DEEP DIVE: Stakeholders Agree There Are Issues with Proposed U.S. Regulation of N-Methylpyrrolidone but Disagree with Each Other

The U.S. Environmental Protection Agency (EPA) has received more than 50 comments from stakeholders offering their concerns and insight about a proposed regulation for n-methylpyrrolidone (NMP). The comment period closed at the end of July.

For some stakeholders, n-methylpyrrolidone (NMP) is a literal lifesaver: a component of Kevlar, the high-strength material that was first used commercially in the early 1970s as a replacement for steel in racing tires and more recently spun into the fabric of ballistic-resistant armor. The EPA’s 2020 NMP risk evaluation, however, determined the chemical poses threats to human health in reproduction, the liver and kidney, and immune and nervous systems. Some stakeholders argue that the risks of the chemical outweigh the benefits and take issue with an exemption for mission- or safety-critical uses.

The proposed regulation would require manufacturers to cap NMP concentration in products, expand labeling requirements for consumer products containing NMP, and impose container size limits. Additionally, the agency proposes an NMP workplace chemical protection program (WCPP), which would require companies to implement further measures for employees exposed to NMP, enforce use of personal protective equipment (PPE), and control concentration limits. There is a special focus on Direct Dermal Contact Control (DDCC), as research suggests NMP is most dangerous when it comes into contact with the skin.

“Our proposed commonsense worker protections would keep people safe while also ensuring that NMP could continue to be used, as needed,” said Michal Freedhoff, Assistant Administrator for the Office of Chemical Safety and Pollution Prevention. WCPP would go into effect one year after the rule is finalized.