EPA TCE Delay: How the Regulation Pause Affects Businesses and Health

Key Takeaways

• The EPA’s Trichloroethylene (TCE) workplace protection rule, delayed until November 2025, highlights a 500-fold gap between outdated OSHA limits and modern science, leaving workers under unsafe exposure levels for longer.

• Aerospace, defense, and battery manufacturing rely heavily on TCE, but the ongoing rule delay exposes workers while industries argue that immediate restrictions could disrupt growth and supply chains.

• Evidence shows that long-term TCE exposure is linked to serious health risks, including kidney and liver cancer, yet employers remain legally compliant by following OSHA’s outdated 1970s standard.

• Success stories from companies that phased out TCE prove safer, cost-saving alternatives exist, demonstrating that innovation and compliance can strengthen worker safety and business performance.

• Regulatory delays may ease industry pressure in the short term, but they compound health risks, liability, and reputational damage, making early action toward safer alternatives the smarter strategy.

How safe is really safe? That’s the question I keep coming back to whenever I encounter compliance issues connected with trichloroethylene (TCE). On paper, the Occupational Safety and Health Administration (OSHA) still says it’s okay for workers to breathe in up to 100 parts per million of this chemical. But the Environmental Protection Agency (EPA) decided anything above 0.2 ppm is unsafe. That’s not a small difference but a 500-fold gap.

And because the EPA delayed its workplace protection rules until November 17, 2025, workers are forced to stay under OSHA’s outdated limit for almost another year. So we’ve got people in billion-dollar industries, like aerospace and battery manufacturing, still working with protections written back in the 1970s, while the science has already moved on.

What Led to the EPA’s TCE Rule Delay? 

The EPA's final rule regulating TCE under the Toxic Substances Control Act (TSCA) was issued on December 17, 2024, after concluding that TCE poses an “unreasonable risk” to workers. This rule included bans on most uses along with time-limited workplace exemptions under TSCA Section 6(g) and was originally scheduled to take effect on January 16, 2025.

Once the rule was announced, legal and administrative challenges quickly followed:

• January 2025 – Industry Petitions: Almost immediately, several companies and trade groups filed petitions for reconsideration and emergency stays. Their argument was straightforward: enforcing the new limits too quickly would create severe supply chain disruptions, increase compliance costs, and even pose risks to national security by affecting aerospace and defense readiness.

• Early 2025 – Litigation Moves Forward: The Fifth Circuit Court of Appeals granted a temporary stay, halting parts of the rule. The litigation was then consolidated in the Third Circuit under the case USW v. EPA (Case No. 25-1055). The case raised fundamental questions about EPA’s authority to impose workplace chemical protection programs under TSCA, which had not been fully tested before.

• January 20, 2025 – Regulatory Freeze: On top of the lawsuits, the incoming administration issued a government-wide “Regulatory Freeze Pending Review,” a standard move for new administrations. EPA responded by delaying the effective date of certain provisions of the TCE rule until March 21, 2025.

• April 2025 – Further Delays: As litigation and petitions mounted, EPA pushed the effective date for certain TSCA Section 6(g) exemptions again, this time to June 20, 2025. This was later extended to August 19, 2025, with EPA acknowledging both industry concerns and the complexity of implementing workplace chemical protection requirements in sectors without ready substitutes.

• August 2025 – Final Postponement: With the court cases still unresolved and ongoing pressure from manufacturers and lawmakers, EPA announced yet another delay. On August 19, 2025, the agency extended the effective date for the exemptions to November 17, 2025. EPA stated this extension would provide time for legal review and ensure regulated industries had clarity on compliance obligations.

Reviewing this timeline, I can’t help but notice that these repeated postponements highlight more than just regulatory back-and-forth. They point to a hard truth I’ve encountered time and again: industries continue to lean heavily on TCE because, for many processes, it still feels indispensable.

Why Is TCE Still Used in U.S. Manufacturing Despite Health Risks?

Even if it comes with well-documented health concerns, TCE remains a critical solvent for degreasing aircraft parts, processing battery separators, and specialized defense applications. 

In many cases, currently available substitutes don’t meet the performance requirements for precision cleaning or specialized materials processing. That’s why EPA’s final rule paired broad prohibitions with time‑limited exemptions for certain uses like rocket engine cleaning or some battery‑separator manufacturing, while phasing out most others.

The Economic Weight of TCE‑Dependent Industries

Industry leaders caution that imposing strict TCE restrictions too quickly could stall growth and undermine U.S. competitiveness, especially against overseas rivals operating under looser chemical regulations. Two sectors illustrate just how significant the stakes are:

Together, these figures explain why TCE remains embedded in U.S. industry. Aerospace and defense rely on high-reliability cleaning, while battery-separator production involves specialized processes where substitutes often fall short. EPA’s rule acknowledges this reality by granting time-limited exemptions in areas where alternatives are not yet feasible, while still planning a gradual phase-out elsewhere.

The Compliance Gap Between OSHA and EPA

Another reason TCE remains in use is the divide between existing OSHA standards and EPA’s pending limits. OSHA’s permissible exposure limit for TCE, written in the 1970s, is still legally enforceable, while EPA’s much stricter standards are tied up in delays and legal challenges.

This means companies can remain within OSHA’s outdated limits and still be considered “legal,” even though modern science shows those levels pose significant risks. In practice, many employers wait until the last possible moment to adapt, leaving workers under protections that lag far behind today’s health evidence.

This compliance gap reflects why OSHA and EPA created an MOU to coordinate chemical safety enforcement, ensuring neither agency leaves workers unprotected.

What Does TCE Exposure Mean for Workers?

As much as industries defend TCE as essential, the human cost tells a different story. Short-term contact often leads to respiratory irritation, skin rashes, and even neurological symptoms like dizziness or headaches. But the bigger concern comes with long-term exposure, which causes kidney cancer, liver cancer, and serious immune system damage.

I’ve reviewed cases related to this chemical, and it led me to countless studies documenting how exposure takes a toll on workers. A 2016 study of 997 male workers in Norway who had long-term occupational exposure to TCE revealed that 13 developed kidney cancer, compared to 7.5 expected cases, yielding a standardized incidence ratio (SIR) of 1.7 (95% CI: 1.0–3.0). The majority of these cases were directly linked to TCE exposure.

In another case, a study of clock factory workers exposed to TCE reported prevalence rates of subjective symptoms 9.61 to 11.76 times higher than unexposed groups. The most common issues included skin irritation (29.6%) and respiratory symptoms (21.1%), underscoring how consistent exposure translates directly into daily health struggles.

This is exactly the reason why the EPA estimates that enforcing its proposed lower exposure limits could cut workplace risks by as much as 97%. For anyone committed to worker health and compliance, that's a reduction that can't be overlooked.

Proof That Change Is Possible

Whenever I hear the argument that TCE is “indispensable,” I find it hard to agree with because there are companies that have already proven otherwise. They didn’t just reduce their reliance, they eliminated it, improved worker health, and even saved money in the process. These success stories show that compliance and innovation can go hand in hand.

These companies prove that TCE dependence isn’t permanent. With the right strategy, eliminating it can protect workers, strengthen compliance, and even reduce costs over time. 

What’s at Risk With the Delay?

If nothing changes, another generation of workers will continue facing the same preventable exposures, despite regulators having long recognized the dangers of TCE. The risks aren’t just medical, they’re systemic.

The potential long-term costs include class-action lawsuits, rising healthcare burdens, and even supply chain instability as workforce health crises ripple through critical industries. But the damage doesn’t stop there. Companies that cling to outdated practices also risk losing investor confidence and falling behind international competitors who are already transitioning to safer alternatives. For sectors tied to government contracts, compliance failures could mean jeopardizing federal partnerships or triggering stricter procurement requirements.

Delays may feel like short-term relief, but they quietly build layers of liability and reputational damage. The reality is that ignoring TCE risks doesn’t just endanger workers but puts the entire business models and industry credibility on unstable ground.

What Comes Next

The November 2025 deadline now looms, but whether it will hold remains uncertain. Ongoing litigation, congressional pushback, and technical hurdles could spark yet another extension. Still, history shows that each delay only postpones the inevitable: the regulatory trend is moving steadily away from TCE.

For companies, betting on another delay is a gamble with high stakes. Compliance costs, legal risks, and reputational damage can escalate quickly for firms that are caught unprepared. The smarter path is to get ahead of the curve by building resilience now. That means:

• Testing safer alternatives early. Industries already experimenting with fluorinated solvents, aqueous cleaning systems, and vacuum vapor degreasers are learning where the real bottlenecks and cost savings lie before demand spikes.

• Strengthening interim protections. Upgrading PPE, ventilation systems, and exposure monitoring programs not only reduces immediate risks for employees but also builds goodwill with regulators and workers alike.

• Phasing out TCE strategically. A planned, step-by-step reduction avoids the disruption of a sudden regulatory cutoff, which can force rushed and more expensive transitions.

• Engaging stakeholders proactively. Transparent communication with employees, investors, and even customers signals responsibility, protects brand reputation, and attracts partners who value compliance and safety.

The bottom line: deadlines may shift, but direction is clear. TCE’s place in U.S. manufacturing is shrinking, and the companies that adapt now will have the advantage. Early movers won’t just sidestep last-minute chaos. They’ll protect their workforce, strengthen compliance, and position themselves as leaders in a safer, more sustainable future.

FAQs

What is the EPA risk evaluation of TCE?

The EPA found TCE poses an unreasonable risk, linking it to cancer, immune damage, and neurological harm. This triggered stricter workplace rules under TSCA.

What is the TCE rule?

Finalized in December 2024, the TCE rule restricts most uses while allowing temporary exemptions for critical sectors like aerospace and battery manufacturing. It replaces outdated OSHA limits with stricter standards aimed at cutting workplace risks by up to 97%.

Why did the EPA delay the TCE rule?

The EPA postponed enforcement until November 17, 2025, due to industry petitions, litigation, and a regulatory freeze. While delays allow time for legal and technical review, they leave workers subject to outdated OSHA limits and ongoing exposure risks.

What is the difference between PCE and TCE?

Perchloroethylene (PCE) is mainly used in dry cleaning, while trichloroethylene (TCE) is common in aerospace and precision cleaning. Both are hazardous solvents, but TCE carries stronger evidence of cancer and immune system harm, making it the EPA’s immediate regulatory focus.

Are there safer alternatives to TCE?

Yes. Companies use aqueous, semi-aqueous, and fluorinated solvents. These safer options reduce exposure, improve workplace safety, and keep industrial performance strong.

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