NCHR Comment to EPA on Regulation of Certain Uses of Trichloroethylene

Office of Pollution Prevention and Toxics (OPPT)
Environmental Protection Agency
1200 Pennsylvania Ave., NW
Washington, DC 20460-0001

National Center for Health Research’s Public Comment on
Trichloroethylene; Regulation of Certain Uses Under TSCA Section 6(a)
[Docket Number: EPA-HQ-OPPT-2016-0163]

The National Center for Health Research is a nonprofit think tank that conducts, analyzes, and scrutinizes research, policies, and programs on a range of issues related to health.  We do not accept funding from companies that make products that are the subject of our work.

We agree with the EPA’s decision to prohibit the use of trichloroethylene (TCE) in aerosol degreasing and spot cleaning in dry cleaning facilitates because it poses an unreasonable risk to the health of workers and bystanders.[1] This proposed rule on particular uses of TCE is the first to restrict uses under the Frank H. Lautenberg Chemical Safety for the 21st Century Act. It requires the EPA to make a determination of unreasonable risk strictly due to health concerns of the chemical. As the EPA was unable to identify safety measures to sufficiently mitigate this risk to workers, consumers, and bystanders, the EPA very appropriately decided that should not be used for these purposes.

TCE exposure results in serious long-term health risks including damage to kidneys, the nervous system, reproduction systems, and liver.[2] It can also induce autoimmune diseases and cancer. Some of these conditions develop years after exposure. When a woman is exposed during pregnancy, her child can have abnormal development of the heart, immune system and nervous system, which can lead to lifelong problems or death.

The EPA-based exposure estimates are an underestimate because they were based only on inhalation and did not include exposure through skin or the dermal route. These uses can include frequent TCE contact with skin. Because TCE is absorbed,2 it contributes to exposure and thus health risk. Even though only a small percentage of TCE on the skin will be absorbed, frequent contact could have a meaningful impact on exposure levels. Even with this underestimate of exposure, the EPA still found concerning levels of exposure that were sufficient to have long-term health effects.[1] While adding exposure from dermal contact to the evaluation would not have changed EPA’s decision in this case, it is important it is important to emphasize that the evidence is even stronger and that future evaluations of chemicals include various routes of exposure.

We support EPA’s approach to eliminating the use of TCE for these uses by targeting multiple levels of the supply stream including manufacturers, processors, and distributors. In addition, we support EPA’s proposal to use an expedited implementation schedule to require the rule to take effect within 6 – 9 months of publication. Because of the long-term health risks due to these uses of TCE and the fact that safer alternatives to TCE are readily available,[1] there is no reason to delay implementation of the prohibition.

In summary, the use of TCE for aerosol degreasing and dry cleaning spot removal represent unreasonable health risks to workers, consumers, and bystanders that cannot be appropriately mitigated. Our scientific analysis agrees with the EPA decision that these uses should be prohibited. The Frank H. Lautenberg Chemical Safety for the 21st Century Act was designed to protect workers, consumers who use chemicals, and people who live where chemicals are released into the environment. Through systematic and comprehensive evaluations of chemicals, the EPA can reduce the risks of chemicals on the U.S. market, saving lives and improving the health of people who live and work in the United States.

Thank you for the opportunity to comment the use of TCE for aerosol degreasing and spot removal by dry cleaners.

The National Center for Health Research can be reached through Stephanie Fox-Rawlings at or at (202) 223-4000.


  1. EPA. Proposed Rule: Trichloroethylene; Regulation of Certain Uses Under TSCA § 6(a). Federal Register. December 16, 2016.–6a.
  2. EPA. TSCA Work Plan Chemical Risk Assessment. Trichloroethylene: Degreasing, Spot Cleaning and Arts & Crafts Uses. CASRN: 79-01-6. EPA/740/R1/4002. Office of Chemical Safety and Pollution Prevention, Washington, DC. June 2014.