Update - July 2015. Good news! EPA issued the following news release: "EPA Reaches Agreement with Manufacturer to Stop Use of TCE in Spray Fixative Products Used on Arts and Crafts. EPA also taking regulatory action to reduce exposure to this chemical". Details on EPA's actions can be found here on its webpage.
Original blog July 2014 follows:
Trichloroethylene (TCE) is a highly toxic solvent commonly found in degreasing agents, spot cleaning agents in dry cleaners, and spray fixatives for arts & craft uses. It is linked to heart malformations in exposed fetuses, kidney toxicity including cancer, immunotoxicity, neurotoxicity, and liver toxicity including cancer. The Environmental Protection Agency (EPA) recently finalized its risk assessment of TCE which, "identified health risks from TCE exposures to consumers using spray aerosol degreasers and spray fixatives" and "health risks to workers when TCE is used as a degreaser in small commercial shops and as a stain removing agent in dry cleaning." (EPA July 25, 2014)
TCE has been linked to cancer and other diseases for a long time. In fact, a letter from Dr. Carey McCord (medical advisor for Chrysler Corp.) published in a 1932 issue of the Journal of the American Medical Association warned that, "any manufacturer contemplating the use of trichloroethylene may find in it many desirable qualities. Too, in the absence of closed systems of operations [no ventilation], he may find in this solvent the source of disaster for exposed workmen" (JAMA July 30, 1932). Even the company doctors were warning against exposing workers to TCE - eighty years ago! Had chemical manufacturers and users heeded the warning, untold diseases and deaths may have been prevented.
EPA should ban TCE in these products, using enforceable regulations, so that no more people have to suffer from predicted and preventable disease or death from TCE. That's what the companies that either use or make safer alternatives told EPA at a public meeting this week. I said the same thing in detailed comments to EPA.
Big thanks to Mr. Mike Partain for also providing comments to EPA at the public meeting this week. Mike has suffered and survived male breast cancer. He was born at Camp Lejeune, a North Carolina marine base infamously polluted with TCE, where his mother drank the contaminated water throughout her pregnancy. The TCE-poisoning of Marines and their families is the cover story of this week's Newsweek magazine. When industry representatives at the EPA Public Meeting this week said they couldn't do business without TCE, Mike asked if their spray, glue, or degreaser was worth more than a Marine's life. Good question, Mike!
The use of consumer general purpose degreaser products that contain TCE are already banned in California and safer substitutes are in use. Water-based cleaning systems are effective, safe, and economical alternatives for vapor degreasing and cold cleaning, and acetone and soy provide safer alternatives for aerosol uses. Water-based cleaners are used extensively in California instead of TCE-based vapor degreasing, due to regulations that limit the use of solvents that are VOCs.
This is the first time EPA has issued an assessment since 1986 under its infamously broken chemical law, the Toxic Substances Control Act (TSCA), when it identified the human health hazards of asbestos (see blog by Dr. Richard Denison, EDF). And, now that EPA has come this far, it must not capitulate to industry arguments that voluntary initiatives will be good enough - they won't be. EPA spent twenty-three years trying to finalize its hazard assessment of TCE (documented in our NRDC Delay Game report). FDA banned TCE from food uses in 1977, almost four decades ago. Ten years later, in 1987, EPA determined that TCE "probably causes cancer". Since then, EPA has been delayed by TCE manufacturers, the American Chemistry Council (ACC) trade group for the chemical industry, and industry allies in Congress. Nonetheless, many forward-thinking companies that use TCE in their operations sought out safer alternatives, and have since moved completely away from TCE-based cleaners.
The hold-out companies that still use TCE have proved by their inaction that they will not move away from TCE unless regulation forces them. EPA has already let decades of harmful exposures occur. EPA needs to cross the finish line with enforceable rules. It is decades too late for EPA to claim it is leading the effort to protect people from TCE-induced cancer, developmental malformations, and chronic disease, but it can bring up the rear by pushing the last 'bad actor' companies towards safer substitutes.
EPA must also be mindful of not allowing 'regrettable substitutes' of TCE onto the market - chemicals that are as bad as or worse than the ones they are replacing. For example, n-hexane and 1-bromopropane have both been used as replacements for TCE, despite severe health risks from exposure to these chemicals, including severe nerve damage and reproductive harm. EPA must take measures to prevent highly hazardous substitutes from coming onto the market.
Specific Technical Comments - praise for EPA
In the final TCE risk assessment, EPA included developmental risks from TCE exposures during fetal development for both acute (high-level short-term) and chronic (low-level long-term) exposure scenarios. The earlier draft only considered acute scenarios. Including chronic exposures is important because the window of developmental vulnerability may occur at any time during child-bearing years - often without warning - for an exposed adult. For example, Mike Partain and other military children born on Camp Lejeune were exposed in utero, during one of the most sensitive and vulnerable life stages to toxic chemicals.
Additionally, EPA based its Point of Departure (POD) for developmental toxicity on fetal cardiac abnormalities in rodents in the final TCE risk assessment. The study - Johnson et al 2003 - reported a statistically significant increase in severe heart malformations associated with fetal exposure to TCE in the drinking water of the pregnant dams. The study findings are supported by similar findings in chick embryos, mechanistic data supporting a possible mode of action, and some weakly positive epidemiologic data (EPA page 97, Section 2.6). Fetal cardiac effects - including deformities in the septum and heart valves - are very serious and may cause lifelong impairments or death. EPA selected this effect because it is the most sensitive - and, therefore protection against this effect is presumed to protect against other effects as well. This is consistent with its long-standing policy that a single exposure of a chemical at a critical window of fetal development may produce long-lasting adverse developmental effects (EPA, 1991).
EPA included exposures for spot dry cleaners in its final assessment. These exposures were determined to pose unacceptably high risks for both commercial users and for bystanders, based on fetal cardiac abnormalities. Chemical formulations that contain high concentrations of TCE are commonly used by dry cleaners to remove spots from fabrics. Exposure to TCE and another common dry cleaning solvent, tetrachloroethylene (also called perchloroethylene or perc), could result in increased risk for harmful effects, as both chemicals are processed by the body to create the same, potentially toxic, metabolites. Under its Consumer Products Regulation, the California Air Resources Board banned dry cleaning uses of TCE-containing spot removers in California effective December 31, 2012. Safer substitutes to TCE-based spot removers are available, and include water-based cleaners, soy-based cleaners and acetone-based cleaners. The cost analysis indicates that the alternatives are less costly than the TCE spotting agents.
The Halogenated Solvents Industry Alliance, Inc. (HSIA) - a trade group representing solvents manufacturers including TCE - has been on the attack, doing back bends in its effort to undermine the scientific credibility of EPAs risk assessment. HSIA funded Exponent Inc. to do an analysis of EPA's assessment, which tries to argue that the exposure data are too uncertain to use in a risk assessment, even though most of the data comes from actual workplace measurements of airborne TCE and industry-reported TCE emissions.
Industry groups also claim the Johnson et al 2003 study of fetal cardiac abnormalities is too flawed for EPA to use. For one thing, they say, some of the test rodents that were reported to have been dosed in 1994 were actually dosed in 1995, and the precise dates of the dosing can no longer be confirmed. The authors acknowledged this reporting misstatement in a published erratum, although it doesn't alter the study's conclusions of the developmental harm of TCE. HSIA is using the published erratum, however, to support its argument that the study is too unreliable for use by EPA.
EPA's successful efforts to use its existing statutory authorities to inform the public about this hazardous and common chemical did not go unnoticed by industrial chemical manufacturers and the chemical-friendly Members of Congress. Senator David Vitter (R-La.), top Republican on the Environment and Public Works Committee, along with Senators Mike Crapo (R-Idaho) and Jim Inhofe (R-Okla.), have requested the raw data that support the EPA TCE assessment, and questioned the scientific integrity of one of the EPA scientists involved in drafting the TCE assessment. EPA is drafting its response to these unwarranted concerns, and my own response is detailed in my comments to EPA.
TCE is the first toxic chemical that EPA is reviewing under this program. There are eighty-three more chemicals lined up behind TCE as candidates for an EPA risk assessment over the next several years. All eighty-three scored high for their combined toxicity, exposure, persistence in the environment, and bioaccumulation in plants or animals. EPA needs to stick to its task, ban all the unsafe and unnecessary uses of TCE that were identified, and do the same for future chemical assessments.