OVERVIEW OF TRICHLOROETHYLENE (TRIC)

UNITED STATES

Over recent years, after the amendment of the Toxic Substance Control Act (TSCA) in 2016, the US Environmental Protection Agency (EPA) reviewed the risks associated with the use of many chlorinated solvents including Trichloroethylene (TRIC or TCE) and proposed rules for the risk management and to eliminate the risks posed by these chemicals. On the 17^th of December 2024, the Final Rule for TCE was published in the Federal Register. In summary, the rule would prohibit TCE for all uses including vapor degreasing but would grant some uses of TCE a longer timeline until prohibition. 

Please find the link to the publication of Final Rule for TCE here.

If the Final Rule of TCE would come into effect, it would prohibited most uses within one year after the effectiveness date including the use in standard vapor degreasing application. Nevertheless, some special uses, also in vapor degreasing, would be granted longer prohibition timelines. 

To continue these uses of TCE a Workplace Chemical Protection Program (WCPP) would be required. A WCPP is a program to protect potentially exposed persons in the workplace. The WCPP requirements include inhalation exposure limits, called interim existing chemical exposure limit (interim ECEL), to protect potentially exposed persons. For TCE the WCPP includes currently an interim ECEL of 0.2 ppm and interim ECEL action level of 0.1 ppm. The interim ECEL is defined as an 8-hour time-weighted average (TWA) value which identifies the level at or below which a potentially exposed person will be protected against unreasonable risk. The interim ECEL of 0.2 ppm must be reached and further measures must be taken and more often exposure monitoring must be conducted, until the interim ECEL action level of 0.1 ppm is reached. 

Below you will find an overview on the uses of TCE with longer prohibition timelines under a WCPP:

• Industrial and commercial use as a solvent for batch vapor degreasing for land-based DoD defense systems by Federal agencies and their contractors

• Industrial and commercial use as a solvent for closed-loop batch vapor degreasing necessary for rocket engine cleaning by Federal agencies and their contractors

• Industrial and commercial use as a solvent for closed-loop and open-top batch vapor degreasing for essential aerospace parts and components and narrow tubing used in medical devices

• Industrial and commercial use as a solvent for closed-loop batch vapor degreasing for rayon fabric sourcing for end use in rocket booster nozzle production by Federal agencies and their contractors 

• Industrial and commercial use in processing aid  for lithium battery separator manufacturing

• Industrial and commercial use in processing aid  for lead-acid battery separator manufacturing

• Industrial and commercial use in processing aid  for specialty polymeric microporous sheet material manufacturing

• Industrial and commercial use in processing aid  in process solvent used in battery manufacture; in process solvent used in polymer fiber spinning, fluoroelastomer manufacture and Alcantara manufacture; in extraction solvent used in caprolactam manufacture; and in precipitant used in beta-cyclodextrin manufacture

• Asphalt testing and recovery using manual centrifuge process

• Asphalt testing and recovery

The effectiveness date of the Final Rule was originally dated to be January 16^th, 2025. Nevertheless, On January 28^th, 2025, EPA issued a final rule delaying the effective date of four rules, including the  final risk management rule for TCE until March 21^st, 2025.  EPA stated that it delayed the effective date of the Final Rule for TCE in response to President Trump’s January 20^th, 2025, memorandum entitled “Regulatory Freeze Pending Review”. 

On March 21, 2025, the new administrator of EPA, Lee Zeldin signed a document further postponing the effective date of all the requirements associated with TSCA section 6(g) exemptions in the final TCE rule for 90 days until June 20, 2025, pending judicial review.   

Please find the link to the pre-publication here.

Please find the link to the exemptions listed under TSCA 6(g) and for which the effective date of all requirements were postponed here.

SAFECHEM will closely monitor the process and keep everyone informed about the future developments.

Additional Links: 

Please note that deadlines mentioned in the Final Rule, as well as the Fact Sheet and Compliance Guide (Links below) are now also effected by the latest developments and might not be correct anymore.

Final Risk Management Rule: Risk Management for Trichloroethylene (TCE) | US EPA
Fact Sheet: Regulation of TCE Under TSCA: Fact Sheet for the 2024 Final Risk Management Rule for Trichlorethylene under TSCA
Compliance Guide: epa.gov/system/files/documents/2025-01/tce-compliance-guide.pdf