Image Credit: Getty Images / Kateryna Bereziuk

In recent months, AIHA has submitted comments to EPA on two regulatory actions related to the Toxic Substances Control Act (TSCA): the risk evaluation for the phthalates DBP and DEPH, and the risk management rule for perchloroethylene. These comments were prepared by the AIHA TSCA Advisory Group. The mission of the advisory group is to position the occupational and environmental health and safety profession as the right partner to support EPA in occupational risk assessments and management as mandated by the Lautenberg Act of 2016, which amended TSCA.

Additionally, the advisory group plans to prepare and submit comments on proposed changes to the EPA TSCA framework rule, the carbon tetrachloride risk management rule, and the D4 (octamethylcyclotetrasiloxane) risk evaluation. Representatives of AIHA and the advisory group also recently met with EPA technical staff to discuss how AIHA can help EPA and the industrial hygiene (IH) community of practice be more successful regarding TSCA, how AIHA can serve as a nexus for outreach and dissemination of key information, and AIHA’s resources on the principles of IH practice.

Thanks to the great work of the advisory group and its leadership team, AIHA continues to advocate for increased awareness of and access to industrial hygiene best practices.

Phthalates Cumulative Risk Evaluations

Phthalates are a class of chemicals widely used as plasticizers in industrial and consumer products, including polyvinyl chloride, adhesives, coatings, rubbers, and other applications. Under TSCA, EPA is required to evaluate whether these substances present an unreasonable risk to human health or the environment. EPA has proposed a cumulative risk evaluation approach, considering exposure to multiple phthalates at once rather than evaluating each chemical in isolation.

In comments submitted to EPA (PDF), AIHA expressed support for the use of IH best practices and provided EPA with a number of technical resources to help support EPA’s approach. These resources included AIHA’s guidance on estimating dermal exposures, AIHA’s dermal absorption model (IH SkinPerm), and AIHA’s Principles of Good Practice. AIHA further emphasized that EPA must carefully define its methodology to ensure consistency, scientific rigor, and transparency.

Perchloroethylene Risk Management Rule

Perchloroethylene, also known as tetrachloroethylene or PCE, is a solvent primarily used in industrial settings for the production of fluorinated compounds as well as in dry cleaning and degreasing applications and in lubricants, adhesives, and sealants. EPA’s final risk evaluation for PCE, which was revised in 2022, determined that the substance presents unreasonable risks to workers, occupational non-users, and consumers, and the agency published a final rule for PCE regulation under TSCA in 2024. But this year, EPA indicated that it is reconsidering its PCE risk management rule and issued a request for comments from stakeholders.

AIHA’s comments (PDF) supported EPA’s focus on protecting workers while raising several recommendations to strengthen the rule. AIHA noted the importance of harmonizing EPA’s requirements with OSHA standards and other regulatory frameworks to avoid confusion and redundancy. AIHA also urged EPA to prioritize effective chemical risk management and workplace exposure controls over a chemical ban. AIHA reiterated support for the use of IH best practices and provided EPA with a number of technical resources to help support EPA’s approach. The comments further highlighted that the AIHA Guideline Foundation and OEL Committee developed and follow rigorous methodology for establishing limits for occupational exposures.

AIHA’s Ongoing Advocacy Role

These comments reflect AIHA’s broader mission of advancing the science and practice of OEHS to protect workers and communities. By engaging with EPA on TSCA rulemakings, AIHA ensures that the agency benefits from the perspectives of industrial hygienists who understand real-world exposure scenarios, risk assessment methodologies, and the challenges of workplace implementation.

As EPA continues to refine its risk evaluations and risk management rules, AIHA will remain an active participant and partner in providing technical expertise, advocating for feasible and effective protections, and working to ensure that regulations are grounded in sound science. For more information, read AIHA’s policy document (PDF) on TSCA.