Minutes for November 14, 2025 Meeting of the Administrative Council on Toxics Use Reduction

Attendees

Council Members Attending (attendance taken by roll call):

• Stephanie Cooper, Executive Office of Energy and Environmental Affairs (EEA)
• Greg Cooper, Department of Environmental Protection (DEP)
• Michael Flanagan, Department of Labor Standards (DLS)
• Jacob Nunnemacher, Department of Fire Services (DFS)
• Kris Callahan, Department of Public Health (DPH)
• Layla D’Emilia, Executive Office of Economic Development (EOED) Office of Consumer Affairs and Business Regulation

Meeting Attendees (recorded by participant list):

• EEA: Read Porter
• DEP: Lynn Cain, Leoni Desai, Rebecca Dolan, Megan Keene, Lillian Zemba
• OTA: Caredwen Foley, Kari Sasportas, Tiffany Skogstrom
• TURI: Colin Hannahan, Hayley Hudson, Heather Tenney, David Turcotte

Other attendees:

• Al Vega, MassCOSH
• Anastasia Swearingen
• Aron Pollard
• Bob Rio
• Carol Holahan
• Christine
• DSelechnik
• Elise Pechter
• Hannah Alleman
• Hotze Wijnja
• Julie Ownbey, Arxada
• Karen Blood
• L Dreilinger
• Laura Spark
• Ligia Duarte Iler
• Liz Harriman
• Meg Blanchet, DPH
• Michelle Lopez Kopa
• Nicholas Georges, HCPA
• Theresah

Welcome and Introductions

Council members were identified by roll call.

The Executive Director described the format for questions and discussion.

Vote to Approve May 21, 2025 Meeting Minutes

The Chair welcomed members and attendees. The minutes from the May 21 meeting were unanimously approved.

Presentation of Response to Comments on the proposed Quaternary Ammonium Compound (QAC) substance category of Didecyl Dimethyl Ammonium Chloride (DDAC) and Alkyl Dimethyl Benzyl Ammonium Chloride (ADBAC) addition to the TURA List

Overview

The Chair invited the Executive Director to present a summary of the response to comments on the proposed QAC category addition to the TURA List.

The Executive Director described the public comment period from July 3 to September 12, 2025, and the July 25 public hearing and presented comments opposed and comments in favor of the proposed regulations.

Topics raised by commenters opposed to the amendment are described below, along with the program’s responses.

Comments Opposed: Policy Considerations

• Beneficial uses of QACs and potential adverse effects on use in necessary settings. Program response is that TURA does not ban chemicals, that healthcare and non-manufacturing food sectors are not covered under TURA, that listing encourages toxics use reduction and provides visibility into chemical use, and that a listing will allow the TURA Program to offer additional training on safe use.
• Alternatives may not be as effective, suitable for all applications, or may have their own hazards. Program response is that listings are based on intrinsic hazard, not comparison to alternatives; that alternatives assessment is offered as a service by the program, and that listing can encourage the development of new, safer alternatives.

A member asked for clarification about the alternatives identified in the policy analysis. The Executive Director clarified that the policy analysis includes information on alternatives but that not all alternatives are suitable for all applications, and that a TURA listing would not inhibit the use of QACs in healthcare or food service settings. Program staff also noted that effectiveness depends on the surface and what is being sanitized, and that the TURI lab can assist with identifying feasible options for specific applications.

A member asked for clarification about healthcare and food service not being covered. The Executive Director clarified that healthcare and food service would not be covered, but that food manufacturers would be covered if they have ten or more employees and are using over the reporting threshold. The member noted that it doesn’t cover those outside the SIC code, regardless of volume used, and asked if businesses outside the SIC code or using smaller quantities are eligible for TUR assistance. The Executive Director confirmed that OTA and TURI are set up to serve all toxics users.

• The policy analysis does not include a risk assessment weighing the benefits of QAC use, nor did it compare risk assessments of QACs and alternatives. Program response is that the TURA Program does not conduct risk assessments, since listings are based on hazard and not risk.
• Safety issues with QACs are the result of inappropriate use, that workers are familiar with QACs and generally use them appropriately, and that the theoretical dangers should be weighed against the real public health benefits. Program response is that listing is based on intrinsic hazard, even in case of misuse or accidents. Program experience is that products are often not used as directed. QACs are frequently associated with work-related illness – these hazards are not theoretical and result in documented injury, and likely many more cases that go unreported.

A member asked whether listing would assist this, and whether alternatives would be any better. The Executive Director noted that the TURI Cleaning Lab assists companies with worker education, that TURI has spent a lot of time on trainings related to the hazards of QACs, and that a listing would allow TURI to conduct more training and customize them better to the needs of users. Program staff added that the lab teaches proper cleaning in advance of proper disinfection as well, and the importance of factors, such as product dwell time, to ensure that users don’t incur the hazards without even achieving disinfection. TURI education includes minimizing chemical use and using the safest chemicals possible to achieve desired result.

• QACs are already subject to sufficient regulatory oversight (FIFRA, MDAR, FQPA). Program response is that TURA’s requirements are different from those of other entities, and TURA is the only law that requires TUR planning. Many disinfectants and pesticides are already on the TURA list, and listing would not prevent any entity from their continued use.
• Other regulatory action should be taken instead, especially by occupational health authorities. Program response is that TURA listing would complement actions by other bodies, and would result in reductions in covered sectors, and can encourage reductions in non-filers as well. The Administrative Council’s role includes coordinating action in their respective agencies to promote TUR. In addition, TURA requires employee notification in advance of TUR planning. This causes companies to engage with their workers, who often have insight into ways to reduce use and waste, and brings personnel together to collaborate on TUR across the workforce.
• Listing would place administrative and financial burden on manufacturers without reducing demand. Program response is that listing requires no capital investment and would only entail a $1,100 per-chemical fee for a manufacturer, that the 3-10 estimated affected filers are already believed to be TURA filers who already employ TUR planners. TUR requirements benefit filers because it encourages responsible use and plugs companies into program assistance with TUR, and can result in financial savings for companies. This listing would also enable the program to expand its education efforts on safer use.

Comments Opposed: Scientific Considerations

• The database of guideline studies supporting ADBAC/DDAC registration substantiates their safety. Program response is that the TURA Science Advisory Board (SAB) reviewed available high-quality data, including the guideline studies. The SAB solicited input and heard presentations from stakeholders, including industry.  The SAB identified respiratory system irritation and inflammation, including outcomes consistent with occupational asthma and work-exacerbated asthma; corrosive effects; aquatic life hazards; and environmental fate and persistence.
• QACs do not conclusively produce new-onset asthma; QACs are irritants and not sensitizers, and respiratory endpoints may be caused by other factors. The SAB identified evidence revealing QAC effects on, or exacerbation of, asthma, pulmonary fibrosis, respiratory sensitization, or irritation.
• QACs are readily biodegradable, adsorbing to sediment and not accumulating in water. Program response is that QACs persist in soil and sediment, wastewater sludge, and vegetables following land application.
• Lack of evidence for endocrine, reproductive or developmental toxicity; no hazardous degradation products, and dermal irritants only at high concentrations. Program response is that these endpoints were not the basis of the SAB recommendation. In addition, many users encounter these products in concentrated form, and listings are based on hazard.
• There is no evidence of distant cellular changes and the mechanism of distant effects is secondary to the initial irritation. Program response is that whether endpoints are primary or secondary, the SAB relies on the presence of the effects in vivo.

Next, the Executive Director shared comments in favor of the proposed listing.

Comments in Favor: Policy Considerations

• Toxics use reduction has economic and organizational benefits for companies
• Availability of alternatives:
  • For many uses, safer alternatives are already available
  • For applications without safer alternatives, listing produces incentives to develop and adopt new ones
• Listing creates an opportunity for the program to address occupational and consumer overuse and misuse through worker education
• Listing helps alleviate the ‘hygiene theatre' perception that over-sanitization is always necessary to protect public health
• Science Advisory Board review was thorough and included ample public participation
• The community has the right to know about chemical use
• QACs present disproportionate harm to vulnerable and susceptible communities (e.g., children; janitorial workers)
• Regulating QACs is consistent with actions of other jurisdictions:
• Inclusion of QACs in the California Biomonitoring Program
• EU prohibitions in specific product categories
• QACs not included on EPA Safer Chemical Ingredients List

Comments in Favor: Scientific Considerations

Occupational health:

• Classification of ADBAC and DDAC as respiratory sensitizers and asthmagens by Association of Occupational and Environmental Clinics
• Epidemiological studies, including multistate surveillance data, associate cleaning and disinfecting products with work-related asthma
• Increased risk of COPD in workers exposed to ADBAC and DDAC products
• Reduction in concentration of QACs is insufficient to protect against sensitization effects

Non-occupational health endpoints:

• Respiratory toxicity
  • Sprayed QACs contribute to reduced lung function
• Reproductive and developmental effects observed in animals, including decreased female and male fertility and neural tube defects
• New research reveals additional hazards:
  • Evidence of neurotoxicity, such as disruptions in oligodendrocyte production
  • Disruption of the gut microbiome
  • Exposure to DDAC accelerates transfer of antimicrobial resistance genes
• QACs are present at detectable levels in blood and breast milk and are ubiquitous in human serum samples

Environmental fate and transport:

• High aquatic toxicity of ADBAC and DDAC
  • Typical environmental concentrations damage fish gills
  • Algae and invertebrates, including indicator species, are harmed by very low concentrations
• Environmental persistence: Cations bind to biomass and sediments
• Adverse effects on wastewater treatment
  • Presence in sediments inhibits microbes needed for nitrogen cycling
  • QACs persist through wastewater treatment and are then released to the environment
• Indoor and outdoor persistence

Discussion

Council Member Discussion

A member noted that one of the key aspects is misuse, and that the program should undertake a robust effort to educate users of the product that, if they’re going to use them, they must use them as directed.

The Executive Director stated that every time a chemical is added to the TURA list, the program conducts a broad outreach effort to manufacturers within TURA SIC codes, including efforts at direct contact with potential filers. TURI also offers events and trainings to reach a broader audience, including covering the topic at TUR planner conferences. The Chair stated that there might be opportunity to expand on outreach about safer cleaning and disinfection among users who are not  required to file, such as entities like hospitals and food service. The employee notification requirements under TURA engages workers who are using the products directly, which both solicits ideas from workers and also enables the TURA Program to partner with companies to educate workers about safe use.

A member asked whether TURA is limited by SIC codes in its outreach, and whether the program’s reach can include hospitals, restaurants, etc. The Executive Director clarified that OTA has done a lot of site visits in hospitals and universities and labs, which aren’t covered by TURA outreach, and can adapt trainings to non-TURA-covered sectors, perhaps with the support of Administrative Council members. The member noted that only 3 to 11 filers are expected to be covered, but that use is much higher outside of TURA SIC codes. The Chair stated that we could expand traditional outreach and could also reach out to hospital and restaurant associations, etc. Program staff also stated that OTA has partnerships with local boards of health, which provides an avenue for outreach and education to local food service establishments.

The Chair invited the DPH representative on the Board to say more about the DPH Occupational Health Surveillance Program. The member stated that DPH is having some internal meetings about this, but there are no updates at the moment. The Executive Director noted that she and another Council member both serve on the OHSP Advisory Board.

Attendee Discussion

An attendee lauded the program for drawing attention to this issue, noting that many workers in cleaning, education, childcare, and healthcare settings have limited English proficiency, and that these workers are at high risk of exposure. Encouraging alternatives and encouraging companies to reduce use and invest in alternatives protects worker health. While plenty of companies encourage PPE use, we know that PPE is often used improperly and workers are not trained adequately to be as safe as possible. Trainings are often not even prioritized or offered in the languages workers understand. Cost always comes up – workers should be able to have the safest work environments. Companies sometimes look for the lowest cost option, but they also need to think about long-term costs such as worker’s compensation and disability costs. Encouraging safer alternatives is the way to go.

An attendee appreciated public engagement on this topic, and noted that in the response to comments, the program is focused only on the SIC codes covered by TURA, and that the program only focuses on hazard, not risk. The attendee stated that these products have clear benefits and there’s a reason that these products are used and need to be used for certain pathogens. The attendee asked whether the program will discuss efficacy in its outreach and trainings, in order to continue to promote public health. These products work when used as directed and we encourage worker training and engagement. Bilingual labeling is being rolled out under new federal legislation. 

The Executive Director responded that this program would not risk public health or discourage use when needed, because a TURA listing is not a ban. A listing would simply put QACs on the radar for when there are safer alternatives. Program staff stated that TURI’s cleaning lab considers safer cleaning and disinfection, and considers efficacy. Staff also pointed out that companies are never required to implement TUR options -- they are required only to plan for TUR. This is true for any TURA listing, and QACs would be no different. Alternatives are always dependent on the specific application, including the substrate being cleaned and what it’s being cleaned or disinfected for.

Conclusion

The Chair thanked members and attendees for the discussion, and stated that the program wishes to be thorough in its review of this proposed listing.

The Executive Director reiterated the requirements TURA places on filers: annual reporting and fees, and biennial TUR planning, which would likely amount to only the $1,100 per chemical fee applying to the 3 to 10 estimated affected filers, plus the marginal addition of QACs to the existing TUR planning and reporting processes these filers undertake.

The Executive Director then thanked the Administrative Council, SAB, Advisory Committee, the TURA Program staff, and all attendees and commenters.

TURA Program Update

The Executive Director provided an update on program activities, including the open public health seat on the Advisory Committee and TRI additions to the TURA List.

TURI staff offered updates on the selection of David Turcotte as the new Interim Director at TURI; upcoming training events, Science Advisory Board activities, TURI Lab activities, a recent EPA grant, and TURI industry and community grants.

OTA staff offered updates on new projects, including tabletop exercises for chemical safety and climate change resiliency, updates to its GIS maps, recent updates to OTA’s Right From The Start program for new and expanding businesses, and updates to OTA’s website, including its case studies, fact sheets, and the Massachusetts Clean Auto Repair Guide. OTA also provided a staffing update.

DEP staff provided updates on staffing, Reporting Year 2024 reports and data, enforcement activities, preparations for Reporting Year 2025, and an update on TRI.

The Chair invited any final questions or comments; none were offered.

Adjourn

The Executive Director invited input following the meeting and thanked participants. Meeting adjourned.