Advocacy Comments on EPA’s Proposed Addition of HHCB to the TRI
In response to a petition filed under the Emergency Planning and Community Right-to-Know Act (EPCRA), on October 18, 2021, EPA proposed to add 1,3,4,6,7,8-hexahydro-4,6,6,7,8,8-hexamethylcyclopenta[g]-2-benzopyran (HHCB), along with 11 other chemicals, to the list of toxic chemicals subject to the reporting requirements under EPCRA and the Pollution Prevention Act (PPA), which will require reporting in the Toxic Release Inventory publicly available database. Moreover, EPA is proposing to add HHCB to the list of chemicals of special concern as a persistent, bioaccumulative, and toxic chemical with the lower, 100-pound, reporting threshold. HHCB is primarily used as a fragrance additive in a number of consumer products. Prior to its incorporation into a final product, HHCB is processed with various other chemicals and is therefore used throughout the supply chain, various layers removed from the manufacturer or importer.
On December 17, 2021, Advocacy filed public comment on this proposed rule. Advocacy is concerned about the impact of this rule given the extremely low threshold for reporting and the multiple downstream users of HHCB who would be subject to the rule’s requirements.