Trichloroethylene (TCE) is a volatile organic compound widely used across industrial and commercial sectors, including metal degreasing, chemical manufacturing, and specialized laboratory applications. While TCE has been indispensable in these processes, decades of research have confirmed its significant health risks, including liver cancer, kidney cancer, non-Hodgkin’s lymphoma, and adverse effects on the central nervous system, reproductive organs, immune system, and kidneys.
In response, the U.S. Environmental Protection Agency (EPA) has implemented a series of regulatory actions under the Toxic Substances Control Act (TSCA) to reduce exposure and protect public health. The following blog provides a comprehensive, chronological overview of EPA’s TCE risk management rule, including compliance dates, phased prohibitions, and public participation.
Early Risk Evaluation and Regulatory Framework
December 2024: Final Risk Management Rule
i. The EPA completed a risk evaluation of TCE and identified unreasonable risks associated with its use across multiple sectors.
ii. The final risk management rule under TSCA Section 6 prohibits most uses of TCE, focusing on both human health and environmental protection.
iii. The rule includes:
a. Prohibition of TCE in consumer products.
b. Limits on industrial uses where safer alternatives are readily available.
c. Phased transitions for uses critical to national security, energy, and defense.
Key Goals
i. Protect workers, consumers, and the public from TCE exposure.
ii. Reduce environmental contamination, particularly in wastewater and soil.
iii. Promote safer alternatives through a phased implementation approach.
2025: Interim Final Rule and Compliance Extensions
September 12, 2025: Interim Final Rule Issued
a. The EPA published an interim final rule extending certain compliance dates for TCE uses.
b. This step responds to stakeholder feedback and ensures industries with critical processes have sufficient time to transition away from TCE use.
Compliance Date Extensions
Downstream Notifications
Manufacturers, processors, and distributors have 90 days from the publication date to update downstream notification requirements.
Wastewater Disposal
i. Prohibition on discharging TCE-containing wastewater extended to December 18, 2026.
ii. Aligns disposal rules with phased use prohibitions.
Nuclear Fuel Manufacturing
i. TCE use as a processing aid now prohibited starting September 15, 2028, instead of the original September 15, 2025.
ii. This accounts for national security and critical energy infrastructure needs.
Enforcement Guidance
1. Current deadlines remain in effect until formally modified.
2. Enforcement of existing deadlines is considered a low priority but may occur to protect human health or the environment.
3. The Assistant Administrator for the Office of Enforcement and Compliance Assurance must approve any enforcement actions under these new provisions.
2025–2028: Phased Out Industrial Uses
Certain industrial applications of TCE receive extended timelines to maintain continuity in critical sectors, while ensuring worker safety and minimizing environmental impact.
Applications with Extended Phaseout
a. Aircraft and Medical Device Manufacturing: Cleaning parts with TCE is phased out with compliance by 2028.
b. Battery Separator Production: Extended timeline to adopt safer cleaning methods.
c. Refrigerant Manufacturing: Aligns with climate legislation and TSCA restrictions.
d. Defense and Security Systems:
Critical infrastructure uses permitted under strict worker protection plans.
Worker Safety Measures
i. Inhalation Exposure Limits: Reduce exposure by 97% in extended-use facilities.
ii. Workplace Chemical Protection Plans: Mandatory for industrial users continuing TCE applications.
iii. Monitoring: Real-time exposure measurement and regular audits ensure compliance.
TCE in Consumer Products
TCE has historically been found in:
a. Cleaning agents.
b. Arts and crafts spray coatings.
c. Automotive products (brake cleaners, degreasers).
d. Furniture care products.
Prohibitions and Alternatives
i. The TSCA rule prohibits most TCE-containing consumer products within one year of rule issuance (effectively late 2025).
ii. Consumers are encouraged to use non-toxic, environmentally friendly alternatives.
iii. Public education programs guide safe disposal of remaining TCE-containing products.
Environmental Impact and Waste Management
TCE contamination poses risks to soil, groundwater, and air quality. The EPA emphasizes proper disposal and cleanup, especially in industrial settings.
Waste Disposal Rules
a. Industrial Wastewater: Discharge prohibited after December 18, 2026.
b. Site Cleanup: Long-term remediation allowed for Superfund and other contaminated sites under strict exposure controls.
c. Laboratory Exemptions: Essential laboratory uses permitted under controlled conditions for up to 50 years.
Research, Innovation, and Alternatives
Industries are encouraged to adopt safer substitutes for TCE, including:
i. Aqueous-based cleaners.
ii. Non-chlorinated solvents.
iii. Mechanical and green chemistry solutions.
Benefits
a. Reduced cancer and organ toxicity risk.
b. Lower environmental footprint.
c. Compliance with strict TSCA safety standards.
Public Participation and Stakeholder Engagement
EPA’s regulatory process emphasizes public involvement to ensure practical, protective rules.
Opportunities for Engagement
a. 30-Day Comment Period: Stakeholders can submit feedback on interim final rule and compliance dates.
b. Dockets and Federal Register: Formal channels for submitting written comments.
c. Outreach Events: Workshops and webinars educate industries and communities about TCE regulations.
The EPA’s updated TCE risk management rules reflect a careful balance between public health protection and industrial practicality. By providing phased compliance timelines, extending critical deadlines, and enforcing rigorous worker safety measures, the agency ensures minimal disruption to essential services while substantially reducing health risks.
Businesses, laboratories, and consumers must remain informed, adhere to updated deadlines, and transition to safer alternatives. The combination of strict regulatory oversight, stakeholder engagement, and public education ensures a sustainable path forward in managing TCE risks.
References:
1. EPA Interim Final Rule on TCE Compliance Date Extensions
2. EPA Risk Management for TCE
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