Methylene Chloride Compliance Guide

Introduction

In April 2024, the Environmental Protection Agency (EPA) issued a final rule regulating methylene chloride (dichloromethane, DCM, CAS# 75-09-2) under the Toxic Substances Control Act (TSCA). This regulation significantly impacts campus research, facilities, and operations, introducing stringent compliance requirements for laboratories and non-laboratory units.

Laboratories must comply with rigorous new monitoring, recordkeeping, and justification requirements to continue using methylene chloride. 
Non-laboratory units (e.g., facilities, art departments) using this chemical must transition to approved substances.

Required Actions for Compliance

For Laboratories and Research Areas

1. Chemical Inventory: Update inventory records for methylene chloride products.
2. Survey Usage: Complete the usage survey distributed by EHS to justify continued use.
3. Justify Use:
   1. Provide a written justification for continued use if substitutes are unavailable.
   2. Dispose of discontinued stock as hazardous waste.
4. Baseline Monitoring:
   1. Coordinate with EHS to conduct initial air monitoring (note: laboratories and research areas will be financially responsible for all monitoring costs/fees)
   2. Schedule periodic monitoring based on usage and exposure levels (note: laboratories and research areas will be financially responsible for all monitoring costs/fees)
5. Training and Recordkeeping:
   1. Ensure task-specific training is completed and documented.
   2. Maintain training records for at least 5 years.
6. Comply with Workplace Chemical Protection Program (WCPP) Requirements: Fulfill all safety, monitoring, and notification responsibilities outlined by EHS.

For Non-Laboratory Units

1. Chemical Inventory:
   1. Check inventory for products containing 0.1% or more methylene chloride.
   2. Use Safety Data Sheets (SDS) for older products to confirm active ingredients.
2. Waste Disposal: Discard any remaining stocks as hazardous waste.
3. Procurement Policies: Establish procurement practices to prevent future acquisition of methylene chloride products.
4. Training: Ensure all staff entering laboratory or research areas complete required safety training identified by EHS.

Compliance Timeline