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The regulatory landscape governing chemical health and safety has significantly changed in ways that will impact Rutgers faculty and staff. The recent amendments to the Toxic Substances Control Act (TSCA) under the Frank R. Lautenberg Chemical Safety for the 21st Century Act reflect the United States Environmental Protection Agency’s (EPA) enhanced authority to evaluate and mitigate risks associated with chemicals that pose unreasonable risks to human health or the environment. As part of these changes, new rules and risk management processes are being implemented that will directly impact research practices and the use, storage, and even procurement of TSCA-listed chemicals.

To proactively assist our researchers with the updated TSCA rules, REHS is conducting a university-wide survey to collect information about chemical usage and current safety practices within our laboratories, which can be accessed HERE.

This page contains information related to each of the TSCA-listed chemicals that have new regulatory requirements. To help the Rutgers community stay up to date with the upcoming changes, this page will be updated regularly to reflect the most currently available information. 

Current Chemical Programs Managed through REHS

REHS already manages several programs which define the means and methods for the use and disposal of additional chemicals that are regulated under TSCA. These include the following:

Research laboratories or facilities groups that have any chemicals that they wish to dispose of can submit a Request for Hazardous Waste Disposal. Please direct all questions regarding hazardous waste to hazwaste@rutgers.edu.

TSCA Section 6 Regulated Chemicals

As of February 3, 2025, the following chemicals have revised TSCA rules:

Carbon Tetrachloride (CTC; CAS #56-23-5)

  • Final Rule: Carbon Tetrachloride (CTC); Regulation under TSCA

Methylene Chloride (DCM; CAS #75-09-2)

Perchloroethylene (PCE; CAS #127-18-4)

Trichloroethylene (TCE; CAS #79-01-6)

Additional chemicals are in various stages of review under TSCA. No action is required at this time.

Commercial and Industrial Product Use

The updated TSCA rules will impact the ability to industrially and commercially purchase, use, and store products containing the aforementioned chemicals. Products that exceed a specified weight percentage of a TSCA chemical will need to be disposed. An alternative product must then be used to complete the same task. The due date for the elimination of products varies by chemical; it is strongly encouraged to begin the disposal process well before the final product disposal date. Below is the current timeline for each of the chemicals with final rules:

Chemical Name % weight* Product Distribution by Retailers Product Disposal

Carbon Tetrachloride

≥ 0.1%

 TBD TBD

Methylene Chloride

≥ 0.1%

May 5, 2025

April 28, 2026

Perchloroethylene

≥ 0.1%

March 8, 2027

June 7, 2027

Trichloroethylene

≥ 0.1%

June 16, 2025

September 15, 2025

Certain applications of product use may have a longer phase-out period that does not align with the above deadlines. If you have any questions as to whether you meet those qualifications, please reach out to REHS.

Worker Chemical Protection Plan

Each regulation details a list of exemptions and conditions that will allow for the continued use of the TSCA regulated chemicals. Continued use of any of these chemicals will require the development of a Worker Chemical Protection Plan (WCPP). The EPA proposed WCPP requirements are crucial for maintaining a safe working environment. REHS can assist in WCPP implementation and provide resources where possible. WCPPs for TSCA-regulated chemicals will include the same general requirements:

  • Initial and Periodic Monitoring: Workplace air concentrations must be determined through personal breathing zone samples. These samples are used to determine what actions are necessary to mitigate exposure, such as using engineering controls or personal protective equipment (PPE).  Periodic monitoring is then required on a routine basis, as often as every three months to once every five years, depending on the initial monitoring results.
     
  • Regulated Areas: Areas where airborne concentrations exceed exposure limits must be identified and marked as designated areas with restricted access.
     
  • Personal Protective Equipment: Chemically resistant gloves are required where dermal exposure is possible. Each regulation dictates circumstances in which each type of respiratory protection would be allowed.
     
  • Training: Individuals working with TSCA-regulated chemicals and/or in restricted areas must complete training before initial job assignments. 
     
  • Exposure Control Plan: An exposure control plan must identify and implement exposure controls to reduce inhalation exposure to a level at or below the chemical’s Existing Chemical Exposure Limit (ECEL) or short term exposure limit (STEL). The exposure control plan includes, but is not limited to, identification of exposure controls, how the hierarchy of controls is applied to reduce inhalation exposures, a description of exposure control implementation, a description of the regulated area(s) and authorized entry, a description of measures to ensure adequate controls, and procedures for responding to any potential changes. Documentation of the efforts identifying why certain non-feasible, ineffective, or otherwise not implemented is also required for the exposure controls not selected.
     
  • Recordkeeping and Notification: Recordkeeping of training, sampling records, and control plans must always be maintained. Notification of potentially exposed persons of the results of workplace exposure monitoring activities and exposure incidents is also required.

The due date for implementation of a WCPP varies by chemical. Below is the current timeline for each of the chemicals with final rules:

Chemical Name

Initial Monitoring*

ECELs and Regulated Areas

Exposure Control Plan

Continued Monitoring

Carbon Tetrachloride

June 11, 2026

September 9, 2026

December 3, 2027

Every 5 years or as needed

Methylene Chloride

May 5, 2025

August 1, 2025

October 30, 2025

Every 5 years or as needed

Perchloroethylene

December 15, 2025

March 13, 2026

June 7, 2027

Every 5 years or as needed

Trichloroethylene

June 16, 2025

September 15, 2025

December 18, 2025

Every 5 years or as needed

*Includes collecting representative personal breathing zone samples

Existing Chemical Exposure Limit (ECELs) and Action Levels

As part of the risk management process and implementation of a WCPP, all exposure monitoring results must align with the new Existing Chemical Exposure Limits (ECELs) established by the EPA.  An ECEL is like an OSHA Permissible Exposure Limit (PEL); however, these new regulations severely reduce the acceptable exposure threshold relative to the OSHA standard. Below is a comparison of the OSHA exposure limits to these new ECELs as defined by their respective finalized EPA rules.

Chemical Name

OSHA PELa

ECELa

Action Level

Carbon Tetrachloride

10 ppm

0.03 ppm

0.02 ppm

Methylene Chloride

25 ppm

2 ppm

1 ppm

Perchloroethylene

100 ppm

0.14 ppm

0.1 ppm

Trichloroethylene

100 ppm

0.2 ppmb

0.1 ppmb

a 8-hour time weighted average
b Interim levels

REHS will help to coordinate risk assessment and air exposure monitoring support to help meet these new standards.

Hierarchy of Controls

The hierarchy of controls identifies a preferred order of actions to best control hazardous workplace exposures. The hierarchy of controls has five levels, with decreasing effectiveness at each level.

Level I-Elimination:  Elimination removes the hazard at the source. It is the preferred solution to protect workers because no exposure can occur. Research laboratories or facilities groups that have TSCA-restricted chemicals that they wish to dispose of can submit a Request for Hazardous Waste Disposal.

Level II-Substitution:  Substitution is the process of using a safer alternative to the source of the hazard. The EPA recognizes that suitable alternatives for the TSCA Restricted chemicals may not be available for all processes. When considering a substitute, it's important to compare the potential new risks of the substitute to the original risks. Below are some references to provide guidance regarding alternative chemical options.

Level III-Engineering Controls: Engineering controls can include modifying equipment or the workspace, using protective barriers, ventilation, and more. Some TSCA rules may specify the required use of laboratory ventilation devices.

Level IV-Administrative Controls: Administrative controls establish work practices that reduce the duration, frequency, or intensity of the exposure to the hazard. This includes the required step of establishing a regulated area. It is noted that thus far, none of the regulations allow for use of a rotating work schedule to comply with their respective ECELs.

Level V-Personal Protective Equipment (PPE): In cases where all other controls have provided inadequate exposure protection, PPE may be required to help mitigate inhalation and dermal exposures. The following types of PPE may be used for protection:

  • use of chemical resistant gloves
  • use of respiratory protection*

*Not all TSCA final rules allow for the use of all kinds of respiratory protection. In addition, the concentration levels present may impact the type of respiratory protection required.

Respiratory protection cannot be used without prior approval from REHS. If it is determined that respiratory protection is necessary, participation in the Rutgers Respiratory Protection Program will be required. For more information, you can contact our program-wide email n95@rutgers.edu.

Contact Us to Learn More

For additional guidance or to discuss these regulatory updates further, please contact:
Program-wide email: rehs-projects@rutgers.edu
REHS: (848) 445-2550