DOD Requests Information on Chemicals Undergoing TSCA Risk Evaluation

Last month, the Defense Department (DOD) issued a request for information (RFI) seeking input on critical military uses of 11 chemicals currently undergoing Toxic Substances Control Act (TSCA) risk evaluation.

The “ability to identify critical applications earlier in the TSCA Section 6 risk evaluation process will allow [DOD] to investigate the availability of alternatives, inform industry and interagency engagement, and better manage chemicals critical to national defense,” the RFI states.

DOD will likely use the information it collects to help ensure that critical applications are protected in any future TSCA risk management rule.

The 11 chemicals include 1,3-Butadiene, 1,1-Dichloroethane, 1,2-Dichloroethane, D4, and seven phthalates: BBP, DBP, DCHP, DEHP, DIBP, DIDP, and DINP.  Some, like DIDP, have finalized risk evaluations.  For others, such as D4, EPA has yet to release a draft.

The RFI focuses on identifying specific DOD applications that require these substances and their industrial criticality.  It asks for details such as annual usage quantities, whether viable alternatives exist, and which TSCA condition of use best matches each application.

According to the RFI, DOD currently relies on safety data sheets (SDSs) for chemical ingredient data, which contain limited information.  As a result, DOD “lacks visibility in tracking upstream applications to understand the implications of developing regulatory drivers, such as TSCA.”

Responses to the RFI were due June 20, but DOD will consider late comments to the extent practicable.  The department also stated that it “will continue to issue RFIs to consider additional TSCA chemicals.”