OVERVIEW OF TRICHLOROETHYLENE (TRIC)


EUROPEAN UNION

With its classification of cancerogen cat 1B (may cause cancer), trichloroethylene (TRIC) meets the criteria to be a substance of very high concern (SVHC) and thus was included into the authorization list (Annex XIV) of the REACH-Regulation in April 2013.

Since April 2016, TRIC is only allowed to be used if the user has a granted authorization. The use of TRIC is therefore limited to special application for which the user has proven that no suitable alternative exists.

 


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).

The Risk Evaluation Process is the second step, following Prioritization and before Risk Management, under the Toxic Substances Control Act (TSCA). 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 December 2023 and found unreasonable risks to workers, occupational non-users, consumers, and bystanders in 52 out of 54 conditions of use.

The EPA will develop ways to address the unreasonable risks identified and consider public comments on any risk management actions. Proposal by the EPA for TRIC is not published yet, but is expected shortly within the next months or even weeks at the date of writing this article.

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

 


CHINA

China has filed a notice in relation to the so-called Blue Sky Plan in 2019, which aims to improve air quality in several big cities in China. This notice was the starting point for several legislative actions regulating and restricting air quality-affecting topics.

Under this plan a new Chinese standard was published in 2020 which regulates volatile organic compounds (VOC) in cleaning agents (GB 38508-2020). The regulation was released as a national standard in March 2020, followed by implementation on December 1st 2020.

The standard provides limit requirements for VOC, test methods and package marks of cleaning agents. This standard is applicable to cleaning agents containing VOC produced and used in industrial production and service activities. This standard is NOT applicable to cleaning agents used in aerospace, nuclear industry, military industry and semiconductor (including integrated circuit) manufacturing. These areas of industrial production are exempted.

Trichloroethylene (TRIC) is listed in this standard and therefore falls under this restriction. According to the standard, cleaning agents with a content of ≥ 20% of TRIC may for example not be used in industrial production and service activities. Cleaning agents with a VOC content of ≥ 900 g/L may not be used in industrial production and service activities. The standard also defines the limit of VOC content in a cleaning product and therefore alternative formulations are needed in order to meet the requirement.

TRIC supplied by SAFECHEM in China can only be used in the industries exempted from the standard, which include aerospace, nuclear industry, military industry and semiconductor (including integrated circuit) manufacturing.