Defense of MOCA during TSCA Review

The US EPA TSCA review process of MOCA [MBOCA, 4,4'-Methylenebis(2-chloroaniline)] is ongoing and is estimated to be completed in the 2031 – 2032 timeframe. Following extensive review, the PMA Leadership has identified a path forward to defending MOCA. This strategy has an estimated cost of approximately $1 million. The work we do now to support MOCA is vital to a positive outcome to this process.

How to Get Involved

Contact your Legislators
Volunteer on the Government Affairs Committee
Volunteer on the MOCA Taskforce
Volunteer on the EHS Committee
Donate to the MOCA Defense Fund
Advance in PMA's Self-Certification Program
Spread the Word

Next Steps

  • Continue obtaining funds to support MOCA Defense.
  • Fund and conduct the MOCA Dermal Exposure Study.
  • PMA MOCA Taskforce meeting routineley to support MOCA in TSCA Risk Evaluation.
  • Utilizing a toxicology consultant to perform studies to advance the science on MOCA and coordinate communications with the EPA.
  • Engaging directly with the EPA and other agencies to support MOCA.
  • Maintaining engagement with other groups including the American Alliance for Innovations (AAI) 
  • Monitoring legislative, judicial, and executive actions that impact MOCA in the TSCA review process. 

 

MOCA Defense Fund

$292,700
pledged toward our $1,000,000 goal
29.3% Funded
Help PMA defend MOCA during TSCA review.

TSCA Existing Chemical Review Overview

 

The EPA chemical review of MOCA involves three phases: Prioritization, Risk Evaluation, and Risk Management. Details about the three phases and PMA efforts to support MOCA are below.

 

Prioritization
Process in which EPA determines if a chemical is a High Priority Substance or Low Priority Substance (offramp to the rest of the review process).
  • MOCA started the 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 presented this information to EPA in-person. 
    • The "load the record" approach consisted of submitting more than three thousand pages of documents. 
  • Prioritization ended on 12/18/24 with MOCA being listed as a High Priority Substance. 

 

Risk Evaluation
Process in which EPA determines whether the conditions of use of MOCA pose an unreasonable risk to the human health or the environment. MOCA is currently in this phase of the review process.


  • Risk Evaluation started on 12/18/24.
  • Fees
    • EPA published preliminary payee list on 12/31/24 and public comment was held through 3/3/25.
    • A final list of payees will be published no later than concurrent with publication of the final risk evaluation scope document. 
  • Agency Engagement
    • PMA has had multiple meetings with the EPA, including in-person meetings. 
    • Met with the Small Business Association and Department of Defense. 
  • Toxicology/Industrial Hygiene Work
    • PMA hired a PhD Toxicologist consultant to lead our scientific efforts to support MOCA. 
    • This is some of the work performed to-date, or is planned to be accomplished. 
      • Performed a thorough information/data search, review, and gap analysis for MOCA. 
      • Reviewed MOCA urinalysis testing limits. 
      • Supported the TSCA 8(d) submission which included unpublished health, safety, environmental, and exposure studies. 
      • Planning to perform dermal absorption testing and dermal exposure modeling. 
      • Planning to conduct a task-based exposure study. 

 

Risk Management
Process in which EPA will ultimately regulate the chemical to the extent it no longer poses an unreasonable risk.
  • EPA has a wide range of risk management options under TSCA, including labeling, record-keeping or notice requirements, actions to reduce human exposure or environmental release, and a ban on the chemical or of certain uses. 
  • The entire review process for MOCA through Risk Managmenet is estimated to be complete in the 2031-2032 timeframe. 

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 $292,000 of the $1M goal has been pledged to date through the generosity and dedication of several companies. Thank you to everyone who has contributed to the PMA's efforts. 

Check Out Our Contributing Companies
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