What Asphalt Labs Must Do to Comply With the TCE Ban

If your organization relies on trichloroethylene (TCE) for asphalt tests, the immediate priorities are these:

• Implement the required workplace chemical protection program (WCPP) and exposure controls now, keeping in mind the TCE rule’s Workplace Chemical Protection Limit (WCPL) states airborne exposure cannot exceed 0.005 ppm (over 8 hours).
• Begin validating alternatives or engineering controls (especially to avoid manual centrifuge uses before December 2029).
• Track state DOT or state environmental guidance (states may add additional requirements or timelines).

At this time. Start by confirming that your lab’s use of TCE falls under “laboratory chemical for asphalt testing and recovery,” then assess your equipment. Identify all equipment and methods using TCE, such as centrifuges, vacuum recovery, asphalt binder extraction, etc.

Also assign a responsible official or Chemical Hygiene Officer to oversee your TCE phase-out and worker-protection compliance.

When implementing your WCPP, develop and maintain written records that cover:

• Engineering controls (fume hoods, closed-loop extraction systems, solvent recovery enclosures);
• Administrative controls (restricted access, time limits, cleaning schedules);
• PPE program (respirators with organic vapor cartridges, gloves, chemical-resistant lab coats);
• Exposure monitoring and medical surveillance; and
• Recordkeeping (SDSs, exposure logs, training records).

By December 2029. Discontinue TCE use in manual centrifuges for asphalt recovery. Replace it with closed-loop or automated extraction systems using alternate solvents (like those approved in ASTM D8159). Make sure you document your conversion or discontinuation.

By December 2034. All TCE use for asphalt testing and recovery must end. Identify and validate alternative solvents or solvent-free recovery methods. Validate new methods through ASTM or AASHTO standards and your client/state DOT specs. And make sure you document it all. Maintain records of solvent substitution testing and approvals, notifications to clients or DOTs about method changes, and all equipment modification and/or decommissioning.

As every good lab should do, follow your ongoing best practices, too.

• Keep up with your emergency procedures: Maintain spill kits, eyewash stations, and first-aid plans specific to chlorinated solvents.
• Double-check your ventilation systems: Inspect and certify hoods or local exhaust every six months.
• Manage waste: Dispose of TCE waste as RCRA hazardous waste (F002 listing).
• Communicate: Ensure vendors are aware of the EPA ban timelines. 

Read next: Navigating the EPA’s TCE Phase‑Out for Asphalt Labs