SBA Environmental Roundtable Meeting June 21

The next U.S. Small Business Administration, Office of Advocacy Environmental Roundtable will meet virtually to discuss the following topic, beginning at 10 a.m. on June 21, 2023. The meeting will be held using the Microsoft Teams platform.

Send your RSVP to A meeting link will be provided to you when you RSVP.


10:00 AM – 10:30 AM: EPA’s Proposed Risk Management of Methylene Chloride Under the Toxic Substance Control Act (TSCA)
Caffey Norman, Halogenated Solvents Industry Alliance (HSIA)

10:30 AM – 11:00 AM: Discussion              

*** Roundtable meetings are open to all interested persons and are intended to facilitate an open and frank discussion about issues of interest to small business. These meetings are off the record and not intended for press purposes. Direct quotations of presenters or attendees may not be used without direct written approval of the person(s) making the statement. All press inquiries should be sent to Agendas and presentations are available to all.***

Small Business Environmental Roundtable Issue for Discussion June 21, 2023
EPA’s Proposed Risk Management of Methylene Chloride under TSCA

On May 3, 2023, EPA published a proposed to rule to restrict the use of methylene chloride under the Toxic Substance Control Act (TSCA). Methylene chloride is used as a solvent in a wide range of industrial, commercial and consumer applications. TSCA requires that EPA address any unreasonable risk of injury to health or the environment identified in a TSCA risk evaluation.  EPA must apply requirements to the extent necessary so that the chemical no longer presents unreasonable risk. EPA evaluated 53 conditions of use of methylene chloride and determined that 47 conditions of use present an unreasonable risk of injury to health for workers and consumers. Based on these risk determinations, EPA is proposing to prohibit the manufacture, processing, and distribution in commerce of methylene chloride for consumer use. EPA is also proposing to prohibit most industrial and commercial uses of methylene chloride. For the remaining uses, EPA is proposing to require a workplace chemical protection program, which would include a chemical exposure limit, set by EPA, and exposure monitoring. The proposal also includes time-limited exemptions for uses of methylene chloride that would otherwise significantly disrupt national security and critical infrastructure. The public comments are due on July 3, 2023.

First, Caffey Norman, on behalf of HSIA, will present on the proposed rule including an overview of issues particularly relevant to small businesses. There will be an opportunity for questions, as well as discussion. Perspectives from all affected small entities are welcome.

Speaker Bio: W. Caffey Norman
Caffey Norman is an attorney with an environmental practice that is focused on the regulation of hazardous chemicals by the Environmental Protection Agency, the Occupational Safety and Health Administration, the Consumer Product Safety Commission, and various state regulatory agencies. Mr. Norman participated, on behalf of HSIA, in EPA rulemakings to regulate hazardous substances under all the environmental statutes and has initiated legislative and judicial review of a number of EPA regulations. HSIA represents producers and users of methylene chloride. Many of HSIA’s user members include small businesses. HSIA participated on the small business advocacy review panel convened for this proposed rulemaking, to assist small entity representatives in providing advice and recommendation to EPA on its potential regulation for the use of methylene chloride.