trans-1,2- Dichloroethylene; TSCA Review

The American Industrial Hygiene Association, AIHA, is an association for scientists and professionals committed to preserving and ensuring occupational and environmental health and safety. We appreciate the opportunity to provide feedback on EPA's draft risk evaluation for trans -1,2-dichloroethylene (TDCE) under TSCA. Below are highlights of the attached comments •Regarding exposure controls, AIHA encourages EPA to better understand the context in which the material/chemical is used to better control exposures. Also, in general when evaluating the exposure potential of any chemical, it is important to consider how the "bioavailability" of that chemical can change based on how it is used, handled or processed. •The AIHA Guideline Foundation has been developing its Principles of Good Practice (PGPs); which are practical, proven, and available practices that are effective in protecting workers and communities from unacceptable risks. PGPs could be included in the EPA risk evaluations as a baseline recommendation. •In most high-end scenarios and some central tendency scenarios, EPA has estimated lower exposures for ONUs than for "average workers." While this may be true of many ONUs, such as office workers who venture on to the shop floor only occasionally, or production workers in a nearby operation, other ONUs may have higher peak or average exposures than production workers. •EPA is encouraged to consider and assess the availability of the IH sampling and analytical methods and their respective LOQ values relative to proposed benchmarks in the risk evaluations. •EPA is encouraged to reconsider its approach to deriving the OEV and the associated point of departure that was part of its basis for finding unreasonable risk of injury to human health. •AIHA through its Guideline Foundation, maintains an Occupational Exposure Limit (OEL) Program.[1] The OEL Program is a multidisciplinary, international committee composed of experts in occupational hygiene, toxicology, epidemiology, medicine, and risk assessment science. We invite EPA to consider AIHA and the OEL Program as resources that can assist the Agency in meeting its mandate. •AIHA recommends EPA institute a clear and transparent process for developing OEVs and existing chemical exposure limits (ECELs) under TSCA that incorporates peer review of the approach and the ultimate outcome (value).