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January 30, 2020

Comments on EPA’s Draft Risk Evaluation of Carbon Tetrachloride Due March 27, 2020

Lynn L. Bergeson Carla N. Hutton

On January 24, 2020, the U.S. Environmental Protection Agency (EPA) released the draft risk evaluation of carbon tetrachloride, “a solvent primarily used in the manufacturing of chlorinated compounds and petrochemicals.”  Carbon tetrachloride is the seventh of the first ten chemicals to undergo risk evaluation under the amended Toxic Substances Control Act (TSCA).  EPA published a Federal Register notice on January 27, 2020, announcing the availability of the draft risk evaluation and beginning a 60-day comment period.  85 Fed. Reg. 4658.  The TSCA Science Advisory Committee on Chemicals (SACC) will hold a preparatory virtual meeting on February 4, 2020, to consider the scope and clarity of the draft charge questions for the peer review.  On February 25-26, 2020, SACC will hold an in-person public meeting to consider and review the draft risk evaluation.  EPA will provide comments submitted on the draft risk evaluation on or before February 19, 2020, to SACC for their consideration before the meeting.  Comments received after February 19, 2020, and prior to the oral public comment period during the meeting will be available to the SACC for their consideration during the meeting.  Comments on the draft risk evaluation are due March 27, 2020.
EPA states that it “reviewed 15 potential uses, all of which are associated with industrial and commercial work and are primarily associated with the manufacturing process of other chemicals.”  According to EPA, there are no consumer uses of carbon tetrachloride.  EPA made the following initial determinations on risk:

  • EPA did not find risk to the environment or workers.  For all the conditions of use included in the draft risk evaluation, EPA states that it has preliminarily found no unreasonable risks to the environment under any of the conditions of use or to workers when appropriate personal protective equipment is used; and
  • EPA’s draft risk evaluation preliminarily found unreasonable risks associated with chronic inhalation exposure for occupational non-users (ONU).  EPA found that ONUs — those workers in the vicinity of carbon tetrachloride’s use but not directly working with the chemical — could be adversely affected by carbon tetrachloride under certain conditions of use.

More information, including an insightful commentary, is available in our January 27, 2020, memorandum, “EPA Releases Draft Risk Evaluation of Carbon Tetrachloride.”