TSCA Update: Progress on Chemical Risk Evaluations

The Toxic Substances Control Act (TSCA), as amended, directs US EPA to evaluate the risks posed to human health and the environmental by chemical substances listed on the TSCA Inventory that are "active in commerce." When EPA determines that a chemical substance poses an unreasonable risk to the environment or human health in some way, the law requires the agency to create new regulations to address the risks identified.

In the past month, EPA announced the availability of draft risk evaluations for three chemical substances: Ethylene dibromide, trans-1,2-dichloroethylene, and 1,2-dichloropropane. Releasing a draft risk evaluation is an important in the rulemaking process, giving the public and the regulated community a chance to review EPA's conclusions and the methods they followed to get there. 

Jump to the details about:

• Ethylene dibromide
• trans-1,2-dichloroethylene
• 1,2-dichloropropane 

Ethylene Dibromide 

A draft risk evaluation for ethylene dibromide released by US EPA finds that 10 uses of the chemical contribute to an unreasonable risk for workers and occupational non-users (ONUs) via potential inhalation or dermal exposure. EPA did not identify any unreasonable risk to consumers, the general population, or the environment from this chemical. 

Comments on the draft risk evaluation for ethylene dibromide will be accepted until 10/19/2026. The 10 “conditions of use” contributing to the unreasonable risk for workers and/or ONUs include manufacturing or importing ethylene dibromide, certain processing activities, industrial and commercial use as a fuel agent, commercial use as a lab chemical, and disposal. 

Down-the-drain disposal: EPA did not evaluate down-the-drain disposal by consumers in the risk evaluation of ethylene dibromide. The agency notes that while private pilots sometimes improperly dispose of contaminated fuel samples onto the ground, this practice is potentially illegal under existing RCRA standards and subject to Clean Air and/or Clean Water Act standards for releases.

Environmental and health risks from aviation fuel: In announcing the draft risk evaluation EPA stresses that the evaluation focused on ethylene dibromide itself. EPA did not analyze aviation fuel or “avgas” containing the chemical as part of this risk evaluation. The agency is evaluating the risks of avgas in the environment separately. (e.g., groundwater contamination). 

trans-1,2-dichloroethylene 

EPA’s draft risk evaluation for trans-1,2-dichloroethylene, a chemical used primarily for cleaning and degreasing, found that 19 conditions of use contribute to an unreasonable risk for workers and/or occupational non-users (ONUs), who may be exposed through acute or chronic inhalation exposure. 

EPA also found that one consumer use—use as a household cleaner or degreaser—contributes to an unreasonable risk to consumers' health. The draft does not identify any unreasonable risk to the general population or the environment.  

Industrial and commercial uses found to contribute to the risk include domestic manufacturing and import, incorporation into some formulations or mixtures, repackaging, recycling, and use in cleaning products, anti-adhesives, paints and coatings, lubricants, and more. 

EPA will take public comments on the draft risk evaluation for trans-1,2-dichloroethylene until 10/26/2026.

1,2-Dichloropropane 

EPA recently announced that a draft risk evaluation for 1,2-dichloropropane is available to review, along with supporting documentation. EPA determined that 14-of-15 conditions of use studied contribute to an unreasonable risk posed to workers, ONUs, and/or consumers. 

• 11 conditions of use contribute to the unreasonable risk determination for workers, including manufacture and import, chemical processing, repackaging, use as a lab chemical, use in cleaning and furniture care products, and disposal
• 4 conditions of use that affect workers also pose an unreasonable risk to occupational non-users: Commercial use as a spray cleaner, wax or polish, or liquid cleaner; and disposal. 
• 3 conditions of use contributed to the risk for consumers or bystanders—use in liquid spray cleaner, use waxes and polishes, and use liquid cleaner and polish. 

The deadline to submit comments on the draft risk evaluation for 1,2-Dichloropropane is 11/3/2026.

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