Key Project

TSCA Implementation

What is TSCA?

The Toxic Substances Control Act (TSCA) is the main federal law that regulates chemicals allowed in commerce.

The outdated Toxic Substances Control Act of 1976 was reformed for the first time in 2016 when President Obama signed into law the Lautenberg Chemical Safety Act. This action followed a long campaign led by Safer Chemicals Healthy Families (now known as Toxic-Free Future’s federal policy program) and allies in the coalition we built with environmental, consumer, business, labor, health, and science groups. While the final reforms fell short of our platform, they were also substantially improved from the chemical industry-crafted “reform” package.

Highlights of the final reforms include a strictly health-based standard for chemicals, explicit protection for vulnerable populations, an expedited process for ordering chemical testing, and limited preemption of state programs.

What we’re doing

Moving forward, our challenge is to watchdog and advocate for strong implementation of the law and to extract as much benefit for public health and the environment as possible. Since the U.S. Environmental Protection Agency (EPA) plays a pivotal role in protecting public health from dangerous chemicals by using the tools in the reformed 2016 Toxic Substances Control Act (TSCA), Toxic-Free Future makes it a priority to urge EPA to take important actions under this law.

TSCA IMPLEMENTATION

Our Priorities

EPA, ban these dangerous chemicals

EPA: Ban vinyl chloride!

EPA announced the beginning of a regulatory process to designate vinyl chloride as a high-priority chemical under TSCA. The examination of all routes of exposure prescribed by the law should lead EPA to the conclusion that vinyl chloride is far too dangerous to make or use, and should be banned.

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EPA: Ban TCE!

The EPA has proposed a ban on TCE and is taking public comment right now. From notorious contamination sites like Woburn, Massachusetts and Camp Lejeune in North Carolina to exposures on the job, workers and communities have been exposed to and made sick by TCE for far too long. As we’ve waited for EPA action, families and communities have suffered its devastating health effects. Now is our opportunity for change!

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Two people in a dry cleaners, cleaning clothes with dry cleaner chemicals and bagging them in plastic bags

EPA: Ban asbestos!

Asbestos is a notoriously toxic substance. A known carcinogen, it can cause fatal illnesses including mesothelioma, asbestosis, and cancers of the lung, larynx, and ovaries. It is estimated that each year more than 40,000 Americans die from entirely preventable asbestos-caused diseases. Today, while asbestos is banned in nearly 70 countries, it is not banned in the United States.

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EPA: Ban methylene chloride!

When fumes from methylene chloride-based paint strippers build up, the chemical can cause asphyxiation and heart attacks. It’s happened to dozens of people, including Kevin Hartley and Joshua Atkins. Not one more family should lose a loved one to these products.

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More on TSCA

Our Resources

Our comments and letters submitted to EPA

From 2016 to 2021

June 23, 2021	Letter to EPA on the development and submission of analytical methods under TSCA Sections 4 and 8
May 17, 2021	Comments to EPA on the final rules for five persistent, bioaccumulative and toxic (PBT) chemicals
April 7, 2021	Letter to EPA on a new direction for the TSCA PMN Program
March 26, 2021	Comments to EPA on proposed fees for the administration of the amended TSCA
March 23, 2021	Letter to EPA on the need for the agency to put public health, science and equity at the center of its mission
February 26, 2021	Letter to EPA on political interference in the TSCA TCE risk evaluation by the prior administration
February 5, 2021	Letter to EPA calling for immediate action on methylene chloride under TSCA
January 22, 2021	Letter to EPA stating request to rescind January 19 Compliance Guide for PFAS SNUR under TSCA
January 15, 2021	Comments to EPA on Draft Compliance Guide for Imported Articles Containing Surface Coatings Subject to the Long-Chain Perfluoroalkyl Carboxylate and Perfluoroalkyl Sulfonate Chemical Substances Significant New Use Rule (SNUR)
December 19, 2020	Comments to EPA on Revised Draft Risk Evaluation for C.I. Pigment Violet 29
December 2020	Principles of Risk Management under TSCA Section 6
November 23, 2020	Letter to EPA requesting an extension of the comment period for the 1,4-dioxane supplemental risk evaluation
August 27, 2020	Letter to EPA expressing concern on the lack of opportunity to comment on two recent requests for critical use exemptions from EPA’s PBT rule
July 6, 2020	Comments on EPA’s Draft Risk Evaluation for Perchloroethylene
June 19, 2020	Letter to EPA on unannounced changes in EPA model consent order under Section 5(e) of TSCA
June 10, 2020	Comments on EPA’s Regulatory Determination on PFOA and PFOS under the Safe Drinking Water Act
June 8, 2020	Comments on EPA’s draft scoping documents for seven high-priority substances
June 2, 2020	Comments on EPA’s Draft Risk Evaluation for Asbestos
April 27, 2020	Comments on EPA’s Draft Risk Evaluation for Trichloroethylene
April 17, 2020	Comments on EPA’s Supplemental Significant New Use Proposal for Long-Chain Perfluoroalkyl Carboxylate and Perfluoroalkyl Sulfonate Chemical Substances
March 18, 2020	Comments to Science Advisory Committee on Chemicals (SACC) on EPA’s Draft Risk Evaluation for Trichloroethylene
March 6, 2020	Letter to EPA on imminent and serious health risks from acute consumer and worker exposure to trichloroethylene (TCE)
February 19, 2020	Comments to Science Advisory Committee on Chemicals (SACC) on EPA’s Draft Risk Evaluation for Carbon Tetrachloride
February 18, 2020	Comments to EPA on the agency’s working approach for making new chemical determinations under TSCA Section 5
January 21, 2020	Comments on EPA’s Draft Risk Evaluation for N-Methylpyrrolidone (NMP)
December 30, 2019	Comments on EPA’s Draft Risk Evaluation for Methylene Chloride
November 26, 2019	Comments to Science Advisory Committee on Chemicals (SACC) on EPA’s Draft Risk Evaluation for Methylene Chloride
November 21, 2019	Comments on proposed high-priority substance designation
November 13, 2019	Comments on proposed low-priority substance designation
November 8, 2019	Letter to EPA on imminent and serious health risks from acute consumer and worker exposure to methylene chloride
October 28, 2019	Comments on EPA’s proposed rule regulating persistent, bioaccumulative and toxic chemicals under TSCA
October 11, 2019	Comments on EPA’s Draft Risk Evaluation for 1-Bromopropane
October 9, 2019	Letter to EPA on imminent and serious health risks from acute consumer and worker exposure to 1-bromopropane; A background paper on the risks was also sent to EPA.
October 7, 2019	Comments on new chemical submissions for four PFAS chemicals
August 30, 2019	Comments on EPA’s Draft Risk Evaluation for Cyclic Aliphatic Bromide Cluster (HBCD)
August 30, 2019	Comments on EPA’s Draft Risk Evaluation for 1,4-Dioxane
June 24, 2019	Comments on EPA’s Proposed Revisions and Small Manufacturer Definition Update for Chemical Data Reporting Under TSCA Section 8(a)
June 19, 2019	Comments on EPA’s Initiation of Prioritization for 20 High-Priority and 20 Low-Priority Candidates under Section 6(b)(1) of TSCA
May 28, 2019	Comments on EPA’s Advance Notice of Proposed Rulemaking for Methylene Chloride Commercial Paint and Coating Removal Training, Certification and Limited Access Program
May 17, 2019	Supplemental comments on EPA’s Draft Risk Evaluation for C.I. Pigment Violet 29
January 14, 2019	Comments on EPA’s Draft Risk Evaluation for C.I. Pigment Violet 29 and Supplemental Information to Comments
November 15, 2018	Comments on EPA’s Working Approach for identifying potential candidate chemicals for prioritization
November 15, 2018	Comments on proposed SNURs on certain chemical substances under Section 5 of TSCA
October 30, 2018	Letter to EPA on public comment and peer review process for the initial 10 risk evaluations under TSCA
August 17, 2018	Comments on EPA Exposure and Use Assessment and Environmental and Human Health Hazards of 5 PBTs
August 16, 2018	Comments on problem formulations for the risk evaluations of 10 chemical substances under TSCA; appendices focusing on individual chemicals were also submitted for 1-BP, asbestos, carbon tetrachloride, HBCD, and NMP; The Healthy Building Network’s report on Chlorine and Building Materials was also submitted as an attachment in the asbestos and carbon tetrachloride dockets
August 16, 2018	Comments on proposed rule strengthening “transparency” in regulatory science
August 16, 2018	Comments on application of systematic review in risk evaluations under TSCA Section 6
August 10, 2018	Comments on proposed Significant New Use Rule (SNUR) for Asbestos
May 24, 2018	Comments on proposed user fees for administration of amended TSCA
May 23, 2018	Letter on finalizing the phase-out rule for methylene chloride paint removal products
April 16, 2018	Comments on draft guidance on expanded access to Confidential Business Information
January 25, 2018	Comments on the public meeting regarding approaches for identifying potential candidates for prioritization
January 19, 2018	Comments on progress implementing the new chemicals review program
January 12, 2018	Decabromodiphenyl ethers (decaBDE), Pentachlorothiophenol (PCTP), Hexachlorobutadiene (HCBD), Phenol, isopropylated, phosophate (3:1) (in these sections: main comments, technical report, EJSCREEN reports 1, 2, 3, and 4), and 2,4,6-Tris(tert-butyl) phenol (2,4,6-TTBP)
December 11, 2017	Letter discussing serious concerns with pre-manufacture notice (PMN)/new chemicals program
October 16, 2017	Letter relaying concerns about pre-manufacture notice (PMN)/new chemicals program
September 19, 2017	Comments on scoping documents
July 25, 2017	Letter critiquing scoping documents and problem formulation
May 24, 2017	Comments on standards for small manufacturers and processors
May 19, 2017	Comments on proposed rule restricting Trichloroethylene (TCE) in vapor degreasing
May 19, 2017	Comments on proposed rule restricting Methylene Chloride and N-methylpyrrolidone (NMP) in paint and coating removal
April 4, 2017	Letter opposing extension request for NMP/Methylene Chloride comment period
April 4, 2017	Letter opposing additional extension request for TCE vapor degreasing comment period
March 20, 2017	Comments on proposed prioritization procedures rule
March 20, 2017	Comments on proposed risk evaluation procedures rule
March 16, 2017	Comments on proposed rule restricting Trichloroethylene (TCE) in aerosol degreasing and spot cleaning
March 15, 2017	General comments on risk evaluation scoping process
March 15, 2017	Comments on scope of risk evaluation for: Asbestos, Carbon Tetrachloride (CTC), Hexabromocyclododecane (HBCD), Methylene Chloride, N-Methylpyrrolidone, and 1-Bromopropane (1-BP/nPB)
March 14, 2017	Comments on proposed inventory notification rule
February 6, 2017	Letter opposing extension request for both TCE rules’ comment periods
January 17, 2017	Comments on Pre-Manufacture Notice/New Chemicals Program
October 4, 2016	Letter regarding Confidential Business Information (CBI) substantiation requirements
August 9, 2016	Letter conveying recommendations for the first 10 chemicals to be evaluated under TSCA