Advocacy Comments on EPA’s Request for Information on the Impacts of Listing 1-bromopropane as a Hazardous Air Pollutant

On July 26, 2021, the Office of Advocacy submitted comments to the Environmental Protection Agency (EPA) on an Advance Notice of Proposed Rulemaking (ANPRM) on listing 1-bromopropane (1-BP) as Hazardous Air Pollutant (HAP). In 2020, EPA announced it would add 1-BP to the Clean Air Act (CAA) list of HAPs. On June 11, 2021, EPA published an ANPRM to solicit information to identify and evaluate the regulatory impacts of adding 1-BP to the HAP list, including the information necessary to develop NESHAP amendments. EPA is simultaneously considering regulation of 1-BP under the Toxic Substances Control Act (TSCA).

Advocacy recommends that EPA engage in a single rulemaking that would satisfy the requirements of both the CAA and TSCA. A single rulemaking would ensure coordination between the rulemakings, minimize the risk of confusion and inconsistencies between the rules, and reduce uncertainty.

A complete copy of Advocacy’s letter to EPA is available here. For more information, please contact Dave Rostker, Assistant Chief Counsel, at (202) 992-6091 or via email at

Comment Letter

Fact Sheet