Do you use hydrochloric acid?

By CMTA Staff

Capitol Update, Aug. 6, 2009 Share this on FacebookTweet thisEmail this to a friend

California’s Department of Toxic Substance Control (DTSC) has taken the position with a manufacturer, Accu Chem Conversion, Inc., that aqueous hydrochloric acid (HCl) falls under their California Accidental Release Prevention (Cal-ARP) regulations even with concentrations less than 37 percent.  If this position is allowed to stand, it would have broad application for a large variety of manufacturers, distributors and retailers across the state.

HCl in such low concentration is commonly used for such diverse applications as: pH (potential of hydrogen) control and neutralization in chemical manufacturing, air pollution control equipment, food processing, pharmaceuticals, drinking water, waste water treatment, swimming pools, regeneration of ion exchange resins, pickling steel to remove rust or iron oxide scale before extrusion, rolling , galvanizing and chemical milling, household cleaning, building construction, process equipment cleaning, and down hole treatment in oil production.

Following an appeal by the manufacturer, the California Emergency Management Agency (formerly the Office of Emergency Services) is soliciting public comment.  CMTA joined with a number of other associations requesting an extension that has since been granted.  The new deadline is September 30th.  

A copy of the hearing officer’s decision and Accu Chem’s rebuttal may be found at  

To date, many users of aqueous HCl solutions have not registered their solution process areas pursuant to Cal-ARP because they interpret the regulated list to mean that Hydrogen Chloride (gas) refers to anhydrous HCl.  This is consistent with the Federal Risk Management Plan (RMP) regulation which specifically regulates aqueous HCl at concentrations greater than or equal to 37 percent (a 15,000 pound threshold) as well as anhydrous hydrogen chloride (5000 pound threshold).

This new interpretation would not only open up regulation of aqueous HCl users that are not currently regulated, but would unnecessarily also open process areas to scrutiny during external audits and require significantly more attention to ensure compliance.

CMTA is joining an ad hoc group to further identify potentially affected parties, issues and drafting comments.  If you or someone in your company with technical and regulatory expertise wish to assist, please contact Mike Rogge at
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