TSCA Compliance Requirements for Regulated Chlorinated Solvents

Overview

The U.S. Environmental Protection Agency (EPA) has issued new regulatory requirements under the Toxic Substances Control Act (TSCA) for four chlorinated solvents commonly used in research laboratories:

  • Dichloromethane (DCM / methylene chloride)
  • Carbon tetrachloride (CTC)
  • Perchloroethylene (PCE)
  • Trichloroethylene (TCE)

These actions follow EPA risk evaluations concluding that these chemicals pose unreasonable risks to human health and the environment, including risks of neurotoxicity, carcinogenicity, and other severe health effects.

EPA’s updated rules require enhanced reporting, exposure monitoring, documentation, and training for all laboratories that use or possess these chemicals.

Purpose of the Regulations

EPA’s TSCA risk management rules are designed to:

  • Reduce worker exposure to hazardous chlorinated solvents.
  • Ensure institutions implement engineering, administrative, and training controls to mitigate identified risks.
  • Phase out or restrict high‑risk uses, including long‑term bans for certain chemicals such as TCE.
  • Improve national reporting and oversight of hazardous chemical use.

Under TSCA, EPA has the authority to require reporting, recordkeeping, testing, exposure monitoring, and risk‑reduction measures for chemicals that present unreasonable risks.

Immediate Requirement

Retention of Shipping Documentation

Effective immediately, laboratories must retain and maintain all shipping documentation that accompanies any shipment of these regulated chemicals received at Rice University.

This documentation must be stored in a manner that is accessible for inspection and compliance verification.

Chemical‑Specific Requirements and Deadlines

Below is a summary of required actions for each regulated solvent. All deadlines reflect Rice University’s compliance schedule aligned with EPA rulemaking.

Dichloromethane (DCM)

1. Usage Notification

Laboratories that have not previously reported DCM use or possession must notify EHSLO by March 20, 2026.

2. Initial Exposure Monitoring

  • Existing activities: EHSLO will complete monitoring by May 5, 2026.
  • New activities: Notify EHSLO within 40 days of initiating use.

3. Exposure Zones

Must be established within 60 days of initial monitoring.

4. Compliance Documentation

  • Upload a DCM Exposure Control Plan to SciShield.
  • Document lab‑specific DCM training.
  • Deadline: August 1, 2026.
  • Template available here.

Carbon Tetrachloride (CTC)

1. Usage Notification

Notify EHSLO of CTC use or possession by March 20, 2026.

2. Initial Exposure Monitoring

  • Existing activities: Monitoring completed by June 11, 2026.
  • New activities: Notify EHSLO within 40 days.

3. Exposure Zones

Must be established within 60 days of initial monitoring.

4. Compliance Documentation

  • Upload a CTC Exposure Control Plan to SciShield.
  • Document lab‑specific CTC training.
  • Deadline: September 9, 2026.
  • Template available here.

Perchloroethylene (PCE)

1. Usage Notification

Notify EHSLO of PCE use or possession by March 20, 2026.

2. Initial Exposure Monitoring

  • Existing activities: Monitoring completed by May 11, 2026.
  • New activities: Notify EHSLO within 40 days.

3. Exposure Zones

Must be established within 60 days of initial monitoring.

4. Compliance Documentation

  • Upload a PCE Exposure Control Plan to SciShield.
  • Document lab‑specific PCE training.
  • Deadline: October 1, 2026.
  • Template available here.

Trichloroethylene (TCE)

1. Usage Notification

Notify EHSLO of TCE use or possession by March 20, 2026.

2. Initial Exposure Monitoring

  • Existing activities: Monitoring completed by May 11, 2026.
  • New activities: Notify EHSLO within 40 days.

3. Exposure Zones

Must be established within 60 days of initial monitoring.

4. Compliance Documentation

  • Upload a TCE Exposure Control Plan to SciShield.
  • Document lab‑specific TCE training.
  • Deadline: September 9, 2026.
  • Template available here.

5. Long‑Term Regulatory Action

EPA has finalized a full ban on TCE, including research uses, effective 2074.

Additional Resources

  • Rice University Laboratory Safety Policy 313
  • SciShield Documentation Upload Portal
  • Exposure Control Plan Templates (linked above)
  • EPA TSCA Overview and Risk Management Rules

Contact

To report chemical use, request exposure monitoring, or ask compliance questions contact your EHSLO representative, email safety@rice.edu, or call X4444.