TCE Public Workshop

July 29-30, 2014

Comments by Christina Franz

Senior Director, Regulatory & Technical Affairs

American Chemistry Council

ACC member companies do not sell TCE into the use applications that were the focus of EPA’s 

TCE risk assessment. ACC members that manufacture TCE sell into large commercial markets 

where exposures are very well controlled. The fact that there are uses and applications of TCE 

where the exposures are well controlled was noted by Dr. Tala Henry yesterday and should be 

reiterated. For these reasons, I was not inclined initially to provide any specific remarks during 

this workshop. However, after listening to the presentations and discussion over the last dayand-a-half, I would like to offer a few thoughts and observations.

First, it is important to note at the outset that ACC supports EPA’s effort to conduct targeted 

risk assessments on priority chemicals. This is important work that should continue in the 

existing chemicals program.

Supporting a model of continuous improvement, some refinements should be made in EPA’s 

overall approach to the assessments and we are collaborating with the agency and assisting 

their efforts to identify effective and efficient ways to improve and refine the assessments, 

particularly as it relates to the exposure assessment component of the assessments. These 

efforts should help to identify if there is any actual risk posed. This is critical if the agency is 

going to rely on these risk assessments for regulatory decision making. No sector or 

stakeholder is well served by regulatory actions that do not actually mitigate real risks.

ACC also very much supports EPA’s openness and engagement with stakeholders in this 

workshop to solicit views and perspectives on risk reduction options that may address potential 

concerns raised in its assessment. 

Over the last-day-and-a-half, we have heard a significant number of presentations about 

alternatives that can be substituted for TCE in various applications. However, risk reduction 

does not always mean that an alternative is the most effective or appropriate risk management 

measure. Alternative assessment is only one of many risk management measures that can and 

should be considered. And, as was very apparent from the discussion yesterday and mentioned 

by Maria Doa in her remarks this morning, there is no one-size-fits-all solution for every 

business or application. Consequently, the industry or industries that will be impacted by the 
risk reduction measures – in this case, small degreasers – should be fully engaged to ensure 

that their businesses, processes, needs, and actual exposure scenarios are fully understood.

I urge EPA to work with the Small Business Administration (SBA) to survey small degreasers to 

answer the exposure questions the agency could not answer or may have over or 

underestimated in its assessment. 

In addition, should the exposures identified actually pose a risk that should be reduced or 

mitigated, the SBA should be able to identify small degreasers to work with the agency to 

identify how those risks might be best managed or reduced. These steps are essential for EPA 

to ensure that future actions that may be considered (be they educational, voluntary, or 

regulatory) are appropriate and will lead to meaningful risk reductions.

Thank you for the opportunity to comment.