This article is for EHS leads, facility managers, and procurement officers at industrial facilities where cleaning goes beyond surface wiping — where cleaning is part of production: parts washing before assembly, degreasing before coating, metal finishing before inspection. If your facility runs vapor degreasers, has chemical storage for industrial solvents, or sources specialized cleaning chemistry for precision applications, the current wave of TSCA Section 6 rulemakings is a direct operational concern. Some of the most-affected chemicals are ones your facility may have used for decades.
The central mistake this guide prevents: assuming that TSCA Section 6 is a manufacturing chemistry problem, not a cleaning problem. Trichloroethylene (TCE) — the chemical at the center of the most consequential recent rulemaking — is primarily a cleaning chemical. Vapor degreasing, cold cleaning, and parts washing are among its largest industrial uses. The ban applies to your cleaning operation, not someone else’s.
A secondary mistake: assuming that TCE is the only TSCA Section 6 chemical with cleaning product implications. Methylene chloride, 1-bromopropane (n-propyl bromide), and perchloroethylene all have Section 6 restrictions affecting cleaning uses. And 1,4-dioxane, while not yet the subject of a final Section 6 rule, is embedded in the surfactant chemistry of common cleaning products and drawing increasing regulatory scrutiny at the state level.
Cross-reference: For an overview of VOC limits and the broader regulatory landscape for cleaning chemistries, see VOC Limits Are Changing: What Industrial Buyers Need to Know in 2025–2026 (Category 1.1). For SDS-level interpretation of regulatory information, see Reading an SDS: What Every Section Actually Means (Category 3.4).
TSCA Section 6: The Regulatory Framework
The Toxic Substances Control Act was enacted in 1976. For its first four decades, Section 6 — the provision authorizing EPA to regulate existing chemicals for unreasonable risk — was largely ineffective. EPA’s landmark failure to regulate asbestos under TSCA in the early 1990s (a court struck down the rule) effectively froze regulatory action on existing chemicals for 20 years.
The Frank R. Lautenberg Chemical Safety for the 21st Century Act of 2016 fundamentally reformed TSCA. Among other provisions, it gave EPA a clear mandate and methodology for prioritizing, evaluating, and regulating high-priority chemicals under Section 6. EPA was required to designate an initial list of 10 high-priority chemicals for risk evaluation, complete those risk evaluations on a statutory timeline, and take regulatory action where unreasonable risk was found.
The 2020s have been the first operational decade of the reformed TSCA Section 6 process. Final rules on several high-priority chemicals have been issued, with compliance timelines beginning to hit. More chemicals are moving through the evaluation pipeline.
For industrial cleaning buyers, the reformed TSCA Section 6 process matters for two reasons: 1. Several chemicals regulated or being regulated are cleaning chemicals or cleaning-adjacent chemicals 2. The timelines are real — these are not proposed rules still years away from effect; several have been finalized
Trichloroethylene (TCE): The Major TSCA Cleaning Chemical Action
EPA finalized its TSCA Section 6 risk management rule on trichloroethylene on December 17, 2024 (published in the Federal Register on that date). This rule is the most consequential chemical regulation affecting industrial cleaning operations in decades.
What TCE Is and Why It Was Used
Trichloroethylene is a chlorinated solvent with exceptional cleaning power on mineral oils, greases, and metalworking lubricants. It is non-flammable, relatively low in viscosity, and evaporates quickly — properties that made it the dominant chemistry for vapor degreasing, the industrial cleaning process used to clean metal parts before coating, assembly, welding, or inspection.
Vapor degreasing uses the solvent in a heated sump. Parts are lowered into the solvent vapor; the solvent condenses on the cooler part surfaces, dissolves and carries away contaminants, and drips back into the sump. It’s a closed-loop process in principle, but solvent is lost through evaporation, dragout, and equipment operation. TCE is an established human carcinogen based on evidence including kidney cancer, non-Hodgkin’s lymphoma, and liver cancer associations. EPA’s 2012 carcinogenicity assessment drove the risk evaluation and ultimately the final rule.
What the December 2024 Final Rule Does
The December 2024 final rule bans most consumer, commercial, and industrial uses of TCE under a phased compliance schedule. Key provisions for industrial cleaning operations:
Consumer uses: Banned with the shortest compliance lead time — most consumer uses are prohibited within the first phase beginning in 2025. If you use any consumer-format products containing TCE (which would be unusual in industrial settings by this point), those need to be eliminated promptly.
Commercial and industrial uses — general: Many non-vapor-degreasing commercial and industrial uses are phased out under intermediate timelines. Cold cleaning operations using TCE in open tanks, for example, face restrictions.
Vapor degreasing — the major industrial cleaning application — has a longer transition window than consumer uses, reflecting the technical and capital complexity of alternatives. The specific compliance dates for vapor degreasing have a phased structure starting from the rule’s effective date; buyers should verify the current compliance schedule directly from the final rule text or EPA’s TSCA Section 6 rulemaking page, as phase-in dates were structured to allow transition. Even with extended timelines, the direction is clear: vapor degreasing with TCE has a defined end date, and the transition planning should be underway now.
Permissible uses during transition: The final rule provides for certain uses during phased periods, subject to strict exposure limit requirements. Industrial facilities retaining TCE during any permissible transition period face strict requirements including worker exposure limits that are significantly more stringent than historical OSHA standards for TCE. These are not “continue as normal” grace periods — they are conditional use periods with active exposure control obligations.
The Compliance Schedule Reality
Verify the current compliance dates directly from the December 2024 Federal Register publication or EPA’s TSCA Section 6 regulatory page. The phase-in structure for vapor degreasing is calibrated to the complexity of transitioning equipment and chemistry, but the deadlines are fixed and are not approximate. Any facility still running TCE vapor degreasing should have an internal project team actively working the transition — not as a future item, as a current capital project.
Alternative Chemistries for Vapor Degreasing
Transitioning away from TCE-based vapor degreasing is not trivial. It involves chemistry change, equipment compatibility verification, cleanliness validation against specifications, and in many cases capital expenditure for equipment modification or replacement.
The alternatives in current use:
Hydrofluoroethers (HFEs): Fluorinated solvents from 3M (Novec brand) and other manufacturers. Non-flammable, relatively low toxicity compared to chlorinated solvents, low ozone depletion potential. Work in modified vapor degreasing equipment. Higher per-gallon cost than TCE. Strong cleaning performance on many soils. VOC-exempt under most regulatory definitions. Widely used in aerospace, medical device, and electronics cleaning.
Hydrofluoroolefins (HFOs): Newer fluorinated solvent class with very low global warming potential. Several HFO-based formulations designed for vapor degreasing. Performance and equipment compatibility vary by formulation; consult your equipment manufacturer before conversion.
Modified alcohol blends: Non-halogenated solvent alternatives based on azeotropic blends of isopropanol, ethanol, or other alcohols, sometimes with co-solvents. Flammability is a key consideration — flammable solvent in a vapor degreaser requires explosion-proof equipment design. Cleaning performance on heavy mineral oil soils varies. Generally lower cost than fluorinated alternatives.
Aqueous cleaning systems: Parts washers using heated water with surfactant-based cleaning chemistry. Effective on many soils. Capital cost can be higher than solvent systems; process validation required for precision applications. Does not use solvent vapor — eliminates the vapor-phase exposure risk. Wastewater treatment becomes the compliance consideration instead of air emissions.
Supercritical CO₂: High-pressure CO₂ as solvent; CO₂ has good solvent properties for many non-polar soils. Specialized equipment; higher capital cost. Some precision cleaning applications in electronics and medical devices use this process. Niche application currently.
The right alternative depends on your soil profile, your part geometry, your cleanliness specification (military, aerospace, and medical device standards specify cleanliness levels that must be validated on the replacement process), and your existing equipment. There is no universal TCE substitute. Budget time for chemistry evaluation and cleanliness validation — not days, but weeks to months depending on your specification stringency.
Methylene Chloride (Dichloromethane, DCM): Cleaning and Stripping Uses
EPA issued a final rule under TSCA Section 6 restricting methylene chloride in 2019, covering consumer-use paint and coating strippers. Subsequent rulemaking has extended restrictions to most commercial and industrial uses. Methylene chloride has been used in industrial cold cleaning, some degreasing applications, and paint stripping.
For cleaning operations specifically: methylene chloride in industrial cleaning solvents (cold dip cleaners, open-tank degreasers) is restricted under the post-2019 regulatory framework. The timeline for commercial and industrial use restrictions has phased compliance dates — verify current applicability for your specific use category against the current rule text or EPA’s TSCA page.
If your facility uses any methylene chloride-containing cleaning solvent, check the SDS for “dichloromethane” or “methylene chloride” or CAS number 75-09-2 in Section 3 (Composition), and verify current compliance status for your specific use type.
1-Bromopropane (n-Propyl Bromide, nPB): The “TCE Substitute” That Wasn’t
1-bromopropane became a widely used alternative to TCE in vapor degreasing and cold cleaning in the 2000s and 2010s. When TCE faced regulatory pressure and toxicological scrutiny, many facilities transitioned to nPB as a drop-in substitute — same general process, different chemistry.
The problem: 1-bromopropane itself has serious neurotoxicity and reproductive toxicity concerns. EPA completed its TSCA Section 6 risk evaluation on nPB and found unreasonable risk. A final risk management rule restricting nPB in its cleaning and degreasing applications has moved through the regulatory process. Verify the current regulatory status of nPB in your specific use category with EPA’s TSCA rulemaking page.
The “frying pan to fire” situation is real and well-documented in the industrial cleaning sector. Facilities that transitioned TCE → nPB and now face nPB restrictions are evaluating the same alternatives list for the third time. If you were an early adopter of nPB as a TCE substitute and have not yet begun the nPB transition process, you are likely behind the compliance timeline. Start the alternative chemistry evaluation now.
Perchloroethylene (PCE, Tetrachloroethylene, PERC): Dry Cleaning and Industrial Uses
Perchloroethylene is the dominant dry-cleaning solvent. It also has industrial cleaning applications in vapor degreasing and cold cleaning, though less commonly than TCE in most industrial sectors. EPA’s TSCA Section 6 process has addressed PCE under its risk evaluation and risk management pipeline.
For industrial cleaning operations using PCE: verify current rule status for your specific use category with EPA. Dry cleaning operations face a separate but parallel regulatory trajectory. PCE’s occupational exposure limits have long been a subject of OSHA discussion independently of the TSCA process.
Carbon Tetrachloride: Legacy Uses Being Eliminated
Carbon tetrachloride was widely used in cleaning applications for much of the 20th century. It is essentially eliminated from consumer and most commercial cleaning uses through a combination of TSCA, CAA, and Montreal Protocol restrictions. Remaining uses are narrow and highly specialized; the current TSCA process is addressing residual authorized uses. If carbon tetrachloride appears in any current cleaning product in your inventory, that product requires immediate attention — SDS Section 15 should flag applicable restrictions.
1,4-Dioxane: The Surfactant Contaminant
1,4-Dioxane is not an intentional cleaning ingredient. It is a byproduct of the ethoxylation process used in manufacturing certain nonionic surfactants — specifically polyethoxylated compounds used in many general purpose cleaners, detergents, and shampoos. 1,4-Dioxane ends up in the product as a contaminant at parts-per-million concentrations, not as a functional ingredient.
1,4-Dioxane is a likely human carcinogen (EPA Group B2 classification). It is highly water-soluble and persistent — it doesn’t biodegrade easily in water treatment systems and has been detected in groundwater at municipal supply wells. Several states have set drinking water standards for 1,4-dioxane.
New York has enacted a specific limit on 1,4-dioxane in consumer cleaning products. New York’s rule limits 1,4-dioxane concentrations in covered products. The specific ppm threshold and the covered product categories should be verified directly with the New York State Department of Environmental Conservation — the limit was established through a regulatory process with specific compliance dates. If you sell into or use products in New York, 1,4-dioxane content in surfactant-based cleaners is a real compliance consideration.
TSCA status: EPA has issued a risk evaluation on 1,4-dioxane finding that certain conditions of use present unreasonable risk. A TSCA Section 6 risk management rule is in the pipeline. The timing should be verified against current EPA TSCA rulemaking status.
Buyer action: For cleaning products using polyethoxylated surfactants (which includes the majority of general purpose cleaners, hand soaps, and multi-surface cleaners), ask your supplier directly about 1,4-dioxane content. Testing is available; many manufacturers have already moved to low-1,4-dioxane or 1,4-dioxane-free ethoxylated surfactants in response to New York’s rule and market pressure. Request written confirmation of 1,4-dioxane content in ppm and ask whether the formulation meets New York’s applicable limit if you have New York operations.
PFAS in Cleaning Products: TSCA and State-Level Action
Per- and polyfluoroalkyl substances (PFAS) are a family of thousands of synthetic fluorinated compounds characterized by extreme chemical and environmental persistence. Some PFAS have documented toxicity at very low concentrations, including associations with cancer, immune disruption, thyroid effects, and developmental concerns.
PFAS in cleaning products is a multi-pathway regulatory issue:
TSCA: EPA has authority to regulate PFAS under TSCA. Section 6 evaluations of specific PFAS compounds are in process. The TSCA reporting rule (PFAS Section 8(a)(7)) requires manufacturers and importers of PFAS-containing articles and products to report to EPA. EPA’s broader PFAS action plan overlaps with the TSCA Section 6 framework.
FIFRA: EPA-registered disinfectants and sanitizers that use PFAS-containing ingredients face review through the FIFRA re-registration and review processes.
State legislation: Several states have passed PFAS-in-products legislation that explicitly covers cleaning products: - Maine enacted a PFAS-in-products law requiring disclosure and, in later phases, prohibition of PFAS in covered product categories including cleaning products. Verify current Maine requirements with the Maine Department of Environmental Protection. - Minnesota has enacted PFAS restrictions with phased product-category coverage. Verify current Minnesota requirements with MPCA. - Additional states are actively considering or have enacted similar legislation.
Buyer action on PFAS: - Include a PFAS-free attestation requirement in RFPs for cleaning products. The attestation should specify “no intentionally added PFAS” at minimum, and ideally “no PFAS detected above [detection limit] by [test method]” for cleaning products used in sensitive environments. - Check SDS Section 3 for any fluorinated compound with “fluoro-” in the chemical name — this may indicate PFAS. Not all fluorinated compounds are PFAS, but the name pattern warrants a follow-up inquiry. - The Safer Choice program’s updated Master Criteria have added PFAS scrutiny — Safer Choice-certified products are unlikely to contain intentionally added PFAS by the nature of the certification criteria.
Reading SDS Section 15 for TSCA Regulatory Status
SDS Section 15 (Regulatory Information) is where suppliers are expected to disclose applicable regulatory requirements for the product. For TSCA-regulated substances, Section 15 should identify the substance under TSCA if it is on the TSCA Chemical Substance Inventory, and should note any specific TSCA Section 6 restrictions applicable to the product’s use.
In practice, Section 15 quality varies enormously across manufacturers. A well-maintained SDS will explicitly state whether the product contains any TSCA Section 6-restricted substances and note the applicable restriction. A poorly maintained SDS may have a generic “complies with applicable TSCA regulations” statement that tells you nothing useful.
If Section 15 is sparse for a product you’re using in a regulated category, don’t assume it’s clean. Ask the supplier directly: - “Does this product contain trichloroethylene, methylene chloride, 1-bromopropane, perchloroethylene, or carbon tetrachloride in any concentration?” - “What is the 1,4-dioxane content in ppm, if detectable?” - “Does this product contain any intentionally added PFAS compounds?”
Get answers in writing. A supplier who cannot answer these questions for their own product is either poorly organized or unwilling to disclose. Both scenarios are procurement risks.
How Buyers Should Respond to the TSCA Section 6 Wave
Step 1: Chemistry Audit
For every cleaning product in active use at industrial facilities, pull the SDS and search Section 3 (Composition) for: - Trichloroethylene (TCE), CAS 79-01-6 - Methylene chloride (DCM), CAS 75-09-2 - 1-Bromopropane (nPB), CAS 106-94-5 - Perchloroethylene (PCE/PERC), CAS 127-18-4 - Carbon tetrachloride, CAS 56-23-5 - Any PFAS (look for “fluoro-” chemistry) - 1,4-Dioxane, CAS 123-91-1 (note: typically not listed because it’s a trace contaminant rather than an ingredient — requires direct supplier inquiry)
Any product containing the first five chemicals on this list needs to be mapped to the applicable TSCA Section 6 rule and current compliance status for your specific use type.
Step 2: Identify Vapor Degreasing Operations
If your facility runs vapor degreasing equipment, identify: - The specific solvent chemistry currently in use - The equipment type and age - The cleanliness specification that the process must meet (military standard, aerospace specification, medical device cleanroom requirement, or internal quality spec) - The current regulatory status of that chemistry under TSCA Section 6
Vapor degreasing with TCE is the highest-urgency item in the TSCA Section 6 landscape for industrial cleaning. If it’s running in your facility, the transition plan should be a named capital project with a project owner and a completion date.
Step 3: Build the Supplier Conversation
For each impacted chemistry: - What is the supplier’s compliant alternative? - What is the transition timeline for supply of the regulated product (i.e., when does the supplier stop selling it for your use category)? - What equipment modifications or replacements are required for the alternative? - What is the cost differential — per gallon and total operational cost including equipment changes?
Step 4: RFP and Contract Language
For new procurement of industrial cleaning chemicals, add the following to RFP terms and purchase order language:
“Supplier warrants that this product does not contain trichloroethylene, methylene chloride, 1-bromopropane, perchloroethylene, or carbon tetrachloride unless explicitly disclosed and accompanied by a current TSCA Section 6 compliance attestation for the specific use category covered by this purchase order.”
“Supplier shall notify buyer within 30 days of any TSCA regulatory action affecting the formulation or permitted uses of this product.”
“Supplier shall provide, upon request, 1,4-dioxane content documentation (ppm by weight) for any product containing polyethoxylated surfactant ingredients.”
Cost and Operational Realities
Transitioning from TCE (or nPB) to compliant alternatives is not cost-neutral. Buyers who plan for this on a “chemical swap” basis will be surprised. The full cost picture includes:
Chemistry cost: HFE and HFO-based solvents are meaningfully more expensive per gallon than TCE. The per-pound soil-removed cost may be closer than the raw per-gallon number suggests (closed-loop systems recover solvent more efficiently in some cases), but the upfront chemistry cost is higher.
Equipment cost: Vapor degreasing equipment designed for TCE may require modification for HFE or HFO chemistry (different vapor temperatures, different materials compatibility). Aqueous parts washers require separate equipment entirely. Budget for equipment assessment and modification as part of the transition project, not just chemical replacement.
Validation cost: If your cleanliness specification references a military standard (MIL-PRF, MIL-STD), an aerospace specification (NADCAP, customer-specified), or a medical device requirement (ISO 13485 manufacturing quality), the alternative cleaning process must be validated against that specification. Validation testing takes time and may require multiple trial runs and measurement. This is not a cost that can be compressed — it has to be done right because the cleanliness specification exists for a reason.
Waste classification changes: Some TCE alternatives have different waste classification under RCRA. HFE and HFO wastes may be classified differently than chlorinated solvent wastes for disposal purposes. Factor waste management cost changes into the transition budget.
Scenario: A Tier 2 Aerospace Component Manufacturer
A Tier 2 aerospace component manufacturer has run a TCE vapor degreaser for 32 years. The degreaser is used to clean aluminum brackets and stainless steel fittings prior to anodizing and chromate conversion coating. The cleanliness spec is customer-specified: < 1 mg/ft² non-volatile residue, verified by ASTM F22 water break test.
The facility received the December 2024 TCE rule and began transition planning in early 2025. The project looks like this:
Phase 1 (Months 1–3): Chemistry evaluation Contact three suppliers of HFE-based and HFO-based degreasing fluids. Request technical data for each fluid including: VOC status, GWP, compatibility with aluminum and stainless steel alloys in use, compatible operating temperature range, and estimated cleanliness performance on mineral oil and hydraulic fluid soils. Request samples.
Phase 2 (Months 2–5): Equipment assessment Engage current degreaser OEM and a vapor degreasing equipment specialist. Assess which HFE/HFO fluids are compatible with current equipment without modification. Identify any required hardware changes: different coil temperatures, modified vapor containment, possible freeboard ratio changes for vapor recovery. Get capital cost estimate for modification vs. full equipment replacement.
Phase 3 (Months 4–7): Trial cleaning and validation Run side-by-side cleaning trials: current TCE process vs. candidate HFE fluid on representative production parts. Test each trial batch against the customer cleanliness specification (ASTM F22 water break; < 1 mg/ft² NVR by gravimetric test). Document pass/fail rates. Identify any process parameter adjustments needed for the HFE process to meet spec consistently.
Phase 4 (Months 6–9): Customer notification and qualification Notify the prime contractor (per AS9102 and first article inspection change notification requirements) of the solvent change. Provide validation data. If customer requires qualification testing, submit parts through qualification process. Build transition into PPAP documentation if applicable.
Phase 5 (Month 9–12): Equipment modification and conversion Order and install equipment modifications. Convert production to HFE chemistry. Drain and dispose of residual TCE per RCRA requirements for chlorinated solvent waste. Document waste manifests.
Cost summary (approximate for this scenario): - HFE chemistry cost vs. TCE: approximately 3–4x per gallon; partially offset by higher recovery efficiency in the converted system - Equipment modification: $15,000–$40,000 depending on scope - Validation testing and customer qualification: 2–4 months of engineering time + test costs - Waste disposal for residual TCE: hazardous waste disposal at chlorinated solvent rates
The transition is manageable and well within the compliance timeline if started in 2025. Facilities that delay until 2026 or 2027 will face compressed timelines for validation and potentially equipment lead time delays.
The TSCA Section 6 Pipeline: What’s Coming Next
The initial 10 high-priority chemicals from the 2016 reformed TSCA process have largely moved through evaluation and into rulemaking. EPA has identified subsequent batches of chemicals for risk evaluation under the ongoing TSCA program. Industrial cleaning buyers should monitor EPA’s TSCA Section 6 work plan for chemicals relevant to their operations.
Of particular interest:
- Additional PFAS compounds: EPA is addressing PFAS through TSCA and other statutory authorities. Specific PFAS compounds used in cleaning or surface treatment applications may face Section 6 action.
- N-methylpyrrolidone (NMP): A high-performance industrial solvent used in some specialty cleaning and coating applications. EPA’s risk evaluation found unreasonable risk for certain uses; risk management rulemaking is in process. Verify current status.
- Formaldehyde: TSCA Section 6 risk evaluation has addressed formaldehyde. Some cleaning and disinfection chemistries have formaldehyde-releasing preservatives; monitor TSCA status.
The practical monitoring approach for buyers: designate an internal owner (EHS or procurement) to review EPA’s TSCA Section 6 work plan quarterly and match any new high-priority substances against your chemical inventory. This is a 30-minute review cycle that can prevent a 12-month reactive scramble.
Common Mistakes
“TCE is for dry cleaning, not us.” TCE is not a dry-cleaning chemical — that’s perchloroethylene (PERC). TCE is primarily an industrial metal-cleaning chemical. If your facility cleans metal parts before finishing, assembly, or inspection, TCE is the first chemical to audit.
Not reading SDS Section 15 for TSCA restrictions. Section 15 should disclose TSCA status for regulated substances. If it doesn’t, ask the supplier directly. The absence of disclosure is not clearance.
Missing the vapor degreasing exposure. Facilities that don’t run a “degreaser” may still run a “parts washer” or “ultrasonic cleaner” or “pre-treatment tank” using chlorinated solvent chemistry. The regulatory category doesn’t track what you call the machine; it tracks the chemistry inside it.
Not asking suppliers about 1,4-dioxane in surfactant chemistries. 1,4-Dioxane is not listed as an ingredient because it’s a trace contaminant. It won’t appear in Section 3 of the SDS because it’s not intentionally added. You have to ask directly and request analytical documentation.
Treating the transition deadline as the project start date. Vapor degreaser transitions involve equipment assessment, alternative chemistry evaluation, cleanliness validation, customer or specification qualification, equipment modification, and waste disposal. That is a 9–18 month project in most industrial facilities. Starting at the compliance deadline means finishing late. Start now.
Printable TSCA Section 6 Procurement Audit Checklist
TSCA SECTION 6 PROCUREMENT AUDIT CHECKLIST
Facility: ___________________ Date: ___________ Completed by: ___________
CHEMICAL INVENTORY SCREEN (check SDS Section 3 for each cleaning product)
[ ] Trichloroethylene (TCE / CAS 79-01-6) — present in any product?
[ ] Methylene chloride (DCM / CAS 75-09-2) — present in any product?
[ ] 1-Bromopropane (nPB / CAS 106-94-5) — present in any product?
[ ] Perchloroethylene (PCE / PERC / CAS 127-18-4) — present in any product?
[ ] Carbon tetrachloride (CAS 56-23-5) — present in any product?
[ ] PFAS compounds (any "fluoro-" named ingredient in Section 3) — present?
VAPOR DEGREASING / SOLVENT CLEANING OPERATIONS
[ ] Vapor degreasing equipment identified and chemistry confirmed
[ ] Cold cleaning / open-tank solvent operations identified and chemistry confirmed
[ ] Parts washers using solvent identified and chemistry confirmed
[ ] For TCE-based equipment: transition project initiated with named owner and target completion date
[ ] For nPB-based equipment: TSCA regulatory status verified; transition plan in place if required
[ ] Alternative chemistry evaluation in progress or complete
SUPPLIER CONVERSATIONS (document in writing)
[ ] TCE / DCM / nPB / PCE absence confirmed in writing for each relevant product
[ ] 1,4-Dioxane content documented in ppm for surfactant-based cleaners
[ ] PFAS-free attestation requested and received for products in sensitive applications
[ ] Reformulation notification requirement in supply agreements
SDS SECTION 15 REVIEW
[ ] Section 15 reviewed for each cleaning product — TSCA restrictions noted
[ ] Products with sparse Section 15 flagged for direct supplier inquiry
[ ] Supplier inquiry responses documented in compliance file
PROCUREMENT LANGUAGE
[ ] TSCA Section 6 attestation language in RFP terms for industrial cleaning chemicals
[ ] 30-day notification clause for TSCA regulatory changes affecting current products
[ ] 1,4-Dioxane disclosure clause for surfactant-based products sold into New York
TSCA PIPELINE MONITORING
[ ] Assigned reviewer for EPA TSCA Section 6 work plan — quarterly review scheduled
[ ] Active chemicals in work plan cross-referenced against facility inventory
[ ] Next review date: ___________