NAPA update on confusing exposure monitoring compliance deadlines under EPA’s chlorinated solvents ban

After further assessment of NAPA’s June 6 notice, and pending both (NAPA external) legal review and EPA’s stated reconsideration of the (TCE) rule, NAPA recommends each company assess their TCE (and other chlorinated solvent) exposure monitoring compliance deadlines.

While implementation of the rule has repeatedly been extended, is currently in litigation, and EPA has stated they are holding in abeyance the final rule for reconsideration with proper notice and comments, there is now some uncertainty regarding the exact date for compliance for TCE exposure assessment monitoring, initially interpretated to be in June 2025, notwithstanding EPA’s additional extensions under TSCA Section 6(g), published the same month.

During NAPA’s Midyear meeting, significant information was provided to attendees about use, exposure assessment/mitigation, and likely the introduction of a non-halogenated solvent. At this point, and as indicated during our Midyear Meeting, NAPA also recommends that each laboratory utilizing TCE (and other chlorinated solvents) expedite exposure monitoring.

For additional information, please contact Howard Marks.