Emerging contaminants are chemicals in the environment that have been recently identified as posing a potential risk to the environment or public health. These contaminants may arise from everyday products or their use in various industries. As these contaminants are detected in the environment with increased frequency and concentration, they become subject to greater scrutiny as they are typically not adequately regulated under current environmental laws and regulations. The EPA has an ever-rotating list of emerging contaminants that they are tracking, including carbon tetrachloride.
What is Carbon Tetrachloride?
Carbon tetrachloride is a colorless liquid with an ether-like odor that is used in a commercial/industrial setting as a raw material for producing other chemicals like refrigerants, chlorinated compounds, and agricultural products and was originally synthesized in 1820. Household or everyday products such as dry-cleaning agents, fire extinguishers, and aerosols/cleaners typically contain carbon tetrachloride. Industries such as chemical manufacturing, plastic/resin manufacturing, and agricultural chemical manufacturing use carbon tetrachloride in their processes.
What are the Concerns?
The toxicity of carbon tetrachloride was originally recognized in the early 1900s, and it was banned by the Consumer Product Safety Commission in 1970. In 1986, the EPA canceled carbon tetrachloride’s use as a fumigant. Carbon tetrachloride is still used in limited industrial settings. An overhaul in 2016 of the Toxic Substances Control Act put carbon tetrachloride in the spotlight when it was chosen as one of the first ten chemicals for EPA risk evaluation. Carbon tetrachloride is a suspected carcinogen known to impact the central nervous system, liver, and kidneys and has also been identified as an ozone-depleting substance. Regarding the environment, concentrations of carbon tetrachloride have been identified in soil, groundwater, and vapor.
In December 2022, US EPA finalized a revision to the Toxic Substances Control Act (TSCA) risk determination for carbon tetrachloride, which means this emerging contaminant is closer to having a rule to regulate the chemical to protect human health and the environment. Once the US EPA generates standards, it is up to the individual state environmental agencies on whether they will follow the US EPA guidelines or opt for more stringent regulations.
What Does This Mean?
Increased regulatory scrutiny often equates to increased sampling efforts, which may be triggered by redevelopment that will be completed at a site or additional sampling as a result of ongoing regulatory oversight, among other scenarios. It is important to consider the history of the site as well as operational exposures to determine if the site may be impacted by emerging trends. What was once an acceptable concentration in soil, groundwater, and/or vapor may no longer be once more stringent guidelines are in place. The onus will then fall on the owner and/or operators at sites to remediate to acceptable levels.
Environmental insurance may be able to lessen or mitigate the risk associated with carbon tetrachloride exposure through the redevelopment of a site, the reopening of a previously closed regulatory case, or an ongoing industrial operation.
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About the Author: Samantha Linton is a Vice President with the Environmental and Construction Professional Division at Distinguished Programs. Ms. Linton has over 11 years of experience in underwriting of environmental and construction insureds.