Posted on January 16, 2026

As the asbestos community moves into the risk‑management phase for Part 2, the path that led EPA to this point tells its own story. What began as a narrow, chrysotile‑only framework under Part 1 became, through years of litigation and advocacy, a legally required Part 2 evaluation that finally addresses legacy uses, all major fiber types, Libby amphiboles, and asbestos‑containing talc. This timeline tracks how ADAO and its allies compelled EPA to broaden its lens, shaped the scope and methodology of Part 2, and are now using those findings to demand robust protections for workers, communities, and future generations.

1. Forcing EPA to do Part 2 (2017–2021)

  • 2017–2019 – Safer Chemicals, Healthy Families v. EPA (Ninth Circuit): ADAO and health allies win a ruling that EPA unlawfully excluded “legacy uses” and “associated disposals” from TSCA risk evaluations, making a supplemental asbestos evaluation (Part 2) legally necessary.​
  • 2018–2020 – ADAO CDR “Right to Know” case: By overturning EPA’s refusal to collect asbestos use/import data under the Chemical Data Reporting rule, ADAO helps expose data gaps that must be addressed for any credible evaluation of legacy asbestos, paving the way for a more robust Part 2.​
  • 2020–2021 – ADAO challenges Part 1 and presses on legacy: ADAO’s petition for review of the Part 1 risk evaluation and its TSCA 60‑day notice over EPA’s failure to evaluate legacy asbestos underscores that a separate, broader Part 2 is required, and ADAO participates in settlement discussions that commit EPA to complete Part 2 by December 1, 2024.​

2. Scoping Part 2: Legacy asbestos and all fibers (2022–2023)

  • June 29, 2022 – EPA issues final scope for Part 2: EPA publishes the final scope for “Risk Evaluation for Asbestos Part 2: Supplemental Evaluation Including Legacy Uses and Associated Disposals,” committing to cover legacy uses, all six AHERA asbestos fibers, Libby amphibole asbestos, and asbestos‑containing talc.​
  • February 28, 2022 – ADAO scoping comments: ADAO files detailed comments strongly supporting a broad Part 2 that implements the 2019 Ninth Circuit decision, urging EPA to: include all fiber types, legacy building materials, contaminated talc, and highly exposed worker and community populations, and to meet the court‑ordered December 1, 2024 deadline.​
  • August 2023 – EPA Part 2 quantitative methods white paper: EPA releases a white paper on the quantitative human‑health approach for Part 2; ADAO engages in review and continues to push EPA to use best available science on fiber potency, exposure scenarios (especially for demolition/renovation), and vulnerable populations.​

3. Draft Part 2 risk evaluation and ADAO’s comments (2024)

  • April 16, 2024 – Draft Risk Evaluation for Asbestos Part 2 published: EPA releases the Draft Part 2 evaluation (legacy uses, associated disposals, all major fiber types, Libby amphibole, asbestos‑containing talc) and opens public comment (docket EPA‑HQ‑OPPT‑2021‑0254).​
  • June 18, 2024 – ADAO formal comments on Draft Part 2: ADAO submits extensive written comments on the draft, supporting EPA’s inclusion of all fiber types and legacy uses but urging stronger treatment of:
    • Workers in demolition, renovation, and maintenance of older buildings.
    • DIY homeowners disturbing legacy asbestos.
    • Communities impacted by disposal, waste sites, and Libby‑related materials.
      ADAO also presses EPA to address uncertainties conservatively and to avoid downplaying risk where monitoring data are sparse.​

4. Final Part 2 risk evaluation (Nov–Dec 2024)

  • November 27, 2024 – EPA releases final Part 2 evaluation: EPA issues the final “Risk Evaluation for Asbestos Part 2: Supplemental Evaluation Including Legacy Uses and Associated Disposals of Asbestos,” just before the consent‑decree deadline, concluding that disturbing and handling asbestos from legacy uses poses an unreasonable risk to human health, while undisturbed asbestos and the environment do not present unreasonable risk.​

5. ADAO’s positioning for Part 2 risk‑management (late 2024–2026)

  • December 2024 – EPA signals next step: Part 2 risk‑management rule: EPA announces it will now begin TSCA Section 6 risk‑management to address unreasonable risks identified in Part 2, including for legacy building materials and asbestos‑containing talc, and previews a future proposed rule.​
  • 2025–2026 – Integrating Part 2 with ADAO’s broader strategy:
    • ADAO uses Part 2’s unreasonable‑risk findings to bolster its arguments in ongoing Part 1 litigation, showing that legacy and ongoing uses together sustain a national asbestos crisis.​
    • ADAO works with Members of Congress to ensure that future Alan Reinstein Ban Asbestos Act language reflects Part 2’s recognition of legacy and talc risks, so that legislation and TSCA risk‑management reinforce each other.​
    • ADAO continues public education on legacy asbestos, using the EPA’s Part 2 conclusions to support calls for improved building inspection, abatement funding, and worker protections.​