By: Moms Clean Air Force
Date: March 21, 2025
About:Vinyl Chloride Draft Scope of the Risk Evaluation Under the Toxic Substances Control Act (TSCA), Docket ID No. EPA-HQ-OPPT-2018-0448
To: EPA
Dear Administrator Zeldin,
Thank you for this opportunity to comment on the draft scope for the risk evaluation of vinyl chloride under the Toxic Substances Control Act (TSCA).1
Vinyl chloride is a toxic, flammable, and explosive chemical that can set off a cascade of health effects including liver cancers, brain and lung cancers, lymphoma, and leukemia. In December, 2024, the Environmental Protection Agency (EPA) designated vinyl chloride a “high priority substance” under the Toxic Substances Control Act (TSCA). Now the EPA must carry out a risk evaluation assessing the entire supply chain of vinyl chloride including its manufacture, processing, distribution in commerce, use, and disposal. TSCA requires the EPA Administrator to evaluate whether the conditions of use of this potent human carcinogen present an “unreasonable risk of injury to health or the environment.”2
The plastics industry produces tens of billions of pounds of vinyl chloride each year. The exact amount is unclear, as EPA shares production volumes only to the closest 10 billion pounds, allowing manufacturers to withhold the actual amounts as “confidential business information.”3
Vinyl chloride is typically made by combining chlorine and ethylene, and then heating the resulting ethylene dichloride to over 900 degrees F in a “cracker.” Ninety-nine percent of the vinyl chloride monomer that’s produced is used in PVC plastic. This plastic is made of roughly half vinyl chloride monomer and half “chemical additives” such as phthalates, flame retardants, UV stabilizers, cadmium, lead, and other synthetic chemicals, many of them extremely toxic.
PVC plastic is used to make everything from children’s toys to drinking water pipes to food packaging.
Workers and communities—including infants and children—are exposed to vinyl chloride throughout the supply chain. Exposures come from PVC plastic products and microplastics as well as from industrial sources such as plastics-and-resin manufacturing facilities, combustion processes, hazardous waste sites, and municipal landfills. There is no safe level of exposure to this carcinogen.
The EPA’s draft scope for its vinyl chloride risk evaluation is deficient.
On January 16, 2025, the EPA published a draft scope outlining what the agency will consider in its TSCA risk evaluation of vinyl chloride. Moms Clean Air Force has reviewed the EPA’s plan and identified significant shortcomings.
These include:
- The EPA omits firefighters and other emergency personnel from its designation as Potentially Exposed and Susceptible Subpopulations. Such an exclusion is an affront to the people who risk their own lives by rushing in protect people from chemical fires, leaks, explosions, and other disasters—whether in East Palestine, Ohio, or in Los Angeles, California.
- The EPA indicates that it may omit from its risk evaluation any catastrophic incidents that do not lead to “regular and predictable” exposures. Chemical disasters, from spills to fires, happen with unfortunate regularity, putting workers and families in harm’s way. They are absolutely foreseeable. It would be a dereliction of duty for EPA to exclude these horrific events from the risk evaluation.
- Likewise the EPA excludes from the scope of its risk evaluation “extreme weather events…and other natural disasters” unless these events are shown to be regular and predictable. In fact, vinyl chloride incidents are an increasingly predictable result of the heatwaves, fires, droughts and other events that result from rising global
- Although the EPA classifies as Potentially Exposed or Susceptible Subpopulations the “communities living near industrial facilities where vinyl chloride is manufactured or used,” a decision we strongly support, the agency leaves out people who live near vinyl chloride disposal sites including hazardous waste facilities, municipal landfills, and incinerators. EPA downplays the risks of chemical leaching and volatilization at those facilities, and the harm from toxic and corrosive gases when vinyl chloride is burned.
- The scoping document is inappropriately quick to cut off several avenues of inquiry related to the exposure pathways to communities from the disposal of vinyl. For example, the EPA suggests that it will not be including in the scope of this risk evaluation the volatilization route from landfills “[b]ecause the majority of the vinyl chloride in landfills is expected to originate from sources outside of scope…” This is at variance with EPA’s own May 2024 procedural rule and with the TSCA statute itself, which call for the comprehensive assessment of all sources of vinyl chloride in the TSCA risk evaluation.
- The EPA has not indicated whether it will use all of the tools at its disposal—including TSCA section 4 test orders—to gather information on risks to children, families, and all people living at the fenceline of vinyl chloride production, processing, and waste disposal sites. This data on exposures and health effects is critically important in evaluating the unreasonable risks of vinyl chloride. Information gaps should not be interpreted to mean safety or the absence of unreasonable risk.
- The EPA leaves out any mention of cumulative and aggregate TSCA requires EPA to use the best available science, which means that the EPA must review cumulative and aggregate risks rather than follow the outdated and unrealistic single-chemical single- exposure paradigm.
- The EPA makes multiple references to vinyl chloride recycling, as if this toxic plastic polymer is part of the illusory “circular economy of ” EPA’s Vinyl Chloride Use Report indicates that nearly 59 percent of production-related vinyl chloride waste gets “recycled.” This figure is misleading, as it refers only to the capture and re-use of materials during the manufacturing process itself. The Use Report also affirms that 99 percent of the vinyl chloride produced goes toward making PVC plastic – using 10 to 20 billion pounds of vinyl chloride per year. What both EPA documents omit to say is that roughly zero post-consumer PVC plastic gets recycled.
- EPA states that the maximum contaminant level (MCL) for average vinyl chloride concentrations will protect Americans from vinyl chloride monomer in drinking water, yet the MCL is not a health-based standard. The MCL is based on cost and feasibility when using vinyl chloride drinking water pipes.
- EPA leaves out mention of alternative materials, products, and Consideration of alternatives is critical to a determination of the “unreasonability” of the risk posed by vinyl chloride on human health and the environment.
We elaborate on these ten issues below.
1. Firefighters and other first responders are Potentially Exposed or Susceptible Subpopulations. TSCA requires EPA to evaluate the risks to “Potentially Exposed or Susceptible Subpopulations” (PESS), yet EPA excludes first responders—some of the most highly exposed and vulnerable people.45 Firefighters and other emergency workers face astronomically high levels of burning vinyl chloride as well as dioxins and other toxic chemical exposures during catastrophic explosions, fires, and other incidents.6 Consider, for example, the people who rushed in to protect East Palestine and surrounding communities from the disastrous Norfolk Southern derailment and detonation, and those who worked tirelessly to clean the waterways and remove the contaminated soils. Their courage and selflessness are commendable. They should not have to pay for it with their lives.
Firefighters and other emergency personnel are also subject to elevated risks from breathing in burning vinyl chloride and the resulting dioxins, hydrogen chloride, and other chemicals in structural fires, both at the scale of individual buildings and during large-scale disasters such as occurred in Los Angeles in January 2025. PVC siding, flooring, wire insulation, plumbing lines, molded furniture, wall coverings, and other products transform conventional building fires into raging toxic infernos. All of us are subject to the dangers of houses, schools, and office buildings made out of PVC and other plastics, but firefighters face some of the most significant risks.7
Toxic exposures aside, vinyl chloride building materials make structural fires far more dangerous. As described by the National Association of Realtors, “An average of about 3,500 people died in fires per year between 2010 and 2019, according to the U.S. Fire Administration. That number is rising.
Construction experts say that homes and buildings are at greater risk because more materials in the building of homes and furniture are more flammable than they used to be. The widespread use of synthetic materials is increasing the risk, they say.
Today, people have just three minutes to escape a home fire, according to UL, a safety certification company. About 40 years ago, homeowners had about 17 minutes to escape from a similar fire.”8
Vast amounts of these “synthetic materials” are made from vinyl chloride. The use of combustible materials such as vinyl siding is making fires more deadly and faster spreading.
It is shocking and inexcusable that EPA plans leave out the risk to firefighters and other first responders. We urge EPA to include fire-safety risks in its evaluation of vinyl chloride, and to designate firefighters as Potentially Exposed and Susceptible Subpopulations.
2. Catastrophic vinyl chloride incidents are regular and predictable. EPA suggests that it may leave out chemical disasters. This would include, for example, the February 3, 2023 Norfolk Southern train derailment, which smothered large swaths of Ohio and Pennsylvania in a toxic cloud of burning vinyl chloride, putting the entire region at risk.
Despite the known dangers from this flammable and explosive carcinogen, EPA proposes to leave out consideration of the catastrophic vinyl chloride incidents that threaten the health of workers, children, and their families. It would be shocking for EPA to conclude that vinyl chloride chemical disasters are not part of the “unreasonable risks” of vinyl chloride.
The precise language in EPA’s draft scope is important:
“EPA generally does not include in the scope of the risk evaluation catastrophic accidents, extreme weather events, and other natural disasters if such events do not lead to regular and predictable exposures associated with a given condition of use. However, such a determination requires a fact-specific, chemical-by-chemical analysis (EPA-HQ-OPPT-2023-0496-0431). Thus, EPA would consider including such events (e.g., catastrophic accidents, extreme weather events, and other natural disasters) in the scope of the risk evaluation if the Agency receives information indicating regular and predictable changes in exposures associated with these events (88 FR 74292).” [Emphasis added.]
In other words, the agency is seeking to omit what it calls “catastrophic accidents, extreme weather events, and other natural disasters” if EPA is not convinced that they lead to “regular and predictable” exposures. Sadly, what happened in East Palestine, while news worthy, was far from an isolated incident. In the United States, vinyl chloride leaks, spills, fires, and explosions have taken place an average of once every five days since 2010.9 These horrific events are absolutely foreseeable—the only questions are, in whose backyard or workplace will they occur next, and on which day?
Since 2010, there have been at least 40 large-scale chemical incidents worldwide involving the production of vinyl chloride monomer and PVC plastics. These chemical fires and explosions killed at least 71 people and injured 637 people. Countless other people and animals have suffered debilitating cancers and other long-term effects from these incidents.10
In addition to leaks, fires, and explosions at facilities, there have been incidents during transportation of vinyl chloride and its constituent chemicals. On average, three trains derail in the U.S. each day. As many as half may be carrying hazardous substances. The National League of Cities reports that over 65% of all derailments occurred within the boundaries of cities.11
As reported by Toxic Free Future and Material Research, at any given moment up to 36 million pounds of toxic vinyl chloride are being shipped via rail by America’s largest producer, OxyVinyls, putting millions of Americans at risk. Every year, an estimated 1.5 billion pounds of this highly combustible and carcinogenic chemical are transported on bomb trains from OxyVinyls chemical plants in Texas to OxyVinyls and Orbia PVC plastics factories in NJ, IL, and Niagara Falls, Ontario.12
Catastrophic incidents have become regular and predictable. EPA must not exclude these spills, leaks, fires, explosions, and other incidents from the TSCA vinyl chloride risk evaluation.
3. Wildfires, heatwaves, and other “extreme weather events” lead to regular and predictable vinyl chloride exposures. The “extreme weather events” that trigger human exposures to vinyl chloride are increasing in both ferocity and frequency. These escalating risks are becoming regular and predictable. While we cannot say in advance the precise time and location where they will occur, their occurrence is nonetheless foreseeable.
Climate change is the principal driver of the increase in fire weather. For example, in January 2025 in Los Angeles, California, the extreme heat, vegetative dryness (eight months of near-zero rainfall) and drought, and the turbo-charged Santa Ana winds preceding the devastating fires have all been linked to climate change. What happened in Los Angeles as well as elsewhere in the south and southwest United States and in Hawaii, give us a glimpse of the droughts, heatwaves, and intense fires on the horizon as climate change accelerates.
Melting and burning vinyl-chloride-based structures can contaminate both the air and the drinking water. Burning vinyl chloride can release toxic air pollutants including phosgene,13 and dioxins.14 Vinyl chloride in the air can also break down into hydrochloric acid and formaldehyde.15 A study of the emissions from burning PVC found the presence of chlorinated components including vinyl chloride, chlorine dioxide, methyl chloride, methylene chloride, allyl chloride, ethyl chloride, 1-chlorobutane, tetrachloroethylene, chlorobenzene, and hydrogen chloride. The researchers also found benzene, 1,3-butadiene, methyl methacrylate, carbon monoxide, acrolein, and formaldehyde, all at levels that can harm human health.16
In addition to releasing hazardous air pollutants, excess heat events can melt PVC pipes and other structures, contaminating drinking water resources.17 A 2021 study found that plastic pipes don’t even have to burn to severely contaminate drinking water. Intense heat from wildfires or structural fires causes PVC to degrade significantly starting at 300°C. The PVC undergoes dehydrochlorination and forms polyene chains, as well as releasing benzene and toluene. The study found that PVC lost 40% of its mass by 400 °C and even more at 475 °C, releasing additional toxic chemicals such as ethylbenzene and xylene.18 Vinyl chloride, styrene, benzene and other carcinogens have also been observed leaching from heated pipes following fires in Santa Rosa and in Paradise, California.19
4. The EPA leaves out from classification as Potentially Exposed or Susceptible Subpopulations the harm to people who live near vinyl chloride disposal sites including hazardous waste sites, landfills, and municipal waste incinerators. While it is a good start that the EPA’s draft PESS category includes “communities living near industrial facilities where vinyl chloride is manufactured or used,” this PESS category needs to be expanded to include people residing near vinyl chloride disposal locations.
EPA downplays the risks of chemical leaching, volatilization, and hazardous air emissions at facilities that accept discarded vinyl chloride products. For example, there is no mention of the health impacts from the dioxins and furans, polycyclic aromatic hydrocarbons, and other incomplete combustion products released in the burning of vinyl chloride products. EPA’s stovepiped approach to its risk evaluation leaves fenceline communities vulnerable to the toxic and corrosive gases released in the disposal of vinyl chloride and PVC plastics.
5. Following on item 4, above, EPA downplays the toxic exposures from the vinyl chloride found in landfills, Superfund sites, and waste incinerators. Vinyl chloride from disposal facilities contaminates drinking water and pollutes communities with hazardous air pollutants. Vinyl chloride is highly mobile in soils, and can leach into groundwater from spills, landfills, and industrial sources. This can result in vapor intrusion—the migration of the vinyl chloride into the air in nearby buildings.
EPA acknowledges that that some portion of the vinyl chloride in landfills “will likely volatilize and may cause areas of elevated atmospheric concentrations above landfill surfaces (ATSDR, 2024; Molton et al., 1987).” EPA nonetheless proposes to exclude this air pollution danger to communities:
“Because the majority of the vinyl chloride in landfills is expected to originate from sources outside of scope, and leaching of vinyl chloride from polymers is likely to be minimal, the Agency expects to assess landfill pathways qualitatively in subsequent risk analyses” [emphasis added]. (Scope, p. 24.)
So the EPA is kicking the can down the road, suggesting a future qualitative analysis on vinyl chloride in landfills. Even if the source of some part of the vinyl chloride releases from landfills originates beyond the “scope,” this does not relieve EPA from including these sources in the risk evaluation, which must consider the aggregate risk from all sources. The TSCA scoping limitation refers to EPA’s ultimate risk management decision years down the line; it does not justify exclusion of sources from the risk evaluation.
As EPA states in its final rule on Procedures for TSCA Chemical Risk Evaluation, May 3, 2024, “(8) EPA will consider aggregate exposures to the chemical substance, and, when supported by reasonably available information, consistent with the best available science and based on the weight of scientific evidence, include an aggregate exposure assessment in the risk evaluation, or will otherwise explain in the risk evaluation the basis for not including such an assessment.
“(9) EPA will assess all exposure routes and pathways relevant to the chemical substance under the conditions of use, including those that are regulated under other federal statutes.”20 [Emphasis added]
Excluding the volatilization route of harmful exposures on the grounds that the source of those emissions is “out of scope” is incompatible with TSCA’s requirement to evaluate the aggregate risk of vinyl chloride exposures along the entire supply chain. The evaluation needs to include the aggregate risk, meaning the combined exposures to an individual from a single chemical substance across multiple routes and exposure pathways.
6. The EPA has tools at its disposal—including TSCA section 4 test orders—to gather information on risks to children, families, and all people living at the fenceline of vinyl chloride production, processing, and waste disposal sites. If the EPA does not have sufficient data on these exposures, as the draft scope appears to suggest, TSCA offers a path forward to build the needed scientific basis. Data on community exposures and health effects at every stage in the vinyl chloride supply chain is critically important in evaluating the unreasonable risks of this potent carcinogen.21
A critical subset of data is that which comes from fenceline monitoring. We urge EPA to use actual fenceline monitoring to assess the exposure levels in fenceline communities, rather than relying exclusively on industry-reported figures. The recent situation in Calvert City Kentucky, where EPA’s air monitoring found dangerous levels of vinyl chloride and other chemicals, demonstrates that fenceline monitoring is essential to identifying risk.22
7. TSCA requires EPA to use the best available science. This includes the evaluation of cumulative and aggregate risk, concepts which do not appear in EPA’s scoping document.
Specifically, there is no mention of cumulative risk—the risk from exposure to multiple chemicals or stressors that are associated with the same health outcomes—nor aggregate risk—the risk from exposure to a single chemical from multiple sources and routes. Yet these concepts are integral to the “best available science” that is supposed to guide the risk evaluation process under TSCA. People face aggregate and cumulative impacts via many different pathways including at daycare, at school, at work, and at home.
It would be absurd to examine the risk from vinyl chloride as if it is the only source of harm.
Vinyl chloride production facilities, for example, release vinyl chloride as well as ethylene dichloride, plasticizers, PFAS chemicals, chlorine-based compounds, heavy metals, asbestos, dioxins, and many other toxic chemicals. Stressors such as poverty and systemic racism compound the risk. Vinyl chloride monomer is like the enabler in a very toxic relationship, and to ignore the injury from aggregate and cumulative chemical exposures is to undervalue the massive health and environmental assault faced by communities. The Toxic Substances Control Act requires EPA to consider these combined exposures.
EPA’s own scientists have been raising the alarm for years about the recurrent, persistent and systematic patterns of pollution, economic marginalization, and public health vulnerability. As the EPA Inspector General concluded in their now-deleted EPA report, the single-pollutant, single-exposure paradigm does not match the reality on-the-ground and runs afoul of the Toxic Substances Control Act. 23 24 25
8. The vinyl chloride scoping document and its supplemental use report make many references to the “recycling of vinyl chloride.” Readers are left thinking that we’ve got a “circular” plastics economy after all.
Data in EPA’s Vinyl Chloride Use Report suggest that nearly 59 percent of production-related vinyl chloride waste gets “recycled.” Apparently this refers to the capturing and re-use of materials during the manufacturing process itself. The report also states that 99 percent of the 10 to 20 billion tons of vinyl chloride produced each year goes toward making PVC plastic.26 What the Vinyl Chloride Use Report does not say is the fact that the US recycling rate for post- consumer PVC plastic is roughly zero percent. A now-deleted EPA website states that less than one-quarter of 1% of post-consumer PVC is recovered for recycling. Most curbside recycling programs and recycling centers do not accept vinyl chloride materials.
The Use Report specifies that 57,609,495 lbs of vinyl chloride are “recycled” during the production process. If the US is producing 20 billion lbs of vinyl chloride per year, this would mean that 0.28 percent of vinyl chloride is recycled each year.
PVC is a major problem for both mechanical recyclers and the so-called “advanced recyclers” that burn plastic waste in pyrolysis incinerators It is widely considered a recycling-incompatible resin due to the extreme toxicity of the component materials, and to the super-toxic dioxins, corrosive hydrochloric acid, and other chemicals such as PFAS and phthalates released in these disposal processes.27 PVC is the least recycled plastic.
9. While EPA acknowledges the potential concern with vinyl chloride monomer in drinking water from PVC pipe, it suggests that there is no problem because we have the MCL to protect us. But the MCL is not health based.
EPA needs to consider more seriously the residual vinyl chloride monomer in PVC drinking water pipes. When vinyl chloride monomer is polymerized into PVC plastic or vinyl, small amounts of the chemical may remain unpolymerized, as a residual chemical in the PVC that is not molecularly bound to it. This unbound vinyl chloride can leach out. Given that towns and cities across the country, funded by the Bipartisan Infrastructure Law,28 may soon begin to remove lead service lines and replace them with PVC pipes, there is an immediate need for EPA to evaluate how much residual vinyl chloride monomer is present in the drinking water that passes through PVC service lines, pipes or plumbing fixtures.
The mass-scale transition to vinyl chloride-based materials for transporting drinking water raises significant concerns, as noted in item 3 above. Extreme heat scenarios aside, the MCL levels for vinyl chloride in drinking water are not health-based drinking water standards. EPA sets the MCLg—the Maximum Contaminant Level Goal for vinyl chloride—at zero, because of the extreme toxicity of this carcinogen. Yet the MCL (the allowable level in drinking water) is 0.002, a number that is “set as close to MCLGs as feasible using the best available treatment technology and taking cost into consideration.” This is not a health-based limit.29
We draw your attention to the October 21, 2024 letter in your EPA prioritization docket from Safe Water Engineering, which discusses the presence of vinyl chloride in drinking water and the need for data quantifying the magnitude of this risk, especially as more and more plastic pipes are being installed in drinking water systems every day. The letter emphasizes that even though the potential for vinyl chloride leaching into drinking water from PVC pipes has been documented,30 31 the EPA has no requirements for collecting samples at the tap.
The EPA relies upon assurances from NSF International, which is an industry-dominated private standard setting body. Their standards do not reflect actual household exposure, and as Safe Water Engineering concludes, “the NSF 61 testing procedure neither represents the true RVCM [Residual Vinyl Chloride Monomer] concentration of the tested product, nor the actual potential for VC [Vinyl Chloride] leaching at the tap.”32
10. EPA makes almost no mention of alternatives to the use of vinyl chloride, which TSCA states are a critical dimension of the review process.
The law states, “…the Administrator shall consider, to the extent practicable, whether technically and economically feasible alternatives that benefit health or the environment, compared to the use so proposed to be prohibited or restricted, will be reasonably available as a substitute when the proposed prohibition or other restriction takes effect.” [Emphasis added.]
While typically the EPA considers alternatives later in the TSCA process—in the risk management review—we would argue that the availability of the safe materials, products, and processes is essential in determining whether the risks from vinyl chloride are “unreasonable.” Unreasonability of risks depends very significantly on what is available or within reach. This matter of alternatives goes well beyond the draft scope’s plans to weigh the use of workplace engineering controls and personal protective equipment. For example, the EPA scope states that “[T]he Agency may assess worker exposure in industrial use scenarios before and after implementation of local exhaust ventilation.” That is not what Congress had in mind when it directed EPA to consider alternatives.
It is worth emphasizing that while vinyl chloride dominates the market in many product categories, the use of this potent carcinogen is almost entirely unnecessary. Even the U.S. Plastics Pact, which includes plastics packaging industry giants, has identified PVC as a “problematic and unnecessary material” and has called upon its members to take measures to eliminate PVC by 2025 (which is now). Pact members include Clorox, Coca Cola, Eastman, Walmart, and many others.33
Safe substitutes exist for most vinyl chloride products, from blood bags to construction materials34 to shrink wrap and clamshells. Where vinyl chloride-free products are not readily available, they can be developed as soon as EPA regulators signal a market opportunity. The transition to safe alternatives will be stymied, however, if the US government continues fast-tracking the expansion of vinyl chloride production and showering vinyl chloride polluters with regulatory subsidies.
On behalf of our more than 1.5 million members, Moms Clean Air Force is calling on EPA to put human health over petrochemical industry profits. It is time for the United States to move toward a ban on vinyl chloride and to begin the transition toward safe materials, products, and processes.
All families and communities deserve protection from this widely-used and extremely potent carcinogen. We will continue to advocate for a ban on vinyl chloride and a world where all children are safe from vinyl chloride, PVC plastic, and other industrial pollutants.
Respectfully submitted,
Cynthia Palmer
Senior Analyst, Petrochemicals
Moms Clean Air Force
1 Regulations.gov. (16 January 2025). https://www.regulations.gov/document/EPA-HQ-OPPT-2018-0448-0616
2 15 USC Ch. 53: TOXIC SUBSTANCES CONTROL. (2016).
https://uscode.house.gov/view.xhtml?path=/prelim@title15/chapter53&edition=prelim
3 EPA Use Report for Vinyl Chloride (CAS RN 75-01-4)(January 2025)
https://www.epa.gov/system/files/documents/2025-01/2-.-vinyl-chloride-.-draft-use-report-.-public-release-.-jan- 2025.pdf
4 Badr H. Alharbi, Mohammad J. Pasha, Mohammed Ahmad S. Al-Shamsi, Firefighter exposures to organic and inorganic gas emissions in emergency residential and industrial fires. Science of The Total Environment, Volume 770, 2021, https://doi.org/10.1016/j.scitotenv.2021.145332
5 Carcinogenicity of occupational exposure as a firefighter. Demers, Paul A et al. The Lancet Oncology, Volume 23, Issue 8, 985 – 986 https://www.thelancet.com/journals/lanonc/article/PIIS1470-2045(22)00390-4/fulltext
6 Zhang, M., Buekens, A., Jiang, X., & Li, X. (2015). Dioxins and polyvinylchloride in combustion and fires. Waste Management & Research the Journal for a Sustainable Circular Economy, 33(7), 630–643.
https://doi.org/10.1177/0734242x15590651
7 Leonardo Trasande, Roopa Krithivasan, Kevin Park, Vladislav Obsekov, Michael Belliveau, Chemicals Used in Plastic Materials: An Estimate of the Attributable Disease Burden and Costs in the United States, Journal of the Endocrine Society, Volume 8, Issue 2, February 2024, bvad163, https://doi.org/10.1210/jendso/bvad163
8 Apartments, homes more at risk for fires than past years. National Association of Realtors. (2022, January 13). https://www.nar.realtor/magazine/real-estate-news/law-and-ethics/apartments-homes-more-at-risk-for-fires-than- past-years
9 Comment letter from Earthjustice, Toxic-Free Future, and Beyond Plastics (18 March 2024) re: Initiation of Prioritization Under the Toxic Substances Control Act (TSCA): Request for Comment, 88 Fed. Reg. 87,423; Docket EPA-HQ-OPPT-2018 0448; Information regarding vinyl chloride, CAS RN 75-01-4 BP_EJ_TFF+Comments+with+Technical+Report+and+Appendices.pdf
10 Material Research. (2023, March 1). Chronology of vinyl chloride / PVC related disasters. https://storymaps.arcgis.com/stories/c201c51292214b969a67e9d544a7bc3b
11 Interactive rail safety map. National League of Cities. (2024). https://www.nlc.org/resource/interactive-rail- safety-map-see-derailments-in-communities-across-the-u-s/
12 Toxic Cargo - How rail transport of vinyl chloride puts millions at risk, an analysis one year after the Ohio train derailment. Toxic-Free Future and Material Research. (2024, January 22). https://toxicfreefuture.org/research/toxic-cargo/
13 Agency for Toxic Substances and Disease Registry. (2014). Medical Management Guidelines for Vinyl Chloride. Centers for Disease Control and Prevention. https://wwwn.cdc.gov/TSP/MMG/MMGDetails.aspx?mmgid=278&toxid=51
14 Burakoff, M., & Costley, D. (2023, February 24). Did dioxins spread after the Ohio train derailment? Associated Press. https://apnews.com/article/did-dioxins-spread-after-ohio-train-derailment- ea75d5991f9529dc83a911297a07bb7a
15 Toxicological profile for vinyl chloride. Agency for Toxic Substances and Disease Registry. (n.d.). https://www.atsdr.cdc.gov/ToxProfiles/tp20-c5.pdf
16 Chong NS, Abdulramoni S, Patterson D, Brown H. Releases of Fire-Derived Contaminants from Polymer Pipes Made of Polyvinyl Chloride. Toxics. 2019 Nov 11;7(4):57. doi: 10.3390/toxics7040057. PMID: 31717947; PMCID: PMC6958356. https://pmc.ncbi.nlm.nih.gov/articles/PMC6958356/#
17 Whelton, A. J. (May 6, 2021). Wildfires are contaminating drinking water systems, and it’s more widespread than people realize. The Conversation. https://theconversation.com/wildfires-are-contaminating-drinking-water- systems-and-its-more-widespread-than-people-realize-159527
18 Isaacson, K. P., Proctor, C. R., Wang, Q. E., Edwards, E. Y., Noh, Y., Shah, A. D., & Whelton, A. J. (2021). Drinking water contamination from the thermal degradation of plastics: implications for wildfire and structure fire response. Environmental Science Water Research & Technology, 7(2), 274–284. https://doi.org/10.1039/d0ew00836b
19 Meadows R. How Do Wildfires Affect Water Systems? ACS Cent Sci. 2022 May 25;8(5):504-506. doi: 10.1021/acscentsci.2c00511. Epub 2022 May 12. PMID: 35647286; PMCID: PMC9136967. https://pmc.ncbi.nlm.nih.gov/articles/PMC9136967/#
20 40 CFR Part 702 [EPA–HQ–OPPT–2023–0496; FRL–8529–02– OCSPP] Procedures for Chemical Risk Evaluation Under the Toxic Substances Control Act (TSCA) May 3, 2024 https://www.govinfo.gov/content/pkg/FR-2024-05-03/pdf/2024-09417.pdf
21 Song, L. (2022, June 27). The polluter just got a million-dollar fine. That won’t cure this woman’s rare cancer. ProPublica. https://www.propublica.org/article/pollution-kentucky-westlake-chemical-cancer
22 Niemeyer, L. (2024b, January 29). Chemical plant pollution has “elevated” cancer risk in a West Kentucky City, study says. Kentucky Lantern. https://kentuckylantern.com/2024/01/29/chemical-plant-pollution-has-elevated- cancer-risk-in-a-west-kentucky-city-study-says/
23 Cumulative Impacts Research: Recommendations for EPA’s Office of Research and Development, September 2022 https://www.epa.gov/system/files/documents/2022-09/Cumulative%20Impacts%20Research%20Final%20Report_FINAL-EPA%20600-R-22-014a.pdf
24 Interim Framework for Advancing Consideration of Cumulative Impacts November 2024 https://www.epa.gov/system/files/documents/2024-11/epa-interim-cumulative-impacts-framework-november- 2024.pdf
25 The EPA Inspector General report is no longer available on EPA Office of Inspector General website, but it was here. https://www.epaoig.gov/reports/audit/epa-needs-further-refine-and-implement-guidance-address- cumulative-impacts-and
26 EPA Use Report for Vinyl Chloride (CAS RN 75-01-4) January 2025 https://www.epa.gov/system/files/documents/2025-01/2-.-vinyl-chloride-.-draft-use-report-.-public-release-.-jan- 2025.pdf
27 Rollinson, A. (2023, October 26). Leaky loop “recycling” a technical correction on the quality of pyrolysis oil made from plastic waste. Zero Waste Europe. https://zerowasteeurope.eu/wp-content/uploads/2023/10/Leaky-Loop- Recycling_-A-Technical-Correction-on-the-Quality-of-Pyrolysis-Oil-made-from-Plastic-Waste-.docx.pdf
28 The White House (2024, October 9). FACT SHEET: Biden-Harris administration issues final rule to replace lead pipes within a decade, announces new funding to deliver clean drinking water. https://www.whitehouse.gov/briefing-room/statements-releases/2024/10/08/fact-sheet-biden-harris-administration-issues-final-rule-to-replace-lead-pipes-within-a-decade-announces-new-funding-to-deliver-clean- drinking-water/
29 National Primary Drinking Water Regulations (Dec. 12, 2024) https://www.epa.gov/ground-water-and-drinking- water/national-primary-drinking-water-regulations
30U.S. Environmental Protection Agency. (2002, August 15). Permeation and leaching. https://www.epa.gov/sites/default/files/2015-09/documents/permeationandleaching.pdf
31 French Ministry of Social Affairs and Health. (2012, October 18). Instruction DGS/EA4 no. 2012-366.
32 Safe Water Engineering comment letter to EPA Administrator Michael Regan, 21 October 2024. Docket ID No. EPA-HQ-OPPT-2023-0601-0145, Proposed High-Priority Substance Designations under the Toxic Substances Control Act (TSCA).
33 U.S. Plastics Pact’s problematic and Unnecessary Materials List - The U.S. Plastics Pact. The U.S. Plastics Pact - (2024). https://usplasticspact.org/problematic-materials/
34 McGrath, Teresa, Rebecca Stamm and Veena Singla (2024, December 10). Buildings’ hidden plastic problem: Policy Brief and recommendations - Habitable. https://habitablefuture.org/resources/constructions-hidden-plastic- problem-policy-brief-and-recommendations/