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EPA Releases Peer Reviewer Comments on Draft Risk Evaluation for Flame Retardant TCEP

Released April 30, 2024

The U.S. Environmental Protection Agency (EPA) has released comments from the letter peer review for its draft risk evaluation for the flame retardant Tris(2-chloroethyl) phosphate (TCEP). EPA will use these comments to help inform the final risk evaluation. 

EPA released the draft risk evaluation for TCEP for public comment in December 2023 and the letter peer review began in March 2024. TCEP is a chemical historically used in paints and coatings, aerospace applications, fabrics and textiles, foam seating and construction materials, and is also found in a range of goods that are imported into the U.S. Although U.S. production of TCEP has decreased by about 99 percent since 2014, it is still used in the U.S. to make some paints and coatings, and is also used as a flame retardant and plasticizer for specific aerospace applications. TCEP has been linked to kidney cancer, as well as reproductive, neurological, developmental and kidney effects. 

EPA’s draft risk evaluation proposed to find unreasonable risk to human health from breathing or ingesting TCEP that comes out of textiles or other products and gets into indoor air. Infants and children may be at risk if they frequently mouth products containing foam, textiles or wood that contain TCEP for long periods of time, which may prove to be conservative assumptions that do not reflect real-world exposures. TCEP can also accumulate in fish if they live in a stream or other waterbody with high concentrations of TCEP. EPA found unreasonable risk for people eating fish taken from TCEP-contaminated water. These concerns are particularly notable for groups that eat higher quantities of fish, such as subsistence fishers and Tribes. 

EPA proposed to find that TCEP poses unreasonable risk to the environment, specifically to aquatic organisms chronically exposed to TCEP through surface water and sediment. 

EPA used a letter peer review to obtain comments on the TCEP draft risk evaluation. As stated in EPA’s Peer Review Handbook, “a letter review takes place when EPA seeks individual written peer review comments from independent experts, typically in the form of correspondence to EPA from the peer reviewer… Each reviewer evaluates the draft technical work product independently without consultation with other reviewers. No collaborative or consensus peer review report is developed.” When EPA undertakes a letter peer review, it takes steps to ensure that letter peer reviewers only provide comments as individuals without consultation or conversation with other reviewers because such consultations or conversations could be subject to the Federal Advisory Committee Act. 

For additional information, please contact Dr. Alaa Kamel, Peer Review Leader, kamel.alaa@epa.gov.

View the peer reviewer comments.

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Last updated on May 14, 2025
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