This week, the Environmental Protection Agency (EPA) published their final rules to ban and/or restrict the use of trichloroethylene, perchloroethylene, and carbon tetrachloride under the 2016 Toxic Substances Control Act (TSCA) amendments. As discussed in our May 3, 2024 blog, most uses of methylene chloride were also banned earlier this year to protect both worker and consumer health and safety.
This blog provides a summary of the most recent information on the EPA prohibitions for carbon tetrachloride, perchloroethylene, and trichloroethylene.
Carbon Tetrachloride (CTC)
CTC is a solvent used in commercial applications as a raw material for producing other chemicals such as those used in refrigerants, aerosol propellants, foam-blowing agents, and vinyl chloride. The U.S. Consumer Product Safety Commission banned the use of CTC in consumer products in 1970. In addition, requirements under the Montreal Protocol on Substances that Deplete the Ozone Layer and the Clean Air Act phased out CTC production in the United States in 1996 for most domestic uses that did not involve manufacturing other chemicals.
Per the EPA, CTC is known to be cancerous and toxic to the liver and can also cause brain and adrenal gland tumors. Because the EPA determined that CTC posed an unreasonable risk to human health, additional restrictions on its commercial use are now required as summarized below.
- Bans were placed on uses of CTC that have already been phased out, including its use in metal recovery and as an additive in fuel and plastic components used in the automotive industry.
- Uses of CTC allowed to continue include as a laboratory chemical, in the processing of vinyl chloride, and for producing hydrofluoroolefin refrigerants which are replacements for climate-damaging hydrocarbons.
- Where CTC use can continue, measures must be put in place to ensure workers are protected. These include, but are not limited to implementing a Workplace Chemical Protection Program as discussed in a recent methylene chloride ban requirements blog. In addition, companies must comply with EPA’s existing chemical exposure limit (ECEL) of 0.03 ppm as an 8-hour time weighted average (OSHA’s permissible exposure limit (PEL) is 10 ppm).
Perchloroethylene (PCE or PERC)
PCE is a solvent that is widely used in consumer products such as for brake cleaners and adhesives, in commercial applications such as dry cleaning, and in many industrial settings. For example, PCE is a chemical intermediate in the production of refrigerants and a process aid at petroleum refineries. Per the EPA, safer alternatives are readily available for the majority of these purposes.
PCE is known to cause liver, kidney, brain, and testicular cancer. In addition, it’s been associated with damage to the kidneys, liver and immune system, neurotoxicity, and reproductive toxicity. Under the final rule, EPA has restricted the use of PCE as described below.
- Bans were placed on the manufacture, processing, and distribution of PCE in commerce for all consumer and many commercial uses; if the ban did not apply, PERC still must be phased out of most processes in less than 3 years.
- A 10-year phaseout for the use of PCE in dry cleaning is required to reduce worker exposure in those facilities. For newly acquired dry cleaning machines, the ban begins at 6 months and for newer machines, 10 months or less.
- When PCE is allowed to be used, for example as a laboratory chemical, degreasing solvent, adhesive, sealant, and in chemical manufacturing, engineering and other hazard controls must be implemented.
- For companies that can continue to use PCE, a Workplace Chemical Protection Program and an EPA ECEL of 0.14 ppm as an 8-hour time-weighted average (OSHA’s PEL is 50 ppm), must be established.
Trichloroethylene (TCE)
TCE is used as a solvent in consumer and commercial products such as cleaning and furniture care products, degreasers, brake cleaners, sealants, lubricants, adhesives, paints, and coatings; it’s also used in the manufacture of some refrigerants. According to the EPA, safer alternatives are readily available for the majority of these applications.
Based on information from the EPA, TCE is an extremely toxic chemical known to cause liver and kidney cancer and non-Hodgkin’s lymphoma. TCE also causes damage to the central nervous system, liver, kidneys, immune system, reproductive organs, as well as fetal heart defects. These risks are present even at very small concentrations.
Details on the EPA’s TCE use restrictions are listed here.
- TCE manufacturing and processing for most commercial and consumer products and the majority of other practices were prohibited within one year. Eventually all uses of TCE will be banned.
- A limited number of workplace applications will be phased out over a longer period; mostly in highly industrialized settings such as aircraft and medical device parts cleaning, and battery separator and refrigerant manufacturing.
- Laboratory use is permitted to support the cleanup activities at sites of past TCE contamination (e.g., Superfund sites). EPA is allowing essential laboratory use to continue for 50 years.
- For applications that weren’t immediately banned, compliance with a Workplace Chemical Protection Program and an EPA ECEL of 0.2 ppm (OSHA’s PEL is 100 ppm) is required.
For additional information on the recent EPA chemical bans or help ensuring that chemical use at your facility is compliant, please contact us.
This blog was written by Beth Graham, Safety Partners’ Director of Quality, Research, and Training
