This article has been updated to reflect EPA’s March 2026 proposed compliance date extensions for perchloroethylene (PCE) and carbon tetrachloride (CTC) under TSCA.
EPA March 2026 Proposal: Compliance Date Extensions for PCE and CTC
On March 24, 2026, EPA released a proposed rule to extend certain compliance dates in the final TSCA risk management rules for perchloroethylene (PCE) and carbon tetrachloride (CTC).
EPA stated that the proposed extensions are intended to provide compliance deadlines that are practical and implementable, while not weakening any existing worker protections or revisiting the underlying “unreasonable risk” determinations for these chemicals.
Key elements of the proposal include:
- Extension of certain Workplace Chemical Protection Program (WCPP) compliance dates for non-federal entities to align with federal agencies and contractors
- Initial inhalation exposure monitoring compliance proposed to be extended to June 21, 2027 (for both PCE and CTC)
- Respiratory protection program compliance proposed to be extended to September 20, 2027 (for both PCE and CTC)
- For PCE only, the compliance date to establish and implement an exposure control plan proposed to be extended to December 20, 2027.
EPA emphasized that current compliance deadlines remain in effect until formally modified through this rulemaking, and enforcement discretion will be coordinated through EPA’s Office of Enforcement and Compliance Assurance while reconsideration is underway.
EPA is accepting public comments on the proposal for 30 days following Federal Register publication under Docket EPA‑HQ‑OPPT‑2026‑0992.
Perchloroethylene (PCE) – Status Clarified
Following legal challenges to the December 9, 2024 final PCE rule, EPA previously reopened a public comment period in July 2025.
As of March 2026, EPA has confirmed that the PCE rule remains under formal reconsideration and is now subject to proposed compliance date extensions as described above. EPA intends to publish proposed amendments to the PCE rule in or around summer 2026, with final revisions anticipated in 2027.
Importantly, the suspension and reconsideration of the PCE rule do not alter EPA’s determination that PCE presents an unreasonable risk to human health.
Carbon Tetrachloride (CTC) – Status Clarified
The final TSCA risk management rule for carbon tetrachloride (CTC), issued December 11, 2024, remains in effect.
EPA’s March 2026 proposal would extend certain WCPP compliance deadlines for non-federal CTC users to align with federal timelines, mirroring the approach taken for PCE. The proposal does not change the scope of permitted uses, exposure limits, or prohibitions established in the final rule.
December 2024 TSCA Restrictions
As one of the more robust and recently modernized statutes controlling industrial chemicals in the US, the Toxic Substances Control Act (TSCA) is systematically used to advance the US Environmental Protection Agency’s (EPA) regulatory agenda.
In past articles, we reported on TSCA activities worth watching, with two of them concerning risk management decisions regarding trichloroethylene (TCE) and perchloroethylene (PCE), which is also known as tetrachloroethylene. On December 9 and 11, 2024, the EPA announced sweeping restrictions on consumer, commercial, and industrial uses of TCE and PCE, as well as another chemical, carbon tetrachloride (CTC), with the final rules becoming effective this year.
On July 30, EPA opened a 30-day public comment period on the final TSCA risk management rule for PCE after several legal challenges were filed against the rule. Public feedback will inform next steps in the rule’s reconsideration, according to EPA. The agency will accept comments until August 29.
This article delves into key aspects of risk management rules, examining the similarities and differences of the regulatory contexts for each substance.
Trichloroethylene (TCE)
TCE (CAS 79-01-6) is a volatile organic compound used in industrial and commercial processes. It can also be found in consumer goods such as cleaning and furniture care products, automotive care products, and arts and crafts materials. This industrial chemical was among the ten substances prioritized for assessment under the Reformed (2016) TSCA paradigm. Currently, most of the TCE on the market is used as a feedstock for refrigerant production. Smaller amounts are used as a degreasing solvent. Because of its past uses, TCE may be found at certain contaminated sites, most commonly in groundwater near dry-cleaning shops, former industrial degreasing operations, and locations of improperly disposed industrial waste.
PROHIBITION OF INDUSTRIAL, COMMERCIAL, AND CONSUMER USES OF TCE
On January 9, 2023, the EPA announced a final determination declaring that TCE poses an unreasonable risk of injury to human health in almost all applications. The EPA’s finding that TCE poses unreasonable risks to the health of workers, non-users in close proximity to TCE, consumers, and bystanders followed a November 2020 risk evaluation, public comments, peer review, and recent policy changes. The uses singled out in the determination were:
- Manufacturing (including import)
- Processing as a reactant/intermediate and into a formulation and articles
- Repackaging and recycling
- Industrial and commercial use as a solvent in adhesives, sealants, lubricants, greases, functional fluids, paints, coating, and a variety of cleaning products
- Commercial and consumer use in several products
- Disposal
On December 9, 2024, EPA announced a risk management decision to act on the unreasonable risk conclusion by implementing mandatory prohibitions and phaseouts within certain compliance timeframes for several conditions of use. Within one year, prohibitions will take effect on manufacturing (including importing) TCE for any use, as well as on processing all consumer and most industrial products containing TCE. Additional prohibitions will be phased in over the next 50 years, addressing specific applications such as parts cleaning in aircraft, medical, transportation, security, space exploration, and defense systems; manufacturing of lead and lithium battery separators, polymeric sheets, and refrigerants; and use as a laboratory chemical. The extended phaseout also applies to TCE releases from process water and remediation systems that discharge to industrial pre-treatment, treatment, or public wastewater systems (POTWs).
In addition to the prohibitions and phaseouts, EPA has also set the industrial worker exposure inhalation limit for airborne TCE—also known as the Interim Existing Chemical Exposure Limit (ECEL)—to 0.2 parts per million (ppm) (1.07 milligrams [mg]/cubic meter [m3]) calculated as an 8-hour time-weighted average (TWA). This also applies to wastewater operators and remediation professions where workers are potentially exposed to contaminated groundwater.
The new limit is 500 times lower than the current Occupational Safety and Health Administration (OSHA) standard of 100 ppm and 5,000 times lower than EPA’s TSCA Action Level TWA of 0.1 ppm.
The wastewater-equivalent ECEL screening level cited by EPA is 0.00282 milligrams per liter (mg/L)—lower than the enforceable Maximum Contaminant Level of 0.005 mg/L for TCE. Under the new restrictions, facilities generating solid waste with TCE above the Resource Conservation and Recovery Act (RCRA) regulatory level of 0.5 mg/L based on the Toxicity Characteristic Leaching Procedure will need to comply with RCRA requirements without the possibility of using dilution as a treatment method.
As an additional requirement, air and wastewater ECELs, air/dermal exposure controls and personal protective equipment (PPE), hazard training, and workplace TCE monitoring requirements must be included in the Workplace Chemical Protection Plan (WCPP).
The TCE risk management rule also comes with record-keeping and downstream notification requirements for affected workers and value chain members (so do the PCE and CTC rules discussed below). However, one major accommodation is the availability of 0.1 percent by weight threshold for TCE in products, which aligns with OSHA’s Hazard Communication Standard for disclosing carcinogens in Safety Data Sheets. Moreover, under defined scenarios, TCE may be claimed as a byproduct and not subject to the rule, like exemptions granted under TSCA Chemical Data Reporting.
Owners and operators of cleanup sites are responsible for ensuring that potentially exposed persons handling TCE-impacted wastewater are protected against ECEL exceedances and dermal contact. However, a groundwater remediation system would have to be classified as a commercial disposal method to either industrial pre-treatment/treatment or Publicly Owned Treatment Works (POTW), subject to a National Pollutant Discharge Elimination System permit to fall under this rule.
IMMUNE SYSTEM EFFECTS VIA INHALATION AND TRANSDERMAL UPTAKE OF TCE
While multiple adverse effects were cited in the rule, such as developmental toxicity, reproductive toxicity, liver toxicity, kidney toxicity, neurotoxicity, and cancer, key points supporting EPA’s determination were associated with immune system effects after acute and chronic inhalation as well as dermal exposure. EPA’s new TCE announcement supersedes the 2020 TCE regulatory determination and affirms the new policy of not considering OSHA’s required use of PPE in risk evaluation.
The EPA intends to delay the effective date of certain Section 6(g) exemption conditions in the final rule until August 19, 2025. These exemptions permit some TCE uses to continue while EPA is reconsidering the final rule, subject to legal challenges and judicial review. The exemptions cover critical or essential uses of TCE for which there are no technically or economically feasible safer alternatives available. This covers uses such as the production of battery separators, microporous sheets, and aerospace parts, as well as the degreasing of medical devices.
Perchloroethylene (PCE)
Many of the general TCE TSCA compliance requirements discussed above also applied to PCE, with specific differences noted below.
PCE is a volatile organic liquid that has many uses as an industrial solvent, degreaser in dry cleaning/parts washing, feedstock in the manufacturing of fluorinated compounds, and a petrochemical catalyst regenerator in isomerization and reforming processes.
EPA completed a final risk evaluation of PCE in December 2022, which resulted in a draft risk management rule published on June 16, 2023, subject to public comment on the unreasonable risk determination. EPA considered comments before announcing the final rule on December 9, 2024.
EPA’s decision was based on all conditions of use and the associated risks of neurotoxicity (vision and cognitive effects) from chronic inhalation and dermal exposure. PCE is also stated to have adverse impacts on the kidneys, the liver, the immune system, reproduction, and development. EPA considers PCE a carcinogen. To control the unreasonable risks associated with PCE exposure, EPA took the following risk management measures.
PROHIBITIONS FOR INDUSTRIAL, COMMERCIAL, AND CONSUMER USES OF PCE
Like TCE, EPA developed an inhalation ECEL and AL at 0.14 ppm (0.98 mg/m3) and 0.10 ppm, respectively, which are also much lower than the current OSHA exposure limit of 100 ppm.
However, recycling and disposal activities are exempt from ECEL and the related implementation measures since EPA deemed that these scenarios do not contribute to unreasonable risk. Moreover, the PCE rule does not establish wastewater-based ECELs.
Nevertheless, the TSCA occupational limit may very well apply to many workers, including those dealing with environmental remediation. For refineries that rely on PCE as a catalyst regenerator, the final rule recognizes the criticality of this substance to ensure a steady fuel supply in the US. As such, it is not banned for that use as long as refineries ensure sufficient worker protection as prescribed in the rule and WCPPs.
The proposed prohibitions and requirements for industrial, commercial, and consumer uses of PCE include restrictions on manufacturing, importing, processing, and distributing most commercial, industrial, and consumer products containing PCE, unless exempted under a 10-year exclusion for certain critical or essential applications. Manufacturing (including importing), processing, and distribution in commerce, as well as commercial use in dry and spot cleaning, will be phased out over a 10-year period.
For permitted uses, facilities must implement Workplace Chemical Protection Programs (WCPP) that include PCE Engineering Control and Exposure Limit Standards (ECELS), occupational monitoring, personal protective equipment (PPE) training, and inhalation and dermal exposure controls. Manufacturers and processors will also be required to maintain records, provide notifications, and conduct ongoing monitoring to demonstrate compliance.
Following legal challenges, however, EPA opened another public comment period for this rule on July 30 and will reconsider the contents of the rule.
Carbon Tetrachloride (CTC)
The third substance subject to recent final risk management rulemaking is carbon tetrachloride (CTC). It was once used as a degreaser, fire suppressant, and pesticide, though all consumer applications have since been banned. The recent announcement concerns the remaining uses, which consist of refrigerant production, aerosol propellants, and foam-blowing agents.
Like TCE and PCE, the final risk management rule imposes WCPPs, worker inhalation limits, monitoring, employee notifications, training, dermal contact precautions, and other workplace controls and PPE requirements for permitted uses, including domestic manufacturing, import, production, processing of hydrofluorocarbons and related industrial agents, as well as disposal. Previously discussed provisions for recordkeeping, value chain notifications, and byproduct exemptions also apply to CTC, except the threshold quantity, which for CTC is defined as incidental “trace quantities.”
EPA’s new restrictions on CTC include prohibitions on petrochemical manufacturing and processing, except for vinyl chloride; chemical manufacturing of chlorinated substances used in solvents, adhesives, paints, and coatings, except for the removal of nitrogen trichloride and chlorine in processing; and industrial and commercial applications in metal recovery, additives, and specific uses for the U.S. Department of Defense.
Risk management of CTC commenced with risk evaluation in November 2020 and a revised risk determination in December 2022. The proposed risk management rule was published on July 28, 2023, and after a public comment period and revisions, the final version was announced on December 11, 2024.
EPA cited the need to protect workers against liver and adrenal cancer associated with chronic inhalation and dermal exposure—as well as liver toxicity due to acute dermal exposure—as the basis for the CTC conditions of use restrictions. Like TCE and PCE, EPA establishes an inhalation ECEL of 0.03 ppm (0.2 mg/m3) to protect against liver and adrenal cancers in workers, with an AL of 0.02 ppm. Prohibitions and WCPP requirements are to take effect as early as mid-2025, and 2026 for certain US Department of Defense applications.
“Whole Chemical Substance” Approach
Unlike previous risk evaluations, EPA’s change in PPE policy resulted in the so-called “whole chemical substance (WCS)” risk determination. This breaks from EPA’s former approach, which, based on use-specific conditions, took into consideration OSHA’s required respiratory, dermal, and other relevant exposure control measures. The agency acknowledged the enhanced conservatism in the WCS approach and incorporated these de facto exposure controls into the current risk management phase. This new approach explains divergences from OSHA’s occupational limits and low ECELs for TCE, PCE, and CTC.
Impacts on Remediation Sites
Owners and operators of cleanup sites where workers are potentially exposed to TCE, PCE, and CTC in water (including contaminated wastewater, surface water, and groundwater) that is handled ex situ via methods such as “pump and treat” for the purpose of remediation, industrial treatment, pre-treatment, or discharge to POTWs are subject to risk management rule WCPP provisions. The applicable worker tasks include system operation and maintenance, as well as any sampling of the incoming or treated water. The rules do not consider worker activities at sites subject to “nature and extent” of groundwater assessments.
EPA’s Next Steps
The final rules for TCE, PCE, and CTC went into effect earlier this year, except for the delayed TCE exemption provisions discussed earlier. The exemptions are expected to be resolved after judicial review. The PCE rule has been suspended while it is being reviewed and reconsidered.
The EPA maintains dedicated resource pages for TCE, PCE, and CTC , listing specific requirements and compliance schedules. Some bans and restrictions are already in effect, with the remainder scheduled to take effect over the next decade.
