Carbon Tetrachloride Exposure Rule Proposed
Earlier this week, the U.S. Environmental Protection Agency announced a proposal to protect workers from exposure to carbon tetrachloride. According to the release, if finalized, the rule would minimize exposures, while banning uses that have already ceased.
CTC is a solvent used in commercial settings as a raw material for producing other chemicals like hydrofluoroolefins (HFOs) used in refrigerants, aerosol propellants, foam-blowing agents, chlorinated compounds and agricultural products. The chemical is known to cause serious health risks such as liver toxicity and cancer.
Painting, or the use of solvents while painting, is one of the industrial processes with risk of exposure, according to the National Institute of Health.
“The science is clear. Exposure to carbon tetrachloride is dangerous and we have a responsibility to protect the public from the risks it poses,” said Assistant Administrator for the Office of Chemical Safety and Pollution Prevention Michal Freedhoff. “Today's proposal is an important first step to ensuring carbon tetrachloride can be used safely by workers and that surrounding communities are protected.”
Requirements under the Montreal Protocol and the Clean Air Act led to a phaseout of CTC production in the United States in 1996 for most domestic uses that did not involve manufacturing of other chemicals, and the U.S. Consumer Product Safety Commission banned the use of CTC in consumer products in 1970.
The EPA reports that this proposal is the fourth proposed risk management rule under the amended Toxic Substances Control Act (TSCA).
In a 2020 risk evaluation, the EPA reportedly determined that CTC presents an unreasonable risk to health, from chronic inhalation and dermal exposures, largely to workers and occupational non-users (workers nearby but not in direct contact with this chemical).
Additionally, the EPA identified potential risks to fenceline communities, or a population in close proximity to source of pollution, from CTC in its 2022 fenceline screening analysis for the ambient air pathway.
If finalized, the proposed rule would require a workplace chemical protection program with strict controls that include inhalation exposure limits and dermal protections for the manufacturing, including import, of CTC, processing and other industrial or commercial uses. These uses reportedly account for almost the entire domestic production volume of CTC.
The agency notes that the workplace chemical protection program would cover uses related to the phasedown of climate pollutants under the American Innovation and Manufacturing (AIM) Act, the production of chlorine and caustic soda, the manufacture of agricultural products, and repackaging for use as a laboratory chemical, recycling and disposal.
Workplace controls have also been proposed by the agency that would require the use of a fume hood and dermal personal protective equipment for laboratory uses, as well as establish downstream notification and recordkeeping requirements.
The EPA will accept public comments on the proposed rule for CTC for 45 days following publication in the Federal Register via docket EPA-HQ-OPPT-2020-0592.
Recent TSCA News
In May, the EPA released proposed amendments to the review of new chemicals under the TSCA. The updated regulations would reportedly improve efficiency, as well as align with the 2016 TSCA amendments under the Frank R. Lautenberg Chemical Safety for the 21st Century Act.
According to the release, the latest proposal eliminates eligibility for exemptions from the full safety review process for new per- and polyfluoroalkyl substances (PFAS) and other persistent, bioaccumulative and toxic (PBT) chemicals.
Additionally, the reforms are anticipated to advance the EPA’s PFAS Roadmap, which outlines actions over the next three years, including steps to control PFAS at its sources, hold polluters accountable, ensure science-based decision making and address the impacts on disadvantaged and disproportionately impacted communities.
The proposed amendments the following provisions:
Proposed PCE Ban
Just last month, the EPA announced a proposed risk management ban on most uses for perchloroethylene (PCE). PCE is used in the production of fluorinated compounds, as a solvent for cleaning and degreasing, as well as in lubricants, adhesives and sealants. Several consumer and commercial products, such as common adhesives, aerosol degreasers, brake cleaners, aerosol lubricants, sealants, stone polish, stainless steel polish and wipe cleaners, also use PCE.
According to the release, the proposed risk management rule would rapidly phase down manufacturing, processing and distribution of PCE for all consumer uses and many industrial and commercial uses, most of which would be fully phased out in 24 months.
The EPA reports that the uses subject to the proposed prohibitions represent less than 20% of the annual production volume of PCE. For most of the uses of PCE that EPA is proposing to prohibit, the analysis also reportedly found that alternative products with similar costs and efficacy to PCE are reasonably available.
The EPA is also proposing a 10-year phaseout for the use of PCE in dry cleaning, with compliance dates depending on the type of machine in which PCE is used. This phaseout period would provide dry cleaners, many of which are small businesses, time to transition to an alternative process, and stakeholders have already noted an overall year-to-year decline in the use of PCE in dry cleaning.
For the industrial manufacturing, industrial processing and other uses of PCE that the EPA is not proposing to prohibit, the agency is proposing a workplace chemical protection program with a strict inhalation exposure limit and requirements to prevent skin exposure to ensure protection for workers.
The EPA says it has received data from industry that indicate many workplaces already have controls in place that may reduce exposures sufficient to meet the inhalation exposure limit in the proposed rule or to prevent direct skin contact with PCE.