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EPA Seeks Comment as It Reconsiders PCE Risk Management Rule
Friday, August 1, 2025

The U.S. Environmental Protection Agency (EPA) announced on July 30, 2025, that it seeks public comment to inform its reconsideration of the Toxic Substances Control Act (TSCA) regulation for perchloroethylene (PCE). 90 Fed. Reg. 35858. EPA notes that as promulgated in December 2024, the PCE risk management rule addresses the unreasonable risk of injury to health presented by PCE under its conditions of use (COU) by requiring various workplace exposure controls, prohibiting certain industrial and commercial uses, and preventing consumer access to the chemical, among other provisions. According to EPA, the request for public comment follows the filing of several legal challenges to the rule in 2025, and EPA’s subsequent determination that the PCE regulation under TSCA should be reconsidered through further rulemaking. EPA states that it “intends to consider information received in response to this public comment solicitation, and other reasonably available information, to inform the development of any proposed rule to amend the PCE regulation as appropriate.” Comments are due August 29, 2025.

EPA invites public comment on all aspects of the final rule, including but not limited to any existing or anticipated implementation issues, experiences with the final rule since it took effect, and whether EPA should consider additional or alternative measures or approaches to address the unreasonable risk presented by PCE under the COUs. EPA states that input on the following “is of particular interest”:

  • The Existing Chemical Exposure Limit (ECEL) of 0.14 parts per million (ppm) as an eight-hour time weighted average (8-hr TWA) promulgated in the PCE final rule as part of the Workplace Chemical Protection Program (WCPP), including whether the use of a different exposure limit would be more appropriate to inform risk management. EPA states that different exposure limits might include but are not limited to: the acute non-cancer exposure limit of 0.50 ppm (8-hr TWA) and the lifetime cancer exposure limit of 0.47 ppm (8-hr TWA) as presented in the April 15, 2021, “Existing Chemical Exposure Limit (ECEL) for Occupational Use of Perchloroethylene” memorandum.
  • COUs that EPA could contemplate subjecting to a WCPP as opposed to imposing a prohibition. According to EPA, “[i]nformation such as workplace controls currently in place or other information demonstrating how regulated parties could mitigate the unreasonable risk of PCE for the condition of use would be most helpful to the Agency.”
  • The use of PCE in industrial dry cleaning processes, including workplace controls that reduce exposure to PCE and the performance of alternatives to PCE in these operations.

To the extent possible, EPA asks commenters to please cite and provide any public data related to or that support comments provided, and to the extent permissible, describe and provide any supporting data that are not publicly available. More information on EPA’s final risk management rule for PCE is available in our January 13, 2025, memorandum.

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