EPA Releases Final Risk Evaluation for 1,2-Dichloroethane, Finds Unreasonable Risk of Injury to Human Health for 15 COUs Involving Workplace Exposure

The U.S. Environmental Protection Agency (EPA) announced on May 5, 2026, the availability of the final risk evaluation under the Toxic Substances Control Act (TSCA) for 1,2-dichloroethane (also known as ethylene dichloride (EDC)). 91 Fed. Reg. 24230. EPA notes that the purpose of TSCA risk evaluations is to determine whether a chemical substance presents an unreasonable risk of injury to health or the environment under the conditions of use (COU), including unreasonable risk to potentially exposed or susceptible subpopulations identified as relevant to the risk evaluation by EPA, and without consideration of costs or non-risk factors. EPA states that it used the best available science to prepare the final risk evaluation for EDC and “determined, based on the weight of scientific evidence, that [EDC] presents an unreasonable risk of injury to human health driven by risk to workers through workplace exposure under 15 COUs.” According to EPA, it did not identify contributions to unreasonable risk of injury for consumer exposure, exposure to the general population, or to the environment, under any COUs for EDC. Consistent with TSCA, EPA will now initiate risk management actions to address the unreasonable risk.

According to EPA’s May 1, 2026, press release, EDC “is a colorless liquid at the heart of American manufacturing and serves as the essential building block for vinyl chloride monomer, the feedstock for polyvinyl chloride (PVC).” More than 90 percent of the 30 to 40 billion pounds of EDC produced or imported in the United States each year goes into making PVC. EPA notes that the United States is “one of the world’s leading producers of PVC and its precursors, with the industry concentrated along the Gulf Coast in Texas and Louisiana and supporting American manufacturing jobs. EPA’s action is designed to protect workers in this vital industry.” EPA states that PVC is used in infrastructure, healthcare, and homes:

• Water and sanitation infrastructure, including drinking water mains, service lines, sewer pipes, and irrigation systems. PVC pipe is a backbone of municipal water systems and a core material in the federal lead-pipe replacement effort;

• Electrical and telecommunications, including wire and cable insulation, conduit, and jacketing;

• Building and construction, including vinyl siding, window frames, doors, flooring, roofing membranes, and wall coverings;

• Healthcare, including IV bags, blood bags, dialysis tubing, oxygen masks, and a wide range of single-use medical devices that depend on PVC’s flexibility, biocompatibility, and ability to be sterilized; and

• Transportation and consumer goods, including automotive interiors and wire harnesses, packaging, footwear, and countless household products.

EPA states that as required by law and consistent with its commitment to safeguarding sensitive populations, the Agency specifically evaluated risks to people who may be more vulnerable due to age, life stage, genetics, or preexisting health conditions, including children, pregnant women, women of childbearing age, workers, and Tribal and subsistence communities that rely on locally caught fish. According to EPA, given the human health hazard assessment findings that male reproductive toxicity is a sensitive endpoint and the Agency’s commitment to protecting future generations, it will design the forthcoming workplace rule “to be especially protective of several critical life stages, including males, pregnant workers, and women of childbearing age.”

EPA will continue to publish data, methods, and analyses so that workers, employers, scientists, and the public can see exactly how conclusions were reached and regulations are informed. EPA will continue to review the latest peer-reviewed research, monitoring data, and information from workplaces and communities “to ensure regulations remain rooted in the most robust universe of evidence available.” According to EPA, two byproducts formed during EDC manufacture — trans-1,2-dichloroethylene and 1,1,2-trichloroethane — will be evaluated in separate TSCA risk evaluations.

Next Steps

EPA will develop a TSCA Section 6(a) rule focused on the 15 COUs that drive workplace risk. According to EPA, the rulemaking will:

• Establish workplace protections, including engineering controls, exposure limits, and personal protective equipment (PPE) where appropriate;

• Be informed by extensive consultation with workers, businesses, labor organizations, frontline communities, and state partners;

• Weigh health benefits, real-world feasibility, and economic impacts; and

• Provide clear, practical compliance pathways so that workers are protected and American manufacturing remains strong.

In proposing rules and selecting among requirements, consistent with TSCA Section 6(c)(2), EPA will consider and factor in, to the extent practicable: the effects of EDC on health and the environment; the magnitude of exposure to EDC of human beings and the environment; the benefits of EDC for various uses; and the reasonably ascertainable economic consequences of the rule. EPA notes that additional information received may inform its risk management of EDC.

Commentary

On EPA’s web page, EPA states that “The risk determination reflects baseline workplace exposures; however, specified respirators and other workplace controls can reduce worker exposures such that the risk would no longer be unreasonable.” The Acta Group (Acta^®) anticipates that EPA may require respirators, PPE, and/or engineering controls to reduce worker exposures and expects these requirements to be proposed in the upcoming TSCA Section 6(a) rule focused on the 15 COUs that drive workplace risk. Additional information submitted to EPA may inform the risk management of EDC and, like the prioritization and risk evaluation processes, there will be an opportunity for public comment on any proposed risk management actions. When the proposed rule is issued, Acta encourages all stakeholders to comment. That being said, EDC is joining a long and growing queue of chemicals awaiting EPA risk management action, including six of the “first 10” chemical rules that are still pending draft or final; four of the “first 10” chemical rules that EPA has publicly stated it is reconsidering; and nine (now ten) of the “next 20” chemicals that are on the statutory clock for issuance of proposed rules. Acta expects numerous additional risk evaluations will be completed before February 2027 under the terms of a court-ordered consent decree, likely increasing the risk management workload even further. Although the statute provides one year for publication of a proposed risk management rule, and two years for publication of a final, EDC’s position in that queue and how quickly EPA will begin work on it is anyone’s guess at this point.

EPA is also in the midst of revising its procedural framework rule for TSCA risk evaluations. The current regulation — a 2024 final rule — prohibits EPA from assuming PPE use by workers and reducing exposure estimates accordingly. The 2025 proposed update to this rule suggests that EPA will consider information on the implementation and use of PPE. What is less clear, however, is how exactly EPA will apply this information after considering it — whether in the exposure assessment, the risk characterization, the risk determination, and/or the risk management rule — and what specific information will or will not move the needle. Acta expects EPA to publish the final updated procedural framework rule in 2026 — well before EPA issues a proposed risk management rule for EDC. Acta again encourages interested stakeholders to stay tuned on these important issues as they will have enormous implications for the ultimate risk management approach used by EPA.

One notable change in the risk evaluation from the draft to final was that EPA did not identify unreasonable environmental risk under any COU. EPA’s final evaluation incorporates public comments and external peer review by the Science Advisory Committee on Chemicals (SACC). EPA updated and clarified methods, considered new or refined workplace and use information, and replaced overly conservative assumptions where better real-world data were available. These improvements led to refined exposure estimates and risk conclusions, resulting in no unreasonable environmental risk under any COU.