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EPA Draft 1,2-Dichloropropane Evaluation Finds Unreasonable Risk Across 14 Conditions Of Use

Dr Steven Brennan
Dr Steven Brennan
3 min readAI-drafted, expert reviewed
Technician reviewing exposure data beside a closed chemical process

Key takeaway

What This Development Means

EPA's draft evaluation preliminarily finds that 14 of 15 assessed 1,2-dichloropropane conditions of use significantly contribute to unreasonable risk, including worker and consumer exposures. No restriction applies yet. Manufacturers, importers and users should test EPA's assumptions against product, exposure and control evidence and comment by 3 November 2026.

Does EPA's Draft Make 1,2-Dichloropropane Illegal?

No. It is a draft risk evaluation, not a prohibition or risk-management rule. Existing requirements remain unchanged while EPA considers comments and peer review. Any new controls would require a final unreasonable-risk finding followed by separate TSCA section 6(a) rulemaking.

Which Uses Are Of Greatest Immediate Interest?

The draft identifies worker risk across 11 conditions, occupational non-user risk across four and risk from three consumer cleaner, polish or wax uses. EPA particularly wants information on imported products because these uses have reportedly disappeared from US-manufactured formulations since 2022.

Source basis: US Environmental Protection Agency, 1,2-Dichloropropane Draft Risk Evaluation Under TSCA, 91 FR 56826 (4 September 2026)

The US Environmental Protection Agency (EPA) has published a draft Toxic Substances Control Act (TSCA) risk evaluation for 1,2-dichloropropane, preliminarily finding that 14 of 15 assessed conditions of use significantly contribute to unreasonable risk. Comments are open until 3 November 2026 under docket EPA-HQ-OPPT-2018-0428.

EPA 1,2-Dichloropropane Risk Evaluation Identifies Worker And Consumer Concerns

1,2-Dichloropropane, also called propylene dichloride, is a volatile chlorinated liquid used as a laboratory chemical and processing reactant. EPA describes it as likely carcinogenic to humans and assessed cancer and non-cancer effects across manufacture, import, processing, distribution, industrial and commercial use, consumer use and disposal.

The draft identifies significant contributions to unreasonable risk for 11 of 12 worker conditions of use. Four conditions also contribute to unreasonable risk for occupational non-users, who may be exposed despite not directly handling the substance. All three evaluated consumer uses, as a cleaner, polish or wax, preliminarily contribute through inhalation and dermal exposure.

EPA says these uses have not appeared in US-manufactured products since 2022, but products made elsewhere may still enter American homes and businesses. It specifically requests information identifying imported products that may contain 1,2-dichloropropane.

What Changed And What Remains Unchanged

Foresight previously covered EPA's peer-review process for five high-priority chemicals, including 1,2-dichloropropane. This is a material progression. The complete draft evaluation now states condition-specific preliminary risk findings and starts a 60-day comment period.

The assessment does not ban the substance, create an occupational exposure limit or amend any existing safeguard. EPA also preliminarily finds no unreasonable risk to the general population, including fenceline communities, or to the environment on the reasonably available evidence. Those conclusions remain open to data and external peer review.

After consultation, EPA will issue a final evaluation. If unreasonable risk remains, TSCA section 6(a) requires a separate risk-management rulemaking for the contributing conditions of use. The form and timing of any restrictions, workplace controls or other requirements are not yet determined.

Implications Across The Chemical Value Chain

Manufacturers and importers should trace volumes, customers and product pathways, including imported cleaners, polishes and waxes. Processors and downstream users should compare EPA's inhalation and dermal assumptions with enclosure, ventilation, task duration, protective clothing and respiratory protection. Distributors should confirm that safety information follows the product. Waste operators should review residual material, air emissions and disposal scenarios.

Inference: EPA's focus on imported consumer products creates a potential evidence gap between domestic formulation records and border supply chains. Importers able to document composition and absence may help narrow the final assessment, while poor supplier visibility may sustain conservative exposure assumptions.

Practical Actions

Map each condition of use to facilities and products, validate exposure and protective-equipment evidence, and review import declarations and supplier composition data. Submit quality-assured, source-referenced evidence to EPA-HQ-OPPT-2018-0428 by 3 November 2026 where the draft does not represent actual operations.

Follow the chemical exposure topic for related workplace evidence and risk-evaluation developments.

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