Please see attached comments from Environmental Defense Fund on EPA's proposed TSCA risk management rule for methylene chloride.
Methylene Chloride; Rulemaking under TSCA section 6(a)
Activity
Environmental Defense Fund filed 2 comments on this docket between Jun 30, 2023 and Jul 7, 2023. 54 other organizations filed here. The comment window closed 397d ago.
What Environmental Defense Fund filed (2)
Dear EPA Administrator Michael Regan, As a constituent, concerned about the risks that chemicals pose to my health and the health of my community, I applaud your proposal to ban all consumer uses of methylene chloride and most commercial uses under TSCA's jurisdiction. I urge you to both strengthen and urgently finalize this rule in order to safeguard the health of Americans across the nation. Methylene chloride is a deadly — yet all too common — chemical that we see on store shelves as well as in workplaces and fenceline communities, across the country. It can be commonly found in aerosol degreasers, brush cleaners for paints and coatings, commercial adhesives and sealants, and other industrial products. Since 1980, there have been at least 85 deaths due to exposure to methylene chloride. Inhaling vapors can result in immediate and serious harm to the central nervous system and even death. Longer-term exposure can also lead to liver toxicity, liver cancer and lung cancer. Simply put, it's an unacceptable risk and should be banned in all TSCA uses. Your proposal will protect many people by banning all consumer uses and many factory uses across the country. However, it is critical that we take every measure to protect all communities from exposure — especially workplaces that would still be permitted to continue using methylene chloride and the families living nearby. The proposal includes exemptions for federal uses of paint and coating removers granted to federal agencies such as the: National Aeronautics and Space Administration (NASA), Federal Aviation Administration (FAA) and the Department of Defense. Exempted uses account for 48% by volume of the methylene chloride uses under TSCA. The workers at these facilities, as well as the communities that surround them, are at risk of continued exposure. By setting stronger standards, with clear time limits for remaining exemptions, the U.S. will be better prepared to protect public health. Please take steps to strengthen the final version of your proposal and ban all TSCA uses of methylene chloride. Thank you for your leadership.
Abstract
Section 6 of the Toxic Substances Control Act (TSCA) requires EPA to address unreasonable risks that the Administrator has determined are presented by a chemical substance under the conditions of use. Following a risk evaluation carried out under the authority of TSCA section 6, EPA has determined that methylene chloride presents unreasonable risks of injury to health. EPA is initiating rulemaking under TSCA section 6 to address these unreasonable risks.
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See everyone who commented →- Environmental Defense FundTHIS ORG2 filings · confidence 97%
- American Chemistry Counciltrade assoc.6 filings · confidence 97%
- American Coatings Associationtrade assoc.3 filings · confidence 97%
- Hach Companyunverified attribution2 filings · confidence 70%
- National Association of Chemical Distributorstrade assoc.2 filings · confidence 85%
- National Federation of Independent Businesstrade assoc.2 filings · confidence 97%
- Purdue Universityunverified attribution2 filings · confidence 70%
- University of Californiaunverified attribution2 filings · confidence 70%
- 3M Companyunverified attribution1 filing · confidence 70%
- Aerospace Industries Associationtrade assoc.1 filing · confidence 97%
- AFL-CIO1 filing · confidence 97%
- AgLogic Chemical LLCunverified attribution1 filing · confidence 70%
- Alliance for Automotive Innovationtrade assoc.1 filing · confidence 97%
- Alliance Technical Group LLCtrade assoc.1 filing · confidence 85%
- American Chemical Societytrade assoc.1 filing · confidence 85%
- American Council of Independent Laboratoriestrade assoc.1 filing · confidence 85%
- American Industrial Hygiene Association (AIHA)trade assoc.1 filing · confidence 97%
- American Petroleum Institutetrade assoc.1 filing · confidence 97%
- Animal Health Institutetrade assoc.1 filing · confidence 97%
- Association of American Pesticide Control Officials (AAPCO) Laboratory Committeetrade assoc.1 filing · confidence 85%
- Azusa Pacific Universityunverified attribution1 filing · confidence 70%
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- The Pennsylvania State Universityunverified attribution1 filing · confidence 70%
- Toxic Substances Control Act (TSCA) New Chemicals Coalitiontrade assoc.1 filing · confidence 85%
- Toxics Use Reduction Institutetrade assoc.1 filing · confidence 85%
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- University of Minnesotaunverified attribution1 filing · confidence 70%
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