Question and Answer Fact Sheet - Overview of Regulations Governing Use and Production of Two Ozone-Depleting Solvents, CFC-113 and Methyl Chloroform

This fact sheet provides an overview of regulations governing use and production of two ozone-depleting solvents, CFC-113 and methyl chloroform. The fact sheet also discusses regulations on substitutes and provides information on how to find a substitute.

A. Solvents Covered under the 1996 Phaseout of Ozone-Depleting Chemicals

  1. Q: I heard that methyl chloroform and CFC-113 are being phased out. Is that true?

    A: Yes. Under the Clean Air Act, the U.S. is phasing out production of methyl chloroform and CFC-113 by January 1, 1996.

  2. Q: Is 1,1,1-trichloroethane ("TCA" or "1,1,1") part of the phaseout?

    A: Yes. 1,1,1 is just another name for methyl chloroform (MCF). If you want more information, EPA has a factsheet explaining the phaseout that you can request from the Stratospheric Ozone Protection Hotline at 1-800-296-1996.

  3. Q: Does that mean I can't use those chemicals any more after that date?

    A: No. The phaseout applies to chemical production and imports, not use. However, as the phaseout date approaches, it will get more and more difficult--and expensive--to buy methyl chloroform and CFC-113. After January 1, 1996, only materials held in inventory or recycled would be available for use.

  4. Q: Are perchloroethylene, methylene chloride, or trichloroethylene part of the phaseout?

    A: No. Although these chemicals are chlorinated solvents like MCF and CFC-113, they are not regulated as ozone depleters under the Clean Air Act. This is because even though these molecules have chlorine in them, they do not damage the stratospheric ozone layer since their atmospheric lifetimes are very short and they decompose before reaching the ozone layer.

B. SNAP Status and Review Process

  1. Q: What does "SNAP" stand for?

    A: EPA's Significant New Alternatives Policy program. The SNAP program implements Section 612 of the Clean Air Act.

  2. Q: What is EPA doing under the SNAP program?

    A: Under SNAP, EPA is evaluating the chemicals that companies want to use instead of the ozone-depleting substances, and making sure that they won't cause greater damage to human health and the environment than the ozone depleters they are replacing. Based on this evaluation, EPA then has to come up with a list of acceptable substitutes and a list of unacceptable substitutes.

  3. Q: Has EPA come out yet with the lists of substitutes that are either approved or restricted under SNAP?

    A: Yes, the first list under SNAP was published in the Federal Register on March 18, 1994 (59 FR 13044). You can request copies of the SNAP tables from the Stratospheric Ozone Protection Hotline at the number listed below. In addition to the decisions issued in February, EPA will continue to add new substitutes to the SNAP lists as they are developed and submitted to the Agency for review.

  4. Q: I sell a solvent substitute for cleaning that I want to get EPA approval for. What do I do?

    A: You should first check the list of acceptable substitutes under SNAP for cleaning. If your substitute is already on the list, you don't need to request EPA approval. If it's not on the list, you should submit your substitute for EPA review by contacting:

    SNAP Coordinator
    Stratospheric Protection Division, 6205J
    U.S. Environmental Protection Agency
    401 M Street, S.W.
    Washington, D.C. 20460
    (202) 233-9739
    FAX (202) 233-9577.

  5. Q: I sell a solvent cleaning substitute. How do I get information out to companies on the availability of my substitute?

    A: EPA has a list of vendors selling cleaning substitutes. You can contact the SNAP Coordinator and request to be placed on that list.

  6. Q: Do I have to check with EPA to make sure each substitute solvent for every single use of CFC-113 or MCF is approved under SNAP?

    A: No. EPA is planning on reviewing only solvent substitutes in three key areas that use CFC-113 and MCF. Those three are industrial solvent cleaning, aerosols, and adhesives, coatings and inks. EPA is not planning to review substitutes for more minor uses of CFC-113 and MCF unless an environmental risk is expected to exist. Minor uses currently not subject to review include:

    1. Bearer media (for example, a substitute for CFC-113 in depositing lubricants on medical catheters)
    2. Hydraulic system testing
    3. Plasma etching
    4. Mold release agents (for nonaerosol applications)
    5. Film cleaning.

C. Acceptable Cleaning Substitutes under SNAP

  1. Q: Which cleaning substitutes for CFC-113 or MCF are approved under the SNAP program?

    A: EPA has already approved most solvent cleaning substitutes, including:

    1. Aqueous and semi-aqueous cleaners (including those based on terpenes or petroleum-based hydrocarbons)
    2. Non-ozone depleting chlorinated solvents (methylene chloride, trichloroethylene, perchloroethylene)
    3. Organic solvents used without water (terpenes, petroleum hydrocarbons, and oxygenated organic solvents such as esters, ethers, alcohols, etc.)
    4. Volatile methyl siloxanes (dodecamethyl-cyclohexasiloxane, hexamethyldisiloxane, octamethyltrisiloxane, decamethyl-tetrasiloxane)
    5. No-clean processes such as those used in manufacturing printed circuit boards
    6. Various hi-tech processes such as supercritical fluid cleaning, UV-ozone cleaning, plasma cleaning.

  2. Q: Does that mean that those substitutes are safe and that I can use them any way I want?

    A: No. If a chemical has other regulations that cover it, you still have to follow those regs. For example, if you use a substitute that is a VOC, you still have to follow whatever controls your state requires you to adopt.

  3. Q: Since perchloroethylene, methylene chloride and trichloroethylene ("perc", "meth" and "trike") are being approved under SNAP and they're not covered under the phaseout, can I use these chemicals any way I want?

    A: No. These chemicals are regulated under other laws for a number of reasons:

    1. Worker health: All three are considered toxic to human health. As a result, the Occupational Safety and Health Administration has set workplace standards for use of these chemicals. To find out about these standards, ask a distributor who sells these chemicals to show you the Materials Safety Data Sheet (MSDS). The MSDS will describe relevant workplace standards.
    2. Environmental releases of air toxics: The Clean Air Act lists these three chemicals due to their toxicity as Hazardous Air Pollutants (HAPs) under Title III. EPA has to develop Maximum Achievable Control Technology (MACT) standards for HAPs used in major industrial source categories. EPA is now working on a MACT for use of perc, meth, and trike in vapor degreasing. This MACT notice is due in November 1994.

    In addition, your state or local air board may have other regulations controlling emissions of these chemicals due to their toxicity.

    1. VOCs: Perc and trike are regulated under federal law (Title I of the Clean Air Act) as VOCs. Meth is exempt. EPA has been investigating exempting perc as well. However, you should check with your state or local air board to see if it has its own regs that control these chemicals as VOCs.
    2. Waste: All three are regulated as hazardous wastes under the federal Resource Conservation and Recovery Act (RCRA). Again, your state may have additional waste disposal requirements. This means that you may have to pay special fees to dispose of any spent solvent if you decide to use these chemicals.

  4. Q: How do I get more information on the MACT standard for vapor degreasing?

    A: You can call EPA's Office of Air Quality Planning and Standards (OAQPS). The name of the analyst working on this regulation is Paul Almodovar. His number is 919-541-0283.

  5. Q: And if I need more information on VOC regulations?

    A: Call David Cole at 919-541-5565 in OAQPS for general information on federal VOC standards. You should also contact your state EPA or local air board to find out the exact regulations for your community.

D. Cleaning Substitutes with Restrictions Under SNAP

  1. Q: Which solvent substitutes are restricted under SNAP?

    A: Two cleaning substitutes are subject to restrictions under SNAP. HCFC-141b is listed as unacceptable, and is banned for non-aerosol cleaning purposes. Perfluorocarbons are listed as "acceptable subject to narrowed use limits" and as a result are approved only for certain specialized uses. In addition, in the "pending" category, several other substitutes are discussed that are likely to be subject to restrictions once EPA issues the next round of SNAP listings.

  2. Q: I'm interested in HCFC-141b. How does the ban on use under SNAP work?

    A: Under SNAP, EPA has banned the use of 141b as a cleaning substitute in new cleaning equipment as of April 18, 1994 (including in retrofits made after the effective date of the rule) and in existing equipment as of January 1, 1996. "Existing equipment" means equipment that companies have shown a clear intention to use and have purchased before the effective date of the SNAP determination. The only exceptions to the ban, if any, will be for 141b as a CFC-113 substitute where users can demonstrate that no other substitute is technically feasible. EPA will not grant future exceptions for replacing MCF with 141b. Under this approach, 141b may not be used for cleaning basic metal parts or cleaning printed circuit boards, since many other substitutes are available for these applications.

    HCFC-141b is also included in the accelerated production phaseout regulations for ozone-depleting substances, and will be phased out of production by January 1, 2003.

    Furthermore, sales of most aerosol products containing HCFCs were prohibited after January 1, 1994 by regulations EPA developed under section 610(d) of the Clean Air Act (the Nonessential Products Ban).

    These restrictions are necessary because 141b has nearly the same ozone depletion potential as MCF, so there's little or no environmental benefit to switching from CFC-113 or MCF to 141b.

    If you want more information on HCFC-141b and its restrictions, you should contact EPA directly.

  3. Q: How does the ban on HCFC use in nonessential products under section 610(d) tie in with the SNAP restrictions?

    A: EPA issued the ban on HCFCs in nonessential products on December 30, 1993 (58 FR 69638) and it was effective on January 1, 1994. This regulation bans, among other things, use of HCFCs in aerosol products. However, section 610 authorizes EPA to grant exemptions from the ban based on lack of alternatives and concerns for flammability and worker safety. EPA has exempted the following products with HCFC solvent or propellants from the section 610(d) ban:

    1. Medical devices listed in 21 CFR 2.125(e)
    2. Lubricants, coatings or cleaning fluids for electrical or electronic equipment, which contain class II substances for solvent purposes, but which contain no other class II substances;
    3. Lubricants, coatings or cleaning fluids used for aircraft maintenance, which contain class II substances for solvent purposes but which contain no other class II substances;
    4. Mold release agents used in the production of plastic and elastomeric materials, which contain class II substances for solvent purposes but which contain no other class II substances, and/or mold release agents that contain HCFC-22 as a propellant where evidence of good faith efforts to secure alternatives indicates that, other than a class I substance, there are no suitable alternatives;
    5. Spinnerette lubricants/cleaning sprays used in the production of synthetic fibers, which contain class II substances for solvent purposes and/or contain class II substances for propellant purposes;
    6. Document preservation sprays which contain HCFC-141b as a solvent, but which contain no other class II substance; and/or which contain HCFC-22 as a propellant, but which contain no other class II substance and which are used solely on thick books, books with coated, dense or paper and tightly bound documents
    7. Wasp and hornet sprays for use near high-tension power lines that contain a class II substance for solvent purposes only, but which contain no other class II substances.

    For these aerosol applications, the SNAP program will not add further HCFC restrictions, since the exemptions are based on a determination that HCFCs are necessary.

    If you have further questions on the Nonessential Products Ban, you should request the related factsheet from the Stratospheric Ozone Protection Hotline at the number listed below.

  4. Q: I'm interested in perfluorocarbons. What's the SNAP policy on those?

    A: Under SNAP, perfluorocarbons (PFCs) are listed as "acceptable subject to narrowed use limits," and may only be used in electronics and precision cleaning for high-performance, precision-engineered applications where companies have made reasonable efforts to ascertain that other alternatives are not technically feasible due to performance or safety requirements.

    These restrictions are necessary because the perfluorocarbons have very long atmospheric lifetimes, and are potent greenhouse gases.

    Examples of the types of specialized parts that may need to be cleaned with PFCs are gyroscopes, direct access storage devices for computers, and electro-optical devices for weapons-targeting systems. Other examples of parts and equipment that may need to be cleaned with PFCs can be found in the SNAP regulation. The SNAP regulation also discusses characteristics of parts and equipment that may indicate the need for a PFC (unusually stringent particulate standards, highly complex geometric configurations, etc.) As with 141b, PFCs are not necessary for cleaning basic metal parts or most printed circuit boards, since many other substitutes are available.

  5. Q: If I want to use a perfluorocarbon, what do I have to do to prove that no other alternative is technically feasible? Do I have to fill out any forms?

    A: No. The goal of the SNAP listing is simply to make sure that you've adequately explored other alternatives before selecting a PFC. This means contacting actual vendors or even testing parts with other cleaning substitutes. Although you are not required to fill out any special forms or report your findings to EPA, you must keep the results of your findings on file for future reference. If you want more information on perfluorocarbons and their restrictions, you should contact EPA directly.

E. Substitutes Pending Review Under SNAP

  1. Q: Several cleaning substitutes are listed as "pending" under SNAP. Why is that?

    A: Certain substitutes were received too late for the Agency to review prior to the final rule. Others are likely to face restrictions under SNAP, and EPA will propose the restrictions later this year in a separate rulemaking for notice and comment.

  2. Q: What is dibromomethane and why is it a problem? I've never even heard of it.

    A: Dibromomethane is a component of a CFC-113/MCF substitute that was sold last year as an industrial cleaner. The concern with this chemical is that it has significant ozone-depleting potential--greater than methyl chloroform--yet it is not regulated under the Clean Air Act. At the same time, its toxicity--although poorly understood--is probably greater than that of methylene chloride. The SNAP program is likely to impose restrictions on use of this chemical until it gets added to the list of ozone-depleters and OSHA has adopted the necessary workplace standards.

  3. Q: What about monochlorotoluene and benzotrifluorides?

    A: These are chemicals that manufacturers are currently investigating for their cleaning properties. Their use in cleaning applications is relatively new, and EPA is still exploring what the chemicals' toxicity and exposure patterns are.

  4. Q: I'm interested in volatile methyl siloxanes (VMSs). Have those been approved?

    A: The SNAP regulation lists four of the VMSs as acceptable. Two more are listed as pending, since they have low company-set exposure limits that EPA plans to adopt as SNAP restrictions in the next round of SNAP determinations. Even though two of the VMSs are likely to face SNAP restrictions, EPA expects that users will be readily able to meet any SNAP conditions for use, since the VMSs that are subject to exposure standards are present in the cleaning formulations only in very small amounts.

  5. Q: The SNAP tables list an HFC as "pending." What's the status of HFCs? I didn't even know they were commercially available.

    A: HFCs are now being brought to market for commercial use and are already being tested in certain specialized applications. The HFC discussed in the SNAP table is still undergoing SNAP review, and it will also need to pass review under the Toxic Substances Control Act since it is a new chemical.

    HFCs are of interest not just for precision and electronics cleaning, but also for other targeted applications such as film cleaning and as a carrier solvent.

    In addition, since HFCs generally have much shorter lifetimes and global warming potential than PFCs, they are appealing prospective alternatives for cleaning applications where PFCs currently are the only viable substitutes.

  6. Q: I've also heard about a new HCFC, HCFC-225. It's on the pending list. Will it be approved?

    A: HCFC-225 is a relatively new chemical. It is actually a blend of two isomers, HCFC-225ca and HCFC-225cb. Although both isomers have some ozone depletion potential, the ODPs are relatively small. In addition, the atmospheric lifetimes are short--approximately 1.6 years for the ca isomer and 5.1 years for the cb isomer.

    The ca isomer has shown some adverse effects in toxicity tests, and it has a company-set exposure limit of 25 ppm. As a result, EPA plans to adopt the exposure limit as a condition for use in the next set of SNAP determinations. However, since HCFC-225 is sold as a blend of the ca isomer with the less toxic cb isomer, EPA expects that companies interested in this chemical will readily be able to meet the exposure limit for the ca isomer. Achieving the limit is also made more feasible by the fact that this chemical is of greatest interest for precision cleaning applications where high-performance cleaning equipment is the norm.

F. Labeling Requirements for Products Manufactured with Ozone-Depleting Solvents

  1. Q: I've heard that if you make a product with CFC-113 or 1,1,1, you have to label it. Is that true?

    A: Yes. As of May 15, 1993, any product made with a Class I substance (which includes CFC-113 and MCF) has to be labeled. The final regulation appeared in the Federal Register on February 11, 1993 (58 FR 8136).

  2. Q: Do the labeling requirements apply to products made with HCFCs?

    A: Yes, although for products made with HCFCs, the Agency has until January 1, 2015 to develop labeling requirements.

  3. Q: What is the label text?

    A: "Warning: Manufactured with [insert name of substance], a substance which harms public health and environment by destroying ozone in the upper atmosphere."

  4. Q: How can I get a copy of the labeling regulation?

    A: You can request it from the Stratospheric Ozone Protection Hotline. EPA also has a summary of the final regulation, which you can get from the Hotline as well.

G. How to Get Help Finding a Solvent Cleaning Substitute

  1. Q: How do I find out about substitutes for cleaning with methyl chloroform (1,1,1-trichloroethane) or CFC-113?

    A: EPA has written a series of manuals in cooperation with the Industry Cooperative on Ozone Layer Protection (ICOLP) that describe alternatives to cleaning with MCF and CFC-113. These manuals exist for:

    1. Metals cleaning
    2. Precision cleaning
    3. Electronics cleaning
    4. Aircraft maintenance cleaning
    5. No-clean processes for electronics assembly
    6. Reducing use of CFC-113 and MCF through conservation practices.

  2. Q: How can I get those manuals?

    A: You can request them from the Stratospheric Ozone Protection Hotline.

  3. Q: How do I find out who sells different solvent cleaning substitutes?

    A: EPA has lists of vendors selling substitutes for metals cleaning, electronics cleaning, and precision cleaning. You can request these lists from the Stratospheric Ozone Protection Hotline.

  4. Q: How can I make sure I'm not just buying another substitute that has MCF or CFC-113 in it?

    A: We also have a list of trade names of products with MCF and CFC-113 in them. You can request that from the Hotline, too.

For more information on Federal Regulations under the Stratospheric Ozone Protection Program, please call the Stratospheric Ozone Protection Hotline at 1-800-296-1996.


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Last Updated: January 16, 1996