
EPA Flags Unreasonable Risk from D4 in Industrial and Environmental Use
EPA draft risk evaluation finds octamethylcyclotetrasiloxane (D4) poses significant risks to workers and aquatic life, signalling regulatory change for industry.


The U.S. Environmental Protection Agency (EPA) released its final risk evaluation for Tris(2-chloroethyl) Phosphate (TCEP), a widely used flame retardant. The EPA determined that TCEP poses significant and unreasonable risks to human health and the environment, identifying risks such as kidney cancer, neurological damage, and fertility issues. This conclusion impacts both consumers and workers exposed to TCEP in products ranging from paints to bedding.
The EPA's final risk evaluation identified TCEP as a carcinogenic substance with severe health impacts. Notably, TCEP exposure can lead to kidney cancer, damage to the nervous system, and reproductive harm. The assessment specifically highlighted the elevated risks for vulnerable groups, including pregnant women, children, and fenceline communities—populations living near facilities that release TCEP. Workers in industries handling TCEP, such as paint manufacturing, face increased risks from direct contact or inhalation of the chemical.
TCEP (CASRN 115-96-8) is predominantly used as a flame retardant and plasticizer in aerospace equipment, paints, and coatings. Despite a reported reduction in its manufacturing from 2016 to 2020, TCEP remains prevalent in various commercial and consumer products. The EPA’s evaluation covered 21 conditions of TCEP use, identifying seven that pose unreasonable risks to workers, such as those in paint and coating industries, and three consumer-related risks, particularly in fabrics, textiles, and foam products. Consumers may unknowingly inhale or ingest TCEP-laden dust, exacerbating health concerns.
Beyond human health, TCEP presents substantial risks to the environment, particularly aquatic ecosystems. Fish and other aquatic organisms are at risk due to TCEP contamination in water bodies. Subsistence fishers and indigenous communities, whose diets rely heavily on fish, are especially vulnerable to these risks. The chemical's ability to bioaccumulate in aquatic life raises alarms for long-term environmental health.
Following the findings, the EPA will initiate risk management efforts under the Toxic Substances Control Act (TSCA) to mitigate the health and environmental dangers posed by TCEP. A proposed rule is expected to follow, with public comments welcomed throughout the process. In previous steps, the EPA had already proposed a Significant New Use Rule (SNUR) in June 2023, which aims to prevent any new uses of TCEP without thorough EPA review.
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