Free tier, this brief uses 1 of 2 remaining for the month.Resets May 1
¶EPA is conducting a TSCA risk evaluation for 1,2-dichloroethane (EDC), a high-volume industrial solvent and chemical intermediate produced at 30 to 40 billion pounds per year. Commenters span the full range of stakeholders: environmental and health advocacy groups (Earthjustice, EDF, NRDC, California Communities Against Toxics), industry trade associations (American Chemistry Council Chlorine Panel, Vinyl Institute, Alliance for Automotive Innovation, AFPM), a tribal council, academic health programs, and labor unions. Industry commenters generally challenge the scope, exposure methodology, and procedural basis of the evaluation, while environmental and health groups press EPA to broaden the scope, include cumulative risk, and protect fenceline and environmental justice communities. A recurring concern from public health commenters is that the 2025 amended TSCA procedures (40 CFR part 702, 90 FR 45690) may result in greater EDC releases than the prior framework cited in the draft, and that worker and occupational non-user (ONU) exposure estimates rely on flawed assumptions.
1,2-Dichloroethane; Draft Risk Evaluation Under the Toxic Substances Control Act (TSCA); Notice of Availability and Request for Comment
The Environmental Protection Agency has released a draft risk evaluation under TSCA section 6 for 1,2-dichloroethane (ethylene dichloride, CASRN 107-06-2), a high-volume chemical used primarily to manufacture vinyl chloride, with production between 30 and 40 billion pounds reported from 2016 to 2019. EPA preliminarily finds, based on the weight of scientific evidence, that 1,2-dichloroethane presents unreasonable risk to human health and the environment driven by certain conditions of use. Public comments are due January 20, 2026. If the final evaluation confirms unreasonable risk, the chemical moves to risk management under TSCA section 6(a), which can include use restrictions or a ban.
1,1-Dichloroethane; Risk Evaluation Under the Toxic Substances Control Act (TSCA); Notice of Availability
EPA has finalized its TSCA risk evaluation for 1,1-dichloroethane (CASRN 75-34-3), a chlorinated solvent produced domestically at 100 million to 1 billion pounds annually. Based on the weight of scientific evidence and best available science, EPA determined that 1,1-dichloroethane presents unreasonable risk to human health under three of eight conditions of use, all driven by inhalation risks to workers in chemical manufacturing and recycling operations. No unreasonable risk was identified for the general population, occupational non-users, or the environment. EPA must now initiate risk management rulemaking under TSCA section 6(a) to address these worker risks.
Industry groups argue that EPA's exposure estimates are overstated, that dermal and inhalation models use incorrect assumptions, and that certain conditions of use should be removed from or clarified in the evaluation.
"30 to 40 billions pounds per year of EDC production isn't Monopoly money. EPA really needs to start thinking closely about what they scrutinize and the chilling effect it has on future chemical investments in the U.S."
Representative quote, cluster 01
Multiple industry organizations formally requested a 30-day extension of the comment period for the draft risk evaluation, citing the complexity and volume of the technical record.
"Vinyl Institute Request for EDC Draft Risk Evaluation Comment Deadline Extension"
Representative quote, cluster 02
At least one commenter argues that the 2025 revised TSCA risk evaluation procedures (90 FR 45690) may lead to greater EDC releases than the prior framework, and asks EPA to provide a validated comparative estimate.
"I request that EPA provide a scientifically validated estimation of likely Dichloroethane release under the amended 40 CFR part 702 as compared to what release would have been under the earlier regulations cited in the draft evaluation."
Representative quote, cluster 03
The American Industrial Hygiene Association and allied commenters contend that EPA improperly removes censored data, underestimates ONU exposures, and uses an inappropriate dermal exposure model for volatile liquids.
"Removing censored data can lead to biased judgments and decisions about exposure conditions in the workplace... ONU exposures need to be analyzed separately from production workers and workers exposed incidentally."
Representative quote, cluster 04
Earthjustice, Louisiana community groups, and California Communities Against Toxics urge EPA to account for disproportionate impacts on communities near EDC production facilities, including in Louisiana's industrial corridor.
"Earthjustice on behalf of Community In-Power and Development Association, Concerned Citizens of St. John, Louisiana Bucket Brigade, Louisiana Environmental Action Network, Mossville Environmental Action Network, RISE St. James..."
Representative quote, cluster 05
Earthjustice, EDF, NRDC, and allied groups argue that EPA must evaluate EDC's risks in combination with co-occurring chemicals, and should coordinate with ATSDR on cumulative risk methodologies required under TSCA.
"We urged ATSDR to consult with EPA regarding whether it can be of assistance in designing methods by which EPA can evaluate cumulative risks for the high priority chemicals currently undergoing risk evaluation."
Representative quote, cluster 06
Multiple commenters from both industry and public health sides argue about which conditions of use EPA should include or exclude, including upstream supplier uses and aerospace applications.
"EDC is not used as a raw material by Honeywell at its Baton Rouge or Geismar manufacturing facilities. This material is likely consumed as raw material by Honeywell suppliers in their manufacture of products supplied to Honeywell."
Representative quote, cluster 07
The UCSF Program on Reproductive Health and the Environment and affiliated health professionals urge EPA to give full weight to evidence of reproductive and developmental toxicity in the hazard assessment.
"Please see attached comments from the University of California, San Francisco Program on Reproductive Health and the Environment, academics, scientists, health professionals and clinicians."
Representative quote, cluster 08
The National Tribal Toxics Council submitted comments at multiple stages urging EPA to address tribal exposure pathways and environmental health impacts on tribal communities.
"National Tribal Toxics Council Comments on 1,2-DCA draft risk evaluation"
Representative quote, cluster 09
Commenters including EDF and Earthjustice argue that EPA must use its TSCA sections 4 and 8 authority to order testing and fill identified data gaps before finalizing the risk evaluation.
"We are submitting these comments...because they discuss EPA's obligations to order testing and data gathering of this substance under TSCA sections 4 and 8 and outline data gaps that should be filled."
Representative quote, cluster 10
The AFL-CIO, UAW, and United Steelworkers, through Earthjustice, argue that the risk evaluation must adequately protect workers and that occupational exposure limits should reflect actual workplace conditions.
"Earthjustice and the Occupational Safety & Health Law Project submit these amended comments...on behalf of the AFL-CIO, the UAW, and United Steelworkers."