manufacturers and 9 importer/repackage firms spend 2 hours
amending their SDSs to include this notification, resulting in a total initial cost of $189 per facility for
downstream notification.
7.6 Reformulation Costs
This section describes the estimated costs for processors who currently formulate products containing
TCE and are expected to reformulate their products in response to a risk management option.
Reformulation involves changing the composition of a product or otherwise changing how it is produced,
and can include activities such as research and development, laboratory testing, and product re-labeling.
Reformulation may be necessary when a chemical use is prohibited (requiring manufacturers to produce
alternative products that do not contain the banned chemical) or when a concentration or emission limit is
imposed (requiring manufacturers to either produce alternative products that do not contain the banned
chemical or to produce a version of the current product that complies with the rule).
Note that manufacturers may comply with a rulemaking by using alternative compliance strategies. For
example, if a processor manufactures similar products that are already compliant with the rule, they may
switch production away from the non-compliant product without needing to reformulate. On the other
hand, if manufacturers only have one product and that product contains the regulated chemical, they will
either need to reformulate that product or discontinue production altogether.
It is also important to note that downstream users of the products that are reformulated may also incur
costs (or cost savings) when products are reformulated. These costs are not explicitly addressed in this
section but are discussed above in Chapter 3. For example, when reformulation results in higher
production costs, some of these costs may be passed on to downstream users. These costs are accounted
for and attributed to the producer who reformulated and are not double-counted as a downstream user cost
in such an instance (even though these costs may be ultimately incurred by users). Another example of
when downstream users might have additional costs resulting from reformulation is when the
reformulated product does not perform as well or is otherwise not a perfect drop-in substitute and they
need to make changes in how they use the product. As discussed in section 7.11, the analysis is unable to
quantify these additional potential costs.
Reformulation costs are dependent on factors such as formulation complexity, reformulation approach,
and cost of alternative chemical inputs. Thus, the cost of product reformulation is highly variable.
Because information on chemical formulation and production processes are proprietary for many firms,
limited data also produce a high degree of uncertainty surrounding reformulation cost estimates.
The bullets below describe two of the potential strategies for reformulation: substitution and product
discontinuation.
•
Substitution. Substitution for another chemical input will vary in complexity. Products that can use
drop-in chemical substitutes may not need extensive production and packaging changes. However, if
the substitute is not as easily integrated into the existing product (e.g., if a solid powder is used to
replace a liquid), manufacturers may have higher costs related to raw material, research and
development, testing, labeling, packaging changes, and/or production changes. As the relative
importance (in terms of functional or safety performance) of the regulated chemical increases, it is
likely that the number and magnitude of cost components also increases (RTI 2002).
•
Product Discontinuation. If manufacturers anticipate high costs associated with large-scale
substitution and/or production changes, the analysis should consider whether those manufacturers will
comply with the rule by discontinuing their product line. This economic analysis assumes that
products will be reformulated.
Cost Analysis
7-16
7.6.1 Reformulation Cost Components
This analysis identified six reformulation cost components that manufacturers may incur, depending on
the type of product and the reformulation approach. These cost components are synthesized from those
described in RTI (2002) and CARB (2013).
1. Research and product development. This component involves a technical team identifying the
reformulation strategy, developing a new product formula, and evaluating product prototypes. It
may also include sourcing any new raw materials and specifying new packaging.
2. Product performance testing. Manufacturers may conduct several types of product testing.
a. Stability testing. Ensures that the new formulation will maintain its composition under a
variety of environmental conditions for a reasonable amount of time. This component is
particularly applicable if the new formulation requires new packaging, a new chemical
input, and/or a production change.
b. Efficacy testing. Ensures the product performance meets any label claims and established
consumer expectations.
c. Safety testing. Ensures the new formulation is safe for employees to manufacture and
transport and for consumers to use and store.
3. Production and manufacturing changes. Production changes may include re-tooling of
production lines, new technology/equipment, and/or construction of new facilities.
Reformulations for minor chemical inputs typically would not require major adjustments to the
production process, but more substantial changes may be necessary for reformulations involving
critical formulation components. This cost component may include a plant trial to ensure that
production changes are feasible. For minor production changes, pilot plant testing (i.e., a smallscale version of the full production) may be sufficient and will not require as many resources as a
plant trial. Costs may also be incurred to start-up production after the plant trial and to verify that
necessary product and production specifications are being met.
4. Packaging. Packaging changes are only likely to be necessary if the regulated substance is a
critical component.
5. Labeling. Labeling modifications may be necessary if product qualities or use instructions
change.
6. Marketing. Marketing costs may include focus group testing, surveys, advertising, and new
technical literature. Market group testing (e.g., focus groups and surveys) will likely not be
conducted in most cases; it is likely only to be performed by large companies for high-profile
products requiring a major reformulation. Similarly, advertising is likely only a relevant cost if a
manufacturer will change its advertising campaign in response to the reformulation (e.g., to
emphasize that the product no longer contains the regulated chemical). Updates to the technical
literature may be necessary for major attribute changes of the reformulated product (e.g., new use
or safety instructions).
Table 7-6 is adapted from a similar table in RTI (2002) and presents suggestions for the types of cost
components incurred under each reformulation strategy.
Cost Analysis
7-17
Table 7-6: Example Cost Components, by Reformulation Approach
Substitution
Cost Component
Recurring Raw Material Cost
Research and Product Development
Stability Testing
Efficacy Testing
Safety Testing
Process Change
Start-up and Verification
Full-Scale Plant Trial
Pilot Plant Testing
Packaging
Labeling
Marketing
Market Group Testing
Technical Literature
1 Components
2 Components
Non-Critical
Component1
Critical
Component2
Production
Process
Change
that do not have functional or safety uses (e.g., preservatives, dyes/colorants)
that have critical functional or safety uses
EPA has identified three sources that provide reformulation cost estimates. Each source and its limitations
is described in the sections below.
7.6.1 (A) Cheminfo Services (2006)
Cheminfo Services (2006) estimated reformulation costs for 25 categories of automotive aftermarket
chemical products for Environment Canada in support of a regulation implementing volatile organic
compound (VOC) content limits. These products included adhesives, air fresheners, brake cleaners,
engine degreasers, and paint removers. Cheminfo Services (2006) sent a questionnaire to 120 companies
(55 responses) asking about costs associated with reformulation, with information ultimately provided for
39 products. The manufacturers responded with a wide range of estimated capital costs of reformulation
($0 to $78,000 in 2005 CAN$), with a mean value of $21,707 per product (2005 CAN$). Notably, capital
costs for products using a dilution approach to reformulation were reported to be about half those for
other reformulation approaches.
There are several limitations to this study. First, Cheminfo Services (2006) only reports a single range of
reformulation capital costs, so EPA cannot determine how reported costs vary by reformulation approach
or product category. For example, dilution was a reformulation method used for 16% of the products in
the study, but reformulation costs for dilution cannot be distinguished from reformulation costs for more
complex reformulations. Similarly, questionnaire respondents were only asked to provide an estimate for
the total reformulation cost, such that EPA cannot determine which cost components the manufacturers
considered in their estimates and the relative contribution of each of those components.
However, the mean reformulation value may be a reasonable estimate for reformulating the TCEcontaining products that will be regulated under the rule. This mean value was used by both the Economic
Analysis of the Proposed TSCA Section 6 Action on Trichloroethylene in Dry Cleaning Spot Removers
and Aerosol Degreasers (EPA 2016a) and the Economic Analysis of the TSCA Section 6 Action on
Methylene Chloride, Paint and Coating Remover (EPA 2019a).
Cost Analysis
7-18
7.6.1 (B) California Air Resources Board (2013)
The California Air Resources Board (CARB) developed a method to estimate reformulation costs, which
it has used to estimate costs for products subject to several of its regulatory actions. These have included
consumer products such as solvents, aerosol paint thinners, and aerosol coatings. Appendix J of CARB’s
Initial Statement of Reasons for Proposed Rulemaking for Proposed Amendments to the Antiperspirants
and Deodorants Regulation, the Consumer Products Regulation, the Aerosol Coating Products
Regulation, the Tables of MIR Values, Test Method 310, and Proposed Repeal of the Hairspray Credit
Program details the methodology to estimate nonrecurring costs (CARB 2013). CARB identified eight
phases that manufacturing facilities will implement to produce a compliant product (e.g., product
development, labeling modification). For each phase, CARB then identified a set of cost components
(e.g., material, personnel, prototype equipment) for which it developed a set of per-product costs. Costs
and underlying assumptions were checked with stakeholders to verify reasonableness.
One limitation of CARB’s methodology is that the estimated component costs for each phase were
originally developed in 1991 and modified in 1999. These cost estimates were then adjusted to 2012$
using engineering plant cost indices. Production cost estimates from 20-30 years ago may not be
representative of reformulation costs in current facilities. For example, “Computer Support” is a separate
cost component for several reformulation phases and was potentially a more significant cost in 1991 than
it would be presently. Another limitation is that while CARB provides estimated costs for each
component, it does not provide the underlying calculations or methodology behind these estimates (e.g.,
burden hours, labor mix).
7.6.1 (C) RTI International (2002)
RTI International developed a food and cosmetics reformulation cost module for the U.S. Food and Drug
Administration (FDA) (RTI 2002). RTI identified a series of cost components that manufacturing
facilities may potentially incur when reformulating products to achieve compliance with FDA regulations.
Cosmetics manufacturers, industry trade association representatives, and food industry consultants and
laboratories were then interviewed to collect the information used to develop the cost estimates. Estimates
were based on respondents’ estimates of material costs, burden hours, and wage rates. RTI then built an
Excel-based tool that can be used to model reformulation costs based on user inputs (e.g., product
category, reformulation type).
To the extent that reformulating food and cosmetics differs from reformulating products subject to a
Section 6 action, RTI’s model may not reflect representative reformulation costs for the options being
considered in this analysis. RTI’s Excel-based tool only allows users to select products and NAICS codes
associated with the food and cosmetics industries and does not allow users to view costs for individual
reformulation components. However, RTI’s cost estimates for individual reformulation components are
presented in Table 7-7 and Table 7-8 based on their underlying data. As with the other sources, the
underlying data do not disaggregate component cost estimates by burden hours, wage rates, or material
costs.
7.6.2 Summary of Available Reformulation Unit Cost Estimates
Table 7-7 and Table 7-8 present a cross-walked summary of cost estimates from Cheminfo Services
(2006), CARB (2013), and RTI (2002) for minor and major modifications, respectively. The cost
component estimates for minor modifications in Table 7-7 approximately correspond to dilution and
substitution of non-critical component reformulation approaches. The cost component estimates for major
modifications in Table 7-8 approximately correspond to substitution of critical components (e.g.,
functional performance or safety uses) and production process changes. Note that EPA used best
professional judgement to map estimates from the three sources to a set of consistent cost components and
reformulation approaches, as each source differs in how it classifies these components and approaches.
Given the degree of uncertainty in each source’s reformulation cost estimates, a low-, high-, and mid- (for
RTI (2002)) range estimate is presented for each cost component.
Cost Analysis
7-19
The RTI (2002) estimates are generally the largest cost estimates, followed by Cheminfo Services (2006)
and CARB (2013). These differences may be the result of any number of differences in methodology or
end user industry, as described in the preceding sections. For example, the food and cosmetics products
evaluated by RTI (2002) may have more sophisticated formulations than the aerosol products evaluated
by CARB (2013). Or, differences in regulatory requirements and/or consumer expectations for food and
cosmetic products as compared to automotive products may incentivize food and cosmetic manufacturers
to invest more in the research and development and marketing phases.
The total cost estimates presented in the tables do not include recurring costs associated with changes in a
product’s raw materials. Cost estimates for each source are inflated to 2022$ using the Consumer Price
Index. Because EPA could not identify the dollar-year for the estimates presented in RTI (2002), it is
assumed that estimates are presented in 2001$.
Cost Analysis
7-20
Table 7-7: Crosswalk of Per-Formula Component Cost Estimates (2022$) - Minor Modification1
Cost Component
Research and Product Development
ChemInfo2
Low
CARB3
High
Low
RTI4
High
Low
Mid
High
-
-
$206
$8,044
$12,473
$52,891
$106,246
-Stability Testing
-
-
-
$1,856
$1,063
$3,657
$8,842
-Efficacy Testing
-
-
-
$1,856
-
-
-
-Safety Testing
-
-
-
$4,331
-
-
-
-
-
-
$1,841
$9,204
$20,294
-
-
-
Product Performance Testing
Production and Manufacturing Changes
-Process Change
-Start-up and Verification
-
-
-
$2,062
-Plant Testing
Packaging
-
-
-
-
-
-
-
Labeling
-
-
-
$1,856
-
-
-
-
-
-
$619
-
-
-
Marketing
-Market Group Testing
-Technical Literature
TOTAL
-
-
-
$412
-
-
-
$0
$27,906
$206
$21,037
$15,376
$65,752
$135,383
A dash "-" indicates that the source did not estimate costs for that component
1 Corresponds to dilution and substitution of non-critical component strategies (e.g. dyes/colorants, preservatives).
2 Low and high estimates correspond to minimum and mean capital cost estimates from Cheminfo Services (2006), respectively.
3 Corresponds to the Low Cost estimates from CARB (2013) (Tables J-1 to J-3). The low estimate is the minimum Low Cost estimate of three product types (adhesive,
aerosol multi-purpose solvent & paint thinner, aerosol coating), and the high estimate is the maximum Low Cost estimate of the three product types.
4 Corresponds to estimates for minor non-critical ingredients from RTI (2002).
Cost Analysis
7-21
Table 7-8: Crosswalk of Per-Formula Component Cost Estimates (2022$) - Major Modification1
Cost Component
Research and Product Development
ChemInfo2
Low
CARB3
High
Low
RTI4
High
Low
Mid
High
-
-
$8,044
$27,225
$49,882
$211,561
$424,983
-Stability Testing
-
-
$1,856
$9,487
$4,247
$14,626
$35,370
-Efficacy Testing
-
-
$1,856
$7,837
-
-
-
-Safety Testing
-
-
$4,331
$14,025
$3,305
$9,419
$34,702
$3,905
$12,916
$28,532
$7,363
$36,819
$180,324
$5,566
$20,294
$172,787
Product Performance Testing
Production and Manufacturing Changes
-Process Change
-Start-up and Verification
-
-
-
$2,062
-Plant Testing
Packaging
-
-
-
-
$10,262
$27,307
$51,310
Labeling
-
-
$1,650
$1,856
-
-
-
-Market Group Testing
-
-
$619
$2,062
$66,099
$115,674
$190,036
-Technical Literature
-
-
-
$412
-
-
-
$27,906
$100,276
$16,214
$57,386
$150,629
$448,616
$1,118,043
Marketing
TOTAL
A dash "-" indicates that the source did not estimate costs for that component
1 Corresponds to substitution of critical component and manufacturing process change strategies.
2 Low and high estimates correspond to mean and maximum capital cost estimates from Cheminfo Services (2006), respectively.
3 Correspond to the High Cost estimates from CARB (2013) (Tables J-1 to J-3). The low estimate is the minimum High Cost estimate of three product types (adhesive,
aerosol multi-purpose solvent & paint thinner, aerosol coating), and the high estimate is the maximum High Cost estimate of the three product types.
4 Corresponds to estimates for major ingredients and production process changes from RTI (2002).
Cost Analysis
7-22
7.6.3 Reformulation Unit Costs Used in this Analysis
This analysis considered two different reformulation costs, which vary according to how complex the
reformulation process is expected to be. The main source for the reformulation costs used in this analysis
is CARB’s (2013) analysis. EPA selected the CARB estimates as the primary basis for the reformulation
costs because they were developed for the same types of products considered in this analysis. In addition,
since the CARB estimates are disaggregated by type of cost, they can more easily accommodate
adjustments to reflect more or less complex reformulations. While the Cheminfo Services (2006)
estimates also pertain to similar types of products, there is no way to separate the costs for simpler
dilution reformulations and those that are more complex. EPA believes that the RTI (2002) estimates,
which were developed for reformulating food and cosmetics products, are likely to reflect higher
reformulation costs than would be expected for the types of products considered in this analysis.
However, EPA does use some of the RTI (2002) estimates’ cost components to estimate reformulation
costs for those products that are expected to require complex reformulations.
Table 7-9 presents the reformulation costs considered in this analysis. For each of the use categories
where reformulation is expected to be necessary, this analysis uses the standard substitution reformulation
cost. This estimate is based on CARB’s highest reformulation cost estimate. The complex substitution
reformulation cost estimate was considered and determined not to be applicable. It would be applicable
for use categories that are expected to require the most complex reformulations. This cost is a
combination of CARB’s highest reformulation cost estimate and the RTI (2002) estimates (R&D,
production and manufacturing, and package/labeling costs come from RTI (2002), and the other cost
components are based on CARB’s highest reformulation cost estimate).
Table 7-9: Reformulation Costs Used in this Analysis (2022$)
Cost Component
Research and Product Development
Standard Substitution Reformulation
Cost
$27,225
•
Stability Testing
$9,487
•
Efficacy Testing
$7,837
•
Safety Testing
$14,025
Production and Manufacturing
•
Process Change
•
Start-up and Verification
•
Plant Testing
Packaging/Labeling
$2,062
$1,856
Marketing
•
Market Group Testing
•
Technical Literature
TOTAL
$2,062
$412
$64,966
Table 7-10 indicates which of the reformulation costs presented in Table 7-9 corresponds to each of the
use categories considered in the analysis. As indicated, affected vapor degreasers and batch cold cleaning
machine users are assumed to switch to different cleaning methods that use existing cleaning agents or a
degreasing method using an existing degreasing fluid. For all other use categories, the analysis assumes
that the standard substitution reformulation costs are incurred.
Cost Analysis
7-23
Table 7-10: Reformulation Costs by Use Category
Use Category
No
reformulation
Standard
Substitution
Reformulation
Cost
($0)
($64,966)
Vapor degreasing fluids
Batch cold cleaning fluids
Notes
EPA assumes that vapor degreasers and batch cold cleaning
machine users will switch to vapor degreasing fluids that
already exist, or switch to a different cleaning method.
All other product formulations
Since alternatives already exist, EPA assumes the standard
substitution reformulation costs for these products.
Sources: CARB (2013) and RTI (2002)
7.6.4 Summary of Estimated Total Reformulations Costs by Use Category
Table 7-11 presents the estimated costs for the reformulation of products that would be necessary if TCE
were prohibited for all use categories. Note that EPA assumes a prohibition of TCE use in vapor
degreasing would result in switching to other cleaning methods and/or solvents that currently exist and
therefore would not require any reformulation.
Table 7-11: Total Reformulation Costs by Use Category
Mold Release
14
$64,966
Total Initial
Reformulation
Costs
$909,524
Liquid Cleaners and Degreasers
3
21
$64,966
$64,966
$1,364,286
4
7
$64,966
$64,966
Use Category
Aerosol Spray Cleaning/Degreasing
Energized Electronic Cleaner
Lubricants and Greases
Products
Reformulated
Reformulation
Costs per
Product
$194,898
16
$64,966
$259,864
$454,762
$1,039,456
Spot Removers
3
$64,966
$194,898
Pepper Spray
1
$64,966
$64,966
$64,966
$4,482,654
Adhesives, Sealants, Paints and Coatings
69
Total
7.7 Costs for Switching to Alternatives to TCE Vapor Degreasing (and TCE Batch
Cold Cleaning)
EPA estimates there are 366 facilities nationwide that use TCE for vapor degreasing (and 52 facilities that
use TCE in batch cold cleaning). This analysis also uses the estimated costs for switching to alternatives
to TCE vapor degreasing as the estimated costs for switching to alternatives to batch cold cleaning
machines. The estimated costs for switching to an alternative to TCE in vapor degreasing includes initial
capital costs and other transition costs (see sections 7.7.2 and 7.7.3). The total costs for switching to
alternatives to TCE in vapor degreasing are summarized in section 7.7.10).
EPA consulted with critical cleaning experts Barbara Kanegsberg and Ed Kanegsberg of BFK Solutions
about the costs of switching to alternatives to methylene chloride in vapor degreasing. BFK Solutions
helps manufacturers develop and/or optimize their cleaning processes. According to these experts, the
alternatives that would be technologically and economically feasible would primarily depend on:
Cost Analysis
7-24
-
the soils being removed,
-
the level of cleanliness required,
-
the characteristics of the components being cleaned,
-
the volume of components being cleaned,
-
and other factors.
Trial and error also add uncertainty to transition costs of an alternative cleaning process. Users may need
to test multiple different cleaning processes before identifying a successful process.
BFK Solutions provided expert estimates of the costs of switching from the use of methylene chloride in
different sized degreasers used in the different cleaning categories in the first two columns of Table 7-12
and the different cleaning methods presented the last column in Table 7-12 .
For this analysis, degreasers are defined as small, medium or large based on the cleaning chamber tank
size. Dimensions for the size categories are small–12 in. x 12 in. x 10 in.; medium–36 in. x 36 in. x 22
in.; large–60 in. x 42 in. x 36 in.).
This economic analysis defines four “cleaning categories” that would need different processes and
cleaning requirements for switching to an alternative cleaning method from vapor degreasing with
methylene chloride. These terms are defined relative to the expected end-use of the product and
consequences of inadequate or inappropriate cleaning.
•
•
•
•
General Cleaning is defined as having relatively low process development and low cost of
process verification. Primary costs will include equipment and performance testing.
High Precision Cleaning covers the cleaning of high value parts where very small residue is
acceptable, at best. Significant process development is needed; customer or other regulatory
performance standards may be the driving force. Primary costs will include evaluation, initial and
on-going performance testing and capital costs.
Safety Critical Cleaning includes product processes where performance failure is not an
acceptable option, because failure poses dire hazards for patient, public safety, or national
security and/or because the cost of failure would be prohibitively high (e.g., space flight). This
category will have higher costs for process verification and validation and may also cover
situations with very high-cost consequences of failure. Primary costs will include evaluation,
initial performance testing, cleanliness validation/verification, and capital costs.
Start-up/R&D Critical Cleaning covers the development process of new high precision or high
value products prior to production; these would typically not require large degreasers and would
need adaptable cleaning systems and perhaps multiple cleaning systems.
The list of cleaning methods in Table 7-12 is not exclusive. There are additional cleaning methods using
CO2, laser, and plasma that have not been included because they would be unlikely to be the primary
method to replace a baseline method. They may become needed as additional methods in order to achieve
required cleanliness specifications. Each method that is used will incur equipment and process
development costs.
Cost Analysis
7-25
Table 7-12: Sizes, Cleaning Categories, and Cleaning Methods Considered in the Vapor
Degreasing Cost Analysis
Size
Cleaning Category
Cleaning Method
Small
General
Baseline - OTVD with TCE
Medium
High Precision
Replace with Airless Degreaser with PCE
Safety Critical
Convert OTVD to use Flashpoint inerted t-DCE
Start-Up/R&D
Replace with OTVD using FlashPoint inerted t-DCE
Large
Replace with Solstice system (trans-1-chloro-3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and
Alcohols
Co-Solvent, Bi-Solvent
High boiling, non-vacuum, non-rinse
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (example: Inventec, HEMO)
Table 7-13 presents the descriptions of the baseline and alternative cleaning methods considered in this
analysis.
Cost Analysis
7-26
ble 7-13: Cleaning Methods and Their Definitions
eaning Method
eline - OTVD with TCE
less Degreaser with PCE
nvert OTVD to use Flashpoint inerted tE
place with OTVD using Flashpoint
rted t-DCE
stice® system (trans-1-chloro,3,trifluoropropene)
VD for Low boiling point (<100C)
cohol or other flammable
VD for Very low flashpoint (<0C)
vent
D for High Boiling Point Combustibles
00C) Hydrocarbons and Alcohols
Solvent, Bi-Solvent
Cost Analysis
Definition
An OTVD uses heated solvent in the liquid and/or vapor phase. For this analysis, the baseline OTVD uses TCE as the solvent. A
OTVD may or may not have a cover. It may be characterized by the equipment supplier using terms like “well-sealed” or havin
“minimal solvent emissions.” As defined here, OTVDs have an atmospheric air-solvent interface, which is why it is difficult to
meet the low emissions required by the methylene chloride ECEL. Some but not all current OTVDs using methylene chloride m
be the same as “National Emission Standards for Hazardous Air Pollutants (NESHAP) compliant” OTVDs, in that they may ha
double-coils and a high freeboard ratio. An OTVD may include ultrasonic cleaning and/or a spray wand.
An airless degreaser (sometimes referred to as an airless/airtight cleaning system) is equipment for which there is never an
atmospheric air-solvent interface. Solvent does not enter the working chamber until the product to be cleaned has been placed in
the chamber, the chamber has been sealed and air has been evacuated, usually to a level of one torr or less. Cleaning then can
occur, usually by computer control, either by immersion (with or without ultrasonics), spray, or vapor degreasing. As with
aqueous cleaning, solvent immersion cleaning could also include cyclic nucleation or cyclic cavitation, where the pressure is
changed to provide boiling cycles. Following cleaning and rinsing cycles, the solvent is pumped back into sealed reservoirs, and
the chamber is again pumped to a vacuum (sometimes through a carbon filter to capture residual traces of solvent vapors), thus
providing vacuum drying. A closed-loop degreaser is not the same as an airless degreaser. While an OTVD that
recirculates/redistills/reuses the solvent may be described as “closed loop”, such systems have not been demonstrated to match
low level of solvent loss achieved with an airless system.
An OTVD uses heated solvent in the liquid and/or vapor phase. For these cleaning methods, flashpoint inerted transdichloroethylene (trans-DCE) is the solvent. An OTVD may or may not have a cover. It may be characterized by the equipment
supplier using terms like “well-sealed” or having “minimal solvent emissions.” Since flashpoint inerted trans DCE blends are
more expensive, it may make sense for users to replace their OTVD if their existing machine is an older, more emissive model.
Trans-DCE is currently undergoing Risk Evaluation by TSCA. The fluorinated inerting agents are also under scrutiny by the U.
EPA and other regulators because of concerns about PFAS.
An OTVD uses heated solvent in the liquid and/or vapor phase. For these cleaning methods, trans-1-chloro-3,3,3,trifluoroprope
is the solvent. An OTVD may or may not have a cover. Because Solstice® has a low boiling point, the specifically designed
OTVD may be characterized by the equipment supplier using terms like “well-sealed” or having “minimal solvent emissions.”
Since trans-1-chloro-3,3,3,trifluoropropene blends are volatile and more expensive, it is very unlikely to be used as a “drop-in”
OTVDs currently in use for chlorinated or brominated solvents.
These systems are vapor degreasers where engineering controls have been employed to eliminate ignition and oxidation sources
order to ensure that flammable liquids can be used. They are certified to meet fire protection standards. Examples of low
flashpoint solvents include simple alcohols like methanol, ethanol, and propanol. An azeotrope of cyclohexane with isopropano
has also been used. The most common very low flashpoint solvent is acetone. It should be noted that, with the exception of
acetone, these other solvents are considered to be VOCs, and have restrictions in areas of poor air quality.
These are systems containing combustible (flashpoint > 37.8C) solvents, with boiling points greater than 100C. The solvents in
current use are either medium chain (~10-12 carbons) iso-paraffins or those that are called “modified alcohols”, such as isopropanol connected to a butane (4-carbon) chain. Because the primary concern is reducing flammability concerns rather than to
exposure, these systems are likely to be the same as airless degreasers, but need not be designed to completely eliminate the
emissions to the degree required from chlorinated and brominated solvents.
These are systems that use two organic solvents. For the purposes of this analysis, the terms Co-Solvent and Bi-Solvent are
interchangeable. In some cases, the cleaning agent (sometimes referred to as the solvating agent) is in one chamber and the rins
7-27
ble 7-13: Cleaning Methods and Their Definitions
eaning Method
Definition
agent (sometimes referred to as the displacement agent) is in a second tank and is used sequentially. In other designs, the washi
step is a mixture of cleaning agent and displacement agent.
Rinsing/displacement with Flashpoint-inerted trans DCE
Typically, a plant-based ester (such as a soy methyl ester is used as the cleaning or solvating agent. Nearly all current co-solven
or bi-solvent systems use flashpoint-inerted trans DCE as the displacement agent. The fluorinated inerting agents are also under
scrutiny because of concerns about PFAS.
h boiling, non-vacuum, non-rinse
mi-Aqueous
ueous Cleaning
Cost Analysis
Rinsing/displacement with alcohol (cost estimates do not reflect this possibility)
If ingredients of flashpoint-inerted trans DCE were to become unavailable through regulatory actions or business decisions, cosolvent and bi-solvent systems are options. Barbara Kanegsberg conducted cleaning studies at Litton Guidance and Control
Systems in the late 1980s- early 1990s for what we now term safety/critical military applications. Cleaning was demonstrated
using cleaning agents such as d-limonene or high-boiling hydrocarbon blends followed by repeated rinsing with isopropyl alcoh
The processes were more readily and consistently accomplished using perfluorocarbons which could not be used today. These
processes involved manual cleaning by highly-specialized technicians along with 100% inspection. Because current bi—solven
and co-solvent processes involve flashpoint-inerted trans-DCE as the rinsing/displacement agent, additional process developme
including testing, would be needed. Low flashpoint cleaning systems would be needed – this would add to equipment costs.
This method is limited to a few general cleaning applications where cleaning agent residue could be tolerated. Examples of
solvents used in such systems include d-limonene and soy methyl esters. The FP is above 37.8 deg C (100 deg F), so they woul
be considered not flammable by NFPA. Equipment would consist of a dip tank, most often but not necessarily heated. There co
be ultrasonics or agitation. Depending on local regulations (notably those restricting VOC), there may or may not be a cover.
Examples:
•
D-limonene (aliphatic hydrocarbon classified as a cyclic monoterpene, the major component in oils from citrus
rinds)
• flashpoint 48 deg C
• boiling point 176 Deg C
•
Methyl Soyate (a mixture of long-chain, typically 16-18 carbons, fatty acid methyl esters)
• flashpoint 130C
• boiling point 200C
A semi-aqueous cleaning process consists of a water-miscible blend, with high solvent concentration (including emulsions), use
as an immersion or spray followed by an aqueous rinse (see the description of aqueous process). Some semi-aqueous processes
are referred to as aqueous (by the supplier of cleaning agent, or cleaning equipment, or by the end-user, in part because there is
not a clear demarcation of the line between an aqueous additive package and a water-rinseable solvent. Equipment costs are hig
Carryover of solvent into the rinse tank can be a problem.
Aqueous cleaning involves washing with a cleaning agent that could be water alone but that typically contains organic and
inorganic chemistry. The quality of the water and the amount of water used is highly variable. Depending on the application, th
water quality can range from tap water to purified water, for example, de-ionized or reverse osmosis.
7-28
ble 7-13: Cleaning Methods and Their Definitions
eaning Method
brid system (e.g., Inventec, HEMO)
Cost Analysis
Definition
Aqueous formulations vary in their composition (organic and inorganic additives), the pH, and the concentration at which they a
used. What is described as an aqueous process may actually be a semi-aqueous process, in large part because it has become mor
acceptable to avoid the concept of using any organic solvent for cleaning.
Heat and various types of cleaning action like ultrasonics, underwater agitation (like a jacuzzi or tubulation) may be used to
enhance cleaning. In most instances there is significant amount of rinsing with water to displace the cleaning agent. In some
instances, the rinse water may include chemicals (rust preventative (RP)) to forestall corrosion. Depending on the substrate to b
cleaned and the end-use of the product, there is most often a drying step. In our model for cost comparison, we have used a was
tank followed by rinse tanks followed by a drying chamber. While we have used immersion tanks as a model to describe the
aqueous process to allow comparison among the cleaning processes, in fact there is an enormous variability in aqueous cleaning
processes and aqueous cleaning equipment.
The cost analyses generally consider aqueous systems to consist of one or two wash tanks followed by HOW MANY rinse tank
and a dryer. Here are a few non-encompassing examples of aqueous cleaning equipment that are not a sequence of cleaning tan
For general cleaning applications, cleaning agent may be applied to the part either by spray or immersion. Rinsing, if it occurs
may be as simple as holding the part under a tap and rinsing all residue down the drain. In some metal cleaning, the part may be
washed in a spray chamber, with or without rinsing. Where rinsing occurs, it may be accomplished by placing the part over a gr
and spraying water on it. Drying may not be necessary. In-line aqueous cleaning equipment is widely used to remove “no-clean
(low residue) flux from electronics assemblies, post-soldering. The cleaning action (washing and rinsing) typically involves spr
in-air. There are wash, rinse, and drying chambers. In some applications such as in some hybrid cleaning water (and/or an aque
cleaner) is introduced into a chamber containing the parts to be cleaned. Ultrasonic cleaning and/or in cyclic cavitation (cyclic
nucleation) may be used to enhance cleaning.
Hybrid systems use two or more cleaning methods in a single piece of cleaning equipment. Sometimes, the parts are cleaned in
single chamber and cleaning solutions are introduced. Other systems use sequential chambers. One equipment manufacturer
described the use of an aqueous cleaning step but with a solvent rinse. This would be distinguished from a semi-aqueous proces
where the high-solvent cleaner is used for washing and water used for rinsing. As contrasted with co-solvent or bi-solvent
systems, hybrid systems, in our definition, use an aqueous process as one of the methods, either sequentially or together as an
emulsion.
7-29
The critical cleaning experts provided two sets of estimates that they described as “optimistic” and
“realistic”. The “realistic” estimates accounted for additional trial and error in identifying and
implementing the new cleaning processes and these are the estimates presented and used in this economic
analysis.
The categories of costs presented in Table 7-14 were considered in the analysis.
Table 7-14: Categories of Costs Considered in the Vapor Degreasing Cost Analysis
Cost Categories Considered
Process Development for Identifying and Implementing the Alternative Cleaning Process (section 7.7.1)
Initial Capital Costs for New Machine (section 7.7.2)
Initial Capital Costs aside from New Machine (section 7.7.3)
Cleaning Agent Costs (section 7.7.4)
Waste Disposal Costs (section 7.7.5)
Annual Maintenance Costs (section 7.7.6)
Annual Labor Costs (section 7.7.7)
Electrical Costs (section 7.7.8)
Additional Floorspace (section 7.7.9)
EPA developed estimates of the baseline mix of cleaning categories by using the 366 sites using TCE for
vapor degreasing in the identified in the National Emissions Inventory (EPA 2020a). EPA classified each
of these facilities as performing high precision cleaning (20% of facilities), safety critical cleaning (30%
of facilities), or general cleaning (45%). Since R&D cleaning facilities are unlikely to have releases that
meet reporting thresholds, EPA assumed that they would be missing from the National Emissions
Inventory data and assumed that R&D cleaning facilities represent 5% of the total. This suggests that the
total fraction in each category is:
-
Safety critical: 30%
-
High precision: 20%
-
General: 45%
-
R&D: 5%
EPA also estimated the baseline mix of small, medium, and large facilities using the TCE emissions
reported in National Emissions Inventory from vapor degreasers. Based on the estimates presented below
in sections 7.7.4 and 7.7.5, liquid waste represents 47% of total solvent consumption. Thus, the NEI
emissions were divided by 53% (53% = 1 - 47%) to estimate consumption and then mapped to the nearest
size category according to the consumption estimates described in section 7.7.4, below. Based on these
estimates the mix of small, medium, and large facilities is estimated to be 31%, 36%, and 32%,
respectively. These baseline estimates are presented in Table 7-15.
Cost Analysis
7-30
Table 7-15: Estimated Baseline Mix for Size and Type
Size, Type, or Size/Type Combined
Estimated Baseline Percentage
Size
Small
31%
Medium
36%
Large
32%
Type
General Cleaning
45%
High Precision Cleaning
20%
Safety Critical Cleaning
30%
R&D Critical Cleaning
5%
Size/Type Combined
Small/General Cleaning
14%
Medium/General Cleaning
16.4%
Large/General Cleaning
14.6%
Small/High Precision Cleaning
9.3%
Medium/High Precision Cleaning
11%
Large/High Precision Cleaning
9.7%
Small/Safety Critical Cleaning
6.2%
Medium/Safety Critical Cleaning
7.3%
Large/Safety Critical Cleaning
6.5%
Small/Start-Up/R&D Critical Cleaning
2.3%
Medium/Start-Up/R&D Critical Cleaning
2.7%
An estimate or assumption about the mix of alternative cleaning methods is also needed to estimate the
costs for switching cleaning methods. EPA asked critical cleaning experts who help manufacturers
develop and/or optimize their cleaning processes to estimate a percentage weight for each alternative
cleaning method that indicates how likely affected vapor degreasers would be to adopt each method.
They provided two sets of percentages, one under a scenario where trans-DCE was considered a viable
alternative cleaning method and a second scenario where it is was not. Note that the estimated percentage
weights intentionally sum to more than 100% to account for instances where a facility switches from
using TCE vapor degreasing to multiple cleaning methods. These percentages are presented below in
section 7.7.10.
7.7.1 Process Development for Identifying and Implementing the Alternative Cleaning Process
The process of identifying and implementing alternative cleaning processes is complex and includes the
following types of activities:
•
Consulting with customers
•
Consulting with suppliers
•
Researching cleaning options (web-search, talk to vendors, attend webinars, trade shows)
•
Obtaining and reviewing equipment costs
•
Selecting, obtaining and shipping representative hardware samples for test at vendor
Cost Analysis
7-31
•
Consulting with insurance carrier and fire department
•
Conducting, evaluating and reviewing cleanliness tests
•
Management review
•
Refining equipment and process design
•
Making facilities changes
•
Setting up and performance testing new equipment
•
Process validation
•
Employee training
EPA asked BFK Solutions to estimate these process development costs and two sets of costs were
provided: (1) optimistic and (2) realistic. The realistic set of estimates are used in this economic analysis.
As presented in Table 7-16, the estimated initial costs associated with the development and
implementation of alternative cleaning processes range from $100,000 to $1,540,000. The 25th, 50th, and
75th percentile for the estimated incremental costs are about $170,000, $340,000, and $1,100,000
respectively.
Table 7-16: Process Development for Identifying and Implementing the Alternative Cleaning
Process
Size Cleaning Category; Alternative Cleaning Method
Estimated Initial Costs (2022$)
General Cleaning of All Sizes; convert to aqueous
$100,000
General Cleaning of All Sizes; convert to cleaning methods other than aqueous
$170,000
High Precision Cleaning of All Sizes; convert to aqueous
$290,000
High Precision Cleaning of All Sizes; convert to cleaning methods other than aqueous
$340,000
R&D Critical Cleaning of All Sizes; all cleaning methods
$410,000
Safety Critical of All Sizes; convert to aqueous
$1,100,000
Safety Critical of All Sizes; convert to cleaning methods other than aqueous
$1,540,000
7.7.2 Initial Capital Costs for New Machine
Machine costs were estimated by looking at currently available new machines on the market and/or used
machines available for purchase. Table 7-17 presents the estimated initial costs associated with
purchasing a new machine or upgrading an existing machine. When these initial costs are incurred, they
range from $4,000 to $6.7 million.
Cost Analysis
7-32
Table 7-17: Initial Capital Costs for New Machine, by Size, Cleaning Category, and Alternative
Cleaning Method
Size/Cleaning Category
Alternative Cleaning Method
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using FlashPoint inerted t-DCE
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
Small/General Cleaning
$60,000
$90,000
$160,000
$160,000
$280,000
Co-Solvent, Bi-Solvent
$440,000
$4,000
Semi-Aqueous
$100,000
Replace with Aqueous Cleaning
$240,000
Hybrid system (e.g., Inventec, HEMO)
$392,000
Replace with Airless Degreaser with PCE
$480,000
Replace with OTVD using Flashpoint inerted t-DCE
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
$0
$380,000
$540,000
$500,000
OTVD for Very low flashpoint (<0C) solvent
$500,000
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
$480,000
Co-Solvent, Bi-Solvent
$500,000
High boiling, non-vacuum, non-rinse
$16,000
Semi-Aqueous
$400,000
Replace with Aqueous Cleaning
$500,000
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using Flashpoint inerted t-DCE
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
$672,000
$4,800,000
$0
$3,600,000
$5,400,000
$4,800,000
OTVD for Very low flashpoint (<0C) solvent
$4,800,000
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
$4,800,000
Co-Solvent, Bi-Solvent
High boiling, non-vacuum, non-rinse
Semi-Aqueous
Replace with Aqueous Cleaning
Cost Analysis
$0
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
Convert OTVD to use Flashpoint inerted t-DCE
Large/General Cleaning
$280,000
OTVD for Very low flashpoint (<0C) solvent
High boiling, non-vacuum, non-rinse
Medium/General Cleaning
Estimated Initial
Costs (2022$)
$288,000
$32,000
$160,000
$4,800,000
7-33
Table 7-17: Initial Capital Costs for New Machine, by Size, Cleaning Category, and Alternative
Cleaning Method
Size/Cleaning Category
Alternative Cleaning Method
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using Flashpoint inerted t-DCE
Small/High Precision Cleaning
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
$90,000
$160,000
$280,000
Co-Solvent, Bi-Solvent
$220,000
Semi-Aqueous
$100,000
Replace with Aqueous Cleaning
$260,000
Hybrid system (e.g., Inventec, HEMO)
$292,000
Replace with Airless Degreaser with PCE
$480,000
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
OTVD for Very low flashpoint (<0C) solvent
$0
$360,000
$540,000
$500,000
$50,000
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
$480,000
Co-Solvent, Bi-Solvent
$480,000
Semi-Aqueous
$400,000
Replace with Aqueous Cleaning
$500,000
Hybrid system (e.g., Inventec, HEMO)
$672,000
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using Flashpoint inerted t-DCE
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
$4,800,000
$0
$3,600,000
$5,400,000
$4,800,000
OTVD for Very low flashpoint (<0C) solvent
$4,800,000
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
$4,800,000
Co-Solvent, Bi-Solvent
$3,200,000
Semi-Aqueous
Cost Analysis
$0
$60,000
$160,000
Replace with Airless Degreaser with PCE
Small/Safety Critical Cleaning
$280,000
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
Replace with OTVD using Flashpoint inerted t-DCE
Large/High Precision Cleaning
$6,720,000
OTVD for Very low flashpoint (<0C) solvent
Convert OTVD to use Flashpoint inerted t-DCE
Medium/High Precision Cleaning
Estimated Initial
Costs (2022$)
$160,000
Replace with Aqueous Cleaning
$4,800,000
Hybrid system (e.g., Inventec, HEMO)
$6,720,000
Replace with Airless Degreaser with PCE
$280,000
7-34
Table 7-17: Initial Capital Costs for New Machine, by Size, Cleaning Category, and Alternative
Cleaning Method
Size/Cleaning Category
Alternative Cleaning Method
Convert OTVD to use Flashpoint inerted t-DCE
$12,000
Replace with OTVD using Flashpoint inerted t-DCE
$60,000
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
$280,000
Co-Solvent, Bi-Solvent
$220,000
Semi-Aqueous
$100,000
$392,000
Replace with Airless Degreaser with PCE
$480,000
Convert OTVD to use Flashpoint inerted t-DCE
$144,000
Replace with OTVD using Flashpoint inerted t-DCE
$360,000
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
$540,000
$500,000
OTVD for Very low flashpoint (<0C) solvent
$500,000
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
$480,000
Co-Solvent, Bi-Solvent
$480,000
Semi-Aqueous
$400,000
Replace with Aqueous Cleaning
$500,000
Hybrid system (e.g., Inventec, HEMO)
$672,000
Replace with OTVD using Flashpoint inerted t-DCE
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
$4,800,000
$720,000
$3,600,000
$5,400,000
$4,800,000
OTVD for Very low flashpoint (<0C) solvent
$4,800,000
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
$4,800,000
Co-Solvent, Bi-Solvent
$4,800,000
Semi-Aqueous
$1,600,000
Replace with Aqueous Cleaning
$4,800,000
Hybrid system (e.g., Inventec, HEMO)
$6,700,000
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using Flashpoint inerted t-DCE
Cost Analysis
$60,000
Hybrid system (e.g., Inventec, HEMO)
Convert OTVD to use Flashpoint inerted t-DCE
Small/Start-Up/R&D Critical Cleaning
$160,000
$160,000
Replace with Airless Degreaser with PCE
Large/Safety Critical Cleaning
$90,000
OTVD for Very low flashpoint (<0C) solvent
Replace with Aqueous Cleaning
Medium/Safety Critical Cleaning
Estimated Initial
Costs (2022$)
$280,000
$0
$60,000
7-35
Table 7-17: Initial Capital Costs for New Machine, by Size, Cleaning Category, and Alternative
Cleaning Method
Size/Cleaning Category
Alternative Cleaning Method
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
$90,000
$160,000
OTVD for Very low flashpoint (<0C) solvent
$160,000
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
$280,000
Co-Solvent, Bi-Solvent
$220,000
Semi-Aqueous
$100,000
Replace with Aqueous Cleaning
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using Flashpoint inerted t-DCE
Medium/Start-Up/R&D Critical Cleaning
Estimated Initial
Costs (2022$)
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
$60,000
$480,000
$0
$720,000
$540,000
$500,000
OTVD for Very low flashpoint (<0C) solvent
$500,000
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
$480,000
Co-Solvent, Bi-Solvent
$480,000
Semi-Aqueous
$400,000
Replace with Aqueous Cleaning
$500,000
7.7.3 Other Initial Capital Costs
Non-machine initial costs may include costs for fire equipment. The cost was estimated as 25% of the
machine cost in most cases.
Table 7-18 presents the estimated initial capital costs other than the costs of purchasing a new machine or
upgrading an existing machine. When these initial costs are incurred, they range from $400 to $1.2
million.
Cost Analysis
7-36
Table 7-18: Other Initial Capital Costs by Size, Cleaning Category, and Alternative Cleaning
Method
Size/Cleaning Category
Alternative Cleaning Method
Replace with Airless Degreaser with PCE
$28,000
Convert OTVD to use Flashpoint inerted t-DCE
$18,000
Replace with OTVD using Flashpoint inerted t-DCE
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
Small/General Cleaning
$16,000
$32,000
$70,000
Co-Solvent, Bi-Solvent
$22,000
Replace with Aqueous Cleaning
$800
$10,000
$3,333
Hybrid system (e.g., Inventec, HEMO)
$39,200
Replace with Airless Degreaser with PCE
$28,000
Convert OTVD to use Flashpoint inerted t-DCE
$54,000
Replace with OTVD using Flashpoint inerted t-DCE
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
$0
$0
$0
$0
$120,000
Co-Solvent, Bi-Solvent
$0
High boiling, non-vacuum, non-rinse
$0
Semi-Aqueous
$10,000
Replace with Aqueous Cleaning
$10,000
Hybrid system (e.g., Inventec, HEMO)
$39,200
Replace with Airless Degreaser with PCE
$28,000
Convert OTVD to use Flashpoint inerted t-DCE
$6,000
Replace with OTVD using Flashpoint inerted t-DCE
$9,000
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
High boiling, non-vacuum, non-rinse
Semi-Aqueous
Replace with Aqueous Cleaning
Cost Analysis
$18,000
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
Semi-Aqueous
Large/General Cleaning
$9,000
OTVD for Very low flashpoint (<0C) solvent
High boiling, non-vacuum, non-rinse
Medium/General Cleaning
Estimated Initial
Costs (2022$)
$0
$16,000
$16,000
$1,200,000
$22,000
$400
$10,000
$180,000
7-37
Table 7-18: Other Initial Capital Costs by Size, Cleaning Category, and Alternative Cleaning
Method
Size/Cleaning Category
Alternative Cleaning Method
Hybrid system (e.g., Inventec, HEMO)
$39,200
Replace with Airless Degreaser with PCE
$28,000
Convert OTVD to use Flashpoint inerted t-DCE
$18,000
Replace with OTVD using Flashpoint inerted t-DCE
Small/High Precision Cleaning
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
$70,000
Co-Solvent, Bi-Solvent
$22,000
Semi-Aqueous
$10,000
$3,333
Hybrid system (e.g., Inventec, HEMO)
$39,200
Replace with Airless Degreaser with PCE
$28,000
Convert OTVD to use Flashpoint inerted t-DCE
$18,000
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
$9,000
$0
$16,000
OTVD for Very low flashpoint (<0C) solvent
$36,000
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
$35,000
Co-Solvent, Bi-Solvent
$22,000
Semi-Aqueous
$10,000
$3,333
Hybrid system (e.g., Inventec, HEMO)
$39,200
Replace with Airless Degreaser with PCE
$28,000
Convert OTVD to use Flashpoint inerted t-DCE
$9,000
Replace with OTVD using Flashpoint inerted t-DCE
$9,000
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
$0
$16,000
OTVD for Very low flashpoint (<0C) solvent
$16,000
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
$35,000
Co-Solvent, Bi-Solvent
$22,000
Semi-Aqueous
$10,000
Replace with Aqueous Cleaning
Cost Analysis
$16,000
$16,000
Replace with Aqueous Cleaning
Small/Safety Critical Cleaning
$0
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
Replace with OTVD using Flashpoint inerted t-DCE
Large/High Precision Cleaning
$0
OTVD for Very low flashpoint (<0C) solvent
Replace with Aqueous Cleaning
Medium/High Precision Cleaning
Estimated Initial
Costs (2022$)
$3,333
Hybrid system (e.g., Inventec, HEMO)
$39,200
Replace with Airless Degreaser with PCE
$28,000
7-38
Table 7-18: Other Initial Capital Costs by Size, Cleaning Category, and Alternative Cleaning
Method
Size/Cleaning Category
Alternative Cleaning Method
Convert OTVD to use Flashpoint inerted t-DCE
$9,000
Replace with OTVD using Flashpoint inerted t-DCE
$9,000
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
$35,000
Co-Solvent, Bi-Solvent
$22,000
Semi-Aqueous
$10,000
$39,200
Replace with Airless Degreaser with PCE
$28,000
Convert OTVD to use Flashpoint inerted t-DCE
$9,000
Replace with OTVD using Flashpoint inerted t-DCE
$9,000
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
$0
$16,000
OTVD for Very low flashpoint (<0C) solvent
$16,000
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
$35,000
Co-Solvent, Bi-Solvent
$22,000
Semi-Aqueous
$10,000
$3,333
Hybrid system (e.g., Inventec, HEMO)
$39,200
Replace with Airless Degreaser with PCE
$28,000
Convert OTVD to use Flashpoint inerted t-DCE
$9,000
Replace with OTVD using Flashpoint inerted t-DCE
$9,000
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
$0
$16,000
OTVD for Very low flashpoint (<0C) solvent
$16,000
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
$35,000
Co-Solvent, Bi-Solvent
$22,000
Semi-Aqueous
$10,000
$3,333
Hybrid system (e.g., Inventec, HEMO)
$39,200
Replace with Airless Degreaser with PCE
$28,000
Convert OTVD to use Flashpoint inerted t-DCE
$18,000
Replace with OTVD using Flashpoint inerted t-DCE
Cost Analysis
$3,333
Hybrid system (e.g., Inventec, HEMO)
Replace with Aqueous Cleaning
Small/Start-Up/R&D Critical Cleaning
$16,000
$16,000
Replace with Aqueous Cleaning
Large/Safety Critical Cleaning
$0
OTVD for Very low flashpoint (<0C) solvent
Replace with Aqueous Cleaning
Medium/Safety Critical Cleaning
Estimated Initial
Costs (2022$)
$9,000
7-39
Table 7-18: Other Initial Capital Costs by Size, Cleaning Category, and Alternative Cleaning
Method
Size/Cleaning Category
Alternative Cleaning Method
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
$0
$16,000
OTVD for Very low flashpoint (<0C) solvent
$16,000
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
$35,000
Co-Solvent, Bi-Solvent
$22,000
Semi-Aqueous
$10,000
Replace with Aqueous Cleaning
$3,333
Replace with Airless Degreaser with PCE
$28,000
Convert OTVD to use Flashpoint inerted t-DCE
$18,000
Replace with OTVD using Flashpoint inerted t-DCE
Medium/Start-Up/R&D Critical Cleaning
Estimated Initial
Costs (2022$)
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
$9,000
$0
$16,000
OTVD for Very low flashpoint (<0C) solvent
$16,000
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
$35,000
Co-Solvent, Bi-Solvent
$22,000
Semi-Aqueous
$10,000
Replace with Aqueous Cleaning
$3,333
7.7.4 Cleaning Agent Costs
The initial fill for the cleaning agent matches the volume of the tank, which is the correct volume if full
immersion cleaning is used. This may overstate the initial fill if the entire chamber is not filled. Some
vapor degreasers, including airless, may clean only in vapor zone, or by spray wand, and will only be
filled to a fraction of the chamber size. This will reduce the amount of solvent needed to be purchased.
General cleaning applications are more likely to need full immersion due to higher soil loading.
Annual fill cleaning agent estimates account for several different factors, including the type of soil,
cleanliness requirements, loss of cleaning agent, and soil loading. Aqueous tanks need to be changed
more frequently than solvent and thus will have a high annual replacement; general cleaning will have a
higher soil load and will need even more frequent changes. BFK Solutions’ estimates for the annual fill
volumes of solvents were informed by various sources of real-world application and SAFECHEM
estimates.
Table 7-19 presents the estimated initial fill costs for cleaning agent. These initial costs range from $120
to $240,000.
Cost Analysis
7-40
Table 7-19: Cleaning Agent Costs: Initial Fill by Size, Cleaning Category, and Alternative Cleaning
Method
Size/Cleaning Category
Alternative Cleaning Method
Replace with Airless Degreaser with PCE
$1,800
Replace with OTVD using Flashpoint inerted t-DCE
$1,800
$300
$180
$1,911
High boiling, non-vacuum, non-rinse
$360
Semi-Aqueous
$348
Replace with Aqueous Cleaning
$120
$3,600
Replace with Airless Degreaser with PCE
$18,750
Convert OTVD to use Flashpoint inerted t-DCE
$37,500
Replace with OTVD using Flashpoint inerted t-DCE
$37,500
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
$37,500
$5,000
OTVD for Very low flashpoint (<0C) solvent
$6,250
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
$3,750
Co-Solvent, Bi-Solvent
$39,813
High boiling, non-vacuum, non-rinse
$7,500
Semi-Aqueous
$7,250
Replace with Aqueous Cleaning
$2,500
Hybrid system (example: Inventec, HEMO)
$75,000
Replace with Airless Degreaser with PCE
$60,000
Convert OTVD to use Flashpoint inerted t-DCE
$120,000
Replace with OTVD using FlashPoint inerted t-DCE
$120,000
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
$120,000
$16,000
OTVD for Very low flashpoint (<0C) solvent
$20,000
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
$12,000
Co-Solvent, Bi-Solvent
$127,400
High boiling, non-vacuum, non-rinse
$24,000
Semi-Aqueous
$23,200
Replace with Aqueous Cleaning
Cost Analysis
$240
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
Hybrid system (e.g., Inventec, HEMO)
Large/General Cleaning
$1,800
OTVD for Very low flashpoint (<0C) solvent
Co-Solvent, Bi-Solvent
Medium/General Cleaning
$900
Convert OTVD to use Flashpoint inerted t-DCE
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
Small/General Cleaning
Estimated Initial
Costs (2022$)
$8,000
7-41
Table 7-19: Cleaning Agent Costs: Initial Fill by Size, Cleaning Category, and Alternative Cleaning
Method
Size/Cleaning Category
Alternative Cleaning Method
Hybrid system (example: Inventec, HEMO)
Replace with Airless Degreaser with PCE
Small/High Precision Cleaning
$1,800
$1,800
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
$240
$300
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
$180
$1,911
Semi-Aqueous
$348
Replace with Aqueous Cleaning
$120
$3,600
Replace with Airless Degreaser with PCE
$18,750
Convert OTVD to use Flashpoint inerted t-DCE
$37,500
Replace with OTVD using FlashPoint inerted t-DCE
$37,500
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
$37,500
$5,000
OTVD for Very low flashpoint (<0C) solvent
$6,250
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
$3,750
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (example: Inventec, HEMO)
Replace with Airless Degreaser with PCE
$39,813
$7,250
$2,500
$75,000
$60,000
Convert OTVD to use Flashpoint inerted t-DCE
$120,000
Replace with OTVD using FlashPoint inerted t-DCE
$120,000
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
$120,000
$16,000
OTVD for Very low flashpoint (<0C) solvent
$20,000
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
$12,000
Co-Solvent, Bi-Solvent
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (example: Inventec, HEMO)
Cost Analysis
$1,800
OTVD for Very low flashpoint (<0C) solvent
Co-Solvent, Bi-Solvent
Small/Safety Critical Cleaning
$900
Replace with OTVD using FlashPoint inerted t-DCE
Hybrid system (example: Inventec, HEMO)
Large/High Precision Cleaning
$240,000
Convert OTVD to use Flashpoint inerted t-DCE
Co-Solvent, Bi-Solvent
Medium/High Precision Cleaning
Estimated Initial
Costs (2022$)
Replace with Airless Degreaser with PCE
$127,400
$23,200
$8,000
$240,000
$900
7-42
Table 7-19: Cleaning Agent Costs: Initial Fill by Size, Cleaning Category, and Alternative Cleaning
Method
Size/Cleaning Category
Alternative Cleaning Method
Convert OTVD to use Flashpoint inerted t-DCE
$1,800
Replace with OTVD using FlashPoint inerted t-DCE
$1,800
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
$180
$348
Replace with Aqueous Cleaning
$120
$3,600
Replace with Airless Degreaser with PCE
$18,750
Convert OTVD to use Flashpoint inerted t-DCE
$37,500
Replace with OTVD using FlashPoint inerted t-DCE
$37,500
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
$37,500
$5,000
OTVD for Very low flashpoint (<0C) solvent
$6,250
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
$3,750
$39,813
Semi-Aqueous
$7,250
Replace with Aqueous Cleaning
$2,500
Hybrid system (example: Inventec, HEMO)
Replace with Airless Degreaser with PCE
$75,000
$60,000
Convert OTVD to use Flashpoint inerted t-DCE
$120,000
Replace with OTVD using FlashPoint inerted t-DCE
$120,000
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
$120,000
$16,000
OTVD for Very low flashpoint (<0C) solvent
$20,000
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
$12,000
Co-Solvent, Bi-Solvent
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (example: Inventec, HEMO)
Replace with Airless Degreaser with PCE
Cost Analysis
$1,911
Semi-Aqueous
Co-Solvent, Bi-Solvent
Small/Start-Up/R&D Critical Cleaning
$240
$300
Hybrid system (example: Inventec, HEMO)
Large/Safety Critical Cleaning
$1,800
OTVD for Very low flashpoint (<0C) solvent
Co-Solvent, Bi-Solvent
Medium/Safety Critical Cleaning
Estimated Initial
Costs (2022$)
$127,400
$23,200
$8,000
$240,000
$900
Convert OTVD to use Flashpoint inerted t-DCE
$1,800
Replace with OTVD using FlashPoint inerted t-DCE
$1,800
7-43
Table 7-19: Cleaning Agent Costs: Initial Fill by Size, Cleaning Category, and Alternative Cleaning
Method
Size/Cleaning Category
Alternative Cleaning Method
Estimated Initial
Costs (2022$)
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
$240
OTVD for Very low flashpoint (<0C) solvent
$300
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
$180
Co-Solvent, Bi-Solvent
Semi-Aqueous
Replace with Aqueous Cleaning
Medium/Start-Up/R&D Critical Cleaning
$1,800
$1,911
$348
$120
Replace with Airless Degreaser with PCE
$18,750
Convert OTVD to use Flashpoint inerted t-DCE
$37,500
Replace with OTVD using FlashPoint inerted t-DCE
$37,500
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
flammable
$37,500
$5,000
OTVD for Very low flashpoint (<0C) solvent
$6,250
EVD for High Boiling Point Combustibles (>100C)
Hydrocarbons and Alcohols
$3,750
Co-Solvent, Bi-Solvent
$39,813
Semi-Aqueous
$7,250
Replace with Aqueous Cleaning
$2,500
Table 7-20 presents the cleaning estimated baseline annual replacement cleaning agent costs.
Cost Analysis
7-44
Table 7-20: Cleaning Agent Costs: Cleaning Agent Costs: Baseline Annual Replacement (2022$)
Size/Cleaning Category
Small/General Cleaning
Cleaning Chamber
Tank Size in
Inches (Approx)
12 x 12 x 10
Cleaning Agent;
Annual
Replacement (gal)
36
Cleaning Agent
Price ($/gal)
$150
Baseline Cost
$5,400
Medium/General Cleaning
36 x 36 x 22
726
$150
$108,900
Large/General Cleaning
Small/High Precision
Cleaning
Medium/High Precision
Cleaning
Large/High Precision
Cleaning
Small/Safety Critical
Cleaning
Medium/Safety Critical
Cleaning
Large/Safety Critical
Cleaning
Small/Start-Up/R&D Critical
Cleaning
Medium/Start-Up/R&D
Critical Cleaning
60 x 42 x 36
1,162
$300
$348,450
12 x 12 x 10
16
$300
$4,860
36 x 36 x 22
330
$300
$99,000
60 x 42 x 36
8,711
$40
$348,450
12 x 12 x 10
97
$50
$4,860
36 x 36 x 22
3,300
$30
$99,000
60 x 42 x 36
2,188
$159
$348,450
12 x 12 x 10
81
$60
$4,860
36 x 36 x 22
28
$58
$1,620
Table 7-21 presents the incremental annual cleaning agent replacement costs, which range from a cost
savings of about $350,000 (indicated as a negative incremental cost) to an increased cost of about $1
million annually.
Cost Analysis
7-45
Table 7-21: Cleaning Agent Costs by Size, Cleaning Category, and Alternative Cleaning Method: Annual Replacement
(2022$)
Size/Cleaning Category
Small/General Cleaning
Medium/General Cleaning
Cost Analysis
Alternative Cleaning Method
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using FlashPoint inerted tDCE
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol
or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles
(>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
High boiling, non-vacuum, non-rinse
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (example: Inventec, HEMO)
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using FlashPoint inerted tDCE
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol
or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles
(>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
High boiling, non-vacuum, non-rinse
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (example: Inventec, HEMO)
Cleaning
Agent;
Annual
Replaceme
nt (gal)
12
45
Cleaning
Agent
Price
($/gal)
$150
$300
Baseline
Cost
$5,400
$5,400
PostConversio
n Cost
$1,800
$13,500
Incremental
Cost
($3,600)
$8,100
45
$300
$5,400
$13,500
$8,100
36
$300
$5,400
$10,800
$5,400
45
$40
$5,400
$1,800
($3,600)
45
$50
$5,400
$2,250
($3,150)
12
$30
$5,400
$360
($5,040)
48
45
12
144
12
55
908
$159
$60
$58
$20
$300
$150
$300
$5,400
$5,400
$5,400
$5,400
$5,400
$108,900
$108,900
$7,644
$2,700
$696
$2,880
$3,600
$8,250
$272,400
$2,244
($2,700)
($4,704)
($2,520)
($1,800)
($100,650)
$163,500
908
$300
$108,900
$272,250
$163,350
726
$300
$108,900
$217,800
$108,900
908
$40
$108,900
$36,320
($72,580)
908
$50
$108,900
$45,400
($63,500)
330
$30
$108,900
$9,900
($99,000)
750
908
908
1,500
660
$159
$60
$58
$20
$300
$108,900
$108,900
$108,900
$108,900
$108,900
$119,438
$54,480
$52,664
$30,000
$198,000
$10,538
($54,420)
($56,236)
($78,900)
$89,100
7-46
Table 7-21: Cleaning Agent Costs by Size, Cleaning Category, and Alternative Cleaning Method: Annual Replacement
(2022$)
Size/Cleaning Category
Large/General Cleaning
Small/High Precision Cleaning
Medium/High Precision Cleaning
Cost Analysis
Alternative Cleaning Method
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using FlashPoint inerted tDCE
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol
or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles
(>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
High boiling, non-vacuum, non-rinse
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (example: Inventec, HEMO)
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using FlashPoint inerted tDCE
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol
or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles
(>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (example: Inventec, HEMO)
Replace with Airless Degreaser with PCE
Cleaning
Agent;
Annual
Replaceme
nt (gal)
300
2,323
Cleaning
Agent
Price
($/gal)
$150
$300
Baseline
Cost
$348,450
$348,450
PostConversio
n Cost
$45,000
$696,900
Incremental
Cost
($303,450)
$348,450
2,904
$300
$348,450
$871,125
$522,675
2,323
$300
$348,450
$696,900
$348,450
2,323
$40
$348,450
$92,920
($255,530)
2,323
$50
$348,450
$116,150
($232,300)
100
$30
$348,450
$3,000
($345,450)
2,400
2,323
2,323
4,800
200
11
41
$159
$60
$58
$20
$300
$150
$300
$348,450
$348,450
$348,450
$348,450
$348,450
$4,860
$4,860
$382,200
$139,380
$134,734
$96,000
$60,000
$1,620
$12,150
$33,750
($209,070)
($213,716)
($252,450)
($288,450)
($3,240)
$7,290
41
$300
$4,860
$12,150
$7,290
32
$300
$4,860
$9,720
$4,860
41
$40
$4,860
$1,620
($3,240)
41
$50
$4,860
$2,025
($2,835)
11
$30
$4,860
$324
($4,536)
43
11
130
11
55
$159
$58
$20
$300
$150
$4,860
$4,860
$4,860
$4,860
$99,000
$6,880
$626
$2,592
$3,240
$8,250
$2,020
($4,234)
($2,268)
($1,620)
($90,750)
7-47
Table 7-21: Cleaning Agent Costs by Size, Cleaning Category, and Alternative Cleaning Method: Annual Replacement
(2022$)
Size/Cleaning Category
Large/High Precision Cleaning
Small/Safety Critical Cleaning
Cost Analysis
Alternative Cleaning Method
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using FlashPoint inerted tDCE
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol
or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles
(>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (example: Inventec, HEMO)
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using FlashPoint inerted tDCE
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol
or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles
(>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (example: Inventec, HEMO)
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using FlashPoint inerted t-
Cleaning
Agent;
Annual
Replaceme
nt (gal)
825
Cleaning
Agent
Price
($/gal)
$300
Baseline
Cost
$99,000
PostConversio
n Cost
$247,500
Incremental
Cost
$148,500
825
$300
$99,000
$247,500
$148,500
660
$300
$99,000
$198,000
$99,000
825
$40
$99,000
$33,000
($66,000)
825
$50
$99,000
$41,250
($57,750)
55
$30
$99,000
$1,650
($97,350)
825
825
375
660
300
2,323
$159
$58
$20
$300
$150
$300
$99,000
$99,000
$99,000
$99,000
$348,450
$348,450
$131,381
$47,850
$7,500
$198,000
$45,000
$696,900
$32,381
($51,150)
($91,500)
$99,000
($303,450)
$348,450
2,323
$300
$348,450
$696,900
$348,450
2,323
$300
$348,450
$696,900
$348,450
2,323
$40
$348,450
$92,920
($255,530)
2,323
$50
$348,450
$116,150
($232,300)
2,323
$30
$348,450
$69,690
($278,760)
100
2,323
2,323
4,800
11
41
41
$159
$58
$20
$300
$150
$300
$300
$348,450
$348,450
$348,450
$348,450
$4,860
$4,860
$4,860
$15,925
$134,734
$46,460
$1,440,000
$1,620
$12,150
$12,150
($332,525)
($213,716)
($301,990)
$1,091,550
($3,240)
$7,290
$7,290
7-48
Table 7-21: Cleaning Agent Costs by Size, Cleaning Category, and Alternative Cleaning Method: Annual Replacement
(2022$)
Size/Cleaning Category
Medium/Safety Critical Cleaning
Large/Safety Critical Cleaning
Cost Analysis
Alternative Cleaning Method
DCE
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol
or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles
(>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (example: Inventec, HEMO)
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using FlashPoint inerted tDCE
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol
or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles
(>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using Flashpoint inerted tDCE
Replace with Solstice system (trans-1-chloro-
Cleaning
Agent;
Annual
Replaceme
nt (gal)
Cleaning
Agent
Price
($/gal)
Baseline
Cost
32
$300
$4,860
$9,720
$4,860
41
$40
$4,860
$1,620
($3,240)
41
$50
$4,860
$2,025
($2,835)
11
$30
$4,860
$324
($4,536)
43
11
130
11
55
55
$159
$58
$20
$300
$150
$300
$4,860
$4,860
$4,860
$4,860
$99,000
$99,000
$6,880
$626
$2,592
$3,240
$8,250
$16,500
$2,020
($4,234)
($2,268)
($1,620)
($90,750)
($82,500)
825
$300
$99,000
$247,500
$148,500
660
$300
$99,000
$198,000
$99,000
825
$40
$99,000
$33,000
($66,000)
825
$50
$99,000
$41,250
($57,750)
825
$30
$99,000
$24,750
($74,250)
55
825
825
375
300
2,323
$159
$58
$20
$300
$150
$300
$99,000
$99,000
$99,000
$99,000
$348,450
$348,450
$8,759
$47,850
$16,500
$112,500
$45,000
$696,900
($90,241)
($51,150)
($82,500)
$13,500
($303,450)
$348,450
2,323
$300
$348,450
$696,900
$348,450
2,323
$300
$348,450
$696,900
$348,450
PostConversio
n Cost
Incremental
Cost
7-49
Table 7-21: Cleaning Agent Costs by Size, Cleaning Category, and Alternative Cleaning Method: Annual Replacement
(2022$)
Size/Cleaning Category
Small/Start-Up/R&D Critical
Cleaning
Medium/Start-Up/R&D Critical
Cleaning
Cost Analysis
Alternative Cleaning Method
3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol
or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles
(>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using Flashpoint inerted tDCE
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol
or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles
(>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Semi-Aqueous
Replace with Aqueous Cleaning
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using Flashpoint inerted tDCE
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol
or other flammable
Cleaning
Agent;
Annual
Replaceme
nt (gal)
Cleaning
Agent
Price
($/gal)
Baseline
Cost
2,323
$40
$348,450
$92,920
($255,530)
2,323
$50
$348,450
$116,150
($232,300)
2,323
$30
$348,450
$69,690
($278,760)
100
2,323
2,323
4,800
11
41
$159
$58
$20
$300
$150
$300
$348,450
$348,450
$348,450
$348,450
$4,860
$4,860
$15,925
$134,734
$46,460
$1,440,000
$1,620
$12,150
($332,525)
($213,716)
($301,990)
$1,091,550
($3,240)
$7,290
41
$300
$4,860
$12,150
$7,290
32
$300
$4,860
$9,720
$4,860
41
$40
$4,860
$1,620
($3,240)
41
$50
$4,860
$2,025
($2,835)
11
$30
$4,860
$324
($4,536)
43
11
130
55
55
$159
$58
$20
$150
$300
$4,860
$4,860
$4,860
$1,620
$1,620
$6,880
$626
$2,592
$8,250
$16,500
$2,020
($4,234)
($2,268)
$6,630
$14,880
825
$300
$1,620
$247,500
$245,880
11
$300
$1,620
$3,240
$1,620
825
$40
$1,620
$33,000
$31,380
PostConversio
n Cost
Incremental
Cost
7-50
Table 7-21: Cleaning Agent Costs by Size, Cleaning Category, and Alternative Cleaning Method: Annual Replacement
(2022$)
Size/Cleaning Category
Cost Analysis
Alternative Cleaning Method
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles
(>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Semi-Aqueous
Replace with Aqueous Cleaning
Cleaning
Agent;
Annual
Replaceme
nt (gal)
825
Cleaning
Agent
Price
($/gal)
$50
Baseline
Cost
$1,620
PostConversio
n Cost
$41,250
Incremental
Cost
$39,630
825
$30
$1,620
$24,750
$23,130
55
825
825
$159
$58
$20
$1,620
$1,620
$1,620
$8,759
$47,850
$16,500
$7,139
$46,230
$14,880
7-51
7.7.5 Waste Disposal Costs
Disposal costs were estimated based on TCE disposal costs and adjusted based on cleaning agent and
method. For example, there is an estimated 20 percent upcharge for fluorinated solvents compared to
TCE. Additionally, if the cleaning agent is combustible than it would be 80 percent of the TCE cost.
Table 7-22 presents the baseline waste disposal costs for TCE vapor degreasing.
Table 7-23 presents the estimated annual waste disposal costs under the baseline, under the new cleaning
method, and the incremental change in the annual waste disposal costs. These costs range from a savings
of about $4,000 (indicated as a negative incremental cost) to $16,000 in additional waste disposal costs.
Table 7-22: Baseline Waste Disposal Costs by Size and Cleaning Category (2022$)
Size/Cleaning Category
Cleaning Agent; Annual
Replacement (gal)
Cleaning Agent
Price ($/gal)
Baseline Cost
17
$309
330
$6,006
1,056
$19,219
6
$100
Medium/High Precision Cleaning
110
$2,002
Large/High Precision Cleaning
352
Small/Safety Critical Cleaning
6
$100
Medium/Safety Critical Cleaning
110
$2,002
Large/Safety Critical Cleaning
352
$6,406
6
$100
110
$2,002
Small/General Cleaning
Medium/General Cleaning
Large/General Cleaning
Small/High Precision Cleaning
Small/Start-Up/R&D Critical Cleaning
Medium/Start-Up/R&D Critical Cleaning
Cost Analysis
$18.20
$6,406
7-52
Table 7-23: Annual Waste Disposal Costs, by Size, Cleaning Category and Alternative Cleaning Method (2022$)
Size/Cleaning Category
Small/General Cleaning
Medium/General Cleaning
Large/General Cleaning
Cost Analysis
Alternative Cleaning Method
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using Flashpoint inerted tDCE
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol
or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles
(>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
High boiling, non-vacuum, non-rinse
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using Flashpoint inerted tDCE
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol
or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles
(>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
High boiling, non-vacuum, non-rinse
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Liquid
Waste (gal)
Disposal
Cost ($/gal)
17
17
$18.20
$21.80
$309
$309
PostConversion
Cost
$309
$371
17
$21.80
$309
$371
17
$21.80
$309
$371
17
$14.50
$309
$247
17
$14.50
$309
$247
17
$14.50
$309
$247
17
17
17
72
17
330
330
$14.50
$14.50
$14.50
$4.00
$14.50
$18.20
$21.80
$309
$309
$309
$309
$309
$6,006
$6,006
$247
$247
$247
$288
$247
$6,006
$7,194
330
$21.80
$6,006
$7,194
330
$21.80
$6,006
$7,194
330
$14.50
$6,006
$4,785
330
$14.50
$6,006
$4,785
330
$14.50
$6,006
$4,785
330
330
330
1,500
330
1,056
1,056
$14.50
$14.50
$14.50
$4.00
$14.50
$18.20
$21.80
$6,006
$6,006
$6,006
$6,006
$6,006
$19,219
$19,219
$4,785
$4,785
$4,785
$6,000
$4,785
$19,219
$23,021
Baseline
Cost
In
7-53
Table 7-23: Annual Waste Disposal Costs, by Size, Cleaning Category and Alternative Cleaning Method (2022$)
Size/Cleaning Category
Small/High Precision Cleaning
Medium/High Precision Cleaning
Cost Analysis
Alternative Cleaning Method
Replace with OTVD using Flashpoint inerted tDCE
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol
or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles
(>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
High boiling, non-vacuum, non-rinse
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using Flashpoint inerted tDCE
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol
or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles
(>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using Flashpoint inerted tDCE
Replace with Solstice system (trans-1-chloro-
Baseline
Cost
PostConversion
Cost
Liquid
Waste (gal)
Disposal
Cost ($/gal)
1,056
$21.80
$19,219
$23,021
1,056
$21.80
$19,219
$23,021
1,056
$14.50
$19,219
$15,312
1,056
$14.50
$19,219
$15,312
1,056
$14.50
$19,219
$15,312
1,056
1,056
1,056
4,800
2,112
3
8
$14.50
$14.50
$14.50
$4.00
$14.50
$18.20
$21.80
$19,219
$19,219
$19,219
$19,219
$19,219
$100
$100
$15,312
$15,312
$15,312
$19,200
$30,624
$55
$174
8
$21.80
$100
$174
6
$21.80
$100
$120
8
$14.50
$100
$116
8
$14.50
$100
$116
3
$14.50
$100
$44
8
8
18
17
110
110
$14.50
$14.50
$4.00
$8.20
$18.20
$21.80
$100
$100
$100
$100
$2,002
$2,002
$116
$116
$72
$139
$2,002
$2,398
110
$21.80
$2,002
$2,398
110
$21.80
$2,002
$2,398
In
7-54
Table 7-23: Annual Waste Disposal Costs, by Size, Cleaning Category and Alternative Cleaning Method (2022$)
Size/Cleaning Category
Large/High Precision Cleaning
Small/Safety Critical Cleaning
Cost Analysis
Alternative Cleaning Method
3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol
or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles
(>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using Flashpoint inerted tDCE
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol
or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles
(>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using Flashpoint inerted tDCE
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol
or other flammable
OTVD for Very low flashpoint (<0C) solvent
Baseline
Cost
PostConversion
Cost
Liquid
Waste (gal)
Disposal
Cost ($/gal)
110
$14.50
$2,002
$1,595
110
$14.50
$2,002
$1,595
110
$14.50
$2,002
$1,595
110
110
940
330
400
352
$14.50
$14.50
$4.00
$14.50
$18.20
$21.80
$2,002
$2,002
$2,002
$2,002
$6,406
$6,406
$1,595
$1,595
$3,760
$4,785
$7,280
$7,674
352
$21.80
$6,406
$7,674
352
$21.80
$6,406
$7,674
352
$14.50
$6,406
$5,104
352
$14.50
$6,406
$5,104
400
$14.50
$6,406
$5,800
352
352
5,500
2,112
3
6
$14.50
$14.50
$4.00
$8.20
$18.20
$21.80
$6,406
$6,406
$6,406
$6,406
$100
$100
$5,104
$5,104
$22,000
$17,318
$55
$120
8
$21.80
$100
$174
6
$21.80
$100
$120
6
$14.50
$100
$80
6
$14.50
$100
$80
In
7-55
Table 7-23: Annual Waste Disposal Costs, by Size, Cleaning Category and Alternative Cleaning Method (2022$)
Size/Cleaning Category
Medium/Safety Critical Cleaning
Large/Safety Critical Cleaning
Cost Analysis
Alternative Cleaning Method
EVD for High Boiling Point Combustibles
(>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using Flashpoint inerted tDCE
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol
or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles
(>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using Flashpoint inerted tDCE
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol
or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles
(>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Semi-Aqueous
Baseline
Cost
PostConversion
Cost
Liquid
Waste (gal)
Disposal
Cost ($/gal)
3
$14.50
$100
$44
6
6
18
17
110
110
$14.50
$14.50
$4.00
$8.20
$18.20
$21.80
$100
$100
$100
$100
$2,002
$2,002
$80
$80
$72
$139
$2,002
$2,398
110
$21.80
$2,002
$2,398
110
$21.80
$2,002
$2,398
110
$14.50
$2,002
$1,595
110
$14.50
$2,002
$1,595
110
$14.50
$2,002
$1,595
110
110
940
330
400
352
$14.50
$14.50
$4.00
$8.20
$18.20
$21.80
$2,002
$2,002
$2,002
$2,002
$6,406
$6,406
$1,595
$1,595
$3,760
$2,706
$7,280
$7,674
352
$21.80
$6,406
$7,674
352
$21.80
$6,406
$7,674
352
$14.50
$6,406
$5,104
352
$14.50
$6,406
$5,104
400
$14.50
$6,406
$5,800
352
352
$14.50
$14.50
$6,406
$6,406
$5,104
$5,104
In
7-56
Table 7-23: Annual Waste Disposal Costs, by Size, Cleaning Category and Alternative Cleaning Method (2022$)
Size/Cleaning Category
Small/Start-Up/R&D Critical Cleaning
Medium/Start-Up/R&D Critical Cleaning
Cost Analysis
Alternative Cleaning Method
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using Flashpoint inerted tDCE
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol
or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles
(>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Semi-Aqueous
Replace with Aqueous Cleaning
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using Flashpoint inerted tDCE
Replace with Solstice system (trans-1-chloro3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol
or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles
(>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Semi-Aqueous
Replace with Aqueous Cleaning
Liquid
Waste (gal)
Disposal
Cost ($/gal)
5,500
2,112
3
6
$4.00
$8.20
$18.20
$21.80
$6,406
$6,406
$100
$100
PostConversion
Cost
$22,000
$17,318
$55
$120
8
$21.80
$100
$174
6
$21.80
$100
$120
6
$14.50
$100
$80
6
$14.50
$100
$80
3
$14.50
$100
$44
6
6
18
110
110
$14.50
$14.50
$4.00
$18.20
$21.80
$100
$100
$100
$2,002
$2,002
$80
$80
$72
$2,002
$2,398
110
$21.80
$2,002
$2,398
110
$21.80
$2,002
$2,398
110
$14.50
$2,002
$1,595
110
$14.50
$2,002
$1,595
110
$14.50
$2,002
$1,595
110
110
940
$14.50
$14.50
$4.00
$2,002
$2,002
$2,002
$1,595
$1,595
$3,760
Baseline
Cost
In
7-57
7.7.6 Annual Maintenance Costs
Maintenance costs are highly dependent on the type and age of the cleaning system. There is an estimated
20-year life for most systems and maintenance costs will be needed for items like filters, process
monitoring, annual employee check-ups, monitoring for soil or water contamination. There is a 25 percent
additional markup for extra items.
Table 7-24 presents the estimated annual maintenance costs under the baseline, under the new cleaning
method, and the incremental change in the annual maintenance costs. These costs range from a savings of
about $200,000 (indicated as a negative incremental cost) to $200,000 in additional waste disposal costs.
Cost Analysis
7-58
Table 7-24: Annual Maintenance Costs, by Size, Cleaning Category, and Alternative Cleaning Method (2022$)
Size/Cleaning Category
Small/General Cleaning
Medium/General Cleaning
Large/General Cleaning
Cost Analysis
Alternative Cleaning Method
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using FlashPoint inerted t-DCE
Replace with Solstice system (trans-1-chloro-3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
High boiling, non-vacuum, non-rinse
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using Flashpoint inerted t-DCE
Replace with Solstice system (trans-1-chloro-3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
High boiling, non-vacuum, non-rinse
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using Flashpoint inerted t-DCE
Replace with Solstice system (trans-1-chloro-3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Baseline
Cost
$3,750
$3,750
$3,750
$3,750
$3,750
$3,750
$3,750
$3,750
$3,750
$3,750
$3,750
$3,750
$22,500
$22,500
$22,500
$22,500
$22,500
$22,500
$22,500
$22,500
$22,500
$22,500
$22,500
$22,500
$225,000
$225,000
$225,000
$225,000
$225,000
$225,000
$225,000
$225,000
PostConversio
n Cost
$19,250
$4,313
$4,313
$6,750
$11,000
$12,000
$21,875
$28,875
$300
$6,875
$15,208
$26,950
$31,750
$11,250
$23,750
$33,750
$31,250
$31,250
$37,500
$31,250
$1,000
$25,625
$31,875
$44,450
$301,750
$225,563
$225,563
$337,500
$301,000
$301,000
$375,000
$19,375
In
7-59
Table 7-24: Annual Maintenance Costs, by Size, Cleaning Category, and Alternative Cleaning Method (2022$)
Size/Cleaning Category
Small/High Precision Cleaning
Medium/High Precision Cleaning
Large/High Precision Cleaning
Cost Analysis
Alternative Cleaning Method
High boiling, non-vacuum, non-rinse
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using Flashpoint inerted t-DCE
Replace with Solstice system (trans-1-chloro-3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using Flashpoint inerted t-DCE
Replace with Solstice system (trans-1-chloro-3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using Flashpoint inerted t-DCE
Replace with Solstice system (trans-1-chloro-3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other flammable
OTVD for Very low flashpoint (<0C) solvent
Baseline
Cost
$225,000
$225,000
$225,000
$225,000
$3,750
$3,750
$3,750
$3,750
$3,750
$3,750
$3,750
$3,750
$3,750
$3,750
$3,750
$22,500
$22,500
$22,500
$22,500
$22,500
$22,500
$22,500
$22,500
$22,500
$22,500
$22,500
$225,000
$225,000
$225,000
$225,000
$225,000
$225,000
PostConversio
n Cost
$2,025
$10,625
$311,250
$422,450
$19,250
$3,750
$3,750
$5,625
$11,000
$11,000
$21,875
$15,125
$6,875
$16,458
$20,700
$31,750
$23,063
$23,063
$33,750
$32,250
$5,375
$32,188
$31,375
$25,625
$31,458
$44,450
$301,750
$225,563
$225,563
$337,500
$301,000
$301,000
In
7-60
Table 7-24: Annual Maintenance Costs, by Size, Cleaning Category, and Alternative Cleaning Method (2022$)
Size/Cleaning Category
Small/Safety Critical Cleaning
Medium/Safety Critical Cleaning
Large/Safety Critical Cleaning
Cost Analysis
Alternative Cleaning Method
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using Flashpoint inerted t-DCE
Replace with Solstice system (trans-1-chloro-3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using Flashpoint inerted t-DCE
Replace with Solstice system (trans-1-chloro-3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using Flashpoint inerted t-DCE
Replace with Solstice system (trans-1-chloro-3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other flammable
Baseline
Cost
$225,000
$225,000
$225,000
$225,000
$225,000
$3,750
$3,750
$3,750
$3,750
$3,750
$3,750
$3,750
$3,750
$3,750
$3,750
$3,750
$22,500
$22,500
$22,500
$22,500
$22,500
$22,500
$22,500
$22,500
$22,500
$22,500
$22,500
$225,000
$225,000
$225,000
$225,000
$225,000
PostConversio
n Cost
$302,188
$1,875
$10,625
$300,208
$422,450
$19,250
$4,313
$4,313
$5,625
$11,000
$11,000
$19,688
$15,125
$6,875
$3,958
$26,950
$31,750
$9,563
$23,063
$33,750
$32,250
$32,250
$32,188
$31,375
$25,625
$31,458
$44,450
$301,750
$45,563
$225,563
$337,500
$301,000
In
7-61
Table 7-24: Annual Maintenance Costs, by Size, Cleaning Category, and Alternative Cleaning Method (2022$)
Size/Cleaning Category
Small/Start-Up/R&D Critical Cleaning
Medium/Start-Up/R&D Critical Cleaning
Cost Analysis
Alternative Cleaning Method
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (example: Inventec, HEMO)
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using FlashPoint inerted t-DCE
Replace with Solstice system (trans-1-chloro-3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Semi-Aqueous
Replace with Aqueous Cleaning
Replace with Airless Degreaser with PCE
Convert OTVD to use Flashpoint inerted t-DCE
Replace with OTVD using Flashpoint inerted t-DCE
Replace with Solstice system (trans-1-chloro-3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Semi-Aqueous
Replace with Aqueous Cleaning
Baseline
Cost
$225,000
$225,000
$225,000
$225,000
$225,000
$225,000
$3,750
$3,750
$3,750
$3,750
$3,750
$3,750
$3,750
$3,750
$3,750
$3,750
$22,500
$22,500
$22,500
$22,500
$22,500
$22,500
$22,500
$22,500
$22,500
$22,500
PostConversio
n Cost
$301,000
$302,188
$301,375
$100,625
$300,208
$421,200
$19,250
$4,313
$4,313
$5,625
$11,000
$11,000
$19,688
$15,125
$6,875
$3,958
$31,750
$45,563
$45,563
$33,750
$32,250
$32,250
$32,188
$31,375
$25,625
$31,458
In
7-62
7.7.7 Annual Labor Costs
Labor costs are dependent on the type of machine, degree of automation and number of runs. Table 7-25
presents the estimated baseline labor costs for operating a vapor degreasing machine.
Table 7-25: Baseline Labor Costs (2022$) Size and Cleaning Category
Size/Cleaning Category
Annual Labor (hours)
Baseline Labor
Cost
Small/General Cleaning
979
$59,876
Medium/General Cleaning
850
$51,986
Large/General Cleaning
790
$48,316
Small/High Precision Cleaning
880
$53,821
Medium/High Precision Cleaning
750
$45,870
Large/High Precision Cleaning
640
$39,142
Small/Safety Critical Cleaning
879
$53,760
Medium/Safety Critical Cleaning
750
$45,870
Large/Safety Critical Cleaning
640
$39,142
Small/Start-Up/R&D Critical Cleaning
720
$44,035
Medium/Start-Up/R&D Critical Cleaning
720
$44,035
For the cleaning types and methods estimated to have incremental differences in labor costs, Table 7-26
presents the estimated annual labor costs under the baseline, under the new cleaning method, and the
incremental change in the annual labor costs. Among those facilities with incremental cost changes, the
costs range from a savings of about $30,000 (indicated as a negative incremental cost) to $15,000 in
additional labor costs.
Cost Analysis
7-63
Table 7-26: Annual Labor Costs (2022$)
Size/Cleaning Category
Small/General Cleaning
Medium/General Cleaning
Large/General Cleaning
Small/High Precision Cleaning
Medium/High Precision Cleaning
Large/High Precision Cleaning
Small/Safety Critical Cleaning
Medium/Safety Critical Cleaning
Large/Safety Critical Cleaning
Small/Start-Up/R&D Critical Cleaning
Medium/Start-Up/R&D Critical Cleaning
Small/Start-Up/R&D Critical Cleaning
Medium/Start-Up/R&D Critical Cleaning
Cost Analysis
Alternative Cleaning Method
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Replace with Aqueous Cleaning
Replace with Airless Degreaser with PCE
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Replace with Aqueous Cleaning
Replace with Airless Degreaser with PCE
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Replace with Aqueous Cleaning
Replace with Airless Degreaser with PCE
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Replace with Airless Degreaser with PCE
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Replace with Aqueous Cleaning
Replace with Airless Degreaser with PCE
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Replace with Aqueous Cleaning
Replace with Airless Degreaser with PCE
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Replace with Aqueous Cleaning
Replace with Airless Degreaser with PCE
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Replace with Aqueous Cleaning
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Replace with Aqueous Cleaning
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Replace with Aqueous Cleaning
Replace with Airless Degreaser with PCE
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Replace with Aqueous Cleaning
Replace with Aqueous Cleaning
Replace with Airless Degreaser with PCE
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Baseline
Cost
$59,876
$59,876
$51,986
$51,986
$51,986
$48,316
$48,316
$48,316
$53,821
$53,821
$45,870
$45,870
$45,870
$39,142
$39,142
$39,142
$53,760
$53,760
$53,760
$45,870
$45,870
$45,870
$39,142
$39,142
$44,035
$44,035
$44,035
$44,035
$44,035
$44,035
$44,035
$44,035
PostConversion
Cost
$32,598
$62,995
$32,598
$32,598
$59,019
$32,598
$32,598
$59,019
$32,598
$32,598
$32,598
$32,598
$49,845
$32,598
$32,598
$47,093
$32,598
$32,598
$59,019
$32,598
$32,598
$49,845
$32,598
$47,093
$32,598
$59,019
$32,598
$32,598
$49,845
$59,019
$32,598
$32,598
7-64
Table 7-26: Annual Labor Costs (2022$)
Size/Cleaning Category
Cost Analysis
Alternative Cleaning Method
Replace with Aqueous Cleaning
Baseline
Cost
$44,035
PostConversion
Cost
$49,845
7-65
7.7.8 Annual Electricity Costs
Electrical costs are assuming 2,000 hours per work year (40hr/wk*50wks). It is also assumed that this
cost is dependent on the size of the cleaning system and is not dependent on the type of cleaning.
For the cleaning types and methods estimated to have incremental differences in electricity costs, Table
7-27 presents the estimated annual electricity costs under the baseline, under the new cleaning method,
and the incremental change in the annual costs. Among those facilities with incremental cost changes, the
costs range from a savings of about $100 (indicated as a negative incremental cost) to about $19,000 in
additional electricity costs.
Cost Analysis
7-66
e 7-27: Annual Electricity Costs by Size, Cleaning Category, and Alternative Cleaning Method (2022$)
Size/Cleaning Category
/General Cleaning
um/General Cleaning
/General Cleaning
/High Precision Cleaning
um/High Precision Cleaning
/High Precision Cleaning
/Safety Critical Cleaning
Cost Analysis
Alternative Cleaning Method
Replace with Airless Degreaser with PCE
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
High boiling, non-vacuum, non-rinse
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Replace with Aqueous Cleaning
Baseline
Cost
$21
$21
$21
$21
$21
$259
$259
$259
$259
$259
$259
$828
$828
$828
$828
$21
$21
$21
$21
$259
$259
$259
$259
$259
$259
$828
$828
$828
$828
$21
$21
$21
PostConversion
Cost
$33
$41
$41
$483
$162
$419
$518
$144
$1,723
$6,041
$2,028
$1,339
$1,657
$19,331
$6,490
$33
$41
$483
$162
$419
$518
$144
$1,723
$6,041
$2,028
$1,339
$1,657
$19,331
$6,490
$33
$41
$483
Increm
al Co
(
$
$
$
$1
$
(
$
$
$
$1
$
7-67
e 7-27: Annual Electricity Costs by Size, Cleaning Category, and Alternative Cleaning Method (2022$)
Size/Cleaning Category
um/Safety Critical Cleaning
/Safety Critical Cleaning
/Start-Up/R&D Critical Cleaning
um/Start-Up/R&D Critical Cleaning
Cost Analysis
Alternative Cleaning Method
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Semi-Aqueous
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Replace with Aqueous Cleaning
Replace with Airless Degreaser with PCE
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Semi-Aqueous
Replace with Aqueous Cleaning
Baseline
Cost
$21
$259
$259
$259
$259
$259
$259
$828
$828
$828
$828
$21
$21
$21
$259
$259
$259
$259
$259
PostConversion
Cost
$162
$419
$518
$144
$1,723
$6,041
$2,028
$1,339
$1,657
$19,331
$6,490
$33
$41
$483
$419
$518
$144
$1,723
$6,041
Increm
al Co
(
$
$
$
$1
$
(
$
$
7-68
7.7.9 Additional Floorspace Costs
The estimates for additional floorspace needed are based on a study done in 1999 with BFK Solutions and
the Toxics Use Reduction Institute (Kanegsberg and LeBlanc 1999, Kanegsberg 2001). Estimated costs
are added if multiple pieces of the cleaning systems are needed (examples include the cleaning system,
rinsing tank and dryer). Floorspace costs are estimated to be $7.03 per square foot, the average national
cost for in-place rents in December 2022 according to the CommercialEdge National Industrial Report
(CommercialEdge 2023).
For the cleaning types and methods estimated to require additional floorspace, Table 7-28 presents the
estimated annual incremental costs. Among those facilities with incremental costs, the costs range from
about $100 to about $9,000 in additional floorspace.
Cost Analysis
7-69
e 7-28: Annual Additional Floorspace Costs, by Size, Cleaning Category, and Alternative Cleaning Method (2022$)
Size/Cleaning Category
/General Cleaning
um/General Cleaning
/General Cleaning
/High Precision Cleaning
um/High Precision Cleaning
Cost Analysis
Alternative Cleaning Method
Replace with Airless Degreaser with PCE
OTVD for Low boiling point (<100C) Alcohol or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
OTVD for Low boiling point (<100C) Alcohol or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
OTVD for Low boiling point (<100C) Alcohol or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Replace with Aqueous Cleaning
Replace with Airless Degreaser with PCE
OTVD for Low boiling point (<100C) Alcohol or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
OTVD for Low boiling point (<100C) Alcohol or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Replace with Aqueous Cleaning
Additional Floorspace
Required (square feet)
20
20
20
20
40
65
30
200
200
200
200
400
650
280
400
400
400
400
800
1,300
20
20
20
20
40
65
30
200
200
200
200
400
650
Incremental
($7.03/sqf
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
7-70
e 7-28: Annual Additional Floorspace Costs, by Size, Cleaning Category, and Alternative Cleaning Method (2022$)
Size/Cleaning Category
/High Precision Cleaning
/Safety Critical Cleaning
um/Safety Critical Cleaning
/Safety Critical Cleaning
Cost Analysis
Alternative Cleaning Method
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
OTVD for Low boiling point (<100C) Alcohol or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Replace with Aqueous Cleaning
Replace with Airless Degreaser with PCE
OTVD for Low boiling point (<100C) Alcohol or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
OTVD for Low boiling point (<100C) Alcohol or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Replace with Aqueous Cleaning
Hybrid system (e.g., Inventec, HEMO)
Replace with Airless Degreaser with PCE
OTVD for Low boiling point (<100C) Alcohol or other flammable
OTVD for Very low flashpoint (<0C) solvent
EVD for High Boiling Point Combustibles (>100C) Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
Replace with Aqueous Cleaning
Additional Floorspace
Required (square feet)
280
400
400
400
400
800
1,300
20
20
20
20
40
65
30
200
200
200
200
400
650
280
400
400
400
400
800
1,300
Incremental
($7.03/sqf
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
7-71
7.7.10 Incremental Costs for Vapor Degreasing Facilities Switching to TCE Alternatives
Table 7-29 through Table 7-39 present the initial and recurring costs for each size, cleaning category, and
alternative cleaning method combination considered. EPA asked BFK Solutions to estimate a percentage
weight for each alternative cleaning method that indicates how likely affected vapor degreasers would be
to adopt each method. They provided two sets of percentages, one under a scenario where trans-DCE was
considered a viable alternative cleaning method and a second scenario where it was not. Note that the
estimated percentage weights intentionally sum to more than 100 percent to account for instances where a
facility switches from using TCE vapor degreasing to multiple cleaning methods.
Table 7-29: Initial and Recurring Costs by Alternative Cleaning Method: Small/General Cleaning
(2022$)
Alternative Cleaning Method
Weight1
with transwithout
DCE
trans-DCE
10%
15%
10%
0%
9%
0%
Initial
Costs
Replace with Airless Degreaser with PCE
$484,925
Convert OTVD to use Flashpoint inerted t-DCE
$191,800
Replace with OTVD using Flashpoint inerted t-DCE
$242,800
Replace with Solstice system (trans-1-chloro8%
10%
$281,800
3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
1%
1%
$348,240
flammable
OTVD for Very low flashpoint (<0C) solvent
0%
0%
$364,300
EVD for High Boiling Point Combustibles (>100C)
20%
30%
$522,180
Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
5%
8%
$635,911
High boiling, non-vacuum, non-rinse
15%
20%
$177,160
Semi-Aqueous
15%
20%
$282,348
Replace with Aqueous Cleaning
20%
25%
$340,597
Hybrid system (e.g., Inventec, HEMO)
7%
10%
$606,800
Weighted Average Across Methods (Including trans-DCE)
$431,304
Weighted Average Across Methods (Excluding trans-DCE)
$549,659
1Weights sum to more than 100 percent in order to account for switching to multiple cleaning methods
Cost Analysis
Annual
Recurring
Costs
($13,309)
$8,724
$8,724
$8,461
$3,728
$5,178
($14,094)
$27,587
($6,192)
($1,642)
$12,956
$21,690
$2,536
$707
7-72
Table 7-30: Initial and Recurring Costs by Alternative Cleaning Method: Medium/General
Cleaning (2022$)
Cleaning method
Weight1
with transwithout
DCE
trans-DCE
12%
15%
10%
0%
9%
0%
Initial
Costs
Replace with Airless Degreaser with PCE
$702,775
Convert OTVD to use Flashpoint inerted t-DCE
$263,500
Replace with OTVD using Flashpoint inerted t-DCE
$589,500
Replace with Solstice system (trans-1-chloro8%
10%
$749,500
3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
1%
1%
$677,000
flammable
OTVD for Very low flashpoint (<0C) solvent
0%
0%
$678,250
EVD for High Boiling Point Combustibles (>100C)
25%
35%
$775,750
Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
5%
8%
$711,813
High boiling, non-vacuum, non-rinse
15%
20%
$195,500
Semi-Aqueous
15%
20%
$589,250
Replace with Aqueous Cleaning
20%
25%
$609,644
Hybrid system (e.g., Inventec, HEMO)
7%
10%
$958,200
Weighted Average Across Methods (Including trans-DCE)
$766,711
Weighted Average Across Methods (Excluding trans-DCE)
$920,775
1Weights sum to more than 100 percent in order to account for switching to multiple cleaning methods
Annual
Recurring
Costs
($107,307)
$153,438
$165,788
$121,338
($63,645)
($54,565)
($102,944)
$20,763
($77,141)
($52,868)
($52,146)
$113,567
($20,220)
($66,650)
Table 7-31: Initial and Recurring Costs by Alternative Cleaning Method: Large/General Cleaning
(2022$)
Cleaning method
Weight1
with transwithout
DCE
transDCE
12%
15%
10%
0%
9%
0%
Initial
Costs
Replace with Airless Degreaser with PCE
$5,064,025
Convert OTVD to use Flashpoint inerted t-DCE
$298,000
Replace with OTVD using Flashpoint inerted t-DCE
$3,901,000
Replace with Solstice system (trans-1-chloro8%
10%
$5,692,000
3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
1%
1%
$5,004,000
flammable
OTVD for Very low flashpoint (<0C) solvent
0%
0%
$5,008,000
EVD for High Boiling Point Combustibles (>100C)
30%
40%
$6,184,000
Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
5%
8%
$609,400
High boiling, non-vacuum, non-rinse
15%
20%
$228,400
Semi-Aqueous
18%
22%
$365,200
Replace with Aqueous Cleaning
20%
25%
$5,085,144
Hybrid system (e.g., Inventec, HEMO)
7%
10%
$7,171,200
Weighted Average Across Methods (Including trans-DCE)
$4,998,652
Weighted Average Across Methods (Excluding trans-DCE)
$6,015,626
1Weights sum to more than 100 percent in order to account for switching to multiple cleaning methods
Cost Analysis
Annual
Recurring
Costs
($237,180)
$352,814
$527,039
$464,752
($180,625)
($157,395)
($211,435)
($170,158)
($435,952)
($431,998)
($127,874)
($73,934)
($156,214)
($310,687)
7-73
Table 7-32: Initial and Recurring Costs by Alternative Cleaning Method: Small/High Precision
(2022$)
Cleaning method
Weight1
with
Without
transtrans-DCE
DCE
15%
25%
20%
0%
20%
0%
Initial
Costs
Replace with Airless Degreaser with PCE
$648,706
Convert OTVD to use Flashpoint inerted t-DCE
$355,581
Replace with OTVD using Flashpoint inerted t-DCE
$397,581
Replace with Solstice system (trans-1-chloro12%
15%
$427,581
3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
5%
8%
$512,021
flammable
OTVD for Very low flashpoint (<0C) solvent
1%
2%
$512,081
EVD for High Boiling Point Combustibles (>100C)
20%
33%
$685,961
Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
5%
15%
$579,692
Semi-Aqueous
2%
5%
$446,129
Replace with Aqueous Cleaning
15%
20%
$551,453
Hybrid system (e.g., Inventec, HEMO)
10%
18%
$670,581
Weighted Average Across Methods (Including trans-DCE)
$654,845
Weighted Average Across Methods (Excluding trans-DCE)
$844,139
1Weights sum to more than 100 percent in order to account for switching to multiple cleaning methods
Annual
Recurring
Costs
($6,939)
$7,364
$7,364
$6,755
$4,167
$4,572
($7,529)
$13,692
($1,093)
$11,332
$15,722
$5,398
$4,314
Table 7-33: Initial and Recurring Costs by Alternative Cleaning Method: Medium/High Precision
(2022$)
Cleaning method
Weight1
With transWithout
DCE
trans-DCE
15%
25%
20%
0%
20%
0%
Initial
Costs
Replace with Airless Degreaser with PCE
$866,556
Convert OTVD to use Flashpoint inerted t-DCE
$391,281
Replace with OTVD using Flashpoint inerted t-DCE
$742,281
Replace with Solstice system (trans-1-chloro12%
15%
$913,281
3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
5%
8%
$856,781
flammable
OTVD for Very low flashpoint (<0C) solvent
1%
2%
$428,031
EVD for High Boiling Point Combustibles (>100C)
20%
33%
$854,531
Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
5%
15%
$877,594
Semi-Aqueous
2%
5%
$753,031
Replace with Aqueous Cleaning
15%
20%
$793,833
Hybrid system (e.g., Inventec, HEMO)
10%
18%
$1,121,981
Weighted Average Across Methods (Including trans-DCE)
$974,528
Weighted Average Across Methods (Excluding trans-DCE)
$1,242,743
1Weights sum to more than 100 percent in order to account for switching to multiple cleaning methods
Cost Analysis
Annual
Recurring
Costs
($91,291)
$149,459
$149,459
$110,646
($55,251)
($73,876)
($99,676)
$43,546
($46,968)
($66,457)
$127,471
$39,947
($31,180)
7-74
Table 7-34: Initial and Recurring Costs by Alternative Cleaning Method: Large/High Precision
(2022$)
Cleaning method
Weight1
with transwithout
DCE
transDCE
15%
25%
20%
0%
20%
0%
Initial
Costs
Replace with Airless Degreaser with PCE
$5,227,806
Convert OTVD to use Flashpoint inerted t-DCE
$464,781
Replace with OTVD using Flashpoint inerted t-DCE
$4,064,781
Replace with Solstice system (trans-1-chloro12%
15%
$5,855,781
3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
5%
8%
$5,167,781
flammable
OTVD for Very low flashpoint (<0C) solvent
1%
2%
$5,171,781
EVD for High Boiling Point Combustibles (>100C)
20%
33%
$5,182,781
Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
5%
15%
$3,685,181
Semi-Aqueous
2%
5%
$528,981
Replace with Aqueous Cleaning
15%
20%
$5,099,333
Hybrid system (e.g., Inventec, HEMO)
10%
18%
$7,334,981
Weighted Average Across Methods (Including trans-DCE)
$5,432,677
Weighted Average Across Methods (Excluding trans-DCE)
$7,331,884
1Weights sum to more than 100 percent in order to account for switching to multiple cleaning methods
Annual
Recurring
Costs
($227,132)
$350,280
$350,280
$462,217
($178,020)
($154,790)
($205,083)
($551,328)
($429,393)
($175,596)
$1,305,573
$178,106
$23,250
Table 7-35: Initial and Recurring Costs by Alternative Cleaning Method: Small/Safety Critical
(2022$)
Cleaning method
Weight1
With transWithout
DCE
transDCE
20%
30%
20%
0%
20%
0%
Initial
Costs
Replace with Airless Degreaser with PCE
$1,849,913
Convert OTVD to use Flashpoint inerted t-DCE
$1,559,788
Replace with OTVD using Flashpoint inerted t-DCE
$1,607,788
Replace with Solstice system (trans-1-chloro15%
18%
$1,628,788
3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
12%
15%
$1,713,228
flammable
OTVD for Very low flashpoint (<0C) solvent
2%
2%
$1,713,288
EVD for High Boiling Point Combustibles (>100C)
25%
33%
$1,852,168
Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
8%
15%
$1,780,899
Semi-Aqueous
2%
5%
$1,647,336
Replace with Aqueous Cleaning
15%
20%
$1,163,453
Hybrid system (e.g., Inventec, HEMO)
10%
18%
$1,971,788
Weighted Average Across Methods (Including trans-DCE)
$2,497,826
Weighted Average Across Methods (Excluding trans-DCE)
$2,687,735
1Weights sum to more than 100 percent in order to account for switching to multiple cleaning methods
Cost Analysis
Annual
Recurring
Costs
($6,878)
$7,872
$7,927
$6,755
$4,130
$4,535
($9,655)
$13,655
($1,129)
$4,092
$21,972
$4,851
$3,442
7-75
Table 7-36: Initial and Recurring Costs by Alternative Cleaning Method: Medium/Safety Critical
(2022$)
Cleaning method
Weight1
with transwithout
DCE
transDCE
20%
30%
20%
0%
20%
0%
Initial
Costs
Replace with Airless Degreaser with PCE
$2,067,763
Convert OTVD to use Flashpoint inerted t-DCE
$1,727,488
Replace with OTVD using Flashpoint inerted t-DCE
$1,943,488
Replace with Solstice system (trans-1-chloro15%
18%
$2,114,488
3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
12%
15%
$2,057,988
flammable
OTVD for Very low flashpoint (<0C) solvent
2%
2%
$2,059,238
EVD for High Boiling Point Combustibles (>100C)
25%
33%
$2,055,738
Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
8%
15%
$2,078,801
Semi-Aqueous
2%
5%
$1,954,238
Replace with Aqueous Cleaning
15%
20%
$1,605,833
Hybrid system (e.g., Inventec, HEMO)
10%
18%
$2,323,188
Weighted Average Across Methods (Including trans-DCE)
$2,945,581
Weighted Average Across Methods (Excluding trans-DCE)
$3,178,086
1Weights sum to more than 100 percent in order to account for switching to multiple cleaning methods
Annual
Recurring
Costs
($91,291)
($95,042)
$149,459
$110,646
($55,251)
($47,001)
($76,576)
($79,077)
($46,968)
($57,457)
$39,892
($29,387)
($60,490)
Table 7-37: Initial and Recurring Costs by Alternative Cleaning Method: Large/Safety Critical
(2022$)
Cleaning method
Weight1
with transwithout
DCE
transDCE
20%
30%
20%
0%
20%
0%
Initial
Costs
Replace with Airless Degreaser with PCE
$6,429,013
Convert OTVD to use Flashpoint inerted t-DCE
$2,385,988
Replace with OTVD using Flashpoint inerted t-DCE
$5,265,988
Replace with Solstice system (trans-1-chloro15%
18%
$7,056,988
3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
12%
15%
$6,368,988
flammable
OTVD for Very low flashpoint (<0C) solvent
2%
2%
$6,372,988
EVD for High Boiling Point Combustibles (>100C)
25%
33%
$6,383,988
Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
8%
15%
$6,486,388
Semi-Aqueous
2%
5%
$3,170,188
Replace with Aqueous Cleaning
15%
20%
$5,911,333
Hybrid system (e.g., Inventec, HEMO)
10%
18%
$8,516,188
Weighted Average Across Methods (Including trans-DCE)
$8,683,115
Weighted Average Across Methods (Excluding trans-DCE)
$10,235,134
1Weights sum to more than 100 percent in order to account for switching to multiple cleaning methods
Cost Analysis
Annual
Recurring
Costs
($220,588)
$170,280
$350,280
$462,217
($178,020)
($154,790)
($205,083)
($251,828)
($339,393)
($175,596)
$1,304,323
$130,757
$64,462
7-76
Table 7-38: Initial and Recurring Costs by Alternative Cleaning Method: Small/R&D Safety
Critical (2022$)
Cleaning method
Weight1
with transwithout
DCE
transDCE
15%
35%
17%
0%
17%
0%
Initial
Costs
Replace with Airless Degreaser with PCE
$727,900
Convert OTVD to use Flashpoint inerted t-DCE
$434,775
Replace with OTVD using Flashpoint inerted t-DCE
$485,775
Replace with Solstice system (trans-1-chloro25%
32%
$506,775
3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
12%
18%
$591,215
flammable
OTVD for Very low flashpoint (<0C) solvent
1%
1%
$591,275
EVD for High Boiling Point Combustibles (>100C)
17%
30%
$730,155
Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
10%
16%
$658,886
Semi-Aqueous
7%
10%
$525,323
Replace with Aqueous Cleaning
15%
20%
$478,428
Weighted Average Across Methods (Including trans-DCE)
$767,783
Weighted Average Across Methods (Excluding trans-DCE)
$1,001,951
1Weights sum to more than 100 percent in order to account for switching to multiple cleaning methods
Annual
Recurrin
g Costs
$14,143
$7,872
$7,927
$6,755
$3,990
$4,395
($71)
$13,374
($1,129)
$13,359
$10,269
$12,551
Table 7-39: Initial and Recurring Costs by Alternative Cleaning Method: Medium/R&D Safety
Critical (2022$)
Cleaning method
Weight1
with transwithout
DCE
transDCE
15%
35%
17%
0%
17%
0%
Initial
Costs
Replace with Airless Degreaser with PCE
$945,750
Convert OTVD to use Flashpoint inerted t-DCE
$470,475
Replace with OTVD using Flashpoint inerted t-DCE
$1,181,475
Replace with Solstice system (trans-1-chloro25%
32%
$992,475
3,3,3,trifluoropropene)
OTVD for Low boiling point (<100C) Alcohol or other
12%
18%
$935,975
flammable
OTVD for Very low flashpoint (<0C) solvent
1%
1%
$937,225
EVD for High Boiling Point Combustibles (>100C)
17%
30%
$933,725
Hydrocarbons and Alcohols
Co-Solvent, Bi-Solvent
10%
16%
$956,788
Semi-Aqueous
7%
10%
$832,225
Replace with Aqueous Cleaning
15%
20%
$920,808
Weighted Average Across Methods (Including trans-DCE)
$1,243,291
Weighted Average Across Methods (Excluding trans-DCE)
$1,527,040
1Weights sum to more than 100 percent in order to account for switching to multiple cleaning methods
Cost Analysis
Annual
Recurrin
g Costs
$6,518
$38,339
$269,339
$13,266
$40,723
$48,973
$21,232
$15,491
$50,412
$37,189
$76,242
$35,674
7-77
*** EO 12866/14094 Review Draft – Deliberative – Do Not Cite, Quote, or Release During Review ***
Table 7-40 and Table 7-41 present a summary of the incremental costs for facilities using TCE for
vapor degreasing that switch to an alternative cleaning method. The primary estimates used in the
analysis are presented in Table 7-41 (assuming trans-DCE cleaning methods are not a viable option).
Table 7-40: Summary of Incremental Costs for Vapor Degreasing:
Including Trans-DCE (2022$)
Size/Type
Small/General Cleaning
Size/Type
Percentage
Weight
Initial Costs
Recurring
Annual
Costs
14.00%
$431,304
$2,536
Medium/General Cleaning
16.4%
$766,711
($20,220)
Large/General Cleaning
14.6%
$4,998,652
($156,214)
9.3%
$654,845
$5,398
11.00%
$974,528
$39,947
Small/High Precision Cleaning
Medium/High Precision Cleaning
Large/High Precision Cleaning
9.7%
$5,432,677
$178,106
Small/Safety Critical Cleaning
6.2%
$2,497,826
$4,851
Medium/Safety Critical Cleaning
7.3%
$2,945,581
($29,387)
Large/Safety Critical Cleaning
6.5%
$8,683,115
$130,757
Small/Start-Up/R&D Critical Cleaning
2.3%
$767,783
$10,269
Medium/Start-Up/R&D Critical
Cleaning
2.7%
$1,243,291
$76,242
-
$2,596,909
$5,380
All Types Combined
Table 7-41: Summary of Incremental Costs for Vapor Degreasing:
Excluding Trans-DCE (2022$)
$549,659
Recurring
Annual
Costs
$707
Medium/General Cleaning
16.4%
$920,775
($66,650)
Large/General Cleaning
14.6%
$6,015,626
($310,687)
Size/Type
Small/General Cleaning
Small/High Precision Cleaning
Size/Type
Percentage
Weight
14.00%
Initial Costs
9.3%
$844,139
$4,314
11.00%
$1,242,743
($31,180)
Large/High Precision Cleaning
9.7%
$7,331,884
$23,250
Small/Safety Critical Cleaning
6.2%
$2,687,735
$3,442
Medium/Safety Critical Cleaning
7.3%
$3,178,086
($60,490)
Large/Safety Critical Cleaning
6.5%
$10,235,134
$64,462
Small/Start-Up/R&D Critical Cleaning
2.3%
$1,001,951
$12,551
Medium/Start-Up/R&D Critical
Cleaning
2.7%
$1,527,040
$35,674
-
$3,161,475
($55,694)
Medium/High Precision Cleaning
All Types Combined
7.8 Costs of the Dermal Protection Component of the WCPP
The estimated costs associated with developing and implementing a dermal protection program is
presented in section 7.8.1 and the dermal protection costs for gloves are presented in section 7.8.2.
Cost Analysis
7-78
7.8.1 Dermal Exposure Control Program Costs
Dermal exposure control program costs include planning how to implement dermal exposure controls
and training employees on dermal exposure control:
•
Developing a dermal exposure control program – Identify each person reasonably likely to
be exposed, identify appropriate gloves to use for dermal protection, and set up training
program. EPA assumes an average of 5 hours per facility by an industrial hygienist to
develop a dermal exposure control program.
•
Training – EPA assumes potentially exposed workers will have an hour of training on
dermal protection annually. The training is assumed to be performed by an industrial
hygienist, who is assumed to perform the training for four workers at a time.
Table 7-42 and Table 7-43 present the unit costs for developing a dermal exposure control program
and dermal protection training.
Table 7-42: Develop Dermal Exposure Control Program (per facility)
Labor Burden
5
Units
hrs
Labor Rate
(2022$)
$71.32
Initial Cost
$356.60
Table 7-43: Conduct Dermal Protection Training (per worker)
Annual Labor Burden1
Units
Labor Rate1
(2022$)
Annual Cost per Facility
0.3125
hrs
$46.34
$14.48
worker is assumed to require an hour of training annually and an industrial hygienist is assumed to deliver
the training to four workers at a time, so the total labor burden is 1.25 hours per worker (1 hour of the worker’s time
and 0.25 hours of the industrial hygienist’s time). Thus, the labor rate is a blended rate of the worker and industrial
hygienist’s wage.
1Each
7.8.2 Estimated Costs for Dermal PPE
Estimating the costs for dermal PPE involves identifying the types of gloves expected to be used in
order to achieve compliance, obtaining the glove unit costs, estimating annual per-employee glove
costs, accounting for the gloves’ useful life, and applying the annual per-employee glove costs to the
estimated number of employees required to have dermal protection.
1.1.1 (A) Gloves Selected for Cost Analysis
Gloves are manufactured to meet the needs of a range of industries and hazards, and thus vary in
properties such as material and thickness. For protection against hazardous chemicals, the
appropriateness of any given glove will depend on the type of chemical, the type of exposure (e.g.,
splash protection, immersion), the length of exposure, dexterity requirements, thermal protection, and
comfort. There are several commonly used materials to protect against chemical hazards (OSHA
2004; Grainger 2019):
Butyl – a synthetic rubber that protects against a wide variety of chemicals and are resistant to
oxidation and abrasion. Does not perform well with aliphatic and aromatic hydrocarbons and
halogenated solvents.
Cost Analysis
7-79
Natural rubber (latex) – often used as a general-purpose glove that is resistant to temperature and
abrasion, with good elasticity and comfort. Protects against most water solutions of acids, alkalis,
salts, and ketones.
Neoprene – a synthetic rubber that protects against petroleum products, alcohols, organic acids, and
alkalis. Provides good dexterity and wear resistance.
Nitrile – often used as a general-purpose glove that provides protection against chlorinated solvents,
as well as oils, greases, petroleum products, acids, caustics, and alcohols. Does not perform well with
strong oxidizing agents, aromatic solvents, ketones, and acetates.
Viton® - provides protection against chlorinated and aromatic solvents. Has low resistance to
abrasion.
Polyvinyl chloride (PVC) – provides protection against most acids, fats, and petroleum
hydrocarbons. Resistant to abrasion.
Polyvinyl alcohol (PVA) – a water-soluble material that provides protection against aromatic and
chlorinated solvents. Cannot be used in water or water-based solutions.
PVA gloves provide the best protection against chlorinated solvents like TCE, so EPA assumes PVA
gloves will be the most common choice for compliance with dermal protection requirements. Table
7-44 presents the unit cost per pair for the gloves used in the cost analysis.
Table 7-44: Unit Cost per Pair of Gloves (2022$)
Brand
Model
Ansell
PVA 15-554
Source: Autumn Supply (2022)
Material
cotton lined PVA
Price
Price per Pair
$44.93/dozen pairs
$3.74
1.1.1 (B) Dermal PPE Unit Cost Per-Employee
To cost this option, the assumption is that firms adopt appropriate procedures for glove changing.
EPA assumes a useful life of 1 week for the supported PVA gloves. Table 7-45 presents the annual
cost per-worker for gloves.
Table 7-45: Annual Per-Worker Cost for Dermal PPE (2022$)
Glove Type
Supported/Lined PVA
Unit Cost
$3.74
Useful Life
(yrs)*
0.02
Pairs per Year
per Worker
50
Annual Costs
$187
*1 pair per week/50 work weeks per year
Source: Autumn Supply (2022)
7.8.3 Total Dermal Exposure Control Costs
Table 7-46 summarizes the total initial and annual dermal protection costs. Since the number of years
of compliance with dermal exposure controls varies by option and whether or not TSCA section 6(g)
exemptions apply, estimates are presented for all applicable durations for dermal exposure control
under the regulatory options.
Cost Analysis
7-80
Table 7-46: Total Dermal Protection Costs, by Use Category (2022$)
Use Category
Laboratory Use
Manufacturing
Import/Repackage
Battery and Synthetic Paper
Processing Aid
HFC Manufacturing
Intermediate in HCL
Production
Fluoroelastomer Manufacture
Open-Top Vapor Degreasing
Enclosed Vapor Degreasing
Conveyorized Vapor
Degreasing
Web Vapor Degreasing
Batch Cold Cleaning
Disposal to Wastewater
Incorporation Into
Formulation, Mixture, or
Reaction Product
Cost Analysis
Number
of
Affected
Facilities
Total Costs
Per Facility
Costs
(Initial)
Workers
251
2
9
3
$356.60
$356.60
$356.60
$356.60
251
140
18
51
$201.69
$201.69
$201.69
$201.69
$89,506.60
$713.20
$3,209.40
$1,069.80
$50,624
$28,237
$3,630
$10,286
2
28
$356.60
$356.60
38
532
$201.69
$201.69
$713.20
$9,984.80
$7,664
$107,299
2
350
7
8
$356.60
$356.60
$356.60
$356.60
34
2,100
42
48
$201.69
$201.69
$201.69
$201.69
$713.20
$124,810.00
$2,496.20
$2,852.80
$6,857
$423,548
$8,471
$9,681
1
52
739
28
$356.60
$356.60
$356.60
$356.60
6
312
9,607
448
$201.69
$201.69
$201.69
$201.69
$356.60
$18,543.20
$263,527.40
$9,984.80
$1,210
$62,927
$1,937,632
$90,357
Per Worker
Costs
(annual)
Initial
Annual
7-81
*** EO 12866/14094 Review Draft – Deliberative – Do Not Cite, Quote, or Release During Review ***
7.9 Costs of the Respiratory Protection Component of the WCPP
This section presents preliminary cost estimates for a WCPP with an Existing Chemical Exposure
Limit (ECEL) of 0.20 ppm under Option 1 and 0.0011 ppm under Option 2 as an 8-hour timeweighted average for TCE and an action level (AL) at half the limits (i.e., 0.10 ppm and 0.0005 ppm,
respectively). The requirements under a WCPP vary according to how far above the action level or
limit the exposure levels found during monitoring are. The different requirements for monitoring
results are presented in Table 7-47.
Cost Analysis
7-82
Table 7-47: Monitoring Threshold Requirements
Exposure Threshold
Monitoring
Requirements
Personal
Protective
Equipment (PPE)
Requirements
No respiratory
protection
Less than the action limit
Initial exposure
monitoring
Between the action limit and the
ECEL
Initial exposure
monitoring
Periodic exposure
monitoring every six
months
No respiratory
protection
ECEL to less than 10 times the
ECEL
Initial exposure
monitoring
Periodic exposure
monitoring every three
months
APF 10
10 times the ECEL to less than 25
times the ECEL
Initial exposure
monitoring
Periodic exposure
monitoring every three
months
APF 25
25 times the ECEL to less than 50
times the ECEL
Initial exposure
monitoring
Periodic exposure
monitoring every three
months
APF 50
50 times the ECEL to less than
1,000 times the ECEL
Initial exposure
monitoring
Periodic exposure
monitoring every three
months
APF 1,000
1,000 times the ECEL to less than
10,000 times the ECEL
Initial exposure
monitoring
Periodic exposure
monitoring every three
months
APF 10,000
Notification and
Recordkeeping
Requirements
Notify employee of
exposure monitoring results
within 15 days of receipt of
results
Retain compliance records
for 5 years
Notify employee of
exposure monitoring results
within 15 days of receipt of
results
Retain compliance records
for 5 years
Notify employee of
exposure monitoring results
within 15 days of receipt of
results
Retain compliance records
for 5 years
Notify employee of
exposure monitoring results
within 15 days of receipt of
results
Retain compliance records
for 5 years
Notify employee of
exposure monitoring results
within 15 days of receipt of
results
Retain compliance records
for 5 years
Notify employee of
exposure monitoring results
within 15 days of receipt of
results
Retain compliance records
for 5 years
Notify employee of
exposure monitoring results
within 15 days of receipt of
results
Retain compliance records
for 5 years
Note that before resorting to compliance through using PPE, engineering or administrative controls
should be used to lower exposure to below the action level. Using robotics and/or some type of
barrier that separates the employee and the exposure area is an example of engineering controls.
Ventilation/carbon adsorption systems are another example of engineering controls. Engineering
controls are very site-specific and their costs would also depend on what controls are already in place,
which is unknown. An example of an administrative control would be having certain employees
vacate the work area when a high exposure activity is taking place. This could be infrequent and have
minimal impacts on productivity or large impacts on productivity.
Cost Analysis
7-83
Thus, for the purpose of estimating costs (and benefits), EPA assumes that PPE is used. Note that is
an assumption made for the purpose of estimating costs only, not an assumption about how facilities
will actually comply with WCPP requirements. As noted in section 7.12.5, the WCPP requires that
feasible engineering and administrative controls are implemented before resorting to PPE use. These
controls would need to be implemented even if they are more expensive than achieving compliance
through a PPE program. However, since PPE programs are costly, achieving compliance through
engineering and/or administrative controls may be less expensive than the estimated PPE costs.
The costs for compliance with a WCPP include initial exposure monitoring, required PPE for the
different thresholds outlined in the ECEL, periodic exposure monitoring, as appropriate, and
notifications and recordkeeping.
To determine the number of entities with exposure monitoring results at the different thresholds, EPA
used the median and 95th percentile exposure levels presented in the final risk evaluation (EPA
2020e) 11 and estimated the distribution assuming the exposures were distributed across facilities
according to a lognormal distribution. 12 EPA estimated the 8-hour TWA exposure distribution to
estimate which threshold monitoring category an entity fell under.
10F
1F
Table 7-48 presents an example for how the exposure monitoring threshold category was determined
for the use categories where data for the 8-hour TWA exposure was available.
11
12
Also, see https://www.epa.gov/sites/default/files/202011/21._tce_supplemental_information_file_risk_calculator_for_occupational_exposures.xlsx.
See https://www.epa.gov/sites/default/files/202011/21._tce_supplemental_information_file_risk_calculator_for_occupational_exposures.xlsx for the
exposure values included in the risk evaluation.
Measured concentrations of various contaminants are very often found to have frequency distributions that are
log-normal, including indoor-air contaminants (Ott 1990). Ott (1990) also provides a physical explanation
for why some common processes in nature, including processes relevant to indoor air pollutant
concentrations, can explain why lognormal distributions arise naturally. Therefore, EPA believes assuming
exposure levels follow a log-normal distribution is a reasonable approach.
Cost Analysis
7-84
Table 7-48. Example for Determining the Distribution of Exposure Threshold Categories
Across Entities with 8-hour and 15-minute TWA Exposure Data
Percentile
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
Cost Analysis
Long Term TWA exposure threshold
category
< Action Level
< Action Level
< Action Level
< Action Level
< Action Level
< Action Level
< Action Level
< Action Level
< Action Level
< Action Level
< Action Level
< Action Level
< Action Level
< Action Level
Between Action Level and Limit
Between Action Level and Limit
Between Action Level and Limit
Between Action Level and Limit
Between Action Level and Limit
Between Action Level and Limit
Between Action Level and Limit
Between Action Level and Limit
Between Action Level and Limit
Between Action Level and Limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
Threshold Category for Costs and
Benefits
14% of entities < Action Level
10% of entities Between Action Level and
Limit
44% of entities 1 to <
10 times the limit
7-85
Table 7-48. Example for Determining the Distribution of Exposure Threshold Categories
Across Entities with 8-hour and 15-minute TWA Exposure Data
Percentile
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
Cost Analysis
Long Term TWA exposure threshold
category
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
1 to <10 times the limit
10 to < 25 times the limit
10 to < 25 times the limit
10 to < 25 times the limit
10 to < 25 times the limit
10 to < 25 times the limit
10 to < 25 times the limit
10 to < 25 times the limit
10 to < 25 times the limit
10 to < 25 times the limit
10 to < 25 times the limit
10 to < 25 times the limit
10 to < 25 times the limit
10 to < 25 times the limit
10 to < 25 times the limit
25 to < 50 times the limit
25 to < 50 times the limit
25 to < 50 times the limit
25 to < 50 times the limit
25 to < 50 times the limit
25 to < 50 times the limit
25 to < 50 times the limit
25 to < 50 times the limit
50 to < 1,000 times the limit
50 to < 1,000 times the limit
Threshold Category for Costs and
Benefits
14% of Entities 10 to < 25 times the limit
8% of Entities 25 to < 50 times the limit
10% of Entities 50 to < 1,000 times the limit
7-86
Table 7-48. Example for Determining the Distribution of Exposure Threshold Categories
Across Entities with 8-hour and 15-minute TWA Exposure Data
Percentile
93
94
95
96
97
98
99
100
Long Term TWA exposure threshold
category
50 to < 1,000 times the limit
50 to < 1,000 times the limit
50 to < 1,000 times the limit
50 to < 1,000 times the limit
50 to < 1,000 times the limit
50 to < 1,000 times the limit
50 to < 1,000 times the limit
50 to < 1,000 times the limit
Threshold Category for Costs and
Benefits
In order to estimate costs (and benefits), EPA assumed that the variation in exposure is reflected
across the entities rather than the workers. Table 7-49 and Table 7-50 present the respective estimated
numbers of entities and workers in each ECEL threshold category.
Cost Analysis
7-87
*** EO 12866/14094 Review Draft – Deliberative – Do Not Cite, Quote, or Release During Review ***
Table 7-49: Count of Entities, by Use Category and Exposure Threshold
Use Category
3%
25 (100%)
5 (100%)
1 (100%)
-
-
$129,845
-
-
330 (100%)
16
$2,371 - $61,637
16 (100%)
-
-
17
651
15
11,574
3,626
332
58
4,949
21,599
$9,571
$1,222
$8
$8
$8
$8
$8
$8
$8 - $129,845
17 (100%)
651 (100%)
15 (100%)
11,574 (100%)
3,626 (100%)
332 (100%)
58 (100%)
4,949 (100%)
21,269 (98.5%)
-
330 (1.5%)
10.3 Employment Effects
Employment impacts of environmental regulations include a mix of potential declines and gains in
different sectors of the economy over time. Impacts on employment can vary according to labor market
conditions and may differ across occupations, industries, and regions. Isolating employment impacts of
regulation is difficult as such impacts are a challenge to disentangle from effects on employment caused
by a wide variety of ongoing concurrent economic changes.
In the long run, environmental regulation is expected to cause a shift of employment among employers
rather than affect the general employment level (Arrow, Cropper et al. 1996; Hafstead and Williams III
2020). However, even if employment impacts are mitigated by long-run market adjustments to full
employment, many regulatory actions have transitional effects in the short run (OMB 2015; Walker
2013). These movements of workers in and out of jobs in response to environmental regulation are
potentially important distributional impacts of interest to policy makers. Of particular concern is the
potential for transitional job losses experienced by workers operating in declining industries, exhibiting
low migration rates, or living in communities or regions where unemployment rates are high.
Compliance with environmental regulation can result in increased demand for the inputs or factors
(including labor) used in the production of environmental protection. However, the regulated sector
generally relies on revenues generated by other market outputs to cover the costs of supplying increased
environmental quality. This can lead to reduced demand for labor and other factors of production used to
produce the market output. Employment impacts, both positive and negative, in sectors upstream and
downstream from the regulated sector, or in sectors producing substitute or complimentary products, may
also occur.
10.3.1 Baseline Employment
Facilities using consumer/commercial products containing TCE are not expected to experience any cost
impacts associated with switching to TCE-free alternatives, since alternative products with similar
efficacy and cost are already available (see Chapter 5).
Economic Impact Analyses
10-9
There are potential employment impacts for other uses of TCE, described below in section 10.3.2. Table
10-5 presents a summary of the affected sites and industry statistics for the affected sectors.
Economic Impact Analyses
10-10
Table 10-5: Industry Statistics for Sectors Affected by WCPP Requirements and Summary of Employment at Affected Facilities
Industry Statistics1
Affected Facilities2
Annual
Preliminary
Payroll Per
Employees
Receipts
Per
10-Year
Employee
Facilities at Affected
(thousands,
Total
EstabPercent (thousands
Facilities
2022$)
lishment Change
2022$)
Laboratory Use
17,847
23,245 2,545,199
109
7%
$77
$634,679,217
251
27,483
Manufacturing
1,636
3,632
210,111
58
3%
$115
$232,920,060
2
208
Battery and Synthetic Paper Processing Aid
1,533
1,805
90,600
50
21%
$73
$44,041,900
3
151
HFC Manufacturing
814
1,118
67,038
60
5%
$106
$51,355,626
2
120
Intermediate in HCl Production
2,729
4,467
286,579
64
8%
$118
$918,626,279
28
1,796
Fluoroelastomer Manufacture
1,157
1,383
74,656
54
15%
$55
$21,016,883
2
108
Open-Top Vapor Degreasing
59,284
65,164 2,304,480
35
10%
$75 $1,065,060,269
350
12,378
Enclosed Vapor Degreasing
10,711
11,530
439,446
38
14%
$66
$146,218,750
7
267
Conveyorized Vapor Degreasing
26,603
27,735
612,528
22
13%
$62
$208,880,429
8
177
Web Vapor Degreasing
369
522
93,552
179
-2%
$89
$109,616,435
1
179
Batch Cold Cleaning
27,259
34,493 1,351,749
39
6%
$87 $1,384,392,899
52
2,038
1Industry Statistics are from Table 3-1 and 2009 U.S. Statistics of U.S. Business data (U.S. Census Bureau 2012), aggregated according to use category.
2Employees at affected sites are estimated as either the number of facilities multiplied by the average employment per establishment (Table 3-1) or the estimated number of
workers and ONUs from Table 6-20, whichever is greater.
Use Category
Economic Impact Analyses
Number
of
Firms
Number
of
Establishments
Employment
10-11
10.3.2 Potential Employment Impacts of the Rule
As noted above, facilities using consumer/commercial products containing TCE are not expected to
experience any cost impacts associated with switching to TCE-free alternatives, since alternative products
with similar efficacy and cost are already available (see Chapter 5). Similarly, EPA believes that the
producers of these products will reformulate them using TCE-free alternatives and importers and
repackagers of these products will import or repackage TCE-free alternatives. Thus, EPA expects
minimal employment impacts from eliminating TCE from consumer/commercial products because there
are adequate substitutes and little to no changes in equipment or processes necessary. Many current
suppliers of TCE products also provide TCE-free alternatives and therefore the effect on their businesses
will likely be limited.
Table 10-5, above, also summarizes the number of potentially affected employees at facilities where there
are potential employment impacts. For several of these uses, a workplace chemical protection plan
(WCPP) is required until the use of TCE is phased out. The costs of WCPP compliance can be substantial
and the estimated annualized costs range from about $44,000 to $7 million at these facilities. Given these
costs, affected facilities may opt to comply with the proposed rule by closing or shifting operations
abroad where TCE use is not regulated or reduce their capacity. 24 While EPA believes these facilities will
likely be able to comply with the WCPP, some unknown number of facilities may close or move
operations abroad.
23F
In the event that some facilities choose not to switch or are unable to switch to an alternative to TCE, they
may close and workers may experience job loss, at least temporarily. While it may not be an option for
small businesses, larger employers may shift workers to other facilities. Finding alternative work may be
more challenging for older workers or workers with specialized skills that are not in demand elsewhere,
or workers in communities with limited job opportunities. Dislocated employees as a result of any
capacity reductions or closures may find new jobs, temporarily enter unemployment, or leave the labor
force. Employment declines in the local communities where these plants are located, if the capacity
reductions or closures are permanent, may result in negative spillovers to the local economy. While the
literature is evolving, a recent update and review of published estimates of such ‘local multipliers’ in the
economics literature suggests that an additional 0.5 jobs may be eliminated in the metropolitan region per
direct job lost (Osman and Kemeny 2021).
Upstream impacts on facilities that use TCE might include impacts on workers at firms that may be
developing alternatives or substitutes to TCE. For example, there may be increased temporary
employment associated with reformulating TCE-free alternatives and converting production processes to
use TCE substitute technologies. In general, EPA expects these impacts to be small as most uses and
users have existing clear alternatives to TCE.
There are multiple regulated uses with the potential for downstream impacts. These include laboratory
use, manufacturing, HFC manufacturing, intermediate in HCl production, fluoroelastomer manufacture,
vapor degreasing, and cold cleaning. Facility closure, shifting production abroad, or downtime while
converting to TCE-free alternative processes could all result in downstream impacts from supply chain
disruptions, including potential employment impacts.
Turning to a nationwide perspective, job impacts (both positive and negative) in the local labor market do
not tell the full story. In the long run environmental regulation is expected to cause a shift of employment
among employers and not affect the general employment level. In general, in periods of low
unemployment, workers experiencing job loss are more easily able to transition to other jobs and
24
Facilities could also comply by switching to a TCE alternative, but employment impacts would not be expected
from switching to a TCE alternative.
Economic Impact Analyses
10-12
industries. The transitional impacts described above are nonetheless important for the employees and
communities in which they are felt.
Finally, EPA acknowledges that employment impacts, both positive and negative, are possible in
indirectly affected sectors upstream and downstream from the regulated sector, or in sectors producing
substitute or complimentary products. This might include gains at upstream facilities that manufacture the
equipment necessary for conversions to an alternative technology.
In conclusion, while EPA does not have data to quantify employment impacts of the final rule, most
workers currently using TCE are expected to continue employment while shifting away from TCE use
and towards alternatives. However, EPA acknowledges that transitional employment impacts may be
experienced by some workers at facilities that opt to close or shift operations abroad instead of complying
with requirements at the facilities currently using TCE.
10.4 Paperwork Burden Analysis
This section presents a summary of the burden and associated costs for the respondents associated with
the recordkeeping and reporting requirements of the final action. The detailed paperwork burden analysis
is presented in the information collection request (ICR) supporting statement for this rulemaking. It
provides the average annual burden and cost estimates for the next three years of the program.
The paperwork burden and associated costs include the activity types listed below. Note that not all
entities would incur burden or costs from these activities because they may already be meeting the
requirements under as part of their usual business practices.
•
•
Rule familiarization
o
The 1,009 facilities complying with WCPP requirements and the 668 firms complying
with prescriptive control requirements are assumed to incur an initial cost of $284 for a 3hour burden associated with rule familiarization. This results in an annual average burden
and cost of 1,677 hours and $158,864.
o
The 21,393 facilities complying with prohibition requirements are assumed to incur an
initial cost of $95 for a 1-hour burden associated with rule familiarization. This results in
an annual average burden and cost of 7,131 hours and $678,520.
Downstream notification
o
•
Each person who processes or distributes in commerce TCE or TCE-containing products
for any use must, prior to or concurrent with the shipment, notify companies to whom
TCE is shipped, in writing, of the restrictions on its use. It is assumed that the two
manufacturers accomplish this by modifying the SDS to note the restrictions. The burden
associated with the downstream notification requirements, including the related
recordkeeping, is 2 hours, with an associated labor cost of $189. This results in an annual
average burden and cost of 7.3 hours and $695. Shipment records are assumed to be kept
as part of ordinary business practices, and therefore no incremental burden is estimated
for this requirement.
Dermal Protection
o
Under the final rule, facilities required to comply with dermal controls include those
facilities complying with the rule through a WCPP or prescriptive controls. These
facilities would be required to develop a dermal protection control program (estimated 5
initial hours per facility).
Economic Impact Analyses
10-13
o
•
Respiratory Protection
o
o
•
EPA estimates that 1,677 respondents will incur a total average annual cost of $199,720
for dermal protection over the first three years of the rule from an average annual total
time burden of 2,800 hours.
Under the final rule, the 1,009 facilities complying with the rule through an WCPP would
be required to develop exposure control plans, monitor exposure levels, maintain records
of this monitoring, provide employees with information about how they can access the
exposure control plans, exposure monitoring records, PPE program implementation
documentation, and respirator program documentation, and obtain an acknowledgment
from the employee that they have received the information. The estimated costs and
burdens are as follows:
The estimated burden and costs for the respiratory exposure monitoring plan and
conducting exposure monitoring (generating the exposure monitoring results) are
presented below in Table 10-7 (labor costs) and Table 10-10 (non-labor costs).
The estimated burden and costs for recordkeeping related to respiratory exposure
monitoring are presented below in Table 10-8.
The estimated burden and costs for notifications related to exposure monitoring
(notifying potentially exposed workers; providing them with access to exposure control
plans, exposure monitoring records, PPE program implementation documentation, and
respirator program documentation; obtaining an acknowledgment that they have received
this information) are presented below in Table 10-9.
Information related to proposed phase outs
o
Under the final rule, 2 facilities complying with the rule through a phase-out for
processing TCE as an intermediate to manufacture HFC-134a would be required to
maintain records that document appropriate reduction or attempts at reduction of use of
TCE. Documentation related to production volumes would be considered usual business
records.
o
The burden and cost of recordkeeping related to demonstrating that the end use is in
rocket booster nozzle production for Federal agencies or their contractors, and records
that demonstrate that a final pre-launch test of rocket booster nozzles without using TCE
was completed using an alternative to TCE in the production of rocket booster nozzles for
Federal agencies and their contractors are described in the economic analysis of the final
rule.
o
EPA estimates that 23,070 respondents will incur an average annual total cost of $8
million over the first three years of the rule from an average annual total time burden of
38,625 hours (1.67 hours and $345 per respondent).
Table 10-11 presents the summary of the average annual burden hours and costs per facility over the first
three years, as well as the three-year total burden hours and costs associated with the primary option. See
Chapter 7 for a more detailed description of how the time burden and wage rates were estimated. The
burden and cost estimates provided reflect the figures provided in the accompanying Information
Collection Request (ICR) for the rule.
Economic Impact Analyses
10-14
Table 10-6: Paperwork Burden and Cost Associated with Rule Familiarization, Downstream
Notification, and Dermal Exposure Control
Activity
Rule Familiarization (WCPP or
prescriptive control firms)1
Rule Familiarization (Prohibition
firms)2
Downstream Notification (SDS)3
Develop Exposure Control Program1
1,677
Average
Annual Burden
Per
Respondent
1
21,393
11
1,677
Number of
Respondents
Average Annual
Total Burden
Average Annual
Total Cost
1,677
$158,864
0.33
7,131
$678,520
0.67
1.67
7
2,800
$695
$199,720
1,4A
wage of $71.32 was used to calculate the labor cost (see Certified Industrial Hygienist wage in Table 7-4).
wage of $95.15 was used to calculate the labor cost (weighted average of sector-specific Managerial wages; see Table 7-4).
3A wage of $94.74 was used to calculate the labor cost (see Manufacturing/Managerial wage in Table 7-4).
2A
Economic Impact Analyses
10-15
Table 10-7: Paperwork Burden and Labor Cost Associated with Respiratory Monitoring
Threshold
95% humidity and 86 degrees Fahrenheit. However, the useful life jumps to 197 hours
when used in an environment of <65% humidity and 32 degrees Fahrenheit. The 3M software confirms that
replacement rate estimates are highly dependent on factors that vary nationally, and that it is up to each facility
to replace cartridges as required by their environmental parameters. The analysis also used the 3M software to
confirm that the replacement rate estimates from ERG (2003) of 50 times per year for PAPR and 100 times per
year for APR fall within the predicted range and are thus reasonable estimates.
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
B-19
Table B-12: Respirator PPE Useful Life
Respirator System
APR, Half Mask
PAPR, Loose-Fitting Facepiece
SAR, Continuous Flow Mode, LooseFitting Facepiece
APR, Full Facepiece
PAPR, Half Mask
Component
Half Mask, APR
Cartridge Filters, APR
Training
Qualitative Fit Testing
Loose-Fitting Facepiece,
PAPR
Cartridge Filters, PAPR
PAPR System
Useful
Life
(years)
Description
APF Factor 10
2
0.01
1
1
Estimate based on the equipment service life of an APR, full facepiece respirator (ERG 2003)
Assume APR cartridges are replaced at a rate of 100 per year (ERG 2003)
ERG (2003)
29 CFR 1910.134(f)(2)
3
ERG (2003)
0.02
3
APF Factor 25
Breathing Tube
3
Training
Loose-Fitting Facepiece
(PAPR)
1
Assume PAPR cartridges are replaced at a rate of 50 per year (ERG 2003)
Assembly kit does not include facepiece and breathing tube. Useful life from OSHA (1996)and ERG (2003)
Assume breathing tubes have the same useful life as a mask or facepiece, since facepieces are regularly sold
with breathing tubes.
ERG (2003)
3
ERG (2003)
Breathing Tube
3
Pump
7
Pump Installation
7
Pump Inlet Filter
0.48
Pump Outlet Filter
0.19
Full Facepiece, APR
Cartridge Filters, APR
Training
Qualitative Fit Testing
Half Mask
2
0.01
1
1
3
Assume breathing tubes have the same useful life as masks or facepieces, since facepieces are regularly sold
with breathing tubes.
Pumps are assumed to have a useful life of 7 years for all industries. The useful life is estimated by
considering a range of daily run times for 260 days per year under the assumption that the pump has a
service life of 10,000 hours (Northern Safety & Industrial 2016) and not more than 10 years.
Assume every time a new pump is purchased, it will need to be installed in a clean air environment. Assume
$50 worth of labor and materials used for installation.
Assume pump inlet filters have a 500 hour life span (MST Inc. 2001). Employees assumed to work 260
days per year. The replacement rate is calculated with the assumption of 4 hours of use per day (1040 hours
per year).
Assume pump outlet filters have a 200 hour life span (MST Inc. 2001). Employees assumed to work 260
days per year. The replacement rate is calculated with the assumption of 4 hours of use per day, and 0.19 is
rounded to 0.20 for analysis
APF Factor 50
ERG (2003)
Assume APR cartridges are replaced at a rate of 100 per year (ERG 2003)
ERG (2003)
29 CFR 1910.134(f)(2)
ERG (2003)
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
B-20
Table B-12: Respirator PPE Useful Life
Respirator System
Component
Cartridge Filters (PAPR)
PAPR System
Components Kit
SAR, Continuous Flow Mode, Half
Mask
PAPR, Full Facepiece
PAPR Helmet/Hood
Useful
Life
(years)
0.02
3
Breathing Tube
3
Training
Quantitative Fit Testing
Half Mask
Breathing Tube and
Airline Hose
1
1
3
Pump (1/4 HP)
7
Pump Installation
7
Pump Inlet Filter
0.48
Pump Outlet Filter
0.19
3
Training
Quantitative Fit Testing
1
1
Full Facepiece
3
PAPR System
3
Breathing Tube
3
Cartridge Filters (PAPR)
Training
Quantitative Fit Testing
Hood
PAPR System
Components Kit
0.02
1
1
3
3
Description
Assume PAPR cartridges are replaced at a rate of 50 per year (ERG 2003)
OSHA (1996); ERG (2003)
Assume breathing tubes have the same useful life as masks or facepieces, since facepieces are regularly sold
with breathing tubes.
ERG (2003)
29 CFR 1910.134(f)(2)
ERG (2003)
Assume breathing tubes have the same useful life as a mask or facepiece, since facepieces are regularly sold
with breathing tubes. Airline hose assumed to be replaced with breathing tube.
Pumps are assumed to have a useful life of 7 years for all industries. The useful life is estimated by
considering a range of daily run times for 260 days per year under the assumption that the pump has a
service life of 10,000 hours (Northern Safety & Industrial 2016) and not more than 10 years.
Assume every time a new pump is purchased, it will need to be installed in a clean air environment. Assume
$50 worth of labor and materials used for installation.
A replacement rate of about once every two years (MST Inc. 2001)
Assume pump outlet filters have a 200 hour life span (MST Inc. 2001). Employees assumed to work 260
days per year. The replacement rate is calculated with the assumption of 4 hours of use per day, and 0.19 is
rounded to 0.20 for analysis
ERG (2003)
29 CFR 1910.134(f)(2)
APF Factor 1,000
ERG (2003)
Assembly kit does not include facepiece and breathing tube. Useful life from OSHA (1996) and ERG
(2003)
Assume breathing tubes have the same useful life as a mask or facepiece because they are regularly sold
with breathing tubes.
Assume PAPR cartridges are replaced at a rate of 50 per year (ERG 2003)
ERG (2003)
29 CFR 1910.134(f)(2)
OSHA (1996); ERG (2003)
OSHA (1996); ERG (2003)
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
B-21
Table B-12: Respirator PPE Useful Life
Respirator System
Component
Breathing Tube
Cartridge Filters (PAPR)
Training
Quantitative Fit Testing
Full Facepiece
SAR, Continuous Flow Mode, Full
Facepiece
SAR, Continuous Flow Mode,
Helmet/Hood
Useful
Life
(years)
3
0.02
1
1
3
Pump (1/4 HP)
7
Breathing Tube and
Airline Hose
3
Pump Installation
7
Pump Inlet Filter
0.48
Pump Outlet Filter
0.19
Training
Quantitative Fit Testing
Hood
1
1
3
Pump (3/4 HP)
7
Breathing Tube and
Airline Hose
3
Pump Installation
7
Pump Inlet Filter
0.48
Pump Outlet Filter
0.19
Training
Quantitative Fit Testing
1
1
Description
Assume breathing tubes have the same useful life as a mask or facepiece because they are regularly sold
with breathing tubes.
Assume PAPR cartridges are replaced at a rate of 50 per year (ERG 2003)
ERG (2003)
29 CFR 1910.134(f)(2)
ERG (2003)
Pumps are assumed to have a useful life of 7 years for all industries. The useful life is estimated by
considering a range of daily run times for 260 days per year under the assumption that the pump has a
service life of 10,000 hours (Northern Safety & Industrial 2016) and not more than 10 years.
Assume breathing tubes have the same useful life as a mask or facepiece because they are regularly sold
with breathing tubes. Airline hose assumed to be replaced with breathing tube.
Assume that every time a new pump is purchased, it will need to be installed in a clean air environment.
Assume $50 worth of labor and materials used for installation.
A replacement rate of about once every two years (MST Inc. 2001)
Assume pump outlet filters have a 200 hour life span (MST Inc. 2001). Employees assumed to work 260
days per year. The replacement rate is calculated with the assumption of 4 hours of use per day, and 0.19 is
rounded to 0.2
ERG (2003)
29 CFR 1910.134(f)(2)
OSHA (1996); ERG (2003)
Pumps are assumed to have a useful life of 7 years for all industries. The useful life is estimated by
considering a range of daily run times for 260 days per year under the assumption that the pump has a
service life of 10,000 hours (Northern Safety & Industrial 2016) and not more than 10 years.
Assume breathing tubes have the same useful life as a mask or facepiece because they are regularly sold
with breathing tubes. Airline hose assumed to be replaced with breathing tube.
Assume that every time a new pump is purchased, it will need to be installed in a clean air environment.
Assume $50 worth of labor and materials used for installation.
A replacement rate of about once every two years (MST Inc. 2001)
Assume pump outlet filters have a 200 hour life span (MST Inc. 2001). Employees assumed to work 260
days per year. The replacement rate is calculated with the assumption of 4 hours of use per day, and 0.19 is
rounded to 0.2
ERG (2003)
29 CFR 1910.134(f)(2)
APF Factor 10,000
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
B-22
Table B-12: Respirator PPE Useful Life
Respirator System
Component
Positive Pressure SCBA
System (includes entire
system, including full
facepiece)
SCBA, Positive Pressure Mode, Full
Facepiece
SCBA, Positive Pressure Mode,
Helmet/Hood
Useful
Life
(years)
3
Description
ERG (2003)
Air Compressor
16
Training
Quantitative Fit Testing
Positive Pressure SCBA
System (includes entire
system, including hood)
1
1
Estimated useful life for air compressor is 20 years with preventative maintenance, 16 years without
preventative maintenance. Assume preventative maintenance not done. Assume an industrial air compressor
($27,021.80) will serve about 5 employees, recharging their SCBA cylinders. ($27,021.800/5 = $5,404.36)
As an alternative to filling SCBA cylinders on site with an air compressor, a cylinder recharge system may
be used. Costs for this service are not currently developed (Koo 2015).
ERG (2003)
29 CFR 1910.134(f)(2)
3
ERG (2003)
Air Compressor
16
Training
Quantitative Fit Testing
1
1
Estimated useful life for air compressor is 20 years with preventative maintenance, 16 years without
preventative maintenance. Assume preventative maintenance not done. Assume an industrial air compressor
($27,021.80) will serve about 5 employees, recharging their SCBA cylinders. ($27,021.800/5 = $5,404.36).
As an alternative to filling SCBA cylinders on site with an air compressor, a cylinder recharge system may
be used. Costs for this service are not currently developed (Koo 2015).
ERG (2003)
29 CFR 1910.134(f)(2)
APR: Air-Purifying Respirators; PAPR: Powered Air-Purifying Respirator; SAR: Supplied-Air Respirator; SCBA: Self-Contained Breathing Apparatus
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
B-23
Table B-13 presents unit costs estimates for respirators and respirator system components. Average
annual recurring costs are estimated as the unit cost divided by the useful life of each component.
Respirators are organized by their corresponding APF. Unit cost estimates for individual respirator
system components and kits are based on price data collected from retailer websites. Price data are
averaged for component and kit unit cost estimates that incorporate the price of more than one product
brand.
Table B-13: PPE Equipment Unit Costs per Worker, by Respirator System
Respirator
System
Component
Unit Cost
Useful Life
(Years)
Unit Costs
Initial
Recurring
APF Factor 10
APR, Half Mask
Half Mask, (APR)
$22.45
2
$22
$11
Cartridge Filters (APR)
$20.32
0.01
$2,032
$2,032
Total
$2,054
$2,043
APF Factor 25
PAPR, LooseFitting Facepiece
Loose-Fitting Facepiece
(PAPR)
$59.03
3
$59
$20
Cartridge Filters (PAPR)
$12.91
0.02
$646
$646
$1,175.01
3
$1,175
$392
$60.41
3
$60
$20
Total
$1,940
$1,077
$59.03
3
$59
$20
$164.32
3
$164
$55
$1,018.46
7
$1,018
$145
Pump Installation
$55.74
7
$56
$8
Pump Inlet Filter
$8.68
0.48
$18
$18
$14.67
0.19
$77
$77
Total
$1,393
$323
PAPR System
Breathing Tube
Loose-Fitting Facepiece
(PAPR)
SAR, Continuous
Flow Mode,
Loose-Fitting
Facepiece
Breathing Tube
Pump
Pump Outlet Filter
APF Factor 50
APR, Full
Facepiece
PAPR, Half Mask
Full Facepiece (APR)
Cartridge Filters (APR)
$246.28
2
$246
$123
$20.32
0.01
$2,032
$2,032
Total
$2,278
$2,155
Half Mask
$22.45
3
$22
$7
Cartridge Filters (PAPR)
$12.91
0.02
$646
$646
$1,175.01
3
$1,175
$392
$60.41
3
$60
$20
Total
$1,903
$1,065
PAPR System Components Kit
Breathing Tube and Airline
Hose
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
B-24
Table B-13: PPE Equipment Unit Costs per Worker, by Respirator System
Respirator
System
Component
Half Mask
Useful Life
(Years)
Unit Costs
Initial
Recurring
$22.45
3
$22
$7
$164.32
3
$164
$55
$1,018.46
7
$1,018
$145
Pump Installation
$55.74
7
$56
$8
Pump Inlet Filter
$8.68
0.48
$18
$18
$14.67
0.19
$77
$77
Total
$1,356
$311
Breathing Tube
SAR, Continuous
Flow Mode, Half
Mask
Unit Cost
Pump
Pump Outlet Filter
APF Factor 1,000
PAPR, Full
Facepiece
Full Facepiece
$202.48
3
$202
$67
PAPR System
$1,175.01
3
$1,175
$392
Breathing Tube
$60.41
3
$60
$20
Cartridge Filters (PAPR)
$12.91
0.02
$646
$646
Total
$2,083
$1,125
$100.14
3
$100
$33
Hood
PAPR,
Helmet/Hood
SAR, Continuous
Flow Mode, Full
Facepiece
PAPR System Components Kit
$1,175.01
3
$1,175
$392
Breathing Tube
$60.41
3
$60
$20
Cartridge Filters (PAPR)
$12.91
0.02
$646
$646
Total
$1,981
$1,091
Full Facepiece
$202.48
3
$202
$67
Pump (1/4 HP)
$1,018.46
7
$1,018
$145
$164.32
3
$164
$55
Pump Installation
$55.74
7
$56
$8
Pump Inlet Filter
$8.68
0.48
$18
$18
Breathing Tube and Airline
Hose
Pump Outlet Filter
0.19
$77
$77
Total
$1,536
$371
$100.14
3
$100
$33
$1,101.11
7
$1,101
$157
$164.32
3
$164
$55
Pump Installation
$55.74
7
$56
$8
Pump Inlet Filter
$13.07
0.48
$27
$27
Pump Outlet Filter
$14.67
0.19
$77
$77
Total
$1,526
$358
Hood
Pump (3/4 HP)
SAR, Continuous
Flow Mode,
Helmet/Hood
Breathing Tube and Airline
Hose
$14.67
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
B-25
Table B-13: PPE Equipment Unit Costs per Worker, by Respirator System
Respirator
System
Component
Unit Cost
Useful Life
(Years)
Unit Costs
Initial
Recurring
APF Factor 10,000
SCBA, Positivepressure Mode,
Full Facepiece
SCBA, Positivepressure Mode,
Helmet/Hood
Positive-pressure SCBA
System (includes full
facepiece):
$2,535.81
3
$2,536
$845
Air Compressor
$6,024.97
16
$6,025
$377
Total
$8,561
$1,222
Positive-pressure SCBA system
(includes hood)
$2,775.05
3
$2,775
$925
Air Compressor
$6,024.97
16
$6,025
$377
Total
$8,800
$1,302
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
B-26
9.
Baseline Respirator PPE Use
Incremental costs of complying with a respirator PPE requirement are estimated by incorporating the
baseline respirator use among affected facilities. The Respiratory Protection Rule specifies that
employees exposed to harmful substances must wear respiratory protection if workplace exposure levels
are above the specified Permissible Exposure Limit (PEL) for that substance. The suitability of an APF
for a workplace is determined by the Maximum Use Concentration (MUC), or the maximum
concentration of a substance that an employee will be protected against while wearing a respirator of a
given APF. The MUC is calculated by multiplying the APF of a respirator by the exposure limit of a
substance (OSHA 2009).
For example, given a PEL of 100 ppm, a worker can be expected to be protected from concentrations of
up to 1,000 ppm while wearing an APF 10 respirator. The APF required for compliance with OSHA’s
Respiratory Protection Rule is therefore determined by dividing the MUC of a workplace by the PEL. For
example, if exposure of a regulated substance is 10,000 ppm, facilities will need to provide workers with
a respirator of an APF of 100 to be compliant with the rule.
It is worth noting that a number of factors are taken into account when selecting a respirator, including
cost, comfort, compatibility with the facility layout, and mobility requirements of the job. Thus, it is
likely that respirator selection is not based solely on required APF or cost alone and that facilities may
provide respirators with APFs above what is required.
This analysis uses the Bureau of Labor Statistic’s 2001 Respirator Usage in Private Sector Firms (RUPS)
survey to estimate the percentage of facilities that use each type of respirator in the baseline (BLS 2003).
The RUPS was conducted jointly by the Bureau of Labor Statistics (BLS) and the National Institute
forOccupational Safety and Health (NIOSH).). The survey was conducted between August 2000 and
January 2001, and collected data on the number of private sector establishments that use respirators, as
well as the types of respirators they use. The survey was sent to a sample of 40,002 establishments (75.5
percent response rate) that is representative of all private sector establishments.
For each industry sector, Table B-14 presents the number and percent of establishments using each type
of respirator and the percent of establishments associated with each APF. Note that because the mode
used by supplied air or self-contained breathing apparatus systems (continuous flow or pressure demand)
is not specified in the survey, it is assumed that establishments are evenly divided between the two modes
for each respirator type.
Table B-14: Baseline Respirator Use, by APF
Sector
APF
10
25
Respirator Type
50
1,000
Percent of
Establishments
Using Respirators
Type
APF
28,345
38.58%
511
0.70%
-
-
15,091
20.54%
PAPR, Half Mask
2,372
3.23%
SAR, Continuous Flow Half Mask
1,971
2.68%
PAPR, Full Facepiece
3,398
4.62%
PAPR, Helmet/Hood
5,647
7.69%
SAR, Continuous Flow Full Facepiece
2,729
3.71%
APR, Half Mask
PAPR, Loose-Fitting Facepiece
SAR, Continuous Flow Loose-Fitting Facepiece
APR, Full Facepiece
Manufacturing
Number
of
Establish
-ments
38.58%
0.70%
26.45%
27.59%
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
B-27
Table B-14: Baseline Respirator Use, by APF
Sector
APF
10,000
10
25
Respirator Type
Construction
1,000
10,000
10
25
50
8,498
11.57%
SCBA, Positive-pressure Mode, Full Facepiece
2,457
3.34%
SCBA, Positive-pressure Mode, Helmet/Hood
2,457
3.34%
26,008
37.38%
2,822
4.06%
-
-
12,834
18.44%
PAPR, Half Mask
5,012
7.20%
SAR, Continuous Flow Half Mask
2,184
3.14%
PAPR, Full Facepiece
3,148
4.52%
PAPR, Helmet/Hood
3,164
4.55%
SAR, Continuous Flow Full Facepiece
4,020
5.78%
SAR, Continuous Flow Helmet/Hood
6,698
9.63%
SCBA, Positive-pressure Mode, Full Facepiece
1,848
2.66%
SCBA, Positive-pressure Mode, Helmet/Hood
1,848
2.66%
APR, Half Mask
2,052
47.10%
PAPR, Loose-Fitting Facepiece
0
0.00%
SAR, Continuous Flow Loose-Fitting Facepiece
-
-
APR, Full Facepiece
727
16.69%
PAPR, Half Mask
241
5.53%
47
1.08%
PAPR, Full Facepiece
265
6.08%
PAPR, Helmet/Hood
150
3.44%
SAR, Continuous Flow Full Facepiece
137
3.15%
SAR, Continuous Flow Helmet/Hood
362
8.30%
SCBA, Positive-pressure Mode, Full Facepiece
188
4.32%
SCBA, Positive-pressure Mode, Helmet/Hood
188
4.32%
4,760
30.19%
124
0.79%
-
-
2,556
16.21%
PAPR, Half Mask
341
2.16%
SAR, Continuous Flow Half Mask
522
3.31%
PAPR, Full Facepiece
810
5.14%
PAPR, Helmet/Hood
796
5.05%
SAR, Continuous Flow Full Facepiece
1,373
8.71%
SAR, Continuous Flow Helmet/Hood
1,716
10.89%
APR, Half Mask
PAPR, Loose-Fitting Facepiece
SAR, Continuous Flow Loose-Fitting Facepiece
SAR, Continuous Flow Half Mask
Mining
1,000
10,000
10
25
APR, Half Mask
PAPR, Loose-Fitting Facepiece
SAR, Continuous Flow Loose-Fitting Facepiece
APR, Full Facepiece
Transportation and
Public Utilities
50
1,000
Percent of
Establishments
Using Respirators
Type
APF
SAR, Continuous Flow Helmet/Hood
APR, Full Facepiece
50
Number
of
Establish
-ments
6.68%
37.38%
4.06%
28.78%
24.48%
5.32%
47.10%
0.00%
23.30%
20.97%
8.64%
30.19%
0.79%
21.68%
29.79%
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
B-28
Table B-14: Baseline Respirator Use, by APF
Sector
APF
10,000
10
25
Respirator Type
SCBA, Positive-pressure Mode, Full Facepiece
Wholesale Trade
1,000
10,000
10
25
50
Retail Trade
1,000
10,000
10
25
Services
1,000
10,000
8.78%
1,384
8.78%
38.42%
1,254
3.19%
-
-
8,637
21.98%
PAPR, Half Mask
814
2.07%
SAR, Continuous Flow Half Mask
726
1.85%
PAPR, Full Facepiece
1,979
5.04%
PAPR, Helmet/Hood
2,371
6.03%
SAR, Continuous Flow Full Facepiece
1,007
2.56%
SAR, Continuous Flow Helmet/Hood
3,055
7.77%
SCBA, Positive-pressure Mode, Full Facepiece
2,178
5.54%
SCBA, Positive-pressure Mode, Helmet/Hood
2,178
5.54%
10,556
43.46%
2,188
9.01%
-
-
APR, Full Facepiece
4,289
17.66%
PAPR, Half Mask
2,270
9.35%
SAR, Continuous Flow Half Mask
1,053
4.34%
PAPR, Full Facepiece
800
3.29%
PAPR, Helmet/Hood
630
2.59%
SAR, Continuous Flow Full Facepiece
684
2.81%
SAR, Continuous Flow Helmet/Hood
720
2.96%
SCBA, Positive-pressure Mode, Full Facepiece
550
2.26%
SCBA, Positive-pressure Mode, Helmet/Hood
550
2.26%
45,508
51.85%
833
0.95%
-
-
15,753
17.95%
PAPR, Half Mask
2,110
2.40%
SAR, Continuous Flow Half Mask
3,800
4.33%
PAPR, Full Facepiece
7,362
8.39%
PAPR, Helmet/Hood
3,157
3.60%
SAR, Continuous Flow Full Facepiece
2,410
2.75%
SAR, Continuous Flow Helmet/Hood
2,386
2.72%
SCBA, Positive-pressure Mode, Full Facepiece
2,229
2.54%
APR, Half Mask
PAPR, Loose-Fitting Facepiece
SAR, Continuous Flow Loose-Fitting Facepiece
APR, Half Mask
PAPR, Loose-Fitting Facepiece
SAR, Continuous Flow Loose-Fitting Facepiece
APR, Half Mask
PAPR, Loose-Fitting Facepiece
SAR, Continuous Flow Loose-Fitting Facepiece
APR, Full Facepiece
50
1,384
Percent of
Establishments
Using Respirators
Type
APF
15,096
SCBA, Positive-pressure Mode, Helmet/Hood
APR, Full Facepiece
50
Number
of
Establish
-ments
17.56%
38.42%
3.19%
25.90%
21.40%
11.08%
43.46%
9.01%
31.35%
11.65%
4.52%
51.85%
0.95%
24.68%
17.46%
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
5.08%
B-29
Table B-14: Baseline Respirator Use, by APF
Sector
APF
Number
of
Establish
-ments
Respirator Type
SCBA, Positive-pressure Mode, Helmet/Hood
2,229
Percent of
Establishments
Using Respirators
Type
APF
2.54%
Source: BLS (2003)
Baseline use of PPE in each industry was estimated using the 2001 RUPS survey data (BLS 2003)
estimates for the number of establishments using PPE and the 2001 Census County Business Patterns data
(U.S. Census Bureau 2001) to estimate the total number of establishments by industry (see Table B-15).
Table B-15: Percent of Baseline PPE Use by Industry
Industry
Percent of Establishments
with Baseline PPE Use
Manufacturing
28%
Construction
22%
Mining
Transportation and Public
Utilities
34%
Wholesale trade
15%
12%
Retail trade
4%
Service
5%
Sources: (BLS 2003) and (U.S. Census Bureau 2001)
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
B-30
10.
Total Annual Respiratory Program Costs
Table B-16 presents the total initial costs of a PPE program, by respirator system. Table B-17 presents the
total annual recurring costs of a PPE program, by respirator system. Both tables cover all seven industry
sectors included in the analysis.
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
B-31
Table B-16: Total Initial PPE Costs
Sector
APF
Respirator System
10
APR, Half Mask
PAPR, Loose-Fitting
Facepiece
SAR, Loose-Fitting
Facepiece
APR, Full Facepiece
PAPR, Half Mask
SAR, Continuous Flow
Half Mask
PAPR, Full Facepiece
PAPR, Helmet/Hood
SAR, Continuous Flow
Full Facepiece
SAR, Continuous Flow
Helmet/Hood
SCBA, Positive-pressure
Mode, Full Facepiece
SCBA, Positive-pressure
Mode, Helmet/Hood
APR, Half Mask
PAPR, Loose-Fitting
Facepiece
SAR, Loose-Fitting
Facepiece
APR, Full Facepiece
PAPR, Half Mask
SAR, Continuous Flow
Half Mask
PAPR, Full Facepiece
PAPR, Helmet/Hood
SAR, Continuous Flow
Full Facepiece
25
25
50
50
50
Manufacturing
1,000
1,000
1,000
1,000
10,000
10,000
10
25
25
Construction
50
50
50
1,000
1,000
1,000
Respirator
Program Costs
Equipment
Costs
Medical
Evaluation
Costs
Fit Test
Costs
Training
Costs
Cleaning
Costs
Total Costs
$409
$2,054
$109
$0
$0
$0
$2,572
$409
$1,940
$109
$0
$0
$0
$2,458
$409
$1,393
$109
$0
$0
$0
$1,911
$409
$409
$2,278
$1,903
$109
$109
$0
$0
$0
$0
$0
$0
$2,796
$2,421
$409
$1,356
$109
$0
$0
$0
$1,874
$409
$409
$2,083
$1,981
$109
$109
$0
$0
$0
$0
$0
$0
$2,601
$2,499
$409
$1,536
$109
$0
$0
$0
$2,054
$409
$1,526
$109
$0
$0
$0
$2,044
$409
$8,561
$109
$0
$0
$0
$9,079
$409
$8,800
$109
$0
$0
$0
$9,318
$446
$2,054
$116
$0
$0
$0
$2,617
$446
$1,940
$116
$0
$0
$0
$2,503
$446
$1,393
$116
$0
$0
$0
$1,955
$446
$446
$2,278
$1,903
$116
$116
$0
$0
$0
$0
$0
$0
$2,841
$2,466
$446
$1,356
$116
$0
$0
$0
$1,919
$446
$446
$2,083
$1,981
$116
$116
$0
$0
$0
$0
$0
$0
$2,646
$2,544
$446
$1,536
$116
$0
$0
$0
$2,099
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
B-32
Table B-16: Total Initial PPE Costs
Sector
APF
1,000
10,000
10,000
10
25
25
50
50
50
Mining
1,000
1,000
1,000
1,000
10,000
10,000
10
25
Transportation
and Public
Utilities
25
50
50
50
1,000
Respirator System
SAR, Continuous Flow
Helmet/Hood
SCBA, Positive-pressure
Mode, Full Facepiece
SCBA, Positive-pressure
Mode, Helmet/Hood
APR, Half Mask
PAPR, Loose-Fitting
Facepiece
SAR, Loose-Fitting
Facepiece
APR, Full Facepiece
PAPR, Half Mask
SAR, Continuous Flow
Half Mask
PAPR, Full Facepiece
PAPR, Helmet/Hood
SAR, Continuous Flow
Full Facepiece
SAR, Continuous Flow
Helmet/Hood
SCBA, Positive-pressure
Mode, Full Facepiece
SCBA, Positive-pressure
Mode, Helmet/Hood
APR, Half Mask
PAPR, Loose-Fitting
Facepiece
SAR, Loose-Fitting
Facepiece
APR, Full Facepiece
PAPR, Half Mask
SAR, Continuous Flow
Half Mask
PAPR, Full Facepiece
Respirator
Program Costs
Equipment
Costs
Medical
Evaluation
Costs
Fit Test
Costs
Training
Costs
Cleaning
Costs
Total Costs
$446
$1,526
$116
$0
$0
$0
$2,088
$446
$8,561
$116
$0
$0
$0
$9,123
$446
$8,800
$116
$0
$0
$0
$9,363
$376
$2,054
$116
$0
$0
$0
$2,547
$376
$1,940
$116
$0
$0
$0
$2,432
$376
$1,393
$116
$0
$0
$0
$1,885
$376
$376
$2,278
$1,903
$116
$116
$0
$0
$0
$0
$0
$0
$2,771
$2,396
$376
$1,356
$116
$0
$0
$0
$1,849
$376
$376
$2,083
$1,981
$116
$116
$0
$0
$0
$0
$0
$0
$2,576
$2,473
$376
$1,536
$116
$0
$0
$0
$2,029
$376
$1,526
$116
$0
$0
$0
$2,018
$376
$8,561
$116
$0
$0
$0
$9,053
$376
$8,800
$116
$0
$0
$0
$9,292
$503
$2,054
$120
$0
$0
$0
$2,677
$503
$1,940
$120
$0
$0
$0
$2,563
$503
$1,393
$120
$0
$0
$0
$2,016
$503
$503
$2,278
$1,903
$120
$120
$0
$0
$0
$0
$0
$0
$2,901
$2,526
$503
$1,356
$120
$0
$0
$0
$1,979
$503
$2,083
$120
$0
$0
$0
$2,706
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
B-33
Table B-16: Total Initial PPE Costs
Sector
APF
Respirator System
1,000
PAPR, Helmet/Hood
SAR, Continuous Flow
Full Facepiece
SAR, Continuous Flow
Helmet/Hood
SCBA, Positive-pressure
Mode, Full Facepiece
SCBA, Positive-pressure
Mode, Helmet/Hood
APR, Half Mask
PAPR, Loose-Fitting
Facepiece
SAR, Loose-Fitting
Facepiece
APR, Full Facepiece
PAPR, Half Mask
SAR, Continuous Flow
Half Mask
PAPR, Full Facepiece
PAPR, Helmet/Hood
SAR, Continuous Flow
Full Facepiece
SAR, Continuous Flow
Helmet/Hood
SCBA, Positive-pressure
Mode, Full Facepiece
SCBA, Positive-pressure
Mode, Helmet/Hood
APR, Half Mask
PAPR, Loose-Fitting
Facepiece
SAR, Loose-Fitting
Facepiece
APR, Full Facepiece
PAPR, Half Mask
1,000
1,000
10,000
10,000
10
25
25
50
50
50
Wholesale Trade
1,000
1,000
1,000
1,000
10,000
10,000
10
25
Retail Trade
25
50
50
Respirator
Program Costs
Equipment
Costs
Medical
Evaluation
Costs
Fit Test
Costs
Training
Costs
Cleaning
Costs
Total Costs
$503
$1,981
$120
$0
$0
$0
$2,604
$503
$1,536
$120
$0
$0
$0
$2,159
$503
$1,526
$120
$0
$0
$0
$2,149
$503
$8,561
$120
$0
$0
$0
$9,184
$503
$8,800
$120
$0
$0
$0
$9,423
$486
$2,054
$106
$0
$0
$0
$2,647
$486
$1,940
$106
$0
$0
$0
$2,532
$486
$1,393
$106
$0
$0
$0
$1,985
$486
$486
$2,278
$1,903
$106
$106
$0
$0
$0
$0
$0
$0
$2,871
$2,496
$486
$1,356
$106
$0
$0
$0
$1,948
$486
$486
$2,083
$1,981
$106
$106
$0
$0
$0
$0
$0
$0
$2,676
$2,573
$486
$1,536
$106
$0
$0
$0
$2,129
$486
$1,526
$106
$0
$0
$0
$2,118
$486
$8,561
$106
$0
$0
$0
$9,153
$486
$8,800
$106
$0
$0
$0
$9,392
$549
$2,054
$100
$0
$0
$0
$2,703
$549
$1,940
$100
$0
$0
$0
$2,588
$549
$1,393
$100
$0
$0
$0
$2,041
$549
$549
$2,278
$1,903
$100
$100
$0
$0
$0
$0
$0
$0
$2,927
$2,552
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
B-34
Table B-16: Total Initial PPE Costs
Sector
APF
50
1,000
1,000
1,000
1,000
10,000
10,000
10
25
25
50
50
50
Services
1,000
1,000
1,000
1,000
10,000
10,000
Respirator System
SAR, Continuous Flow
Half Mask
PAPR, Full Facepiece
PAPR, Helmet/Hood
SAR, Continuous Flow
Full Facepiece
SAR, Continuous Flow
Helmet/Hood
SCBA, Positive-pressure
Mode, Full Facepiece
SCBA, Positive-pressure
Mode, Helmet/Hood
APR, Half Mask
PAPR, Loose-Fitting
Facepiece
SAR, Loose-Fitting
Facepiece
APR, Full Facepiece
PAPR, Half Mask
SAR, Continuous Flow
Half Mask
PAPR, Full Facepiece
PAPR, Helmet/Hood
SAR, Continuous Flow
Full Facepiece
SAR, Continuous Flow
Helmet/Hood
SCBA, Positive-pressure
Mode, Full Facepiece
SCBA, Positive-pressure
Mode, Helmet/Hood
Respirator
Program Costs
Equipment
Costs
Medical
Evaluation
Costs
Fit Test
Costs
Training
Costs
Cleaning
Costs
Total Costs
$549
$1,356
$100
$0
$0
$0
$2,005
$549
$549
$2,083
$1,981
$100
$100
$0
$0
$0
$0
$0
$0
$2,732
$2,630
$549
$1,536
$100
$0
$0
$0
$2,185
$549
$1,526
$100
$0
$0
$0
$2,174
$549
$8,561
$100
$0
$0
$0
$9,209
$549
$8,800
$100
$0
$0
$0
$9,449
$541
$2,054
$116
$0
$0
$0
$2,711
$541
$1,940
$116
$0
$0
$0
$2,596
$541
$1,393
$116
$0
$0
$0
$2,049
$541
$541
$2,278
$1,903
$116
$116
$0
$0
$0
$0
$0
$0
$2,935
$2,560
$541
$1,356
$116
$0
$0
$0
$2,013
$541
$541
$2,083
$1,981
$116
$116
$0
$0
$0
$0
$0
$0
$2,740
$2,638
$541
$1,536
$116
$0
$0
$0
$2,193
$541
$1,526
$116
$0
$0
$0
$2,182
$541
$8,561
$116
$0
$0
$0
$9,217
$541
$8,800
$116
$0
$0
$0
$9,456
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
B-35
Table B-17: Total Annual Recurring PPE Costs
Sector
APF
Respirator System
10
APR, Half Mask
PAPR, Loose-Fitting
Facepiece
SAR, Loose-Fitting
Facepiece
APR, Full Facepiece
PAPR, Half Mask
SAR, Continuous Flow
Half Mask
PAPR, Full Facepiece
PAPR, Helmet/Hood
SAR, Continuous Flow
Full Facepiece
SAR, Continuous Flow
Helmet/Hood
SCBA, Positive-pressure
Mode, Full Facepiece
SCBA, Positive-pressure
Mode, Helmet/Hood
APR, Half Mask
PAPR, Loose-Fitting
Facepiece
SAR, Loose-Fitting
Facepiece
APR, Full Facepiece
PAPR, Half Mask
SAR, Continuous Flow
Half Mask
PAPR, Full Facepiece
PAPR, Helmet/Hood
SAR, Continuous Flow
Full Facepiece
SAR, Continuous Flow
Helmet/Hood
25
25
50
50
50
Manufacturing
1,000
1,000
1,000
1,000
10,000
10,000
10
25
25
Construction
50
50
50
1,000
1,000
1,000
1,000
Respirator
Program Costs
Equipment
Costs
Medical
Evaluation
Costs
Fit Test
Costs
Training
Costs
Cleaning
Costs
Total Costs
$102
$2,043
$22
$65
$128
$418
$2,777
$102
$1,077
$22
$0
$255
$418
$1,874
$102
$323
$22
$0
$255
$418
$1,120
$102
$102
$2,155
$1,065
$22
$22
$65
$152
$128
$255
$418
$418
$2,889
$2,013
$102
$311
$22
$152
$255
$418
$1,259
$102
$102
$1,125
$1,091
$22
$22
$152
$152
$255
$255
$418
$418
$2,073
$2,039
$102
$371
$22
$152
$255
$418
$1,319
$102
$358
$22
$152
$255
$418
$1,306
$102
$1,222
$22
$152
$510
$418
$2,425
$102
$1,302
$22
$152
$510
$418
$2,505
$112
$2,043
$23
$74
$147
$530
$2,929
$112
$1,077
$23
$0
$293
$530
$2,035
$112
$323
$23
$0
$293
$530
$1,281
$112
$112
$2,155
$1,065
$23
$23
$74
$173
$147
$293
$530
$530
$3,040
$2,196
$112
$311
$23
$173
$293
$530
$1,442
$112
$112
$1,125
$1,091
$23
$23
$173
$173
$293
$293
$530
$530
$2,256
$2,222
$112
$371
$23
$173
$293
$530
$1,502
$112
$358
$23
$173
$293
$530
$1,489
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
B-36
Table B-17: Total Annual Recurring PPE Costs
Sector
APF
10,000
10,000
10
25
25
50
50
50
Mining
1,000
1,000
1,000
1,000
10,000
10,000
10
25
Transportation
and Public
Utilities
25
50
50
50
1,000
1,000
Respirator System
SCBA, Positive-pressure
Mode, Full Facepiece
SCBA, Positive-pressure
Mode, Helmet/Hood
APR, Half Mask
PAPR, Loose-Fitting
Facepiece
SAR, Loose-Fitting
Facepiece
APR, Full Facepiece
PAPR, Half Mask
SAR, Continuous Flow
Half Mask
PAPR, Full Facepiece
PAPR, Helmet/Hood
SAR, Continuous Flow
Full Facepiece
SAR, Continuous Flow
Helmet/Hood
SCBA, Positive-pressure
Mode, Full Facepiece
SCBA, Positive-pressure
Mode, Helmet/Hood
APR, Half Mask
PAPR, Loose-Fitting
Facepiece
SAR, Loose-Fitting
Facepiece
APR, Full Facepiece
PAPR, Half Mask
SAR, Continuous Flow
Half Mask
PAPR, Full Facepiece
PAPR, Helmet/Hood
Respirator
Program Costs
Equipment
Costs
Medical
Evaluation
Costs
Fit Test
Costs
Training
Costs
Cleaning
Costs
Total Costs
$112
$1,222
$23
$173
$586
$530
$2,646
$112
$1,302
$23
$173
$586
$530
$2,726
$94
$2,043
$23
$74
$147
$530
$2,911
$94
$1,077
$23
$0
$293
$530
$2,017
$94
$323
$23
$0
$293
$530
$1,263
$94
$94
$2,155
$1,065
$23
$23
$74
$173
$147
$293
$530
$530
$3,023
$2,178
$94
$311
$23
$173
$293
$530
$1,424
$94
$94
$1,125
$1,091
$23
$23
$173
$173
$293
$293
$530
$530
$2,238
$2,204
$94
$371
$23
$173
$293
$530
$1,484
$94
$358
$23
$173
$293
$530
$1,471
$94
$1,222
$23
$173
$586
$530
$2,628
$94
$1,302
$23
$173
$586
$530
$2,708
$126
$2,043
$24
$79
$157
$580
$3,009
$126
$1,077
$24
$0
$314
$580
$2,120
$126
$323
$24
$0
$314
$580
$1,366
$126
$126
$2,155
$1,065
$24
$24
$79
$183
$157
$314
$580
$580
$3,121
$2,290
$126
$311
$24
$183
$314
$580
$1,537
$126
$126
$1,125
$1,091
$24
$24
$183
$183
$314
$314
$580
$580
$2,350
$2,316
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
B-37
Table B-17: Total Annual Recurring PPE Costs
Sector
APF
1,000
1,000
10,000
10,000
10
25
25
50
50
50
Wholesale Trade
1,000
1,000
1,000
1,000
10,000
10,000
10
25
Retail Trade
25
50
50
Respirator System
SAR, Continuous Flow
Full Facepiece
SAR, Continuous Flow
Helmet/Hood
SCBA, Positive-pressure
Mode, Full Facepiece
SCBA, Positive-pressure
Mode, Helmet/Hood
APR, Half Mask
PAPR, Loose-Fitting
Facepiece
SAR, Loose-Fitting
Facepiece
APR, Full Facepiece
PAPR, Half Mask
SAR, Continuous Flow
Half Mask
PAPR, Full Facepiece
PAPR, Helmet/Hood
SAR, Continuous Flow
Full Facepiece
SAR, Continuous Flow
Helmet/Hood
SCBA, Positive-pressure
Mode, Full Facepiece
SCBA, Positive-pressure
Mode, Helmet/Hood
APR, Half Mask
PAPR, Loose-Fitting
Facepiece
SAR, Loose-Fitting
Facepiece
APR, Full Facepiece
PAPR, Half Mask
Medical
Evaluation
Costs
Respirator
Program Costs
Equipment
Costs
Fit Test
Costs
$126
$371
$24
$183
$126
$358
$24
$126
$1,222
$126
Cleaning
Costs
Total Costs
$314
$580
$1,597
$183
$314
$580
$1,583
$24
$183
$627
$580
$2,761
$1,302
$24
$183
$627
$580
$2,841
$122
$2,043
$21
$52
$102
$380
$2,719
$122
$1,077
$21
$0
$203
$380
$1,802
$122
$323
$21
$0
$203
$380
$1,049
$122
$122
$2,155
$1,065
$21
$21
$52
$144
$102
$203
$380
$380
$2,831
$1,934
$122
$311
$21
$144
$203
$380
$1,181
$122
$122
$1,125
$1,091
$21
$21
$144
$144
$203
$203
$380
$380
$1,994
$1,960
$122
$371
$21
$144
$203
$380
$1,241
$122
$358
$21
$144
$203
$380
$1,228
$122
$1,222
$21
$144
$406
$380
$2,295
$122
$1,302
$21
$144
$406
$380
$2,374
$137
$2,043
$20
$35
$69
$285
$2,590
$137
$1,077
$20
$0
$138
$285
$1,657
$137
$323
$20
$0
$138
$285
$904
$137
$137
$2,155
$1,065
$20
$20
$35
$126
$69
$138
$285
$285
$2,702
$1,771
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
Training
Costs
B-38
Table B-17: Total Annual Recurring PPE Costs
Sector
APF
50
1,000
1,000
1,000
1,000
10,000
10,000
10
25
25
50
50
50
Services
1,000
1,000
1,000
1,000
10,000
10,000
Respirator System
SAR, Continuous Flow
Half Mask
PAPR, Full Facepiece
PAPR, Helmet/Hood
SAR, Continuous Flow
Full Facepiece
SAR, Continuous Flow
Helmet/Hood
SCBA, Positive-pressure
Mode, Full Facepiece
SCBA, Positive-pressure
Mode, Helmet/Hood
APR, Half Mask
PAPR, Loose-Fitting
Facepiece
SAR, Loose-Fitting
Facepiece
APR, Full Facepiece
PAPR, Half Mask
SAR, Continuous Flow
Half Mask
PAPR, Full Facepiece
PAPR, Helmet/Hood
SAR, Continuous Flow
Full Facepiece
SAR, Continuous Flow
Helmet/Hood
SCBA, Positive-pressure
Mode, Full Facepiece
SCBA, Positive-pressure
Mode, Helmet/Hood
Medical
Evaluation
Costs
Respirator
Program Costs
Equipment
Costs
Fit Test
Costs
$137
$311
$20
$126
$137
$137
$1,125
$1,091
$20
$20
$137
$371
$137
Cleaning
Costs
Total Costs
$138
$285
$1,018
$126
$126
$138
$138
$285
$285
$1,831
$1,797
$20
$126
$138
$285
$1,078
$358
$20
$126
$138
$285
$1,064
$137
$1,222
$20
$126
$277
$285
$2,067
$137
$1,302
$20
$126
$277
$285
$2,146
$135
$2,043
$23
$75
$148
$519
$2,943
$135
$1,077
$23
$0
$295
$519
$2,050
$135
$323
$23
$0
$295
$519
$1,296
$135
$135
$2,155
$1,065
$23
$23
$75
$171
$148
$295
$519
$519
$3,055
$2,209
$135
$311
$23
$171
$295
$519
$1,455
$135
$135
$1,125
$1,091
$23
$23
$171
$171
$295
$295
$519
$519
$2,269
$2,234
$135
$371
$23
$171
$295
$519
$1,515
$135
$358
$23
$171
$295
$519
$1,502
$135
$1,222
$23
$171
$590
$519
$2,661
$135
$1,302
$23
$171
$590
$519
$2,740
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
Training
Costs
B-39
11.
Annual Incremental Respirator PPE Costs
Facilities that do not provide PPE in the baseline are assumed to incur the total costs for implementing a
respirator program with the APF level required under TSCA. These costs are estimated as the weighted
average of the costs presented in Table B-16 and Table B-17 for each given APF and industry sector,
using the percentages presented in Table B-14 to weight the different respirator systems with the same
APF.
Facilities with a baseline respirator program are assumed to incur incremental costs if they are required to
switch to respirators with a higher APF or to switch from purified air respirators to supplied air
respirators. Facilities that are already using respirators compliant with the TSCA requirements are not
assumed to incur any costs. Estimated baseline respirator costs for facilities that must switch to compliant
respirators is estimated as the weighted average of the costs of respirators that can no longer be used,
using the percentages presented in Table B-14 to weight the costs of the different respirator systems.
Respirators that can no longer be used include those with APFs below the requirements or respirators that
use purified air when supplied air respirators are required.
Note that the costs of using higher APF respirators are sometimes lower than costs of using lower APF
respirators. This is generally the case when comparing purified air respirators with supplied air respirators
because the filters used in purified air respirators are relatively expensive. These purified air respirators
are still often preferred, despite their higher costs, because they are more comfortable to wear (with a
supplied air respirator the workers are either carrying a relatively heavy tank or are tethered to the hose
that is supplying the air). However, when the estimated costs of compliant respirators are lower than the
cost of the baseline respirators, the incremental costs of the compliant respirators are assumed to be zero
(rather than assuming a cost savings).
Table B-18 presents the initial incremental PPE costs for purified or supplied air. Table B-19 presents the
annual incremental recurring PPE costs of purified or supplied air. Table B-20 presents the initial
incremental PPE costs for supplied air only. Table B-21 presents the annual incremental recurring PPE
costs for supplied air only. All four tables cover the seven industry sectors included in the analysis.
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
B-40
Table B-18: Incremental PPE Costs, Purified or Supplied Air, Initial Costs
Sector
Manufacturing
Construction
Mining
Transportation
and Public
Utilities
Wholesale
Trade
Retail Trade
Services
APF
10
25
50
1,000
10,000
10
25
50
1,000
10,000
10
25
50
1,000
10,000
10
25
50
1,000
10,000
10
25
50
1,000
10,000
10
25
50
1,000
10,000
10
25
50
1,000
10,000
Baseline Percentage of
No Use
72%
78%
66%
88%
85%
96%
95%
Baseline No Use
Cost
$2,572
$2,458
$2,657
$2,265
$9,198
$2,617
$2,503
$2,646
$2,278
$9,243
$2,547
$2,432
$2,639
$2,256
$9,173
$2,677
$2,563
$2,723
$2,325
$9,303
$2,647
$2,532
$2,775
$2,379
$9,273
$2,703
$2,588
$2,687
$2,436
$9,329
$2,711
$2,596
$2,737
$2,546
$9,337
Baseline Use
Cost
Average Incremental APF
Cost
$0
$0
$52
$0
$6,246
$0
$0
$24
$0
$6,353
$0
$0
$62
$0
$6,093
$0
$0
$29
$0
$5,558
$0
$0
$84
$0
$5,920
$0
$0
$3
$0
$6,373
$0
$0
$19
$0
$6,313
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
$1,845
$1,763
$1,920
$1,625
$8,364
$2,046
$1,957
$2,075
$1,782
$8,613
$1,678
$1,602
$1,759
$1,486
$8,122
$2,361
$2,260
$2,405
$2,051
$8,861
$2,255
$2,157
$2,376
$2,027
$8,776
$2,600
$2,490
$2,585
$2,343
$9,216
$2,569
$2,461
$2,595
$2,413
$9,179
B-41
Table B-19: Incremental PPE Costs, Purified or Supplied Air, Recurring Costs
Sector
Manufacturing
Construction
Mining
Transportation
and Public
Utilities
Wholesale
Trade
Retail Trade
Services
APF
10
25
50
1,000
10,000
10
25
50
1,000
10,000
10
25
50
1,000
10,000
10
25
50
1,000
10,000
10
25
50
1,000
10,000
10
25
50
1,000
10,000
10
25
50
1,000
10,000
Baseline Percentage of
No Use
72%
78%
66%
88%
85%
96%
95%
Baseline No Use
Cost
$2,777
$1,874
$2,617
$1,641
$2,465
$2,929
$2,035
$2,655
$1,770
$2,686
$2,911
$2,017
$2,748
$1,816
$2,668
$3,009
$2,120
$2,796
$1,844
$2,801
$2,719
$1,802
$2,641
$1,616
$2,334
$2,590
$1,657
$2,191
$1,447
$2,107
$2,943
$2,050
$2,692
$2,023
$2,701
Baseline Use
Cost
$0
$0
$0
$0
$71
$0
$0
$0
$0
$169
$0
$0
$0
$0
$46
$0
$0
$0
$0
$229
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$1
Average Incremental APF
Cost
$1,992
$1,344
$1,877
$1,177
$1,788
$2,290
$1,591
$2,076
$1,384
$2,137
$1,917
$1,329
$1,810
$1,196
$1,773
$2,653
$1,870
$2,466
$1,626
$2,497
$2,316
$1,536
$2,250
$1,377
$1,989
$2,491
$1,594
$2,108
$1,392
$2,026
$2,789
$1,943
$2,551
$1,918
$2,560
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
B-42
Table B-20: Incremental PPE Costs, Supplied Air Only, Initial Costs
Sector
Manufacturing
Construction
Mining
Transportation
and Public
Utilities
Wholesale
Trade
Retail Trade
Services
APF
25
50
1,000
10,000
25
50
1,000
10,000
25
50
1,000
10,000
25
50
1,000
10,000
25
50
1,000
10,000
25
50
1,000
10,000
25
50
1,000
10,000
Baseline Percentage of
No Use
72%
78%
66%
88%
85%
96%
95%
Baseline No Use
Cost
$1,911
$1,874
$2,046
$9,198
$1,955
$1,919
$2,092
$9,243
$1,885
$1,849
$2,021
$9,173
$2,016
$1,979
$2,153
$9,303
$1,985
$1,948
$2,121
$9,273
$2,041
$2,005
$2,179
$9,329
$2,049
$2,013
$2,188
$9,337
Baseline Use
Cost
Average Incremental APF
Cost
$0
$0
$0
$6,694
$0
$0
$0
$6,709
$0
$0
$0
$6,669
$0
$0
$0
$6,742
$0
$0
$0
$6,657
$0
$0
$0
$6,675
$0
$0
$0
$6,651
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
$1,371
$1,344
$1,468
$8,490
$1,529
$1,500
$1,636
$8,691
$1,242
$1,218
$1,331
$8,318
$1,778
$1,746
$1,899
$9,001
$1,691
$1,660
$1,807
$8,885
$1,964
$1,928
$2,096
$9,228
$1,942
$1,908
$2,073
$9,197
B-43
Table B-21: Incremental PPE Costs, Supplied Air Only, Recurring Costs
Sector
Manufacturing
Construction
Mining
Transportation
and Public
Utilities
Wholesale
Trade
Retail Trade
Services
APF
25
50
1,000
10,000
25
50
1,000
10,000
25
50
1,000
10,000
25
50
1,000
10,000
25
50
1,000
10,000
25
50
1,000
10,000
25
50
1,000
10,000
Baseline Percentage of
No Use
72%
78%
66%
88%
85%
96%
95%
Baseline No Use
Cost
$1,120
$1,259
$1,309
$2,465
$1,281
$1,442
$1,494
$2,686
$1,263
$1,424
$1,475
$2,668
$1,366
$1,537
$1,589
$2,801
$1,049
$1,181
$1,231
$2,334
$904
$1,018
$1,071
$2,107
$1,296
$1,455
$1,508
$2,701
Baseline Use
Cost
Average Incremental APF
Cost
$0
$0
$0
$76
$0
$0
$0
$178
$0
$0
$0
$50
$0
$0
$0
$278
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$1
$803
$903
$939
$1,790
$1,002
$1,127
$1,168
$2,139
$832
$938
$971
$1,775
$1,205
$1,355
$1,402
$2,503
$893
$1,006
$1,049
$1,989
$869
$979
$1,030
$2,026
$1,228
$1,379
$1,429
$2,560
As noted previously, when the estimated costs of compliant respirators are lower than the cost of the
baseline respirators, the incremental costs of the compliant respirators are assumed to be zero (see Table
B-18 to Table B-21). We present alternative incremental cost estimates in Table B-22 through Table B25, which include all cost savings from switching to higher APF respirators in the incremental cost
estimates.
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
B-44
Table B-22: Alternative Incremental PPE Costs (includes cost savings where more protective PPE
has lower costs), Purified or Supplied Air, Initial Costs
Sector
Manufacturing
Construction
Mining
Transportation
and Public
Utilities
Wholesale
Trade
Retail Trade
Services
APF
10
25
50
1,000
10,000
10
25
50
1,000
10,000
10
25
50
1,000
10,000
10
25
50
1,000
10,000
10
25
50
1,000
10,000
10
25
50
1,000
10,000
10
25
50
1,000
10,000
Baseline Percentage of
No Use
72%
78%
66%
88%
85%
96%
95%
Baseline No Use
Cost
$2,734
$2,619
$2,818
$2,427
$9,360
$2,741
$2,627
$2,771
$2,403
$9,367
$2,741
$2,627
$2,834
$2,451
$9,367
$2,745
$2,630
$2,791
$2,393
$9,371
$2,731
$2,617
$2,859
$2,463
$9,357
$2,725
$2,610
$2,709
$2,457
$9,351
$2,741
$2,626
$2,766
$2,576
$9,367
Baseline Use
Cost
Average Incremental APF
Cost
$0
($112)
$52
($239)
$6,246
$0
($103)
$24
($255)
$6,353
$0
($115)
$62
($248)
$6,093
$0
($112)
$29
($236)
$5,558
$0
($106)
$84
($237)
$5,920
$0
($95)
$3
($219)
$6,373
$0
($112)
$19
($140)
$6,313
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
$1,961
$1,847
$2,036
$1,673
$8,479
$2,144
$2,032
$2,172
$1,823
$8,710
$1,806
$1,691
$1,887
$1,530
$8,250
$2,421
$2,307
$2,464
$2,082
$8,921
$2,327
$2,214
$2,448
$2,064
$8,848
$2,621
$2,507
$2,606
$2,355
$9,237
$2,598
$2,483
$2,623
$2,434
$9,207
B-45
Table B-23: Alternative Incremental PPE Costs (includes cost savings where more protective PPE
has lower costs), Purified or Supplied Air, Recurring Costs
Sector
Manufacturing
Construction
Mining
Transportation
and Public
Utilities
Wholesale
Trade
Retail Trade
Services
APF
10
25
50
1,000
10,000
10
25
50
1,000
10,000
10
25
50
1,000
10,000
10
25
50
1,000
10,000
10
25
50
1,000
10,000
10
25
50
1,000
10,000
10
25
50
1,000
10,000
Baseline Percentage of
No Use
72%
78%
66%
88%
85%
96%
95%
Baseline No Use
Cost
$2,817
$1,914
$2,657
$1,681
$2,506
$2,960
$2,066
$2,686
$1,801
$2,717
$2,960
$2,066
$2,797
$1,864
$2,717
$3,025
$2,137
$2,813
$1,861
$2,818
$2,740
$1,824
$2,662
$1,637
$2,356
$2,595
$1,663
$2,197
$1,453
$2,112
$2,950
$2,057
$2,699
$2,031
$2,708
Baseline Use
Cost
Average Incremental APF
Cost
$0
($887)
($86)
($748)
$71
$0
($806)
($110)
($738)
$169
$0
($894)
($109)
($802)
$46
$0
($866)
($112)
($679)
$229
$0
($846)
($5)
($782)
($56)
$0
($772)
($149)
($784)
($119)
$0
($877)
($160)
($676)
$1
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
$2,021
$1,122
$1,882
$994
$1,817
$2,314
$1,440
$2,076
$1,247
$2,161
$1,950
$1,056
$1,805
$954
$1,805
$2,668
$1,782
$2,468
$1,561
$2,512
$2,334
$1,428
$2,267
$1,279
$1,998
$2,496
$1,570
$2,107
$1,367
$2,027
$2,796
$1,904
$2,550
$1,889
$2,567
B-46
Table B-24: Alternative Incremental PPE Costs (includes cost savings where more protective PPE
has lower costs), Supplied Air Only, Initial Costs
Sector
Manufacturing
Construction
Mining
Transportation
and Public
Utilities
Wholesale
Trade
Retail Trade
Services
APF
25
50
1,000
10,000
25
50
1,000
10,000
25
50
1,000
10,000
25
50
1,000
10,000
25
50
1,000
10,000
25
50
1,000
10,000
25
50
1,000
10,000
Baseline Percentage of
No Use
72%
78%
66%
88%
85%
96%
95%
Baseline No Use
Cost
$2,072
$2,036
$2,208
$9,360
$2,080
$2,043
$2,217
$9,367
$2,080
$2,043
$2,216
$9,367
$2,083
$2,047
$2,221
$9,371
$2,070
$2,033
$2,205
$9,357
$2,063
$2,027
$2,201
$9,351
$2,079
$2,043
$2,217
$9,367
Baseline Use
Cost
Average Incremental APF
Cost
($709)
($746)
($548)
$6,694
($693)
($729)
($527)
$6,709
($697)
($734)
($552)
$6,669
($712)
($748)
($535)
$6,742
($713)
($750)
($560)
$6,657
($678)
($715)
($506)
$6,675
($703)
($740)
($529)
$6,651
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
$1,286
$1,249
$1,428
$8,606
$1,475
$1,439
$1,618
$8,788
$1,132
$1,095
$1,271
$8,446
$1,753
$1,717
$1,895
$9,060
$1,658
$1,621
$1,796
$8,957
$1,959
$1,922
$2,098
$9,249
$1,934
$1,897
$2,074
$9,225
B-47
Table B-25: Alternative Incremental PPE Costs (includes cost savings where more protective PPE
has lower costs), Supplied Air Only, Recurring Costs
Sector
Manufacturing
Construction
Mining
Transportation
and Public
Utilities
Wholesale
Trade
Retail Trade
Services
APF
25
50
1,000
10,000
25
50
1,000
10,000
25
50
1,000
10,000
25
50
1,000
10,000
25
50
1,000
10,000
25
50
1,000
10,000
25
50
1,000
10,000
Baseline Percentage of
No Use
72%
78%
66%
88%
85%
96%
95%
Baseline No Use
Cost
$1,160
$1,300
$1,350
$2,506
$1,312
$1,473
$1,525
$2,717
$1,312
$1,473
$1,523
$2,717
$1,383
$1,553
$1,606
$2,818
$1,070
$1,202
$1,252
$2,356
$909
$1,023
$1,076
$2,112
$1,303
$1,462
$1,516
$2,708
Baseline Use
Cost
Average Incremental APF
Cost
($1,528)
($1,389)
($1,291)
$76
($1,475)
($1,315)
($1,211)
$178
($1,537)
($1,376)
($1,307)
$50
($1,519)
($1,349)
($1,225)
$278
($1,536)
($1,404)
($1,321)
($63)
($1,468)
($1,354)
($1,235)
($125)
($1,544)
($1,385)
($1,264)
$1
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
$400
$540
$603
$1,819
$704
$865
$928
$2,163
$340
$501
$557
$1,807
$1,040
$1,211
$1,272
$2,518
$684
$816
$871
$1,997
$819
$932
$988
$2,027
$1,155
$1,314
$1,370
$2,567
B-48
12.
Appendix C References
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http://extra8.3m.com/SLSWeb/submitChemicalInfoSLife.html.
3M. (2019). "OSHA Respirator Medical Evaluation Questionnaire." Retrieved March 22, 2019, from
https://www.3m.com/3M/en_US/safety-centers-of-expertise-us/respiratory-protection/respiratormedical-evaluations/.
Eastern Research Group (ERG) (2003). Support for an Economic Analysis of a Proposed OSHA Standard
for Assigned Protection Factors for Respirators: Final Report; as prepared for OSHA, OSHA,
Office of Regulatory Analysis, U.S. Department of Labor. 2015: TASK Order NO. 51, OptionYear Fourt Contract NO. J-59-F-59-0010.
Koo, W. L. (2015). Determining the Economic Value of Preventative Maintenance. Jones Lang LaSalle.
T. V. Hoy.
MST Inc. (2001). "Instruction Manual Fresh-Air Pump Model 8050501."
National Institute for Occupational Safety and Health (NIOSH). (2012, August 22, 2012). "Certified
Equipment List. Definitions of Terms." Retrieved April 2, 2019, from
https://www2a.cdc.gov/drds/cel/def.htm.
Northern Safety & Industrial. (2016). "Allegro(R) 1-Worker 1/4 HP Ambient Air Pumpt." Supplied Air
Airline Respirators & Ambient Air Pumps Retrieved January 8th, 2016, 2016, from
https://www.northernsafety.com/Product/3589/Allegro-1-Worker-1-4-HP-Ambient-Air-Pump.
Occupational Safety and Health Administration (OSHA) (1996). "Final Economic and Regulatory
Flexibility Analaysis for OSHA's Standard for Occupational Exposure to Methylene Chloride."
135-137.
Occupational Safety and Health Administration (OSHA) (2009). Assigned Protection Factors for the
Revised Respiratory Protection Standard. OSHA 3352-02 2009.
Occupational Safety and Health Administration (OSHA) (2010). III. Costs of Compliance. Docket
H054A Ex. 50-2-3: 25-29.
Occupational Safety and Health Administration (OSHA). (2015). "Respirator Fit Testing." from
https://www.osha.gov/video/respiratory_protection/fittesting_transcript.html.
Occupational Safety and Health Administration (OSHA) (2016). Beryllium Final Economic Analysis
(FEA) and Final Regulatory Flexibility Analysis. OSHA-H005C-2006-0870-2042.
U.S. Bureau of Labor Statistics (BLS) (2003). Respirator Usage in Private Sector Firms, 2001. National
Institute for Occupational Safety and Health (NIOSH).
U.S. Bureau of Labor Statistics (BLS) (2023a). BLS Occupational Employment Statistics (Occupational
Employment and Wages), For May 2022.
U.S. Bureau of Labor Statistics (BLS) (2023b). Consumer Price Index - All Urban Consumers (Current
Series). CUUR0000SAM2,CUUS0000SAM2. Medical care services in U.s. city average, all
urban consumers.
U.S. Bureau of Labor Statistics (BLS) (2023c). Employer Costs for Employee Compensation (ECEC)
Supplementary Tables, for June 2022.
U.S. Bureau of Labor Statistics (BLS) (2023d). Employer Costs for Employee Compensation. Table 4.
Private industry workers by occupational and industry group. December 2022.
U.S. Bureau of Labor Statistics (BLS) (2023e). May 2022 Occupational Employment and Wage Statistics
(OEWS).
U.S. Census Bureau. (2001). "2001 County Business Patterns (NAICS)." Retrieved April 9, 2019.
U.S. Department of Energy (DOE) (1999). DOE-HDBK-1122-99: Site Academic Training Study Guide
Phase I; Module 2.07 - Respiratory Protection.
U.S. Environmental Protection Agency (EPA) (2020a). EPA Valuing Time Handbook - 2020.
U.S. Environmental Protection Agency (EPA) (2020b). Handbook on Valuing Changes in Time Use
Induced by Regulatory Requirements and Other EPA Actions. EPA-236-B-15-001. National
Center for Environmental Economics.
Appendix B: Estimated Costs for Respirator PPE for 2023 TSCA Risk Management Economic Analyses
B-49
| File Type | application/pdf |
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| Author | KSleasma |
| File Modified | 2024-11-21 |
| File Created | 2024-11-21 |