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ECSA position on the use of Methylene Chloride in paint removers

November 2002 - Following discussions with Member States and stakeholders througout 2002, DG Enterprise revised their original proposal for an amendment to Annex 1 of Directive 76/769/EEC to restrict the marketing of dichloromethane (DCM, methylene chloride) for use in paint removers as follows:

Dichloromethane [CAS No. 75-09-2]:

1. May not be placed on the market or used as a substance or constituent of preparations in a concentration equal or higher than 1.0% by mass in products used in the cleaning of facades;
2. May not be placed on the market or used as a substance or constituent of preparations in a concentration equal or higher than 1.0% by mass in paint strippers.

Paragraph 2 shall not apply to preparations used for:

• Immersion baths;
• Stripping coating systems built of stoving, XR- or UV-curing or multi-pack reactive coatings;
• Disolving bindings built of reactive curing organic adhesives.

Paragraphs 1 and 2 shall not apply to preparations:

• Supplied in containers of a capacity not greater than 1,000 ml intended for profesional uses;
• Formulated so that the loss by evaporation is not more than 3% by weight of the loss by evaporation for pure dichloromethane;
• Intended for industrial use in controlled closed systems;
• Intended for applications where breathing apparatus with separate air supply is used.

ECSA maintains the view expressed in the early stages of this debate, that there are sufficient regulations already covering occupational use of dichloromethane in the workplace, and that there are no reasons for marketing restrictions on the product for professional use.

ECSA also believes that there are insufficient grounds for restrictions on consumer sales of dichloromethane-based paint removers. Quantities used by the consumer are minimal, and there is little evidence from surveys of Poison Centres across Europe that the substance is of concern in this application. Those events which give rise to concern are mostly where adjunct substances are included with the formulatoin, especially hydrofluoric acid, phenol and chloroacetic acids, which are used primarily by industry rather than consumers.

ECSA sees no clear reason for any restrictions on DCM paint removers. However, it is aware of concerns regarding the small number of fatalities caused by misuse of the substance in this application, and believes that through product stewardship and Responsible Care, efforts may be needed to minimise these incidents.

ECSA supports the proposal as it stands and accepts the continued possibility of use of vapour retarded products which will limit the risk to occupational and consumer users of DCM-based paint removers by minimising the exposure to DCM, maximising the efficiency of paint removal, and reducing the quantities required for the work. Where unformulated product is necessary, then we accept limitation to professional use in limited quantities.

Paint removal will still need to be carried out by the general public, and we do not believe that the alternative chemicals and processes have been sufficiently evaluated for the risks they may present.

ECSA believes that methylene chloride represents the best available paint remover, based on health and environmental factors and on socio-economic considerations, if properly formulated to suppress vapourisation, handled appropriately and used with adequate ventilation. DCM has the following valuable benefits in this application:

• Fast-acting paint removal in 1-3 hours;
• Effective stripping of multiple layers and easy to use;
• Low odour;
• Low cost;
• Safe - no health risks or flammability concerns;
• Causes no substrate damage.

There is evidence from regions of the EU where restrictions on DCM are already in place, that in order to provide alternative systems with the rapidity of action of DCM, flammable and abusable solvents are added. Formulators are concerned that minimal risks to the consumer from use of DCM will be significantly increased through Volatile Substance Abuse incidents from replacement paint removers. Deaths from Volatile Substance Abuse in the UK are around 70 per year. Encouraging further products onto the consumer shelves is felt to be unacceptable against this background, and not what a responsible industry wishes to see.

Conclusion

• ECSA does not believe that any restrictions are required on dichloromethane paint strippers;
• ECSA accepts the Commission proposal in the spirit of Responsible Care and Product Stewardship;
• ECSA would welcome a thorough review of the paint stripping application covering all processes and products.

Update