Compliance Guide
v>EPA
A COMPLIANCE GUIDE FOR THE
WORKPLACE CHEMICAL PROTECTION
PROGRAM UNDER THE TOXIC
SUBSTANCES CONTROL ACT (TSCA)
U.S. Environmental Protection Agency
Document Number: 740B24012, JANUARY 2025
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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. This guide does not stipulate the outcome of ongoing or future rulemaking conducted by the EPA. The
statements in this guide are intended solely as guidance to aid you in complying with EPA regulations issued under the
Toxic Substances Control Act (TSCA) section 6. 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, 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 specific rule
information, consult the EPA's Risk Management for Existing Chemicals under TSCA resources. Fact sheets
summarizing information in a given risk management rule may also be available.
FOR FURTHER 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 manual may be reproduced, but if this manual is altered, it may not provide accurate information that
owners or operators need to comply with the requirements of the EPA's regulations for the Workplace
Chemical Protection Program (WCPP) under TSCA. 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 WCPP in the future. Please check the EPA's website for
further information and current amendments.
This manual, titled "A Compliance Guide for the Workplace Chemical Protection Program Under the Toxic
Substances Control Act" and other materials related to the WCPP are available at
https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/guidance-regulations-issued-under-toxic-
substances.
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Table of Contents
I: Understanding the Workplace Chemical
Protection Program Under Section 6 of TSCA
1
A. Does this guide apply to me? 2
B. What is my role and how might the WCPP
affect me? 2
C. Additional regulations 2
II: Key Concepts in the WCPP 4
A. What are the EPA's TSCA ECELs? 4
B. ECEL action level 5
C. Occupational exposure monitoring 5
D. Regulated areas 6
E. DDCC and dermal PPE 6
F. Exposure Control Plan 7
G. Personal protective equipment 7
H. WCPP recordkeeping 8
III: Implementing the WCPP ........9
A. How do I calculate TWAs for an ECEL or
EPASTEL? 9
B. When or how should I conduct initial
monitoring? 9
C. When or how should I conduct periodic
monitoring? 10
D. How do I know when to conduct additional
monitoring? ...11
E. How do I establish a regulated area? 12
F. How do I implement a PPE program? 12
G. How do I implement the Exposure
Control Plan? 14
H. What does a downstream notification
require? 15
IV: Recordkeeping 16
V: Other Important Information 17
A. What is the hierarchy of controls? 17
B. What are the deadlines for meeting WCPP
requirements? 18
C. What about multi-chemical exposures in the
workplace? 19
D. What if the EPA discovers a violation? 19
E. Small business considerations 20
VI: Conclusion 21
Frequently Asked Questions (FAQs) 22
Appendix A: Abbreviation List and Glossary 25
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I: Understanding the Workplace Chemical Protection
Program Under Section 6 of TSCA
Words or phrases that appear in bold red text
throughout this guide are defined in Appendix A:
Abbreviation List and Glossary.
The EPA evaluates chemical substances under
section 6(b) of TSCA to determine whether the
chemical substance presents an unreasonable risk of
injury to health or the environment, without
consideration of costs or non-risk factors, including
potentially exposed or susceptible subpopulations,
under the conditions of use. If the EPA determines
that a chemical substance presents an unreasonable
risk to a potentially exposed susceptible subpopulation
such as workers, the Agency must then regulate the
chemical under section 6(a) of TSCA so that the
chemical no longer presents such risk. The resulting
regulation is issued for a chemical substance in the
Federal Register.
The information in this guide can help you understand
and comply with new workplace regulations from the
EPA for TSCA section 6 regulated chemical
substances. A thorough understanding of the EPA's
Workplace Chemical Protection Program (WCPP)
will help ensure compliance with the applicable WCPP
requirements and protect people in the occupational
workspace from chemical hazards.
The WCPP is an occupational chemical protection
program designed to address unreasonable risk from
chemical exposures in the workplace. A WCPP
program includes anyone in the workplace who has the
potential for exposure to a chemical regulated under
TSCA. if a TSCA regulation authorizes conditions of
use under a WCPP for a chemical substance, the
regulation will include specific WCPP requirements to
ensure the safety of persons engaging directly or
indirectly in those conditions of use. Such requirements
would include actions to protect persons in the
workplace from inhalation risk, dermal risk, or both, as
well as recordkeeping and other general requirements
outlined in Unit II and Unit ill. Though this guide uses
the term "occupational" to describe WCPP
requirements typically found in a TSCA regulation, it is
important to note that the WCPP provisions protect all
potentially exposed persons within an occupational
setting. Refer to potentially exposed person in Unit I.B.
or the Glossary at the end of this guide for examples.
This compliance guide provides information to help you
understand the EPA's WCPP. It is not intended to
replace compliance with a specific EPA risk
management regulation under TSCA section 6(a).
TSCA section 6(a) risk management regulations may
be accompanied by individual compliance guides to
address small business needs and/or provide a
general overview of a specific TSCA section 6(a)
regulation. Upon publication of a final rule and prior to
its effective date, the EPA may post the
accompanying chemical-specific compliance guide.
Therefore, it is recommended to regularly review the
EPA risk management page for the desired chemical
substance(s) to determine whether a compliance guide
is available for an individual TSCA section 6 regulation.
This guide aims to provide an overview of the WCPP
as it may apply across a wide range of industries.
However, no document can anticipate or address every
possible industry or situation that may arise. The
business landscape is diverse and constantly evolving,
and workplace compliance factors can vary
significantly depending on industry sector, company
size, geographic location, and specific regulatory
requirements. Users of this guide should consider their
particular circumstances and consult with legal or
compliance professionals when dealing with complex
or ambiguous circumstances. The information in this
document is intended to provide a predictable starting
point, and should be carefully reviewed and adapted
based on the details of a chemical-specific TSCA
section 6(a) regulation and facility circumstances.
This compliance guide for the WCPP:
Describes the EPA's WCPP and why it is
important.
Helps you understand:
Whether it applies to you;
Potential responsibilities for a WCPP within a
TSCA section 6 rule; and
Additional resources to plan for successful
implementation.
Explains how important WCPP concepts affect
compliance responsibilities.
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Provides insight into occupational exposure control
considerations within the WCPP
Provides notes to help you better understand
potential compliance responsibilities.
A. Does this guide apply to me?
You may be impacted by the WCPP if you own or
operate a business that manufactures (including
imports), processes, distributes in commerce, uses, or
disposes of a chemical substance for conditions of use
that the EPA has identified to present unreasonable
risk and has subsequently regulated. This guide also
provides entities with information to protect workers
and other potentially exposed persons that use or are
in the vicinity of the use of chemicals that are regulated
due to unreasonable risk. The conditions of use or
subsets of conditions of use for which the WCPP would
apply will vary from chemical substance to chemical
substance based on chemical-specific hazards,
occupational exposure, risk characterization, and other
factors. While the EPA anticipates that broad principles
of the WCPP will be common across rules, individual
rule provisions may vary and could potentially include
unique requirements necessary to protect individuals
from unreasonable risk in the workplace. Consult with
the WCPP section of the final TSCA section 6 risk
management rule and the accompanying compliance
guide, if available, for more details on specific
chemicals. Additionally, conditions of use, or subsets of
a condition of use, authorized under the WCPP will be
specified in the rule for that chemical.
B. What is my role and how might the WCPP
affect me?
Persons who own or operate a facility that use a
chemical substance managed under TSCA section 6
are responsible for complying with the prohibitions and
other restrictions in a specific TSCA chemical
rulemaking, which may include complying with
regulatory provisions that are consistent with the
WCPP. The EPA has defined "owner or operator" to
include any person who owns, leases, operates,
controls, or supervises a workplace covered within 40
Code of Federal Regulations (CFR) Part 751 (see 40
CFR 751.5). if you are unsure if your business uses a
chemical substance managed under TSCA section 6,
see the EPA's final risk management rule for the
particular chemical substance and condition of use. For
additional information, please visit the Regulation of
Chemicals Under TSCA Section 6 webpage.
Other individuals, such as potentially exposed persons,
or other representatives acting on behalf of those
persons, may want to refer to this guide to understand
what protections are required in the workplace under
TSCA section 6 regulations that require the WCPP.
Potentially exposed persons are those 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 (see 40 CFR 751.5).
Potentially exposed persons include workers,
employees, independent contractors, employers,
university students, volunteers, self-employed persons,
and state and local government workers, and all other
persons in the workplace where a TSCA-regulated
chemical substance is present.
C. Additional regulations
In addition to applicable risk management regulations
for chemical substances under TSCA section 6(a),
other Federal, state, or local statutes or regulations
may also be relevant to you. These statutes or
regulations may apply to you in addition to WCPP, or
potentially be cross-referenced in a TSCA section 6
rule. Some examples include:
EPA
National Emission Standards for Hazardous Air
Pollutants (NESHAP), which include:
o 40 CFR Part 63. subpart F Synthetic
Organic Chemical Manufacturing Industry;
o 40 CFR Part 63, subpart DP Off-Site
Waste and Recovery Operations;
a 40 CFR Part 63, subpart VW Publicly
Owned Treatment Works; and
o 40 CFR Part 63. subpart VWVVV
NESHAP for Chemical Manufacturing Area
Sources.
Comprehensive Environmental Response.
Compensation, and Liability Act (CERCLA)
Resource Conservation and Recovery Act
(RCRA)
Occupational Safety and Health Administration
(OSHA)
29 CFR 1910 Subpart Z Toxic and Hazardous
Substances
29 CFR 1904 Reporting Occupational Injuries
and Illnesses
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29 CFR 1910.120 Hazardous Waste
Operations and Emergency Response
29 CFR 1910.132 General Requirements
(PPE)
29 CFR. 1910.133 Eye and Face Protection
29 CFR 1910.134 Respiratory Protection
(including fit test protocols under Appendix A)
29 CFR. 1910.138 Hand Protection
29 CFR 1910.146 General Industry Permit-
Required Confined Spaces
29 CFR. 1910.147 Control of Hazardous
Energy (lockout/tagout)
29 CFR 1910.307 Hazardous Locations
29 CFR 1910.1000 Air Contaminants
29 CFR 1910.1020 Access to Employee
Exposure and Medical Records
29 CFR 1910.1020 Access to Employee
Exposure and Medical Records
29 CFR 1910.1200 Hazard Communication
29 CFR. 1910.1450 Occupational Exposure to
Hazardous Chemicals in Laboratories
29 CFR 1926 Subpart Z Toxic and Hazardous
Substances
Did You Know?
WCPP requirements in EPA rules do not
supersede OSHA's rules. The regulated
community must ensure compliance with all
applicable regulations. If OSHAhas 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.
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II: Key Concepts in the WCPP
The WCPP is a program that can be utilized in TSCA
section 6 rules to protect potentially exposed persons
in the workplace from unreasonable risk due to
exposure to a TSCA regulated chemical substance.
WCPP provisions may include a regulatory
occupational exposure limit called an Existing
Chemical Exposure Limits (ECEL), initial and
periodic monitoring, respirator selection criteria,
training, recordkeeping, downstream notification, or
other provisions to ensure that potentially exposed
persons are not exposed to unreasonable risk from a
chemical substance. Depending on the chemical
substance's particular hazard and exposure
characteristics, circumstances, or the EPA's
considerations, owners or operators can use the
flexibility within the WCPP in deciding how to best
prevent exceedances of the EPA's exposure limits for
the TSCA regulated chemical substance. Typical
WCPP provisions required in chemical specific TSCA
section 6 regulations may include:
An EPA Occupational Exposure Limit (e.g., ECELs
or EPA Short-Term Exposure Limit (EPA STEL)
designated under TSCA;
An ECEL action level;
Occupational exposure monitoring;
Regulated area(s);
An Exposure Control Plan;
Direct Dermal Contact Control (DDCC);
Personal Protective Equipment (PPE) Program;
Respiratory protection;
Dermal/eye and face protection;
Training requirements;
Recordkeeping requirements; and
Downstream notification.
These provisions of a WCPP work together to ensure
that potentially exposed persons are protected from
unreasonable risk in the workplace from use of a TSCA
section 6 regulated chemical. While this guide provides
a broad look at useful information to consider, 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.
A. What are the EPA's TSCA ECELs?
A WCPP for a TSCA section 6 rule may include an
exposure limit as part of a WCPP. ECELs are legal
limits on the amount or concentration of a chemical
substance in workplace air. To protect potentially
exposed persons from the unreasonable risks from
inhalation exposure to chemicals in the workplace, the
EPA may establish exposure limits (e.g., an ECEL, EPA
STEL, etc.) for conditions of use in a chemical specific
TSCA section 6 rule. A given section 6 risk
management rule may also include provisions or
specific workplace controls for a condition of use that
are outside of a WCPP.
An exposure limit (e.g., ECEL) promulgated as part
of a TSCA risk management rule may be different
from the occupational exposure value (OEV)
identified as part of the chemical substance's risk
evaluation. The OEV is set in the risk evaluation at
the level below which the EPA would not expect
any appropriate adverse health effects for a worker
exposed to the chemical substance for a working
lifetime without exposure-reducing controls in place,
such as PPE.
The EPA's ECELs are included in a WCPP when rules
are proposed and finalized. The ECEL is typically
expressed as an 8-hour time-weighted average (TWA),
and is a maximum average airborne concentration of
the chemical substance that a person can be exposed
to in the workplace. The EPA may also establish an
EPA STEL in a final risk management rule, typically
expressed as a 15-minute TWA to protect potentially
exposed persons from acute occupational inhalation
risk.
Did You Know?
You can find all the EPA's TSCA Section 6 ECELs
at https://www.epa.gov/assessing-and-managing-
chemicals-under-tsca/list-final-and-proposed
existing-chemical-exposure.
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As part of a WCPP, owners or operators must ensure
that potentially exposed persons are not exposed to
concentrations of chemical substances above the
ECEL and/or EPA STEL in the workplace. Regulated
entities have flexibility within the parameters of the
WCPP of a given TSCA section 6 rule in deciding how
to best prevent exceedances of the EPA exposure
limits for the regulated chemical substance. The
flexibility is accomplished by instituting one or a
combination of controls that work for the particular
facility based on the National Institute for Occupational
Safety and Health (NIOSH) hierarchy of controls (see
Unit Y.A. for more details on the hierarchy of controls).
The hierarchy of controls is a hazardous exposure
mitigation model that identifies the preferred order of
actions to mitigate workplace exposures and includes:
Elimination;
Substitution:
Implementing engineering controls;
Administrative controls (if appropriate); and
Where feasible controls are not sufficient to reduce
exposures to or below the ECEL and/or the EPA
STEL, supplementing such controls using PPE
(e.g., use of respiratory protection in combination
with an engineering control when inhalation
exposure may occur).
The EPA's risk management rules typically require
owners or operators to consider and implement
feasible exposure controls before resorting to PPE to
reduce exposures to or below the ECEL and/or EPA
STEL within a regulated area. Additional information on
the hierarchy of controls and the Exposure Control
Plan may be found in Unit II.F. and Unit Ili.G.
B. ECEL action level
The concept of the action level is familiar to many in
the occupational health profession, from chemical-
specific OSHA standards under 29 CFR part 1910.
Subpart Z. that establish action levels for various
chemicals
An ECEL action level is an airborne concentration of a
chemical substance typically identified as an 8-hour
TWA. ECEL action levels are not an exposure limit, but
they do provide useful occupational exposure
information that may trigger additional compliance
action(s) by an owner or operator. Not all TSCA section
6 rules for a chemical will include one. As part of a
WCPP, the EPA may establish an ECEL action level,
typically set at half the regulatory ECEL, established in
the TSCA section 6 rule. For example, air
concentrations at or above an established action level
may trigger more frequent periodic monitoring or other
necessary ancillary requirements to ensure the
protection of human health. See Unit II.C. and Unit
MLC. for additional information on periodic monitoring.
For information on the ECEL action level for a specific
chemical substance, consult the WCPP section of the
TSCA risk management rule for the chemical
substance.
C. Occupational exposure monitoring
Occupational exposure monitoring within a WCPP
typically encompasses:
Initial monitoring - monitoring that establishes a
baseline exposure for potentially exposed persons
to the regulated chemical substance.
Periodic monitoring - monitoring conducted at
some minimum interval established in the WCPP
and laid out in the regulation for the specific
chemical.
Additional monitoring - monitoring where there
is a workplace change (e.g., change in equipment)
that may increase or otherwise introduce additional
sources of exposure to a TSCA section 6 regulated
chemical substance.
When conducting monitoring, the owner or operator is
responsible for evaluating occupational exposure(s)
against one or more of the following established
chemical substance-specific air concentrations:
ECEL action level
ECEL
EPA STEL
In general, the WCPP may reflect some basic
occupational sampling requirements:
Minimum accuracy criteria (e.g., accurate to a
confidence level of 95% are within plus or minus
25% of airborne concentrations of the chemical
substance relative to the 8-hour TWA ECEL);
Identifying and/or requiring specific analytical
methods to be used for occupational sampling(s);
Identifying and/or requiring specific sampling
media for occupational sampling(s) (e.g.,
intrinsically safe gas metering devices, monitoring
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badges, gas chromatography equipment, gas
detection tubes, etc.);
Use of accredited laboratories and facilities for
analysis of occupational sampling(s);
Requiring a safety and health professional for
review of certain occupational exposure sampling
(e.g., a Certified Safety Professional, a Certified
Industrial Hygienist, etc.);
Sample(s) must be taken from the personal
breathing zone (PBZ) of a representative
population, and without regard to respiratory
protection;
Sample(s) must be taken for potentially exposed
person(s) expected to have the highest exposure
in an exposure group;
Sample(s) must be taken when and where the
operating conditions are best representative of
each potentially exposed person's full-shift or
short-term exposure;
Potentially exposed person, or a representative
acting on their behalf, must have an opportunity to
observe monitoring representative of the exposure;
and/or
Other chemical substance or condition of use-
specific requirements.
Did You Know?
There are a wide array of chemical
management/industrial hygiene resources
available to develop appropriate occupational
sampling strategies. NIOSH is currently
considering updating the 1977 Occupational
Exposure SamDlina Strateav Manual (OESSIVD to
reflect advances in the state of the sciences of
exposure and occupational risk assessment.
NIOSH has also published more recent guidance
for workplace samplina for some enaineered
nanomaterials.
D. Regulated areas
Within a WCPP, a regulated area means an area
established by the regulated entity to distinguish areas
where airborne concentrations of a specific chemical
substance exceed, or there is a reasonable possibility
they may exceed, the applicable ECEL or EPA STEL.
Regulated areas must be established as part of a
WCPP, serving as an important
engineering/administrative control to limit the number
of potentially exposed persons and ensure that only
properly authorized, trained and/or certified, and
protected individuals enter areas with elevated
exposure potential.
The EPA anticipates that regulated areas required by a
WCPP for a chemical will be established within a
reasonable time period after initial monitoring has been
conducted and the airborne concentrations of the
chemical substance have been ascertained. Because
implementation timeframes may differ between
respective TSCA section 6 rules depending on
chemical-specific hazards, exposures, risk
characterization, and other factors, it is best to consult
the chemical-specific regulation.
E. DDCC and dermal PRE
To reduce exposures in the workplace and address the
unreasonable risk of injury to health resulting from
dermal exposures to a chemical substance, the EPA
may include a DDCC component or other dermal
control measures in the WCPP. DDCCs are designed
to prevent dermal exposures to potentially exposed
persons while in the presence of a chemical substance
and may include chemical resistant gloves or other
PPE. Similar to the requirements for reducing
inhalation exposure, DDCC provisions in a risk
management rule are likely to require, in accordance
with the hierarchy of controls, that feasible controls that
are more protective be considered and implemented
prior to the use of PPE. Such protective controls
include elimination, substitution, engineering, and
administrative controls, or a combination of these
controls.
For dermal protections, the EPA recommends PPE
selection based on the tasks to be performed and the
performance and characteristics of the gloves/dermal
PPE. Glove selection for chemical protection should be
based on the chemical resistance and penetrative
properties of the glove material against the particular
chemical substance. Some TSCA section 6 risk
management rules require the owner or operator to
demonstrate that the selected dermal PPE will prevent
direct contact with the chemical substance under the
expected conditions within the work area by evaluating
the manufacturer's specifications or available test data.
For information on the dermal PPE requirements for a
specific chemical substance, consult the WCPP
section of the TSCA risk management rule for that
chemical substance.
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F. Exposure Control Plan
A regulation of a chemical substance under TSCA
section 6 typically requires owners or operators to
develop and implement an Exposure Control Plan as
part of the WCPP The purpose of the Exposure
Control Plan is to document the consideration and
implementation of exposure controls in accordance
with the hierarchy of controls to reduce exposure to or
below EPA exposure limits. Specifically, the Exposure
Control Plan provisions require that owners or
operators consider each level of the hierarchy of
controls, and document thorough rationale on what
exposure controls were available and considered, what
exposure controls were or were not implemented, and
an explanation of why other exposure controls
considered were or were not implemented. The
rationale generally must demonstrate compliance with
the requirement that the more effective exposure
controls were considered and exhausted in order to
prevent an overreliance on PPE and provide
assurance to potentially exposed persons of their
health and safety. As such, the Exposure Control Plan
serves to inform potentially exposed persons about
how they are being protected, and acts as a conduit for
continuous improvement and accountability.
The Exposure Control Plan serves as an important
programmatic documentation of the measures taken to
mitigate occupational exposure to a TSCA section 6
regulated chemical. The Exposure Control Plan
represents the culmination of the earlier elements of
the WCPP (e.g., initial monitoring, implementing
occupational exposure controls, and documenting
other WCPP requirements). The implementation
timeframes may differ between respective TSCA
section 6 rules depending on chemical-specific
hazards, exposures, risk characterization, and other
factors.
G. Personal protective equipment
PPE is equipment worn to reduce or mitigate exposure
to chemical substances or physical hazards. Examples
of PPE include gloves, safety glasses, face shields,
and respirators. A PPE requirement may be included
as part of a WCPP to serve a role in mitigating
occupational exposure. Elements of determining
appropriate PPE may include PPE selection, use
training, PPE inspection and replacement schedules,
storage, and effectiveness monitoring. Under a WCPP,
owners or operators are generally not permitted to rely
on PPE as a primary method of mitigating exposures
without first considering and implementing all feasible
controls in accordance with the hierarchy of controls
and documenting the consideration of available
controls in the Exposure Control Plan.
An individual TSCA section 6 rule may include an
implementation time period for respiratory protection
measures and/or PPE program implementation. The
implementation timeframes may differ between
respective TSCA section 6 rules depending on
chemical-specific hazards, exposures, risk
characterization, and other factors.
Both OSHAand NIOSH offer valuable guidance and
information on PPE and personal protective technology
(PPT).
OS HA offers guidance on PPE [OSHA 3151-02R
20231.
NIOSH offers guidance on key PPE resources and
PPT research at NIOSH.
Respiratory protection
A WCPP may require owners or operators to institute
engineering and/or administrative controls, and
maintain their effectiveness to reduce employee
exposure to or below the ECEL or EPA STEL.
Respirators as a means of compliance are generally
only allowed under the rules when all feasible
engineering controls, work practices, and
administrative controls are insufficient. If respiratory
protection is relevant to a particular TSCA section 6
regulated chemical substance, the EPA generally
intends to align WCPP respiratory protection
requirements with OSHA's requirements on respiratory
protection, such that the respirator requirements are
based on recent exposure monitoring concentrations.
Respirator use and accompanying medical evaluation,
fit-testing, and training must be in accordance with the
requirements in 29 CFR 1910.134.
Respirators are an important piece of PPE for
potentially exposed persons that safeguards users
through two potential ways. One type of respiratory
protection filters harmful contaminants from ambient air
in the workplace. These respirators include air purifying
respirators that may filter particulates or chemicals and
gases, depending on the cartridges used with the
respirator. Alternatively, some respirators protect
potentially exposed persons by supplying clean air
from an external source. Supplied air respirator
examples include airline respirators and self-contained
breathing apparatus (SCBA) respirators.
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Dermal, eye and face protection
When issuing TSCA section 6 risk management rules,
the EPA considers all routes of exposure that
contribute to the unreasonable risk, including inhalation
and dermal exposures, and the exposed populations.
Depending on the nature of the chemical hazard and
the occupational exposures, a WCPP for a specific
chemical substance may include dermal PPE
requirements and potentially eye and face protection,
consistent with OSHA's PPE standards. See Unit II.E.
for more information on DDCC and dermal PPE.
Training
The EPA may include general requirements that
owners or operators provide training to all persons
required to use respiratory protection (consistent with
29 CFR 1910.134(kV) and PPE (consistent with 29
CFR 1910.132) prior to or at the time of initial
assignment to a job involving potential exposure to the
TSCA section 6 regulated chemical substance. These
requirements typically include retraining of all persons
required to use respiratory protection or PPE at least
annually, or whenever the owner or operator has
reason to believe that a previously trained person does
not have the requisite understanding or skill to properly
use respiratory protection or PPE, or when there are
changes in the workplace, or when changes to the
respirator or PPE to be used render the previous
training obsolete.
As part of the PPE requirements, the EPA may require
that owners or operators comply with OSHAs general
PPE training requirements under 29 CFR 1910.132 for
application of a PPE training program, including
providing training on proper use of PPE (e.g., when
and where PPE is necessary, proper application
(donning), wear (clean shaven or securing loose
clothing/jewelry/hair), removal of PPE (doffing),
maintenance, storage, useful life, and disposal of
PPE). The EPA may also require chemical-specific
training related to the chemical's hazard(s) and
associated adverse health effects, routes and
pathways of exposure, the hierarchy of controls,
implemented exposure controls, regulated areas, or
other aspects of the WCPP.
The recordkeeping provisions of a WCPP typically
require that owners or operators document training(s)
associated with a respiratory protection program or a
PPE program. See Unit II.H. and Unit IV. for more
information on WCPP recordkeeping.
H. WCPP recordkeeping
Recordkeeping is an important component of
demonstrating compliance with TSCA section 6 rules.
An individual TSCA section 6 rule typically includes
recordkeeping requirements for the rule (e.g., retention
of bills-of-lading to demonstrate compliance with
restrictions in a given rule) and/or WCPP
recordkeeping requirements. For owners or operators
to demonstrate compliance with the WCPP provisions,
the EPA requires that owners or operators retain
compliance records for five years.1
In addition to the recordkeeping requirements
associated with the Exposure Control Plan discussed
above in Unit. II.F.. the WCPP recordkeeping
requirements document training or re-training of any
potentially exposed person, as necessary, to ensure
the potentially exposed person has demonstrated
understanding of how to use and handle the TSCA
section 6 regulated chemical substance and how to
appropriately use any required PPE.
1 EPA's TSCA section 6 recordkeeping requirements do not supplant recordkeeping retention time periods such as those required
under 29 CFR 1910.1020, or other applicable regulations.
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III: Implementing the WCPP
This unit offers some general information about
implementation considerations for several key WCPP
elements.
A. How do I calculate TWAs for an ECEL or EPA
STEL?
As already noted, a WCPP may include monitoring
requirements or require that airborne chemical
concentrations remain below the chemical substance's
ECEL or EPA STEL. TWA calculations are essential for
accurately assessing worker exposure, allowing you to
compare the true exposure burden against established
exposure limits to protect worker health. Below are two
TWA calculation examples, one representing an 8-hour
TWA (i.e., an ECEL). and the other a 15-minute TWA
(i.e., an EPA STEL).
Both the ECEL and the EPA STEL are expressed as
TWA exposures. The ECEL is a regulatory exposure
iimit set by the EPA to establish a maximum average
airborne concentration of a chemical substance to
address unreasonable risk in the workplace. TWA
measurements account for variable exposure levels
over the course of a work shift, averaging periods of
higher and lower exposures. The TWA exposure for an
8-hour work shift is computed using a simple formula:
TWA = (CaTa + CbTb+. . . CnTn)/8
TWA is the time-weighted average exposure for
the work shift; C is the concentration during any
period of time (7) where the concentration remains
constant; and Tis the duration in hours of the
exposure at the concentration (C). The totality of
the variables in the formula are then divided by the
8-hour work shift, or "8," as depicted in the formula.
Note: when calculating an ECEL, be sure that all
concentration and time units are normalized
For example, assume that a potentially exposed
person is subject to the following exposure scenario to
a chemical substance regulated under TSCA section 6,
which has an action level of 4 rng/m3, an ECEL of 8
mg/m3, and an EPA STEL of 57 mg/m3:
Two hours exposure at 10 mg/m3
Two hours exposure at 5 mg/m3
Four hours exposure at 1.9 mg/m3
Substituting this information in the formula:
TWA = (2x10 + 2x5 + 4x1,9)/8 = 4.7 mg/m3
Since 4.7 mg/m3 is greater than 4 mg/m3, the action
level has been exceeded. However, as 4.7 mg/m3 is
less than 8 mg/m3, the ECEL has not been exceeded.
Additional information on the ECEL action level is
available in Unit II.B.
Now take for example, an employee that is subject to
the following chemical substance exposure over a
short-term period of 15 minutes (the EPA STEL is 57
mg/m3):
15-minute exposure at 25 mg/m3
Substituting this information in the formula (and
replacing 8 hours with a 15-minute time interval):
TWA = (15*25)/15 = 25 mg/m3
Since 25 mg/m3 is less than 57 mg/m3, the EPA STEL
has not been exceeded.
To review an additional example of an 8-hour TWA
for a chemical regulated under TSCA section 6,
view page 20 of the Trichloroethvlene Compliance
Guide.
B. When or how should I conduct initial
monitoring?
Where TSCA section 6 regulated chemical substances
are used in the workplace and pose inhalation risk, a
WCPP typically requires owners or operators to
perform initial monitoring to:
Establish a baseline of inhalation exposure for
potentially exposed persons (highest likely 8-hour
exposures and/or 15-minute inhalation exposures);
Determine the need for new, revised, or additional
exposure controls (such as engineering controls,
administrative controls, and/or a respiratory
protection program);
Inform development of the Exposure Control Plan:
and
Determine the frequency of certain compliance
activities, such as periodic monitoring or other
necessary ancillary actions to protect human
health from unreasonable risk.
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Initial monitoring requirements require characterization
of each potentially exposed person's exposure by
taking a PBZ air sample of each person's exposure or
by taking PBZ air samples that are representative.
Generally, owners or operators may consider PBZ air
samples to be representative of each potentially
exposed person's exposure when one or more
samples are taken for at least one potentially exposed
person and the person sampled is expected to have
the highest exposure. The EPA also recognizes the
utility of exposure groups or grouping potentially
exposed persons with a similar exposure profile to a
chemical substance or mixture based on the tasks
performed, the manner in which the tasks are
performed, and the materials and processes with which
they work. Sampling should be representative (i.e.,
taken from the breathing zone of potentially exposed
persons and reflect the appropriate duration of
exposure) of the most highly exposed persons relevant
or the exposure groups.
Air monitoring results from faulty or otherwise
unreliable equipment that may be malfunctioning,
uncalibrated or has exceeded its calibration schedule,
exceeded its inspection schedule as required by the
manufacturer, or in any state that the manufacturer has
deemed incapable of producing reliable
measurements, are not valid samples and require
resampling consistent with the provisions in the WCPP
section of the TSCA section 6 rule.
Did You Know?
The PBZ is a hemispheric area forward of the
shoulders within a six to nine inch radius of a
worker's nose and mouth. Exposure monitoring air
samples must be collected from within this space.
For each initial monitoring, the EPA generally requires
that the owner or operator record relevant information
about the monitoring event. This may include who the
potentially exposed persons are or who the results are
intended to represent, conditions that may affect
monitoring results such as humidity or extreme
environments, the type of sampling media, workplace
ventilation, and more. Occupational exposure data
ascertained from initial monitoring will help inform the
development of an effective Exposure Control Plan.
For more information on the Exposure Control Plan,
see Unit ILF and Unit lil.G.
C. When or how should I conduct periodic
monitoring?
Where regulated chemical substances are used in the
workplace and pose inhalation risk, a WCPP requires
owners or operators to perform periodic monitoring to:
Ensure continuity of protections so that potentially
exposed persons are not exposed to regulated
TSCA section 6 chemical substances at levels
above the ECEL and/or EPA STEL;
Ensure exposure controls are operating within
expected parameters and provide advance
awareness of potential exposure control
deterioration or failure;
Consider the need for new, revised, or additional
exposure controls (such as engineering controls,
administrative controls, and/or a respiratory
protection program); and
Inform necessary updates to the Exposure
Control Plan.
As noted previously, occupational sampling should be
representative (i.e., taken from the breathing zone of
potentially exposed persons and reflect the appropriate
exposure duration) of the most highly exposed persons
in the workplace.
For each periodic monitoring sampling event, the EPA
generally requires that the owner or operator record
relevant information. This may include who the
potentially exposed persons are or who the results are
intended to represent, conditions that may affect
monitoring results such as humidity or extreme
environments, the type of sampling media, workplace
ventilation, and more. Periodic monitoring frequency
may change depending on the results of the most
recent monitoring but will likely be required to be
repeated at least once every five years. For more
information on the Exposure Control Plan, see Unit II.F.
and Unit lil.G. For an example of how initial monitoring
may inform the periodic monitoring frequency, see
Table 1 below.
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Table 1 - Example of Periodic Monitoring Requirements Based on Initial Exposure Monitoring Results
Air Concentration Condition
Periodic Monitoring Requirement
If the initial exposure monitoring concentration is
below the ECEL action level and at or below the
EPA STEL.
ECEL and EPA STEL periodic monitoring at least once
every 5 years.
If the initial exposure monitoring concentration is
below the ECEL action level and above the EPA
STEL
ECEL periodic monitoring at least once every 5 years,
and EPA STEL periodic monitoring required every 3
months.
If the initial exposure monitoring concentration is at or
above the ECEL action level and at or below the
ECEL; and at or below the EPA STEL.
ECEL periodic monitoring every 6 months.
If the initial exposure monitoring concentration is at or
above the ECEL action level and at or below the
ECEL; and above the EPA STEL.
ECEL periodic monitoring every 6 months and EPA STEL
periodic monitoring every 3 months.
If the initial exposure monitoring concentration is
above the ECEL and below, at, or above the EPA
STEL.
ECEL periodic monitoring every 3 months and EPA STEL
periodic monitoring every 3 months.
If 2 consecutive monitoring events have taken place at
least 7 days apart that indicate that potential exposure
has decreased from above the ECEL to at or below
the ECEL, but at or above the ECEL action level.
Transition from ECEL periodic monitoring frequency from
every 3 months to every 6 months.
If 2 consecutive monitoring events have taken place at
least 7 days apart that indicate that potential exposure
has decreased to below the ECEL action level and
at or below the EPA STEL.
Transition from ECEL periodic monitoring frequency every
6 months to once every 5 years. The second consecutive
monitoring event will delineate the new date from which
the next 5-year periodic exposure monitoring must occur.
D. How do I know when to conduct additional
monitoring?
Where there is inhalation risk, additional exposure
monitoring will likely be required as part of a WCPP
after any change that may introduce additional
potential sources of exposure to a chemical substance
regulated under section 6 of TSCA, or otherwise result
in increased exposure to a chemical substance
compared to its most recent monitoring event.
Examples include changes in production, use rate,
process, control equipment, or work practices and
start-up, shutdown, or malfunction of facility equipment.
Additional exposure monitoring should not delay
implementation of any necessary cleanup or other
remedial action to reduce the exposures to potentially
exposed persons. Such remedial actions may
necessitate consideration of spill kits or to establish a
response program to address exposures that may
result from non-routine incidents. The result of
additional exposure monitoring may affect the
frequency of periodic monitoring in a TSCA section
6 rule.
Unlike initial monitoring, under a typical WCPP, prior
monitoring data cannot be used to satisfy additional
monitoring requirements. This is due to the nature of
additional monitoring requirements which generally
address and document changes in production or
processes that are unlikely to be represented by
previous exposure data and result in increased
exposure or additional sources of exposure.
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E. How do I establish a regulated area?
See Unit II.D. for an overview of regulated area
requirements.
Regulated area locations typically need to be
documented in the Exposure Control Plan. The owner
or operator is expected to establish and demarcate the
regulated area as part of the WCPP Additionally, as
part of a WCPP, the owner or operator is typically
required to restrict access to the regulated area from
any potentially exposed person who lacks proper
training and/or certification, PPE and/or respirators, or
is otherwise unauthorized to enter. A regulated area
may be established as either a permanent or transient
location within the workplace. While the regulated area
is not required to be a fixed area, designation of
temporary regulated areas may create challenges in
documenting the areas in the Exposure Control Plan.
For example, the Exposure Control Plan generally
requires a description of the regulated areas, how they
are demarcated, and persons authorized to enter.
When establishing regulated areas, owners or
operators must implement clear, visible signifiers that
alert potentially exposed persons to boundaries and
the restricted nature of the area. These markings
should be tailored to the workforce, including the use of
multiple languages, where appropriate. For example,
Spanish language signs may be appropriate in
workplaces with Spanish-speaking employees.
Once the regulated area is established, the WCPP will
likely include additional requirements, such as:
The owner or operator is required to restrict access
to the regulated area by any person that lacks
proper training and/or certification, lacks PPE, if
required, or is otherwise unauthorized to enter. For
example, restricting access could be achieved by
implementing a physical barrier that prevents
unauthorized entry (e.g., walls, doors, fencing),
sensory cues (e.g., signs, lights, audible systems),
issuing access credentials, providing informative
training, or instituting a combination of these.
Owners or operators must provide respiratory
protection sufficient to reduce inhalation exposures
to at or below the ECEL and/or EPA STEL for all
potentially exposed persons in the regulated area
within a specified time period (e.g., 3 months after
receipt of the results of any exposure monitoring).
The WCPP will typically require owners or operators to
use all feasible controls to reduce airborne
concentrations of regulated chemical substances to the
lowest levels achievable and supplement controls as
necessary with respiratory protection and/or PPE
before potentially exposed persons enter a regulated
area.
F. How do I implement a PPE program?
Where all feasible elimination, substitution,
engineering, and administrative controls are insufficient
in reducing the air concentration of a regulated
chemical substance to or below the ECEL and/or EPA
STEL, or preventing dermal contact, the WCPP may
require owners or operators to provide PPE, including
respiratory protection and dermal protection identified
in the section 6 rule, and to implement PPE/respirator
programs described in the individual rules. The
PPE/respirator programs may include respiratory
protection, dermal protection, training, and
recordkeeping to support an effective PPE program.
Elements of the PPE/respirator programs may have
unique requirements for particular chemical
substances, but will generally align with OSHA
standards under 29 CFR 1910.132 (PPE) and 29 CFR
1910.134 (respiratory protection).
1. What are the respiratory protection
requirements?
A WCPP may include a requirement to develop and
administer a written respiratory protection program in
accordance with OSHA's respiratory protection
standard under 29 CFR 1910.134(c)(1). (c)(3). and
(c)(4). This would also include requisite medical
evaluations needed to qualify potentially exposed
person for respirator use per 29 CFR 1910.134(6) and
fit testing protocols under 29 CFR 1910.134 Appendix
A. If the EPA determines that respiratory protection is
necessary to protect human health from unreasonable
risk, the EPA anticipates that the required NIOSH
Approved respirators would be based on the measured
air concentration of the TSCA chemical substance.
The EPA would require training to all persons required
to use respiratory protection that aligns with 29 CFR
1910.134(k) prior to or at the time of initial assignment
to a job involving potential exposure to the chemical
substance. Owners or operators would be required to
retrain all persons required to use respiratory
protection at least annually, or whenever the owner or
operator has reason to believe that a previously trained
person does not have the requisite understanding or
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skill to properly use respiratory protection, or when
there are changes in the workplace, or when changes
to the respirator to be used render the previous training
obsolete. The WCPP may include an implementation
period to establish or revisit an existing PPE program
as necessary to reflect current workplace conditions.
The timeframes may differ between respective TSCA
section 6 rules depending on chemical-specific
hazards, exposures, risk characterization, and other
factors.
NIOSH offers extensive guidance on respirator
selection and performance at:
https://www.cdc.qov/niosh/npptl/topics/respirators/disp
part/RespSource.html.
Did You Know?
There are two recent American Standard for
Testing and Materials (ASTM) standards that have
replaced obsolete American National Standards
Institute (ANSI) American Industrial Hygiene
Association (AIHA) standards. These new
standards address standard respiratory
protections practices and medical qualifications:
ASTM F3387 23 F3387 Standard Piactice for
Respiratory Protection
ASTM F3620 F3620 Standard Practice for
Respiratory Protection Respirator Use
Physical Qualifications for Personnel
2. What are the DDCC and dermal PPE
requirements?
To reduce exposures in the workplace and address
unreasonable risk of injury to health from dermal
exposures to a TSCA section 6 regulated chemical
substance, a WCPP may include DDCC requirements.
DDCC requirements are generally intended to
separate, distance, physically remove, or isolate
potentially exposed persons from direct handling of
regulated chemical substances and from skin contact
from surfaces that may be contaminated with the
regulated chemical substance. DDCC elements are not
generally applicable to vapor exposure to regulated
chemical substances, although the EPA recommends
and encourages owners or operators to implement
control measures to prevent or reduce dermal
exposure to airborne vapors of regulated chemical
substances.
Where the DDCC is required, owners or operators can
implement from the hierarchy of controls measures to
mitigate dermal exposures, except to the extent that
the owner or operator can demonstrate that such
controls are not feasible. Such control measures
should reduce direct dermal contact to the extent
achievable by those controls and subsequently
supplement those controls with dermal protection
measures.
Owners or 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.
a) How can I pick the right glove/dermal protection?
To help end-users select the appropriate glove type for
their chemical of concern, some glove manufacturers
and suppliers now include a rating for glove
degradation in addition to permeation efficacy. Some
glove types and materials may demonstrate efficient
permeation barrier results but may not be fully resistant
to degradation from a specific chemical exposure.
When this occurs, the glove manufacturer may adjust
their glove ratings for expected levels of protection to
recognize the potential for a decrease in permeation
barrier performance during use due to material
degradation. Other factors such as degradation can be
evaluated using standard test methods such as select
test methods within ASTM Method D 471 Standard
Test Method for Rubber Property - Effect of Liquids
(e.g., ASTM D412 Standard Test Methods for
Vulcanized Rubber and Thermoplastic Elastomers-
Tension). The WCPP may require documentation of
impermeability based on manufacturer specifications or
third-party testing. For chemicals undergoing TSCA
section 6 regulation, there is a potential that glove
performance against these specific chemicals or
chemical mixtures has not been previously
characterized by glove manufacturers.
b) How can I pick the right eye/face protection?
The EPA generally includes eye and face protection
within dermal PPE considerations. Depending on the
nature of a chemical-specific hazard(s), an EPA TSCA
section 6 rule may also require eye and face protection
as part of the WCPP, consistent with OSHA's standard
for eye and face protection at 29 CFR 1910.133.
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G. How do i implement the Exposure
Control Plan?
The Exposure Control Plan serves as the owner's or
operator's documented strategy for protecting
potentially exposed persons and fully implementing the
requirements of the TSCA section 6 WCPP for a
chemical substance. The following elements may be
required in an Exposure Control Plan:
Identification of possible exposure control
measures and the rationale for using or not using
available exposure controls in the sequence
described by hierarchy of controls based on
feasibility;
For the exposure controls not selected,
documentation of the efforts identifying why these
are not feasible, not effective, or otherwise not.
implemented;
A description of actions the owner or operator must
take to implement exposure controls selected,
including proper installation, regular inspections,
maintenance, training, or other steps taken;
A description of regulated areas, how they are
demarcated, and persons authorized to enter the
regulated areas;
A description of activities conducted by the owner
or operator to review and update the Exposure
Control Plan to ensure effectiveness of the
exposure controls, identify any necessary updates
to the exposure controls, and confirm that all
persons are properly implementing the exposure
controls; and/or
An explanation of the procedures for responding to
any change that may reasonably be expected to
introduce additional sources of exposure to a
TSCA section 6 regulated chemical substance, or
otherwise result in increased exposure to the
chemical substance, including procedures for
implementing corrective actions to mitigate
occupational exposure.
As a reminder, the EPA typically requires owners or
operators to consider, use, and document exposure
controls consistent with the hierarchy of controls (i.e.,
sequentially working through elimination, substitution,
then engineering controls and administrative controls)
to manage chemical exposure to the extent feasible
before using PPE as a means of mitigating
occupational exposure(s). See the hierarchy of controls
in Unit V.A. for more detail.
The EPA encourages, but does not require, owners or
operators to develop an Exposure Control Plan with
input from potentially exposed persons that the plan
may cover. The plan may be prepared as a stand-
alone document or as part of an existing industrial
hygiene or chemical management program.
Additionally, owners or operators may prepare a stand-
alone Exposure Control Plan for compliance with
multiple TSCA section 6(a) regulations, so long as that
Exposure Control Plan meets the requirements of each
individual chemical substance.
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H. What does a downstream notification
require?
Downstream notification is intended to spread
awareness throughout the supply chain regarding
important information in a TSCA section 6 rule (e.g.,
ECELs for an ongoing use or timeframes for use until
prohibition). Chemical manufacturers (including
importers), processors, and distributors of regulated
TSCA section 6 chemical substances are typically
required to provide downstream notification through
Safety Data Sheets (SDSs).
I. What is an SDS?
SDSs are required under OSHAs Hazard
Communication Standard (HCS) (29 CFR
1910.1200(q ). They include information about the
chemical's properties; the physical, health, and
environmental health hazards; protective measures;
and safety precautions for handling, storing, and
transporting the chemical. For more detailed
information on SDSs, visit OSHAs HCS SDS page at:
https://www.osha.gov/publications/osha3514.html.
2. Where does TSCA section 6 information go on
the SDS?
The EPA typically requires TSCA section 6 information
for a chemical substance to be added to the following
sections of the SDS:
Sections 1(c): Prohibitions;
Sections 8: Exposure Controls/Personal
Protection; and
Section 15: Regulatory Information.
Section 1(c) (Prohibitions)
This section provides dates beyond which the chemical
substance is restricted for distribution in commerce and
processing, and lists the prohibited uses.
Section 8 (Exposure Controls/Personal Protection)
This section provides the ECEL/EPA STEL for the
chemical substance as required in the final rule for the
chemical substance.
Section 15 (Regulatory Information)
This section provides dates beyond which the chemical
substance is restricted for distribution in commerce and
lists the prohibited uses.
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IV: Recordkeeping
This unit offers general information about
recordkeeping for elements within the WCPP TSCA
section 6 regulations for a chemical substance typically
require owners or operators to keep records that
document compliance with WCPP requirements,
including records of the following:
Exposure Control Plans;
Regulated areas and authorized personnel;
Facility exposure monitoring records;
Notifications of exposure monitoring results;
PPE and respiratory protection used and program
implementation; and
Information and training provided by the owner or
operator to each potentially exposed person prior
to or at the time of initial assignment to a job
involving potential exposure to the chemical
substance.
All records required in a TSCA section 6 regulation for
a chemical substance can be kept in the most
administratively convenient form, such as electronic
record or paper.
TSCA section 6 rules typically include a requirement to
retain records for 5 years. The record retention
requirement supports continuous program
improvement by ensuring that facilities maintain a
comprehensive historical record that aligns with the
Exposure Control Plan review cycle. Therefore, when
owners or operators conduct their review of the
Exposure Control Plan, they have access to a robust
set of monitoring results, program changes, and other
key documentation. This allows for a thoughtful review
and may help identify patterns or trends that may not
be apparent over a shorter review cycle.
It is important to note that while the WCPP generally
requires records to be maintained for 5 years, this may
not fulfill OSHA recordkeeping requirements that have
a different retention period. Owners or operators are
encouraged to review chemical management
recordkeeping requirements to ensure they meet all
applicable regulatory record retention requirements.
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V: Other important Information
This unit provides other important information
regarding the WCPP
A. What is the hierarchy of controls?
The EPA requires that in the Exposure Control Plan,
owners or operators look to the sequence of exposure
reductions in the hierarchy of controls to identify
possible control measures prior to implementing the
use of PPE. The Exposure Control Plan requires the
identification of feasible exposure control measures,
and a documented rationale for whether these
measures have or have not been implemented.
The hierarchy has five levels in a preferred order of
actions based on most effective to least effective
exposure controls. For more information on the
hierarchy of controls, visit the NIOSH website:
https://www.cdc.gov/niosh/hierarchv-of-
controls/about/index.html.
The hierarchy of controls is a key component of the
WCPPfrom initial exposure monitoring that
characterizes exposure, to periodic monitoring that
verifies control effectiveness, and finally,
documentation of the Exposure Control Plan. A TSCA
section 6 rule for a chemical substance requires that in
the Exposure Control Plan, owners or operators
evaluate the sequence of exposure reductions in the
hierarchy of controls to identity possible exposure
control measures, and to document rationale for
whether these measures have or have not been
implemented. See Unit II.F. and Unit III.G. for more
information on the Exposure Control Plan within the
WCPP.
Most
effective
Hierarchy of Controls
Elimination
Physically remove
the hazard
Substitution
Replace
the hazard
Least
effective
Engineering
Controls
Isolate people
from the hazard
Change the way
people work
Protect the worker with
Personal Protective Equipment
Image by NIOSH
https-J/www.«k.gov/nioih/topi
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Owners or operators must follow the hierarchy of
controls, and should consider the following:
Elimination - Remove the chemical substance at the
source. This could include changing the work process
to stop using the chemical substance.
Substitution - Use a safer alternative. When
considering a substitute, compare the potential risks of
the substitute to those of the chemical substance being
replaced. This review should consider how the
substitute will combine with other agents in the
workplace. Effective substitutes reduce the potential for
harmful effects and do not create new risks. The EPA
recommends careful review of the available information
on potential substitutes (including the chemical
substance's Alternatives Assessment that
accompanies some TSCA section 6 rules) to avoid a
substitute chemical that might later be found to present
unreasonable risks or be subject to regulation
(sometimes referred to as a "regrettable substitution").
Engineering controls - Engineering controls can
include modifying equipment or the workspace, using
local exhaust ventilation, protective barriers, and more
to remove or prevent exposure to a chemical
substance. Effective engineering controls:
Remove or block the chemical substance at the
source before it comes into contact with the
potentially exposed person;
Prevent users from modifying, tampering, or
otherwise interfering with the engineering control
itself;
Need minimal user input; and
Operate correctly without interfering with the work
process or making it more difficult.
Administrative controls/Work practices - Establish
work practices that reduce the duration, frequency, or
intensity of exposure to hazards (e.g., a chemical
substance). This may include work process training,
ensuring adequate rest breaks, or limiting access to
areas where exposure(s) may be possible.
Establishment of a regulated area may be an
administrative control. Individual TSCA section 6 rules
for a chemical substance may indicate whether owners
or operators have the flexibility to use rotating work
schedules as an exposure control to comply with the
chemical substance's ECEL.
PRE - PPE is equipment worn to reduce or minimize
exposure to hazards. Examples of PPE include gloves,
safety glasses, and respirators. PPE use should be
accompanied by a PPE/respirator program, which
includes such elements as PPE/respirator selection
and use training, PPE/respirator inspection and
replacement schedules, and effectiveness monitoring.
Owners or operators should generally not rely on PPE
as a primary method to control hazards when other
effective control options are feasible. See more
information in the "How do I implement a PPE
program?" in Unit III.F. of this guide.
B. What are the deadlines for meeting WCPP
requirements?
TSCA section 6(a) risk management rules may include
a staggered WCPP compliance timeline to ensure
adequate time is afforded to regulated entities for
successful implementation of the WCPP. While the
compliance timelines are expected to differ for each
TSCA section 6(a) rule based on stakeholder input and
other considerations, the EPA anticipates that the order
of compliance with the WCPP elements will be:
WCPP implementation Phase 1:
Conduct initial monitoring
Consider feasible exposure controls
WCPP Implementation Phase 2:
Provide and implement. PPE/respirators use
Establish the regulated area
Ensure that the ECEL/EPA STEL are not exceeded
WCPP Implementation Phase 3:
Implement Exposure Control Plan
The EPA anticipates that the WCPP implementation
sequence follows a data-driven approach that builds
protective measures on established occupational
exposure information. In Phase 1, initial monitoring is
expected to be implemented first because it
establishes the baseline of occupational exposure for
potentially exposed persons and determines whether
new or additional controls are necessary. These initial
monitoring data are important for owners or operators
to understand the highest likely 8-hour and 15-minute
(where applicable) exposures in the workplace.
In Phase 2, once the baseline of exposure is
established through initial monitoring, owners or
operators can begin the process of implementing
appropriate occupational control measures to ensure
no person is exposed above the established ECEL (8-
hour TWA) and/or EPA STEL (15-minute TWA). This
step requires that owners or operators have monitoring
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data as a basis to establish regulated areas and
consider what engineering controls, administrative
controls, or PPE may be necessary, and to begin
implementing considered controls within a facility.
Finally, in Phase 3 the Exposure Control Plan is
documented as the culmination of previous steps
because it needs to incorporate both monitoring data
and the exposure controls considered for
implementation. The Exposure Control Plan
development may be considered in earlier phases and
documented as part of this phase. The plan documents
the specific actions considered and used to mitigate
occupational exposures through the hierarchy of
controls framework.
This sequenced approach ensures the Exposure
Control Plan reflects actual workplace conditions and
control measures in practice, as opposed to theoretical
information, making it more effective at protecting
potentially exposed persons from risks by chemical
exposure.
C. What about multi-chemical exposures in the
workplace?
Workplaces have the potential to involve exposure to
multiple chemicals, some of which may be subject to
TSCA section 6 rules, while others may not. It's
important for workplaces to be aware of the potential
for multi-chemical exposures and take appropriate
precautions.
When developing an Exposure Control Plan as part of
a WCPP, it is acceptable for a facility to create a
comprehensive plan that covers multiple chemicals
regulated under TSCA section 6, as long as the
specific requirements are met for each regulated
chemical substance. This may allow for a more
streamlined approach to chemical management and
protection of potentially exposed persons within a
facility. As detailed in Unit II.F.. the Exposure Control
Plan is expected to detail the engineering controls,
work practices, and PPE needed to mitigate
occupational exposure for a regulated chemical
substance.
The presence of multiple chemicals in the workplace
may have implications for the selection and use of
PPE. Different chemicals may require different types of
PPE, such as specific dermal protection and/or gloves.
Within a WCPP, owners or operators may be required
to ensure the PPE provided is appropriate for the
chemical substances that are present. In some cases,
combinations of chemical substances may warrant a
higher level of protection than would be required for
each chemical individually. TSCA section 6 rules do not
supersede OSHA requirements. As such, it is important
to be knowledgeable about OSHA requirements as well
for ensuring occupational safety in multi-chemical work
environments.
Proactive chemical management is important for an
effective occupational health and safety program.
Chemical management in the workplace is a
systematic and proactive process of identifying
chemicals present in the working environment,
determining if and how they present hazards to
potentially exposed persons, and taking action to
prevent or control exposure to hazardous chemicals. In
addition to protecting health and safety, chemical
management programs can also reduce or eliminate
environmental harms.
D. 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:
Fail or refuse to establish or maintain records as
required by the final rule or other regulations
promulgated under this chapter;
Fail or refuse to permit access to or copying of
records, as required by TSCA; or
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.
Under section 17 of TSCA, U.S. district courts have
jurisdiction over civil actions to restrain violations of
section 15 of TSCA, restrain prohibited activity under
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section 6 of TSCA, and compel the taking of actions
required under TSCA.
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, 16, and 17 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.
E. Small business considerations
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-enforcement'). The EPA's enforcement
program is aimed at protecting the public by ensuring
compliance with regulations under TSCA section 6.
Your state's Small Business Environmental Assistance
Program (SBEAP) may provide resources to help
transition from a chemical regulated by a TSCA section
6 rule. The National SBEAP maintains a list of contact
persons for state SBEAPs. Some state and local
governments or other agencies provide resources,
including training or funding, to businesses to help
transition away from prohibited chemical substances.
No such Federal programs exist as of the publication of
this guide. Check with local authorities for programs
that may exist in your area.
The EPA encourages small businesses to work with
the Agency to discover, disclose, and correct violations,
including those related to the WCPP. 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 SBEAP here: States I National
Small Business Environmental Program
(nationalsbeap.org).
For general questions and document requests about
TSCA requirements, contact the TSCA Hotline at 1-
800-471-7127 or TSCA-Hotline@epa.gov.
For general information or questions on environmental
regulations and compliance for small business owners,
visit https://www.epa.gov/resources-small-
businesses/asbestos-and-small-business-ombudsman
or contact asbo@epa.gov.
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VI: Conclusion
The elements of a WCPP work together to create a
comprehensive system protecting potentially exposed
persons' health, providing clear documentation for an
organization's chemical substance protections
regulated under TSCA, and facilitating continuous
improvement measures.
Successfully implementing a WCPP for a TSCA section
6 regulated chemical offers a number of organizational
benefits beyond regulatory compliance. A well-
executed WCPP helps ensure regulatory compliance
and protects potentially exposed persons (e.g.,
employees, workers, independent contractors, etc.)
from unreasonable risk associated with occupational
chemical exposure. By identifying, assessing, and
controlling these risks through WCPP compliance,
organizations create a safer work environment and
minimize the likelihood of occupational chemical-
related injuries and illnesses.
The WCPP's emphasis on initial and periodic
occupational exposure monitoring ensures that
workplace conditions are accurately assessed and
evaluated overtime. This data-driven foundation allows
organizations to implement appropriate exposure
controls and adjust them as needed to create an
effective chemical management program. Regulated
areas further ensure that access to areas with potential
for inhalation and/or dermal exposures are controlled.
Through its systematic exposure control planning
process, a WCPP helps organizations make informed
decisions about implementing controls according to the
hierarchy of controls - prioritizing elimination,
substitution, and engineering controls, before turning to
administrative controls and use of PPE. This structured
approach provides better protection for potentially
exposed persons and can lead to more cost-effective
long-term solutions. The program's emphasis on
documenting occupational exposure controls and the
selection rationale creates valuable institutional
knowledge that supports consistent chemical
management practices.
The WCPP's elements encouraging transparency (e.g.,
notification of occupational exposure monitoring and
maintaining accessible Exposure Control Plans) bolster
an informed workforce that understands the chemical
hazards and workplace mitigations. Programmatic
review is incorporated into the WCPP to maintain
program impact and allow for continuous improvement
based on operational experience.
Reducing chemical-related injuries and illnesses
through a WCPP can help minimize work disruption. A
safer workplace often translates to a more productive
workforce. While implementing an effective WCPP may
require an initial investment, long-term benefits may be
realized by reducing owner or operator's legal
liabilities, investigations, medical costs, or fines
associated with workplace injuries or illnesses.
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Frequently Asked Questions (FAQs)
If OSHA already has a chemical-specific standard or other standards that overlap with the EPA's rule, which
do I need to follow? Does one supersede the other?
The EPA rules do not supersede OSHA's rules and the regulated community must ensure compliance with all
applicable regulations. If OSHA has existing regulations for a chemical substance for which the EPA also promulgates
a rule for, the EPA anticipates that the provisions of the EPA rule will align with the existing OSHA requirements to the
extent appropriate. When appropriate, the EPA may make certain requirements under the WCPP more stringent to
ensure adequate protections are afforded to potentially exposed persons in the workplace.
If my condition of use or subset of a condition of use is identified for prohibition under a rule, am I still
required to implement the WCPP until it is phased out?
It depends on the particular rule. Under the appropriate circumstances, certain conditions of use or subsets of
conditions of use identified by the EPA may require compliance with a WCPP or specific interim controls until the
condition of use is phased out as part of a regulatory prohibition.
Are ECELs and EPA STELs the only TSCA exposure limits from the EPA?
No. The EPA has another type of regulatory workplace exposure limit called New Chemical Exposure Limits (NCELs)
under section 5 of TSCA. NCELs are created by the EPA in order to provide adequate protection to human health in
workplace settings from unreasonable risks associated with chemical substances that are being introduced into the
U.S.
The NCELs provisions, which are modeled after OSHA's Permissible Exposure Limits, include requirements
addressing performance criteria for:
Sampling and analytical methods;
Periodic monitoring;
Respiratory protection; and
Recordkeeping.
The EPA has created an NCELs table that lists the actual NCEL concentrations established by the EPA for specific
chemical substances. The NCELs table is intended to provide a convenient list of all NCELs established by the EPA
(up to the date of internet posting). The NCELs table can be found at https://www.epa.aov/reviewina-new-chemicals-
under-toxic-substances-control-act-tsca/non-confidential-list-tsca-new.
Does the Design for the Environment (DfE) come into play for TSCA Work Plan Chemicals?
The EPA uses alternatives assessment to look for commercially available alternative chemicals. DfE alternatives
assessments are conducted as risk management actions when warranted for TSCA Work Plan Chemicals.
They have also been conducted as part of a Chemical Action Plan. By identifying and evaluating the safety of
alternative chemicals, this approach may:
Complement regulatory action by showing that safer and higher functioning alternatives are available;
Encourage industry to move to safer alternatives; and/or
Limit chemical substitution for a particular use.
More information on DfE can be found at: https://www.epa.gov/saferchoice/desian-environment-alternatives-
assessments.
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Can exposure monitoring conducted after the rule was proposed be considered as initial monitoring for a final
rule?
Occupational exposure monitoring data collected from within the previous 5 years of the publication date of a final rule,
including after the proposed rule was issued, may be used to comply with initial monitoring requirements in some
cases. You should consult the rule for the specific chemical substance to determine whether it is permitted in your
situation.
If exposure monitoring indicates that air concentrations of a chemical substance are below the ECEL or action
level identified by the EPA for that chemical substance, is an Exposure Control Plan still required?
Yes. Anyone using a chemical substance in accordance with its WCPP needs an Exposure Control Plan as part of
compliance with the requirements, if you are monitoring below the action level, the Exposure Control Plan can serve
as a useful way to document best practices and provide additional certainty to regulated entities that they are
complying with all WCPP and recordkeeping requirements. It would also provide assurances to potentially exposed
persons that they are being adequately protected against exposure to a chemical substance.
Can an Exposure Control Plan be integrated as part of an existing occupational safety program such as a
Chemical Hygiene Plan?
Yes. The EPA has no issue with using elements of an existing chemical safety program such as the Chemical Hygiene
Plan of Cal/OSHA 5191(e) orOSHA's 1S10.1450(e) to meet the requirements for an Exposure Control Plan. The EPA
encourages regulated entities to make use of information, tools, and procedures that are already in place, so long as
they have the required elements of the Exposure Control Plan required by the chemical-specific rule.
Does the EPA require specific, accredited laboratories to analyze monitoring samples?
Generally, analyzing air monitoring samples may be conducted by any accredited laboratory including GLP AIHA (AIHA
Laboratory Accreditation Programs, LLC Policy Module 2A/B/E of Revision 17.3), or other analogous industry-
recognized program.
Are there conditions of use or subsets of conditions of use that TSCA section 6 rules do not apply to?
Yes. TSCA section 3 excludes uses that are considered outside the scope of a "chemical substance" as defined under
TSCA. Such exclusions, for example, include drugs which are defined under the Federal Food, Drug, and Cosmetic
Act (FFDCA) section 201 when being manufactured, processed, or distributed in commerce for such use. See
chemical substance in the Glossary below for more information.
Will the EPA release a format guide or standardized compliance documents for implementing the WCPP?
The WCPP components laid out in this document are meant to serve as general guidance by highlighting elements
that regulated entities can expect to see in TSCA section 6 rulemakings. For each chemical-specific regulation, the
EPA may release a Fact Sheet and a Compliance Guide specific to that regulation to assist with compliance.
Will the EPA allow passive monitoring for compliance with the exposure limits and WCPP?
Some chemical-specific regulations under TSCA section 6 may require specific types of air monitoring media or allow
flexibility in choosing the type of air monitoring media, depending on its efficacy with the chemical substance. The EPA
will generally provide greater flexibility, including passive monitoring, as long as it is capable of meeting accuracy
criteria that would be established within the chemical-specific rule.
Will I be able to choose what analytical sampling method to use?
Some chemical-specific regulations under TSCA section 6 may identify specific analytical methods for use or aliov/ any
method so long as it is capable of meeting accuracy criteria that would be established within the chemical-specific rule.
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Will laboratories be required to comply with WCPPs in the same way industries must, even if the chemical
substance use is infrequent, in small volumes, or if the OSHA lab standard under 29 CFR 1910.1450 applies?
The EPA may require that laboratories conduct air monitoring, similar to industry users, depending on the chemical
substance, existing regulations, or other relevant considerations. The EPA may also, under the appropriate
circumstances of a given chemical substance, consider exempting infrequent and negligible volume uses in
laboratories from certain requirements of the WCPP
Will the EPA make the WCPP universally applicable to all conditions of use for a chemical substance?
Under TSCA, the EPA must address unreasonable risk to human health or the environment from exposure to a
chemical substance. If there is insufficient information on a specific condition of use to determine it can continue safely
under a WCPP, the EPA may determine that prohibition of that use would be more appropriate to address the
unreasonable risk. Therefore, the EPA does not provide blanket coverage for all conditions of use under a WCPP
unless there is robust information supporting such a determination.
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. For small businesses, please see the EPA's Small Business Ombudsman Website. Small
businesses may find the national SBEAPs helpful for providing resources and information about a chemical-specific
regulation, https://www.epa.qov/resources-small-businesses/asbestos-and-small-business-ombudsman.
Is this guide updated?
This manual is the first version of the compliance guide. The EPA may update this guide without public notice. The
most up-to-date version of the compliance guide will be available at https://www.epa.aov/assessina-and-manaaina-
chemicals-under-tsca/auidance-reaulations-issued-under-toxic-substances.
What if I become aware of a violation?
To report a violation, please see instructions at https://www.epa.aov/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.
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.aov/assessina-and-manaaina-chemicals-under-tsca/risk-manaaement-existina-chemicals-under-tsca.
You may also contact the EPA's TSCA Hotline by telephone at (202) 554-1404 or by email at TSCA-Hotiine@epa.aov.
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Appendix A: Abbreviation List and Glossary
Abbreviation List
AIHA American Industrial Hygiene Association
ANSI American National Standards Institute
ASTM American Standard for Testing and Materials
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR Code of Federal Regulations
DDCC Direct Dermal Contact Control
DfE Design for the Environment.
ECEL Existing Chemical Exposure Limit
EPA U.S. Environmental Protection Agency
EPA STEL EPA Short-Term Exposure Limit
FAQs Frequently asked questions
HCS Hazard Communication Standard
NCEL New Chemical Exposure Limit
NESHAP National Emission Standards for Hazardous Air Pollutants
NIOSH National Institute for Occupational Safety and Health
OESSM Occupational Exposure Sampling Strategy Manual
OEV Occupational exposure value
OSHA Occupational Safety and Health Administration
PBZ Personal breathing zone
PPE Personal protective equipment
PPT Personal protective technology
RCRA Resource Conservation and Recovery Act
TWA Time-weighted average
SBEAP Small Business Environmental Assistance Program
SDS Safety Data Sheet
TSCA Toxic Substances Control Act
WCPP Workplace Chemical Protection Program
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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).
Chemical management - A systematic and proactive process of identifying chemicals present in the working
environment, determining if and how they present hazards to workers, and taking action to prevent or control workers'
exposure to hazardous chemicals.
Condition of use - Defined in TSCA section 3(4) to mean the circumstances, as determined by the 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 control (DDCC) - Direct handling of a chemical substance or mixture or skin contact with
surfaces that may be contaminated with a chemical substance or mixture.
ECEL action level - An air concentration that indicates when certain compliance activities would need to be taken,
and at which frequency, to prevent exceedances of the ECEL.
Effective date - The date on which a regulation takes effect and becomes enforceable.
EPA Short-Term Exposure Limit (EPA STEL) - A short-term exposure limit, which is an EPA regulatory limit on
workplace exposure to an airborne concentration of a chemical substance, based on an exposure of less than eight
hours.
Existing Chemical Exposure Limits (ECELs) - An Existing Chemical Exposure Limit is an airborne concentration,
typically calculated as an 8-hour TWA. When implemented along with other WCPP measures, unreasonable risk under
the conditions of use identified is no longer presented at or below the air concentration level of the ECEL.
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Exposure group - (40 CFR § 751.5) A group of potentially exposed persons with a similar exposure profile to a
chemical substance or mixture based on the substantial similarity of tasks performed, the manner in which the tasks
are performed, and the materials and processes with which they work.
Owner or operator - (40 CFR § 751.5) Any person who owns, leases, operates, controls, or supervises a workplace.
Personal breathing zone (PBZ) - A hemispheric area forward of the shoulders within a six- to nine-inch radius of a
worker's nose and mouth and requires that exposure monitoring air samples be collected from within this space.
Personal protective equipment (PPE) - Equipment worn to reduce or mitigate exposure to chemical substances or
physical hazards. Examples of PPE include gloves, safety glasses, face shields, and respirators.
Potentially exposed person - (40 CFR § 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. The term includes
workers, employees, independent contractors, employers, university students, volunteers, self-employed persons,
state and local government workers not covered by an OSHA state plan, and all other persons in the workplace where
a TSCA-regulated chemical is present.
Regulated area - (40 CFR § 751.5) An area established by the regulated entity to demarcate areas where airborne
concentrations of a specific chemical substance exceed, or there is a reasonable possibility they may exceed, the
applicable ECEL or EPA STEL.
Worker - Person who performs work in areas where a chemical substance is present, including both those who
handle chemical substances and those who do not directly handle chemical substances.
Workplace Chemical Protection Program (WCPP) - A program to protect potentially exposed persons 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 chemical protection program for a TSCA-regulated
chemical. WCPP provisions include a regulatory ECEL, initial and periodic monitoring, respirator selection criteria,
recordkeeping, and downstream notification for a TSCA-regulated chemical to ensure that potentially exposed persons
are no longer at risk.
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