In a final rule published in the Federal Register on November 13, 2025, the Environmental Protection Agency (EPA) extended compliance dates by 18 months for non-federal laboratories. This update aligns with the requirements for federal laboratories and their contractors in the original risk management rule for methylene chloride (MC) published in 2024.
The new compliance dates for non-federal labs are as follows:
- Initial exposure monitoring: from May 5, 2025 to November 9, 2026.
- Establishment of regulated areas and EPA exposure limit compliance: from August 1, 2025 to February 8, 2027.
- Development of an Exposure Control Plan (ECP) and implementation of Workplace Chemical Protection Program (WCPP) compliance measures: from October 30, 2025 to May 10, 2027.
According to the EPA, the compliance date amendments were made “in order to ensure long-term compliance with the rule’s requirements.” The Agency notes that the date extensions address other concerns for laboratories including:
- Having sufficient time to choose a different, less toxic solvent when performing analytical analyses, especially testing that must be performed in accordance with specified methods.
- Avoiding disruption of important functions such as the use of environmental monitoring methods needed for cleanup sites and wastewater treatment, as well as activities associated with both university research and law enforcement laboratories.
- Having adequate time to plan, schedule, and secure resources to cover the cost of industrial hygiene personnel to conduct initial exposure monitoring.
Per the EPA, the amended rule will help minimize confusion in administering it, by aligning with the compliance dates that were already established for federal agencies.
Many laboratories have already met the original 2025 deadlines, so the extension will have minimal impact. It is strongly recommended that these labs continue to maintain their compliance status. However, if your facility has not implemented all the requirements of the 2024 EPA MC regulation, you now have more time to become compliant!
While the EPA has stated that it will prioritize enforcement based on the new dates, it retains the authority to intervene sooner if they determine that there are significant threats to human health and/or cases of immediate danger resulting from MC use.
More information on EPA’s risk management rule is available in our March 7, 2025 EPA Methylene Chloride Rule – What You Need to Know blog. Contact us if you have any questions or need help with MC regulation implementation at your facility.
This blog was written by Beth Graham, Safety Partners’ Director of Quality, Research, and Training.
