EPA Issues Draft TSCA Risk Evaluations for Seven Chemicals; All Show Preliminary Human-Health Risks

# What happened The U.S. Environmental Protection Agency's Office of Chemical Safety and Pollution Prevention released draft Toxic Substances Control Act (TSCA) risk evaluations for seven chemicals between June and August. EPA preliminarily concluded that each chemical presents an unreasonable risk to human health under at least some conditions of use (COUs). The set includes six solvents or solvent-related substances and one flame retardant.

# Which chemicals are involved

• Ethylene dibromide (EDB): lead scavenger in leaded aviation fuel (avgas). EPA found cancer risk drives the unreasonable-risk determination.
• Ortho-dichlorobenzene (o-DCB): solvent, intermediate, cleaning product ingredient. Peer reviewed by SACC in June.
• Para-dichlorobenzene (p-DCB): used in air fresheners, solvents, and laboratory chemicals. Peer reviewed by SACC in June.
• Trans-1,2-dichloroethylene (t-DCE): solvent used in cleaning, degreasing, adhesives, semiconductor manufacturing.
• Tetrabromobisphenol A (TBBPA): flame retardant in electronics, plastics, construction materials. EPA found unreasonable risk to the environment for one COU and to human health for three COUs.

# How EPA reached these preliminary conclusions EPA evaluated multiple COUs for workers, occupational non-users (ONUs), consumers, the general population, and the environment. Across the set, workplace inhalation exposures were a major focus. Cancer risk was a primary driver for EDB, 1,1,2-TCA, and 1,2-DCP. TBBPA was the only chemical where EPA preliminarily found an unreasonable environmental risk.

# Notable distinctions among the seven

• 1,2-DCP stands out for consumer risk: all three consumer COUs assessed (cleaning and furnishing care products) contributed to the preliminary unreasonable-risk finding.
• Some chemicals showed no preliminary risk to the general population or the environment, while others did for certain COUs.

# Science advisory review and next steps Several hazard assessments were reviewed by the Science Advisory Committee on Chemicals (SACC): o-DCB and p-DCB in June, TBBPA in July, and t-DCE, 1,1,2-TCA, and 1,2-DCP in August. Each draft evaluation is now open for public comment. After the comment period and any revisions, EPA will issue final risk evaluations. If the final evaluation confirms unreasonable risk for a chemical, EPA is required by statute to start risk management rulemaking under TSCA Section 6(a).

# Practical implications for industry and downstream users

# What to watch next

• Public comment windows and EPA responses to SACC feedback for each draft evaluation.
• Final risk evaluations and the timing of any TSCA Section 6(a) rulemakings that would follow confirmed unreasonable-risk findings.
• Enforcement and compliance guidance addressing worker inhalation exposures and consumer-product uses, particularly for 1,2-DCP and the three cancer-driven chemicals.