In an effort to strengthen chemical safety regulations, the U.S. Environmental Protection Agency (EPA) has announced the initiation of the prioritization process for five additional toxic chemicals under the Toxic Substances Control Act (TSCA). This decision may substantially impact manufacturers as the EPA takes steps to evaluate the risks associated with these chemicals. These are the five substances in question:

• Vinyl Chloride (CASRN 75-01-4),
• Acetaldehyde (CASRN 75-07-0),
• Acrylonitrile (CASRN 107-13-1),
• Benzenamine (CASRN 62-53-3), and
• 4,4’-Methylene bis(2-chloroaniline) (MBOCA) (CASRN 101-14-4).

These substances play crucial roles in various manufacturing processes, including the production of plastics, adhesives, petrochemicals, and more. All five chemicals were selected from the 2014 TSCA Work Plan, which is a list of chemicals identified by EPA for further assessment based on their hazards and potential for exposure.

Breaking Down the Chemicals Being Evaluated

Acetaldehyde is primarily used in the manufacturing and processing of adhesives, petrochemicals, and other chemicals, as well as intermediates for products like packaging and construction materials. Exposure to acetaldehyde may result in a range of health effects such as irritation of the respiratory system. It is a probable human carcinogen.

Acrylonitrile is primarily used in the manufacturing and processing of plastic materials, paints, petrochemicals and other chemicals. Exposure to acrylonitrile may result in a range of health effects such as irritation of the respiratory system. It is a probable human carcinogen.

Benzenamine is used in the manufacturing and processing of dyes and pigments, petrochemicals, plastics, resins and other chemicals. Exposure to benzenamine may result in a range of health effects such as adverse effects on the blood, fetal development, and reproduction. Benzenamine is a probable human carcinogen.

MBOCA is used in the manufacturing and processing of rubbers, plastics, resins and other chemicals. It is a probable human carcinogen. There is also extensive data that demonstrates exposure to MBOCA may damage genetic material in cells, potentially leading to other adverse health effects, particularly when exposure occurs to infants and children.

Vinyl chloride is primarily used in the manufacturing and processing of plastic materials like polyvinyl chloride (PVC), plastic resins, and other chemicals, many of these materials are used for pipes, insulating materials, and consumer goods. This chemical was also involved in the Norfolk Southern train derailment in East Palestine, Ohio. Exposure to vinyl chloride may result in a range of health effects such as liver toxicity. It is also a known human carcinogen. In the 1970s, the White House Council on Environmental Quality and EPA officials raised serious concerns about the health impacts of vinyl chloride. These concerns were the impetus for Congress to write a law to ensure chemicals were made and used safely, which led to the passage of the “original” TSCA in 1976.

Regulatory Process and Industry Comments

The prioritization process is the initial step under the EPA’s authority to regulate existing chemicals, leading to risk evaluations. The agency plans to prioritize five chemicals annually to maintain a sustainable pace for risk assessments. If the risk evaluation indicates unreasonable health or environmental risks, the EPA must promptly initiate risk management actions.

EPA’s decision comes after consultations with federal partners, industry stakeholders, environmental organizations, labor groups, and others. The agency invites public comments and additional information regarding the use and potential risks of these chemicals. Manufacturers using these substances are encouraged to participate in the public comment period and provide insights into their practices and the safety measures in place.

Potential Impact for Manufacturers

Manufacturers using these chemicals in their processes may face increased scrutiny and potential regulatory changes based on the outcomes of risk evaluations. The EPA aims to comprehensively study the safety of these chemicals, which have been in use for decades, to better protect people from toxic exposure. The prioritization process will assess factors such as how the chemicals are used, their impact on overburdened communities, and potential risks to vulnerable populations like children and factory workers.

Manufacturers using Acetaldehyde, Acrylonitrile, Benzenamine, MBOCA, and Vinyl Chloride should closely monitor developments in the EPA’s prioritization process. Public participation and industry input will play a crucial role in shaping the regulatory decisions that may follow. As the EPA moves forward with its commitment to environmental justice, manufacturers should be prepared for potential changes in regulations and safety requirements related to these chemicals.