The US Environmental Protection Agency has released draft Toxic Substances Control Act risk evaluations for seven chemicals, covering a wide range of industrial and consumer applications.
The chemicals assessed include ethylene dibromide, ortho-dichlorobenzene, para-dichlorobenzene, trans-1,2-dichloroethylene, tetrabromobisphenol A, 1,1,2-trichloroethane, and 1,2-dichloropropane.
EPA’s Office of Chemical Safety and Pollution Prevention preliminarily concluded that each of the seven chemicals presents an unreasonable risk to human health under at least some conditions of use.
Six of the seven chemicals are solvents or used in solvent-related applications, with tetrabromobisphenol A standing alone as a flame retardant widely used in electronics, plastics, and construction materials.
Tetrabromobisphenol A is also the only chemical among the seven for which EPA identified unreasonable risk to the environment, in addition to the human health findings.
Three chemicals, ethylene dibromide, 1,1,2-trichloroethane, and 1,2-dichloropropane, received findings that cancer risk materially drives the unreasonable risk determination.
1,2-dichloropropane carries the broadest consumer risk finding in the group, with all three of its consumer conditions of use contributing to EPA’s preliminary determination of unreasonable risk.
Across the seven evaluations, EPA continues to focus heavily on workplace inhalation exposures, particularly for solvent uses where worker and occupational non-user populations face the greatest risk.
Once the public comment periods close, EPA will issue final risk evaluations, and if unreasonable risk is confirmed, the agency is required by statute to initiate risk management rulemaking under TSCA Section 6(a).
Potential risk management measures could include restrictions on manufacture, processing, distribution, use, disposal, or workplace practices, creating significant compliance obligations across multiple industries.
The industries potentially affected extend well beyond chemical manufacturers and importers, touching electronics companies, semiconductor firms, aviation fuel stakeholders, adhesive formulators, and cleaning product manufacturers.
Downstream users, distributors, and companies whose products rely on affected chemical supply chains may ultimately feel the regulatory impact as much as the manufacturers themselves.
Comment deadlines vary by chemical, with current opportunities remaining open through September 28 for 1,1,2-trichloroethane, October 9 for both ortho-dichlorobenzene and para-dichlorobenzene, October 19 for ethylene dibromide, October 26 for trans-1,2-dichloroethylene, and November 3 for 1,2-dichloropropane.
Companies are being urged to engage with EPA now by providing real-world information on use patterns, workplace practices, exposure data, engineering controls, and personal protective equipment before final evaluations are issued.
EPA’s unreasonable risk findings can also raise broader questions regarding business planning, customer communications, ESG disclosures, transactional diligence, and investor scrutiny beyond the immediate regulatory concerns.