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Measure twice van buren
1. Measure Twice, Cut Once
PRISM 2017
Carol Jones Van Buren
Van Buren Law, PLLC
cvanburen@vanburenlaw.com
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. 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
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.
9. 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
10. 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
11. 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.
