The U.S. Environmental Protection Agency (“EPA”) has recently made a proposal to prohibit most industrial and commercial uses of perchloroethylene (“PCE”). This regulation would also disallow manufacturing, processing, and distribution of PCE for all consumer uses. PCE is a chlorinated solvent widely used across various industries, including automotive and manufacturing. The impact of this prospective regulation on manufacturing sectors, particularly automotive, is considerable.
PCE, a volatile organic compound, has been in widespread use due to its degreasing properties. This transition is proposed to be implemented in two major phases. To begin with, most uses of PCE would be phased out in two years. This initial phase primarily targets non-essential applications in the manufacturing world.
However, some PCE applications have been considered too critical to be phased out immediately. A notable example is PCE’s use in dry cleaning. The proposed regulation calls for a slower phaseout of this application, spanning across a period of ten years. This extended timeline acknowledges the complexities involved in identifying and adopting alternatives in certain sectors.
Legal professionals working within manufacturing and automotive sectors should play close attention to this development. It is crucial to develop strategies to anticipate and adapt to these changes. Among the challenges to be addressed are the identification of suitable substitutes for PCE, modifications to manufacturing processes, and potential impacts on product quality or performance.
As ever, the regulatory environment continues to evolve in unforeseen ways, revealing the urgent need for legal counsel to stay updated and responsive to these shifts. For more details on the proposed regulation by the EPA, the original report can be accessed here.