TSCA Chemicals
Toxic Substances Control Act Regulated Chemicals – Research and Laboratory Resource Hub
In recent years, the US Environmental Protection Agency (EPA) has introduced new regulation under the authority granted by The Frank R. Lautenberg Chemical Safety for the 21st Century Act of 2016. This federal legislation amended the Toxic Substances Control Act (TSCA), mandating the EPA take action to assess risk to health or the environment for existing chemicals, and implement a risk management strategy for chemicals determined to present an “unreasonable risk”. The resulting regulations have significantly altered the landscape of federal regulations governing hazardous chemical use in the workplace.
Laboratories and other research areas at U-M are subject to these new EPA regulations and the impact on research activities may be significant. Effects may range from greater utilization of safety controls to the outright prohibition of certain chemicals. Many factors may determine the overall compliance requirements, including the specific chemical(s) used, the specific use case and setting, and existing safety controls present.
EPA Risk Management activities generally address a single chemical or a select group of similar chemicals. These rules and compliance requirements may vary significantly from one chemical to another. As of November 2025, there exists four “Risk Management Final Rulings” that have been officially adopted as federal law that impact U-M research activities. Additional chemicals are under review currently by the EPA and new regulations may be adopted in the near future.
Read more about current Risk Management activities by the EPA on the EPA website.
EHS has provided the following guidance for the current regulated chemicals:
- Methylene Chloride
- Trichloroethylene
- Perchloroethylene
- Carbon Tetrachloride
EHS approval is required for use of these chemicals. Laboratories intending to purchase these chemicals or initiate new operations must complete the TSCA Regulated Chemicals Request Form and receive approval from EHS.
Contact your EHS representative or email [email protected] if you use or possess any of these chemicals in your research area to assess compliance.
Methylene Chloride (dichloromethane, CAS # – 75-09-2)
EPA – Risk Management for Methylene Chloride
In May 2024, the US Environmental Protection Agency (EPA) issued a final rule regulating methylene chloride (also known as DCM or Dichloromethane) under the Toxic Substances Control Act (TSCA). The regulation prohibits most industrial and commercial uses of methylene chloride and creates strict workplace protections for 13 conditions of use that are permitted under the new rule.
Laboratories and other research areas that use methylene chloride must do so in compliance with the Methylene Chloride Workplace Chemical Protection Plan (WCPP).
Laboratories and other research units are required to evaluate options for eliminating methylene chloride from their operations or substitute it with a less hazardous alternative. Units that continue use of methylene chloride must be granted approval by EHS, implement all components of the U-M WCPP, and maintain personal exposures below the EPA exposure limits.
- Appendix A: Operation Specific Exposure Control Plan documents actions taken to mitigate occupational exposures and comply with the WCPP. This includes information regarding the operation involving methylene chloride, the control methods in place, and for control measures not selected, the rationale for why they cannot be implemented.
Supervisors, or a competent representative must complete Appendix A for any operation involving methylene chloride. Multiple operations by one user group may be listed under a single ECP, only if the controls implemented for the operations are the same. Multiple ECP forms may be required if the operations involve substantially different control measures.
Completed ECP forms must be submitted to EHS and a local copy should be stored with the group’s Chemical Hygiene Plan Documentation.
Contact [email protected]
Trichloroethylene(TCE, CAS # – 79-01-6)
EPA – Risk Management for Trichloroethylene (TCE)
General laboratory use of trichloroethylene is prohibited as of December 16, 2025, with only very limited exceptions given extended timeframes for phaseout. These exceptions are as follows:
- Lab use for asphalt testing and recovery
- Lab use for essential laboratory activities associated with cleanup and exposure monitoring
- Lab use for essential laboratory activities conducted by Federal agencies and their contractors
Laboratory uses that meet the criteria above must comply with TCE Workplace Chemical Protection Program requirements, as outlined in the EPA’s Final Rule. All other users must discontinue use of TCE in the laboratory and send remaining inventory for disposal. Contact [email protected] to determine if your application is eligible for extended phase-out under the EPA regulation.
Perchloroethylene (PCE, CAS # – 127-18-4)
EPA – Risk Management for Perchloroethylene (PCE)
Laboratory use of perchloroethylene must meet requirements for certain prescriptive control measures to protect workers. Ventilation devices such as fume hoods or glove boxes must be used to limit personal exposure. Additionally, personal protective equipment must be provided to limit dermal exposure to PCE. Individual laboratories should document their application of these controls and adhere to the U-M SOPs – Acutely Toxic Chemicals and Carcinogens.
Carbon Tetrachloride (CAS # – 56-23-5)
EPA – Risk Management for Carbon Tetrachloride
Laboratory use of carbon tetrachloride must meet requirements for certain prescriptive control measures to protect workers. Ventilation devices such as fume hoods or glove boxes must be used to limit personal exposure. Additionally, personal protective equipment must be provided to limit dermal exposure to carbon tetrachloride. Individual laboratories should document their application of these controls and adhere to the U-M SOPs – Acutely Toxic Chemicals and Carcinogens.
