Assessing and Managing Chemicals under TSCA

Fact Sheet on Trichloroethylene (TCE)

General TCE Questions

TCE Vapor Degreasing Questions

TCE Aerosol Degreasing and Spot Cleaner Questions

General TCE Questions

Q1. What action is EPA taking to reduce risks from trichloroethylene (TCE)?

In January, 2017 and December 2016, EPA published two proposed rules under section 6(a) of the Toxic Substances Control Act (TSCA), one to ban commercial use of TCE in vapor degreasing, and the other to ban use of TCE in commercial and consumer aerosol degreasing and as a spot cleaner in dry cleaning. With these actions, EPA is proposing to prohibit the manufacture (including import), processing, and distribution in commerce and to prohibit commercial use of TCE for these purposes. EPA is also proposing to require manufacturers, processors, and distributors, except for retailers, to provide downstream notification of these prohibitions throughout the supply chain, and to keep limited records. EPA plans to issue one final rule addressing the TCE uses in both proposed rules. These proposed regulatory actions follow a June 2014 TSCA Work Plan Chemical Risk Assessment for TCE that identified serious risks to workers associated with this TCE use and concluded that the chemical can cause a range of adverse health effects, including cancer, developmental and neurotoxicological effects, and toxicity to the liver.

Q.2 What uses of TCE did EPA evaluate?

EPA’s 2014 final TCE risk assessment evaluated health risks to consumers and workers using TCE as a degreaser, to consumers using it as a protective coating to finish prints or artwork, and to dry cleaners' workers using it to remove stains.

Q3. What are the potential risks of TCE to people?

The risk assessment showed risks from inhalation of TCE to consumers and workers, including bystanders  from use as an aerosol degreaser and as a spot cleaner. It also showed risks to workers and bystanders from use as a vapor degreaser. Short-term and long-term exposures can potentially affect the developing fetus. High acute concentrations of TCE vapors can irritate the respiratory system and skin and induce central nervous system effects such as light-headedness, drowsiness, and headaches. Repeated (chronic) or prolonged exposure to TCE has been associated with effects in the liver, kidneys, immune system, central nervous system. EPA has concerns for effects in the developing fetus from both acute and chronic exposure. TCE is carcinogenic to people through all routes of exposure, which include inhalation, dermal (skin), and ingestion.

Q4. How does the new TSCA law effect these rules?

For a chemical substance listed in the 2014 update to the TSCA Work Plan for Chemical Assessments for which a completed risk assessment was published prior to the date of enactment of the Frank R. Lautenberg Chemical Safety for the 21st Century Act, TSCA section 26(l)(4) expressly authorizes EPA to issue rules under TSCA section 6(a) that are consistent with the scope of the completed risk assessment and consistent with the other applicable requirements of TSCA section 6. TCE is listed in the 2014 update to the TSCA Work Plan and the completed risk assessment was published on June 25, 2014.

Additionally, TCE is one of the first 10 chemicals identified for evaluation under amended TSCA. That evaluation will address the remaining uses of TCE.

Q5. Are there TCE products available to consumers?

The vast majority of TCE use is in commercial or manufacturing facilities and sold through industrial supply chains. While not widely marketed to consumers, there are products containing TCE that can be purchased by consumers.

Q6. Are there specific names of products that contain TCE?

Product names and ingredients change. Searching the Internet using the terms “TCE” and “degreaser” results in a number of TCE-containing products.

Q7. How do I know if TCE is an ingredient in a product?

In general, labels identify product ingredients so look at them carefully, or consult the material safety data sheet (MSDS) or the product safety data sheet (PSDS), available from manufacturers. TCE can be referred to as trichlor, trike, tri, and sold under a variety of trade names. It is identified by its Chemical Abstract Service Number, which is 79-01-6.

TCE Vapor Degreasing Questions

Q8:    How does a vapor degreasing machine work?

Solvents such as TCE are heated in a degreasing unit to produce a hot vapor. When parts are placed into the degreaser, the hot vapor within the unit condenses onto the parts, causing beading and dripping. The dripping action carries the contaminants away from the fabricated part, leaving behind a clean surface. After vapor degreasing, the parts are suspended on a rack in order to drain the solvent.

 Vapor degreasing may take place in batches or as part of an in-line (i.e., continuous) system. In batch machines, each load (parts or baskets of parts) is loaded into the machine after the previous load is completed. With in-line systems, parts are continuously loaded into and through the vapor degreasing equipment as well as the subsequent drying steps. Vapor degreasing is used in a variety of occupational settings such as metal plating, electronics assembly, metal or composite part fabrication, and repair shops. 

Q9.    If vapor degreasing is done in a closed system, why is EPA concerned about the exposure to people if the system eliminates any exposure?

In EPA’s analysis, short-term and long-term non-cancer and cancer risks were identified for all types of vapor degreasing machines, although the risks for some closed systems are estimated to be lower than for any of the other types of vapor degreasing machines. 

Q10.   Are there safer chemical alternatives or technologies available to use instead of TCE as a vapor degreaser?

For vapor degreasing, alternatives to TCE with similar performance characteristics are available. Alternatives can include using different solvents, switching to aqueous cleaners, adopting other mechanical cleaning techniques, or equipment substitution.

However, EPA is specifically requesting additional comments, information, and data to assist in evaluating the availability of alternatives to TCE in vapor degreasing applications.

It is EPA’s understanding that most vapor degreasing machines can be used with other solvents, either as-is, or with minor modifications. However, there are significant hazards associated with these “drop-in alternatives.” EPA urges vapor degreasing facilities to think strategically about their choices should they replace or upgrade vapor degreasing equipment.   To the extent that a process currently using TCE in a vapor degreasing system can be converted to a significantly less toxic alternative, such as an aqueous cleaning system, significant risks to workers will be avoided and additional process changes avoided if there are further actions on toxic solvents.

Q11.   What advice does EPA have for workers to reduce exposure when TCE is used in vapor degreasing?   

EPA is proposing that the best way to reduce the risks from TCE is to prohibit the use of TCE in vapor degreasing, so workers should avoid using TCE in vapor degreasing. Workers should take steps to avoid exposure to TCE since inhalation of the chemical can be harmful.

Q12. How do these proposed regulations relate to OSHA requirements?

EPA is working closely with both OSHA and the Consumer Product Safety Commission (CPSC) on the development of these regulations.  CPSC regulates consumer products, including those that contain TCE. EPA under TSCA authority can address risks that cut across worker, public sector and consumer settings.

Further, OSHA has indicated that many of its permissible exposure limits (PELs) issued shortly after adoption of the OSHA Act in 1970, including the TCE, are outdated and inadequate for ensuring protection of worker health. A ban on the use of TCE in vapor degreasing machines would facilitate compliance with OSHA’s permissible exposure limit (PEL) for TCE.

When finalized, depending on the provisions of the final rule, EPA, in coordination with OSHA, will issue guidance to help companies comply with the rule.

TCE Aerosol Degreasing and Spot Cleaner Questions

Q13. Are there safer chemical alternatives available to use instead of TCE as an aerosol degreaser?

Yes, alternative formulations of aerosol degreasers that do not contain TCE are available.

Q14. Are safer alternatives or technologies available to use as a spot cleaner in dry cleaning?

Recent advances in both technology and garment care have resulted in alternatives to TCE and other dry cleaning solvents. These methods are becoming more widespread in the industry. Your dry cleaner will be able to advise you on whether or not your garments can be successfully cleaned using new cleaning processes.

Q15. Are there health concerns for people who wear garments that were treated with TCE for spot removal?

EPA does not believe that wearing clothes dry cleaned where TCE may have been used as a spotting agent poses a concern.

Q16. What advice does EPA have for consumers and workers to reduce exposure when TCE is used as an aerosol degreaser?

Consumers and workers should avoid using TCE-containing aerosol degreasers. EPA is proposing that the only way to reduce the risks from TCE is to prohibit the use of TCE in aerosol degreasers.  Read the consumer fact sheet on TCE.

Q17. What advice does EPA have for workers at dry cleaners to reduce exposure when TCE is used as a spot cleaner?

Dry cleaning workers should avoid using TCE-containing spot cleaners. EPA is proposing that the only way to sufficiently reduce risks from TCE is to prohibit the use of TCE in spot cleaners in dry cleaning facilities.