As the U.S. Environmental Protection Agency (EPA) considers reforms to the Toxic Substances Control Act (TSCA), the Independent Lubricant Manufacturers Association (ILMA) is advocating for a more focused and practical approach to chemical risk evaluations under TSCA Section 6, which covers existing chemicals.

In comments submitted November 7, ILMA urged the agency to assess chemical risks based on specific conditions of use rather than through broad, sweeping characterizations that could lead to unnecessary regulation without meaningful environmental or health benefits.

ILMA emphasized that the EPA’s framework should account for real-world industry practices and mitigation measures, such as common safety controls already in place throughout the lubricants industry. These factors, the Association noted, are essential to ensuring that risk evaluations reflect actual exposure potential.

To support its position, ILMA pointed out that chemical additives used in finished lubricant formulations have very limited potential for harmful release or exposure during normal use.

Overall, ILMA endorsed the EPA’s goal of systematic chemical review while calling for a targeted, use-based approach that directs regulatory resources toward areas of greatest potential risk—protecting both the environment and the continued innovation of the lubricants industry.

Read the comments here.