With the May 5, 2025 sampling deadline approaching, we wanted to follow up on our May 2024 blog post EPA Finalizes Ban on Methylene Chloride Use and provide more details on the requirements and timeline. If your facility uses or stores methylene chloride, please read on.
Methylene chloride (MC, aka dichloromethane or DCM) is an OSHA regulated chemical with a dedicated standard, 29 CFR 1910.1052. The Environmental Protection Agency (EPA) has finalized a rule under TSCA (40 CFR Part 751) to regulate MC due to its hazardous, carcinogenic nature. The ban primarily targets manufacturing and processing for consumer, commercial, and many industrial uses, but excludes laboratory use.
Laboratories using MC must adhere to the EPA’s required Workplace Chemical Protection Program (WCPP) and demonstrate a need for continued use following the hierarchy of controls shown below.
Your company will need to assess its use of MC and determine how to proceed as follows:
Program Deadlines
If you will be implementing a program for MC, please be aware of the following deadlines:
Program Requirements
- Scope: The rule applies to “all potentially exposed persons,” including contractors and visitors in addition to employees. When evaluating MC exposure potential, consider all persons in areas where it is being used.
- Initial and periodic exposure monitoring: Demonstrate exposure is below regulatory limits by sampling or providing objective data (we always recommend sampling).
- Controls: Implement additional engineering controls, administrative controls, and personal protective equipment (PPE) as necessary to ensure EPA exposure limits are met. Note: nitrile gloves are unsuitable for MC – polyvinyl alcohol or viton are a better choice.
- Documentation: Develop a Workplace Chemical Protection Program and Exposure Control Plan specific to MC use (note: this Exposure Control Plan is different from the OSHA Bloodborne Pathogens Standard Exposure Control Plan). Documentation must include a justification for MC usage and demonstrate no viable alternatives.
- Designate regulated areas: Any areas where MC exposure limit exceedances may occur require signage and a Respiratory Protection Program. Note that only an atmosphere-supplying respirator like an SCBA is acceptable for respiratory protection, as air-purifying filters cannot capture MC.
- Training: Ensure all employees, contractors, and visitors receive awareness training, and those working with MC receive process-specific training.
Safety Partners can assist with documentation, training, and sampling to ensure compliance. Contact us if you have any questions or need help with MC regulation implementation at your facility.
This blog was written by Karen Yurek, a Principal Consulting Safety Officer who has been at Safety Partners for 12 years.
