EPA Adds 1-BP to Clean Air Act Hazardous Air Pollutants List
EPA has added 1-bromopropane (1-BP), aka n-propyl bromide, to its list of hazardous air pollutants under the Clean Air Act.
EPA has added 1-bromopropane (1-BP), aka n-propyl bromide, to its list of hazardous air pollutants under the Clean Air Act. This is the first time since 1990 that EPA has added a chemical to the list from a petition request. The CAS number for 1-BP is 106-94-5.
⚡ TL;DR: EPA added 1-BP to the hazardous air pollutants list—the first chemical addition since 1990. This affects SARA 313, air permits, and EPCRA reporting obligations for facilities using the chemical.
How is 1-BP Used?
1-BP is found in products for the following applications: Adhesive sprays Solvent sprays for asphalt production, aircraft maintenance, and synthetic fiber manufacturing Vapor and immersion degreasers for cleaning plastics, metals, electronic components and optical components Dry cleaning Spot removers Coin cleaners Paintable mold release products Automotive refrigerant flushes Lubricants
⚠️ What’s at stake: Facilities using 1-BP without proper controls face EPA enforcement penalties ranging from $25,000 to $40,000+ per day of violation. Chemical-related hazard violations can result in multi-million-dollar settlements and operational shutdowns.
Which EPA Compliance Obligations Will This Affect?
Since the change is part of the Clean Air Act, you will need to take note that this will affect the following EPA reports and permits: SARA 313, Form R Toxic Release Inventory Air Emissions Permits EPCRA Tier II Report You should also now start tracking the quantities purchased and used to help you with these reports.
What is the Hazard?
1-BP can be inhaled as a vapor or mists of spray and can also be absorbed through skin contact. It is colorless with a sweet odor. It can cause irritation of the eyes, nose and throat, and can damage the nervous system. Women of childbearing age are cautioned that prolonged exposure can cause developmental and reproductive effects. Extreme cases can cause kidney and liver issues as well as neurological issues such as dizziness, loss of consciousness, slurred speech, confusion, twitching and difficulty walking. Some people have experienced symptoms with use as little as 2 days, but most cases have effects after long-term exposure.
Make Sure You Know Your Exposures
If your company is using products with 1-BP, please make sure you are conducting industrial hygiene sampling of your employees and their usage of 1-BP to identify what their exposures are. The American Conference of Governmental Industrial Hygienist’s (ACGIH) threshold limit value for 1-BP is a very low 0.1 ppm, so any exposures over that will require respiratory protection. iSi has conducted 1-BP sampling for two of our clients within the past year. Each were using vapor degreasers with 1-BP in them. Exposures measured at 3.74 ppm for one company and 49.5 ppm for another. These were very well above the recommended 0.1 ppm and each company needed to change protocols to get the exposures down.
PPE and Administrative Controls
Besides respiratory protection when limits are over the thresholds, both EPA and OSHA recommend usage of chemical protective gloves/clothing and eye protection when handling 1-BP. OSHA has specific recommendations for eliminating the hazard altogether through isolation, ventilation and other engineering controls. Some administrative controls they recommend include reducing both the time and number of workers exposed to the chemical, purchasing and storing the least amount possible and keeping containers closed between use. Because of the hazard, there are other products now on the market that can be used for the same functions that do not have 1-BP in them.
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💰 The cost of non-compliance: EPA penalties for 1-BP violations range from $25,000 to $40,000+ per day. A single multi-day enforcement action at a manufacturing facility easily exceeds $500,000 in penalties, not counting remediation, legal fees, and operational disruption.
Frequently Asked Questions
Q: What is 1-bromopropane (1-BP) and why did EPA add it to the hazardous air pollutants list?
1-Bromopropane (1-BP, n-propyl bromide, CAS 106-94-5) is a volatile solvent used in adhesive sprays, degreasers, dry cleaning, and electronics manufacturing. EPA added 1-BP to the Clean Air Act hazardous air pollutants list in response to a petition request—the first such addition since 1990. The chemical is absorbed through inhalation and skin contact, causing eye, nose, and throat irritation and potentially damaging the nervous system, kidneys, and liver with prolonged exposure. Women of childbearing age face particular risk for developmental and reproductive effects. iSi Environmental helps facilities identify 1-BP use and assess occupational exposure risks.
Q: Which EPA compliance obligations are triggered by 1-BP being listed as a hazardous air pollutant?
Companies using 1-BP must now track and report quantities in SARA 313 Form R Toxic Release Inventory reports if they exceed reporting thresholds (typically 10,000 pounds). Air emissions permits must be updated to include 1-BP emissions. EPCRA Tier II chemical inventory reports must include 1-BP if quantities exceed thresholds. Facilities must begin documenting purchases and usage of 1-BP for regulatory reporting. Companies should review their air permits and emissions inventory to determine if 1-BP listings are needed. iSi Environmental helps facilities understand reporting obligations for 1-BP and other hazardous air pollutants.
Q: What is the ACGIH occupational exposure limit for 1-BP?
The American Conference of Governmental Industrial Hygienists (ACGIH) threshold limit value (TLV) for 1-BP is 0.1 ppm—an extremely low occupational exposure limit. OSHA’s occupational exposure limit for 1-BP is 10 ppm, but the ACGIH value of 0.1 ppm is considered the more protective health standard for occupational hygiene purposes. Exposures above 0.1 ppm require respiratory protection and engineering controls. iSi Environmental has documented 1-BP exposures as high as 49.5 ppm in degreasing operations, far exceeding safe limits. Facilities using 1-BP must conduct air sampling to quantify employee exposures.
Q: What controls must facilities implement for 1-BP to comply with OSHA and EPA requirements?
OSHA’s hierarchy of controls recommends eliminating 1-BP use by substituting non-1-BP products that perform the same function. If 1-BP cannot be eliminated, engineering controls (isolation, ventilation systems) should reduce exposure. When engineering controls are insufficient, respiratory protection is required. Administrative controls include reducing worker time and numbers exposed, minimizing quantities purchased and stored, and keeping containers sealed except during use. Personal protective equipment includes chemical-resistant gloves, protective clothing, and eye protection. iSi Environmental helps facilities implement 1-BP controls and conducts occupational exposure monitoring.
Every satisfactory compliance program starts with knowing where the gaps are. iSi Environmental helps industrial and manufacturing facilities understand their regulatory obligations and close operational vulnerabilities before they become penalties.
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