On August 20, 2025, the Occupational Safety and Health Administration (OSHA) extended the comment period on their recent proposals to amend many of their substance-specific standards from September 2 to November 1, 2025. According to OSHA, the updated rulemakings would better align substance-specific requirements with the Respiratory Protection Standard [29 CFR 1910.134], and would remove duplicative obligations without compromising employee safety.
Of the OSHA substance-specific standards affected by these changes, the one that is often the most directly relevant to our clients is the Methylene Chloride (MC) Standard [29 CFR 1910.1052].
The proposed revisions to the MC rule are intended to provide greater compliance flexibility and remove duplicative language as it relates to the Respiratory Protection Standard. They also include two technical corrections. The recommended changes are summarized below.
- In the various sections of the MC Standard that address general respiratory protection requirements [29 CFR 1910.1052 (g)(1)(i) through (v)], the duplicative provisions on when respirators must be provided and used are removed and a cross reference to the appropriate section of the Respiratory Protection Standard is added.
- The requirement for employers to provide employees with full facepiece respiratory protection because methylene chloride may cause eye irritation or damage [29 CFR 1910.1052 (g)(3)(i)] is removed, and an allowance for the use of half mask respirators is included if adequate eye protection is provided.
- The medical evaluation requirements [29 CFR 1910.1052(g)(4)] are removed since under section (g)(2)(i) of the Standard, employers already have to comply with the more comprehensive medical evaluation requirements of the Respiratory Protection Standard.
- Two technical corrections are being proposed; both address improper citations. The first replaces an incorrect reference on respirator selection criteria in the MC Standard [29 CFR 1910.1052(e)(3)] to paragraph (h)(3), rather than section (g)(3) of the Regulation. The second corrects a typo in 29 CFR 1910.1052(g)(2)(i), which requires that employers implement a Respiratory Protection Program in accordance with 29 CFR 1910.13(b) instead of 29 CFR 1910.134(b).
OSHA is also considering, but not officially proposing, removing limiting employers to the use of atmosphere supplying respirators [29 CFR 1910.134(g)(3)(i)]. They state that the Agency recognizes that, at this time, there are no other available options for protection from methylene chloride. However, because technology is constantly evolving, alternative equipment with equivalent protections may be available for future use. Because of this, OSHA is interested in comments addressing how they could word this provision to allow for greater flexibility as technology changes.
Based on OSHA’s evaluation, the recommended changes would increase compliance options with the MC Standard without reducing worker protections. Comments can be made on the revisions by following this link. The Agency will also be announcing details on informal public hearings about the proposed updates in the Federal Register.
For additional information on the recommended revisions, or for help developing and implementing a Methylene Chloride Worker Protection Program and/or a Respiratory Protection Program—contact us!
This blog was written by Beth Graham, Safety Partners’ Director of Quality, Research, and Training.
