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Measure twice van buren


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Measure twice van buren

  1. 1. Measure Twice, Cut Once PRISM 2017 Carol Jones Van Buren Van Buren Law, PLLC
  2. 2. TCE Studies Studies showing TCE in indoor air is an acute hazard at very low levels Study Showed: Fetal Heart Malformations Developmental Immunological Effects Risk is Greatest in 1st Trimester of Pregnancy
  3. 3. Acute Hazard Studies showing TCE in indoor air may be an acute hazard based on low dose, short term maternal exposure. Acute = Short Term Exposure May Harm Immediate Action Required For Risk Mitigation
  4. 4. TCE Standards
  5. 5. The Formula  ug/m3 to ppb ***Warning: Ideal Gas Law Involved****
  6. 6. Pollution Prevention TSCA Work Plan Chemical Risk Assessment – June 2014
  7. 7. TCE in Consumer Products (now or formerly) • Adhesives • Cleaning Fluids for Rugs • Paint Removers/Strippers • Spot Removers • Typewriter Correction Fluid • Fire Arm Cleaner/Gun Scrubber • Brake Sprays
  8. 8. Risks TCE May Not Have Been Adequately Assessed/Regulated in the Past - Refis Disclosure to Tenants and Tenant Freak Out Employment Situations—Very Difficult to Discuss Risk Avoidance (i.e., Don’t Get Pregnant) Soft “No Entry” Directives from Agency
  9. 9. Risks Sorting Out Background & Ambient Air Issues Monitoring of Indoor Air If Subslab Levels Are High Accrual for Contingency if Conditions Change Certain Sensitive Uses (Like Apts) May Warrant Requiring Preventative Mitigation to Avoid Indoor Air Sampling
  10. 10. EPA Proposes Limiting TCE Under TSCA In January, 2017 and December 2016, EPA published two proposed rules under section 6(a) of the Toxic Substances Control Act (TSCA) One to ban commercial use of TCE in vapor degreasing One to ban use of TCE in commercial and consumer aerosol degreasing and as a spot cleaner in dry cleaning.