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EPA Proposes Ban of TCE for Use in Vapor Degreasing
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By Lynn L. Bergeson, Charles M. Auer, and Margaret R. Graham

On January 11, 2017, the U.S. Environmental Protection Agency (EPA) announced it would be issuing a rule proposing to prohibit the manufacture (including import), processing, and distribution in commerce of trichloroethylene (TCE) for use in vapor degreasing; to prohibit commercial use of TCE in vapor degreasing; to require manufacturers, processors, and distributors, except for retailers of TCE for any use, to provide downstream notification of these prohibitions throughout the supply chain; and to require limited recordkeeping.  EPA is proposing under Section 6 of the Toxic Substances Control Act (TSCA) to prohibit these uses due to its determination that there are “significant health risks associated with TCE use in vapor degreasing,” and they present “an unreasonable risk to human health.”  The pre-publication of the proposed rule is available on EPA’s website.  Once it has been published in the Federal Register, comments must be submitted within 60 days of publication. More information on the final rule is available in our memorandum on our website under the key phrase TSCA.