As the U.S. Environmental Protection Agency (EPA) intensifies its scrutiny under the Toxic Substances Control Act (TSCA), laboratories handling chemicals face increased pressure to reduce harmful emissions and better protect worker health. The TSCA, originally enacted in 1976 and amended by the Frank R. Lautenberg Chemical Safety for the 21st Century Act in 2016, empowers the EPA to prioritize, evaluate, and manage risks associated with chemical substances. Recent updates have heightened the regulatory spotlight on chemical exposure pathways—particularly inhalation and dermal contact—requiring labs to move beyond compliance checkboxes and toward a more preventive approach.
This article explores what lab leaders need to know about TSCA’s evolving impact and provides practical strategies to assess and reduce emissions exposure risks in research and analytical settings. With a strong focus on engineering controls and effective facility design, the guidance below draws from expert insights and industry best practices to help labs align with regulatory expectations while fostering safer environments for staff.
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TSCA’s renewed focus: What lab managers need to know
Under the updated TSCA framework, the EPA applies a risk-based approach to chemical evaluation. This includes a structured review process that prioritizes chemicals for risk assessment, evaluates potential hazards and exposure routes, and determines whether a chemical poses an unreasonable risk under its conditions of use.
For laboratories—especially those engaged in chemical synthesis, analytical testing, or materials development—this means that chemicals commonly used in research may come under closer scrutiny. Substances once deemed routine could now be flagged for their volatile organic compound (VOC) content, toxicity, or potential for off-gassing.
“Employees working with chemicals identified by the EPA as posing unreasonable risks to human health and the environment should be aware of forthcoming regulations,” says Patrick J. Mulrooney, CIH, CSP, CHMM, a sub-task lead on the American Industrial Hygiene Association’s (AIHA) TSCA Task Force. “Once these regulations are enacted, the EPA will have enforcement responsibilities, seeking to restrict or eliminate workplace exposure to these substances from all sources. Notably, EPA fines tend to be significantly higher than those imposed by OSHA.”
As Paul DeLeo, also a member of the AIHA TSCA Task Force, notes, the EPA’s regulations are similar to OSHA’s regulations but are not identical. Laboratories should be aware that they will be required to comply with both sets of regulations.
Recognizing emission sources in lab environments
Labs are unique in their emissions profiles, often generating both point-source emissions—from known outlets like fume hoods—and fugitive emissions, which escape from less obvious sources.
Common sources include both types:
- Volatile solvents stored in open containers or handled on benchtops (fugitive)
- Chemical reactions that release vapors when heated or pressurized (can be point-source or fugitive, depending on containment)
- Inadequate storage systems that allow off-gassing from chemical cabinets (fugitive)
- Poorly maintained equipment (e.g., aging fume hoods, ductwork leaks) (can contribute to both)
- Manual transfer of chemicals between vessels without proper containment (fugitive)
Evaluating risks: Monitoring and exposure pathways
Understanding a lab’s emissions footprint begins with a thorough assessment. Air sampling, real-time gas detection, and qualitative walkthroughs can help identify where emissions occur and how they travel through the facility.
Inhalation remains the most significant route of exposure for most lab settings, though dermal contact is often underestimated. For example, vapors can condense on surfaces and be transferred through touch. That’s why assessment needs to go beyond the air and consider how chemicals behave in the environment.
Recommended assessment methods include:
- Air sampling (active and passive): To identify specific VOCs and quantify concentrations
- Ventilation flow measurements: To verify that fume hoods and exhaust systems are operating within specification
- Smoke testing or tracer gas: To visualize airflow patterns and spot inefficiencies
- Surface wipe sampling: To detect residual contamination from fugitive emissions
Collecting baseline data helps lab managers prioritize interventions and track improvements over time. It also strengthens documentation should the lab face regulatory inspection or third-party audits.
Engineering controls and facility design
While eliminating emissions at the source is the most effective way to protect lab personnel, it is not always possible. When this is the case, the focus should be on engineering controls—strategies baked into the infrastructure of the lab.
“The implementation of controls should follow the hierarchy of controls, which seeks to manage exposures by eliminating the hazard, substituting the hazard, applying engineering controls, instituting administrative controls, and finally, using personal protective equipment, in that order,” explains Mulrooney.
Examples of engineering controls include:
- High-efficiency fume hoods with airflow monitoring and auto-sash closures
- Local exhaust ventilation (LEV) systems for benchtop operations or high-use areas
- Containment enclosures or gloveboxes for working with particularly hazardous or volatile substances
- Ducted storage cabinets for flammable or corrosive materials
- HVAC systems with dedicated supply and exhaust zones to maintain directional airflow and prevent recirculation of contaminants
Older facilities may require retrofits to meet current performance expectations. While this can be a significant investment, the long-term benefits to safety, compliance, and staff retention often outweigh the costs.
Maintaining control effectiveness
Even the best engineering controls can lose effectiveness over time without regular upkeep. Labs should implement routine inspection and testing protocols to ensure continued performance.
Best practices for ongoing verification include:
- Scheduled certification of fume hoods and LEV systems (typically annually)
- Routine HVAC inspections and filter replacements
- Use of continuous monitoring systems with alarms for VOCs or low airflow
- Training for lab staff on proper equipment use and prompt reporting of failures
A proactive path forward
As the EPA continues to evaluate chemicals under TSCA, lab leaders must stay informed and adapt. “The current administration is reconsidering many aspects of how TSCA was implemented by the previous administration. Consequently, effective dates of these regulations continue to be extended, so impacted organizations should keep track of the latest developments,” says Mulrooney.
Aligning operations with modern expectations means adopting a more proactive, holistic view of emissions management—one that spans facility design, chemical use practices, and ongoing performance verification.
Laboratories that invest in emissions risk reduction not only meet regulatory demands—they build environments that support innovation, staff well-being, and long-term success.