Monitoring Trichloroethylene (TCE) Under the EPA ECEL Requirement: A Clear Path to TSCA Compliance

The U.S. Environmental Protection Agency (EPA) has rolled out a critical new Toxic Substances Control Act (TSCA) compliance requirement for facilities that use Trichloroethylene (TCE). This update is a game-changer, demanding technical precision and meticulous record-keeping from EHS professionals and Certified Industrial Hygienists (CIHs).

The regulation mandates 8-hour personal breathing zone (PBZ) monitoring to ensure airborne TCE exposures stay below the strict Exposure Concentration Equivalent Limit (ECEL) of 0.2 ppm, with an action level set at 0.1 ppm.

Understanding the ECEL Framework for TCE

The ECEL is a risk-based exposure limit introduced by the EPA under TSCA for high-priority substances like TCE. Unlike Occupational Safety and Health Administration (OSHA) Permissible Exposure Limits (PELs) or American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs), the ECEL is derived directly from TSCA risk evaluations and incorporates a more stringent margin of safety.

With the TCE ECEL at 0.2 ppm and the action level at 0.1 ppm (8-hour Time-Weighted Average or TWA), your compliance efforts must prioritize highly sensitive and accurate sampling techniques.

Sampling Methodology: The Need for Validated Diffusive Badges

To meet this new rule, the EPA requires the use of validated sampling devices specifically suited for full-shift PBZ monitoring. These samplers must be able to reliably quantify TCE concentrations within the critical range of 0.10–0.20 ppm.

Facilities must confirm that their chosen sampling device has a consistent uptake rate and has been properly validated. Key specifications include:

• Target Accuracy: Must achieve ±25% accuracy at 95% confidence relative to the exposure limit.
• Duration: Requires 8-hour TWA sampling, focusing only on the ambient PBZ—no respirator credit is allowed.
• Detection Requirements: The method must have a clearly defined Limit of Detection (LOD) and Limit of Quantification (LOQ) that are suitable for these low-level TCE exposures.

Essential Analytical and Reporting Requirements

Meeting EPA reporting expectations demands that your results be processed using a laboratory method recognized by AIHA or an equivalent accreditation for industrial hygiene analyses.

Final reports must include specific, detailed information:

• 8-hour TWA results reported in both ppm and mg/m3.
• Method uncertainty and statistical confidence.
• A clear statement of the LOQ.
• Results of Field and laboratory blank corrections.
• Detailed information on the sampler model, batch/lot number, uptake rate, and desorption efficiency (if applicable).
• Complete chain-of-custody documentation.

Expert Support for Your Compliance Efforts: Eurofins Built Environment Testing

Eurofins Built Environment Testing in Richmond, VA is an AIHA LAP, LLC accredited laboratory—with continuous accreditation since 1977—specializing in industrial hygiene analytical services. We are fully equipped to support your TCE monitoring program and help you align with the EPA’s TSCA ECEL requirements.

Our capabilities are designed to ensure your program is compliant and effective:

• Validated diffusive badge samplers that are suitable for 8-hour PBZ monitoring.
• Low-level TCE detection capabilities with method LOQs well below 0.1 ppm.
• Accurate 8-hour TWA reporting in ppm and mg/m3.
• Complete documentation, including chain-of-custody, uncertainty, and lab blanks.

Our team, which includes several CIHs with both laboratory and field experience, works directly with EHS managers and CIHs to ensure your sampling strategies are effective, your data is reliable, and your regulatory submissions meet EPA expectations.

Whether you need assistance with designing a robust monitoring program or simply need reliable analysis of your collected samples, Eurofins Built Environment Testing is ready to assist.

Final Thoughts

The new ECEL requirement for TCE underscores the EPA’s commitment to more protective exposure limits under TSCA. For EHS professionals and CIHs in TSCA-regulated environments, this means: implementing high-accuracy PBZ sampling programs, verifying laboratory capabilities, and maintaining robust documentation.

Have you updated your TCE monitoring program to meet the new EPA ECEL requirements?

Contact Eurofins Built Environment Testing today to discuss how we can support your compliance strategy with reliable sampling and analysis solutions.