← American Industrial Hygiene Association (AIHA)
EPARulemakingEPA-HQ-OPPT-2025-0036

Asbestos Part 2: Legacy Uses and Associated Disposals of Asbestos; Regulation under the Toxic Substances Control Act (TSCA)

RIN
2070-AL21
Last modified
Sep 25, 2026
Comment window
closed 43d ago
American Industrial Hygiene Association (AIHA) filings
1

Activity

American Industrial Hygiene Association (AIHA) filed 1 comment on this docket between Sep 24, 2026 and Sep 24, 2026. 9 other organizations filed here. The comment window closed 43d ago.

What American Industrial Hygiene Association (AIHA) filed (1)

Sep 24, 2026· Comment submitted by American Industrial Hygiene Association (AIHA)· EPA-HQ-OPPT-2025-0036-0023

Dear Assistant Administrator Troutman, 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 June 2026 Request for Information (RFI) concerning legacy uses of asbestos under TSCA section 6(a). These comments address the four questions under Topic (E) of the RFI regarding air sampling methods and laboratory testing capabilities. We hope you find our feedback useful and are happy to answer any questions you may have. •AIHA Encourages EPA to Treat Low-Level Asbestos Measurement as a Sampling-and-Analysis System, Not as a Laboratory Question Alone. •AIHA Recommends Retaining PCM Where It Is Fit for Purpose and Using TEM Strategically in Dusty or Fiber-Interference Environments. •AIHA Recommends That EPA Assess National TEM Capacity Before Requiring TEM for Routine ECEL Compliance. •A TEM-Dependent ECEL Would Increase Compliance Costs and Turnaround Times and Could Delay Work Thank you, Dr. Michele Twilley AIHA Chief Science Officer See attached file(s)

Download attachment ↓View on regulations.gov →

Abstract

This rulemaking will address the unreasonable risk of injury to health from asbestos, as a chemical substance, identified by EPA in a risk evaluation completed under TSCA section 6(b) that focused on legacy uses of asbestos and associated disposals, asbestos-containing talc, and types of asbestos fibers other than chrysotile. Section 6 of the Toxic Substances Control Act (TSCA) requires that EPA, when it determines in a TSCA risk evaluation that a chemical presents an unreasonable risk of injury to health or the environment, apply one or more requirements under TSCA section 6(a) by rule to the extent necessary so the chemical substance no longer presents an unreasonable risk. EPA has bifurcated the risk management of asbestos into two parts; Part 1: Chrysotile Asbestos and Part 2: Legacy Uses and Associated Disposals of Asbestos. EPA completed its Part 1 risk evaluation and rulemaking activities for Chrysotile Asbestos. EPA’s Part 2 risk evaluation for asbestos, describing the conditions of use and presenting EPA’s determination of unreasonable risk, and related materials for that risk evaluation, are available in docket EPA-HQ-OPPT-2021-0254

View on regulations.gov →

Co-filers (9)

See everyone who commented →