Advocacy Submits Comments on Trichloroethylene; Regulation of Certain Uses Under TSCA
March 15, 2017
The U.S. Small Business Administration’s (SBA) Office of Advocacy (Advocacy) submits the following comments in response to the Environmental Protection Agency’s (EPA) proposed rule, “Trichloroethylene; Regulation of Certain Uses Under TSCA § 6(a).” Safe chemical use and prevention of hazardous exposure to chemicals are a priority for small business formulators and users to be able to protect both the consumer and their employees. Small businesses, however, are concerned that the rule does not consider important compliance costs that will be imposed on them. Small businesses have also expressed their disappointment that they were not afforded an opportunity to provide their feedback at the Small Business Advocacy Review panel. Finally, small businesses have also raised concerns with EPA’s basis (i.e., risk assessment) for its regulatory proposal for the use of trichloroethylene (TCE) in aerosol degreasing and spot removal in dry cleaning facilities. Advocacy urges EPA to carefully address the small business concerns and carefully reconsider the impact of its proposal on small businesses.