EPA Extends Voluntary Submission Deadline for Certain Chemicals

DECEMBER 7, 2017

EPA announced this week that it is extending the deadline from December 9, 2017 to January 12, 2018 to voluntarily submit information and data regarding uses, alternatives, exposed populations and products containing the five chemical substances the Agency is reviewing as “persistent, bioaccumalative, and toxic” (PBT) under TSCA Section 6 (h).

EPA states that three of the chemicals are identified as used in lubricants. ILMA members should review the list to determine if any of the substances are currently used in their products and if they are in possession of any information or data that should be potentially submitted directly or through ILMA. 

The five substances are: 

  1. Decabromodiphenyl ethers (DecaBDE), used as a flame retardant in textiles, plastics, wiring insulation, and building and construction materials;
  2. Hexachlorobutadiene (HCBD), used as a solvent in the manufacture of rubber compounds and as hydraulic, heat transfer or transformer fluid;
  3. Pentachlorothiophenol (PCTP), used as a mercaptan (sulfur) cross-linking agent to make rubber more pliable in industrial uses;
  4. Phenol, isopropylated, phosphate (3:1), used as a flame retardant in consumer products and as a lubricant, hydraulic fluid, and other industrial uses; and
  5. 2,4,6-Tris(tert-butyl) phenol, an antioxidant that can be used as a fuel, oil, gasoline or lubricant additive. 


Under TSCA Section 6 (a), EPA is required to take expedited regulatory action, including possible bans, on those chemicals deemed to be PBT in the 2014 update to the TSCA Work Plan for Chemical Assessments, if certain statutory requirements are met. Specifically, EPA is directed to move forward without completing a risk evaluation on those five substances, instead proposing a rule to reduce risks and exposures from the chemicals, no later than June 22, 2019, with a final rule to follow no more than 18 months later.

EPA has opened dockets for each of these chemicals to collect information on use, exposure, and disposal. This opportunity to submit information and data at this point is invaluable, as it will potentially shape EPA’s proposed and then final risk management approach regarding the substances. ​​