In October, EPA issued proposed restrictions on the manufacture, processing, and distribution of a chemical called trichloroethylene (TCE). EPA determined in 2020 that TCE presents an unreasonable risk under certain conditions of use, and the agency is now statutorily obligated to eliminate this risk under the Toxic Substances Control Act. Accordingly, EPA need not find that the Proposed Rule’s monetized benefits outweigh its monetized costs before proceeding to finalization. Nevertheless, we argue in comments that aspects of the agency’s Economic Analysis of the proposed restrictions could be clarified or expanded upon to better inform policymakers and the broader public about the benefits of ending TCE use. To that end, we recommended the following:
- EPA should consider conducting a break-even analysis focused on the Proposed Rule’s potential to reduce the incidence of congenital heart disease (CHD).
- EPA should consider conducting a break-even analysis focused on the Proposed Rule’s potential to reduce the need for future remediation of soil and groundwater contamination.
- EPA should use a 2% discount rate, as recommended in the 2023 update to Circular A-4, to calculate the present value of the Proposed Rule’s expected benefits and costs.
- EPA should acknowledge potential benefits from reducing the need for personal protective equipment (PPE) in some workplaces.