Guide to Complying With the 2024 Perchloroethylene (PCE) Workplace Requirements for Energized Electrical Cleaners Under the Toxic Substances Control Act (TSCA) (RIN 2070-AK84)


Compliance Guide

SEPA

A GUIDE TO COMPLYING WITH THE
2024 PERCHLOROETHYLENE (PCE)
WORKPLACE REQUIREMENTS FOR
ENERGIZED ELECTRICAL CLEANERS
UNDER THE TOXIC SUBSTANCES
CONTROL ACT (TSCA) (RIN 2070-AK84)

U.S. Environmental Protection Agency

Document Number: 740B24007, JANUARY 2025

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This guide includes small entity compliance guidance prepared pursuant to section 212 of the Small Business
Regulatory Enforcement Fairness Act of 1996, Pub. L. 104-121 as amended by Pub. L. Number 110-28. The statutory
provisions and U.S. Environmental Protection Agency (EPA) regulations described in this document contain legally
binding requirements. This guide does not substitute for those provisions or regulations, nor is it a regulation itself.
Thus, this guide does not, and is not intended to, impose legally binding requirements on the EPA or the regulated
community, and may not apply to a particular situation based upon the circumstances. This guide is not intended,
nor can it be relied upon, to create any rights enforceable by any party in litigation with the United States. The
statements in this guide are intended solely as guidance to aid you in complying with the EPA regulation
Perchloroethylene (PCE); Regulation under Section 6(a) of the Toxic Substances Control Act (TSCA) and the
implementing regulations in 40 Code of Federal Regulations (CFR) Part 751. The EPA retains the discretion to adopt
approaches on a case-by-case basis that differ from this guide where appropriate. The EPA may decide to revise this
guide without public notice to reflect changes in the EPA's approach to regulating chemical substances generally, PCE
under TSCA, or to clarify information and update text.

To get help accessing technical resources on environmental regulations and compliance assistance information
contact the EPA's Small Business Ombudsman or visit the EPA's small business resources page. For information
specific to the PCE regulation, consult the EPA's PCE TSCA risk management website A fact sheet summarizing
information from the regulation is at https://www.epa.gov/svstem/files/documents/2024-12/pce-fact-sheet english.pdf.

The full text of the implementing regulation can be found at 40 CFR Part 751, subpart G and also in the Federal
Register (89 FR 103560, December 18. 2024) and at docket EPA-HQ-OPPT-2020-0720 at https://www.regulations.gov.

FOR FURTHER INFORMATION CONTACT: For PCE technical information contact: email address:
PCE.TSCA@epa.gov. For general information contact: The TSCA-Hotline, ABVI-Goodwill, 422 South Clinton Ave.,
Rochester, NY 14620; telephone number: (202) 554-1404; email address: TSCA-Hotline@epa.gov.

Reproduction of the manual

This guide may be reproduced, but if this guide is altered, it may not provide accurate information that owners or operators
need to comply with the requirements of the EPA's regulation of chemical substances under TSCA, including for PCE.
Additionally, altering this guide may prevent potentially exposed persons from properly informing themselves of the
protections required by the EPA.

The EPA may issue additional guidance about the PCE regulation and may amend the rule in the future. Please check the
EPA's PCE website for further information and current amendments.

This guide, titled "A Guide to Complying with the 2024 Perchloroethylene (PCE) Workplace Requirements for Energized
Electrical Cleaners under the Toxic Substances Control Act (TSCA) (RIN 2070-AK84)" and other materials related to PCE
are available at https://www.epa.qov/assessinq-and-manaqinq-chemicals-under-tsca/risk-manaqement-perchloroethvlene-
pee.

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Table of Contents

IV:

V:

VI:

Overview	1

A.	Does this guide apply to me?	1

B.	What is your role and how might the rule
affect you?	1

C.	How can this compliance guide help me?....2

The EPA's Regulation of PCE Under Section 6

of TSCA	3

A.	What is PCE?	3

B.	What are the risks to health from PCE?	3

C.	Why is the EPA regulating PCE?	3

The EPA's Workplace Requirements for PCE

as an Energized Electrical Cleaner	4

A.	How is the EPA regulating the use of PCE as
an energized electrical cleaner?	4

B.	What are the dermal protection
requirements?	4

C.	What are the respiratory protection
requirements?	5

D.	I am choosing to comply with the WCPP
instead of the prescriptive workplace
controls. What do I need to do?	5

E.	Are the EPA's requirements consistent with
existing OSHA regulations?	5

F.	Are there additional requirements?	5

Self-Certification Requirements	6

A.	What are the self-certification requirements
for owners and operators?	6

B.	What are the self-certification requirements
for distributors?	6

Downstream Notification and Labeling

Requirements	7

A.	What are the downstream notification
requirements?	7

B.	What are the labeling requirements?	7

Recordkeeping Requirement	8

A.	General Records Requirements	8

B.	Records requirements for owners and
operators of business entities that use PCE
as an energized electrical cleaner.	8

C.	Records that distributors of PCE as an
energized electrical cleaner are required to
keep	8

VII: Violations for Non-Compliance	9

A.	What if the EPA discovers a violation?	9

B.	How does the EPA address violations by
small businesses?	9

Frequently Asked Questions (FAQs)		 10

Appendix A: Abbreviation List and Glossary	11

Appendix B: Fact Sheet	14

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I: Overview

The U.S. Environmental Protection Agency (EPA)
issued Perchloroethvlene (PCE): Regulation under the
Toxic Substances Control Act (TSCA) on December
18, 2024, in the Federal Register. These regulations
went into effect on January 17, 2025, and updated the
Code of Federal Regulations (CFR) at 40 CFR Part
751, subpart G. This regulation is also referred to
throughout this guide as the PCE rule.

While the PCE rule regulates all uses of PCE under
TSCA, this compliance guide specifically focuses on
the requirements for the use of PCE as an energized
electrical cleaner. More specifics on the workplace
requirements for PCE as an energized electrical
cleaner are in Unit III. For more information on the
conditions of use of PCE other than as an energized
electrical cleaner and for additional compliance
guidance regarding the use of PCE in dry cleaning, see
the EPA's PCE risk management webpaoe. and the
final rule at 40 CFR part 751, subpart G.

Words or phrases that appear in bold red text
throughout this guide are defined in the glossary
in . Other abbreviations are also

spelled out in the Abbreviation List.

A. Does this guide apply to me?

You may be impacted by certain provisions of the PCE
rule if you manufacture (including import), process,
distribute in commerce, or use PCE (including PCE-
containing products) as an energized electrical
cleaner, which is a sub-use of the industrial and
commercial use as an aerosol spray
degreaser/cleaner.1 Energized electrical cleaner refers
to aerosol products used to clean and/or degrease
electrical equipment that have an electrical current or
residual electrical potential (e.g., transmission lines
and capacitors). This guide also provides information
for formulators, manufacturers (including importers),
processors, and distributors who make or sell these
products.

However, upstream manufacturers and processors of
PCE, including those who use PCE as an energized
electrical cleaner, are subject to Workplace Chemical
Protection Program (WCPP) requirements under 40
CFR 751.607. and manufacturers, processors, and
distributors of PCE may potentially be affected by certain

prohibitions under 40 CFR 751.605. For more
information on the WCPP and other requirements,
which are not covered at length in this compliance
guide, see the PCE rule for its requirements.

If you are unsure if you make, sell, or use PCE as an
energized electrical cleaner, see Unit III of this guide
for more information.

What is energized electrical cleaning?

Energized electrical cleaning is a process that
uses a product, sometimes containing PCE, to
clean equipment that has an electrical current or
residual electrical potential. In 40 CFR 751.803,
the EPA defines an energized electrical cleaner as
a product that meets both of the following criteria:

• The product is labeled to clean and/or
degrease electrical equipment, where
cleaning and/or degreasing is accomplished
when electrical current exists, or when there
is a residual electrical potential from a
component, such as a capacitor; and

• The product label clearly displays the
statements: "Energized Equipment use only.
Not to be used for motorized vehicle
maintenance, or their parts."

The EPA recognizes that users of PCE as an
energized electrical cleaner are technically
sophisticated and already complying with a variety
of state and federal regulations. As such, this
guide assumes some technical knowledge and
includes detailed compliance instructions for the
2024 EPA PCE rule under TSCA. Additionally, the
FAQ at the end of this guide has additional
resources and information.

B. What is your role and how might the rule
affect you?

Persons who own or operate a business entity that
uses PCE, including any PCE-containing products, for
the industrial and commercial use as an energized
electrical cleaner are subject to the PCE rule (see 40

CFR 751.611).

The EPA has defined the phrase "owner or operator"
to mean any person who owns, leases, operates,
controls, or supervises a workplace (see 40 CFR

1 The provisions of the PCE rule only apply when PCE is present in a formulation at 0.1% or greater.

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751.5). While owners or operators remain responsible
for ensuring compliance, they may contract with others
to provide services required for compliance. For a
business entity that purchases and uses PCE as an
energized electrical cleaner, any person who either
owns or operates the business entity is ultimately
responsible for compliance with this rule. The EPA has
defined the phrase "potentially exposed person" to
mean any person who may be exposed to a chemical
substance (in this case, PCE) or mixture in a
workplace as a result of a condition of use (e.g.,
manufacturing (including importing), processing,
distributing, or using) of that chemical substance or
mixture (see 40 CFR 751.5). This includes those who
work directly with the chemicals, other employees,
independent contractors, employers, and all other
persons in the workplace where PCE is present

Additionally, in several subsections throughout the
PCE rule, the EPA has required that the Occupational
Safety and Health Administration (OSHA) provisions
that apply to an "employee" apply equally to potentially
exposed persons and the provisions that apply to an
"employer" apply equally to owners and operators.

Table 1 - Energized Electrical Cleaner Requirements, Who They Apply To, and Relevant Units Within This Guide

Who

| Relevant Units in this Guide

Owners and operators of a workplace using PCE as an energized
electrical cleaner

Workplace controls (Unit lii)
Self-certification (Unit IV.A.)
Recordkeepina (Unit VI.A. and VLB.)

Distributors of PCE or PCE-containing products for use as an
energized electrical cleaner

Self-certification (Unit IV.B.)

Downstream Notification and Labelina (Unit V)

Recordkeepina (Unit VI.A. and Unit VI.C.)

Manufacturers (including importers) and processors of PCE or
PCE-containing products for use as an energized electrical cleaner

Downstream Notification and Labelina (Unit V)
Recordkeepina (Unit VI.A. and Unit VI.C.)

C. How can this compliance guide help me?

This guidance document provides information to help
you comply with the requirements of the PCE rule, with
a focus on PCE as an energized electrical cleaner, it is
important to note that the PCE rule covers all
conditions of use of PCE; there are restrictions and
prohibitions on other uses of PCE as well. For more
information, visit the EPAs PCE risk management
website.

It is also important to note that it is a violation of
Federal law to manufacture (including import), process,
distribute in commerce, use, or dispose of a chemicai
substance in a manner inconsistent with TSCA and the
PCE rule. Violations may result in penalties and
injunctive relief (e.g., preventing certain actions), as
appropriate.

This compliance guide:

•	Provides a short description of why the EPAs
regulations of chemical substances are important

(Unit IQ;

•	Helps you determine whether you need to comply
with the PCE rule and what your responsibilities
may be (Unit Ml);

•	Gives you detailed information on how to comply
with the workplace requirements for PCE as an
energized electrical cleaner (Unit ill);

•	Outlines the energized electrical cleaner
compliance timeframes (Unit III.A);

•	Explains how important definitions affect your
compliance responsibilities; and

•	Provides notes to help you better understand your
compliance responsibilities and how the rule
applies to you.

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II: The EPA's Regulation of PCE Under Section 6 of TSCA

This unit describes what PCE is as weil as how and why
the EPA is regulating PCE under section 6 of TSCA.

A. What is PCE?

Perchloroethylene (CASRN 127-18-4) —also called
tetrachloroethylene, tetrachloroethene, PCE, or perc—
is a colorless liquid primarily used in industrial settings
to produce fluorinated compounds. This chemical is
also a solvent used in dry cleaning and in other
industries for cleaning and degreasing, and in
lubricants, adhesives, and sealants. PCE is both
produced in and imported into the United States and is
distributed in commerce, used, and disposed of as part
of many industrial and commercial conditions of use.

B, What are the risks to health from PCE?

PCE's health risks are well established. Some of
the adverse effects from breathing PCE or skin
contact with PCE can be experienced immediately
following short-term (acute) exposure or long-term
(chronic) repeated exposure. Health effects include
neurotoxicity, kidney and liver effects, immune
system toxicity, reproductive toxicity, developmental
toxicity, and cancer.

C. Why is the EPA regulating PCE?

The EPA determined that PCE presents an
unreasonable risk of injury to health under the
conditions of use, including for the use of PCE as an
energized electrical cleaner. This is based on a risk
evaluation under TSCA section 6(b) for PCE that the
EPA issued in 2020 pursuant to TSCA section 6(b).
The EPA's unreasonable risk determination was
finalized in December 2022.

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III: The EPA's Workplace Requirements for PCE as an Energized
Electrical Cleaner

This unit provides information on the workplace
requirements for PCE as an energized electrical
cleaner.

A. How is the EPA regulating the use of PCE as
an energized electrical cleaner?

The EPA has issued a rule under TSCA that prohibits
many uses of PCE, such as all consumer use and
commercial use in automotive are products, and allows
some uses of PCE to continue, including its industrial
and commercial use as an energized electrical cleaner,
subject to workplace controls. The PCE rule requires
owners or operators of business entities that use PCE
as an energized electrical cleaner to either:

•	By March 13, 2026, utilize specific prescriptive
controls including dermal personal protective
equipment (PPE) and (in certain instances)
respiratory protection (see Unit III.C. of this guide

and 40 CFR 751.611(b)(1)): or

•	Implement the WCPP outlined in the PCE rule,
including performing initial monitoring by
December 15, 2025, and providing PPE by March

13, 2026 (see 40 CFR 751.611(b)(2) and 751.607).

This compliance guide discusses the specific
prescriptive controls. For more information on the
WCPP requirements, see 40 CFR 751.611(b)(2) and
751.607.

Upstream manufacturers and processors of PCE,
including for use as energized electrical cleaner, are
subject to the WCPP requirements under 40 CFR
751.607, and manufacturers, processors, and
distributors of PCE may potentially be affected by
certain prohibitions under 40 CFR 751.605. For more
information on the WCPP, which is not covered at
length in this compliance guide, see the PCE rule for
its requirements.

B. What are the dermal protection requirements?

The EPA is requiring that owners or operators provide
dermal PPE and comprehensive training for each
potentially exposed person using PCE, including any
PCE-containing products (see 40 CFR 751.611(b)(1)(ii)
and 40 CFR 751.607(f)(3)).

Owners and operators must supply dermal PPE that
separates and provides an impervious barrier to
prevent skin contact with PCE to each person who is
reasonably likely to be exposed in the work area
through direct dermal contact with PCE. Direct
dermal contact means direct handling of PCE
(including a mixture or product containing PCE) or skin
contact with surfaces that may be contaminated with
PCE (e.g., equipment or materials on which PCE may
be present)under routine conditions in the workplace
(see 40 CFR 751.5). Owners and operators must
select and provide appropriate dermal PPE based on
an evaluation of the performance characteristics of the
dermal PPE relative to the task(s) to be performed,
conditions present, and the duration of use.2

Dermal PPE includes, but is not limited to:

•	Eye and face protection as defined in 29 CFR

1910.133(b):

•	Impervious gloves selected based on
specifications from the manufacturer or
supplier or by individually prepared third-party
testing;3 and

•	impervious clothing covering the exposed
areas of the body (e.g., long pants, long
sleeved shirt).

There are additional dermal protection requirements in
the PCE rule that apply to owners and operators of a
workplace using PCE as an energized electrical
cleaner. To find a more thorough description of these
requirements, owners and operators should see 40
CFR 751.611(b)(1)(ii) and 40 CFR 751.607(f)(3).

2	This is in alignment with the OSHA Hand Protection PPE Standard (29 CFR 1910.138).

3	For example, owners and operators can select gloves that have been tested in accordance with the American Society for Testing
and Materials (ASTM) F739 "Standard Test Method for Permeation of Liquids and Gases through Protective Clothing Materials
under Conditions of Continuous Contact."

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C.	What are the respiratory protection
requirements?

Owners or operators must ensure that all persons
using PCE, including any PCE-containing products, are
provided with respirators and training on proper use of
respiratory PPE if any of the following criteria are met:

•	The potentially exposed person is in a confined
space, as defined in 29 CFR 1910.146(b). or in an
enclosed space (such as a manhole or vault), as
described in 29 CFR 1910.269(e); or

•	The potentially exposed person approaches the
exposed energized equipment closer than the
employer's established minimum approach
distance required under 29 CFR 1910.269(0(3) or
when there is no established minimum approach
distance.

Under the PCE rule, owners or operators must provide
all persons using PCE, including any PCE-containing
products, with respiratory PPE and training in
accordance with 40 CFR 751,607(fi(2'). except that
instead of selecting appropriate respirators based on
monitoring results, owners or operators must select
from and provide one of the following types of
respirators:

•	Any National Institute for Occupational Safety and
Health (NIOSH) Approved® air-purifying full
facepiece respirator equipped with organic vapor
cartridges or canisters [APF 50];

•	Any NIOSH Approved® power air-purifying
respirator (PAPR) with a half mask equipped with
organic vapor cartridges or canisters [APF 50];

•	Any NIOSH Approved® supplied-air respirator
(SAR) or Airline Respirator in a continuous flow
mode equipped with a half mask [APF 50];

•	Any NIOSH Approved® SAR or Airline Respirator
operated in a pressure-demand or other positive-
pressure mode with a half mask [APF 50];

•	Any NIOSH Approved® self-contained breathing
apparatus (SCBA) in demand-mode equipped with
a full facepiece or helmet / hood [APF 50]; or

•	Any respirator affording a higher degree of
protection.

D.	I am choosing to comply with the WCPP
instead of the prescriptive workplace controls.

What do I need to do?

Owners or operators who choose to follow the WCPP as
an alternative to the prescriptive workplace controls must:

•	Document and maintain a statement that they are
electing to comply with the WCPP; and

•	Comply with the WCPP provisions In 40 CFR

751.607 and document compliance in accordance
with 40 CFR 751.615(b).

The requirements of the WCPP are described in 40

CFR 751.607.

E.	Are the EPA's requirements consistent with
existing OSHA regulations?

The EPA recognizes the importance of existing OSHA
regulations and other best practices designed to protect
workers from other dangers such as electric shock,
electrocution, fires, and exposures. The EPA's workplace
requirements to address the unreasonable risk for PCE
as an energized electrical cleaner are consistent to the
extent possible with existing regulations and best
practices for work in electrical spaces. Some existing
practices protect workers from the dangers of energized
electrical cleaning, such as maintaining a minimum
approach distance from exposed energized parts and
using a hotstick with an aerosol spray can holder
adapter or other live-line tools to clean energized
electrical equipment.

F.	Are there additional requirements?

In addition to the PCE rule under TSCA section 6(a),
federal, state, or local statutes or regulations on
energized electrical equipment may also be relevant to
you. Some examples:

•	OSHA standards:

—	Construction standards (see 29 CFR part
1926, subparts E. K. and V) i

—	Electrical Standard (see 29 CFR part 1910.
subpart S);

—	Electric Power Generation, Transmission, and
Distribution Standard (see 29 CFR part 1910.
subpart R): and

—	Electrical Protective Equipment Standard (see

29 CFR part 1910. subpart D.

Other standards may apply to energized electrical
equipment, such as the National Fire Protection
Association (NFPA) for Electrical Safety in the
Workplace (see NFPA 70E).

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IV: Self-Certification Requirements

A. What are the self-certification requirements

for owners and operators?

Self-certification requires that owners or operators
attest that they are complying with the energized
electrical cleaner provisions of the PCE rule. Starting
on March 13, 2026, the owner or operator of the
business entity purchasing and using PCE, including
any PCE-containing products, for the industrial and
commercial use of PCE as an energized electrical
cleaner must self-certify that use is in compliance with
the workplace protection requirements of the rule.

The certification states that use is in compliance with
the requirements in 40 CFR 751.611(b) (discussed in
detail in Unit III of this guide). The following written
statement must be included in the self-certification:

I certify each of the following statements under
penalty of law. This document was prepared under
my direction and supervision. This energized
electrical cleaner will be used for energized
equipment use only. This business entity has
implemented and complies with the EPA
requirements for the use of energized electrical
cleaner that contains perchloroethylene under 40
CFR § 751.611 and only trained and qualified
persons will handle the energized electrical cleaner.

Based on my inquiry of the person or persons who
manages this business entity and/or those persons
directly responsible for implementing the EPA
requirements for energized electrical cleaner that
contains perchloroethylene, and to the best of my
knowledge and belief, this business entity is in
compliance with the EPA requirements for energized
electrical cleaner. I am aware that there are
significant penalties, including the possibility of civil
penalties for failing to comply with these
requirements and criminal fines and imprisonment,
for knowingly failing to comply with these
requirements. I understand that this certification shall
serve as a certification that this business entity will
properly implement and comply with the EPA
requirements for energized electrical cleaner
consistent with the applicable regulatory timelines.

Additional Self-Certification Requirements

The self-certification must also include the following:

•	Printed name and signature, job classification, title,
email address, and phone number of the owner or
operator who is self-certifying;

•	Date of self-certification;

•	Name and address of the business entity; and

•	Indication of whether this is the business entity's
first purchase of PCE, including PCE-containing
products, after publication of the final rule.

Owners or operators (or persons specifically
authorized by the owner or operator to purchase an
energized electrical cleaner) must provide a copy of
the self-certification statement for each business entity
to the distributor from whom PCE, including PCE-
containing products, is being purchased (see 40 CFR
751.611(d)(3)). This is required for every purchase.
Owners or operators must retain the self-certification
statement for at least 5 years from the date the
statement is created (see 40 CFR 751.615(f)).

B, What are the self-certification requirements
for distributors?

Distributors of PCE, including PCE-containing
products, must review the self-certification statement to
ensure it is appropriately completed and includes the
owner or operator's and the business entity's required
information (see 40 CFR 751.611(d)(4)). Distributors of
PCE, including PCE-containing products, must have a
complete and valid self-certification statement in
accordance with this section for each sale of PCE,
including PCE-containing products, for use as an
energized electrical cleaner to demonstrate compliance
with regulations if necessary (see 40 CFR
751.611(d)(5)). Distributors must retain the self-
certification statement for at least 5 years from the date
the statement is created (see 40 CFR 751.615(f)).

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V: Downstream Notification and Labeling Requirements

This unit provides information about downstream
notification and labeling requirements for manufacturers,
processors, and distributors that are relevant to owners
and operators of a workplace using PCE as an
energized electrical cleaner.

A. What are the downstream notification
requirements?

The EPA requires that manufacturers (including
importers), processors, and distributors of PCE and
PCE-containing products for any use, including as an
energized electrical cleaner, provide downstream
notification of certain prohibitions by updating language
in safety data sheets (SDSs) that are provided with the
PCE or any PCE-containing product. Manufacturers
(including importers) of PCE, for any use, must update
relevant SDSs by February 18, 2025. Processors and
distributors of PCE for any use must update relevant
SDSs by June 16, 2025.

For downstream notification, any product containing
PCE must have the following text (see box below)
added to two places in the product SDS (to section 1(c)
and section 15). This text describes the restrictions in
the rule and must be provided in writing prior to or with
the shipment of the PCE (see 40 CFR 751.613):

B. What are the labeling requirements?

By March 13, 2026, all manufacturers (including
importers), processors, and distributors in commerce of
PCE or PCE-containing products for industrial and
commercial use as an energized electrical cleaner
must provide a label securely attached to each product
(see 40 CFR 751.611(c)). Label information must be
prominently displayed in an easily readable font size.
The label must include the following sentences:

"This product contains perchloroethylene (PCE) (CASRN 127-
18-4), a chemical determined by the Environmental Protection
Agency to present unreasonable risk of injury to health under
the Toxic Substances Control Act (TSCA), based on
neurotoxicity and other adverse health effects. The use of PCE.
is restricted under 40 CFR part 751, Subpart G. This product is
for Energized Equipment use only. Not to be used for motorized
vehicle maintenance, or their parts."

After December 8, 2026 this chemical substance (as defined in
TSCA section 3(2))/product cannot be distributed in commerce
to retailers for any use. After March 8, 2027, this chemical
substance (as defined in TSCA section 3(2))/product is and can
only be distributed in commerce or processed with a
concentration of PCE equal to or greater than 0.1% by weight
for the following purposes: (1) Processing as a
reactant/'intermediate; (2) Processing into formulation, mixture
or reaction product; (3) Processing by repackaging; (4)
Recycling; (5) Industrial and commercial use as solvent in
open-top batch vapor degreasing; (6) Industrial and commercial
use as solvent in closed-loop batch vapor degreasing; (7)
Industrial and commercial use in maskant for chemical milling;
(8) Industrial and commercial use as a processing aid in
catalyst regeneration in petrochemical manufacturing; (9)
Industrial and commercial use as a processing aid in sectors
other than petrochemical manufacturing; (10) Industrial and
commercial use as solvent for cold cleaning of tanker vessels;
(11) Industrial and commercial use as energized electrical
cleaner; (12) Industrial and commercial use in laboratory
chemicals; (13) Industrial and commercial use in solvent-based
adhesives and sealants; (14) Industrial and commercial use in
dry cleaning in 3rd generation machines until December 20,
2027; (15) Industrial and commercial use in all dry cleaning and
related spot cleaning until December 19, 2034; (16) Export;
and (17) Disposal.

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VI: Recordkeeping Requirement

This unit provides information about recordkeeping
requirements for owners and operators of a workplace
using PCE as an energized electrical cleaner. This unit
also includes information about recordkeeping
requirements for manufacturers, processors, and
distributors that are relevant to owners and operators
of a workplace using PCE as an energized electrical
cleaner.

A. General Records Requirements

If you manufacture (including import), process,
distribute, or use PCE, there are general requirements
for recordkeeping for ordinary business records
regarding PCE. There are also specific records owners
and operators and distributors must maintain to
demonstrate compliance with the EPA's workplace
requirements for energized electrical cleaners, which
are described in Unit VLB, and VI.C. below.

Manufacturers (including importers), processors,
distributors, and industrial/commercial users are
required to maintain ordinary business records that
demonstrate compliance with the EPA's regulation of
PCE under TSCA (see 40 CFR 751.615CaY). These
records are necessary to demonstrate that PCE is
being manufactured, processed, distributed, used, or
disposed of only in compliance with the restrictions of
the PCE rule.

These records must be maintained for 5 years from the
date the record is created (see 40 CFR 751.615(f)).

This requirement begins on February 18, 2025.

Examples of ordinary business records:

•	Bills-of-lading;

•	Invoices;

•	Receipts; and

•	Downstream notifications.

B,	Records requirements for owners and
operators of business entities that use PCE as an
energized electrical cleaner.

In accordance with 40 CFR 751.615(d)(Th persons
who own or operate a business entity that purchases
and uses PCE, including any PCE-containing products,
for the industrial and commercial use as an energized
electrical cleaner must retain records of the following:

•	Statement regarding whether the owner or
operator is complying with the prescriptive PPE
requirements or with the WCPP (see Unit III for
more information);

•	Dermal and respiratory protection used by each
potentially exposed person and program
implementation (see 40 CFR 751.611 (WT;') or
WCPP records (see 40 CFR 751.615(b^:

•	Labels used (see Unit V.B. of this guide and 40
CFR 751.611 (cY): and

•	Self-certification statements provided (see Unit
IV.A. of this guide and 40 CFR 751.611 ftTO.

C.	Records that distributors of PCE as an
energized electrical cleaner are required to keep.

In accordance with 40 CFR 751.615(d)(2). distributors
of PCE, including PCE-containing products, for use as
an energized electrical cleaner must retain sale
records, including:

•	Name of purchaser;

•	Date of sale;

•	Quantity of PCE or PCE-containing products sold;

•	Self-certification statement for each purchase of
PCE; and

•	Copies of labels required as discussed in Unit V.B.
of this guide (see 40 CFR 751.611(c)).

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v>E

VII: Violations for Non-Compliance

This unit describes violations of the PCE rule for use of
PCE as an energized electrical cleaner, including for
small businesses.

A. What if the EPA discovers a violation?

In accordance with section 15 of TSCA, it is unlawful to
fail or refuse to comply with any requirement under
TSCA, or with any rule promulgated under TSCA.
Therefore, any failure to comply with the final rule
would be a violation of section 15 of TSCA. It is also
unlawful under section 15 of TSCA for any person to
use for commercial purposes a chemical substance or
mixture which such person knew or had reason to
know was manufactured, processed, or distributed in
commerce in violation of TSCA section 6.

In addition, under section 15 of TSCA, it is unlawful for
any person to;

1. fail or refuse to establish or maintain records as
required by the final rule or other regulations
promulgated under this chapter;

2. fail or refuse to permit access to or copying of
records, as required by TSCA; or

3. fail or refuse to permit entry or inspection as
required by section 11 of TSCA.

Violators of the regulations under TSCA section 6 may
be subject to both civil and criminal liability.

• Under the penalty provision of section 16 of TSCA,
any person who violates section 15 could be
subject to a civil penalty for each violation. Each
day in violation of the final rule could constitute a
separate violation.

• Knowing or willful violations could lead to the
imposition of criminal penalties for each day of
violation and imprisonment. In addition, other
remedies are available to the EPA under TSCA. It
is unlawful to knowingly and willfully make or
submit in writing materially false, fictitious, or
fraudulent statements.

Individuals, as well as companies, could be subject to
enforcement actions. Sections 15 and 16 of TSCA
apply to "any person" who violates various provisions
of TSCA. The EPA may, at its discretion and where
appropriate, proceed against individuals as well as
companies.

B. How does the EPA address violations by
small businesses?

To maximize compliance, the EPA implements a
balanced program of compliance assistance,
compliance incentives, and traditional law
enforcement. Compliance assistance information and
technical advice like this guide help small businesses
to understand and meet their regulatory requirements
of protecting potentially exposed persons' health and
the environment. Compliance incentives, such as the
EPA's Small Business Policy, apply to businesses with
100 or fewer employees and encourage persons to
voluntarily discover, disclose, and correct violations
before they are identified by the government (more
information about the EPA's Small Business Policy is
available at https://www.epa.gov/enforcement/small-
businesses-and-enforcemenf). The EPA's enforcement
program is aimed at protecting the public by ensuring
compliance with regulations under TSCA section 6.

The EPA encourages small businesses to work with
the Agency to discover, disclose, and correct violations.
The EPA's Audit Policy, which provides incentives for
regulated entities to voluntarily discover and fix
violations of federal environmental laws and
regulations, may be helpful for this process. The
Agency has developed self-disclosure, small business,
and small community policies to mitigate penalties for
small and large entities that cooperate with the EPA to
address compliance problems.

For more information on compliance assistance and
other EPA programs for small businesses, please
contact the EPA's Small Business Ombudsman
Program via their toll-free hotline at 800-368-5888 or
by email at asbo@epa.gov. You can also find technical
environmental compliance assistance in your state
through the Small Business Environmental Assistance
Program (SBEAP) here: States I National Small
Business Environmental Program (nationalsbeap.org).

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Frequently Asked Questions (FAQs)

Where can I go if I have questions or need further
assistance?

Please contact the EPA's TSCA Hotline with questions
by telephone at (202) 554-1404 or by email at tsca-
hotline@epa.gov or PCE.TSCA@epa.qov. For small
businesses, please see the EPA's Small Business
Ombudsman Website. Small businesses may find the
helpful for providing resources and information about
this PCE regulation. For direct technical assistance
related to this rule and other state-specific
environmental regulations, the National SBEAP can
provide free one-on-one consultations in most states to
help consider your small business environmental
compliance responsibilities and to assist in pollution
prevention opportunities.

Should I follow the prescriptive workplace controls
or the WCPP, or both?

The PCE rule allows for the owner or operator of a
business entity purchasing and using PCE, including
any PCE-containing products, for the industrial and
commercial use as an energized electrical cleaner to
choose whether to follow the prescriptive workplace
controls or the WCPP (see 40 CFR 751.611(b)').
Owners or operators are not required to follow both,
although there are some overlapping provisions.
Depending on the specific circumstances of a business
entity, the owner or operator may find one easier or
more suitable to implement than the other.

Where can I find more information?

More information on how the EPA is addressing the
unreasonable risk from chemical substances can be
found at https://www.epa.gov/assessinq-and-
managing-chemicals-under-tsca/risk-management-
existinq-chemicals-under-tsca. You may also contact
the EPA's TSCA Hotline by telephone at (202) 554-
1404 or by email at tsca-hotline@epa.gov.

For PCE, additional information is available at

https://www.epa.gov/assessinq-and-manaQinq-
chemicals-under-tsca/risk-manaqement-
perchloroethvlene-pce. The regulations can be found in
the Federal Register Notice at

https://www.federalregister.gOv/documents/2024/12/18/
2024-30117/perchloroethvlene-pce-regulation-under-
the-toxic-substances-control-act-tsca or at docket
EPA-HQ-OPPT-2020-0720 at
https://www.regulations.gov. You can also email
PCE.TSCA@epa.gov with information or questions.

Is this guide updated?

This manual is the first version of the compliance
guide. The EPA will ensure that the latest updated
compliance guides are available at

https://www.epa.gov/assessing-and-managing-

chemicals-under-tsca/risk-management-

perchloroethvlene-pce.

What if I become aware of a violation?

To report a violation, please see instructions at

https://www.epa.gov/report-violation. The EPA's Audit
Policy, which provides incentives for regulated entities
to voluntarily discover and fix violations of federal
environmental laws and regulations, may also be
helpful for this process.

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oE

Appendix A: Abbreviation List and Glossary

Abbreviation List

ASBO

Asbestos and Small Business Ombudsman

CAS RN

Chemical Abstracts Service (CAS) Registry Number

CFR

Code of Federal Regulations

EPA

Environmental Protection Agency

FAQs

Frequently Asked Questions

NFPA

National Fire Protection Association

NIOSH

National Institute for Occupational Safety and Health

OSHA

Occupational Safety and Health Administration

PAPR

Power air-purifying respirator

PCE

Perchloroethylene

PPE

Personal protective equipment

SAR

Supplied-air respirator

SBEAP

Small Business Environmental Assistance Program

SCBA

Self-contained breathing apparatus

SDS

Safety data sheet

TSCA

Toxic Substances Control Act

WCPP

Workplace Chemical Protection Program

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v>E

Glossary

Chemical substance - Defined in TSCA section 3(2) to mean organic or inorganic substance of a particular molecular
identity, including:

(1)	Any combination of such substances occurring in whole or in part as a result of a chemical reaction or
occurring in nature, and

(2)	Any element or uncombined radical.

Such term does not include:

(i)	any mixture,

(ii)	any pesticide (as defined in the Federal Insecticide, Fungicide, and Rodenticide Act) when manufactured,
processed, or distributed in commerce for use as a pesticide,

(iii)	tobacco or any tobacco product,

(iv)	any source material, special nuclear material, or byproduct material (as such terms are defined in the
Atomic Energy Act of 1954 and regulations issued under such Act),

(v)	any article the sale of which is subject to the tax imposed by section 4181 of the Internal Revenue Code of
1954 (determined without regard to any exemptions from such tax provided by section 4182 or 4221 or any
other provision of such Code) and any component of such an article (limited to shot shells, cartridges, and
components of shot shells and cartridges), and

(vi)	any food, food additive, drug, cosmetic, or device (as such terms are defined in section 201 of the Federal
Food, Drug, and Cosmetic Act) when manufactured, processed, or distributed in commerce for use as a food,
food additive, drug, cosmetic, or device.

The term "food" as used in clause (vi) of this subparagraph includes poultry and poultry products (as defined in
sections 4(e) and 4(f) of the Poultry Products Inspection Act), meat and meat food products (as defined in
section 1(j) of the Federal Meat Inspection Act), and eggs and egg products (as defined in section 4 of the Egg
Products Inspection Act).

Condition of use - Defined in TSCA section 3(4) to mean the circumstances, as determined by EPA, under which a
chemical substance is intended, known, or reasonably foreseen to be manufactured, processed, distributed in
commerce, used, or disposed of.

Direct dermal contact - (40 CFR § 751.5) Direct handling of a chemical substance or mixture (such as PCE) or skin
contact with surfaces that may be contaminated with a chemical substance or mixture (such as PCE).

Effective Date - The date on which a regulation takes effect and becomes enforceable. In this case, the effective date
is on January 17, 2025.

Energized electrical cleaner - (40 CFR § 751.603) The EPA defines an energized electrical cleaner as a product that
meets both of the following criteria:

•	The product is labeled to clean and/or degrease electrical equipment, where cleaning and/or degreasing is
accomplished when electrical current exists, or when there is a residual electrical potential from a component,
such as a capacitor; and

•	The product label clearly displays the statements: "Energized Equipment use only. Not to be used for
motorized vehicle maintenance, or their parts."

Owner or operator - (40 CFR § 751.5) Any person who owns, leases, operates, controls, or supervises a workplace.

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v>E

Potentially exposed person - (40 CFR Part § 751.5) Any person who may be exposed to a chemical substance or
mixture in a workplace as a result of a condition of use of that chemical substance or mixture. This includes those who
work directly with the chemicals, other employees, independent contractors, employers, and all other persons in the
workplace where PCE is present.

Products - (40 CFR § 751.5) The chemical substance, a mixture containing the chemical substance, or any object
that contains the chemical substance or mixture containing the chemical substance that is not an article.

Worker-A person who performs work in areas where PCE is present, including both those who handle PCE and
those who do not directly handle PCE.

Workplace Chemical Protection Program (WCPP) - A program to protect workers from unreasonable risk posed by
exposure to a regulated substance for certain conditions of use under TSCA. The WCPP includes a suite of measures
to work together to create a workplace safety program for PCE. WCPP provisions include a regulatory ECEL, initial
and periodic monitoring, respirator selection criteria, recordkeeping, and downstream notification for PCE to ensure
that workers are no longer at risk.

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v>E

Appendix B: Fact Sheet

The next page reproduces the EPA's fact sheet providing an overview of the 2024 regulation of PCE under TSCA. The
fact sheet is available at https://www.epa.aov/assessina-and-manaaina-chemicals-under-tsca/risk-manaaement-
perchloroethvlene-pce.

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FACT SHEET

2024 Final Risk Management Rule for
Perchloroethylene under TSCA

oEPA

What is perchloroethylene (PCE)?

Perchloroethylene (CASRN 127-18-4) - also called PCE or perc- is a colorless liquid and a volatile chemical with a mildly
sweet odor. PCE is a solvent that is widely used for consumer uses such as brake cleaners and adhesives, in commercial
applications such as dry cleaning, and in many industrial settings. For example, PCE is used as a chemical intermediate
in the production of refrigerants and as a processing aid at petroleum refineries.

In December 2024, EPA issued a final rule regulating PCE under the Toxic Substances Control Act (TSCA) to protect
people from health risks such as damage to the kidney, liver, and immune system, neurotoxicity and reproductive toxicity,
and cancer from inhalation or dermal exposures.

Who is subject to the PCE regulation?

Anyone who manufactures (including imports), processes, distributes in commerce, uses, or disposes of PCE or products
containing PCE may be impacted by EPA's regulation of the chemical.1 The table below is a summary of key points; full
details are in the final rule.

What is the PCE regulation2 under TSCA?

PCE Workplace Chemical Protection Program

A workplace chemical protection program (WCPP) is required for several
occupational conditions of use of PCE. These include:

Domestic manufacturing.

Import.

Processing as a reactant.

Processing into formulation, mixture, or reaction product.
Repackaging.

Use in maskant for chemical milling.

Use in petrochemical manufacturing as a processing aid in catalyst
regeneration.

Use in solvent-based adhesives and sealants.

Use as a processing aid in sectors other than petrochemical
manufacturing.

Use as a solvent for open-top batch and closed-loop batch vapor
degreasing.

Use as a solvent for cold cleaning of tanker vessels.

Recycling.

Disposal.

The WCPP requires that owners and operators of facilities using PCE
take appropriate measures to meet a new inhalation exposure limit (0.14
ppm as an 8-hour time weighted average),3 prevent skin contact, and
develop and implement an exposure control plan, among other
requirements. Additional details on the WCPP requirements and
compliance timeframes are available on page 3.

Recordkeeping and Downstream Notification

Manufacturers, processors, and distributors are required to update Safety
Data Sheets to spread awareness throughout the supply chain. Relevant
SDS must be updated by February 18, 2025 for manufacturers and June
16, 2025 for processors and distributors. Manufacturers, processors,
distributors, and users are required to maintain ordinary business records
that demonstrate compliance with the rule.

Prohibitions for Consumer Uses of PCE

Distributing PCE for consumer use will be phased out,
with distribution by retailers for all such uses prohibited
after March 8, 2027.

Prohibitions for Commercial Uses of PCE4

Most commercial uses will be phased out, with all such
uses prohibited after June 7, 2027.

Prohibitions for PCE in Dry Cleaning

Use of PCE for dry cleaning and spot cleaning will be
phased out in stages beginning June 16, 2025, with all
such uses prohibited after December 19, 2034.

Workplace Controls for PCE in Energized
Electrical Cleaning

After March 13, 2026, owners and operators must
provide dermal and (in certain cases) respiratory
protection (or comply with the WCPP) and self-certify
compliance with the rule to purchase and use PCE for
energized electrical cleaning. Manufacturers,
processors, and distributors of PCE-containing
energized electrical cleaner must include a warning
label on each product, as specified at§ 751.611(c).

Workplace Controls for PCE in Laboratory
Use

After December 15, 2025, owners and operators must
use laboratory ventilation devices and provide dermal
protection in laboratory settings.

1 Products containing PCE up to 0.1% by weight are excluded from this regulation.

2 Details of these requirements are in 40 CFR Part 751, subpart G, available at https://www.federalreqister.gov/documents/2024/12/18/2024-
30117/perchloroethvlene-pce-requlation-under-the-toxic-substances-control-act-tsca.

3 The inhalation exposure limit and related requirements do not apply to recycling and disposal. All other WCPP requirements apply.

4 There is a 10-year TSCA section 6(g) exemption for the emergency use of PCE for NASA in furtherance of its mission-critical needs. Only
NASA and its contractors are exempted for a narrow set of conditions of use.

December 2024

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FACT SHEET

2024 Final Risk Management Rule for
Perchloroethylene under TSCA

Compliance Timelines for Prohibitions

EPA prohibits manufacturing (including importing), processing, and distributing in commerce PCEforall consumer and
most industrial and commercial uses. The final rule imposes prohibitions in a staggered timeframe, beginning at the top of
the supply chain.

Requirement*

Compliance Date

Prohibition on manufacturing

Manufacturers All persons are prohibited from manufacturing (including importing) PCE except for
(including industrial and commercial uses that will continue under the WCPP or other workplace
importers) controls and drv cleaning (see § 751.605(b)(1)).

June 11,2026

Prohibition on processing

Processors All persons are prohibited from processing PCE, including any PCE-containing products,
except for industrial and commercial uses that will continue under the WCPP or other
workplace controls and drv cleaning (see § 751.605(b)(2)).

September 9, 2026

Prohibition on all distributors

Distributors All persons are prohibited from distributing in commerce (including making available)
PCE, including any PCE-containing products, to retailers for any use other than dry
cleaning (see § 751.605(b)(3)).

December 8, 2026

All persons are prohibited from distributing in commerce (including making available)
PCE, including any PCE-containing products, except for industrial and commercial uses
that will continue under the WCPP or other workplace controls and dry cleaning (see
§ 751.605(b)(5)).

March 8, 2027

Prohibition on distribution by retailers

Retailers All retailers are prohibited from distributing in commerce (including making available)
PCE. including anv PCE-containing products (see § 751.605(b)(4)).

March 8, 2027

Prohibition on industrial and commercial use

Industrial and All persons are prohibited from industrial or commercial use of PCE, including any PCE-
commercial containing products, except for uses that will continue under the WCPP or other
users workplace controls and drv cleaning (see § 751.605(b)(6)).

June 7, 2027

Prohibition on use of PCE in newly acquired dry cleaning machines

Dry cleaners All persons are prohibited from industrial or commercial use of PCE in dry cleaning
machines acguired after June 16. 2025 (see § 751.605(b)(7)).

June 16,2025

Prohibition on dry cleaning and related spot cleaning in 3rd generation machines

Dry cleaners All persons are prohibited from industrial or commercial use of PCE in dry cleaning and

and spot related spot cleaning in 3rd generation machines (see § 751.605(b)(8)).

cleaners

December 20, 2027

Prohibition on all dry cleaning and related spot cleaning

Dry cleaners All persons are prohibited from manufacturing (including importing), processing,	December 19, 2034

and spot	distribution in commerce, or industrial or commercial use of PCE for dry cleaning and spot

cleaners	cleaning (see § 751.605(b)(9)).

* These prohibitions do not apply to the manufacturing, processing, or distribution of PCE solely for export. Additionally, there is an
extended timeframe for prohibitions related to industrial or commercial use of PCE in an emergency by NASA or its contractors (see §
751.605(b)(10)).

vvEPA

16

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EPA Document #740F24014

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FACT SHEET

2024 Final Risk Management Rule for
Perchloroethylene under TSCA

&EPA

Compliance Timelines* for the
Workplace Chemical Protection Program

Initial Monitoring

Exposure Limit
and Dermal
Protections

Workplace
Information and
Training

Exposure
Control Plan

Other Exposure
Monitoring

Complete initial
monitoring to
determine airborne
concentration of PCE
in the workplace that
persons may be
exposed to.

Demarcate regulated
area within 3 months
of initial monitoring
data.

Existing Facilities
Before December
15, 2025 (360 days
after final rule
publication).

New Facilities
Within 30 days of
initiating the use of
PCE for a condition
of use allowed to
continue under the
rule.

Ensure that PCE
inhalation exposures
do not exceed the
ECEL for all
potentially exposed
persons (e.g.,
workers and others in
the workplace).

Ensure all persons
are separated,
distanced, physically
removed, or isolated
from direct dermal
contact with PCE.

Provide respiratory
and/or dermal
protection as
applicable.

Existing Facilities
Before March 13,
2026 (450 days after
final rule publication).

New Facilities
Within 4 months of
initiating PCE use.

All Facilities
Respiratory protection
within 3 months of
exposure monitoring
indicating ECEL
exceedance.

Develop and
implement a
program to train
potentially exposed
persons (e.g.,
workers and others
in the workplace) on
the rule's
requirements.

Ensure potentially
exposed persons
(e.g., workers and
others in the
workplace)
participate in a
training and
information program
by March 13, 2026
(450 days after final
rule publication).

Develop and
implement an
exposure control
plan.

Notify potentially
exposed persons
(e.g., workers and
others in the
workplace) of the
availability of
exposure control
plan within 30 days
of its completion.

Potentially exposed
persons can request
certain records that
must generally be
provided within 15
working days of
request.

Existing Facilities
Before June 7, 2027
(900 days after final
rule publication).

All Facilities
Update at least
every 5 years or
when circumstances
change significantly.

Periodic Monitoring
Conduct at a
minimum every 5
years, but could
occur as

frequently as every
3 months,

dependent upon
initial monitoring or
most recent
exposure monitoring
results.

As Needed
Monitoring
Conduct additional
monitoring within 30
days after any
change that may
result in new or
additional PCE
exposures.

f There are longer timeframes for Federal agencies and contractors acting for or on behalf of those agencies. See final rule for details.

For More Information

• For information or questions on the regulation of PCE under TSCA, and for additional compliance guidance that the EPA
intends to release regarding the use of PCE in dry cleaning and energized electrical cleaning, visit
https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/risk-management-perchloroethvlene-pce or contact
PCE.TSCA@epa.gov.

• For general questions and document requests about TSCA requirements, contact the TSCA Hotline at 1-800-471-7127 or
tsca-hotline@epa.gov.

• To read a non-technical summary of the risk evaluation for PCE. visit
https://www.epa.gov/svstem/files/documents/2022-12/PCE Non%20Technical%20Summarv 12-5-22-final.pdf.

• For general information or questions on environmental regulations and compliance for small business owners, visit
https://www.epa.gov/resources-small-businesses or contact asbo@epa.gov.

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EPA Document #740F24014

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