Earthjustice and Material Research Reveal Life Cycle Impacts of 20 Toxic Chemicals

Late one afternoon last November, attorneys for Earthjustice submitted twenty (20) technical reports to the official dockets of the U.S. Environmental Protection Agency. EPA was collecting information about these chemicals’ “conditions of use” as a part of its Toxics Substances Control Act (TSCA) review process.

According to Earthjustice, “EPA has been ignoring a wide range of chemical exposures” in its TSCA risk evaluations. Earthjustice, the premier, public interest environmental law organization, hired Material Research and our team of environmental data analysts, to prepare these technical reports and identify essential “upstream and downstream” places the EPA should look in determining public health risks. 

The 20 reports identify the companies responsible for making these chemicals and at what volume, the chemicals’ distributions into commerce, and dispersal into neighboring communities and our air, water, land, and waste. We overcame EPA’s tendency to cloak company data under the label of “confidential business information.” Much of the data EPA accepts as proprietary is actually public in other forms; indeed, much of our research and insights came from publicly available government data.

We were able to assemble and crunch massive amounts of information in a relatively short time, thanks to Larry Kilroy, a technical strategist for Material Research who developed code that stitches together critical EPA data on toxic pollution. U.S. Customs records of chemical imports also informed our analysis. 

“Material Research provided comprehensive information including from sources that are not generally available, and presented it in an accessible, user-friendly format,” said Eve Gartner, Healthy Communities Attorney for Earthjustice. “This information will prove invaluable in demanding EPA consider the full range of uses and exposure pathways in its risk calculations.” 

The TSCA technical reports that are now part of the public record totaled 336 pages of text and 817 citations. Our amazing team on this project included Amy Callner, Larry Kilroy, Connie Murtagh, Verónica Odriozola, Caroline Pryor, Alex Schultz, and Jill Weber.

Sharon Lerner, the award-winning environmental justice journalist, used our research to inform her article, “The War On The War On Cancer.” This extensive report, published this week in The Intercept, reveals how EPA is “gutting regulations” for polluters, and profiles people who are suffering the health consequences. “Changes made under the Trump administration,” she writes, “promise to weaken protections for Americans’ health, many of which were intended specifically to stave off cancers…. Having the Trump administration at the helm during a once-in-a-generation reassessment of toxic pollutants is especially disastrous for the effort to protect Americans from cancer.”

The following drop-down list summarizes essential facts about the 20 subjects of Earthjustice’s submissions, sequenced in five groups: brominated chemicals; chlorinated chemicals; phthalates; organophosphorus flame retardants; and, others. Links in the chemical name lead to the federal docket that contains the full, corresponding technical report and comment from Earthjustice.

TBBPA is the most produced chemical by volume in the brominated flame-retardant class. TBBPA production is rapidly declining: only one manufacturer continues to make it in the U.S. - Albemarle’s plant with capacity to produce 50,000-metric-tons per year, in Magnolia, Arkansas. U.S. companies also import TBBPA from Israel, Jordan, and China. Imports fell 70% between 2009 and 2018. Most TBBPA enters commerce in laminate (comprising flame-resistant epoxy resins) of electronic circuit boards. It’s also used in electronic enclosures that are composed of polycarbonate and acrylonitrile-butadiene-styrene (ABS) resins.


Much of the electronics industry has committed to end the use of BFRs, including TBBPA, in plastics. Legacy TBBPA is re-distributed through plastics and e-waste recycling. It has been identified in products such as children’s musical toys, kitchen utensils, and Mardi Gras beads.

In popular thought, certain toxic chemicals are no longer for sale, like asbestos and mercury. In reality, these well-known toxic substances remain in commerce. For example, some engines (mainly in aviation and racing cars) still run on leaded gas. Ethylene dibromide is used as an anti-knock agent in leaded gasoline. Petrochemical companies continue to import EDB for this purpose. The full extent is not known because EPA has withheld manufacturing and imports data for this chemical since 2006. Shipping records indicate a robust trade: U.S. companies imported over 3.7 million pounds of EDB between January 2012 and September 2019. The main importers are Ethyl Corp., Innospec, and Lanxess. Ethyl and Innospec sell tetraethyl lead gasoline additives. Lanxess sells EDB for use as a scavenger for lead in gasoline, and as a general solvent and fumigant. ExxonMobil’s petrochemicals complex in Baton Rouge, Louisiana, was the second leading source of airborne releases of EDB (6,041 pounds) between 2012 and 2018. This refinery makes aviation fuels that it distributes throughout the Western Hemisphere. Ethylene dibromide is converted to lead bromide during combustion, volatilizes, and is released as solid lead bromide in the particulate matter from cooled exhaust. Concentrations of lead bromide particulate emitted from airplane exhaust are highest near airports (especially small ones that service general aviation), but planes with piston engines spread lead far and wide throughout their flights.

One of the only intentional uses of 1,1-DCA is in producing methyl chloroform. Methyl chloroform contributes to the depletion of Earth’s protective ozone layer in Earth’s stratosphere. is a potent ozone depleting substance and was phased out of use as a solvent in 1996 Under the Montreal Protocol on Substances that Deplete the Ozone Layer, it was phased out from use as a solvent. However, the parties to this global agreement opened a loophole which allows manufacturing to continue if the methyl chloroform is used as a process chemical. At least one company – Westlake -- continues to make and sell methyl chloroform for use in the “production of fluorinated chemical compounds, including refrigerants and polymers.” Degradation of 1,1-DCA in the air creates additional ozone-depleting substances. Two chemical plants in Louisiana reported 78% of air releases of 1,1-DCA from 2012 to 2018. Both plants – Westlake in Lake Charles and Olin in Plaquemine – produce methyl chloroform.

1,2-dichloropropane is a degradation product from a chlorinated flame retardant, tris (1-chloro-2-propyl) phosphate (TCPP), that is widely used in spray polyurethane foam (SPF) insulation for buildings. 1,2-dichloropropane also is a by-product of the reaction of propene and chlorine in epichlorohydrin manufacturing. Epichlorohydrin is mostly used to make epoxy resins. Olin Corporation’s epoxy chemical plant in Freeport, Texas, generates over 2 million pounds of 1,2-dichloropropane waste per year. Our examination of public data identified another major source of 1,2-dichloropropane pollution: The Solenis paper sizing plant in Courtland, Virginia, accounted for 70% of all air emissions of 1,2-dichloropropane between 2012 and 2018. Paper sizing agents are applied to paper for water resistance and printability.

Vinylidene chloride (VDC) manufacturing is the main industry that consumes 1,1,2-TCE; the only plant in the U.S. that makes VDC is Olin’s in Freeport, Texas. Manufacturers of chlorine, EDC, and vinyl chloride monomer (VCM) create over 100 million pounds of 1,1,2-TCE per year, mostly as waste byproduct of these processes. Federal regulations require companies to report the manufacturing (intentional or otherwise) of a chemical if a plant makes over 25,000 pounds per year. This is called the Chemical Data Report (CDR). Several plants generate far more than 25,000 pounds per year but have not filed CDRs for this chemical. Chemical plants have polluted groundwater with 1,1,2-TCE around the world, from Vila-Seca, Spain to Delaware City, Delaware. 1,1,2-TCE also is used as a solvent, including in some adhesives sold in retail stores.

Sabic’s plant in Mount Vernon, Indiana, produces a chemical called ODPA by processing o-DCB. This facility, owned by the government of Saudi Arabia, was responsible for 80% of the country’s reported air emissions of o-DCB. Sabic also reported releasing 67% of the country’s o-DCB wastewater into the Ohio River (right).  EPA’s information about o-DCB does not yet mention it role in the production of ODPA or epoxies. 

The second leading source o-DCB releases, Covestro, in Baytown, Texas, processes o-DCB in the manufacturing of isocyanates. The EPA’s TSCA review of this chemical does not mention isocyanates. o-DCB also is processed in the production of some rubber products, pigments, and pesticides.

All p-dichlorobenzene (also called p-DCB or 1,4-DCB) that is distributed in the United States is imported, not domestically manufactured. Ultimately, this chemical is released into the air and water.   “Most of the 1,4-DCB enters the environment when it is used in mothballs and in toilet-deodorizer blocks,” according to the Agency for Toxic Substances and Disease Control. It is a carcinogen and is very toxic to aquatic life.

Ten states ban its use in cleaning products such as urinal blocks; however, state governments are unable to restrict its use in mothballs. The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) prevents states from regulating pesticides. Mothballs are regulated as pesticides. EPA has not restricted this use under FIFRA, so p-DCB mothballs and toilet blocks remain commonplace. The indoor air of most homes contains p-DCB and most people have p-DCB in our bodies. In 2012, U. Michigan scientists found that p-DCB was chronically present in urban homes’ indoor air. They concluded, “The high p-DCB levels found suggest the need for policies and actions to lower exposures, e.g., sales or use restrictions, improved labeling, and consumer education.”

EDC is mainly processed to make polyvinyl chloride (PVC) plastic. EDC is one of the highest volume chemicals in the U.S., especially on the Gulf Coast, where four of the eight largest PVC plants in the world are located. EDC manufacturing generates a suite of other toxic chemicals which are dispersed into the air, groundwater, and nearby rivers and estuaries. People suffer cumulative impacts from chronic inhalation and ingestion of organochlorine pollutants. 


Westlake Chemical owns three of the top four sources of EDC air pollution in the United States. These are in Calvert City, Ky., and Geismar and Westlake (Lake Charles), La. 


The chemical industry creates over 2.5 million pounds of toxic EDC waste per year, most of which is burned in incinerators and cement kilns. EPA has not considered the potential release of toxic byproducts, such as dioxins, from burning chlorinated toxic waste in its TSCA assessments. Three factories – Occidental in La Porte, Texas, and Formosa Plastics in Baton Rouge, La., and Point Comfort, Tex. – were responsible for over half of the country’s shipments of EDC waste to other communities.

Trans-1,2-dichloroethylene is an unintended byproduct of chlorinated chemical production, especially vinylidene chloride (VDC). Olin, co-located with Dow’s massive chemical complex in Freeport, Texas, is the only VDC manufacturer in the U.S. and a leading source of trans-1,2-dichloroethylene waste transfers.

This chemical is used as a refrigerant in industrial chillers, as a reactive ingredient of polyurethane spray foam insulation, and as a solvent for cleaning or degreasing. The leading source of trans-1,2-dichloroethylene waste – Versum Materials in Carlsbad, California – supplies the chemical to the superconductors industry.  Recently, scientists determined that trans-1,2-dichloroethylene has a “small but measurable” potential to deplete Earth’s protective ozone layer. However, Versum describes its product as “ozone-safe.”

DCHP is a relatively low-volume phthalate (less than 0.1% of all phthalates produced or imported in the U.S.). The only two plants in the U.S. that produce DCHP are in Greensboro, North Carolina. They are owned by Lanxess and Vertellus Performance Materials. Lanxess sells DCHP for use in substances that come into contact with food, including food wrappers (mainly cellophane) and labels. Vertellus sells this chemical for use in food contact products as well as latex gloves and marine coatings. DCHP has been found in numerous foods, including vegetable oil, meat pies, and confectionaries. The U.S. Food and Drug Administration allows the unlimited use of DCHP as an adhesive in food grade packaging. In contrast to the FDA’s approach, the Consumer Products Safety Commission (CPSC) prohibits its use in children’s toys at levels over 0.1%. EPA does not track the release of DCHP from manufacturing, processing, and disposal operations.

Demand for this plasticizer is dwindling. In 2011, U.S. companies imported or manufactured less than 500,000 pounds of DiBP, down from 28 million pounds in 2004. One factory, perhaps, is still producing it (Lanxess in Greensboro, N.C.). The primary uses have been in the manufacture of foundry sands for metal casting and as a solvent and plasticizer in plastics, rubber and many other products.  As with DCHP and the other phthalates in this series, the CPSC prohibits the use of more than 0.1% of this chemical in children’s toys and child care articles.


While manufacturing and intentional processing of DiBP is coming to a close, the chemical will be redistributed into commerce through plastics recycling operations. EPA does not track DiBP pollution (on-site releases or off-site waste transfers). DiBP is not to be confused with the much more common but similarly named phthalate, di-n-butyl or di-butyl phthalate (DBP, CAS No. 84-74-2).

As with DiBP, DBP manufacturing is in rapid decline, in the U.S. Unlike DiBP, demand for DBP appears to remain strong. Companies import over 7 million pounds per year. A leading use of this chemical is as a propellant for ammunition. The leading source of reported DBP air releases in the U.S. is an Army ammunition plant in Iowa. Other high releases of DBP originate from marine-related shops, and are likely caused by the use of DBP in marine faring compounds. Faring compounds are epoxy-based putties that fill and smooth the shape of hulls. Other industries that process and release DBP include manufacturers of maleic anhydride, adhesives, sealants, plastics, coatings, catalysts, and heat pump fluids. The Nordic Ecolabel prohibits the use of DBP in heat pump fluids. DBP is a common contaminant in plastic waste and around recycling plants.

Regulations and marketplace deselection have curtailed the once-wide distribution of BBP in recent years. No company is intentionally manufacturing BBP in the U.S. All BBP that is distributed is imported, and since 2017, there have been no U.S. Customs records of BBP imports arriving by ship. As recently as 2016, BASF, the world’s largest chemical company, reported importing BBP for use in resins, paints and coatings, some of which are in swimming pool decks and playgrounds.

DEHP is the most commonly distributed phthalate. Two companies in the U.S. manufacture this plasticizer: Eastman Chemical (Kingsport, Tennessee) and Teknor Apex (Brownsville, Tennessee), and both release the chemical into the air. U.S. companies also imported over 14 million pounds between 2012 and 2019. The auto industry is the leading industrial source of DEHP air pollution, led by Honda’s plant in Lincoln, Alabama, which released 29% of the country’s DEHP into air between 2014 and 2018. Imported PVC products are more likely to contain DEHP than domestically produced plastics. Products that contain DEHP include rubber coated textiles, hydraulics, plastic films, vinyl flooring, and, perhaps most notably, medical supplies. The use of DEHP in blood bags, catheters, and oxygen masks is most impactful on the most vulnerable people: newborn infants in intensive care. The medical supply industry is an active distributor and user of DEHP products. Manufacturing takes place primarily at Baxter Healthcare plants in Puerto Rico and Mississippi. Baxter Healthcare and ICU Medical Fleet Services are the leading sources of DEHP waste. From 2012 to 2018, these companies transferred over 10 million pounds of DEHP waste to plastics recycling plants in North Carolina, Puerto Rico, Mexico, and the Dominican Republic.

Nearly half of the country’s reported phthalic anhydride air releases occur near Joliet, Illinois, where Stepan Chemical operates a phthalic anhydride plant. The primary use of phthalic anhydride is in the production of phthalates; as demand for those plasticizers declines, so too does phthalic anhydride manufacturing. Two of the five largest plants have closed recently.

There is only one company in the U.S. that produces TPP. ICL-IP Americas LP’s plant in Gallipolis, West Virginia, makes a flame-retardant plasticizer that contains TPP. Other companies import TPP for similar purposes. Lanxess and Akzo Nobel import it from their operations overseas. TPP is added to plastic, foam, rubber, and lubricant products. A State of Washington product testing program found concentrations of over 1% TPP in the foam of children’s chairs sold by Amazon and Target. In 2014, a research team from the University of Antwerp found that plastics recycling has introduced “harmful organic chemicals in children’s toys. TPP was “a major representative” of these contaminants, with levels of up to 1.3% by weight detected in toys.

There’s been a sharp decline in the use of TCEP as a flame retardant. All recent volume appears to have been imported, not domestically manufactured. Few shipments of TCEP have arrived in the U.S. since 2015, as retailers, processors, product specifiers, and governments have implemented policies that dissuade TCEP distribution. Most common uses are in paints, mastics, coatings, pharmaceuticals, and polyurethane foam. It is also found unintentionally in carpet padding that uses recycled furniture foam. 

There are no government databases that track TCEP or TPP discharges into the air or water or transfers of toxic waste containing it.

A variety of synthetic rubbers use 1,3-butadiene, with the majority being used in styrene butadiene rubber. Other common varieties include chloroprene, acrylonitrile-butadiene rubber, and polybutadiene rubber. Some of this rubber winds up inside peoples’ homes, in rubber flooring and carpet as well as in playgrounds, in recycled rubber “mulch.” Synthetic rubber workers have been affected by high rates of leukemia. The industry is characterized by accidents and “upset conditions” that release unpermitted 1,3-butadiene into the air. 

“Nearly 180 million Americans live in the worst-case scenario zones for a chemical disaster, and at least one in three children go to a school near a hazardous chemical facility,” notes Earthjustice. Other major manufacturers, such as Ineos in Alvin, Texas; Firestone in Sulphur, Louisiana; Shell in Norco, Louisiana; American Synthetic Rubber in Louisville, Kentucky, frequently release unapproved emissions of 1,3-butadiene. In Norco, alone, since 2015, Shell reported 32 separate, accidental releases of 1,3-butadiene.

The fragrance industry is notoriously opaque, and EPA is not using its power to provide transparency for the public. In an August 2019 report, EPA asserted that, “due to Confidential Business Information, EPA cannot disclose whether HHCB was manufactured in the United States.” 


Millions of pounds of HHCB shipments enter U.S. commerce each year. EPA does not track its release into air, water, or into the waste stream. This chemical is not regulated by the FDA. The public – consumers, neighbors of manufacturing plants – have little to no information about, or protection from, this widely distributed musk fragrance. 

Scientists from Harvard and Silent Spring Institute recently found HHCB is every air and dust wipe sample taken from ten low-income housing units. Consumers are exposed to it through the use of cleaning products, deodorants, and shampoo. It has also been incorporated into products like jeans for scent-branding. The scent branding industry, like its fragrance suppliers, considers its blends to be trade secrets. When a sports arena opened in Brooklyn, reporters and fans remarked about the “weird, musky, cologne-y” smell during Nets basketball games. The source: cartridges that discharged scents into the arena’s HVAC system.

Last, and certainly not least, is formaldehyde, one of the ten most commonly produced chemicals in the United States It is found in a wide range of building materials including laminated floors, adhesives, countertops, and insulation. Formaldehyde is processed in a range of other applications. Monsanto’s pesticides plant in Luling, Louisiana, is the nation’s leading source of formaldehyde releases, by far. It uses formaldehyde in the manufacture of glyphosate pesticides there and in Muscatine, Iowa. Formaldehyde is used in sugar production to prevent bacterial growth. U.S. Sugar, the largest producer of sugar cane, released over 200,000 pounds of formaldehyde into the air around its facilities between 2014 and 2018. 


It also is used in fracking fluids, which brings this petrochemical’s life cycle full circle: Methanol is used to manufacture formaldehyde, and methanol is produced from fluids fracked using formaldehyde. Researchers in 2014 found formaldehyde that “exceeded health-based risk levels” around fracking sites, with measurements 30-240 times greater than background levels.