Workplace chemical protection programs: New compliance guide from EPA

Washington — Complying with workplace chemical protection programs for chemicals regulated under the Toxic Substances Control Act helps “ensure that potentially exposed persons are protected from unreasonable risk in the workplace,” the Environmental Protection Agency says.

The agency outlines this position in a recently released guide on following WCPP requirements. It’s intended for employers whose facilities are involved in the manufacturing (including import), processing, distribution in commerce, use or disposal of chemicals regulated under Section 6 of the act that are subject to WCPPs in agency rulemaking.

The guide, which also applies to workers who may be exposed to such chemicals, features a closer look at typical program requirements, including:

• Occupational exposure limits designated under the TSCA
• Existing chemical exposure limit action levels
• Occupational exposure monitoring
• Regulated areas
• Direct dermal contact controls
• Respirators
• Personal protective equipment
• Exposure control plans
• Recordkeeping
• Downstream notifications

EPA notes that although the guide “provides a broad look at useful information to consider,” it advises users to “consult the WCPP section within a specific risk management rule for the specific provisions of the WCPP for any individual chemical substance regulated by the EPA.”

As part of previous rulemaking, EPA published chemical-specific compliance guides for methylene chloride and trichloroethylene, respectively, as well as for the use of perchloroethylene in dry cleaning and energized electrical cleaning.

In the latest guide, the agency adds that its rules don’t supersede those of OSHA and that the regulated community “must ensure compliance with all applicable regulations.”

The guide continues: “If OSHA has existing regulations for a chemical substance for which the EPA also promulgates a rule, the EPA anticipates that the provisions of the EPA rule will align with the existing OSHA requirements to the extent appropriate.”