On January 16, 2025, the U.S. Environmental Protection Agency (EPA) released a compliance guide to assist the regulated community in complying with Workplace Chemical Protection Program (WCPP) requirements for chemicals regulated under Section 6 of the Toxic Substances Control Act (TSCA). EPA states that a WCPP “is a chemical protection program designed to address unreasonable risk posed by chemical exposure to persons in occupational settings.” The compliance guide provides an overview of typical WCPP requirements that the regulated community may be subject to as part of a TSCA Section 6(a) rulemaking. As reported in our previous memoranda, in 2024, EPA issued final risk management rules with WCPP requirements for methylene chloride, perchloroethylene, trichloroethylene, and carbon tetrachloride.

According to EPA, the compliance guide is intended for owners and operators of businesses that manufacture (including import) or process, distribute in commerce, use, or dispose of a chemical regulated under TSCA Section 6 that is subject to the WCPP in EPA rules. EPA notes that the guide will also be of interest to people who may be exposed to these regulated chemicals in the workplace. The guide broadly addresses the requirements of a typical WCPP, including:

• EPA TSCA occupational exposure limits (Existing Chemical Exposure Limits (ECEL) or EPA Short-Term Exposure Limits (EPA STEL)) designated under TSCA;
• ECEL action levels;
• Occupational exposure monitoring;
• Regulated areas;
• Direct dermal contact controls (DDCC);
• Respirators;
• Personal protective equipment (PPE);
• Exposure control plans;
• Recordkeeping; and
• Downstream notifications.

EPA states that while the compliance guide “provides useful information to consider when implementing a WCPP, the regulated community should also consult the WCPP provisions within the applicable risk management rule.” Individual compliance guides for rules may also provide additional chemical-specific guidance. EPA has issued guides for methylene chloride, trichloroethylene, and for the use of perchloroethylene in dry cleaning (also available in Korean and Spanish) and energized electrical cleaning.

EPA’s diligence in preparing the compliance guide is commendable given all of the other demands on EPA’s time. Stakeholders are urged to review the guide as its contents could be of use to regulated entities.