Defense of MOCA during TSCA Review

How to Get Involved

1. Click here to contribute funds towards MOCA defense.
2. Provide PMA access to your Toxicologist. (Click here to email contact info.)
3. Send a letter to your legislators in support of this strategy.
1. Click here to download the template letter. (coming soon)
2. Click here to locate your legislators.
4. Volunteer to be involved with the Government Affairs Committee.
5. Spread the word! Share this information with any members, non-members, suppliers and anyone else that is willing to support the defense of MOCA.

Next Steps

• Obtain funds to support MOCA defense.
• Find 2 experienced EHS personnel (e.g., air, waste, water experience) and 2-3 R&D heads with TSCA PMN experience.
• Find a toxicologist either within PMA or externally with prior TSCA Existing Chemical Review experience.

TSCA Existing Chemical Review Overview
(information shared at the 2025 PMA Annual Meeting)

What Does Success Look Like For MOCA

• At the end of Risk Management, PMA MOCA Safe Handling Guidelines is written into the requirements.
• No bans or restrictions beyond PMA MOCA Safe Handling Guidelines.

Four defense options considered

• Option 1: Do Nothing
• Provide no further support for the defense of MOCA.
• Challenging messaging to membership as the defense of MOCA has been foundational since the beginning of PMA.
• This will likely lead to a more unfavorable outcome.
• Could include exposure limits lower than the limits of detection of modern testing methods.
• Possible strict regulations that make it impractical to use MOCA such as in Kentucky.
• Worst case could be a ban on MOCA use in the US.
• Option 2: Comprehensive Defense
• This would be a full defense of MOCA relying significantly on legal and external services.
• This will likely lead to a more favorable outcome.
• This is relatively costly.

•  Option 3: Lower Cost Defense
• This option would rely more on PMA members providing support and less on legal and external assistance.
• We would need to recruit additional people with specialized skills to perform work (including reviewing information from EPA and other sources, interpreting data, generating reports, outreach to members, outreach to regulatory agencies, etc.).
• This would likely lead to a more favorable outcome.
• The cost is more economical.
• Legal time would be limited to 6 hours/month (at rate of $350/hour).
• Minimum required work includes:
• Meetings (preventing anti-trust issues, providing feedback, and keeping up on progress)
• Reviewing completed work products (e.g., reports, communications to membership, information before it is submitted to regulatory agency)
• Interacting with members when antitrust issues could pose a concern (e.g., detailed conversations on TSCA Fees Rule that involve CBI).
• Additional work beyond the budget would not be done without prior approval by a PMA group (e.g., EHS Committee, Executive Committee, BOD, etc.).
• Others would perform tasks that have been traditionally been performed by legal (e.g., regulatory reviews, communications with membership and outside groups, generating primary documents, submitting information to EPA, etc.).
• Work to defend MOCA will be performed by members of the GA/EHS/Advocacy MOCA group (or delegated to other members within PMA).
• We need to recruit more people to replace people (e.g., Steve Seneker) and find specialized resources
• 2-3 R&D Heads (with knowledge of chemistry, applications, and TSCA PMN experience).
• 2 EHS generalists (with knowledge of air, waste, water, reporting, etc.).
• 1 Toxicologist with a lot of time to help (or multiple toxicologists or industrial hygienists with strong toxicology background).
• Need staffing to adequately respond to issues (e.g., EPA MOCA publications in Risk Evaluation and Risk Management, meetings/requests with EPA, TSCA rules changes, etc.).
• In Risk Evaluation we need to address the Hazards associated with MOCA and the Exposure (potential) of MOCA.
• Work related to hazards (and some exposure) will need a toxicologist to predict where EPA will land (e.g., urinalysis limits, airborne exposure limits, worker dermal exposure modeling to pure MOCA, cancer end point) and review toxicological information from EPA (e.g., draft/final Risk Evaluation, draft/final Risk Management).

• Other exposure work could be done by other members of the group (e.g., promote PMA Safe Use including urinalysis, correct the record for air emissions, modeling dermal exposure of finished goods, TCLP, etc.).

• Option 4: Midrange Cost Defense
• This option would rely more on PMA members providing support and less on legal and external assistance.
• The budget reflects the cost of the lower cost defense (Option 3) plus PMA hiring a toxicologist.
• This would likely lead to a more favorable outcome.