The Environmental Protection Agency's (EPA) Workplace
Chemical Protection Program (WCPP) under Section 6 of the Toxic
Substances Control Act (TSCA) has fundamentally changed the
compliance landscape for occupational exposures to certain
chemicals.
For multiple high‑priority substances, the EPA has issued
legally binding occupational exposure limits—Existing
Chemical Exposure Limits (ECELs), and, in some cases, EPA
Short‑Term Exposure Limits (EPA STELs)—that are
significantly more stringent than the Occupational Safety and
Health Administration's (OSHA) long-standing Permissible
Exposure Limits (PELs) and Short‑Term Exposure Limits
(STELs).
Where a WCPP applies, owners and operators must ensure that
exposures do not exceed the EPA's limits, even if they are far
below OSHA's regulatory values. As a result, employers may be
obligated to implement engineering, administrative, and personal
protective equipment controls to achieve exposure levels well
beneath OSHA's
