EPN Submits Comments on Draft Risk Evaluation of the Chemical Methylene Chloride

On November 26, 2019, EPN submitted comments in response to EPA’s announcement that it was seeking public input on the draft risk evaluation of the chemical Methylene Chloride (MC). MC is primarily used as an industrial solvent and also as a potent paint stripper and paint thinner that has been linked to cancer, cognitive impairment, and asphyxiation. EPA also announced a 2-day in-person meeting of the Toxic Substances Control Act (TSCA) Science Advisory Committee on Chemicals (SACC) from December 3-4, 2019, to consider and review this draft risk evaluation. The purpose of these risk evaluations is to determine whether a chemical substance like MC presents unreasonable risks to health or the environment, including an unreasonable risk to a relevant potentially exposed or susceptible subpopulation.

As EPN noted in its comments for 1-Bromopropane and Cyclic Aliphatic Bromide Cluster (HBCD) and 1,4-Dioxane, it is extremely disingenuous that a SACC meeting, at which the risk evaluation will be discussed, was scheduled prior to the deadline for the comments. This is a reversal of the way EPA normally does things, is an approach that seems to value an arbitrary deadline over solid decision-making, and is potentially a mechanism to discourage public comment.

EPN objects to the process followed and basis on which EPA conducted the risk evaluation for MC, as it did with the previous risk evaluations for Pigment Violet 29, HBCD and 1,4-Dioxane, and 1-Bromopropane. EPA needs to base its decisions on adequate data and expand its considerations of the populations at risk. EPN urges EPA to discontinue the use of the flawed TSCA systematic review process to prevent endangering public health and the environment. 

Read a summary of the comments.

Read the comments.