TSCA Chemical Work Plan Progress

EPA continues fleshing out its Chemical Work Plan for its batch of TSCA chemicals of concern under existing authority.  They’ve recently released the Chemical Risk Assessment for N-Methylpyrrolidone (NMP) and the Problem Formulation and Initial Assessment for 1, 4-Dioxane and are considering section 6 restrictions action on trichloroethylene (TCE) and methylene chloride (DCM) if voluntary efforts fail.  Naturally, industry is complaining about overly conservative and outdated exposure data analysis, but it does appear that EPA is taking a more refined look at where significant uncontrolled risks might exist rather than a "just ban it" approach which failed for asbestos long ago.

The Agency is publishing its assessments and considering comments early in the process, so it behooves companies to offer the best data for consideration and work with the Agency to mitigate exposure risks where feasible.