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 name | Examples of uses | Examples of hazards |
| 1,4-dioxane | Dyes, 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 |
| Asbestos | Insulation, brake pads, chlor-alkali industry | Known human carcinogen; acute and chronic toxicity from inhalation exposures |
| Carbon tetrachloride | Chemical 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 29 | Dye 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