EtO Public Comment Guide

The Union of Concerned Scientists (UCS) published this guide to help the public influence the EPA's proposed rule on ethylene oxide (EtO) emissions from commercial sterilizers. The guide argues that while the proposal is a positive step—potentially reducing emissions by 80%—it contains significant gaps regarding cumulative health risks, fenceline monitoring, and the regulation of off-site warehouses. It urges commenters to support the use of the 2016 IRIS risk assessment, demand continuous emissions monitoring systems (CEMS), and call for a faster compliance timeline than the proposed 18 months. The document also highlights environmental justice concerns, noting that people of color and low-income communities are disproportionately located near these facilities.

• The EPA's proposed rule aims to reduce ethylene oxide (EtO) emissions from commercial sterilization facilities by 80% and affirms the use of the 2016 risk assessment, which found EtO to be up to 60 times more toxic than previously understood.
• UCS analysis indicates that nearly 14 million people live within five miles of a commercial sterilization facility, with cancer risks from toxic air pollutants being nearly three times higher in census tracts containing such facilities compared to the US average.
• The proposed rule is criticized for failing to require fenceline monitoring and for not covering off-site warehouses, which can act as "secondary off-gassing rooms" and emit significant uncontrolled EtO.
• The EPA's residual risk assessment is argued to underestimate public health risks because it uses actual reported emissions instead of allowable emissions and does not account for cumulative impacts from other carcinogenic hazardous air pollutants (HAPs) or social stressors.
• The guide advocates for the replacement of annual compliance demonstrations with continuous emissions monitoring systems (CEMS) and the removal of the startup, shutdown, and malfunction (SSM) loophole, which is described as a "free pass to pollute."
• There is a call for the EPA to expedite the compliance timeline to be faster than the proposed 18 months and to proactively communicate risks in Spanish and other languages, particularly for communities in Puerto Rico and Latine communities in the US.

APA

Union of Concerned Scientists (2023). EtO Public Comment Guide. https://www.ucs.org/resources/eto-public-comment-guide

Chicago

Union of Concerned Scientists. EtO Public Comment Guide. 2023. https://www.ucs.org/resources/eto-public-comment-guide.

Wikipedia

{{cite report |author=Union of Concerned Scientists |title=EtO Public Comment Guide |date=15 May 2023 |url=https://www.ucs.org/resources/eto-public-comment-guide |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{unionofconcernedscientists2023eto, author = {{Union of Concerned Scientists}}, title = {{EtO Public Comment Guide}}, institution = {Union of Concerned Scientists}, year = {2023}, month = may, url = {https://www.ucs.org/resources/eto-public-comment-guide}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }