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Subject: [DCHAS-L] CSB Releases New Safety Video on 2019 Explosions and Fires at the TPC Group Chemical Plant in Port Neches, Texas

Date: Jul 19, 2023 19:38 UTC

Author: Ralph Stuart <ralph**At_Symbol_Here**RSTUARTCIH.ORG>

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Subject: [DCHAS-L] Submit Abstracts for SERMACS 2023

Date: Jul 20, 2023 13:32 UTC

Author: Mary Beth Koza <mbkoza2**At_Symbol_Here**GMAIL.COM>

From: Harry Elston <harry**At_Symbol_Here**MIDWESTCHEMSAFETY.COM>

Subject: Re: [DCHAS-L] EPA Proposes Workplace Safety Requirements for Carbon Tetrachloride to Protect Worker Health, Fenceline Communities

Date: Jul 19, 2023 19:42 UTC

Reply-To: harry**At_Symbol_Here**MIDWESTCHEMSAFETY.COM

Message-ID: <00ac01d9ba79$19b8a240$4d29e6c0$@midwestchemsafety.com>

In-Reply-To: <SJ0PR04MB7773DEB0490049FAC8EE3AE0F739A**At_Symbol_Here**SJ0PR04MB7773.namprd04.prod.outlook.com>

Demystify: 

No, you’re not the only one that believes they’re making stuff up as they go along.

 

The administration can’t get employee limits pushed through OSHA/DOL route as it really takes time and has to go through the rule making process.  EPA has been generally unchecked and now they are diving into uncharted territory – employee exposure control.  So far, they’ve been unchallenged for plowing in OSHA’s garden.  I’m hoping “someone” will take EPA to task about that soon.

 

Harry

 

From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Kolodziej, Christopher
Sent: Tuesday, July 18, 2023 20:47
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] EPA Proposes Workplace Safety Requirements for Carbon Tetrachloride to Protect Worker Health, Fenceline Communities

 

Am I the only one who feels like the EPA is making it up as they go along? Of the three rules they’ve proposed in recent months for chlorinated solvents, none of them are fully consistent with each other (at least in terms of what they’re proposing for use as laboratory chemicals). Nor is it clear what rationale might account for the differences. The proposed exposure limits for perchloroethylene and carbon tetrachloride are 1-2 orders of magnitude lower than that proposed for methylene chloride, yet EPA only proposes requiring exposure monitoring for methylene chloride. At a high level, the approaches towards perchloroethylene and carbon tetrachloride are similar, but the documentation requirements for PPE selection for carbon tetrachloride are significantly more detailed/burdensome/inapplicable in many university labs.

 

Does anyone have any insight into why these proposed rules aren’t taking a more consistent approach?

 

Chris

 

 

________________________________

Christopher M. Kolodziej, Ph.D.
Chemical Hygiene Officer

UCLA Environment, Health & Safety | Chemical Safety

 

Mobile: (203) 241-6515

Book a virtual appointment

 

My working hours may not be your working hours. Please do not feel obligated to reply outside of your normal work schedule.

 

From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Ralph Stuart
Sent: Monday, July 17, 2023 11:04 AM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: [DCHAS-L] EPA Proposes Workplace Safety Requirements for Carbon Tetrachloride to Protect Worker Health, Fenceline Communities

 

Proposal would also ban discontinued uses so they cannot restart

 

EPA

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Biden-Harris Administration Proposes Workplace Safety Requirements for Carbon Tetrachloride to Protect Worker Health, Fenceline Communities

Proposal would also ban discontinued uses so they cannot restart

Today, the U.S. Environmental Protection Agency (EPA) announced a proposal that will better protect workers from exposure to carbon tetrachloride (CTC), a chemical known to cause serious health risks such as liver toxicity and cancer. This proposal, if finalized, would protect people from these risks by minimizing exposures to workers and communities, while banning uses that have already ceased. The proposal announced today is the fourth proposed risk management rule under the amended Toxic Substances Control Act (TSCA), demonstrating significant implementation progress as the agency, under the Biden-Harris Administration, works to ensure these hazardous chemicals, including CTC, are being used safely and all communities are protected.

"The science is clear. Exposure to carbon tetrachloride is dangerous and we have a responsibility to protect the public from the risks it poses,” said Assistant Administrator for the Office of Chemical Safety and Pollution Prevention Michal Freedhoff. “Today's proposal is an important first step to ensuring carbon tetrachloride can be used safely by workers and that surrounding communities are protected.”

CTC is a solvent used in commercial settings as a raw material for producing other chemicals like hydrofluoroolefins (HFOs) used in refrigerants, aerosol propellants, foam-blowing agents, chlorinated compounds and agricultural products. Requirements under the Montreal Protocol and the Clean Air Act led to a phaseout of CTC production in the United States in 1996 for most domestic uses that did not involve manufacturing of other chemicals, and the U.S. Consumer Product Safety Commission banned the use of CTC in consumer products in 1970.

In its 2020 risk evaluation, EPA determined that CTC presents an unreasonable risk to health, including liver toxicity and cancer from chronic inhalation and dermal exposures, largely to workers and occupational non-users (workers nearby but not in direct contact with this chemical). EPA also identified potential risks to fenceline communities (population in close proximity to source of pollution) from CTC in its 2022 fenceline screening analysis for the ambient air pathway.

If finalized, this rule would require a workplace chemical protection program with strict controls that include inhalation exposure limits and dermal protections for the manufacturing (including import) of CTC, processing, and other industrial or commercial uses which account for essentially the entire domestic production volume of CTC. The workplace chemical protection program would cover uses related to the phasedown of climate pollutants under the American Innovation and Manufacturing (AIM) Act, the production of chlorine and caustic soda, the manufacture of agricultural products, and repackaging for use as a laboratory chemical, recycling and disposal.

EPA is also proposing workplace controls that would require the use of a fume hood and dermal personal protective equipment for laboratory uses and would establish downstream notification and recordkeeping requirements. Additionally, the proposed rule would prohibit uses of CTC that the Agency determined have already ceased. 

The proposed controls, if finalized, will also advance the Biden-Harris Administration’s commitment to environmental justice by reducing exposures to fenceline communities. For example, the proposed rule includes a requirement for owners and operators to attest that engineering controls selected to comply with the rule do not increase emissions of CTC to ambient air outside of the facility. EPA is also seeking comments on additional steps that can be taken, including requiring fenceline monitoring.

EPA encourages members of the public to read and comment on all aspects of the proposed rule. EPA will accept public comments on the proposed rule for CTC for 45 days following publication in the Federal Register via docket EPA-HQ-OPPT-2020-0592 at www.regulations.gov.

EPA will also host a public webinar targeted to employers and workers, but useful for anyone looking for an overview of the proposed regulatory action to discuss the proposed program. The date, time and registration information will be announced soon.

Learn more about today's proposal

--- For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org

--- For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org

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