EPA Finds Major Workplace Risks in 1,2-Dichloroethane Use
EPA's final risk evaluation confirms 1,2-dichloroethane poses serious workplace health risks in 15 uses.
Why it matters: Regulatory and compliance teams in chemical manufacturing face new obligations and potential liability as EPA prepares rulemaking to mitigate workplace exposure risks. Legal teams should anticipate stricter requirements for worker protection under TSCA.
- On May 5, 2026, EPA finalized its risk evaluation for 1,2-dichloroethane, citing unsafe workplace exposure in 15 of 20 uses.
- 12 of these 15 uses also endanger occupational non-users—workers onsite but not directly handling the chemical.
- EPA will write a TSCA Section 6(a) rule to address these risks, including engineering and PPE requirements.
- No unreasonable risks were found for consumers, the environment, or general public exposure.
The EPA’s final risk evaluation for 1,2-dichloroethane (1,2-DCA), published May 5, 2026, determined that workplace exposures to the chemical create an unreasonable risk to human health in 15 of 20 assessed conditions of use (COUs). The findings underscore significant compliance concerns for companies manufacturing, processing, or disposing of 1,2-DCA.
- EPA highlights that 12 of the 15 high-risk uses also threaten occupational non-users: workers present in facilities but not directly managing the substance.
- “EPA determined that 1,2-DCA presents an unreasonable risk to human health driven by worker inhalation and dermal exposures under 15 of 20 total COUs,” according to the agency’s risk evaluation.
- Upcoming risk management will target these 15 conditions of use and is expected to establish workplace safety rules—such as engineering controls, new exposure limits, and required personal protective equipment (PPE).
EPA’s assessment did not identify unreasonable risks to consumers, the general population, or the environment in any use scenario. Over 90% of 1,2-DCA is used to make vinyl chloride for PVC manufacturing, with national production (including imports) estimated at 30–40 billion pounds annually.
This action falls under the Toxic Substances Control Act (TSCA), which requires EPA to review and regulate chemicals with substantial health risks. The agency noted that “specified respirators and other workplace controls can reduce exposures such that the risk would no longer be unreasonable.”
For in-house counsel and compliance professionals, these findings signal new regulatory obligations, especially for facilities producing or using large quantities of 1,2-DCA. Preparation for more stringent workplace protocols and possible reporting requirements is essential as EPA moves to implement its findings through rulemaking.
By the numbers:
- 15 out of 20 — conditions of use with unreasonable workplace risks
- 12 out of 15 — risky uses also impacting occupational non-users
- 30–40 billion lbs/year — annual U.S. 1,2-DCA production (including imports)
Yes, but: The EPA has not specified a timeline for release of its proposed TSCA Section 6(a) rule addressing these workplace risks.