Update | EPA Extends Compliance Date for TSCA PIP 3:1 Prohibition

Posted on 3/8/2022 by Roger Marks

Update: March 8, 2022

US EPA has again extended the compliance date for prohibiting processing and distribution-in-commerce of PIP (3:1), PIP (3:1)-containing articles, and the PIP (3:1) used to make those articles until October 31, 2024. 

The extended compliance date also applies to the associated recordkeeping requirement for manufacturers of PIP (3:1) containing articles. 

PIP (3:1) is a common name for Phenol, Isopropylated Phosphate 3:1 (PIP 3:1). It is used as a plasticizer, a flame retardant, or additive in hydraulic fluids, lubricants, industrial coatings, adhesives, sealants, and plastic articles.

Update: September 23, 2021 

US EPA extended the compliance date for processing and distribution of PIP (3:1), PIP (3:1)-containing products, and PIP (3:1)-containing articles until March 8, 2022.

From the Final Rule


The articles covered by this amendment include a wide range of key consumer and commercial goods such as cellular telephones, laptop computers, and other electronic and electrical devices and industrial and commercial equipment used in various sectors including transportation, life sciences, and semiconductor production.


Reporting and recordkeeping requirements applicable to manufacturers, processors and distributors will also take effect on March 8, 2022. PIP (3:1) is one of five persistent, bioaccumulative, toxic (PBT) chemicals for which EPA established new management standards under TSCA on January 6, 2021. 

(Details below)

Update: March 17, 2021

On March 16, US EPA requested additional public comments about new TSCA management programs concerning five persistent, bioaccumulative, and toxic (PBT) chemicals. 

From the announcement: "In particular, EPA is seeking comment on newly-raised issues associated with the March 8, 2021 compliance date in the PIP (3:1) rule for certain regulated articles."  

EPA will accept additional public comments until May 17, 2021. 

Read the announcement in the Federal Register. 

Original Article 

New TSCA Restrictions for 5 PBT Chemicals

TSCA, as amended by the Frank R. Lautenberg Chemical Safety for the 21st Century Act (LCSA), requires EPA to evaluate the risks of chemicals on the TSCA inventory.

The law also directs EPA to take expedited action to address the risks of some specific substances that had been identified in a previous TSCA Work Plan. These include persistent, bioaccumulative, and toxic (PBT) chemicals that EPA believes pose a high or moderate risk to human health of the environment.

EPA recently completed risk evaluations and established new regulatory management programs for five PBT chemical substances. For many of these chemicals, EPA will prohibit all manufacture, import, processing, and distribution in commerce.

The five PBT chemicals for which EPA issued new rules are:

  • Pentachlorothiophenol (PCTP)

  • Hexachlorobutadiene (HCBD)

  • Decabromodiphenyl ether (DecaBDE)

  • Phenol, Isopropylated Phosphate 3:1 (PIP 3:1)

  • 2, 4, 6-tris(tert-butyl)phenol (2, 4, 6-TTBP)

The five new rulemakings illustrate EPA’s broad authority under TSCA to restrict how chemicals are made and used in order to protect human health and the environment. Read on for details about new restrictions EPA has put in place for these chemicals.

Do you know your facility's responsibilities for chemical management, notification, and reporting under TSCA? The TSCA Regulations Online Course covers what you need to know to make informed decisions about compliance.   

Pentachlorothiophenol (PCTP)

EPA will prohibit all manufacture, import, processing, and distribution in commerce of PCTP and PCTP containing products or articles for any use, unless PCTP concentrations are at or below 1% by weight.

Pentachlorothiophenol or PCTP (CASRN 133-49-3) is used in rubber manufacturing, including as an ingredient in the rubber core of golf balls. 

PCTP Final Rule. 1/6/21.

2,4,6-tris(tert-butyl)phenol (2,4,6-TTBP)   

This Final Rule:

  • Prohibits the distribution in commerce of 2,4,6-TTBP and products containing 2,4,6-TTBP at concentrations above 0.3 percent in any container with a volume less than 35 gallons for any use.

  • Prohibits the processing and distribution in commerce of 2,4,6-TTBP and products containing 2,4,6-TTBP in concentrations above 0.3 percent by weight for use as an oil lubricant or additive, regardless of container size.

2,4,6-TTBP is used as an intermediate/reactant in chemical processing, to treat fuel in refineries and fuel facilities, in motor vehicle and machinery maintenance and repair, and as a liquid lubricant and grease additive.

2,4,6-TTBP Final Rule, 1/6/21

Phenol, isopropylated Phosphate (3:1) (PIP (3:1))

This Final Rule:

  • Prohibits processing and distribution in commerce of PIP (3:1) and products that contain it, with specific exclusions.

  • Prohibits the release of PIP 3:1 to water during manufacturing, processing, or distribution

  • Requires commercial users to follow existing regulations and best practices to release to the water during use.

The rule also includes notification and recordkeeping requirements for persons who manufacture the chemical, process it, or distribute it in commerce.

PIP (3:1) (CASRN 68937-41-7) is a versatile chemical. It can be used as a plasticizer, a flame retardant, or an anti-wear additive or an anti-compressibility additive. It is used for various purposes in hydraulic fluids, lubricants, industrial coatings, adhesives, sealants, and plastic articles.

PIP (3:1) Final Rule, 1/6/21
PIP (3:1) Extension of Compliance Date, 9/17/21
New PIP (3:1) 2nd Extension of Compliance Date 3/08/22

Decabromodiphenyl Ether (DecaBDE)

The Final Rule for decaBDE prohibits all manufacture, import, processing, and distribution in commerce of decaBDE and products or articles containing decaBDE, with some exclusions.

DecaBDE is a flame retardant. It is used in plastic enclosures for TVs, computers, audio and video equipment, textiles, upholstered articles, wires and cables, and more. 

A handful of states already ban decaBDE, including Washington, Maine, Oregon, Vermont, and Maryland. The largest commercial producers and suppliers of decaBDE reached an agreement with EPA in 2009 to phase out use of the chemical by the end of 2013.

DecaBDE Final Rule, 1/6/21

Hexachlorobutadiene (HCBD)

This Final Rule prohibits all manufacture, import, processing, and distribution in commerce of HCBD and HCBD containing products or articles.

EPA notes that the production of chlorinated solvents produces HCBD as a byproduct, and that a “very limited subset of that byproduct” will be distributed in commerce for burning as waste fuel.

A halogenated aliphatic hydrocarbon, HCBD is produced as a byproduct during the manufacture of other chemicals, including some for which EPA recently completed risk evaluations—PCE, TCE, and Carbon Tetrachloride (Carbon Tet).

HCBD Final Rule, 1/6/21

Note: Don’t confuse HCBD with hexabromocyclododecane (HBCD). HBCD is used as a flame retardant in building materials, recycled plastics, and car parts and was among the first ten chemicals to undergo TSCA risk evaluation. A Final Risk Evaluation for HBCD was released in September 2020.

Ongoing TSCA Chemical Risk Evaluations

Under LCSA, EPA is required to evaluate the risks of the more than 40,000 active chemicals on the TSCA inventory. When EPA’s risk evaluations determine that unreasonable risk to the environment, workers, or the public, EPA must address these risks with new regulations.

EPA has now completed ten chemical risk evaluations, many of which uncovered unreasonable risks that EPA must address with regulations within two years. Chemicals for which EPA has completed risk evaluations so far include methylene chloride, NMP, TCE, PCE, chrysolite asbestos, and 1-bromopropane.

Master Environmental 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. 

Check out more environmental compliance training options:
 Clean Air Act Regulations Online
TSCA Regulations Online
Clean Water Act & SDWA Regulations Online
Superfund and Right-to-Know Act Regulations Online 

Tags: chemical risk evaluations, chemicals, lautenberg, lcsa, TSCA

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