The EPA Plans to Ban Three Common Industrial Chemicals: Here's What to Know

On June 8, 2023, the U.S. Environmental Protection Agency (EPA) announced a proposed ban on most uses of the common industrial chemical perchloroethylene. This announcement follows two similar announcements made by the EPA in April, when the agency also proposed bans or restrictions on two other chemicals, ethylene chloride and methylene chloride.

These proposals have triggered many questions from members and stakeholders within affected industries, such as: why were these bans proposed, and what is the potential impact of these bans? What are the routes of exposure and known health risks of these chemicals? Other than stricter regulations, what can be done to protect workers from these chemicals?

In this article, we explore these questions to help industry leaders remain well-informed about these potential changes, and to ensure that workers within a range of industries are adequately protected with appropriate chemical safety clothing and personal protective equipment (PPE)—now and in the years to come.

Current Chemicals Facing Potential Ban Under the EPA

Regulating and restricting chemicals for industrial and commercial use is a power held by the EPA since 1976, thanks to the passing of the Toxic Substances Control Act (TSCA). But with more than 80,000 chemicals on the market in the United States, a relatively small number of chemicals have been heavily restricted or outright banned, including asbestos, mercury, formaldehyde, per- and polyfluoroalkyl Substances (PFAS), and polychlorinated biphenyls (PCBs).

This year, however, at least three additional chemicals are facing new restrictions per the EPA. These chemicals include ethylene oxide, methylene chloride, and perchloroethylene. Each chemical is highlighted below, with specific information on its intended uses, its potential impacts on human health, its common routes of exposure, and the proposed control measures as outlined by the EPA and collaborating organizations, including the Occupational Safety and Health Administration (OSHA) and U.S. Centers for Disease Control and Prevention (CDC).

Ethylene Oxide

According to the National Institute for Occupational Safety and Health (NIOSH), ethylene oxide (C₂H₄O) is a flammable gas that has a slightly sweet odor. It is primarily used to sterilize medical equipment and supplies, although the CDC notes that the chemical is also used during the production of substances like solvents, antifreeze, textiles, detergents, adhesives, and polyurethane foam. Some farm workers also use ethylene oxide to control insects in grain bins. Areas or situations where ethylene oxide may be used include museums, archival settings, beekeeping, musical instruments, and even cosmetics.

Short- and long-term exposure to ethylene oxide has been associated with a range of harmful health effects, including headaches, nausea, vomiting, diarrhea, fatigue, weakness, respiratory distress, burns to the eyes and skin, frostbite, and reproductive problems.

The EPA also notes that long-term exposure to ethylene oxide—including occupational and residential exposure (e.g., living near a place where ethylene oxide is used)—can significantly increase the risk of certain types of cancer.

On April 11, 2023, the EPA announced new proposals that would restrict exposure to ethylene oxide and implement new health protections to "increase safety in communities and for workers." Should these proposals be finalized, the EPA estimates that ethylene oxide emissions from sterilization facilities will be cut by as much as 80 percent per year.

Additional workplace control measures would include the prohibition of ethylene oxide where alternatives exist and the requirement of new engineering controls to monitor exposure levels.

Methylene Chloride

NIOSH describes methylene chloride (CH2Cl2) as a colorless liquid used in many industries, with purposes ranging from degreasing to paint removal. Workers at risk of exposure include bathtub refinishers, factory workers involved in metal cleaning and degreasing, any individual who uses paint-stripping products, and workers within the pharmaceutical manufacturing industry.

On April 20, 2023, the EPA proposed a ban on all consumer and most industrial and commercial uses of methylene chloride. The proposed ban would allow for "some uses to continue only where strict workplace controls could be implemented to minimize exposures to workers."

The proposal comes as a result of the EPA recognizing methylene chloride as "a dangerous chemical known to cause serious health risks and even death." The agency added that methylene chloride exposure was responsible for the deaths of at least 85 American workers between 1980 to 2018.

NIOSH writes that exposure to this substance can harm the "eyes, skin, liver, and heart" and can lead to additional effects such as drowsiness, dizziness, numbness and tingling, and nausea. Severe exposure can lead to loss of consciousness, coma, and death, and long-term exposure may cause cancer.

Once finalized, the EPA's proposal would require widespread phasing out of methylene chloride within 15 months.

Perchloroethylene

Perchloroethylene (Cl₂C=CCl₂), also known as tetrachloroethylene or PCE, is a colorless liquid that has a mild odor similar to chloroform. It is often used in dry cleaning, metal degreasing, paint and coating removal, wood furniture manufacturing, and chemical manufacturing.

The June 2023 announcement to ban perchloroethylene was made by the EPA due to the concern that exposure to this chemical can cause "serious health risks such as neurotoxicity and cancer." Exposure to this chemical has also been known to cause irritation of the eyes, skin, nose, throat, and respiratory system, as well as liver damage.

The EPA's new proposal stipulates that commercial use of perchloroethylene would be phased out within two years and would be removed from use in dry cleaning within 10 years. Perchloroethylene would still be allowed for use in certain industries—including petrochemical and aerospace manufacturing—under strict workplace controls.

Understanding "Unreasonable Risk" Associated With These Chemicals

Under the TSCA, the EPA aims to evaluate "potential risks from new and existing chemicals and acts to address any unreasonable risks chemicals may have on human health and the environment." The term "unreasonable risk" suggests that the risk of injury presented by a chemical should be formally evaluated, with particular study of the utility of the chemical, the nature and severity of the risk, the level of exposure to workers and/or the public, and the likelihood of a chemical resulting serious injury or death.

Following formal risk evaluations, the EPA has concluded that these three chemicals are the latest ones which pose unreasonable risk and therefore require further action to be taken to protect both the American workforce and the public.

As an example, methylene chloride was determined by the EPA to pose unreasonable risk of injury or harm under 52 of 53 conditions of use studied (including adhesive/caulk removal, plastic and rubber manufacturing, cold pipe insulation, and aerosol and non-aerosol degreasing). Such harm has even been documented in situations in which workers were fully equipped with the appropriate PPE.

Keeping Your Workforce Safe: Chemical Protective Clothing Required When Handling These Chemicals

A frequent stipulation included within the EPA's proposed chemical bans on ethylene oxide, methylene chloride, and perchloroethylene is the strict regulation (and, in some cases, mandated use) of chemical protective clothing for workers who are currently exposed to these substances.

Industry leaders should be particularly aware of these regulations and evolving workplace controls, given that the phasing out of these chemicals could take years or decades. With that said, the following PPE that should be used by any worker facing potential exposure to ethylene oxide, methylene chloride, and perchloroethylene:

  • NIOSH-approved respirators, ideally a full facepiece, or a powered-air purifying respirator (PAPR)
  • Gloves, to avoid contact with skin
  • Gowns, coveralls, and boot or shoe covers, to avoid contact with clothing or exposed skin

All PPE should be clean, intact, easy to access at any point during a worker's shift, and well-fitting enough to provide adequate protection while not restricting worker comfort and productivity. Disposable PPE is particularly ideal as it reduces the risk of cross-contamination.

In addition to providing ready access to clean and appropriately rated PPE, workplaces should also ensure that their workforce is adequately trained in chemical safety measures, including proper PPE donning and doffing, proper chemical handling and storage, and other basic workplace safety measures (e.g., not eating, drinking, smoking, and/or applying cosmetics in work areas or before thoroughly removing PPE and washing hands).

Conclusion

The chemicals ethylene oxide, methylene chloride, and perchloroethylene are commonly used within a wide range of American industries but are now facing strict regulations and potential bans under new proposals from the EPA. These regulations result from the "unreasonable risk" that the chemicals are thought to pose to human health, which includes the risk of neurological problems, cancer, and even death.

It's important to realize that the phasing out of these chemicals (pending approval of the EPA proposals) will likely take months to years. In the meantime, it is critical to ensure that your workplace safety measures and PPE are compliant with OSHA regulations.