OVERVIEW OF TRICHLOROETHYLENE (TRIC)

UNITED STATES

Several solvents which are used in industrial parts cleaning operations, including prior and after heat treatment processes, are currently filed under Risk Evaluation by the Environmental Protection Agency (EPA) under the Toxic Substances Control Act (TSCA).

There are various other regulations which affect industrial cleaning applications, such as The Clean Air Act including NESHAP, The Resource Conservation and Recovery Act or The Clean Water Act. Nevertheless, the scope of this article is limited to TSCA only as this is a regulation which is applied all over the US without further break-down of state individual adoptions. However, SAFECHEM recommends readers to also take into account state specific regulation. There are very strict regulations in certain states like California which are further limiting the use of certain chemistries (e.g. on Ground Water Protection).

Under TSCA, the Risk Evaluation Process is the second step, following Prioritization and before Risk Management. The purpose is to determine whether a chemical substance presents an unreasonable risk to health or the environment, under the conditions of use, including an unreasonable risk to a relevant potentially exposed or susceptible subpopulation. As part of this process, the EPA must evaluate both hazard and exposure, exclude consideration of costs or other non-risk factors, use scientific information and approaches in a manner that is consistent with the requirements in TSCA for the best available science, and ensure decisions are based on the weight-of-scientific-evidence.

Currently all kind of brominated and chlorinated solvents are under review. This includes the use of trichloroethylene (TRIC), perchloroethylene (PERC), methylene chloride/dichloromethane (DCM) and 1-Bromopropane (nPB) but also trans-dichloroethylene (t-DCE).

The EPA released a final revised evaluation on TRIC in January 2023 and found unreasonable risks to workers, occupational non-users, consumers, and bystanders in 52 out of 54 conditions of use.

Proposals by the EPA for TRIC were already published in the Federal Register in October 2023. It proposed a prohibition of TRIC in industrial parts cleaning application.The public was given time to comment on the proposal until mid December 2023. Currently, the EPA is reviewing all received comments in consideration of their final rule for TRIC under TSCA, which is expected in the course of 2024. If the proposal enters into force, TRIC will not be allowed anymore in vapor degreasing one year after the publication of the final rule.

SAFECHEM will closely monitor the process and will inform as soon as new information is available.

For more information, please visit: 

Final Risk Evaluation: Final Risk Evaluation for Trichloroethylene | US EPA
Risk Management: Risk Management for Trichloroethylene (TCE) | US EPA