Occupational Exposure Monitoring for Flame Retardant Chemicals under TSCA

OUR CHALLENGE

Two company consortia required assistance in responding to the U.S. Environmental Protection Agency (EPA) Section 4 test orders for occupational exposure data for two flame retardant chemicals prioritized for risk evaluation under the Toxic Substances Control Act (TSCA). The challenge was to conduct comprehensive occupational exposure assessments and provide robust data for EPA submission to ensure compliance with regulatory requirements among all members of the consortia while minimizing unnecessary testing across similar facilities. The assessment had to account for several conditions of use and occupational exposure scenarios across multiple facilities in the United States. 

OUR APPROACH

Our team collaborated with an American Industrial Hygiene Association Industrial Hygiene Laboratory Accreditation Program (AIHA IHLAP) accredited laboratory and a contract research organization to design and validate methods for measuring both air and dermal wipe samples. We led air monitoring campaigns at numerous facilities across the country, collecting occupational inhalation exposure data. Key elements of our approach included: 

• Validating sampling methods for air and dermal matrices to ensure accurate and reliable results. 

• Conducting air monitoring campaigns at various facilities, focusing on worker job titles, tasks, facility processes, and raw material and chemical characteristics (i.e., considering chemical vapor pressure and the physical state of raw materials and final products). 

• Collating and analyzing occupational inhalation exposure data to identify trends based on company exposure scenarios. 

• Preparing detailed reports based on the collected data for submission to EPA in 2024, ensuring compliance with Section 4 test order requirements. 

OUR IMPACT

By designing and conducting thorough exposure assessments, we provided the consortia with robust data on occupational exposures to the flame retardant chemicals. The validation of methods and extensive air monitoring campaigns ensured that the exposure data were accurate and relevant to the companies’ specific operations. Our final reports provided the necessary information for EPA submissions, helping the consortia comply with TSCA Section 4 test orders and contributing to the overall risk evaluation process.