WASHINGTON (Dec. 16, 2024) – The Chlorine Panel of the American Chemistry Council today expressed deep disappointment in the Environmental Protection Agency’s (EPA) final Toxic Substances Control Act (TSCA) risk management rule on carbon tetrachloride (CTC). This rule imposes unnecessary burdens on industries critical to climate goals and national infrastructure while failing to adequately consider scientific and technical factors.
EPA’s rigid and impractical requirements for carbon tetrachloride risk management are a step backward for regulatory pragmatism and chemical safety. The rule ignores EPA’s own guidance, extensive scientific evidence, and industry feedback, resulting in an unworkable regulatory framework that undermines critical sectors of our economy.
Unrealistic Existing Chemical Exposure Limit (ECEL)
EPA has set an ECEL of 0.03 ppm—a value significantly lower than international standards and 333 times lower than OSHA’s permissible exposure limit. ACC has repeatedly highlighted that this threshold is impractical for routine monitoring and compliance with currently available technology. Manufacturers have stressed that meeting this ECEL will require investments in engineering controls and monitoring systems that are still under development, making the compliance timeline infeasible.
Insufficient Implementation Timeline
The rule grants only 18 months for initial monitoring and 21 months for full compliance with workplace chemical protection programs. This timeline does not account for the technical challenges and supply chain disruptions involved in achieving compliance with such a low occupational exposure limit.
Critical Uses Overlooked
ACC supports EPA’s decision to allow certain uses of CTC in closed-system applications, such as its role as a feedstock for producing low global warming potential hydrofluoroolefins (HFOs). However, the rule still falls short by imposing unwarranted constraints that threaten the future of industries essential to achieving the nation’s climate and energy goals.
Call for Reconsideration
The Chlorine Panel urges EPA to reconsider its decision, especially regarding the ECEL and implementation timeline, and to align the final rule with the best available science.
About the Chlorine Panel
The Chlorine Panel of the American Chemistry Council represents manufacturers and users of chlorinated organics. The Panel promotes the safe, effective, and scientifically grounded use of chlorine and its derivatives, promoting sustainable innovation for future generations. For more information, please visit: https://www.americanchemistry.com/industry-groups/chlorinated-solvents/carbon-tetrachloride.