CSHEMA - Campus Safety, Health, and Environmental Management Association

CSHEMA Comments on the EPA TSCA Rules

October 29, 2025—The Campus Safety, Health, and Environmental Management Association (CSHEMA) has submitted formal comments to the Environmental Protection Agency (EPA) on its 2024 Final Risk Management Rule for Carbon Tetrachloride (CTC) under the Toxic Substances Control Act (TSCA). In keeping with CSHEMA's support for robust, science-based safety standards in higher education, CSHEMA's letter calls for the EPA to harmonize laboratory chemical regulations with the existing OSHA Laboratory Standard, and to consider the unique operational realities of academic laboratories.

CSHEMA's Track Record of Advocacy

This submission is the latest in a series of comments to the EPA advocating for practical, evidence-based regulations affecting laboratories in higher education. Specifically, this year CSHEMA has provided detailed comment letters regarding EPA regulations on:

• Methylene Chloride (DCM): Documenting laboratory exposure data and supporting the continued reliance on the Laboratory Standard for managing volatile solvents. View comments
• Perchloroethylene (PCE): Highlighting the cumulative burden of overlapping regulatory requirements and the effectiveness of established campus protocols. View comments

About CSHEMA

CSHEMA is the national leader in safety and environmental management in higher education. Representing over 400 member institutions, it provides leadership and resources to improve environmental health and safety in colleges and universities.