In December 2024, the U. S. Environmental Protection Agency (EPA) finalized a new rule under the Toxic Substances Control Act (TSCA) to protect workers, the public, and the environment from the risks of trichloroethylene (TCE) exposure. While certain portions of the rule are currently under legal review, most of its requirements are still expected to go into effect starting on September 15, 2025.
The new rule is anticipated to result in the eventual prohibition of TCE in consumer, industrial, and commercial use. Most uses of TCE, including most laboratory use, are prohibited after September 15, 2025.
Allowed Uses
Use in “essential laboratory activities,” narrowly defined as laboratories involved in TCE cleanup and exposure monitoring activities, will be allowed to continue under a 50-year exemption.
Use in “energized electrical cleaners,” narrowly defined for use when cleaning of equipment must occur where there is live electrical current or where there is a residual electrical potential, will be allowed to continue under a 3-year exemption.
There will be strict interim exposure control and exposure monitoring requirements for uses with extended prohibition timeframes; however, the implementation timelines for these uses are currently being litigated.
Actions
Environmental Health & Safety (EH&S) is asking University units and departments that use or possess TCE to take the following steps to prepare for the new rule:
- By August 31, 2025: University units check their workspaces for TCE, ensure all items are inventoried in MyChem, determine whether their interim use is allowed under the new rule, and find replacements. University units with prohibited TCE uses submit a Chemical Waste Collection Request Form. Once waste items have been picked up, remove items from the MyChem inventory.
- Early September: EH&S will reach out to groups with TCE in their MyChem inventories to verify an allowable interim use, and provide additional information and compliance timelines as appropriate.
About Trichloroethylene
TCE is a component in some degreasers, electrical cleaners, paint removers, and adhesives. It is also used as a laboratory reagent.
TCE is a known human carcinogen and is also associated with other non-cancer effects including kidney, liver, immunological, reproductive, and neurological toxicity.
The new rules are in addition to Washington state safety standards for airborne contaminants (WAC 296-841-20025).
More information about the EPA’s risk evaluation can be found on the EPA website.
Please contact Environmental Health & Safety with questions.