The Environmental Protection Agency published a notice in the Federal Register on October 9, 2025, announcing its intent to reconsider the risk management rule for carbon tetrachloride, or CTC, under the Toxic Substances Control Act. This development stems from legal challenges filed in 2025 against the rule's December 2024 promulgation, which imposed workplace exposure controls, prohibited certain uses, and established other requirements to address unreasonable health risks. The notice opens a public comment period until November 10, 2025, inviting input on implementation challenges and potential alternatives. This reconsideration reflects broader administrative efforts to evaluate existing regulations, potentially reshaping how CTC is managed in industrial settings. By soliciting stakeholder feedback early, the EPA aims to refine its approach based on practical experiences and data since the rule took effect.
Background on Carbon Tetrachloride and TSCA Regulation
Carbon tetrachloride is a chemical substance used in various industrial processes, including as a feedstock in the production of other chemicals. Under TSCA section 6(a), the EPA is required to regulate chemical substances that present an unreasonable risk of injury to health or the environment, as determined through risk evaluations. The agency's 2020 risk evaluation for CTC identified unreasonable risks primarily from occupational exposures, such as liver toxicity and cancer risks from chronic inhalation.
The original rule, finalized on December 18, 2024, and published in the Federal Register (89 FR 103512), addressed these risks by mandating a Workplace Chemical Protection Program. This program included an Existing Chemical Exposure Limit of 0.03 parts per million as an 8-hour time-weighted average, along with requirements for exposure monitoring, personal protective equipment, and recordkeeping. The rule also prohibited certain industrial and commercial uses where risks could not be adequately mitigated. These measures applied to entities involved in manufacturing, processing, distribution, use, and disposal of CTC.
This regulatory framework builds on TSCA's emphasis on risk-based management, drawing from precedents like the EPA's rules for other chemicals such as methylene chloride and perchloroethylene. However, the CTC rule faced immediate scrutiny, highlighting tensions between environmental protection goals and industry feasibility concerns.
Legal Challenges and Decision to Reconsider
Following the rule's publication, multiple petitions for review were filed and consolidated in the U.S. Court of Appeals for the Eighth Circuit. These challenges likely focused on aspects such as the stringency of exposure limits and compliance burdens, though specific details of the petitions are not outlined in the Federal Register notice.
On September 12, 2025, the EPA announced its decision to reconsider the rule through further rulemaking. This step aligns with Executive Order 14219, issued by President Trump on February 19, 2025 (90 FR 10583), which promotes lawful governance and deregulatory initiatives under the 'Department of Government Efficiency.' The order encourages agencies to review regulations for potential improvements in efficiency and effectiveness. Additionally, the reconsideration supports the EPA's Powering the Great American Comeback Initiative, specifically Pillar I, which emphasizes clean air, land, and water protections balanced with practical implementation.
The notice emphasizes that the review complies with applicable laws and administration policies, underscoring a commitment to evidence-based adjustments without preempting ongoing litigation.
Key Provisions Under Review and Request for Comment
The EPA is inviting comments on all aspects of the 2024 rule, with particular interest in implementation issues experienced since its effective date. A focal point is the Existing Chemical Exposure Limit of 0.03 ppm as an 8-hour time-weighted average, part of the Workplace Chemical Protection Program (detailed in 40 CFR 751.703 and 751.707(b)). Commenters are encouraged to address the feasibility of exposure monitoring and whether an alternative limit might better balance risk management with operational realities.
Other areas include existing or anticipated challenges with workplace controls, prohibitions on certain uses, and overall compliance. The agency requests public data supporting comments, such as exposure monitoring results or economic impact studies, while advising against submitting confidential business information electronically.
This comment period, managed through docket EPA-HQ-OPPT-2020-0592 on regulations.gov, represents an opportunity for stakeholders—including industry groups, environmental organizations, and tribal nations—to influence potential amendments. The notice does not propose specific changes but signals openness to alternative measures that could address unreasonable risks differently.
Perspectives and Implications
Stakeholders may offer diverse views on the rule. Industry representatives might argue that the 0.03 ppm limit is overly restrictive, potentially increasing costs without proportional risk reduction, citing challenges in monitoring low-level exposures in facilities handling CTC as a feedstock. Environmental and health advocates, conversely, could emphasize the need to maintain or strengthen protections, referencing the risk evaluation's findings on CTC's toxicity.
Short-term implications include possible delays in enforcement as the EPA gathers input, providing temporary relief for regulated entities. Long-term, amendments could set precedents for how the agency handles TSCA risk management for other chemicals, influencing balances between health protections and economic considerations. This process also intersects with broader debates on regulatory reform under current administration priorities.
In conclusion, the EPA's reconsideration of the CTC rule highlights the dynamic nature of chemical regulation under TSCA. Key takeaways include the agency's response to legal challenges and executive directives, with a focus on refining workplace exposure limits based on stakeholder input. Potential next steps involve analyzing comments to develop a proposed rulemaking, which could amend or replace elements of the 2024 rule. Ongoing challenges may revolve around integrating new data with existing risk assessments, while debates continue on achieving effective risk mitigation without undue burdens. This effort underscores the importance of adaptive governance in addressing chemical risks.