The U.S. Environmental Protection Agency (EPA) is asking manufacturers, processors, and downstream users to provide technical and operational information that could influence its final risk evaluation for 1,1,2-trichloroethane, following a preliminary finding that the chemical poses unreasonable risk to human health under certain conditions of use. The agency will accept public comments through September 28, 2026, before completing the evaluation required under the Toxic Substances Control Act.
EPA published the draft risk evaluation on July 24 in docket EPA-HQ-OPPT-2018-0421, the same docket that has tracked the chemical since the agency designated it high-priority in December 2019. The draft covers acute, intermediate, and chronic risks to workers and occupational non-users, consumers, the general population including fenceline communities, and aquatic and terrestrial species. While the draft concludes that certain uses may drive unreasonable risk, much of the notice focuses on information EPA says it still needs. Rather than limiting comments to policy questions, the agency is requesting detailed operational data that could refine its exposure estimates and affect the final determination.
EPA Wants Operational Detail, Not General Comments
The agency is specifically requesting manufacturing and import volumes, production process descriptions, worker schedules, airborne exposure measurements, personal protective equipment and dermal protection practices, environmental release data, transportation and container methods, and use information for adhesives, sealants, laboratory chemicals, and cleaning and degreasing operations. EPA is also seeking detail on how 1,1,2-trichloroethane generated as a byproduct at pulp and paper facilities, an occupational exposure scenario the agency flagged specifically, is subsequently used, disposed of, or distributed. One targeted question asks whether 350 operating days per site-year, the default EPA used across several exposure scenarios, reflects how manufacturing facilities actually run. That kind of granular pushback is similar to the operational burden companies already navigate under TSCA’s Chemical Data Reporting rule, which requires similarly detailed production and use information every four years.
Why It Matters
For companies that manufacture, process, or use 1,1,2-trichloroethane, the comment period is an opportunity to put facility-specific information into the record before EPA finalizes its determination. Under TSCA, that final call has to rest on the weight of scientific evidence, and the agency is barred from weighing costs or other non-risk factors. EPA’s chemical program has shown it will act once a final risk evaluation is in hand, from targeted rules requiring workplace exposure controls to, in more severe cases, emergency suspension of a chemical’s registration entirely. Recent TSCA reviews of other chemicals have also shown that findings often turn on specific industrial exposure scenarios rather than a chemical’s presence in a product generally, which is exactly the kind of use-by-use detail EPA is asking commenters to help fill in here.
After reviewing public comments and input from the Scientific Advisory Committee on Chemicals, EPA will issue a final risk evaluation. If the agency determines the chemical presents an unreasonable risk under its conditions of use, that finding becomes the basis for whatever risk management rule follows, which is typically where compliance obligations, exposure limits, or use restrictions actually take shape.
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