Vinyl Chloride and 4 Other Chemicals Prioritized for TSCA Risk Evaluation, Restrictions

Updated 07/24/2024

Five chemical substances used to manufacture petrochemicals, plastics, PVC, pharmaceuticals, and more are officially on the path to have their production, distribution, and use restricted or prohibited under the Toxic Substances Control Act (TSCA). 

EPA gave notice on July 25, 2024 that five substances, including vinyl chloride, will be added to the High Priority list for TSCA-mandated risk evaluation. Vinyl chloride was one of the substances involved in a widely publicized train derailment and hazmat release in Ohio in February 2023.

The other four substances covered are acetaldehyde, acrylonitrile, benzenamine, and MBOCA. 

Industry stakeholders and the public can submit comments on EPA's announcement until October 23, 2024. In the rest of the blog below, keep reading about these chemicals, how EPA chose them for risk evaluation, and what to expect as the risk evaluation process moves forward in 2024 and 2025.

TSCA Tuesday: 5 Plastics Chemicals May Be Restricted

EPA is prioritizing these 5 chemicals for TSCA risk evaluation: 

• Acetaldehyde (CASRN 75-07-0),
• Acrylonitrile (CASRN 107-13-1),
• Benzenamine (CASRN 62-53-3),
• 4,4’-Methylene bis(2-chloroaniline) (MBOCA) (CASRN 101-14-4), and
• Vinyl Chloride (CASRN 75-01-4).

A TSCA risk evaluation is a process by which EPA determines if a chemical made or used in the United States poses “unreasonable risks” to human health or the environment.

If a chemical  poses unreasonable risk, the law authorizes the agency to place restrictions on activities like manufacturing, processing, distribution, and use. Those restrictions range from added reporting or notification requirements to all-out prohibition or “ban” on all activities involving the chemical. 

Manufacturers use these chemicals to produce goods like plastics, resins, other chemicals, paints, and many others. The fifth substance on the list, vinyl chloride, was the chemical released in a large quantity during the derailment and hazmat release incident in Palestine, OH earlier this year.

What is a TSCA "High Priority" Chemical?

Under TSCA, the process to designate a chemical as a high priority for risk evaluation takes one year and includes opportunities for input from industry stakeholders and the public. As it stands now, EPA "expects these chemicals to be designated as high-priority for risk evaluation" when the process is complete.  

The five chemicals listed above would join the list of 20 tagged as high priority in 2019. The announcement from EPA goes on to say that the Agency aims to initiate the prioritization process for five chemicals every year. 

Unreasonable Risk and TSCA Prohibitions

EPA has followed several already completed chemical risk evaluations with TSCA prohibitions, new management standards, and worker protections.   

EPA started evaluating the risks of chemicals on the TSCA inventory shortly after 2016, when the Frank R. Lautenberg Chemical Safety in the 21^st Century Act (i.e., LCSA or “Lautenberg Law”) reformed TSCA to add the risk evaluation procedures. 

New to TSCA? New to EPA Compliance?

If you’re new to the field of environmental compliance or need an update on changing EPA rules, online training is a convenient way to quickly build in-depth expertise.

The Complete Environmental Regulations online course will prepare you to identify the 40 CFR regulations that impact your facility and take the steps need to achieve compliance. The course covers the keys to applicability for major EPA air, water, and chemical programs and will help you make informed decisions about environmental compliance.

Or, take a course focused on one area of environmental compliance: 

• TSCA Regulations Online
• Clean Air Act Regulations Online
• Clean Water Act & SDWA Regulations Online
• Superfund and Right-to-Know Act Regulations Online 
• Developing an SPCC Plan Online

Tags: environmental compliance, TSCA, TSCA Section 6, vinyl chloride