Final Risk Evaluation for n-Methylpyrrolidone (NMP)
In December 2022, EPA released a final revised risk determination for n-methylpyrrolidone (NMP) as a whole chemical substance. This revision supersedes the previous condition of use-specific risk determinations in the 2020 NMP risk evaluation (and withdraws the associated order under TSCA section 6(i)(1)). These chemical-specific changes are in accordance with the path forward for the first 10 risk evaluations under TSCA laid out by EPA in June 2021.
The final revised risk determination does not assume that all workers exposed to NMP are protected by personal protective equipment (PPE). The consideration of this information will be part of the risk management process.
EPA determined that 29 out of the 37 conditions of use evaluated drive the determination that NMP presents an unreasonable risk of injury to human health under its conditions of use.
Read the Federal Register notice.
Read the revised NMP risk determination.
Read the Response to Public Comments to the draft revised Unreasonable Risk Determination for NMP.
On this page:
- Risk evaluation findings
- Next steps and public participation
- 2020 risk evaluation and supporting documents
On other pages:
- Read about the steps in EPA’s risk evaluation process for NMP.
- Learn more about EPA’s risk evaluation process.
Risk Evaluation Findings
In December 2022, EPA released a final revised risk determination for NMP. The final revised risk determination finds that NMP presents an unreasonable risk of injury to human health when evaluated under its conditions of use.
In the December 2020 risk evaluation, EPA reviewed the exposures and hazards of NMP uses and made risk findings on this chemical. This risk evaluation includes input from the public and peer reviewers as required by TSCA and associated regulations. EPA considered the hazards and exposure, magnitude of risk, exposed population, severity of the hazard, uncertainties, and other factors as part of its unreasonable risk determination.
EPA determined that NMP, as a whole chemical substance, presents unreasonable risk to human health.
EPA assessed the impact of NMP on workers, occupational non-users, consumers and bystanders. The primary health risks identified in the risk evaluation are developmental post-implantation fetal loss from short-term exposure and reduced fertility and fecundity from long-term exposure to the chemical. After reviewing these data, EPA determined that risk to workers for all occupational uses and to consumers from one consumer use of NMP drive the whole chemical determination of unreasonable risk of injury to health. Risk from 29 out of 37 conditions of use, including import, processing, commercial use, consumer use, and disposal, of NMP drive the whole chemical determination of unreasonable risk to health.
The revised risk determination for NMP does not reflect an assumption that workers always and appropriately wear personal protective equipment (PPE), even though some facilities might be using PPE as one means to reduce worker exposure, or that there is widespread non-compliance with applicable federal standards. EPA understands there could be occupational safety protections in place at some workplace locations; however, not assuming use of PPE in its baseline exposure scenarios reflects EPA’s recognition that certain subpopulations of workers exist that may be highly exposed because they are not covered by OSHA standards, because their employers are out of compliance with OSHA standards, because OSHA’s chemical-specific Permissible Exposure Limits (largely adopted in the 1970’s) are described by OSHA as being “outdated and inadequate for ensuring protection of worker health,” or because OSHA has not set a chemical-specific PEL, as is the case for NMP. The consideration of information on use of PPE, engineering controls, and other ways industry protects its workers, as potential ways to address unreasonable risk will be part of the risk management rule development process.
Next Steps and Public Participation
In June 2024, EPA proposed a risk management rule to address the unreasonable risk posed by n-methylpyrrolidone NMP to human health. Learn more and submit a comment.
EPA hosted a webinar on June 20, 2024, about the proposed risk management rule. View materials from the webinar.
Stay up to date on additional opportunities for public participation. Just like the risk evaluation process, there will be opportunities for public comment as EPA works to propose and finalize risk management actions for NMP. You can stay informed by signing up for our email alerts or checking the public docket at EPA-HQ-OPPT-2020-0744 at www.regulations.gov.
2020 Risk Evaluation and Supporting Files
Below are the final revised risk determination, 2020 risk evaluation for NMP, non-technical summary, response to comments, and other supporting documents.
The discussion of the issues in the final revision to the risk determination supersedes any conflicting statements in the 2020 NMP risk evaluation and the response to comments document.
Read the Federal Register notice.
- Final Revised Unreasonable Risk Determination for n-Methylpyrrolidone (NMP), December 2022 (pdf)
- Non-Technical Summary of n-Methylpyrrolidone, December 2022 (pdf)
- Response to Public Comments, NMP Revised Unreasonable Risk Determination, December 2022 (pdf)
- Risk Evaluation for n-Methylpyrrolidone, December 2020 (pdf)
- Summary of External Peer Review and Public Comments and Disposition for n-Methylpyrrolidone, December 2020 (pdf)
- Supplemental File on Occupational Risk Calculations, December 2020 (xlsx)
- NMP Rat PBPK Model Code Inputs and Outputs, December 2020 (zip)
- Please Note: The PBPK Model zip folders ("NMP Human PBPK Model Code Inputs and Outputs" and "NMP Rat PBPK Model Code Inputs and Outputs") contain several file types (.m, .aps, .ape, .ail, .csl, .dll, .obj, .cpp, .csi) associated with ASCLX software. The PBPK model equations are defined in the .csl files. The .m files set inputs to the model, including model parameters and exposure conditions, produce plots comparing model predictions to ADME data, and calculate internal dose metrics corresponding to animal bioassays or human exposure scenarios. Both .csl and .m files can be viewed in any text editor. Model inputs and outputs, in particular for human exposure scenarios, are in .csv and .xls files that can be viewed in Excel or Google Spreadsheets.
- Final Risk Evaluation for n-Methylpyrrolidone Systematic Review Supplemental File: Data Quality Evaluation of Environmental Fate and Transport Studies, December 2020 (pdf)
- Final Risk Evaluation for n-Methylpyrrolidone Systematic Review Supplemental File: Data Quality Evaluation of Physical and Chemical Properties Studies, December 2020 (pdf)
- Final Risk Evaluation for n-Methylpyrrolidone Systematic Review Supplemental File: Data Quality Evaluation of Environmental Release and Occupational Exposure Data, December 2020 (pdf)
- Final Risk Evaluation for n-Methylpyrrolidone Systematic Review Supplemental File: Data Quality Evaluation of Environmental Release and Occupational Exposure - Common Sources, December 2020 (pdf)
- Final Risk Evaluation for n-Methylpyrrolidone Systematic Review Supplemental File: Data Quality Evaluation of Consumer and General Population Exposure Studies, December 2020 (pdf)
- Final Risk Evaluation for n-Methylpyrrolidone Systematic Review Supplemental File: Data Quality Evaluation of Ecological Hazard Studies, December 2020 (pdf)
- Final Risk Evaluation for n-Methylpyrrolidone Systematic Review Supplemental File: Data Quality Evaluation of Human Health Hazard Studies – Animal and In Vitro Studies, December 2020 (pdf)
- Final Risk Evaluation for n-Methylpyrrolidone Systematic Review Supplemental File: Data Quality Evaluation of Human Health Hazard Studies - Epidemiological Studies, December 2020 (pdf)
- Final Risk Evaluation for n-Methylpyrrolidone Systematic Review Supplemental File: Updates to the Data Quality Criteria for Epidemiological Studies, December 2020 (pdf)
- Final Risk Evaluation for n-Methylpyrrolidone Systematic Review Supplemental File: Data Extraction of Epidemiological Studies, December 2020 (pdf)
- Final Risk Evaluation for n-Methylpyrrolidone Supplemental Information on Occupational Exposure Assessment, December 2020 (pdf)
- Final Risk Evaluation for n-Methylpyrrolidone Supplemental Information on Consumer Exposure Assessment, December 2020 (pdf)
- Final Risk Evaluation for n-Methylpyrrolidone Benchmark Dose Modeling Supplemental File, December 2020 (pdf)
- Final Risk Evaluation for n-Methylpyrrolidone Supplemental PBPK Model Code, December 2020 (pdf)