Off and running: EPA identifies first 10 chemical for review under new TSCA

Richard Denison, Ph.D.is a Lead Senior Scientist.  Lindsay McCormick and Jennifer McPartland contributed to this post.

Today, in advance of the December 19, 2016 deadline specified under the new TSCA, EPA has announced the first 10 chemicals to undergo risk evaluations (see list below).

This is a very important early step called for under the Lautenberg Act, which passed Congress with overwhelming bipartisan support.  Early action by EPA was seen by stakeholders across the spectrum as essential to begin the process of restoring public and market confidence in our nation’s chemical safety system.  So EPA’s issuance of this list in advance of the statutory deadline next month is a welcome sign of timely implementation of the new law.

While not every chemical that everyone may have wanted is included among the first 10, that is because there are many more than 10 chemicals that need far greater scrutiny as to their safety.  Indeed, the longer “Work Plan Chemicals” list from which EPA drew the first 10 consists of nearly 100 chemicals that present significant potential risk.

What is most important is that EPA gets started, so that it can complete risk evaluations of the first 10 and move on to the next.  EPA now has 6 months to establish the scope of its risk evaluations for these chemicals, identifying the uses, hazards, exposure and vulnerable populations it will evaluate.  

The 10 chemicals EPA has identified clearly warrant scrutiny, as there is significant evidence both that they pose hazards to health and the environment and that exposure to them is likely or actually occurring.  For three of the 10 chemicals – TCE, methylene chloride, and NMP – EPA previously completed risk assessments for narrow uses of them.  Those assessments identified very high risks to workers and consumers from those uses, and EPA has proposed restrictions on them that are pending in OMB review (see here, here and here).  EPA’s inclusion of these three chemicals on the first-10 list indicates it intends to examine a broader range of their uses and potential exposures going forward, which is called for under the new law.

Below are the first 10 chemicals and examples of their uses and hazards.  We’ll have more information on these chemicals going forward.

Chemical nameExamples of usesExamples of hazards
1,4-dioxaneDyes, varnishes, waxes, impurity in some industrial and consumer products

Possible human carcinogen
1-bromopropane
(aka n-propyl bromide
or nPB)
Vapor degreasing, aerosol adhesives, foam cushions, dry cleaning

Possible human carcinogen
AsbestosInsulation, brake pads, chlor-alkali industryKnown human carcinogen; acute and chronic toxicity from inhalation exposures

Carbon tetrachlorideChemical intermediate, solvent

Probable human carcinogen
HBCD (hexabromo
cyclododecane)*
Flame retardant used in foam, electronics

Acute aquatic toxicity
Methylene chloride
(aka dichloromethane
or DCM)**
Paint and coating-removal products,
automotive products, spray paint, adhesives

Probable human carcinogen
N-methyl pyrrolidone
(NMP)**
Paint and coating-removal products,
cleaning agent, chemical intermediate

Reproductive toxicity
Pigment Violet 29Dye used in automotive and other coatings
and plastics

Aquatic toxicity
Trichloroethylene
(TCE)**
Dry cleaning, consumer, commercial, and industrial degreasers

Known human carcinogen
Tetrachloroethylene
(aka “Perc”)
Dry cleaning, metals degreasing, spot
removers, wood cleaners,
shoe polish

Probable human carcinogen

*   as part of cyclic aliphatic bromides cluster of flame retardants
** additional uses  and exposures beyond those in first risk assessments

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