Citizen Petition under TSCA Section 21 to Prohibit 6PPD in Tires

The Yurok Tribe, Port Gamble S’Klallam Tribe, and Puyallup Tribe of Indians petition the EPA under TSCA Section 21 to prohibit 6PPD in tires. They argue that 6PPD transforms into 6PPD-quinone (6PPD-q), a highly toxic chemical responsible for 'urban runoff mortality syndrome' in coho salmon and other salmonids. The petition highlights that 6PPD-q is ubiquitous in urban runoff and sediments, threatening species protected under the Endangered Species Act and undermining Tribal cultural and economic interests. It asserts that the EPA must act because the tire industry has not prioritized alternatives and stormwater treatment is insufficient to remove the toxin.

• 6PPD, used since the 1950s or 1960s as an antioxidant and antiozonant in tires, transforms into 6PPD-quinone (6PPD-q), which is identified as the second most toxic chemical to aquatic species ever evaluated by the EPA.
• 6PPD-q causes 'urban runoff mortality syndrome,' which can kill up to 100% of coho salmon returning to spawn in urban streams, and is acutely toxic to other species including rainbow trout, steelhead trout, Chinook salmon, brook trout, and white spotted char.
• The chemical is ubiquitous in the environment, appearing in stormwater runoff, urban watersheds, sediments, soils, road and household dust, and human urine, with evidence suggesting potential hepatotoxicity and adverse immune effects in mammals.
• The use of 6PPD in tires presents an 'unreasonable risk' under TSCA methodology because the predicted environmental concentration (PEC) of 6PPD-q in receiving waters is orders of magnitude higher than the concentration of concern (COC) for coho salmon (calculated as 0.009 µg/L).
• 6PPD-q threatens 23 distinct population segments (DPSs) or evolutionary significant units (ESUs) of coho, steelhead, and Chinook salmon listed as threatened or endangered under the Endangered Species Act (ESA).
• The petition argues that a ban at the source is necessary because current stormwater treatment practices are generally insufficient to remove 6PPD-q and the tire industry has not prioritized finding an alternative to 6PPD.

APA

Earthjustice (2023). Citizen Petition under TSCA Section 21 to Prohibit 6PPD in Tires. https://earthjustice.org/wp-content/uploads/2023/08/tsca-section-21-petition-to-epa-re-6ppd-in-tires.pdf

Chicago

Earthjustice. Citizen Petition under TSCA Section 21 to Prohibit 6PPD in Tires. 2023. https://earthjustice.org/wp-content/uploads/2023/08/tsca-section-21-petition-to-epa-re-6ppd-in-tires.pdf.

Wikipedia

{{cite press release |author=Earthjustice |title=Citizen Petition under TSCA Section 21 to Prohibit 6PPD in Tires |date=1 August 2023 |url=https://earthjustice.org/wp-content/uploads/2023/08/tsca-section-21-petition-to-epa-re-6ppd-in-tires.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{earthjustice2023citizen, author = {{Earthjustice}}, title = {{Citizen Petition under TSCA Section 21 to Prohibit 6PPD in Tires}}, publisher = {Earthjustice}, year = {2023}, month = aug, url = {https://earthjustice.org/wp-content/uploads/2023/08/tsca-section-21-petition-to-epa-re-6ppd-in-tires.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }