Department of Defense Again Requests Information on TSCA-Prioritized Substances

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On May 12, 2026, the Department of Defense’s (DOD’s) Chemical and Material Risk Management Program issued a request for information (RFI) seeking industry data on defense and defense industrial base applications that rely on ten substances undergoing EPA’s Toxic Substances Control Act (TSCA) Section 6 risk evaluation process. The RFI is intended to help DOD better understand applications that require these chemicals and their importance to industry and defense supply chains.

The Risk Evaluation Process

The TSCA Section 6 risk evaluation process mandated by the 2016 Lautenberg amendments to TSCA provides a pathway for EPA to evaluate chemicals currently in commerce to determine whether they present an unreasonable risk to human health or the environment. Where such risks are identified, the agency is required to develop rules to protect human health and the environment. Regulation can range from improved workplace protections to bans on specific uses. For examples, see our previous posts on risk management rules for n-methylpyrrolidone (NMP) and 1-bromopropane.

The RFI is intended to help DOD better understand potential impacts of future TSCA regulation on military applications and defense supply chains. In particular, DOD is seeking information about how the substances are used, their importance to defense applications, quantities needed, and the availability of alternatives.

Substances Covered by the RFI

The RFI focuses on ten TSCA high-priority substances:

  • Phthalic anhydride (CASRN 85-44-9)
  • o-Dichlorobenzene (o-DCB) (CASRN 95-50-1)
  • p-Dichlorobenzene (p-DCB) (CASRN 106-46-7)
  • 4,4’-(1-Methylethylidene)bis[2,6-dibromophenol] (TBBPA) (CASRN 79-94-7)
  • Tris(2-chloroethyl)phosphate (TCEP) (CASRN 115-96-8)
  • Phosphoric acid, triphenyl ester (TPP) (CASRN 115-86-6)
  • 1,1,2-Trichloroethane (CASRN 79-00-5)
  • trans-1,2-Dichloroethylene (DCE) (CASRN 156-60-5)
  • Formaldehyde (CASRN 50-00-0)
  • Vinyl Chloride (CASRN 75-01-4)

EPA has finalized risk evaluations for some of these substances, including TCEP. For others, like phthalic anhydride, EPA has released a draft risk evaluation. Some, such as TPP and vinyl chloride, remain at the scoping stage.

The RFI is for information and planning purposes only. DOD intends to use the information to identify critical applications earlier in the TSCA Section 6 process, investigate the availability of alternatives, and better manage chemicals important to national defense.

Continued DOD Information Gathering

This is not DOD’s first RFI on substances undergoing TSCA risk evaluation. In May 2025, DOD issued an RFI seeking information on critical military uses of 11 other substances. That RFI similarly sought information about chemical applications, supply-chain importance, and potential alternatives. The 2026 RFI expressly states that it continues that information-gathering effort and covers a new group of ten TSCA high-priority substances.

Responses to the RFI were due June 19, 2026. However, DOD’s webpage states that companies may continue to submit responses to closed RFIs.