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. The ruling prohibits most industrial and commercial uses of the methylene chloride, including in research, laboratory and workspaces. The ruling also creates stringent regulatory procedures and workplace protections while its use is phased out.

Laboratories and research areas 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: initial monitoring will be provided by EHS for free, however laboratories and research areas that require ongoing monitoring to meet the regulation will be financially responsible for those 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