Advocacy Submits Comments on Trichloroethylene(TCE); Regulation of Use in Vapor Degreasing Under TSCA

April 17, 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 (TCE); Regulation of Use in Vapor Degreasing Under TSCA § 6(a).” Safe chemical use and prevention of hazardous exposure to chemicals are a priority for small business users to be able to protect themselves and their employees. Small businesses, however, have raised concerns with EPA’s basis (i.e., risk assessment) for its regulatory proposal for the use of trichloroethylene (TCE) in vapor degreasing. Small businesses are also concerned that the EPA’s risk analysis does not support the ban of TCE use in all vapor degreasing machines. In addition, small businesses have expressed concerns with the agency’s consideration of the feasibility of alternatives and substitute solvents for TCE. Finally, small businesses have also raised concerns with the short transition period provided by the agency to ban the use of TCE in vapor degreasers. Advocacy urges EPA to carefully address the small business concerns and carefully consider providing regulatory flexibilities to small businesses while still accomplishing the agency’s regulatory objective.

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