On August 6, 2026, the Environmental Protection Agency (EPA) released draft Toxic Substances Control Act (TSCA) risk evaluations for o-dichlorobenzene (oDCB) and p-dichlorobenzene (pDCB). Both chemicals are used in products that can release vapors, such as certain cleaning products, industrial applications, air fresheners, and deodorizers. While these are preliminary findings that do not require immediate changes to labeling or safety requirements, they signal the potential for future regulatory action. Businesses should monitor the risk evaluation process for these two chemicals and be prepared for potential future restrictions or controls on labeling or employee exposure.
Submitting Public Comments
The EPA will accept comments on these draft risk evaluations for 60 days at regulations.gov for oDCB via EPA-HQ-OPPT-2018-0444 and pDCB via EPA-HQ-OPPT-2018-0446. The 60-day comment period will end on October 9, 2026.
During the comment period, the EPA is looking for input on its draft exposure assessments, draft hazard assessments, and draft risk evaluations, with particular interest in its assessment of human exposures, exposure controls and the use of mitigating personal protective equipment, and risk determinations.
TSCA Risk Evaluations
The purpose of risk evaluations under TSCA is to determine whether a chemical substance poses an unreasonable risk of injury to human health or the environment under “conditions of use." The EPA will consider public comments on a draft evaluation before making a final risk evaluation. If the EPA determines in its final risk evaluation that a chemical presents an unreasonable risk to health or the environment, the chemical will move to risk management action under TSCA Section 6(a) for the relevant conditions of use. Final risk evaluations will determine whether new restrictions or controls are required under TSCA. There will be a separate opportunity for public comment on any proposed risk management actions.
Key Findings in the EPA’s Draft Risk Evaluations
Both oDCB and pDCB are found in household and commercial products and can evaporate into the air.
Industrial and commercial uses for oDCB include use as a solvent in dyes and pigments, in lubricant and degreaser products, and in inks and paint strippers. Consumer uses for oDCB include lubricant and degreaser products, air care products, and ceramics glazing and cleaning products.
Industrial and commercial uses of pDCB include use in solvents, air care products, and manufacture of thermoplastics. Consumer uses include air care products, lubricants and greases, and building and construction products.
For oDCB, the EPA’s draft evaluation preliminarily found:
- oDCB contributes to unreasonable risk to workers from 14 conditions of use (inhalation in all, dermal in seven), and to consumers from one condition of use through inhalation.
- Non-cancer hazards, including developmental, liver, and respiratory toxicity.
For pDCB, the EPA’s draft evaluation preliminarily found:
- pDCB contributes to unreasonable risk to workers from seven conditions of use through inhalation and dermal exposure, and to consumers from one condition of use via inhalation.
- Non-cancer hazards, including developmental, liver, and respiratory toxicity.
- pDCB is not likely to be carcinogenic to humans. The EPA recognized that the International Agency for Research on Cancer, commonly known as “IARC,” and the National Toxicology Program have classified pDCB differently and invited comment on this evaluation.
The EPA’s draft evaluation found no unreasonable risk for the general population via ambient outdoor air or to the environment.
Significance and Next Steps
These draft risk evaluations contain preliminary findings that do not require immediate action. However, potential future restrictions or controls may include use restrictions, labeling changes, product redesign, or limiting worker exposure through personal protective equipment and engineering controls. Businesses that manufacture, supply, or use oDCB or pDCB should determine whether their workers may be exposed through handling, mixing, or using products containing these chemicals and consider ways to reduce inhalation risk and dermal exposure.
If you have any questions, or would like additional information, please contact one of the attorneys on our Environmental, Land Use & Natural Resources team.
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