Defense of MOCA during TSCA Review

The TSCA review process has an estimated duration of an additional 5 years, finishing in Q2, 2030. Following extensive monitoring, review and involvement, the PMA Leadership has identified a path forward to defend MOCA. This strategy has an estimated cost of approximately $2 million. 

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)

Prioritization
1 year process in which EPA determines if a chemical is a High Priority or Low Priority Substance (offramp to review).
  • MOCA started Initiation of Prioritization on 12/18/23.
  • PMA utilized the rifle shot and load the record approach.
    • The rifle shot presented the case that MOCA did not belong in the TSCA review process and should be a Low Priority Substance.
      • PMA met with EPA to review the rifle shot.
    • The load the record approach consisted of submitting 3000 pages of documents to EPA to build the case for future litigation if desired.
  • Prioritization ended on 12/18/24 with MOCA being listed as a High Priority Substance.
Risk Evaluation
3 - 3.5 year process in which EPA determines whether the condition(s) of use (1st Trump Admin) or “whole chemical” (Biden Admin) poses an unreasonable risk to the human health or the environment.
  • Risk Evaluation started on 12/18/24.
    • EPA published preliminary payee list on 12/31/24.
    • Public comment was held through 3/3/25.
    • Final list will be published no later than concurrent with publication of the final risk evaluation scope document.
  • The entire review process for MOCA through Risk Management is expected to be complete in 2030.
    • One goal would be to try to complete Risk Management before the 2nd Trump Administration ends.
Risk Management
2 year process in which EPA will ultimately regulate the chemical until it no longer poses an unreasonable risk.
  • EPA is given a range of risk management options under TSCA, including labeling, recordkeeping or notice requirements, actions to reduce human exposure or environmental release, and a ban of the chemical or of certain uses. 

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.

 

 

Special Thanks to Contributing Companies

More than $200,000 of the $2M goal has been pledged to date through the generosity and dedication of these companies: 

  • Acrotech, Inc

  • Anderson Development Company

  • Chemi-Flex, LLC

  • Chemline, Inc

  • COIM, Inc

  • Dicar, Inc

  • Dynasauer Corp

  • Elastomer Engineering, Inc

  • Ephrata Precision Parts, Inc

  • Era Polymers Corporation, LLC

  • Esco Plastics Co

  • Everchem Specialty Chemicals

  • Gallagher Corporation

  • Green Rubber-Kennedy Ag

  • Jewell Hudgens, Inc

  • Kastalon, Inc

  • Kumiai Chemical Industry Co, Ltd

  • Meridian Laboratory, Inc

  • Molded Dimensions, LLC

  • MPE Global

  • Omni Technologies, Inc

  • Polymer Components

  • Polyurethane Products Corporation

  • Prothane, Inc

  • Provient

  • PSI Urethanes, Inc

  • Q-Cast, Inc

  • Royalthane, Inc

  • StateMix, Ltd

  • Suncast Polytech, Inc

  • Superior Tire & Rubber Corporation

  • Thombert, Inc

  • Universal Urethane Products, Inc

  • Urethane Innovators, Inc

  • Velsicol Chemical, LLC

     
Want to appear on this prestigious list? Click here to contribute funds towards MOCA defense.